California Insurance Commissioner Ricardo Lara recently sent a bulletin to admitted insurers, accident and health agents, and other interested parties pertaining to health care sharing ministries. The Alliance of Health Care Sharing Ministries shares the Commissioner’s concern that bad actors purporting to be health care sharing ministries may be misleading consumers, misrepresenting the products they sell, and violating California and federal law.

This sort of deception is not part of legitimate authentic health care sharing ministries, and we stand with regulators in their efforts to protect consumers from such tactics from any organization purporting to be a health care sharing ministry.

Health Care Sharing Ministries are communities of people with similar beliefs coming together to share in each other’s medical burdens and these programs are not to be miscategorized as insurance.

California law exempts members of health care sharing ministries as defined by the Affordable Care Act (ACA) from the state’s individual insurance mandate. The most reliable way to determine if a health care sharing ministry satisfies this test is a federal certification letter from the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services (CMS) that the ministry meets the federal definition and is therefore exempt from the ACA requirements.

The following sharing ministries are among the more than 100 ministries that do have the CMS certification letter, satisfying the federal and California definition of a health care sharing ministry, and their members are exempt from the federal and state individual coverage mandates.

Commissioner Lara recently took action against Aliera Healthcare, a for-profit company selling insurance products, and its affiliated organization Trinity HealthShare, purporting to be a health care sharing ministry, but which allegedly misled consumers into thinking they were buying insurance. Neither Aliera nor Trinity are federally certified as exempt from the ACA.

Legitimate health care sharing ministries go to great lengths to inform prospective members of how their sharing guidelines, always publicly available on their web sites, work and to clarify that their sharing program is not an insurance plan. As such, consumer complaints that they were misled into thinking they were buying insurance arising from these ministries are quite rare.

Any consumers that wish to confirm for themselves that a health care sharing ministry is legitimate should ask the following:

  • Ask for a copy or link to the ministries’ federal certification letter;
  • Ask if the sharing program is a 501(c)(3) nonprofit organization as certified by the Internal Revenue Service;
  • Ask if the ministry has a history of meeting its eligible sharing needs continuously since 1999 (the date specified by the ACA);
  • Ask for a copy of the ministry’s audited financial statements;
  • Ask for a copy of the sharing programs member guidelines and statement of faith.

The Alliance stands ready to work with regulators, legislators, other policy makers, our members and the public to protect consumers from bad actors and to help any Americans wishing to participate in health care sharing find a legitimate, CMS-certified ministry that complies with all applicable federal and state consumer protections.

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