In February, President Donald Trump signed an executive order to expand access to in vitro fertilization. The Departments of the Treasury and Labor have finalized language that allows employer-based insurance plans to offer fertility benefits to make IVF more affordable and accessible. While infertility is a growing and devastating problem, promoting IVF as the answer is fraught with ethical and practical issues. We ask you to submit a comment highlighting the problems with this rule.
The United States is in the midst of a fertility crisis. With the current average of 1.5 babies per woman of childbearing age, we will see a significant decline in the American population in the coming decades. The Trump administration recognizes this and acknowledges the value that families bring to a thriving nation. The intention to create healthy families is commendable; however, serious ethical issues abound. First, during the IVF process, embryos — i.e., human lives — are destroyed because they are deemed defective or otherwise undesirable. Even if pre-implementation sorting and screening are not done, the failure rate for IVF is extraordinarily high, and often not disclosed to vulnerable parents-to-be. Additionally, with IVF, the underlying issues that prevented fertility in the first place are never addressed, leaving couples with the same health problems as before.
The proposed rule allows fertility benefits to be recognized as a ‘limited excepted benefit’ with a lifetime dollar limit of $120,000. This would allow employers to provide fertility benefits in addition to the medical coverage they already offer, but as a separate policy — similar to a vision or dental plan. A single round of IVF can cost between $12,000 and $30,000, and many women need multiple rounds to achieve successful implantation. This means the limit could be reached quickly, perhaps for just one pregnancy.
Too many problems exist with IVF to create a new benefit. Embryo screening is encouraged to eliminate those undesirable traits or conditions. When too many embryos are created, the remainder are often destroyed. This eugenics approach allows parents and medical professionals to play God, deeming which human life is valuable and which should be destroyed.
Doctors who perform IVF procedures do not adhere to the moral obligations that will create a successful outcome for that child after birth. Same-sex couples, single mothers, and surrogates have the same access to IVF as a two-parent heterosexual couple. Children who are raised with a mother and father in the household are shown to have healthier physical development and more sustainable future relationships.
There is one good part of this rule, though. The insurance plan also provides coverage for a range of alternative fertility methods. Procedures such as lab work, imaging, and certain surgeries for problems such as endometriosis would fall under this plan. This means that more successful methods such as Restorative Reproductive Medicine (RRM), body literacy, and fertility awareness-based methods would qualify. These serve to educate women on their bodies’ natural cycles, identify abnormalities, and cure the underlying problems through diet, exercise, medicine, and surgery. These are meant to heal the body for the long-term rather than force a pregnancy. Not only are these much cheaper and healthier, but they also cut out the need for IVF. Our top healthcare leaders should be championing methods that create healthy individuals rather than unsafe solutions.
RRM has proven to be the healthiest way to address infertility by identifying, diagnosing, and treating the root cause of the infertility long-term rather than putting a band-aid over persistent physical issues. However, this limited benefit is an unnecessary vehicle for its promotion. Many established insurance plans cover all or a portion of these procedures already. Instead, federal funding that promotes and funds abortions, birth control, IVF, and other artificial reproductive technologies should be diverted to education on RRM for young women and medical professionals.
We have created a sample comment to submit to the Departments of the Treasury and Labor, but we highly encourage you to edit it to fit your words. If each comment is different, by law, they are required to reach each one and respond. Submit your comment before Monday, July 13th, to the Departments of Treasury and Labor here.
To learn more about IVF, join us at Eagle Council 54 in Nashville, Tennessee, from September 24–26. Author Katy Faust will be one of our keynote speakers addressing the implications of IVF and surrogacy.
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Sample Comment: (Please copy and paste into the Comment Section here)
With the recent proposal to provide expanded access to in vitro fertilization, I ask that you eliminate any coverage or discount of IVF in the new limited exception benefit. IVF often fails to achieve the outcomes parents expect. During the process, embryos containing human lives are destroyed after being deemed unwanted or defective. Additionally, the underlying issues that prevented fertility in the first place are never addressed, leaving parents with the same health problems afterward.
IVF is also very costly. A single round of IVF can cost between $12,000 and $30,000 per round, with women needing multiple rounds for a successful implantation. The lifetime dollar limit of $120,000 could be reached quickly for just one pregnancy. IVF is not the most successful, ethical, or cost-effective method.
If the rule must remain, I ask that you only allow healthy alternatives to IVF, such as Restorative Reproductive Medicine, body literacy, and fertility awareness-based methods that heal the body long-term, thus producing healthier parents and babies. These serve to educate women on their bodies’ natural cycles, identify abnormalities, and cure the underlying problems through diet, exercise, medicine, and surgery. These are meant to heal the body for the long-term rather than force a pregnancy. Not only are these much cheaper and healthier, but they also cut out the need for IVF.
Additionally, infertility must be adequately defined as consistent with standard medical criteria — something that is absent in the current rule. I propose the following:
Infertility means a symptom of an underlying disease or condition within a person’s body that makes it difficult or impossible to successfully conceive and carry a live child to term, where it should otherwise be possible through intercourse with a person of the other sex. A diagnosis of infertility often occurs after 12 months of targeted intercourse for women under 35, or after six months of targeted intercourse without the use of a chemical, barrier, or other contraceptive method for women 35 and older.
However, this limited benefit is ultimately an unnecessary vehicle for its promotion. Many established insurance plans cover all or a portion of these procedures already. Instead, federal funding that promotes and funds abortions, birth control, IVF, and other artificial reproductive technologies should be diverted to the education of young women and medical professionals on RRM.
Creating healthy families is notable, especially since we are nearing a fertility crisis in the United States. However, IVF does not produce the healthy family that parents expect. I ask that you seek more sustainable, life-giving methods.