EPPC Scholar Responds to CDC’s Proposed Notice on Assisted Reproductive Technology 


Published January 29, 2024

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On January 29, 2024, EPPC scholar Natalie Dodson submitted a public comment responding to a proposed notice by the Centers for Disease Control and Prevention (CDC) that would modify the reporting requirements for assisted reproductive technology (ART). 

ART, which includes in vitro fertilization, surrogacy, egg donation, and sperm donation, is an almost entirely self-regulation industry and poses serious risk to both women and children. As such, proper oversight by the CDC through clinic record requirements is important. 

Dodson, a Policy Analyst with EPPC’s HHS Accountability Project, wrote

Assisted reproductive technology (ART) is a primarily self-regulated industry. It addresses highly emotional, sensitive, and challenging reproductive situations such as infertility. Ethical and safety questions surrounding ART have historically been ignored by state and federal governments. As such, the CDC, via the FCSRCA, plays an essential role in the oversight of ART and ought to fulfill its duty to require adequate reporting.  

Dodson urged the CDC to retain the reporting requirements it proposed to eliminate and suggested additional reporting requirements the CDC could adopt. Finally, Dodson called out the CDC for proposing to eliminate targeted data verification, even though the ART industry lacks accurate and robust data.  

A number of medical professionals and policy experts also submitted comments responding to the CDC’s proposal, including: 


Natalie Dodson is a Policy Analyst at the Ethics and Public Policy Center, where she works on a range of initiatives focusing on sexuality, gender ideology, religious liberty, health care rights of conscience, abortion, and nondiscrimination in EPPC’s HHS Accountability Project.

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