Consequences of Organ Procurement Reform

12/01/2025
Summary of working paper 34140
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This figure consists of two side-by-side line charts titled "Kidney Recoveries and Transplants following Organ Procurement Reform" showing the impact of organ procurement reform on organ recovery and transplantation rates. The y-axis for both panels shows organs recovered or transplanted monthly per Organ Procurement Organization, ranging from 10 to 50. The x-axis for both panels shows years from 2013 to 2025. The figure includes blue lines representing kidneys and red lines representing other organs in both panels. A vertical dashed line marks the year of organ procurement reform in both panels. The left panel shows organs recovered monthly per Organ Procurement Organization. Kidney recoveries increased from approximately 20-22 organs per month in 2013 to nearly 50 organs per month by 2024, with the steepest increase occurring after the reform year marked by the dashed line. Other organs increased from approximately 18-20 to about 38 organs per month over the same period.  The right panel shows organs transplanted monthly per Organ Procurement Organization. Kidney transplants increased from approximately 15-17 organs per month in 2013 to about 33-35 organs per month by 2024. Other organ transplants increased from approximately 17-19 to about 32-35 organs per month. Both kidney and other organ transplants show steady growth throughout the period, with continued increases after the reform year. The source line reads: Researchers' calculations using data from the United Network for Organ Sharing and various other sources.
 

In 2019, the United States introduced new regulations for Organ Procurement Organizations (OPOs) designed to increase transparency and accountability in the organ donation system. These changes included stronger performance incentives aimed at improving outcomes in a sector that handles over 45,000 transplants annually and manages a waiting list of more than 100,000 patients. In Economic Incentives and Organ Procurement: Evidence from a US Reform (NBER Working Paper 34140), Erkut Y. OzbayAriel RavaSergio S. Urzúa, and Emanuel Zur examine the impact of this reform on organ donations, transplant activity, and system costs.

A 2019 US reform of Organ Procurement Organizations increased kidney recoveries by 29 percent and resulted in an estimated $359 million in fiscal savings.

The reform replaced inconsistent, self-reported performance metrics with standardized, independently verified measures. Currently, the 56 OPOs operating across the United States hold monopolistic rights within their designated service areas to recover donor organs from the deceased. The reform introduced a three-tier performance ranking system that automatically recertifies high-performing OPOs, while lower-performing organizations face intensified oversight or potential decertification. 

Using comprehensive data from Freedom of Information Act requests and official transplant records from 2015 to 2024, the researchers compare kidney procurement with that of other organs. Because Medicare provides full reimbursement for kidney procurement costs, the OPOs have strong financial incentives to prioritize kidney recovery over recovery of other organs.

After the reform, the average number of kidneys procured per OPO per month increased by just over 7, a nearly 30 percent increase relative to the pre-reform baseline of about 25. However, only 39 percent of these newly recovered kidneys were transplanted, compared to 81 percent prior to the reform, suggesting that financial incentives drove procurement activity even when transplant outcomes were uncertain.

The reform's impact varied across OPO performance tiers. Mid-performing OPOs showed the largest increases with 8.7 additional kidneys per month, compared to 7.4 for top-performing and 6.0 for low-performing OPOs. The increased organ recovery came primarily from strengthening relationships with hospitals that had only occasional pre-reform interactions with OPOs, rather than establishing entirely new partnerships.

Increased procurement came with higher costs. Total kidney-related procurement costs rose by an average of $2.63 million per OPO per year. The researchers estimate that between January 2019 and September 2024, the reform generated approximately $1.96 billion in reduced aggregate dialysis costs. After accounting for increased OPO operational spending, they calculate net savings of roughly $359 million to US taxpayers through 2023.

While the reform, along with Medicare’s guaranteed reimbursement for kidney procurement, increased organ procurement and generated fiscal benefits, the researchers note that it may also have led to resource concentration on kidneys at the potential expense of other organs, like hearts, livers, and lungs, which have shorter viability windows and face more complex reimbursement structures.

                                                                                                                                    - Abby Hiller