EBSA-2026-0232-0001, Stanford, Joseph

Dear Federal Public Service Professionals, I write in strong support for the proposed rule to establish certain fertility benefits as a new category of limited excepted benefits. I am a clinician and researcher in restorative reproductive medicine. Among the patients I see and communicate with every day, I see a pressing need for access to fertility evaluation and treatment benefits. I support the expanded access that would be provided by the proposed rule. For every women in the United States who has a birth from IVF, there are 3-4 more who have a birth from non-IVF fertility treatment. Thus, it's essential to include the full spectrum of fertility treatments in this rule, not just IVF. (See https://pubmed.ncbi.nlm.nih.gov/21559776/). Most of my patients seek out me and my colleagues because they want to receive restorative reproductive medicine (RRM) for evaluation and treatment of their infertility. We have a high success rate in treatment (see https://pubmed.ncbi.nlm.nih.gov/35974874). I believe it's critical for patients and employers to make RRM a prominent part of the fertility benefits that are available through this rule. RRM includes medical evaluation and treatment for underlying "root" causes of infertility in women and men, medical treatment including ovulation induction medications, ovulation tracking with ultrasound, medications to support sperm production, semen analyses, and sometimes, restorative reproductive surgeries, such as laparoscopy to treat endometriosis in females, and varicocelectomy for males. Among the groups that are promoting an evidence-based approach to providing RRM, in my opinion, the most active and effective is the International Institute for Restorative Reproductive Medicine (IIRRM). I am a member of the Board of Directors of the IIRRM. If I can provide further information that would be helpful, please contact me. Sincerely, Joseph B. Stanford, MD, MSPH Professor Joseph B. Stanford and Kathleen B. Stanford Presidential Chair in Restorative Reproductive Medicine Spencer Fox Eccles School of Medicine University of Utah Salt Lake City, Utah