A health care sharing ministry is a nonprofit, usually faith-based group whose members send monthly contributions that are shared to pay other members’ eligible medical bills. It is not health insurance: it has no legal obligation to pay your bills, isn’t bound by ACA protections such as pre-existing condition coverage, and doesn’t qualify for premium tax credits.
Updated October 2026 for the 2027 plan year
Key facts (2027 plan year)
- The National Association of Insurance Commissioners (NAIC) says sharing ministries “are not insurance and can’t guarantee the payment of claims” (NAIC, 2023).
- Sharing ministries don’t have to follow ACA consumer protections, “like covering treatments for pre-existing conditions or capping out-of-pocket costs” (NAIC).
- As of 2022, the NAIC counted 30 states whose laws explicitly exempt sharing ministries from insurance regulation (NAIC, 2022).
- Federal law defines the term in the ACA’s individual mandate, including a 501(c)(3) nonprofit sharing medical expenses continuously since December 31, 1999 (26 U.S.C. 5000A(d)(2)(B)).
- The federal penalty for going without coverage dropped to zero starting in 2019 (HealthCare.gov).
- To contribute to an HSA you must be covered by a high-deductible health plan (IRS Publication 969); sharing ministry membership is not a health plan.
What is a health care sharing ministry?
A health care sharing ministry is an organization whose members share a common set of ethical or religious beliefs and agree to share one another’s medical expenses. Members make a monthly contribution, and the ministry matches that money to members with eligible bills. People also call them health share plans or health sharing ministries.
The NAIC describes them simply: “HCSMs are organizations in which the members share the costs of health care,” and a member “will typically contribute a monthly payment to cover the qualifying medical expenses of other members” (NAIC).
Federal law has a precise definition, written for the Affordable Care Act’s individual mandate. Under 26 U.S.C. 5000A(d)(2)(B), a qualifying ministry must:
- Be a 501(c)(3) tax-exempt organization.
- Have members who share common ethical or religious beliefs and share medical expenses, regardless of the state they live in.
- Let members keep their membership after they develop a medical condition.
- Have existed, with members sharing expenses continuously, since at least December 31, 1999 (or have a predecessor that did).
- Conduct an annual independent audit that is available to the public on request.
That definition mattered for the old tax penalty. It doesn’t make a ministry an insurer.
Is a health care sharing ministry health insurance?
No. A sharing ministry doesn’t take on financial risk and isn’t legally or contractually required to pay your medical costs. Regulators across the country say this plainly.
The Michigan Department of Insurance and Financial Services says that by law, sharing ministries “are not considered health insurance because they do not assume any risk, and because the ministries are not legally or contractually obligated to pay health care costs” (Michigan DIFS, 2024).
The NAIC adds that while sharing ministries “may share funds with members who have health needs, they are not legally required to do so.” If a bill isn’t shared, it stays yours to pay.
A health insurance policy is a contract with guaranteed benefits. A sharing ministry is a voluntary arrangement governed by its own guidelines, which it can change.
How do health share plans work?
You pay a monthly contribution, get care, and then submit your bills to the ministry. If the expense meets the ministry’s guidelines, it is shared with money from other members. Each ministry writes its own rules on what is eligible.
A few practical points stand out:
- No guaranteed network. The NAIC says sharing ministries “usually don’t have provider networks, so members may be charged full price by doctors and hospitals.” Many members are treated as self-pay patients.
- Member guidelines decide eligibility. The guidelines list what is shared, what isn’t, waiting periods and any limits. They are not an insurance policy and are not reviewed the way policy forms are.
- Lifestyle and faith requirements. Colorado’s Division of Insurance warns that members “may also be subject to religious or moral restrictions,” which can leave them paying the full cost of care tied to an activity the ministry doesn’t accept (Colorado DOI).
- Insurance-like marketing. Colorado also warns that some programs mimic ACA plans, calling payments “premiums” or using terms like “bronze, silver and gold tiers.”
The NAIC notes that people are drawn to these programs because of “typically lower up-front costs, compared to ACA plans,” and that sharing ministries “may provide value to some, but they pose a risk to others.”
Honesty.AI checks your 2027 subsidy and ACA plans side by side, so you know what guaranteed coverage would really cost you.
What ACA protections don’t apply to sharing ministries?
Almost none of the Affordable Care Act’s consumer protections apply. A sharing ministry doesn’t have to share costs for pre-existing conditions, cover the essential health benefits or cap what you pay in a year.
Here is what that means in practice:
- Pre-existing conditions. ACA plans can’t refuse you, charge you more or limit benefits because of a pre-existing condition (HealthCare.gov). Colorado says sharing programs “typically have restrictions or exclusions on pre-existing conditions.”
- Essential health benefits. ACA plans cover ten categories of care, including mental health, maternity and prescriptions (HealthCare.gov). Colorado warns that sharing programs often don’t share costs for mental health or substance use disorder treatment.
- Out-of-pocket maximum. For 2027, an ACA plan caps your in-network costs at $12,000 for one person and $24,000 for a family (CMS). A sharing ministry has no such cap on what you may owe.
- Appeals and oversight. Michigan says sharing ministries are not regulated as insurance under state or federal law, so complaints there go to the Attorney General, not the insurance department.
If you have a health condition, be careful. A sharing ministry may not share the costs of a condition you already have. The ACA plan you skipped would have been required to cover it from day one.
Who regulates health care sharing ministries?
Mostly no one, in the way insurers are regulated. The NAIC says “state insurance regulators don’t supervise HCSMs,” and as of 2022, 30 states explicitly exempted them from insurance regulation, while the other 20 states and Washington, DC had no explicit exemption.
Some states have stepped up oversight anyway. Colorado’s House Bill 22-1269 requires sharing plans and arrangements to report enrollment, financial data, use of licensed producers, member guidelines and marketing materials each year, and the Division of Insurance publishes summary reports (Colorado DOI).
Regulators have also acted against groups that claimed ministry status but didn’t meet it. In 2019, Colorado issued cease-and-desist orders against Trinity HealthShare and Aliera, Texas sued Aliera, and Washington found that Trinity operated as an unauthorized insurer (Georgetown CHIR).
If you have a problem with a ministry, ask your state insurance department who handles complaints in your state.
Is there still a penalty, and do tax credits or HSAs work with a sharing ministry?
There is no federal penalty for going without health insurance, and there hasn’t been since 2019. Sharing ministry membership doesn’t qualify for the premium tax credit and, on its own, doesn’t make you eligible for an HSA.
The penalty history. From 2014 through 2018, people without qualifying coverage owed a federal tax penalty, and members of a qualifying health care sharing ministry were exempt from it under 26 U.S.C. 5000A. That exemption is why many people joined. Federal law set the penalty to zero starting in 2019 (26 U.S.C. 5000A(c)). HealthCare.gov confirms the fee “no longer applies” (HealthCare.gov).
State mandates. A few states run their own coverage mandate with their own exemption rules. California’s, for example, is administered by the Franchise Tax Board. Check your state tax agency before you rely on a ministry instead of insurance.
Premium tax credits. The credit is only for health coverage bought through the Marketplace (IRS). Monthly ministry contributions get no subsidy, so compare them with your 2027 subsidy, not with full-price premiums.
HSAs. IRS Publication 969 says you must be covered under a high-deductible health plan to contribute to an HSA (IRS Publication 969). A sharing ministry isn’t a health plan, so membership alone doesn’t qualify you. If you combine membership with an HSA-eligible plan, ask a tax professional how the rules apply to you. Our HSA guide explains eligible plans for 2027.
Enrollment timing. The loss-of-coverage Special Enrollment Period is for losing minimum essential coverage (45 CFR 155.420). Ministry membership isn’t on the list of coverage types that count (26 U.S.C. 5000A(f)), so leaving a ministry generally won’t open a Special Enrollment Period. You may have to wait for Open Enrollment.
How does a sharing ministry compare with an ACA plan?
An ACA plan is a regulated insurance contract with guaranteed benefits. A sharing ministry is a voluntary arrangement with no guarantee of payment. The table sets out the main differences.
| Feature | Health care sharing ministry | ACA Marketplace plan |
|---|---|---|
| Is it insurance? | No | Yes |
| Guarantee that bills are paid | None; sharing is voluntary | Yes, under the policy terms |
| Pre-existing conditions | Often restricted or excluded | Covered; no higher price for health history |
| Essential health benefits | Not required | Ten required categories |
| Yearly out-of-pocket cap | None required | Up to $12,000 single / $24,000 family |
| Provider network | Usually none; often billed as self-pay | Yes, with negotiated rates |
| Premium tax credit | No | Yes, if eligible |
| Minimum essential coverage | No | Yes |
| Faith or lifestyle rules | Often required | Not allowed to affect coverage |
| Main oversight | Limited; varies by state | Federal ACA rules plus your state |
If you’re weighing other non-ACA products too, see short-term health insurance and our guide to supplemental health insurance, which pays on top of a main plan instead of replacing it.
What should you ask before joining a sharing ministry?
Ask for the member guidelines in writing and read them before you pay. The NAIC advises understanding how a plan works and what benefits you can count on before you sign up. These questions help:
- Is this insurance? Colorado’s regulator suggests asking directly, and asking whether there is a guarantee of coverage.
- What is not shared? Ask about pre-existing conditions, maternity, mental health, prescriptions and preventive care.
- Are there waiting periods or limits? Ask how long before a condition is eligible and whether any per-incident or yearly limits apply.
- What faith or lifestyle rules apply? Find out what you must sign and which activities could make a bill ineligible.
- How are bills paid? Ask whether you pay the provider first and wait to be reimbursed, and how long that takes.
- Can the guidelines change? Ask how members are told about changes and whether past bills are affected.
- Does it meet the federal definition? Ask for its most recent independent audit, which a qualifying ministry must make public on request.
- Who takes complaints? Check with your state insurance department before you join.
What should you compare before choosing a sharing ministry?
Check what guaranteed coverage would cost you after subsidies first. Many people who look at sharing ministries assume ACA plans cost more than they actually would for their income.
- Marketplace plan with a premium tax credit. For 2027, the credit is based on your income up to 400% of the federal poverty level. See health insurance subsidies.
- Silver with cost-sharing reductions. At lower incomes, cost-sharing reductions cut deductibles and copays.
- Medicaid or CHIP. Check Medicaid eligibility for adults and children in your state.
- Catastrophic plans. If you’re under 30 or qualify for a hardship exemption, see catastrophic health insurance.
For a step-by-step process, follow our guide on how to shop for health insurance, then compare health insurance plans by total yearly cost.
How can Honesty help?
Honesty®, a licensed AI insurance agent from Honesty® Insurance Services, LLC (NPN 21094885, licensed in 49 states and DC), compares ACA, alternative and ancillary plans by your family’s needs. Honesty does not offer sharing ministry memberships; this page is a neutral guide.
What Honesty can do is show you, for your ZIP code and income, what your individual options would cost in 2027 after any subsidy, and whether your doctors and prescriptions are covered. It is unbiased and never steers you to a carrier, never sells or shares your data, makes no spam calls and enrolls you in minutes, 24/7. Learn how Honesty.AI works or read about individual health insurance.
Compare your individual options before you decide
Honesty®, a licensed AI insurance agent from Honesty® Insurance Services, LLC (NPN 21094885), checks your 2027 subsidy and compares ACA, alternative and ancillary plans by your family’s needs. Chat, voice or text, 24/7.
Frequently asked questions
Is a health care sharing ministry the same as health insurance?
No. A sharing ministry isn’t insurance and can’t guarantee your bills will be paid. It doesn’t take on risk, isn’t legally required to pay and doesn’t have to follow ACA protections.
Do health share plans cover pre-existing conditions?
Often not, or only after a waiting period. Sharing ministries aren’t bound by the ACA rule that requires coverage of pre-existing conditions, and state regulators warn that restrictions and exclusions are common.
Is there a tax penalty for using a sharing ministry instead of insurance?
Not at the federal level. The federal penalty has been zero since 2019. A few states have their own mandates with their own exemption rules, so check your state tax agency.
Can I use an HSA with a health care sharing ministry?
Not with membership alone. IRS Publication 969 requires coverage under a high-deductible health plan to contribute to an HSA, and a sharing ministry isn’t a health plan. Ask a tax professional about your situation.
Can I get a subsidy for a sharing ministry?
No. The premium tax credit only applies to health coverage bought through the Marketplace. Sharing ministry contributions get no federal subsidy.
Who regulates health care sharing ministries?
Oversight is limited. The NAIC says state insurance regulators don’t supervise them, and 30 states explicitly exempt them from insurance law. Some states, like Colorado, require yearly reporting.
Can I switch from a sharing ministry to an ACA plan at any time?
Usually not. Leaving a sharing ministry isn’t a loss of minimum essential coverage, so it generally doesn’t open a Special Enrollment Period. You may need to wait for Open Enrollment unless another life event applies.
Keep learning: read about short-term health insurance, supplemental health insurance and how Obamacare works, or see the health insurance terms glossary.
