Definition of Imminent
Death Proposed
The OOSN Executive Committee, in response to the Medicare
requirement that hospitals refer both deaths and imminent deaths to the organ procurement
organization, approved in November a proposed definition of imminent death to be shared
with physicians and hospitals throughout Oklahoma.
In proposing its definition, OOSN, like a number of other organ
procurement organizations throughout the country, utilized the Glasgow Coma Scale.
Following discussion, it was determined that for purposes of hospital referrals imminent
death would be defined as a GCS score of 4 or less. It was felt by the physicians
comprising the OOSN executive committee that such a definition would find ready
acceptance.
According to the Health Care Financing Administration (HCFA),
the new Medicare Conditions of Participation (COP) require hospitals to report imminent
deaths to the OPO and to work cooperatively with the OPO, tissue bank and eye bank to
maintain potential donors while necessary testing and placement of potential organs,
tissues, and eyes take place. HCFA, while it does not define imminent death, does suggest
that any definition "would include a brain dead or severely brain-injured individual
on a ventilator.
HCFA goes on to suggest that, "Once the imminent death is
reported, if the patient is identified by the OPO as a potential donor, the hospital is
required to continue to maintain the patient so that the patient’s organs remain
viable."
In order for Oklahoma hospitals to meet the requirements of the
new COP it was necessary to have a definition of imminent death. OOSN believes that its
proposed definition meets that need and will make it possible for hospitals to fully meet
all requirements of the new Medicare Conditions of Participation.
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Hospital Education and Death Chart Reviews Planned
The Medicare Conditions of Participation that took effect in August of
1999 have greatly increased the responsibility of Oklahoma Organ Sharing Network in regard
to maximizing potential for organ and tissue donation. In addition to providing training
for designated requestors, OOSN is now required to work with hospitals in the education of
hospital staffs regarding donation and the review of death records to improve
identification of potential donors.
The Office of Inspector General in a recent survey assessing responses to the
COP asked very specific questions about steps taken by the OOSN to verify that hospitals
are appropriately reporting deaths. They also made inquiry about OOSN efforts to work with
hospitals failing to report all deaths.
While OOSN has long been involved in both the education of medical
professionals and death chart reviews, it now seems necessary that this be done routinely
in acute care hospitals throughout the state.
OOSN, in the new year, will be contacting Oklahoma hospitals to schedule death
chart reviews and training for hospital personnel. OOSN will also continue its practice of
providing quarterly reports on death referrals to assist hospitals in documenting
compliance with Medicare Conditions of Participation.
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