June 25th, 2025

Re: Opposition to AB224

To: Senator Caroline Menjivar (Chair), and Members of the Senate Committee on Health

On behalf of the Center for Bioethics and Culture Network (CBC), I write in strong opposition to AB 224, which proposes the legislative intent to revise California’s “essential health benefits” (EHB) benchmark plan under the Affordable Care Act. While the bill itself is vague in scope, our concern lies in the potential expansion of mandated insurance coverage for elective fertility procedures—including in vitro fertilization (IVF), embryo testing, and surrogacy—that have significant health consequences for egg “donors”, surrogate mothers, and the children born through these technologies.

Surrogacy involves complex medical interventions that carry substantial physical and psychological risks to the women who serve as gestational carriers. These include, but are not limited to: increased risk of pregnancy complications, including preeclampsia, placenta previa, gestational diabetes, and preterm labor, particularly when carrying multiples, which are more common in IVF or surrogacy; psychological and emotional trauma, including an increased risk for postpartum depression, associated with relinquishing a child they have carried to term, which is often underestimated or dismissed; exposure to intensive hormone treatments, which may have long-term implications for women’s health and fertility (studies are sorely lacking).

Any legislative move that could incentivize or expand commercial surrogacy through mandated insurance coverage risks turning women—often financially vulnerable—into a means to an end for others’ reproductive desires. As a bioethics organization, we find this deeply concerning. Further, it has the real potential to cause chronic health conditions later in life for the woman that serves as a surrogate mother, increasing her and the state’s healthcare costs.

Read the Entire Letter of Opposition

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CBC-Network