EBSA-2026-0232-0001, Freedom FertilityCare Services of Central Ohio

On behalf of Freedom FertilityCare Services of Central Ohio, Mount Carmel Health Services of Ohio NFP Program, Mount Carmel St. Ann's of Westerville, Ohio NFP Program, I, Jen Loos, FertilityCare Practioner, submit this testimony in support of the the proposed regulation change. Women in the United States of America have the "Right to be Informed" about every medical option that can support, cure, or heal their reproductive medical conditions. This includes insurance reimbursement for Restorative Reproductive Medicine. When a woman in medical need goes to her primary care doctor or OB/GYN she has a resonable expectation that she will be offered and informed of care that will heal her health concerns. Whether this is hormonal, surgical, or functional, her doctors, that she recieves medical care, from have a duty to help her and do no harm. When her care is delayed by outdated, missinformed, or excluding research supported methods and treatments her care is not supporting her — it is harming her physically, emotionally, and reproductively. In the work that our collective group performs in Central Ohio we meet with female teenagers, single women, and couples who are in need of chemical free and natural family planning information, restorative medical referrals, and restorative infertility support. More often than not, medical insurance does not cover these resources. At best, they offer reduced rates or reimbursement. This is unacceptable in a medical industry that offers other chemical, superficial, and synthetic hormonal methods of family planning for free nationwide. And that is to say nothing of predatory financially lucrative practices and procedures that only provide pregancy support without addressing underlying root causes of sub/in-fertility. This disconnect between what is covered and provided vs what is excluded and denied is shameful to a nation such as the USA. Restorative Reproductive Medicine stands as a suppressed standard of care for the last 50-years in the USA. Starting with NaPro Technology developed in Omaha, Nebraska at the Creighton University in the 1970's. In the 50-years that have followed, demand by women and couples for better care in medical offices has gone largely ignored, despite independent studies, peer-reviewed research, and thousands of positive result patient cases. Women deserve better and giving them the right to know what options are available to them is the right step with this rule change on a federal level. Additionally, research shows that addressing infertility in the USA is a path to reversing our need for high-rates of immigrant workforce by simply restoring the fertility of women and couples. This research is shown here: Stanford JB, Harris ER, Najmabadi S, Smith KR. Potential increase of the U.S. total fertility rate resulting from restorative treatment of unresolved subfertility: a simulation study. Frontiers in Reproductive Health. 2026. doi:10.3389/frph.2026.1856175 (https://www.frontiersin.org/journals/reproductive-health/articles/10.3389/frph.2026.1856175/full) Not only does allowing for full-access to restorative care allow for underlying medical issues to be addressed, thereby restoring the health of Americans who have been left-behind by current medical practices in the average doctor's office — but this also works to restore the sovereignty of the USA by healing and increasing towards full fertility replacement rates of our natural-born workforce. This is not a case of just making babies, this is about the restoration of fertility of the citizens of the USA who for decades have been denied restorative care in pursuit of quick fixes or simply telling women nothing is wrong this them. We can do so much better. Americans deserve that. Women and couples need it. https://www.freedomfertilitycare.com/creighton-model https://www.mountcarmelhealth.com/event/2026/08/20/creighton-model-fertilitycare-system-introductory-session https://www.fertilitycare.org/creighton-model-system/ See attached file(s)