Domain Atlas / Clinical decision support & deterioration alerting

Case fileUnited States — the national organ allocation network. The HRSA-contracted Organ Procurement and Transplantation Network (OPTN), operated by UNOS, applied across all US kidney transplant programs (roughly 230 active programs). Policy record: the race-neutral eGFR requirement (OPTN Board unanimous 27 June 2022, effective 27 July 2022), the Waiting Time Modifications policy (Board unanimous 5 December 2022, effective 5 January 2023, attestation deadline 3 January 2024), and the Monitor Ongoing eGFR Modification Policy Requirements update (Board June 2025, effective 10 September 2025, program completion due 11 September 2026)large deployment

OPTN eGFR Waiting-Time Correction

Explore this deployment in the PAN Lab ↗

In the PAN Lab, the readouts of this case's model organization carry a shaded evidence band whose width follows the least-established class among the modeling inputs the readings rest on.

The least-established input behind this case's model organization's readings is an assumption, not a measurement. Evidence base: 2 assumed · 15 published baseline.

The object corrected here is a clinical equation, not a learned system. The standard formulas for estimating glomerular filtration rate from a serum creatinine result — the 1999 MDRD equation and then the 2009 CKD-EPI creatinine equation — applied a coefficient that raised the estimated kidney function of any patient identified as Black; in the 2009 equation that coefficient was 1.159 (95 percent CI 1.144 to 1.170). The stated biological rationale, higher average muscle mass, treated race as a biological rather than a social category, and the MDRD equation behind it was derived from roughly 1,400 White and fewer than 200 Black patients. Inker and colleagues reported in the New England Journal of Medicine on 23 September 2021 that the race-including equation overestimated measured GFR in Black patients by a median of 3.7 mL/min/1.73m2, and concluded that race in eGFR equations is a social and not a biologic construct; OPTN's own patient materials state in a different register that the race variable automatically increased all Black patients' eGFR values, by as much as 16 percent. A kidney transplant candidate begins accruing waiting time when the estimate reaches 20 mL/min/1.73m2 or lower, so an estimate raised above that line delayed the clock; two studies cited in the nephrology commentary put the lost time at 1.3 and 1.9 years for affected Black candidates.[3]

What happened

The object at the centre of this case is not an AI system. It is an equation. For decades the standard formulas for estimating glomerular filtration rate from a serum creatinine result — the 1999 Modification of Diet in Renal Disease (MDRD) equation, then the 2009 Chronic Kidney Disease Epidemiology Collaboration (CKD-EPI) creatinine equation — applied a coefficient that raised the estimated kidney function of any patient identified as Black. In the 2009 equation that coefficient was 1.159 (95% CI 1.144-1.170). The stated biological rationale, higher average muscle mass, treated race as a biological rather than a social category; the MDRD equation behind it had been derived from roughly 1,400 White and fewer than 200 Black patients. In 2021 a joint National Kidney Foundation and American Society of Nephrology task force recommended immediate adoption of a race-free equation, and Inker and colleagues published new race-free 2021 CKD-EPI equations in the New England Journal of Medicine, reporting that the race-including equation overestimated measured GFR in Black patients by a median of 3.7 mL/min/1.73m2 and concluding that race in these equations is a social and not a biologic construct. OPTN's own patient materials put the same point in a different register: the race variable automatically increased all Black patients' eGFR values, by as much as 16 percent. The two magnitudes come from different registers and are cited separately throughout this file.

What turned a measurement question into a governance one is a threshold. A kidney transplant candidate begins accruing waiting time when their estimated GFR reaches 20 mL/min/1.73m2 or lower. An estimate raised by a coefficient could sit above that line when the same creatinine value without it would have sat below — so the clock started late. Two studies cited in the nephrology literature put the lost time at 1.3 and 1.9 years for affected Black candidates. Accrued waiting time is a term in the ranking donor kidneys are offered down, so this was not an abstraction about a number in a chart; it was a position in an allocation queue.

The correction came in two layers and then a third. After a public comment period, the OPTN Board of Directors unanimously approved "Establish OPTN Requirement for Race-Neutral eGFR Calculations" on 27 June 2022, requiring every kidney transplant program to use a formula without a Black-race variable from 27 July 2022. The National Kidney Foundation called it an important first step, saying there is no place for race-based variables in evaluating organs offered through the allocation system. A prohibition, though, only runs forward. So on 5 December 2022 the Board unanimously approved the retroactive remedy, effective 5 January 2023: every kidney program had to assess its waiting list, identify Black candidates disadvantaged by race-inclusive eGFR, establish whether a race-neutral calculation would have qualified them sooner — documentation had to show the estimate was over 20 mL/min with the race coefficient and 20 or lower without it — and apply to OPTN to backdate that waiting time. Programs had until 3 January 2024 to complete their assessments, file every qualifying modification through UNet, notify every kidney candidate before and after assessment regardless of race, and attest to OPTN that they had done so. Programs that did not comply would be referred to the Membership and Professional Standards Committee. In practice, as the trade guidance written for the programs describes, this meant pulling a candidate list from OPTN's custom reporting tool, retrieving historical laboratory results from hospital records, external and reference laboratories, dialysis centers and record-retrieval systems, comparing the race-inclusive and race-neutral figures, and filing an eGFR Waiting Time Modification Form with supporting documentation.

The numbers came with snapshot dates, and they grew. The early monitoring report (published 4 December 2023, data through 5 July 2023) recorded more than 6,100 Black candidates with modified waiting times at a median of 1.7 years, 491 of whom had received a deceased-donor transplant and 15 a living-donor transplant; at that date only 12 of 232 active programs had attested. The one-year report (published 8 May 2024, data through 4 January 2024) recorded 14,701 waiting-time modifications processed, a median of 1.7 years with roughly half receiving between one and three years, 2,709 modified candidates transplanted from deceased donors and 158 from living donors — and all 230 active kidney programs attested. These are counts of modifications and registrations rather than of distinct people.

Then the outside measurement. Schold and colleagues published a national study in the Journal of the American Society of Nephrology on 6 May 2025: of 44,912 Black candidate kidney waitlist registrations assessed, 32 percent (14,419) received a modification, worth a median of about 610 priority days, and modified candidates had an adjusted hazard ratio of 2.85 (95% CI 2.7-3.02) for deceased-donor transplantation against non-modified candidates. The study also found that modification rates varied significantly by candidate characteristics and by transplant center. The investigators' reading of that variability was that there was still mixed use of the policies and that the requirement had not been articulated clearly at the beginning. The Membership and Professional Standards Committee, having observed programs implementing the requirements in various ways, referred a follow-on project to the Minority Affairs Committee. The Board approved "Monitor Ongoing eGFR Modification Policy Requirements" in June 2025, effective 10 September 2025: programs must now maintain written protocols and document compliance for confirming a candidate's race, for fulfilling notification requirements, and for seeking supporting documentation, naming at minimum which sources will be reviewed; notification duties apply to candidates registered on or after 4 January 2024; and every registered kidney candidate must be assessed for eligibility. Programs have until 11 September 2026 to complete the strengthened requirements. The peer-reviewed commentary on the programme is warm and unillusioned at once: it uses the language of restorative justice, and it records the critique that the policy has been called both unfairly too broad and too narrow, addressing one input and one population while leaving open the question of whether all patients should accrue predialysis waiting time.

The sociotechnical reading

Nearly every deployment in this atlas is read at the moment a correction channel fails. This one is carried because a correction channel worked, and reading it honestly means holding two things at once: what the record establishes was repaired, and what the same record establishes about the repair's shape.

Start with why the defect was invisible from inside. The estimating equation is not a learned system that could drift, be retrained, or be audited against a held-out sample. It is a published formula with fixed coefficients, running identically in thousands of independent laboratories. Every laboratory's quality process checks whether the arithmetic was performed correctly on the specimen in front of it, and the arithmetic was correct every time. A bias living inside the formula itself is invisible to every check that trusts the formula — which is why no local fix was available and why the correction had to arrive as a professional standard converted into an allocation rule. That is also the reason the monoculture on this diagram is drawn at full strength: one formula, one direction of adjustment, every patient it touched, nationwide, for over a decade.

The remedy the record documents is genuinely unusual, and its unusual part is the backward-looking half. Removing the coefficient was the recommendation of a professional task force and the subject of a board vote; that step, on its own, would have left every candidate whose clock had already run late holding a late qualifying date. What the OPTN did next was order its own registry state recomputed: retrieve the history, apply a formula without the coefficient, and write the corrected qualifying date into UNet, where it re-ranks the candidate in the live deceased-donor offer sequence. The measured allocation effect — an adjusted hazard ratio of 2.85 for deceased-donor transplantation among modified candidates — is what makes the point that the correction was not advisory. The map draws this as structure: the registry drives the offer sequence, and the corrected value has no path into the registry except through a person.

That last absence is where the honest complications live, and the record supplies them rather than the atlas inventing them. First, the undo ran by hand. Roughly 230 autonomous programs each executed a uniform rule against messy historical laboratory data spread across hospitals, reference laboratories and dialysis centers, with wide discretion over which sources to pull and how to confirm a candidate's recorded race — and the independent national evaluation measured the result: modification rates that varied significantly by transplant center, which the investigators read as mixed use of a requirement that was not clearly articulated at the outset. A programme's own monitoring reports could count how much restitution had been made; they could not see that it was being made unevenly, and it took an outside study with a denominator to establish that. Second, the correction outran its own checking at the far end: the trade guidance for the audit describes candidates receiving a lot of time back, moving to the top of the list and beginning to receive offers, while centers worked to ensure those candidates had been re-evaluated recently. Nothing settles a changed rank against the record before offers issue on it, and that is drawn on the diagram rather than argued in prose. Third, the correction's scope is a scope, not a completeness. It applies to registered kidney candidates on programs' waiting lists; it can only advance a qualifying date, never delay one; and the peer-reviewed commentary records the standing critique that it addresses one input and one population, leaving open whether all patients should accrue predialysis waiting time. And fourth, the strengthening that answered the variance finding is in force but not finished: programs have until 11 September 2026 to complete the written-protocol requirements, so the record as it stands describes a rhythm that has started.

What the Lab reads here is institutional, and only institutional. Transplant candidates are the subjects of this correction and appear nowhere in the dynamics: no waiting time, qualifying date, offer or transplant outcome for any person is computed on the diagram. The published figures about candidates are recorded external observations, each carrying its own denominator and data-snapshot date — more than 6,100 modifications at six months, 14,701 at one year, 14,419 of 44,912 assessed registrations in the peer-reviewed count, the transplant subtotals, the hazard ratio — and they belong in this file, not on the network. What the network carries is the shape of the thing: a governance body that ordered its own registry to recompute an input's historical effect, measured the result publicly, and then tightened on what the measurement showed.

The concepts used in this reading are defined in the Field Guide; the governance responses live in the Practice Library. The model organization for this case can be stress-tested in the PAN Lab.

Grounding sources for this case

The same sources that ground this model organization in the PAN library: evaluations, government documents, investigative reporting, and advocacy documentation, each labeled by tier.

inker2021GroundingAcademicSave

Inker, L. A., Eneanya, N. D., Coresh, J., et al. (2021). New Creatinine- and Cystatin C-Based Equations to Estimate GFR without Race. New England Journal of Medicine, 385(19), 1737-1749 https://pmc.ncbi.nlm.nih.gov/articles/PMC8822996/

https://pmc.ncbi.nlm.nih.gov/articles/PMC8822996/

Grounds: model org: optn_egfr_race_correction

pavlakis2023GroundingAcademicSave

Pavlakis, M. (2023). A Restorative Justice Project in Kidney Allocation: The Wait Time Modification for Black and African American Candidates Affected by the Race-Based eGFR Equation. Journal of the American Society of Nephrology, 34(10), 1618-1620 https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

Grounds: model org: optn_egfr_race_correction

hrsaoptn2023GroundingGovernmentSave

HRSA / OPTN (2023, December 4). Early monitoring report shows Black kidney candidates are receiving waiting time modifications after implementation of new policies https://www.hrsa.gov/es/node/30440

https://www.hrsa.gov/es/node/30440

Grounds: model org: optn_egfr_race_correction

hrsaoptn2024GroundingGovernmentSave

HRSA / OPTN (2024, May 8). Over 14,700 waiting time modifications completed for Black kidney patients one year after policy implementation https://www.hrsa.gov/optn/news-events/news/over-14700-waiting-time-modifications-completed-black-kidney-patients-one-year-after-policy-implementation

https://www.hrsa.gov/optn/news-events/news/over-14700-waiting-time-modifications-completed-black-kidney-patients-one-year-after-policy-implementation

Grounds: model org: optn_egfr_race_correction

schold2025GroundingAcademicSave

Schold, J. D., Arrigain, S., Husain, S. A., et al. (2025). Variation of eGFR Wait Time Modifications for Black Kidney Transplant Candidates in the United States. Journal of the American Society of Nephrology (published online 6 May 2025) https://pubmed.ncbi.nlm.nih.gov/40327843/

https://pubmed.ncbi.nlm.nih.gov/40327843/

Grounds: model org: optn_egfr_race_correction

Seeing your organization in this case file?

The histories here are documented after the harm. Mapping a live deployment's pathways and pressures, before the incident report, is engagement work: intake, diagnosis, prescription, and monitoring, with every limitation stated.

Sources & Evidence

Claims made on this page and what supports them. The full registry lives in Evidence.

EmpiricalThe object corrected here is a clinical equation, not a learned system. The standard formulas for estimating g…

The object corrected here is a clinical equation, not a learned system. The standard formulas for estimating glomerular filtration rate from a serum creatinine result — the 1999 MDRD equation and then the 2009 CKD-EPI creatinine equation — applied a coefficient that raised the estimated kidney function of any patient identified as Black; in the 2009 equation that coefficient was 1.159 (95 percent CI 1.144 to 1.170). The stated biological rationale, higher average muscle mass, treated race as a biological rather than a social category, and the MDRD equation behind it was derived from roughly 1,400 White and fewer than 200 Black patients. Inker and colleagues reported in the New England Journal of Medicine on 23 September 2021 that the race-including equation overestimated measured GFR in Black patients by a median of 3.7 mL/min/1.73m2, and concluded that race in eGFR equations is a social and not a biologic construct; OPTN's own patient materials state in a different register that the race variable automatically increased all Black patients' eGFR values, by as much as 16 percent. A kidney transplant candidate begins accruing waiting time when the estimate reaches 20 mL/min/1.73m2 or lower, so an estimate raised above that line delayed the clock; two studies cited in the nephrology commentary put the lost time at 1.3 and 1.9 years for affected Black candidates.

inker2021GroundingAcademicSave

Inker, L. A., Eneanya, N. D., Coresh, J., et al. (2021). New Creatinine- and Cystatin C-Based Equations to Estimate GFR without Race. New England Journal of Medicine, 385(19), 1737-1749 https://pmc.ncbi.nlm.nih.gov/articles/PMC8822996/

https://pmc.ncbi.nlm.nih.gov/articles/PMC8822996/

Grounds: model org: optn_egfr_race_correction

pavlakis2023GroundingAcademicSave

Pavlakis, M. (2023). A Restorative Justice Project in Kidney Allocation: The Wait Time Modification for Black and African American Candidates Affected by the Race-Based eGFR Equation. Journal of the American Society of Nephrology, 34(10), 1618-1620 https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

Grounds: model org: optn_egfr_race_correction

EmpiricalThe correction arrived in two board actions. After a public comment period running 27 January to 23 March 2022…

The correction arrived in two board actions. After a public comment period running 27 January to 23 March 2022, the OPTN Board of Directors unanimously approved 'Establish OPTN Requirement for Race-Neutral eGFR Calculations' on 27 June 2022, requiring every kidney transplant program to use an eGFR formula without a Black-race variable from 27 July 2022; the National Kidney Foundation, whose joint task force with the American Society of Nephrology had recommended a race-free equation, called the vote an important first step and said there is no place for race-based variables in evaluating organs offered through the allocation system. Because a prohibition runs only forward, the Board then unanimously approved the retroactive remedy on 5 December 2022, effective 5 January 2023: each kidney program had to assess its waiting list, identify Black candidates disadvantaged by race-inclusive eGFR, establish whether a race-neutral calculation would have qualified them sooner, and apply to OPTN to backdate the qualifying date. Eligibility required documentation that the candidate's eGFR was over 20 mL/min under the race-inclusive calculation and 20 mL/min or lower without it. Programs had until 3 January 2024 to complete assessments, submit every qualifying modification, notify all kidney candidates before and after assessment regardless of race, and file an attestation; programs that did not comply would be referred to the Membership and Professional Standards Committee.

pavlakis2023GroundingAcademicSave

Pavlakis, M. (2023). A Restorative Justice Project in Kidney Allocation: The Wait Time Modification for Black and African American Candidates Affected by the Race-Based eGFR Equation. Journal of the American Society of Nephrology, 34(10), 1618-1620 https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

Grounds: model org: optn_egfr_race_correction

EmpiricalThe undo ran by hand, program by program. Trade guidance written for transplant programs describes the working…

The undo ran by hand, program by program. Trade guidance written for transplant programs describes the working method: identify candidates through the OPTN custom reporting tool's 'Current waitlisted African American Candidates' query, pull historical laboratory results from the electronic medical record, from external and reference laboratories, from dialysis centers and through record-retrieval and health-information-exchange systems, compare the race-inclusive and race-neutral figures against the 20 mL/min threshold, submit an eGFR Waiting Time Modification Form in UNet with supporting documentation, and send two notifications — before and after assessment — to every kidney candidate regardless of race. The same guidance records the correction's own second wave as a documented operational pressure: some patients were getting a lot of time back, bouncing them to the top of the list to start receiving offers, which it describes as a significant operational impact on many transplant centers, especially in ensuring that a patient had been re-evaluated recently. Accrued waiting time is a term in the ranking donor kidneys are offered down, so a backdated qualifying date changes a candidate's position in the live deceased-donor offer sequence directly rather than serving as a note on a file.

EmpiricalOPTN published its own counts twice, and each figure carries the date its data was cut. The early monitoring r…

OPTN published its own counts twice, and each figure carries the date its data was cut. The early monitoring report (published 4 December 2023, data through 5 July 2023) recorded more than 6,100 Black candidates with modified waiting times at a median of 1.7 years, of whom 491 had received a deceased-donor transplant and 15 a living-donor transplant; at that date 12 of 232 active kidney programs had submitted attestations. The one-year report (published 8 May 2024, data through 4 January 2024) recorded 14,701 waiting-time modifications processed at a median of 1.7 years, with roughly half of modified registrations receiving between one and three years, 2,709 modified candidates transplanted from deceased donors and 158 from living donors, and all 230 active kidney programs having submitted attestations confirming that lists were reviewed, candidates notified and required modifications submitted. These are counts of modifications and of registrations at specific snapshot dates rather than counts of distinct people, and they are cumulative figures that grew between the two reports.

hrsaoptn2023GroundingGovernmentSave

HRSA / OPTN (2023, December 4). Early monitoring report shows Black kidney candidates are receiving waiting time modifications after implementation of new policies https://www.hrsa.gov/es/node/30440

https://www.hrsa.gov/es/node/30440

Grounds: model org: optn_egfr_race_correction

hrsaoptn2024GroundingGovernmentSave

HRSA / OPTN (2024, May 8). Over 14,700 waiting time modifications completed for Black kidney patients one year after policy implementation https://www.hrsa.gov/optn/news-events/news/over-14700-waiting-time-modifications-completed-black-kidney-patients-one-year-after-policy-implementation

https://www.hrsa.gov/optn/news-events/news/over-14700-waiting-time-modifications-completed-black-kidney-patients-one-year-after-policy-implementation

Grounds: model org: optn_egfr_race_correction

EmpiricalAn independent national evaluation measured what the programme's own counts could not. Schold and colleagues, …

An independent national evaluation measured what the programme's own counts could not. Schold and colleagues, publishing in the Journal of the American Society of Nephrology on 6 May 2025, assessed 44,912 Black candidate kidney waitlist registrations nationally and found that 32 percent (14,419) received an eGFR waiting-time modification worth a median of about 610 priority days, and that modified candidates had an adjusted hazard ratio of 2.85 (95 percent CI 2.7 to 3.02) for deceased-donor transplantation against candidates who were not modified. The same study found modification rates varying significantly by candidate characteristics and by transplant center; the investigators read that variability as indicating there was still mixed use of the policies and that the requirement was not articulated clearly at the beginning. The study's primary record was behind a paywall and a consent wall at verification time on 28 August 2026, and these figures are carried as corroborated through the trade report of the same study rather than as directly retrieved from the primary.

schold2025GroundingAcademicSave

Schold, J. D., Arrigain, S., Husain, S. A., et al. (2025). Variation of eGFR Wait Time Modifications for Black Kidney Transplant Candidates in the United States. Journal of the American Society of Nephrology (published online 6 May 2025) https://pubmed.ncbi.nlm.nih.gov/40327843/

https://pubmed.ncbi.nlm.nih.gov/40327843/

Grounds: model org: optn_egfr_race_correction

EmpiricalThe measured unevenness produced a further governance action rather than a closed file. The Membership and Pro…

The measured unevenness produced a further governance action rather than a closed file. The Membership and Professional Standards Committee, having observed programs implementing the requirements in various ways, referred a follow-on project to the OPTN Minority Affairs Committee; after public comment from 21 January to 19 March 2025 the OPTN Board approved 'Monitor Ongoing eGFR Modification Policy Requirements' at its June 2025 meeting, effective 10 September 2025. The update converts the one-time legacy audit into a standing per-candidate obligation: every registered kidney candidate must be assessed for eligibility, and each program must maintain written protocols and document compliance in three areas — confirming a candidate's race, fulfilling the notification requirements, and seeking supporting documentation, naming at minimum which sources will be reviewed. The notification requirements (education, eligibility and outcome) apply to candidates registered on or after 4 January 2024, and the update removes the superseded 3 January 2024 attestation language. Programs must complete the strengthened requirements by 11 September 2026, a date that had not passed as of 28 August 2026.

EmpiricalThe equity framing around this programme belongs to the commentary and policy materials that used it, and the …

The equity framing around this programme belongs to the commentary and policy materials that used it, and the same commentary records the critique. Pavlakis, writing in the Journal of the American Society of Nephrology in 2023, describes the waiting-time modification as a restorative justice project in kidney allocation and also records that the policy has been criticised as being unfair to people suffering under other inequities besides Black or African American race, and as both unfairly too broad and too narrow, leaving open the broader question of whether all patients should accrue predialysis waiting time. The remedy's scope is bounded on the face of the policy: it reaches registered kidney candidates whose documentation meets the eligibility rule, it addresses the eGFR-driven delay and no other source of delay, and it can only advance a qualifying date, never delay one. No litigation and no enforcement action appears anywhere in this record as of 28 August 2026; the record is affirmative governance — a prohibition, a retroactive modification programme, published monitoring, an independent peer-reviewed evaluation, and a tightening in response to measured variance.

pavlakis2023GroundingAcademicSave

Pavlakis, M. (2023). A Restorative Justice Project in Kidney Allocation: The Wait Time Modification for Black and African American Candidates Affected by the Race-Based eGFR Equation. Journal of the American Society of Nephrology, 34(10), 1618-1620 https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

https://pmc.ncbi.nlm.nih.gov/articles/PMC10561813/

Grounds: model org: optn_egfr_race_correction