Health Sharing Ministries Face New Rules: Must Disclose Claim Denials, Payout Ratios, and Financial Reserves

If you’ve ever looked into a Health Care Sharing Ministry (HCSM) as an alternative to traditional insurance, this bill is a game-changer. The Health Share Transparency Act of 2025 is essentially forcing these ministries to pull back the curtain and show exactly how they operate, financially and operationally. Since HCSMs aren't regulated like insurance, they haven't had to disclose much—until now.

The Numbers Game: What the Government Gets to See

This Act mandates that HCSMs report a serious amount of data annually to three heavy-hitting agencies: the Department of Health and Human Services (HHS), the IRS, and the Consumer Financial Protection Bureau (CFPB). Think of it as a mandatory financial and operational audit, but public. The data includes their total financial reserves, the percentage of member contributions that actually goes toward paying medical claims versus administrative costs, and the total number of members. Crucially, they must report their claim denial rate from the previous year and the average time it took to pay a claim. HHS then has to take all this data and post it on a public website. This means for the first time, you can potentially look up Ministry X and see, “Okay, they denied 15% of claims last year, and it took them 90 days on average to pay.” That’s information you couldn't easily get before, and it shifts the power balance toward the consumer.

Fine Print, Large Font: What Members Must Be Told

Beyond government reporting, the bill focuses heavily on disclosures to the people signing up. Ministries must now give prospective and current members a detailed, clear warning—in at least 14-point font—that their arrangement is not guaranteed insurance. If you’re used to the protections of traditional insurance, this is the most important part. The disclosure must detail exactly how members can appeal coverage decisions, and whether they are forced into arbitration (meaning you can’t sue them in court). They also have to disclose the average out-of-pocket expenses members faced last year, giving you a much clearer picture of the true cost. If you’re a small business owner considering an HCSM for your employees, this transparency makes due diligence much easier.

The Enrollment Checkpoint

If an HCSM uses a third-party contractor to sign up new members, those contractors now have a new burden: they can’t get paid until they explain alternatives to the potential enrollee. This means they must inform people about any tax credits they might qualify for on the health insurance Exchange, and whether they are eligible for Medicaid or Medicare. They also have to provide a comparison showing what consumer protections the enrollee is giving up by choosing the ministry over a standard group health plan. This provision is designed to ensure that people aren't accidentally missing out on subsidized coverage they might desperately need because they were only shown one option.

The Financial Hammer and Public Shame

Compliance isn't optional. If a ministry fails to follow these disclosure rules, the Secretary can issue a fine of up to $100 per day, multiplied by the number of individuals affected by that failure. That fine structure could quickly turn a simple administrative error into a massive financial liability. For a ministry with 10,000 members, a 30-day failure to disclose could result in a $30 million fine. This is a serious regulatory stick intended to ensure full compliance. Furthermore, the Federal Trade Commission (FTC) is now required to track and publicly report consumer complaints against these ministries twice a year, detailing the nature of the complaint and the name of the ministry involved. This creates a public record of poor performers, which is a powerful tool for consumer awareness.