EBSA-2026-0232-0001, CAMEN
CAMENSupportAdvocacy
Summary: CAMEN ASSOCIATION advocates for a federal framework that includes coverage for Restorative Reproductive Medicine (RRM) and fertility awareness-based methods (FABMs). They argue that addressing root-cause pathologies is more cost-effective and patient-centered than relying solely on assisted reproductive technologies like IVF.
On behalf of CAMEN ASSOCIATION (www.camen.org), an organization dedicated to the promotion, education, and scientific research and advancement of fertility awareness and natural fertility regulation, we welcome the opportunity to submit this public comment regarding the proposed federal rule on fertility benefits.
Our organization strongly advocates for a federal framework that guarantees comprehensive access to Restorative Reproductive Medicine (RRM) and fertility awareness-based methods (FABMs). Based on our extensive clinical and educational experience, true patient-centered reproductive healthcare must encompass root-cause diagnosis and restorative treatments rather than defaulting exclusively to assisted reproductive technologies (ART) such as In Vitro Fertilization (IVF). Standard IVF protocols heavily prioritize high-tech interventions over exhaustive medical investigations. In our experience, a substantial number of couples who seek restorative care after experiencing failed IVF cycles are found to have underlying functional, hormonal, or anatomical abnormalities—both male and female—that were neither identified nor treated during their previous conventional treatments. Restorative Reproductive Medicine systematically diagnoses and treats these underlying pathologies. From an economic perspective, integrating RRM into fertility benefits significantly reduces the financial burden on families and the healthcare system. Correcting root-cause pathologies resolves infertility even for subsequent pregnancies and lowers the overall reliance on repeated, highly invasive, and expensive IVF cycles, making public and private healthcare expenditures far more sustainable.
For these reasons, CAMEN strongly recommends that the definition of comprehensive fertility benefits explicitly mandates the coverage of the full continuum of care: including fertility awareness charting, targeted diagnostic testing, medical/surgical restoration, and restorative reproductive medicine.
The Board of Directors CAMEN association