Update on Lung Continuous Distribution Policy

Current policy

Every lung transplant candidate receives an individualized lung Composite Allocation Score (CAS). This score determines priority for receiving a lung transplant when donor lung(s) become available. The lung CAS is individual for each candidate and each organ offer. The lung CAS point values represent each of the factors used to match organ offers with transplant candidates (Exhibit 1). The people who have the highest number of points for that organ offer will have the highest priority.  

In October 2025, the Health Resources and Services Administration’s (HRSA) preliminary analyses documented a rise in allocation out of OPTN sequence (AOOS) that correlates with the implementation of the lung continuous distribution policy in 2023. In response, the OPTN Board of Directors considered potential changes to lung allocation to promote policy compliance and reduce AOOS

Note: Certain changes described in this proposal were previously implemented following emergency action by the OPTN Board of Directors and are currently in effect while the proposal proceeds through the formal policy process.

Supporting media

Remote Video URL

Exhibit 1. Current Lung Composite Allocation Score 

Attribute Definition % of Available Points 
Waiting List Survival Expected 1-year waiting list survival 25
Post-Transplant Outcomes Expected 5-year post-transplant survival 25 
Candidate Biology Total of ABO, CPRA, and height points 15 
ABO Based on percentage of compatible donors by blood type 
CPRA Based on percentage of compatible donors by CPRA 
Height Based on percentage of compatible donors by height 
Patient Access Total of pediatric and prior living donor points 25 
Pediatric For candidates under 18 years old 20 
Prior Living Donor For candidates who donated any organ 
Placement Efficiency Total of travel and proximity efficiency points 10 
Travel Efficiency Based on impact of distance on costs of travel 
Proximity Efficiency Based on impact of distance on other efficiency (time, availability, etc.) 

Note. Total Score = Waiting List Survival + Post-Transplant Outcomes + Candidate Biology + Patient Access + Placement Efficiency 

Acronyms. ABO=ABO blood group system, CPRA=Calculated Panel Reactive Antibody 

Proposed changes

  • Increasing the weight on placement efficiency from 10% to 15% of the overall score. 
  • Reducing the weight on all other parts of the score proportionally, including points assigned to pediatric candidates less than 12 years old for waitlist survival and post-transplant outcomes. 
  • Replacing the existing travel efficiency and proximity efficiency rating scales with a single placement efficiency rating scale to assign points to potential transplant recipients based on the nautical mile distance between the donor hospital and the transplant hospital.
  • Lung CAS scores for all lung and heart-lung candidates on the waiting list will be updated to reflect the changes to the lung CAS (Exhibit 2).  
  • Approved exceptions will remain in effect based on the percentage of available points approved by the Lung Review Board, and the points assigned for each exception will be reduced proportionately to the adjusted goal weights. 

Exhibit 2. Revised Lung Composite Allocation Score 

Attribute Definition % of Available Points 
Waiting List Survival Expected 1-year waiting list survival 23.6111 
Post-Transplant Outcomes Expected 5-year post-transplant survival 23.6111 
Candidate Biology Total of ABO, CPRA, and height points 14.1666 
ABO Based on percentage of compatible donors by blood type 4.7222 
CPRA Based on percentage of compatible donors by CPRA 4.7222 
Height Based on percentage of compatible donors by height 4.7222 
Patient Access Total of pediatric and prior living donor points 23.6111 
Pediatric For candidates under 18 years old 18.8889 
Prior Living Donor For candidates who donated any organ 4.7222 
Placement Efficiency Total of travel and proximity efficiency points 15 

Note. Total Score = Waiting List Survival + Post-Transplant Outcomes + Candidate Biology + Patient Access + Placement Efficiency 

Acronyms. ABO=ABO blood group system, CPRA=Calculated Panel Reactive Antibody 

Anticipated impact

  • What it's expected to do
    • Reduce median travel distance for lungs
    • Reduce logistical complexity in lung allocation
    • Improve policy compliance
  • What it won’t do
    • It will not completely alleviate AOOS.

Terms to know

  • Allocation out of OPTN sequence (AOOS): An organ allocation event in which an organ is offered, accepted, and/or transplanted outside the established match sequence.
  • Composite Allocation Score (CAS): This score determines priority for receiving a lung transplant when donor lung(s) become available.
  • Calculated Panel Reactive Antibody (CPRA): A score (0–100%) indicating the percentage of potential donors a patient is immunologically incompatible with due to antibodies.

Read the full proposal (PDF - 354 KB)

Date Last Reviewed:

Submit a Comment

Spencer Reinewald 05/23/2026

John Spencer Reinewald
State of Residence: Indiana

Relationship to Lung Transplant: Lung Transplant Candidate/Recipient

Regarding the November 20, 2025 OPTN Board meeting vote to alter the Lung Transplant Continuous Allocation Score (CAS) points and ratios in order to address concerns about Allocation out of Sequence (AOOS).

I am writing to express my strong desire for HRSA/OPTN Board to reverse the decision voted on during the November 20, 2025 Board meeting to remove five points from categories describing a recipient's medical condition and reallocating them to the efficiency category, returning the CAS point allocation and ratios to the pre November 20, 2025 vote levels.

This matters to me because CAS score is fair to all, there is nothing that is perfect. If all the transplant DR. and hospitals, have agreed with this for several years I believe they would know best for there patience. TRUST YOUR DOCTORS OPINION.

Additionally, I share the concerns expressed by the Lung Transplant Foundation letter directed to HRSA and the OPTN Board of Directors, submitted via the Critical Comments and Directives Pathway on April 13, 2026, and signed on to by seventeen distinct lung disease patient advocacy organizations, identifying the following primary concern areas as reasons to oppose this change to the CAS:

- Bucking decades of protocol, no prospective public comment period occurred before this major policy change, and no clinical evidence was supplied justifying the use of the emergency pathway at the time of the vote.
- No clinical rationale was given for ignoring the recommendation of the Lung Committee, which unanimously opposed this change to the CAS, and no solutions were proposed to address the concern that initial modeling suggested that these changes would increase the waitlist mortality for high-risk individuals.
- The change in protocol from extensive modeling before policy changes are implemented to minimal modeling with an intention of catching problems after they occur will endanger lives unnecessarily.
- Patient voices and specialized lung transplant expert opinion should be centered at every stage of OPTN policy development, including the identification of problems, proposed solutions, and the implementation of new policy geared at addressing identified problems.

Thank you again for the opportunity to comment. I sincerely hope that, based on the consistent and unanimous dissent from lung transplant professionals, lung transplant candidates/recipients, and community members, HRSA and the OPTN Board of Directors will reverse the November 20, 2025 vote and restore the CAS to its previous point and ratio allocation.

Sincerely,
John Spencer Reinewald

Rachel Garvin 05/23/2026

I am not sure if my last comment saved so I am submitting again to make sure my voice is heard. I am the sister and caregiver of a double lung transplant recipient. My sister received her first new set of lungs about 10 years ago, at just 32 years old. My family and I are so grateful for the last decade of time we have had with her, a gift that would have absolutely not been possible without this life-saving surgery. Now my sister is in chronic rejection of her lungs and is re-listed for a second double lung transplant. I am so upset to learn of the new changes made to the lung allocation process, against the unanimous recommendations of experts and the people who will be most effected by these changes. This time around, my sister is at a marked disadvantage for getting new lungs because of the unnecessary changes that have been made, along with many others including children in need of lung transplant. I beg you to please restore the CAS to its previous guidelines, which rightly take into account the special factors that make matching someone up with donor lungs more equitable. Listen to experts, listen to the data, listen to the community you are tasked with serving. People's lives depend on it.
Sincerely, Rachel Garvin

Ellen Bondi 05/23/2026

Ellen Bondi
State of Residence: Washington

Relationship to Lung Transplant: Caregiver/Community Member

Regarding the November 20, 2025 OPTN Board meeting vote to alter the Lung Transplant Continuous Allocation Score (CAS) points and ratios in order to address concerns about Allocation out of Sequence (AOOS).

I am writing to express my strong desire for HRSA/OPTN Board to reverse the decision voted on during the November 20, 2025 Board meeting to remove five points from categories describing a recipient's medical condition and reallocating them to the efficiency category, returning the CAS point allocation and ratios to the pre November 20, 2025 vote levels.

This matters to me because My daughter in law is a double lung transplant recipient and is now listed again.

Additionally, I share the concerns expressed by the Lung Transplant Foundation letter directed to HRSA and the OPTN Board of Directors, submitted via the Critical Comments and Directives Pathway on April 13, 2026, and signed on to by seventeen distinct lung disease patient advocacy organizations, identifying the following primary concern areas as reasons to oppose this change to the CAS:

- Bucking decades of protocol, no prospective public comment period occurred before this major policy change, and no clinical evidence was supplied justifying the use of the emergency pathway at the time of the vote.
- No clinical rationale was given for ignoring the recommendation of the Lung Committee, which unanimously opposed this change to the CAS, and no solutions were proposed to address the concern that initial modeling suggested that these changes would increase the waitlist mortality for high-risk individuals.
- The change in protocol from extensive modeling before policy changes are implemented to minimal modeling with an intention of catching problems after they occur will endanger lives unnecessarily.
- Patient voices and specialized lung transplant expert opinion should be centered at every stage of OPTN policy development, including the identification of problems, proposed solutions, and the implementation of new policy geared at addressing identified problems.

Thank you again for the opportunity to comment. I sincerely hope that, based on the consistent and unanimous dissent from lung transplant professionals, lung transplant candidates/recipients, and community members, HRSA and the OPTN Board of Directors will reverse the November 20, 2025 vote and restore the CAS to its previous point and ratio allocation.

Sincerely,
Ellen Bondi

Leslie Rojas 05/23/2026

Leslie Rojas
State of Residence: Florida

Relationship to Lung Transplant: Lung Transplant Candidate/Recipient

Regarding the November 20, 2025 OPTN Board meeting vote to alter the Lung Transplant Continuous Allocation Score (CAS) points and ratios in order to address concerns about Allocation out of Sequence (AOOS).

I am writing to express my strong desire for HRSA/OPTN Board to reverse the decision voted on during the November 20, 2025 Board meeting to remove five points from categories describing a recipient's medical condition and reallocating them to the efficiency category, returning the CAS point allocation and ratios to the pre November 20, 2025 vote levels.

This matters to me because [Add your personalized message]

Additionally, I share the concerns expressed by the Lung Transplant Foundation letter directed to HRSA and the OPTN Board of Directors, submitted via the Critical Comments and Directives Pathway on April 13, 2026, and signed on to by seventeen distinct lung disease patient advocacy organizations, identifying the following primary concern areas as reasons to oppose this change to the CAS:

- Bucking decades of protocol, no prospective public comment period occurred before this major policy change, and no clinical evidence was supplied justifying the use of the emergency pathway at the time of the vote.
- No clinical rationale was given for ignoring the recommendation of the Lung Committee, which unanimously opposed this change to the CAS, and no solutions were proposed to address the concern that initial modeling suggested that these changes would increase the waitlist mortality for high-risk individuals.
- The change in protocol from extensive modeling before policy changes are implemented to minimal modeling with an intention of catching problems after they occur will endanger lives unnecessarily.
- Patient voices and specialized lung transplant expert opinion should be centered at every stage of OPTN policy development, including the identification of problems, proposed solutions, and the implementation of new policy geared at addressing identified problems.

Thank you again for the opportunity to comment. I sincerely hope that, based on the consistent and unanimous dissent from lung transplant professionals, lung transplant candidates/recipients, and community members, HRSA and the OPTN Board of Directors will reverse the November 20, 2025 vote and restore the CAS to its previous point and ratio allocation.

Sincerely,
Leslie Rojas

Amy Lobue 05/22/2026

Amy Lobue
State of Residence: Kentucky

Relationship to Lung Transplant: Caregiver/Community Member

Regarding the November 20, 2025 OPTN Board meeting vote to alter the Lung Transplant Continuous Allocation Score (CAS) points and ratios in order to address concerns about Allocation out of Sequence (AOOS).

I am writing to express my strong desire for HRSA/OPTN Board to reverse the decision voted on during the November 20, 2025 Board meeting to remove five points from categories describing a recipient's medical condition and reallocating them to the efficiency category, returning the CAS point allocation and ratios to the pre November 20, 2025 vote levels.

This matters to me because I have friends/loved ones who may not be able to get the life-saving care they need as a result of these changes. I also am a widow of an organ donor, and I know my husband wouldn’t want these changes affecting his legacy and selfless gift.

Additionally, I share the concerns expressed by the Lung Transplant Foundation letter directed to HRSA and the OPTN Board of Directors, submitted via the Critical Comments and Directives Pathway on April 13, 2026, and signed on to by seventeen distinct lung disease patient advocacy organizations, identifying the following primary concern areas as reasons to oppose this change to the CAS:

- Bucking decades of protocol, no prospective public comment period occurred before this major policy change, and no clinical evidence was supplied justifying the use of the emergency pathway at the time of the vote.
- No clinical rationale was given for ignoring the recommendation of the Lung Committee, which unanimously opposed this change to the CAS, and no solutions were proposed to address the concern that initial modeling suggested that these changes would increase the waitlist mortality for high-risk individuals.
- The change in protocol from extensive modeling before policy changes are implemented to minimal modeling with an intention of catching problems after they occur will endanger lives unnecessarily.
- Patient voices and specialized lung transplant expert opinion should be centered at every stage of OPTN policy development, including the identification of problems, proposed solutions, and the implementation of new policy geared at addressing identified problems.

Thank you again for the opportunity to comment. I sincerely hope that, based on the consistent and unanimous dissent from lung transplant professionals, lung transplant candidates/recipients, and community members, HRSA and the OPTN Board of Directors will reverse the November 20, 2025 vote and restore the CAS to its previous point and ratio allocation.

Sincerely,
Amy Lobue