EBSA-2026-0232-0001, Blue Cross Blue Shield Association (BCBSA)
Blue Cross Blue Shield Association (BCBSA)SupportTrade association
Summary: The Blue Cross Blue Shield Association (BCBSA) supports the proposed rule creating a voluntary, employer-driven pathway for excepted fertility benefits. They recommend adding specific regulatory text to clarify the voluntary nature of the benefit, establishing a quantitative threshold for "substantially all," and extending the applicability date to January 1, 2028.
Attached please find comments from the Blue Cross Blue Shield Association (BCBSA).