*Purpose: The 12/17/19 CMS proposed rule revises outcome measures for OPOs using CDC Multiple Cause of Death to determine donation potential defined as the number of inpatient deaths less than 76 years without an absolute contraindication cause of death (COD). We report COD and donor eligibility determination based on Death Certificates (DC) against hospital data collected by the OPO. The purpose is to examine the COD concurrence between DC and OPO Electronic Medical Record (OPO EMR) and secondly to compare estimated donor potential against True Potential (TP) as determined by the OPO in real time disposition of donor referrals.

*Methods: In patient deaths from a single Level I Trauma center for a 3 month period were examined using 2 data sources. Death certificate data were compared to OPO EMR data. A final analysis applied OPO evaluation of clinical exclusion characteristics to determine donor True Potential. The Death Certificate report template captures narrative description of immediate cause of death and up to three underlying cause of death descriptions. Qualitative review classified records to ICD10 categories and exclusions of diagnostic categories. The second data source was OPO EMR records. Finally, clinical evaluation to determine True Donor Potential, defined as:

*Results: Death Certificates and OPO EMR records revealed strong consistency in total deaths, by age and with no exclusions. Total donor potential using the CMS proposed definition yielded 77 and 72 cases using Death Certificate and OPO EMR data sources, resulting in a donor potential of 55% and 52% of total reported deaths. Application of True Donor Potential classification reduced the number of potential donors to 14. Of the 72 potential donors using Death Certificate diagnoses 25 were eliminated due to lack of ventilatory support and 33 were excluded due to other medical criteria. Resulting in an overall rate of 10% of all deaths (14/140).

*Conclusions: Death certificate files may provide an overall estimate of donation potential and serve as an initial review to assess donor potential. However, diagnostic detail is insufficient to assess true donation potential. Further study is called for to examine the concurrence of Death Certificate data with individual OPO level determination of donor potential

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