On February 18, 2025, President Trump issued executive order 14216 directing the Assistant to the President for Domestic Policy to provide policy recommendations on improving access to IVF and “aggressively reducing out-of-pocket and health plan costs for IVF treatment.”
Who this applies to:
Employers of any size sponsoring a medical plan
Go Deeper:
While the executive order does not facilitate any changes yet, employers may want to consider budgeting for potential future IVF coverage rules. Nothing is known yet about the direction this could take, but some possibilities might include:
- A possible coverage mandate
- Approximately one quarter of plans offer coverage and often limit to one or two rounds of IVF
- California recently passed a law mandating large group fully insured plans must cover three rounds of IVF, and fully insured small group carriers must offer IVF coverage for employers who want it, for plan years on/after July 1, 2025
- Diagnosis and treatment of IVF possibly being deemed an essential health benefit (EHB), which would mean:
- An annual or lifetime dollar limit could not apply
- In-network cost-sharing would be subject to the in-network out-of-pocket limit
- There may also be considerations for expanding what is reimbursable under flexible spending accounts (FSAs), health reimbursement arrangements (HRAs), and health savings accounts (HSAs). We will be watching for further guidance.

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