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Policy tightens documentation, neurologic reassessment and consent standards for DCD cases

September 24, 2026 | Health Resources and Services Administration, Department of Health and Human Services (HHS), Executive, Federal


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Policy tightens documentation, neurologic reassessment and consent standards for DCD cases
Webinar speakers said OPOs are required to document ongoing neurologic assessments performed by the patient’s care team at least every 12 hours after case initiation and again within two hours of planned withdrawal. Presenters noted assessments may be performed by physicians, advanced practice providers, or nurses and documentation in donor records will demonstrate compliance.

The presenters also clarified disclosure and consent expectations: OPOs must establish written protocols specifying what must be disclosed to families/agents at authorization for DCD cases, and explicit consent is required for premortem cannulation or administration of medications before death, including discussion of potential complications and documentation in the donor record.

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