EBSA-2026-0232-0001, Dr. Tracey A Parnell Inc

As a Canadian physician and clinic owner who has provided care to patients with infertility and related reproductive health conditions for more than 30 years, I strongly request that restorative reproductive medicine (RRM) be explicitly included within the proposed Excepted Fertility Benefits framework. Throughout my years in practice, I have cared for many American patients who travelled to Canada seeking diagnostic and therapeutic care that they were unable to access in the United States. These patients were not simply seeking another fertility procedure. They were seeking physicians willing and able to investigate why they were experiencing infertility, recurrent pregnancy loss, menstrual-cycle abnormalities, endometriosis, polycystic ovary syndrome, hormonal dysfunction, male-factor infertility, or other reproductive conditions, and to provide treatment directed toward the underlying pathology. The shortage of accessible RRM care in the United States affects patients beyond its borders. When American patients cannot obtain appropriate root-cause reproductive healthcare close to home, they may be forced to travel internationally, pay privately, delay care, or proceed directly to treatments that bypass rather than investigate their reproductive dysfunction. Explicit inclusion of RRM within Excepted Fertility Benefits would expand access within the United States and would also reduce the need for patients to seek this care in Canada and elsewhere. I therefore request that the final framework explicitly recognize: 1.Restorative reproductive medicine as an eligible model of infertility and reproductive healthcare, including diagnostic, medical, surgical, hormonal, metabolic, fertility-awareness–informed, and other clinically appropriate treatment of underlying reproductive pathology. 2.Physicians and other eligible clinicians who are professionally trained in RRM in accordance with the standards and definitions established by the Institute for Restorative Reproductive Medicine in the United States (IRRMUS) or the International Institute for Restorative Reproductive Medicine (IIRRM), along with RRM allied health professionals who work with interdisciplinary teams or to whom they refer. 3.A comprehensive definition of infertility consistent with the IIRRM consensus document, recognizing infertility as a clinical condition characterized by the inability to become pregnant or sustain a pregnancy conceived through sexual intercourse and reflecting underlying male and/or female pathology. The terminology used in the final policy will be important. If RRM is not named explicitly, patients, employers, benefit administrators, insurers, and clinicians may interpret infertility benefits as applying primarily or exclusively to assisted reproductive technology or to clinician who purport to offer something restorative but lack the training to safely and effectively do so. Explicit recognition would make clear that patients may also receive medically necessary evaluation and treatment intended to identify, correct, and, where possible, restore reproductive function. Based on more than three decades of clinical experience, including caring for numerous American patients who could not obtain this form of care in their own country, I believe explicit inclusion of restorative reproductive medicine and professionally trained RRM clinicians is necessary to achieve meaningful access, patient choice, and comprehensive infertility care. Policy change in the USA often results in positive change in Canada and we look forward to RRM being more widely accepted and accessible. 1.Minjeur, M., Parnell, T., Stanford, J., Boyle, P., Arraztoa, J. A., Horodenchuk, Z., Suszczewicz, N., & McCarthy, K. (2026). Definition of Infertility and Indications for Fertility Evaluation: Consensus Document. Journal of Restorative Reproductive Medicine, 2, 1-7. https://doi.org/10.63264/zvpr3e66 2.RRM Clinician Recognition | International Institute for Restorative Reproductive Medicine