Donation After Circulatory Death in the United States: What the 2026 OPTN Policy Resolves and What Remains for NRP

Background. Donation after circulatory death (DCD) has become a major component of deceased organ donation in the United States. On August 20, 2026, the Organ Procurement and Transplantation Network (OPTN) Board approved revised national DCD policy, effective November 18, 2026, to strengthen safeguards, communication, consistency, and accountability across the DCD pathway. Methods. We performed a documentary policy analysis of the complete Board briefing paper and final policy language, together with current HRSA/OPTN implementation materials. Because normothermic regional perfusion (NRP) sits at an important interface between the DCD policy and separate NRP policy development, we additionally considered current NRP policy-development materials and selected human evidence addressing cerebral circulation during thoracoabdominal NRP. Results. The 2026 policy establishes recurrent confirmation that withdrawal of life-sustaining therapies remains appropriate; neurological documentation and escalation of discordant assessments; a formal unplanned DCD pause; stakeholder education; expanded donor-family information; consent requirements for premortem procedures; reporting of unplanned pauses and autoresuscitation events; and a minimum five-minute period of circulatory cessation before organ recovery. The policy text also requires an explanation of potential NRP when its use is anticipated, including the rationale, likely restoration of select organ function, and safeguards to prevent cerebral blood flow. Comprehensive technical NRP standards are not established by this DCD policy. Conclusions. The 2026 OPTN DCD policy establishes a national process-safety and accountability floor rather than a comprehensive procedural protocol. NRP illustrates the scope of this approach: NRP-specific disclosure is present in the DCD policy, whereas technical standardization remains a separate policy-development problem. Post-implementation evaluation should determine whether these safeguards reduce clinically important variation while generating data sufficient to guide subsequent DCD and NRP policy.