EBSA-2026-0232-0001, Catholic Medical Association

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Summary: The commenter supports the proposed action by arguing against the use of IVF, which they characterize as unethical and wasteful. They advocate for more holistic and compassionate fertility alternatives, such as the Preconception to Infancy project (P2i).
In the IVF process more babies die than are ever born. The babies that are eventually terminated, after lengthy periods of cold storage, do not voluntarily sacrifice their freedom, their potential or their lives. Their participation is mandated by people and professionals devoid of any empathy, compassion or respect for them as separate beings with unique DNA documenting and evidencing their being-ness. By contrast, RRM is more holistic, gentler, more respectful of human life, more compassionate, more empathetic and more generous. It is devoid of violence or neglect or disdain toward viable beings denied access to being "in utero." The Preconception to Infancy project (P2i) has addressed prevention in improving fertility for husband and wife, minimizing miscarriages, stillbirths, pregnancy complications, and reducing childhood illnesses. I attended the inaugural launch in 2012 and have seen many families implementing the program successfully without the need for IVF. It is credibly reported and likely true that IVF "costs" several $billions each year and fails half the time (46%). Why should our culture, our citizenry, and our medical community invest or profit that much for such a failing process and protocols? Some will tout the "success" of the 54% as having generated that many children for those unable to co-create. Yet, that is a shallow analysis which blind-eyes the ethical facet. The reported 46% failure rate is misleading, as is the 54% success rate. More objectively viewed, each and every attempt at IVF contains multiple failures--not only failures to generate a viable fetus to-term and to life--but destruction of other fertilized lives in being in each instance.

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