EBSA-2026-0232-0001, Respect Life Ministry

As members of the Respect Life Ministry at our Catholic parish, we support the proposed rules regarding excepted benefits to establish CERTAIN fertility benefits as a new category. We ask that the following provisions be part of the new measures: 1. Restorative Reproductive Medicine (RRM) is covered as “best practice” to diagnose and treat infertility. RRM respects the beliefs of our faith and poses no cultural or ethical dilemma for couples. RRM recognizes fertility as a “clinical condition, with the symptoms of inability to conceive or sustain a pregnancy, that points to underlying female or male pathology”. It treats the root cause of infertility. Https://iirrm.org/what-is-rrm/ In 2025, the Dept. of Health and Human Services sponsored the MAHA Institute's Women's Health and Fertility Roundtable panel on “Root Causes, Restorative Treatment, and Informed Consent”. Their initiative demonstrates the HHS considers RRM as a respected standard of care. Https://www.mahainstitute.us/womens-roundtable-roundup/ 2. IVF and other forms of Assisted Reproductive Technologies (ART) are NOT included. IVF results in the creation of embryos (children) who may exist in a frozen state indefinitely. IVF also causes the loss (death) of thousands of children at the blastocyst or early embryonic stage. The reasons for loss include: genetic abnormalities; being unwanted because they are “surplus”; and implantation failure (National Institute of Health). 3. If the original ruling remains, the question of how the COST of ART procedures will affect the overall cost of health insurance for both the insurance providers AND the consumers, must be answered.4. The final ruling must be clear that the provision of infertility benefits is voluntary, to protect an employer's freedom of religion under the First Amendment to the Constitution of the USA. 5. If the original ruling remains, it must include conscience protections for those employers who would ONLY support restorative treatments from RRM-trained healthcare professionals, and not IVF or other forms of ART. Thank you for this opportunity to comment.