Alternative Payment Model Updates and the Increasing Organ Transplant Access Model Proposed Rule Summary

On December 11, 2025, CMS published in the Federal Register (90 FR 55342) a proposed rule that would update and revise the Increasing Organ Transplant Access (IOTA) Model. The IOTA Model is a 6-year mandatory alternative payment model tested by the CMS Innovation Center that began on July 1, 2025, and will end on June 30, 2031. The IOTA Model is testing whether performance-based incentives paid to or owed by participating kidney transplant hospitals can increase access to kidney transplants for kidney transplant waitlist patients, while preserving or enhancing quality of care and reducing Medicare expenditures.

CMS has selected 103 kidney transplant hospitals to participate in the IOTA Model and will be measuring and assessing the participating kidney transplant hospitals’ performance during each performance year across three performance domains: achievement, efficiency, and quality. The IOTA Model was established through notice and comment rulemaking, finalized in the Medicare Program; Alternative Payment Model Updates and the Increasing Organ Transplant Access Model final rule (2024 Final Rule), CMS-5535-F, published December 4, 2024. In the 2024 final rule, CMS signaled that there were several policies that could be addressed through future rulemaking including: the addition of a risk-adjustment methodology in the calculation of the composite graft survival rate, the addition of transplants furnished to Medicare Advantage beneficiaries to the definition of Medicare kidney transplants, and the addition of transparency requirements, among other changes.

The deadline for public comment is February 9, 2026.