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Dr. Morse’s comment for the Infertility Insurance rule

Jennifer Roback Morse: comment on the infertility insurance rule proposed by the federal government, using the Heritage Action form.

July 9, 2026

I support the Departments of Labor, Health and Human Services, and Treasury’s proposed rule establishing excepted fertility benefits for root-cause care, and I urge the Departments to ensure that the final rule reflects true root-cause fertility care that treats infertility and honors every family.

I am opposed to the use of IVF.

I particularly support clearly defining infertility as a medical condition due to underlying symptoms and explicitly including Restorative Reproductive Medicine (RRM), NaProTechnology, FEMM, and NeoFertility, and general root-cause diagnostic care among the services employers may cover.

My husband and I experienced four painful years of infertility. Fortunately, we were blessed to find a doctor who helped us identify and treat the underlying causes of our low fertility. This was back in the 1980’s. I shudder to think what would happen to us today: we would likely be funneled toward invasive procedures that don’t treat the underlying problem.

Thank you for considering my comments.

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Paragraphs 2 and 4 are my personal comments.

Paragraphs 1, 3 and 5 were part of the template that appeared on the Heritage Action’s form.

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