Excepted Fertility Benefits
Impact view for Heritage Foundation
EBSA-2026-0232EBSARIN 1210-AC40comments due 2026-07-13
Parallel dockets checked: IRS-2026-0562 (IRS): 0 comments
4.4 to 1
Root-cause comments led Expand IVF access comments.
All form letters plus own-words comments on each side. Unclear comments are left out.
8 in 10
commenters with a clear side backed the Root-cause side.
Out of 4,379 comments with a clear side. Unclear comments are left out.
Total comments
4,652
posted, a floor · retrieved 2026-07-17
Total showing: Root-cause
3,566
form letters 2,639 + own words 927 · of all 4,652 comments
Total showing: Expand IVF access
813
form letters 483 + own words 330 · of all 4,652 comments
Unclear
271
own words, side not clear · of all 4,652 comments
Coalition
24 vs 16
org letters, our side vs the other side · hand-checked
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.
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.
cumulative totaldeadline day (2026-07-13)
Linear scale: a running total of comments posted. Dates are when comments posted, not when they came in.
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.
| Campaign | Organization | Position | Confidence | Matches | Share | Posted |
|---|---|---|---|---|---|---|
| heritage_action | Heritage Action for America | Root-cause / restorative | confirmed | 418/4650 | 9.0% | 418 |
| usccb_votervoice | U.S. Conference of Catholic Bishops (VoterVoice) | Root-cause / restorative | confirmed | 2189/4650 | 47.1% | 2,189 |
| expand_access | unattributed | Expand IVF access | unattributed | 297/4650 | 6.4% | 297 |
| expand_access_cost_a | unattributed | Expand IVF access | unattributed | 125/4650 | 2.7% | 125 |
| expand_access_cost_b | unattributed | Expand IVF access | unattributed | 61/4650 | 1.3% | 61 |
| reject_ivf_coverage | unattributed | Root-cause / restorative | unattributed | 23/4650 | 0.5% | 23 |
| restore_act_definition | unattributed | Root-cause / restorative | unattributed | 9/4650 | 0.2% | 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.
Attribution boundary
How each side's total showing is built across all 4,652 posted comments. Form letters are direct campaign output; own-words comments count toward the side a person read them onto.
3,122form letters, direct campaign output
1,257own words, backing a side
271own words, side not clear
Own-words comments count toward each side's total showing, not to one group's tool. A person read every one to set its side. We do not say any one group recruited any one commenter.
How the three tiers work
- Tier 1, form letters: exact copies of a known form letter, plus letters a group filed under its own name. This is direct campaign output.
- Tier 2, own words: comments a computer could not tie to a form letter. A person read each one and set its side. They count toward that side's total showing.
- Tier 3, total showing: tier 1 plus tier 2 on each side. This is the headline number. Unclear comments are counted on their own, on neither side.
How we sorted the own-words comments
Each comment was read and sorted into one of three groups by what the writer wanted paid for, not just whether they liked the rule. Root cause means they backed care that finds the cause, or wanted less IVF coverage. Expand access means they wanted IVF or fertility care kept or paid for. Unclear means the note was thin, backed only the rule, or wanted both. A script checked that all 1,528 ids were tagged once and that every quote was real text from its comment. Four fresh readers then re-graded a random 195 note sample with no view of the first tags. They matched every root cause call, missed 3 in 100 expand access calls, and split on 22 in 100 unclear calls. Most of those were soft pleas that we kept as unclear. We changed a tag only when clearly right, and fixed 11. We also checked that both sides met the same bar. Of notes with clear stance words, 91 percent of pro IVF and 99 percent of root cause got a side. That gap is 8 points, under the 10 point limit.
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
Canadian Institute for RRM
Show all 24
About these organizations
RRM Foundation RRM Foundation is a 501(c)(3) public charity in Camp Hill, Pennsylvania. It funds teaching and research on restorative reproductive medicine. That approach treats the root causes of infertility. Through RRM Academy, it trains clinicians, teaches patients, and runs a free research library. It gives no clinical care. It has no money stake in treatment choices. Its comment backed the rule. It asked that coverage put diagnosis first, before assisted reproduction.
U.S. Conference of Catholic Bishops The United States Conference of Catholic Bishops is the national body of Catholic bishops in the U.S. Based in Washington, D.C., it sets Church positions on faith, morals, and public policy. Its comment opposed treating IVF coverage as a standard workplace benefit, citing embryo loss and freezing. It asked the rule to favor restorative reproductive care instead and to protect employers' and employees' religious objections.
The Heritage Foundation The Heritage Foundation is a conservative think tank in Washington, D.C. It studies and publishes policy views on the economy, social issues, and national security. It filed its own comment on the rule, under its name, and backed the plan. It urged that restorative and root-cause fertility care be covered alongside IVF in employer benefit plans.
Heritage Action for America Heritage Action for America is the advocacy arm of The Heritage Foundation. It runs grassroots and legislative campaigns on conservative issues. For this rule, it posted a template comment on its website. Supporters could submit it under their own names. The template asked for restorative reproductive medicine to be named in the rule. Heritage Action is mainly a campaign group, not a clinical or research body.
International Institute for Restorative Reproductive Medicine (IIRRM) The International Institute for Restorative Reproductive Medicine is a UK-registered charity. It promotes this field around the world. It offers clinician training, courses, and a research journal. It also runs a yearly science congress and a member list. Its Board of Trustees signed the docket comment. The comment asked the rule to name this care as a covered benefit, alongside IVF.
Institute for RRM United States The Institute for Restorative Reproductive Medicine United States is the U.S. chapter of IIRRM. It supports training and recognition for clinicians in this field. Its comment backed the proposed rule. It asked for clear coverage of this care and of fertility awareness methods. It also asked for a clear path to recognize providers.
Canadian Institute for RRM The Canadian Institute for Restorative Reproductive Medicine, in its comment, calls itself a national chapter of IIRRM. Canadian doctor Tracey A. Parnell leads it. No standalone website could be found. Its comment backed the proposed rule. It asked that restorative reproductive medicine be a covered, diagnosis-based option, alongside IVF. It cited Quebec's past IVF funding costs as a caution.
Dr. Tracey A. Parnell Inc Dr. Tracey A. Parnell Inc is the medical practice of Dr. Tracey Parnell. It is in Cranbrook, British Columbia. The clinic offers family medicine, immigration exams, electrolysis, and restorative reproductive care. Parnell also works with IIRRM as a global director of communications. She leads its Canadian chapter. Her comment asked that this care be named in the new rule.
Family Research Council Family Research Council is a Washington, D.C. nonprofit founded in 1983. It studies and publishes policy views on marriage, family, religious liberty, and abortion. It works from a conservative Christian view. It lobbies Congress and federal agencies. It runs a news outlet called The Washington Stand and makes radio and digital content. It speaks for conservative Christian and pro-life groups. It works to shape law and policy along those lines.
Center for Bioethics & Culture Network The Center for Bioethics & Culture Network is a California-based 501(c)(3) nonprofit. It studies ethics in medicine and new biology. Its topics include surrogacy, egg and sperm donation, and genetic research. It makes films, articles, podcasts, and public talks. Its audience includes students, journalists, and policymakers. It says its goal is to show how new medical technology affects people. Its contributors come from varied religious and secular backgrounds.
Center for Bioethics & Culture Network (Tennessee chapter) The Tennessee Center for Bioethics & Culture is a Tennessee-based 501(c)(3) nonprofit that has run for about 20 years. It publishes articles and teaching material for the public on bioethics topics such as reproductive technology, genetics, and end-of-life care, and is led by physician D. Joy Riley. Despite the similar name, its own website states no formal chapter tie to the national Center for Bioethics & Culture Network. The two appear to be run separately.
MyCatholicDoctor Foundation MyCatholicDoctor Foundation is a 501(c)(3) nonprofit. It supports a national network of Catholic doctors and other clinicians. They provide telehealth, home-visit, and in-person care in line with Catholic moral teaching. The foundation funds charitable and teaching programs and clinical support. It works alongside the related MyCatholicDoctor telehealth platform. It serves patients who want care that fits Catholic values. It says it welcomes patients of all faiths.
Catholic Medical Association The Catholic Medical Association is a membership group in Fort Washington, Pennsylvania. It is for Catholic doctors, dentists, medical students, and other health workers. It offers ongoing education, a yearly conference, local guilds, and student chapters. It keeps a doctor directory. It publishes the peer-reviewed journal The Linacre Quarterly. It also speaks up on conscience rights and health policy for its members.
National Catholic Bioethics Center The National Catholic Bioethics Center is a 501(c)(3) research and teaching group in Pennsylvania. It was founded in 1972. It focuses on Catholic teaching in health care and medical research. It offers ethics advice, training, and policy analysis. It serves Catholic dioceses, hospitals, seminaries, and health workers. It also shares teaching material with the public. Its stated mission is to protect human dignity in medicine and research.
National Assoc. of Catholic Nurses The National Association of Catholic Nurses, USA is a 501(c)(3) nonprofit founded in 1993. It is based in St. Johns, Florida. It supports nurses and nursing students who follow Catholic moral teaching. It runs local and regional councils. It offers scholarships, spiritual formation, and ongoing education. It belongs to the International Catholic Committee of Nurses. It speaks for Catholic nurses and other health workers who support its mission.
Alliance Defending Freedom Alliance Defending Freedom is a conservative Christian legal advocacy group founded in 1994 and based in Scottsdale, Arizona. It provides free legal help and funds lawsuits on religious freedom, free speech, life, parental rights, and family issues, and has argued many cases before the U.S. Supreme Court. It also does policy work and trains allied attorneys. It represents people, churches, and groups whose legal aims match its Christian conservative view.
Ethics and Public Policy Center The Ethics and Public Policy Center is a Washington, D.C. think tank founded in 1976. It studies law, culture, and public policy. It works from a Jewish and Christian view. Its scholars publish articles, policy papers, and public comments on federal rules. They also testify before lawmakers and file court briefs. Its topics include bioethics, family policy, religious liberty, and constitutional law. Its readers include lawmakers, journalists, and religious groups.
Minnesota Family Council Minnesota Family Council is a Christian advocacy group based in Minnesota. It has been active since the 1980s. It works on state policy on abortion, religious liberty, schools, and family issues. The group tracks bills and publishes voter guides. It offers legal help through a linked legal arm. It also rallies churches and faith groups to take political action. It speaks for state residents with conservative Christian views.
Maryland Family Institute Maryland Family Institute is a nonprofit advocacy group in Annapolis, Maryland. It lobbies on state policy on abortion, marriage, religious liberty, and parental rights. The group publishes policy briefs. It hosts events and prayer meetings. It asks supporters to contact lawmakers. It speaks for Maryland residents with conservative, faith-based views on family policy. It works to shape state law to match those views.
American Assoc. of Pro-Life Obstetricians & Gynecologists (AAPLOG) AAPLOG is a professional medical group founded in 1973. It is for obstetricians and gynecologists who oppose abortion. It gives members clinical guides, training, a yearly meeting, and legal support. That support covers expert testimony on abortion-related bills. It runs a public list to help patients find like-minded doctors. It represents board-certified OB/GYNs across the country. It calls itself the largest such group in the world.
St Gianna Center for Women's Health & FertilityCare St. Gianna Center is a Florida-based teaching and advice center. It teaches the Creighton Model FertilityCare System. That is a fertility-charting method for natural family planning. The method also helps spot health problems. The center connects patients with NaProTechnology care. That care treats painful periods, irregular bleeding, and PCOS. Certified FertilityCare practitioners and doctors provide its services. It serves women who want natural, drug-free care.
The Center for Restorative Reproductive Surgery The Center for Restorative Reproductive Surgery is a surgical practice near Atlanta, Georgia. Dr. Nicholas Kongoasa leads it. It focuses on excision surgery for endometriosis. It also does other surgery to restore reproductive anatomy and fertility. Its stated approach treats the root cause. It favors that over drugs, or over bypassing the problem with assisted reproduction. It treats patients with pelvic pain and infertility from across the country and abroad.
Billings Ovulation Method Association Billings Ovulation Method Association is a U.S. nonprofit that trains teachers and offers classes in the Billings Ovulation Method. This is a natural fertility-awareness method used to plan or avoid pregnancy without hormonal birth control, and to track reproductive health. The group certifies instructors, including health care workers, and offers classes, webinars, apps, and materials to the public. It represents users of the method and the network of certified teachers across the country.
Science Alliance for Life and Technology (SALT) Science Alliance for Life and Technology is a new 501(c)(3) nonprofit, introduced in 2025. It is made up of scientists and ethicists. They aim to steer biology and technology research toward protecting human life from conception on. It publishes commentary and teaching material on ethics in science. It presents itself as a science-based check on research it sees as wrong. As a new group, its public footprint is still small.
Expand IVF access 16
Show all 16
About these organizations
American Society for Reproductive Medicine (ASRM) The American Society for Reproductive Medicine is a nonprofit group for doctors, scientists, nurses, and other staff who work in fertility care. It was founded in 1944. It is based in Washington, D.C. and Birmingham, Alabama. ASRM sets medical guidelines, publishes a research journal, and holds a yearly conference. It also lobbies on issues like insurance coverage for fertility care. It has almost 8,000 members in over 100 countries.
RESOLVE: The National Infertility and Family Building Association RESOLVE is a nonprofit group for people affected by infertility. It was founded in 1974 and is based in McLean, Virginia. RESOLVE runs peer support groups and offers facts on treatment options and insurance coverage. It also pushes for laws that widen access to fertility care and lower its cost. It runs local support groups across the country and serves thousands of members each year.
IVI RMA North America IVI RMA North America is a group of fertility clinics. It is part of IVIRMA Global, a large network of fertility clinics around the world. In North America it runs about two dozen IVF labs. Its clinics are in states such as New Jersey, Pennsylvania, Florida, and California. It offers IVF, egg donation, fertility preservation, and genetic testing. It is a for-profit clinic network, not a trade group. It treats patients who seek fertility care.
Blue Cross Blue Shield Association Blue Cross Blue Shield Association is a national group of 34 independent, locally run Blue Cross and Blue Shield health plans. It covers every U.S. state and several territories. It is based in Chicago. It licenses the Blue Cross and Blue Shield names to its member plans. It also runs shared programs, such as coverage for federal workers, and speaks for its member plans on federal health rules. Member plans cover more than 100 million people.
Aflac, Inc. Aflac is a public insurance firm based in Columbus, Georgia. It was founded in 1955. Through its U.S. and Japan arms, it sells extra insurance plans, such as coverage for accidents, cancer, disability, dental, vision, and life. People buy these plans on their own or through work as an added benefit. Aflac is one of the largest sellers of this kind of coverage in the U.S. It is also a major seller of such plans in Japan.
American Benefits Council American Benefits Council is a trade group based in Washington, D.C. It speaks for more than 220 large U.S. firms that offer health, retirement, and other work benefits to staff. The group pushes its views to Congress, federal agencies, and courts on rules that affect these benefits. Its focus areas include health coverage, 401(k) retirement plans, and paid leave. Its member firms, taken together, offer benefits to a large share of U.S. workers.
Business Group on Health Business Group on Health is a nonprofit group based in Washington, D.C. It speaks for large U.S. firms, mostly Fortune 500 firms, on health benefit rules and plans. Its member firms give health coverage to more than 60 million staff, retirees, and family members. The group shares data and best practices among its members on how to run health benefit plans. It also speaks for these firms on federal health rules, such as rules on plan design and cost.
The ERISA Industry Committee The ERISA Industry Committee, known as ERIC, is a trade group based in Washington, D.C. It speaks for large firms, including many Fortune 100 and Fortune 500 firms, on rules that affect work benefits. Its focus areas are health care, retirement, and paid leave. ERIC lobbies lawmakers, files comments on new rules, and takes part in lawsuits, including fights to keep federal law ahead of state benefit rules. It speaks for firms that offer benefits, not for workers or patients.
Pharmaceutical Care Management Association (PCMA) PCMA is a Washington, D.C. trade group. It speaks for pharmacy benefit managers. Those firms run prescription drug plans for insurers, employers, unions, and government programs. It lobbies on drug pricing and health benefit policy. It publishes research and cost data. It represents its member firms before Congress and federal agencies. It speaks for the pharmacy benefit industry, not for patients or providers. It engages on health benefit rules that affect plan design and drug costs.
Fertility Advocacy Coalition for Technology (FACT) FACT is a coalition of IVF technology and equipment firms. Its members include CooperSurgical, Vitrolife, and AutoIVF. It formed to back policies that protect and widen access to IVF technology. It lobbies for supportive laws. It backs new fertility technology. It runs public campaigns about IVF. It speaks for commercial IVF-technology suppliers. It does not speak for patients, clinicians, or a religious or civic base.
Fertility Providers Alliance The Fertility Providers Alliance is a trade group set up by fertility care providers. Its members include clinic networks, independent clinics, and individual specialists. It works to widen access to fertility care and to shape policy on it. It says it also stands up for the patients its members treat. It acts as a shared voice for IVF and fertility clinics. It does not speak for a single firm or a patient base.
Fertility Business Initiatives Institute Fertility Business Initiatives Institute, also called Fertility LIFE Initiatives, is a small 501(c)(3) nonprofit. It promotes the Billings Ovulation Method, a natural fertility-awareness charting method. It teaches this method to pro-life and family-life groups and to the public. Its stated aim is to give women simple, non-drug tools to track their own cycles. Despite its name, it does teaching, not industry or provider lobbying.
Hadassah, The Women's Zionist Organization of America Hadassah is a large American Jewish volunteer women's group, founded in 1912. It has about 300,000 members across the country. It funds a hospital system in Israel, the Hadassah Medical Organization. It also runs teaching, public policy work, and youth programs. It has joined efforts to widen health coverage for fertility care. That work included group letters to Congress on access to that care.
Tzedek Association Tzedek Association is a New York-based faith-linked nonprofit. Rabbi Moshe Margaretten founded it. Its main work has been criminal justice reform and aid for people in need. More recently it has also backed wider access to fertility treatment. It has supported bills such as the HOPE with Fertility Services Act. It also welcomed the 2026 executive order on IVF access. It frames coverage for infertility as a family-building and cost issue.
Puah Puah, also known as Machon Puah, is an Israel-founded group active in many countries. It helps Jewish people and couples go through fertility treatment under Jewish law. Its advisors mix rabbinic training with knowledge of reproductive medicine. They offer counseling and oversee IVF lab work to keep it within Jewish law. They also help with Sabbath-related medical needs, funding, and education. It serves observant Jewish patients seeking fertility care.
National Health Law Program The National Health Law Program is a national nonprofit legal advocacy group, founded in 1969. It has offices in Washington, D.C., Chapel Hill, and Los Angeles. It uses lawsuits, policy work, and public education. It works to protect and widen health care access and civil rights for low-income and underserved people. Its work covers Medicaid and reproductive health. It also covers disability rights, language access, and immigrant health care. It stands for patients and communities facing barriers to care.
Reading list 34
Org candidates we have not assigned yet. The tool finds candidates; a person assigns each side after reading.
- Ovulio Corp. ·0326
- Center for Bioethics and Culture ·0613
- Blue Cross Blue Shield Association (BCBSA) ·0619
- American Society for Reproductive Medicine ·0662
- American Medical Association ·0663
- PEONY Family, Inc. ·0749
- University of Navarra ·0967
- St. Anne Catholic Church ·1232
- College for Reproductive Biology ·1241
- Alliance for Fertility Preservation ·1475
- Institute of Restorative Reproductive Medicine of America ·2191
- The Center for Restorative Reproducitve Surgery ·2705
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
- 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.
- 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.
- 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.
- 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 does not copy a template, so it cannot be tied to one group's tool. We read those comments and count each one toward the side it backs, as part of that side's total showing. So each campaign figure is a floor on the real total, and a large own-words count is not proof that no group was organizing.
- 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.
DataREADME.txt · attachments.csv · bodies.csv · campaigns.csv · classifications.csv · coalition.csv · headline.csv · ownwords_receipts.csv · timeline.csv · unassigned_candidates.csv
Generated 2026-07-17T18:00:38Z · analysis schemaVersion 1 · census · all 4650 comments checked · threshold=0.7 · built by docketscope (stdlib-only; all charts inline SVG)