How to Submit a Grievance

Membership in The Society for Ethics in Egg Donation & Surrogacy (SEEDS) is voluntary. Our mission is to work together with our members and peers to help define the highest ethical standards in the Assisted Reproductive Technology industry. While attorneys and medical professionals are licensed and regulated by individual states, only New York State regulates egg donation and surrogacy programs. It is the goal of SEEDS that all of its members will meet or exceed the Ethical Standards it has established.

To that end, the SEEDS Grievance Committee was established to provide a pathway for those in the industry, both professionals and consumers, to voice concerns or register complaints regarding alleged violations of SEEDS Ethical Standards. The Committee cannot offer legal advice, nor can we help someone file a grievance. It also is important to remember that the SEEDS Ethical Standards are not enforceable rules. It is the goal of the Committee to assist the parties in reaching a resolution to a legitimate problem or creating understanding where there was misunderstanding.

Grievances must meet all of the following criteria to be considered:

  • The grievance is against a current SEEDS member or potential SEEDS member who has started the membership process.
  • The grievance alleges a violation of a SEEDS Ethical Standard.
  • The grievance must be submitted through the SEEDS Grievance Submission form, which authorizes the inclusion of supporting documentation and witness statements if so desired.
  • The Complainant or entity filing the grievance has had a direct interaction, transaction, or service-related engagement with the SEEDS member or potential SEEDS member, and the grievance pertains to that interaction, transaction or service-related engagement.
    • Note: Only an attorney may submit a grievance on behalf of another individual or entity and only with their express, written consent.
  • The grievance pertains to an issue that arose within the previous 12 months.
  • The grievance is not in pre-litigation (e.g., voluntary mediation, arbitration, or other settlement negotiations) or litigation, and it has not been resolved through court action, mediation, arbitration, or settlement.

Grievances Not Handled By SEEDS Grievance Committee: The SEEDS Grievance Committee does not handle grievances involving:

  • Employee-employer disputes, provided they don’t involve a violation of a standard.
  • Disputes between Intended Parents and Donors or Intended Parents and Surrogates unless the point of the grievance is to address the way in which the member handles intended parents, donor and/or surrogates in violation of standards.
  • Discrimination claims so long as they are not violative of SEEDS standards, such as refusal to work with a group that is protected by those standards.
  • Civil rights claims so long as they are not violative of SEEDS standards, such as refusal to work with a group that is protected by those standards.
  • Chapter 7 bankruptcy cases.
  • Business-to-business grievances for collection purposes, but the Grievance Committee can address when an agency has taken funds of a clients inappropriately.
  • Companies that are out of business, unless they are still members.
  • Issues based solely on dissatisfaction with a company’s price.
  • Cases of “buyer’s remorse,” provided that it is limited to a decision by an intended parent, surrogate and/or donor that has no basis other than a change of mind, and is not based on a violation of a standard.

Important Notes:

  • Representation of Truth: By submitting a grievance, the Complainant affirms that it is a truthful account of their experience with the business.
  • Notification to Business: An exact copy of the grievance, including who filed the grievance and the nature of the grievance, and any accompanying documents or witness statements, will be sent to the business against which the Complainant is filing the grievance if, and only if, the Grievance Committee determines that there is a valid Grievance as set forth below.
  • Non-Member Businesses: If the grievance is against a business that is not a current or applying SEEDS member, the SEEDS Grievance Committee will maintain the submitted information confidentially in case the business applies for membership in the future.

To file, please use the link on this website to open up the grievance form. Click on the “SUBMIT A GRIEVANCE” button below to proceed.

Step 1: Submission of the Grievance

  • Within 21 business days of the filing of the submission, the Grievance Committee will review the submission form and determine if the grievance meets the requirements stated above. *Note: The day a document is received/filed will be considered day 0 in all cases for calendaring purposes.

Step 2: Notification to the Complainant

  • If the Grievance has been rejected, the notification will include:
    • Notification that the Grievance did not meet the qualifications.
    • The reason the Grievance did not meet the qualifications.
    • a copy of the SEEDS grievance policy.
  • If the Grievance has been accepted for review, the notification will include:
    • Notification that the Grievance meets the criteria for consideration.
    • The reason the Grievance Committee accepted the grievance.
    • A copy of the SEEDS Grievance policy.

Step 3: Notification to the Accused

  • If the Grievance meets the criteria, the accused member or potential SEEDS member will be notified in writing within 5 business days of the acceptance of the Grievance.
  • The notification will include:
    • A copy of the Grievance and all accompanying documents and witness statements.
    • A copy of the SEEDS Grievance policy.
    • The reason the Grievance Committee accepted the Grievance.
    • A timeline for submitting a written response (within 10 business days).

Step 4: Response by the Accused

  • Within 10 business days of the date the notification of the Grievance was sent, the accused party may respond in writing to grievance@seedsethics.org, addressing the allegations and providing:
    • Their account of the events.
    • Supporting evidence, including documentation and witness statements if they deem appropriate.

Step 5: Response by the Complainant

  • Within 10 business days of the receipt of the response to the Grievance, that document shall be supplied to the entity filing the Grievance, giving the Complainant a 10 business day opportunity to provide a rebuttal, including supporting evidence and any witness statements, if they deem appropriate.

Step 6: Ensuring Due Process

    • Once the Complainant’s response has been provided, the Grievance committee will, within 10 business days, ask both parties to determine (within 10 business days) if they would like to be heard on the complaint or their response thereto.
    • If neither party says yes, then the Grievance Committee may address the grievance itself and decide whether the grievance is valid or not and how to address the Grievance with the Complainant within 21 business days.  Upon so determining, the Grievance Committee will provide both parties with their determination in writing.
    • If either party says yes, then the Grievance Committee must hold a hearing at the convenience of the parties but in no event later than 21 business days to hear each party’s presentation. At that presentation, an opportunity will be given by both parties to present witnesses, documents and arguments and to cross examine the other side’s witnesses. The rules of evidence will not apply to such hearing, but more weight will be given if evidence is supplied by the Complainant party than third parties.
    • The entire time for the hearing cannot exceed 2 hours, with each party being given an hour to present their case.  In rare exceptions a party may request a longer time and the Grievance Committee can decided whether to so grant it, but in no instance may more than 8 hours be granted to any hearing and if so much time is needed then the Committee may choose to spread the hearing over more than one day.  The hearing may be held by video conferencing.
    • A recording shall be made of the hearing.
    • Any member of the SEEDS Grievance Committee that has been party to a Grievance, or who has an identified or potential conflict of interest with either the Complainant or the Accused, will announce this to the Committee.  If the Committee Member believed there is a conflict, they will recuse themselves. If they do not believe there is a conflict, the Committee will vote (by majority) to remove that Committee Member or to have that Committee Member participate in hearing a specific Grievance.
    • In addition, confidentiality of all witnesses and parties must be maintained by the Committee.

Step 7: Decision Making

  • Within 21 business days of the completion of a hearing on the Grievance submission, The SEEDS Grievance Committee will:
    • Review all evidence, including the Grievance, the accused party’s response, and any additional documentation or testimony gathered during the subsequent process.
    • Assess the findings in accordance with SEEDS Ethical Standards and grievance policies.
    • Make a formal recommendation regarding the outcome, which may include:
      • No action if the Grievance is unsubstantiated.
      • Corrective actions or recommendations for resolution.
      • Disciplinary actions, such as warnings, suspension, or expulsion from SEEDS.
    • Submit their recommendation to the SEEDS Board for review.
  • Only if a recommendation of Corrective action or disciplinary action is involved, within 10 business days of receiving the formal recommendation, The SEEDS Board will:
    • Review the Grievance Committee’s recommendation.
    • Consider all supporting evidence and the rationale behind the recommendation.
    • Make the final decision on the outcome of the Grievance.

Step 8: Communication of Decision

  • Within 5 business days of the Board’s decision, both the Complainant and the accursed party will be notified in writing of the final decision, which will include:
    • A summary of the findings.
    • The rationale for the decision.
    • Details of any actions or sanctions imposed.

Step 9: Documentation

  • Records of the Grievance, investigation, and resolution will be securely and confidentially maintained.  This does not preclude the Grievance Committee from supplying this information upon court order.

Grievance Submission: A Complainant submits a grievance alleging a violation of SEEDS ethical standards by a SEEDS member or potential member.
Preliminary Review: (within 21 business days of grievance submission) The SEEDS Grievance Committee reviews the submission for completeness and adherence to criteria.
Complainant Notification: (within 5 business days of grievance acceptance/rejection) The Complainant is notified whether the grievance is accepted or rejected.
Accused Notification (If accepted): (within 10 business days of notification) The accursed party submits their account of events and any supporting evidence.
Accused Response (If accepted): (within 10 business days of notification) The accursed party submits their account of events and any supporting evidence.
Committee Provides Documentation to Complainant (if accepted): (within 10 business days of notification) Grievance Committee will provide all documentation that was presented by the Accursed to the Complainant.
Complainant Response (if accepted): (within 10 business days of notification)  The Complainant will, if they choose, provide a rebuttal.
Opportunity to Request a Hearing (if accepted, and if requested): (within 10 business days of notification) Either party may request a hearing.
Hearing: (within 21 business days from the date of the request for a hearing) The Grievance Committee shall hold a hearing and within 21 business days will make a recommendation based on the findings of the evidence supplied in writing and at the hearing proposing no action, corrective actions, or disciplinary action.
Recommendation: (within 21 business days from the date of the grievance submission if no hearing is requested, or within 21 business days of the completion of the hearing(s) if requested) The Grievance Committee makes a recommendation based on the findings of the review of the documentation and witness statements if any provided, proposing no action, corrective actions, or disciplinary action.
Board Decision: (within 5 business days of receiving the recommendation), if and only if a recommendation of Corrective action or disciplinary action is involved, the SEEDS Board will review the recommendation and make the final decision on the outcome of the grievance.
Outcome Notification: (within 5 business days of Board decision), Both parties will be notified in writing of the final decision and any actions or sanctions imposed.

  1. Your grievance cannot be changed, edited or deleted once it has been submitted.
  2. An exact copy of your grievance will be sent to the business you are filing the complaint against.
  3. By submitting your grievance, you are representing that it is a truthful account of your experience with the business.
  4. To ensure confidentiality is preserved, please do not submit any information on behalf of another without their express, written consent.
  5. If the business is not a current member the Grievance Committee will attempt to best assist you in identifying avenues for redress and will maintain the information submitted should the business apply for membership in the future.

Please note: The SEEDS Grievance Filing, Response, and Resolution Policy has been updated and adopted as outlined as of April 9, 2025.