*Purpose: CMS has proposed a rule change to re-define the OPO donation metric, using CDC inpatient death data to calculate: # of donors/1,000 inpatient deaths from causes consistent with donation among patients <75 years of age. Concerns have been raised that this metric does not account for rates of ventilation or co-morbidities.

*Methods: We estimated OPO-level donation rates using CDC data, and used AHRQ/HCUP data from 43 State Inpatient Databases (SIDs) to determine whether adjusting for statewide rates of ventilation, cancer, and severe sepsis among inpatient deaths impacted the among-OPO comparisons using the CMS metric.

*Results: The CMS metric and the ventilation-adjusted CMS metric were highly concordant in absolute terms and based on the number of standard deviations (SDs) relative to the mean (Spearman correlation coefficient: 0.95, Pearson correlation coefficient: 0.97; p<0.001; Figures 1a and 1b). There was near-identity between the CMS donation metric and the CMS metric adjusted for ventilation, cancer, and sepsis rates (Spearman correlation coefficient: 0.94, Pearson correlation coefficient: 0.97; p<0.001; Figures 2a and 2b).

*Conclusions: These conclusions should provide CMS, and the transplant community, with a large degree of comfort that the proposed CMS metric is the correct option by which to better benchmark and incentivize OPO performance.

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