"If an employer decides to create an HRA to reimburse infertility treatment expenses, the COBRA treatment is more complex.... For purposes of assessing the employer's COBRA obligation in connection with [long-term fertility preservation ], the key question is whether the reimbursement of such expenses constitutes the provision of 'health care.' ... In general, reimbursement of costs related to adoption or surrogacy shouldn't give rise to a program that provides medical benefits -- meaning neither program should be subject to COBRA."

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