Health care sharing ministries are exploding in popularity due to their lower costs and the shared values they promote. Popular sharing ministries include Medi-Share, Liberty HealthShare, Christian Healthcare Ministries, Samaritan Ministries, Altrua HealthShare, and Shared Health Alliance among others.
Do Sharing Plans Qualify as MEC?
Remember that in order to participate in the QSEHRA, an employee must have health insurance that qualifies as MEC, and health Sharing Plans are not technically insurance under the Affordable Care Act. Based on the IRS guidance and input from our own lawyers, we do not consider sharing ministries as meeting the MEC requirements.
Sharing ministry members have a special exemption under the Affordable Care Act from maintaining MEC; however, sharing ministries themselves do not meet the MEC requirement that qualifies you for reimbursement through a QSEHRA. We explored this circular reference in detail in this blog post.
Can sharing plans be reimbursed through QSEHRA?
Not exactly, but they can still be reimbursed.
As mentioned above, health Sharing Plans are not technically insurance under the Affordable Care Act, and the premiums you pay to be a member of a Sharing Plan, typically referred to as a "monthly share," are not recognized by the IRS as being actual insurance premiums under IRS Section 213(D). Therefore, monthly share amounts are not eligible for reimbursement through the QSEHRA.
However, because they are not recognized as actual insurance premiums, even though they cannot be reimbursed tax-free through QSEHRA, they can be reimbursed on a taxable basis outside of QSEHRA, if the employer chooses to include it as part of their plan. On the Take Command Health platform, we will still verify proof of the sharing plan and employees will submit claims for their monthly shares. We'll report the sharing plan reimbursements right alongside QSEHRA reimbursements on the reimbursement statements we provide.
Can medical expenses be reimbursed for sharing plan members?
Because these plans do not qualify as Minimum Essential Coverage for QSEHRA, employees on sharing plans cannot claim reimbursement for medical expenses through QSEHRA, either. However, they can qualify for medical expense reimbursement with an individual MEC. The MEC plan itself would be reimbursable tax-free through the QSERHA, and it would also qualify them for medical expense reimbursement if allowed by the QSEHRA.