Organ Procurement Organizations (OPOs):
OPOs will need to review and update their policies, procedures and workflows as needed, as well as complete any required personnel and required education to comply with the new requirements by Nov. 18, 2026. 

The policy changes establish new and enhanced patient safety requirements throughout the DCD process, including: 

• Comprehensive information sharing with patient families about the DCD process, supporting informed decision making
• Ongoing donor hospital and OPO collaboration to ensure ongoing patient eligibility for DCD
• Documentation of donor hospital facilitated neurological assessments with escalation of identified discrepancies between the assessments and OPO patient observations
• Adoption of the unplanned DCD pause, a formal mechanism to suspend donation-related activities when concerns arise regarding a patient’s safety during the DCD process, inclusive of education for families, clinical professionals and other involved stakeholders of their ability to call for a pause
• Defined procedures to address and resolve any requested unplanned DCD pause
• Required reporting of any requested unplanned DCD pause
• Adoption of a standardized, minimum waiting period of five minutes between circulatory cessation and commencement of organ recovery

The policy changes establish new requirements for enhanced information sharing and communication with patients and their families including: 

• Minimum required disclosure content for all organ donation cases
• Minimum required disclosure content specific to DCD cases
• Required consent specific to any DCD related procedures or drug administration that occurs prior to the patient’s death

The policy changes establish new requirements for data entry into the OPTN Computer System as well as formal data submission including: 

• Registration of all donors into the OPTN Computer System within a defined time period
• Submission of the Donor Organ Disposition form for all individuals, except living donors, for whom authorization for donation is granted
• Reporting of any requested unplanned DCD pause through the OPTN Patient Safety Reporting Portal
• Reporting of any autoresuscitation event that occurs beyond the waiting period through the OPTN Patient Safety Reporting Portal

OPOs should review the final policy requirements and ensure appropriate staff understand the new requirements before implementation. 

Transplant Programs:
Transplant programs will need to ensure that required education is completed and documented by Nov. 18, 2026. 

The policy establishes newly required education including: 

• Education about the purpose of the unplanned DCD pause and what applicable transplant program personnel and contracted third parties can expect during a DCD case.