EBSA-2026-0232-0001, Veranova Health

My name is Timothy Jakubisin, Fairview Park, Ohio. I am co-founder and current Board President of Veranova Health, a nonprofit women and family medical clinic in Cleveland, Ohio metropolitan area. The clinic specializes in providing medical care focused on protecting, restoring and maintaining human fertility utilizing cycle awareness and restorative reproductive medicine. The care provided by Veranova Health is especially attractive to Orthodox Jewish, Muslim and Catholic populations who desire care which can be summarized as being provided compliant with the Ethical and Religious Directives of the United States Conference of Catholic Bishops. (“ERD’s”) The practice was opened a little over three years ago and has grown rapidly, currently all providers are booked out for three months with waiting lists for new patients. The difficulty of the practice is finding physicians trained in Restorative Reproductive Medicine. Veranova Health providers consist of MD, DO, PA’s, NP’s and CNM with training including NaPro Technology, Marquette, Sympto-Thermal, FEMM and Integrative Medicine. Speaking for myself, but also representing the board of the practice, and the practices growing patient base of over 3,000, I can say that we are very much in favor of the proposed rule, particularly that it 1) provide more funding for training of RRM providers, 2) that it be supportive of services addressing male factor infertility, 3) that it allow employers broad discretion to tailor medical coverage in order to allow providers to select only RRM rather than no coverage in the situation where RRM was perceived by the employer as a lower cost, more effective, more long term beneficial, or more ethical option, and 4) allow better CPT code reimbursement for RRM services which, due to their addressing an individual’s root cause health issues leading to infertility, are more time consuming at the patient visit level than approaches which working around a couples bodies or masking symptoms with pharmaceuticals are ultimately more expensive due to technological costs. With regards to male factor infertility, we find that this is often not addressed in the current IVF paradigm. As an RRM clinic following the ERD’s we collect sperm samples collected in intercourse which has been established to obtain better samples. We have had experience with couples advised for IVF, who refused IVF, and after much searching and wasted time and money found an RRM provider who determined male factor infertility. One memorable example the male had a cyst blocking sperm migration. Had the couple not sought alternatives to IVF the cyst would not have been detected. Searching for root causes of infertility led to a better health outcome for the male and to normal sperm counts. Regarding employers’ broad discretion in tailoring their infertility treatment options, this is important since many privately held employers influenced and guided by their religious convictions are impeded from offering fertility care that includes IVF. We are familiar with many privately held employers who would will not consider fertility care which includes IVF due to their management’s moral convictions. Employers are also interested in solutions that limit medical costs and reduce future costs of both the parents (by addressing root cause health issues) and the conceived children (by not introducing medical complications linked to IVF). Regarding point four above, cost reimbursement, our clinic struggles due to poor CPT reimbursement afforded by private clinics using an insurance model. Large hospital systems primarily use a pharmaceutical approach to address symptoms of women (such as excessive bleeding, painful periods) and refer to IVF for infertility. And they have 200%+ reimbursement due to their leverage with insurance companies. An RRM clinic looks for a root cause which takes more time and labs but a private clinic using an insurance model gets reimbursed less. Our clinic uses an insurance model, accepting Medicaid and Medicare so that services are available to all. However, this is very difficult to attract providers because we need to compensate our providers below market level due to low reimbursement and seek donor funding to close the gap between practice revenue and costs. Alternatively, some clinics are moving to Direct Primary Care (DPC) model which provides higher reimbursement to the providers but often excludes the poor or uninsured. Adequate RRM reimbursement rates are essential through insurance models to providing accessible care to all. In summary, we see a strong community desire for Restorative Reproductive Medicine. Lack of sufficient RRM providers, lack of adequate care for male factor infertility, the ethical and cost implications of IVF, and systemic under compensation for RRM care should be addressed in the Proposed US Federal Rule on Excepted Fertility Benefits. We are highly support of passage of the rule.