Last week, the Department of Health and Human Services released a draft of its latest strategic plan, which will guide the agency from 2018 to 2022. Near the top of the document, the agency presents its mission statement: HHS activities “cover a wide spectrum of activities, serving and protecting Americans at every stage of life, beginning at conception” (the emphasis is mine).

This is a religious definition of life, not a scientific one. Health and Human Services is a government organization. Its actions should be evidence-based, not faith-based, and this decidedly unscientific language should be eliminated from its strategic plan.

As an infertility specialist, I witness human fertilization in the laboratory every day. The human egg is a single living cell and it becomes a one-cell embryo if it successfully combines with a live sperm. No new life is formed — the egg and the sperm were already alive — and fertilization is not instantaneous. Nearly 48 hours pass from the time sperm first bind to the outside of the zona pellucida, the human eggshell, until the first cell division of the fertilized egg. The two newly formed cells then have the potential to give rise to a human being, but only if they are appropriately nurtured so that they continue to divide and then successfully implant in the uterus.

A preimplantation embryo has the theoretical potential to become a human life, but it cannot be considered on the same moral plane as a human life.


As women age, the proportion of eggs with chromosomal abnormalities increases dramatically. If such eggs are fertilized, they implant rarely, or result in a miscarriage. In vitro fertilization has shown human reproduction to be a highly inefficient process. Even a chromosomally normal embryo will successfully implant and result in a live birth only about half the time. This is true whether fertilization takes place in the body or in the laboratory.

The multicellular pre-implantation embryo cannot be equated with a human being. It is a collection of stem cells, each of which has the capacity to grow into any part of the placenta, as well as fetal tissues and organs, but it is not itself a new human life. It is also potentially more than one individual, since identical twins are the result of a single implantation.

From a scientific perspective, life doesn’t begin at any one point, it is a continuum. For HHS to define it as beginning at conception is a transparent attempt to justify restrictions on certain contraceptives as well as abortion. It may also have an unintended consequence: the restriction of infertility treatments, especially in vitro fertilization.


Now nearly 40 years old, IVF has revolutionized infertility treatment. More than 7 million babies have been born worldwide as a direct result of this technology, though it fails as often as it succeeds. If a pre-implantation embryo were to be considered a human being, then its lack of implantation during IVF would logically have to be considered a human death. Fertility clinics would not be able to function if they could be accused of harming human life in the process of trying and failing to achieve a successful pregnancy.

A preimplantation embryo has the theoretical potential to become a human life, but it cannot be considered on the same moral plane as a human life. We should insist that the Department of Health and Human Services be driven by science and data, not faith-based belief. All those concerned with the unscientific nature of the current HHS strategic plan draft have until Oct. 27 to email their comments to HHSPLan@hhs.gov. We need to embrace the founders’ doctrine of separation of church and state, to keep faith and religion separate from the administration of our nation’s healthcare.

Dr. Richard Paulson is a professor of obstetrics and gynecology at USC, the director of the Keck School of Medicine’s infertility program, and the president of the American Society for Reproductive Medicine (ASRM.org). @DrRPaulson

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