I would like to comment on behalf of our organization, LifeNet Health, the federally designated organ procurement organization for most of Virginia on this petition.

The petition for rulemaking was submitted on behalf of nurses that approached our organization inquiring why there was no standardized training for nurses currently being provided regarding organ, eye and tissue donation in Virginia. Every nurse will be encountering the CMS required "referral of all deaths and all imminent deaths to the OPO" in their work environments. Currently some nursing schools are offering coursework on the topics but others are not.

Our organization provides education within hospitals, communities, high schools and selected nursing programs that have facilitated presentations to their nursing students. However, still today 18 Americans die because a life saving organ does not become available and transplantable organs are buried because a clinical trigger for referral was not identified and referrals are missed.

The nursing curriculum is surely comprehensive and the requirements numerous, but this education would benefit each nursing student and the knowledge acquired would be utilized by each nurse when entering the workforce. Our organization is prepared to assist nursing schools with the development of the curriculum and would provide resources to facilitate the education. This education can literally save lifes. 

On behalf of the 114,000 Americans currently waiting for a life saving organ please consider the implementation of required coursework on organ, eye and tissue donation.