HRSA Wants to Change OPTN Data Forms: What OPOs Should Know Before Nov. 9

On October 9, 2026, the Health Resources and Services Administration (HRSA) published a notice in the Federal Register about the data the Organ Procurement and Transplantation Network (OPTN) collects. If you work in an OPO, especially in quality, compliance, or data, it's worth a few minutes of your time.

Here's what it is, what it isn't, and how to weigh in before the deadline.

First, what this is (and isn't)

This is not a new clinical policy. It doesn't change how you identify, evaluate, or manage a donor, and it doesn't change allocation.

It's an information collection request. Under the Paperwork Reduction Act, the federal government has to get approval from the Office of Management and Budget (OMB) before it collects information from the public, and that includes the forms OPOs, transplant centers, and histocompatibility labs fill out in the OPTN computer system. When the OPTN Board approves new or changed data elements, HRSA sends them to OMB for official approval. That's what this notice does. HRSA has submitted the revised OPTN data collection (OMB No. 0906-0110) to OMB for review.

This is the second round. HRSA published a first notice on May 15, 2026, and received one comment, from a transplant center. This notice opens a 30-day comment period before OMB can act.

What's proposed

Two new forms:

  • Patient Safety Contact Management Form. OPTN members will use it to name their primary and secondary patient safety contacts, consistent with OPTN Policy 15.1.
  • Patient Transfer Form. Transplant centers will use it to transfer post-transplant patients to another transplant center during ongoing follow-up.

Three forms removed:

  • Death Notification Registration and Deceased Donor Death Referral. The notice says that since OMB approved the OPTN Ventilated Patient Form (OMB No. 0906-0112), these are no longer needed in the OPTN data system, because the Ventilated Patient Form contains the information they used to collect.
  • VCA Transplant Candidate Registration. New vascularized composite allograft (VCA) registration forms now live in the OPTN waiting list system, so this older form is read-only and members no longer need to validate it.

Minor edits to other previously approved forms, for clarity.

The burden numbers

HRSA estimates the total annual burden of the OPTN data collection at 903,607.48 hours. That's 52,029.48 hours more than the package OMB approved on June 25, 2025.

HRSA says the increase comes from updated respondent and response counts based on 2025 OPTN data, the two new forms, and Board-approved revisions to existing forms. Removing the three forms offsets 6,960.18 of those hours. In other words, most of the increase isn't from the new forms. HRSA estimates the two new forms at about 3,310 hours a year combined.

What it means day to day

For OPO staff, the biggest practical piece is the referral and death data. The two OPTN forms that used to carry that information are coming out of the data system, because the Ventilated Patient Form now holds it. If your team has been working with the Ventilated Patient Form, this notice is the paperwork catching up.

Your OPO will also need to keep its patient safety contacts current through the new Patient Safety Contact Management Form. The Patient Transfer Form is for transplant centers, but it's good to know it exists if you work closely with your local programs.

The notice doesn't give go-live dates for the form changes, so watch for OPTN system notices and your organization's guidance.

How to comment

Comments should be received by November 9, 2026. Send them through reginfo.gov: choose "Currently under 30-day Review – Open for Public Comments" or search for OMB No. 0906-0110.

HRSA asks for comments on four things: whether the collection is necessary and useful, whether the burden estimate is accurate, how to improve the quality and clarity of the information, and how technology could reduce the burden.

Want to see the actual forms? HRSA says the draft forms can be requested during the comment period in clean and redline versions. Email Samantha Miller, HRSA's Information Collection Clearance Officer, at paperwork@hrsa.gov, or call (301) 443-9094.

If you're the person in your OPO who actually completes these forms, your view on the time they take is exactly what the burden question is asking for.

Sources

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