HHS Should Define and Promote Restorative Reproductive Medicine as Root-Cause Treatment for Infertility, Not Just Fund IVF
Source: Merlot Fogarty and Emma Waters. "What Thousands Of Women Told HHS About The Limits Of IVF." August 7, 2026. thefederalist.com
The Gist
The authors argue that thousands of public comments to a federal health agency show that women want fertility treatment that finds and fixes the root causes of infertility (like hormone imbalances) rather than just jumping to IVF. They use personal success stories and survey data to argue that the government's new fertility benefit rule should officially define infertility this way and promote this root-cause approach instead of treating IVF as the default option.
Conclusion
The final HHS fertility benefit rule should explicitly define infertility as a symptom of underlying conditions and name, explain, and prioritize root-cause restorative reproductive medicine (RRM), rather than defaulting to IVF as the standard treatment.
Premises
- The federal comment period on the proposed 'excepted fertility benefit' drew an unusually high 4,652 comments, with a majority (over 62%) calling for root-cause care and explicit naming of restorative reproductive medicine in the final rule.
- Numerous personal testimonies from women describe successful pregnancies and improved health outcomes after switching from standard IVF-oriented care to RRM approaches that diagnosed and treated underlying hormonal and metabolic conditions.
- Independent surveys (Carrot 2026, J.L. Partners 2025) show large majorities of women and Americans want less invasive, root-cause, personalized fertility treatment options before resorting to IVF.
- Standard fertility care often fails to test for or treat underlying conditions (e.g., requiring three miscarriages before testing), leaving many root causes undiagnosed and untreated.
- RRM approaches address the health of both partners and treat underlying causes, whereas IVF bypasses the body's own reproductive function without treating the underlying health issues.
- IVF carries known drawbacks, including increased adverse health outcomes for mother and baby and the large-scale ethical/logistical problem of embryo storage (an estimated 1.5 million frozen embryos in the U.S.).
- Current insurance models are not structured to cover the time-intensive testing and treatment RRM requires, creating a financial barrier that could be addressed by the new HHS rule.
Assumptions
- Public comments submitted during the regulatory comment period are representative of broader patient preferences and not skewed by advocacy campaigns or selection effects.
- The individual success stories cited are representative of typical outcomes for RRM rather than being anecdotal or unusually favorable.
- Treating 'underlying conditions' via RRM is generally effective and scalable to the broader population experiencing infertility, not just to a subset of cases with identifiable hormonal/metabolic causes.
- IVF and RRM are functionally in competition for regulatory attention and resources, such that prioritizing RRM in the rule benefits patients more than maintaining a neutral or IVF-focused approach.
- Patients' stated preference for less invasive options (per surveys) translates into a policy obligation for regulators to structure benefits around those preferences.
- The rise in infertility rates is substantially attributable to undiagnosed underlying conditions that RRM can identify and treat, rather than other factors (age, environmental factors, etc.) that may not respond to RRM.