Public Comments for 06/17/2025 Health Insurance Reform Commission
If you haven't personally struggled with infertility, you know someone who has or you will in the future. 1 in 6 people worldwide struggle with infertility, per a WHO study. Millions of people who want to have children can’t. Being unable to have a child affects people physically, financially, and emotionally. As a person who married her high school sweetheart, I always thought having a family would come easy to us. We made assumptions that if we did everything "right," it would all work out. So we graduated from college, got married, and decided we would wait 5 years to have kids so that we could get established in our respective careers. 13 years later, we finally had our son via IVF, after a 7 year journey of 6 rounds of IUI, 2 rounds of IVF and three embryo transfers. This journey took many twists, turns, and breaks, however we are a story of hope! We, very luckily, are some of the very few in our great Commonwealth who have insurance coverage that includes fertility services through my husband's employer, so we only needed to take a few breaks to save up for medications and our out of pocket expenses, but nothing like many of my peers who did things like moving states where they could have mandated fertility coverage, changing to jobs outside of their expertise to places like Starbucks and Harbor Freight Tools to get family building coverage, or those who borrow from parents, equity in their homes, their 401ks or do online fundraisers to fund their family building journey. Infertility is a medical condition, not a choice. It does not discriminate. This medical condition has several treatments that are very effective, but many people do not have access to them because of cost, access to clinics, and the public perception is that fertility treatments are optional. To many, including my husband and I, it was the ONLY way to build our family. Having insurance coverage for IVF allowed us to breathe in this already daunting and emotionally charged process. It allowed us to invest in our communities, our careers, and our future family, AND it made us better Virginia residents. We are committed to my husband's employer because they took care of us. Now it is time for our Commonwealth to take care of the future families like ours, who don't know that they'll struggle yet, or are clinging to hope that their child will come, who read their insurance plans late at night and find out that they can breathe in their process, because this committee stood up for IVF and infertility coverage in Virginia. Thank you so much for your time reading our story. Resolve: The National Infertility Association has been a lifesaving organization for me with their local support groups. If you have any questions about infertility coverages, model plans, or legislation that can help families like mine, I would love to talk more and/or connect you with policy experts at Resolve. https://resolve.org/learn/financial-resources/insurance-coverage/fertility-insurance-coverage-myths-and-facts/
As you weigh the potential to add Fertility Preservation and IVF Benefits to the EHB plan, we just wanted to share our unique story about IVF access. After three years of trying to conceive and multiple types of interventions, we moved to IVF and had our daughter five weeks premature in August 2021. We also had a son in October 2023. We have not yet decided on additions to our family, but wanted to share that we have no regrets and would do it all over again. However, we wish some elements were easier. The financial and physical burden of IVF need to be addressed. We had the financial resources to engage in IVF, costing us approximately $75,000 in total, but many do not. The financial restraints add to the already heavy emotional burden and grief that we carry in this attempt to build our family. Ensuring both access to and resources for IVF coverage is crucial for the one in eight childbearing folks in the US who experience infertility and need Artificial Reproductive Technology to grow the families they desire. A physical fatigue also comes into play. We travelled nearly 2.5 hours each way for our clinic, since a reliable one was not near us. For one cycle, we did this for 21 days in a row. Again, we would do it all over again, but financial coverage would make an amazing process accessible to more folks in need of it. I have been advocating at my state workplace for nearly four years for IVF coverage and I am grateful to the legislator for considering this issue. Thank you for your time.
On behalf of the Oncology Nursing Society (ONS) and the more than 800 oncology nurse members in the state of Virginia, we would like to express our strong support for the inclusion of fertility preservation benefits for men and women undergoing cancer treatments, which may cause infertility, in the updated Essential Health Benefits (EHB) Benchmark Plan.
Please find attached a letter of support for the updating of the state's EHB benchmark plan to include coverage for medically indicated fertility preservation services. This letter is sent on behalf of the Alliance for Fertility Preservation.
Thank you for the opportunity to present written comments regarding the Step 2 Analysis of HB976/SB376 (2024). Attached is a full-version document of these comments. We appreciate the Bureau of Insurance for their openness and collaboration.
As a Virginia resident who cares deeply about those struggling to build their family in our state, I strongly urge you to include in vitro fertilization (IVF) and fertility preservation coverage in the update to Virginia’s 2028 Essential Health Benefit (EHB) Benchmark Plan. Infertility is a recognized disease, affecting 1 in 6 people globally according to the World Health Organization. It does not discriminate by income, race, or background. The American Medical Association and the American College of Obstetricians and Gynecologists also recognize infertility as a medical condition that deserves insurance coverage—just like other health conditions. Unfortunately, too many Virginians face insurmountable financial barriers to accessing the medical care they need to build a family. Without insurance coverage, IVF and fertility preservation are often out of reach. This is especially devastating for people who must preserve their fertility due to cancer or other urgent medical treatments. Others are forced into debt or are simply unable to begin treatment at all. At age 30 my husband became a cancer survivor. Due to his cancer treatment, our primary option for building a family is IVF. We’re currently in the middle of IVF treatment, which is emotionally, physically and financially taxing, especially as a young couple starting our family building journey. I need your support, along with the 1 in 6 in our state living with the disease of infertility and the thousands of Virginians diagnosed with cancer during their reproductive years. Please support Virginian families by including IVF and fertility preservation coverage in the update to the state’s EHB plan. Thank you! Sincerely, Liam Gandelsman
Hello. I am writing in support of adding Fertility Preservation (FP) and IVF benefits to the state’s Essential Health Benefit (EHB) Benchmark Plan. My husband and I were married in 2000, and two years later we began to actively try to conceive our first child. My husband was born with spina bifida, a birth defect that damaged his spine and left him permanently paralyzed below the waist. Doctors at the time knew of no reason why he wouldn't be able to produce children, but after 3 years of trying, it became clear we would need some help. After multiple tests to rule in or rule out the various factors that can affect fertility, and after attempts with both intrauterine insemination (IUI) and in vitro fertilization (IVF), our twin daughters were finally born in 2009. They are now bright, creative, compassionate young ladies finishing their first year of high school. At the time of our fertility journey, I was fortunate to be working for an educational company whose health insurance plan included fertility benefits. Though I was living in Virginia, the company was based in New Jersey, where fertility benefits were part of state law. The emotional ups and downs of trying to conceive can be intense, and I am grateful that the intense financial demands of treatment didn't have to add to that stressful time of life. I have friends with similar fertility journeys who were not so lucky. I honestly cannot say what path my husband and I would have chosen if we had had to pay the entire cost of fertility treatment out of pocket. It is entirely possible that our lovely daughters would not be here today. It is also possible that we would have begun parenthood with two beautiful children but a substantial debt to pay off as new parents raising twins. More people should have the chance that we had -- to have a family without the financial burden of the medical treatments necessary for people like us.
As a Virginia resident who cares deeply about those struggling to build their family in our state, I strongly urge you to include in vitro fertilization (IVF) and fertility preservation coverage in the update to Virginia’s 2028 Essential Health Benefit (EHB) Benchmark Plan. Infertility is a recognized disease, affecting 1 in 6 people globally according to the World Health Organization. It does not discriminate by income, race, or background. The American Medical Association and the American College of Obstetricians and Gynecologists also recognize infertility as a medical condition that deserves insurance coverage—just like other health conditions. Unfortunately, too many Virginians face insurmountable financial barriers to accessing the medical care they need to build a family. Without insurance coverage, IVF and fertility preservation are often out of reach. This is especially devastating for people who must preserve their fertility due to cancer or other urgent medical treatments. Others are forced into debt or are simply unable to begin treatment at all. At age 30 my husband became a cancer survivor. Due to his cancer treatment, our primary option for building a family is IVF. We’re currently in the middle of IVF treatment, which is emotionally, physically and financially taxing, especially as a young couple starting our family building journey. I need your support, along with the 1 in 6 in our state living with the disease of infertility and the thousands of Virginians diagnosed with cancer during their reproductive years. Please support Virginian families by including IVF and fertility preservation coverage in the update to the state’s EHB plan. Thank you! Sincerely, Maren Stunes-Gandelsman
June 12, 2025 Re: Include fertility preservation and treatment services to the Essential Health Benefits benchmark plan as enacted in HB 1609 Dear Esteemed Members of the Health Insurance Reform Commission, On behalf of FORCE (Facing Our Risk of Cancer Empowered), a national nonprofit organization that represents families facing hereditary cancers and our Virginia constituents, I am writing to express strong support for including fertility preservation and treatments as outlined in HB 1609 (which was recently enacted into law) in the Essential Health Benefits benchmark plan. This would facilitate fertility services in Virginia for those dealing with a medical diagnosis or treatment that may impair their ability to have children. Patients dealing with a frightening diagnosis—who are about to begin lifesaving, but potentially sterilizing treatments—have to make urgent, difficult decisions about their future hopes of becoming a parent. Similarly, women with an inherited genetic mutation predisposing them to ovarian cancer are advised to undergo surgery to remove their ovaries and fallopian tubes to avoid this deadly disease. For these individuals, fertility preservation is the only means available to protect their reproductive capability and may be the only viable option to build a biological family. Without insurance coverage for fertility services, patients cannot afford these procedures and fees and will face permanent, involuntary infertility. Fortunately, with the enactment of this legislation, most Virginians will have options when confronting this dilemma by ensuring that they have insurance coverage for effective, evidence-based options for preserving their fertility before their surgery or initiation of cancer therapy and pursuing future interventions to realize their dream of having children. These fertility services are consistent with national guidelines issued by leading medical associations, including the American Society of Clinical Oncology (ASCO) and the American Society for Reproductive Medicine (ASRM). FORCE has a strong presence throughout the state of Virginia. Members of our community facing cancer are desperate for a glimmer of hope to help them preserve the option of having children. We respectfully ask you to help patients facing infertility by supporting the addition of these services. Thank you for your consideration. Please don’t hesitate to contact me should you have any questions. Sincerely, Lisa Peabody Advocacy Manager 202-381-1357
I write as a father whose daughter lost her first child 20 weeks into her first pregnancy. Sarah and her husband Stephen underwent months of IVF treatments, incurring expenses far beyond what any growing family can plan for. And this I know, the emotional toll far exceeded those costs. You know this too. Virginia needs to lead in Family First policies, and insuring young families have the support and financial resources they need to grow and prosper is a fundamental State interest. It is a universal human interest as well. Including IVF as an Essential Benefit in Virginia’s 2028 Benchmark Plans is an absolutely necessary first step. There are no negatives in the political calculus of supporting growing families, so do the obviously correct thing and include IVF coverage as essential care for all Virginia residents, Thank you, Richard Moore Reston, Virginia.
Dear Members of the Health Insurance Reform Commission, Thank you for the opportunity to share my story in support of adding in-vitro fertilization (IVF) and fertility preservation as Essential Health Benefits in Virginia’s 2028 Benchmark Plans. Our daughter was conceived through IVF, but the journey to build our family was deeply painful and unnecessarily difficult because of insurance coverage barriers. After experiencing a pregnancy loss at 21 weeks following a naturally conceived pregnancy, I was referred by my OB for IVF. We had discovered a genetic condition with an 50% chance of recurrence that would require PGT testing to avoid the same outcome one as my prior pregnancy. All of this information was uncovered in the aftermath of the devastating loss of a very wanted pregnancy. Initially, my insurance denied fertility treatment coverage. Despite my diagnosis, my Virginia insurance plan refused to cover IVF based on my situation not meeting the too narrow definition of “infertility”. I had to go through a lengthy and traumatic appeal process, retelling my deeply personal story to 1-800 lines and faceless representatives, hoping to reach someone humane enough to approve the coverage so we could build the family we so desperately wanted. Ultimately, after 8 devastating months we were able to switch insurance providers and access the medical care we needed. It was a nightmare—compounding my grief with unnecessary red tape and financial strain. Access to IVF is not a luxury—it is a medical necessity. No one should have to endure the trauma of pregnancy loss and then be told they don’t “qualify” for treatment because their body didn’t behave in a textbook manner. This situation left me feeling punished for something entirely out of my control. States like Maryland and Washington, D.C. already require coverage for IVF, and Virginians deserve the same opportunity to grow their families without facing devastating financial and emotional hurdles. Adding IVF and fertility preservation to Virginia’s Essential Health Benefits would provide hope to thousands of residents across the Commonwealth, as well as honor our states position as the first successful IVF birth in the United States. Please do the right thing and support the inclusion of these services. Virginia families deserve it. Sincerely, Sarah Mong
Dear Health Insurance Reform Commission Members, My wife and I struggled with infertility for over 3 years. During this time period, neither of our insurance companies covered infertility treatments. This resulted in over $15,000 in out-of-pocket medical costs for my wife and myself. It is infuriating to be paying for insurance that does not cover your medical needs. My wife eventually had to leave a job she liked in her field to a job she does not like in a non-related career field to gain access to fertility coverage. I am writing to ask you to make sure all insurance plans offered in Virginia cover infertility treatments to make sure no one else has to go through what my wife and I did. Thank you for your time, John Meszaros Midlothian, VA
It is important for Virginians to have access to IVF benefits with their health care. I have PCOS and I am the 1 in 6 that experiences infertility. We started trying to conceive in our late 20's and had barriers, so we decided to seek IVF treatment. As someone who has benefitted from IVF coverage from her job, I have been able to set aside funds to provide for our future rather than spend it on fertility treatments. Couples utilize IVF out of necessity and it is already emotionally, physically, and mentally stressful. Removing the financial component will make it easier for couples in Virginia to focus on the other stressors. People are already spending thousands per year in healthcare and it would be an absolute blessing for Virginia families to be able to utilize IVF without taking out significant debts. Also, infertility covers a broad range of conditions that necessitate the use of IVF. If couples want to create families with help, they should be able to do so. My husband and I wouldn't be parents to our two daughters without it.
My spouse has lived in VA his whole life and I have lived here since my family moved when I was 16. We met at high school in Leesburg and now live in Reston. When we were 31 years old, we were diagnosed with unexplained infertility. I tried medication to ensure ovulation, we did several rounds of artificial insemination and we tried adoption and everything failed -- and we lost $20k to the failed adoption. When we were 34 years old, we found out that my spouse's company based in MA offered comprehensive fertility benefits and IVF became affordable to us. We immediately began the steps to undergo it. After two miscarriages, the 3rd time work and our son is now 7 years old. After my spouse changed jobs, we lost that benefit but the same month that I turned 39 years old, my company - based in DC - began offering fertility benefits through our health insurance. I immediately began the process to do IVF again and it worked the first time. Our daughter is almost 2.5 years old. Without the insurance coverage help from our out-of-state employers, the cost of IVF would have been too high for us to do multiple times to have our children. We did explore every other less expensive option but ultimately, IVF was the only way we could afford to become parents, especially after the loss of $20k to the failed adoption. We don't know why we couldn't have children on our own and we were not particularly old when we began to try to have children (we were both about to turn 30 when we began). There are many more people like us who would be unable to have children without the help of IVF or related fertility treatments and having health insurance coverage can make it affordable and possible. Thank you.
Virginia taxpayer citizens don’t need higher insurance rates, unqualified physicians, and more government interference.
Dear Chair Sullivan and Members of the Health Insurance Review Commission, The Virginia Association of Hematologists and Oncologists (VAHO) and the Association for Clinical Oncology (ASCO) are grateful for the opportunity to provide the attached comments on the potential inclusion of fertility preservation coverage in Virginia’s essential health benefits benchmark plan. We urge the Commission to include this benefit in the benchmark plan. Please let me know if you have any questions about cancer care; we're happy to be a resource. Best, Sarah Lanford
Comments Document
June 17, 2025 Delegate Rip Sullivan, Chair Health Insurance Reform Commission General Assembly Building, 4th Floor 201 North 9th Street Richmond, VA 23219 RE: Include fertility care treatment in Virginia’s EHB plan Dear Chairman Sullivan and Members of the Health Insurance Review Commission: On behalf of RESOLVE: The National Infertility Association, we write in strong support of HB 1609 and urge the Commission to include Fertility Preservation and In Vitro Fertilization (IVF) as Essential Health Benefits (EHB) in Virginia’s benchmark plan for 2028. According to the CDC, 1 in 7 women in the U.S., age 15-49, have trouble getting pregnant or sustaining a pregnancy. Infertility does not discriminate by income, race, or background. The American Medical Association and the American College of Obstetricians and Gynecologists also recognize infertility as a medical condition that deserves insurance coverage—just like other health conditions. Unfortunately, too many Virginians face insurmountable financial barriers to accessing the medical care they need to build a family. Without insurance coverage, IVF and fertility preservation are often out of reach. The high out-of-pocket costs of IVF and fertility preservation are financially devastating, particularly for those undergoing time-sensitive treatments like chemotherapy. These Virginians deserve the opportunity to build their families without facing insurmountable financial barriers or going into significant debt. The Virginia Bureau of Insurance estimates that roughly 1,600 Virginians may be eligible for fertility preservation annually, and that the cost to cover those individuals would range from $0.01 to $0.24 per member per month. A similar analysis found the cost to cover IVF coverage was estimated to range from $1.00 to $2.50 PMPM for one IVF cycle annually, and an estimated $3.50 to $5.50 PMPM for unlimited number of cycles. This is a negligible price to pay so that patients without the financial means can make important family planning decisions and thousands of Virginia families could gain access to medical care they desperately need to grow their families. We are happy to provide you additional information on this issue as RESOLVE has been providing support, information, and advocacy for the infertility community since 1974. I can be reached at barb.collura@resolve.org and our website is www.resolve.org. Sincerely, Barbara Collura President and CEO RESOLVE: The National Infertility Association