Policy Rewrite Parking Lot Quick Fixes Policy Oversight Committee (POC) Fall 2014
The Problem OPTN Policies Plain Language Rewrite (effective Feb. 1, 2014) Rewrite did not address substantive changes “Parking Lot” contains substantive changes we still need to address In 2013 the POC sponsored the OPTN Policies Plain Language Rewrite, which became effective February 1, 2014. This proposal identifies the “quick fixes” or easy, non-controversial changes that are currently in the rewrite parking lot and offers the corrected policy language to further clarify the OPTN Policies. Many of the items in the parking lot came from OPTN members who responded during the rewrite’s public comment period. During the rewrite, reviewers identified a number of issues that would require substantive changes to the polices; these issues were recorded in the rewrite “parking lot” to be addressed in the future
Goal of the Proposal Clarify and increase policy readability & consistency Identify potential non-controversial changes that will increase usability Increase understanding of actual policy requirements vs. recommendations
How the Proposal will Achieve its Goal Identify quick fixes from the “parking lot” Circulate proposed changes to the relevant Committees UNOS staff and POC address comments and concerns about proposed changes Staff and OPTN/UNOS Committees identified the easy to fix changes that had been stored in the parking lot. Although we’ve identified “easy” fixes, the parking lot still has a number of identified issues that the appropriate committees will address in separate projects. These projects will allow for input and collaboration with all the appropriate stakeholders. For example, the parking lot includes a number of comments and concerns about the deceased donor requirements in Policy 2, but these are being addressed as a separate project by the OPO Committee because they are too complex to include here. There are numerous items like this in the parking lot that are best addressed by the appropriate Committee, with input from the appropriate stakeholders. Their comments and concerns were discussed and addressed by staff and the POC before including them in this proposal.
How the Proposal will Achieve its Goal Changed “shoulds” to “must” for true policy requirements Standardized time periods (days rather than weeks or months) Streamlined administrative rules and definitions (deleted duplicate definitions) More consistently used common policy terms (ex: transplant hospital versus center) Deleted outdated or superfluous sections Made minor clerical and punctuation changes These bullets are the types of changes we proposed. The POC welcomes your feedback on whether the proposed language is more easily understood and whether these substantive changes are appropriate. In particular, we want to know what you think about the sections of policies where “should” was changed to “must” and therefore are now requirements rather than recommendations. All of these sections are clearly identified in the POC’s public comment proposal, with proposed modifications beginning on page XX.
What Members will Need to Do Become familiar with new policy language once it is effective Board review – June 2015 If approved, effective date is Sept. 1, 2015 Proposal doesn’t change current routine compliance monitoring Members are expected to maintain documentation of data entered in UNet and provide documentation upon request Transplant programs, OPOs, and histocompatibility labs will need to familiarize themselves with this new policy language once it becomes effective If the board approves the proposal, the effective date is Sept. 1 2015 and most importantly, it does not involve any change to how we currently monitor members’ compliance with policy.
Questions? Yolanda Becker, MD Chair, Policy Oversight Committee ybecker@surgery.bsd.uchicago.edu Leigh A. Kades, MA Liaison, Policy Oversight Committee leigh.kades@unos.org