JoAnn Volk, Emily Curran and Justin Giovannelli

Health Care Sharing Ministries (HCSMs) are a form of health coverage in which members – who typically share a religious belief – make monthly payments to cover expenses of other members. HCSMs do not have to comply with the consumer protections of the Affordable Care Act and may provide value for some individuals, but pose risks for others. Although HCSMs are not insurance and do not guarantee payment of claims, their features closely mimic traditional insurance products, possibly confusing consumers. Because they are largely unregulated and provide limited benefits, HCSMs may be disproportionately attractive to healthy individuals, causing the broader insurance market to become smaller, sicker, and more expensive.

In order to understand state regulators’ perspectives on regulation of HCSMs, we interviewed officials in 13 states and analyzed state laws governing HCSMs in all states. We found that while state regulators voiced concerns regarding the potential risks of HCSMs to consumers and their individual market, regulators have been unable to adequately assess the harm these arrangements might impose due to lack of enrollment data. To learn more about HCSMs and how your state regulates them, you can access the full issue brief here.