Recently, The Center for Bioethics and Culture encouraged readers to submit a brief public comment supporting the inclusion of root-cause fertility care, comprehensive diagnostic evaluation, and restorative treatments within any fertility benefit framework. The CBC has submitted the following comments in support of the Departments of Labor, Health and Human Services, and Treasury’s (“Departments”) proposed rule establishing “Excepted Fertility Benefits” for true root cause treatments for infertility.
RE: Comment on Proposed Rule, Excepted Fertility Benefits (RIN 1545-BS02; 1210-AC40; 0938-AU13)
Submitted by the Center for Bioethics and Culture
The Center for Bioethics and Culture (CBC) respectfully submits the following comments in support of the Departments of Labor, Health and Human Services, and Treasury’s (“Departments”) proposed rule establishing “Excepted Fertility Benefits” for true root cause treatments for infertility.
The CBC is an educational nonprofit dedicated to informing members of the general public, thought leaders, lawmakers, and others on ethical issues in healthcare, biomedical research, and biotechnological advancement, including assisted reproductive technologies. For over 25 years, we have shared the testimonies of women, men, surrogate mothers, donor-conceived individuals, egg “donors”, families, and others who have utilized or been harmed by the fertility industry.
We appreciate the Departments’ efforts to expand access to fertility-related benefits and their recognition that infertility is a serious health concern affecting many Americans – a concern deserving compassionate and effective treatment. We are encouraged by the flexibility afforded under the proposed rule and its acknowledgment that fertility care encompasses a broad range of services. However, greater clarity is needed to distinguish between treatments that diagnose and address the underlying causes of infertility and those that primarily bypass infertility through assisted reproductive technologies (ART). Such clarity is important to ensure that benefit designs support the full spectrum of fertility care, including restorative approaches that seek to improve reproductive health and treat underlying medical conditions.
Author Profile
Latest entries
Egg FreezingSeptember 2, 2026Egg Freezing Goes Mainstream—but Are Women Getting the Whole Story?
FeaturedSeptember 2, 2026The World Is Waking Up to the Harms of Surrogacy
BlogAugust 20, 2026August is National Make-A-Will Month: What Legacy Will You Leave?
Egg FreezingAugust 20, 2026AOC, Egg Freezing, and the Story We Are Telling Women
