Excepted Fertility Benefits

Impact view for Heritage Foundation
EBSA-2026-0232EBSARIN 1210-AC40comments due 2026-07-13
4,652 comments posted so far, a floor and not a count of what came in · retrieved 2026-07-17
Parallel dockets checked: IRS-2026-0562 (IRS): 0 comments
Total comments
4,652
posted, a floor · retrieved 2026-07-17
Aligned form letters
56.8%
of all 4,652 comments · every comment checked · threshold 0.7
Campaign output
418
counted across all 4,652 comments · a floor on comments received
Coalition
24 vs 16
org letters, our side vs the other side · hand-checked
Own words
1,528
of all 4,652 comments, written in own words · side unknown until read
Org letters analyzed
40
55 attachments · 2,531,874 chars pulled

Timeline

Comments posted each day on a log scale, or the running total on a linear scale. The deadline day is marked in a different color.
1101001,000May 13May 19May 27May 29Jun 3Jun 10Jun 12Jun 16Jun 25Jul 92,164Jul 131,870Jul 14
1101001,000May 13May 20May 29Jun 8Jun 12Jun 172,164Jul 13
1101001,000May 13May 29Jun 122,164Jul 13
comments per daydeadline day (2026-07-13)
Log scale: a big deadline-week push can be 100 times an average day. Dates are when comments posted, not when they came in.
Deadline week: 2,374 comments (51.0% of total).
Backlog: the full total is 2.1x the count posted on the deadline day itself. Posting lags receipt, since agencies post in batches.

Campaigns

Form-letter templates matched across all 4,652 posted comments. Counts are exact; a matched form letter can still stand for many comments received.
A computer can safely count only exact copies of known form letters. 1528 of the 4650 comments were written in someone's own words. A person has to read those to know their side.
CampaignOrganizationPositionConfidenceMatchesSharePosted
heritage_actionHeritage Action for AmericaRoot-cause / restorativeconfirmed418/46509.0%418
usccb_votervoiceU.S. Conference of Catholic Bishops (VoterVoice)Root-cause / restorativeconfirmed2189/465047.1%2,189
expand_accessunattributedExpand-access / IVF-inclusiveunattributed297/46506.4%297
expand_access_cost_aunattributedExpand-access / IVF-inclusiveunattributed125/46502.7%125
expand_access_cost_bunattributedExpand-access / IVF-inclusiveunattributed61/46501.3%61
reject_ivf_coverageunattributedRoot-cause / restorativeunattributed23/46500.5%23
restore_act_definitionunattributedRoot-cause / restorativeunattributed9/46500.2%9
heritage_action · Heritage Action for America418 (9%)
usccb_votervoice · U.S. Conference of Catholic Bishops (VoterVoice)2,189 (47%)
expand_access · unattributed297 (6%)
expand_access_cost_a · unattributed125 (3%)
expand_access_cost_b · unattributed61 (1%)
reject_ivf_coverage · unattributed23 (0%)
restore_act_definition · unattributed9 (0%)
heritage_action · confirmed · template preview & where it came from
confidence confirmedtemplate 3,994 charsduplicates +0
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. …
Where it came from: Click-to-submit tool hosted at heritageaction.com/support-care-for-healthy-families; confirmed by a submitter's own written disclosure ('Paragraphs 1, 3 and 5 were part of the template that appeared on the Heritage Action's form' — Dr. Jennifer Roback Morse, Ruth Institute) and by an independent Center for Bioethics & Culture Network 'Take Action' post linking the same campaign URL.
usccb_votervoice · confirmed · template preview & where it came from
confidence confirmedtemplate 841 charsduplicates +0
This comment is with reference to the proposed rule on Excepted Fertility Benefits, RIN 1210-AC40. I thank the Administration for taking seriously the heartbreaking challenge of infertility while not imposing a new insurance mandate on people, especially people of faith. I support the proposal of ne…
Where it came from: USCCB Action Center campaign on the VoterVoice platform at votervoice.net/USCCB/Campaigns/138581; a Jul 12 Aleteia article ('By Monday night: Submit comments on IVF, fertility') drove readers to this exact campaign link, and the phrasing mirrors USCCB's own separately-filed 17-page comment almost verbatim.
expand_access · unattributed · template preview & where it came from
confidence unattributedtemplate 1,364 charsduplicates +0
I strongly support the proposed rule to expand access to fertility benefits through excepted benefit coverage options. Infertility is a medical condition that affects millions of Americans. For many, treatments such as IVF represent the only path to building a family. Expanding access to this care i…
Where it came from: Full canonical letter recovered by census-scale discover clustering 2026-07-17; the earlier config text was the first half of this letter and under-matched (1 of ~300 copies). Not yet traced to a sponsoring campaign page.
expand_access_cost_a · unattributed · template preview & where it came from
confidence unattributedtemplate 448 charsduplicates +0
I'm submitting this comment in support of the proposed rule to expand access to fertility benefits through excepted benefit coverage options. At $20,000–$30,000 per cycle, cost is the single biggest barrier keeping people from care they need — that shouldn't be the deciding factor in whether someone…
Where it came from: Found by whole-docket discover clustering on 2026-07-17 (census of 4,650 bodies). Not yet traced to a sponsoring campaign page.
expand_access_cost_b · unattributed · template preview & where it came from
confidence unattributedtemplate 407 charsduplicates +0
I'm submitting this comment in support of the proposed rule to expand access to fertility benefits through excepted benefit coverage options. IVF can cost $20,000–$30,000 per cycle and for many people facing infertility, that cost is the only thing standing between them and the chance to build a fam…
Where it came from: Found by whole-docket discover clustering on 2026-07-17 (census of 4,650 bodies). Not yet traced to a sponsoring campaign page.
reject_ivf_coverage · unattributed · template preview & where it came from
confidence unattributedtemplate 2,702 charsduplicates +0
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…
Where it came from: Found by whole-docket discover clustering on 2026-07-17 (census of 4,650 bodies). Not yet traced to a sponsoring campaign page.
restore_act_definition · unattributed · template preview & where it came from
confidence unattributedtemplate 838 charsduplicates +0
Infertility is 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 would otherwise be possible through intercourse with a person of the opposite sex, as the RESTORE Act defines i…
Where it came from: Found by whole-docket discover clustering on 2026-07-17 (census of 4,650 bodies). Not yet traced to a sponsoring campaign page.
Across all 4,652 posted comments, form letters backing root-cause total 2,639.
Across all 4,652 posted comments, form letters backing expand-access total 483.
7 campaigns found · 67.2% of all posted comments matched a known template.
Credited campaign output is a floor on the real total, never the whole total. See the attribution boundary below.

Attribution boundary

What this analysis can tie to a source, and what it cannot across all 4,652 posted comments. Credited campaign output is a floor on the real total, never the whole total.
67.2%credited to a campaign tool
40org letters, credited to themselves
32.9%credited to no source
Own-words organizing leaves no textual fingerprint. No source is not the same as no organizing. Credited campaign output is a floor, never the whole total.
How each tier is bounded
  1. Credited to a campaign tool: comments that match a known template at the threshold, which is copy-paste campaign output. Each is tied to a source we confirmed by evidence (see each campaign's confidence).
  2. Credited to the filing group: groups on record under their own name, including attachment letters. We tie these to the group itself, hand-checked in the docket config.
  3. Credited to no source: original writing (own-words aligned plus unclassified). Some groups ask supporters to write in their own words, through social media, newsletters, or word of mouth. That writing has no textual fingerprint. No source is not the same as no organizing.

Coalition map

Organization letters by side. A person sets each side by hand in docket_config.json. 📎 marks groups whose content came as an attachment.
Evidence for 40 of 40 orgs: v0.1 report coalition map, read in full 2026-07-15.
Root-cause / restorative 24
RRM Foundation 📎 6 pp ·4273
U.S. Conference of Catholic Bishops
The Heritage Foundation
Heritage Action for America
International Institute for Restorative Reproductive Medicine (IIRRM)
Institute for RRM United States
Canadian Institute for RRM
Dr. Tracey A. Parnell Inc ·4625
Family Research Council
Center for Bioethics & Culture Network
Show all 24
Center for Bioethics & Culture Network (Tennessee chapter)
MyCatholicDoctor Foundation
Catholic Medical Association
National Catholic Bioethics Center
National Assoc. of Catholic Nurses
Alliance Defending Freedom
Ethics and Public Policy Center
Minnesota Family Council
Maryland Family Institute
American Assoc. of Pro-Life Obstetricians & Gynecologists (AAPLOG)
St Gianna Center for Women's Health & FertilityCare
The Center for Restorative Reproductive Surgery
Billings Ovulation Method Association
Science Alliance for Life and Technology (SALT)
Expand-access / IVF-inclusive 16
American Society for Reproductive Medicine (ASRM)
RESOLVE: The National Infertility and Family Building Association
IVI RMA North America
Blue Cross Blue Shield Association
Aflac, Inc.
American Benefits Council
Business Group on Health
The ERISA Industry Committee
Pharmaceutical Care Management Association (PCMA)
Fertility Advocacy Coalition for Technology (FACT)
Show all 16
Fertility Providers Alliance
Fertility Business Initiatives Institute
Hadassah, The Women's Zionist Organization of America
Tzedek Association
Puah
National Health Law Program
Reading list 34
Org candidates we have not assigned yet. The tool finds candidates; a person assigns each side after reading.
Show all 34
  • The Nat. Catholic Bioethics Center; Catholic Medical Assoc.; National Assoc. of Catholic Nurses, USA ·2806
  • Ukrainian Association of Perinatologists ·3035
  • Fertility Advocacy Coalition for Technology ·3233
  • American College of Obstetricians and Gynecologists ·3770
  • Susan B. Anthony Pro-Life America ·3776
  • St Gianna Center for Women’s Health & FertilityCare ·3794
  • Flourish Adoption Ministries, INC. ·3852
  • Progyny, Inc. ·4062
  • The American Association of Pro-Life Obstetricians and Gynecologists (AAPLOG) ·4065
  • Southeastern Fertility Center ·4142
  • Health Data Safe Foundation ·4163
  • IFPC Legal Center ·4165
  • NeoFertility LLC ·4269
  • Center for Reproductive Rights ·4270
  • Kalandjai Inc. ·4378
  • The Tennessee Center for Bioethics & Culture ·4380
  • Institute for Restorative Reproductive Medicine United States ·4381
  • Women's Reproductive Health Foundation ·4491
  • Bioethics Center for the Practices of Maternal, Family, and Mitochondrial Health EIN 93-3950855 ·4495
  • International Institute for Restorative Reproductive Medicine ·4502
  • Council, Vicki ·4634
  • Canadian Institute for Restorative Reproductive Medicine ·4642

Attachments coverage

How many attachments we downloaded and pulled text from, across all posted comments and org letters.
4,650comments checked (all posted + org letters)
47with attachments
58files downloaded
55files with text pulled
2,531,874characters pulled
31.4 MBtotal size
34attachment-only comments
PDF58 (100%)
Could not read: ·0662 (downloaded_no_text) · ·4495 (downloaded_no_text) · ·4381 (downloaded_no_text)
34 attachment-only comments. For these, the real content sits only in an attached file, with pasted text under 200 chars. This analysis read those attachments.

Caveats and methods

  1. The total of 4,652 comments is a posted count, taken 2026-07-17T07:58:21Z. Agencies post comments in batches. Near a deadline, or just after, many are still waiting to post. So this total is a floor on how many came in, not the final count.
  2. We matched each comment body we checked against the known form letters. We used full-text similarity, at a 0.70 threshold. In all, we checked 4,650 of the 4,652 posted comments. We could not fetch 2 comment bodies, so they are left out.
  3. Every share and count here is an exact count, not an estimate from a sample. So there is no confidence interval and nothing is projected.
  4. How we credit campaigns: campaign figures count only two things. First, comments that match a known template, which is copy-paste campaign output. Second, organization letters on record. Some groups instead ask supporters to write in their own words, through social media, newsletters, or word of mouth. That writing leaves no textual fingerprint, so we credit it to no source. It lands in the own-words and unclassified counts. So each campaign figure is a floor on the real total, and a large unclassified count is not proof that no group was organizing.
  5. Attachment coverage: we pulled text from 55 of 58 attachment files, across 47 comments that had attachments. 34 of the 47 comment(s) with extracted attachment text and a fetched body keep their real content only in the attachment. Their pasted text runs under 200 characters. Files that failed text extraction are left out of every text-based figure.
Generated 2026-07-17T15:08:39Z · analysis schemaVersion 1 · census · all 4650 comments checked · threshold=0.7 · built by docketscope (stdlib-only; all charts inline SVG, zero external requests)