Health Share Ministries to Face Stricter Transparency: 2025 Act Mandates Detailed Disclosures and Public Complaint Reports

The "Health Share Transparency Act of 2025" is shaking things up for health care sharing ministries (HCSMs). In a nutshell, this bill, specifically SEC. 2, amends the Public Health Service Act to make these ministries open their books and be much clearer with folks like you and me. They'll now have to submit annual reports to the government – think the Secretary of Health and Human Services, the IRS, and the Consumer Financial Protection Bureau – and give a laundry list of crucial details to anyone thinking about joining or already in their programs. The goal? To make sure you know exactly what you're getting into, because these plans are not traditional health insurance, and the bill wants to make that crystal clear.

The Fine Print Gets Bigger: What Health Share Ministries Must Now Tell You

So, what exactly do these ministries need to spill? The list is pretty extensive. We're talking about their financial reserves – basically, how much cash they have on hand. They also need to show the ratio of how much enrollee money actually goes towards covering medical costs versus their total collections, similar to how regular insurance companies report spending under section 2718(a) of the Public Health Service Act. You'll also get to see the number of people enrolled, the total amount members paid in, how much the ministry paid out for services, and the average out-of-pocket expenses for members.

Crucially, they must disclose the percentage of claims denied, their average claim reimbursement time, and a list of services not covered. They also need to be upfront about their complaint and appeals process, including whether you'd be forced into arbitration or if you have other legal options. And here’s a big one: they must clearly state that reimbursement is not guaranteed – unlike traditional insurance – and whether they have lifetime caps on what they'll contribute. This info has to be prominent, in multiple languages, provided before you enroll, and in at least 14-point font. No more squinting at tiny disclaimers!

Not Your Typical Insurance: Making Sure You Know the Difference Before Signing Up

It's not just the ministries themselves that have new homework. Any entity that enrolls people into these HCSMs also has new responsibilities. Before you sign on the dotted line, they are required to explain a few key things. First, they need to tell you about potential tax credits you might be eligible for under section 36B of the Internal Revenue Code if you were to get a qualified health plan through the marketplace. They also have to let you know if you might qualify for state Medicaid plans (under Title XIX of the Social Security Act) or Medicare benefits (under Title XVIII).

Beyond alternatives, they must clearly spell out the differences in benefits and cost-sharing between the ministry plan and traditional insurance. And the most important disclaimer: they have to explicitly state that the ministry is not a guaranteed health plan or insurance coverage. Think of it like this: if you're considering a HCSM, the people signing you up now have to act a bit like a financial advisor, laying out all the options and the fundamental differences in risk and coverage, ensuring you understand that these ministries, defined under section 5000A(d)(2)(B) of the Internal Revenue Code, operate under a different set of rules and guarantees (or lack thereof).

Accountability Check: New Rules for Reporting and Penalties

To make sure these new rules have teeth, the bill includes enforcement measures. If a ministry fails to meet these disclosure requirements, the Secretary of Health and Human Services can impose a civil monetary penalty of up to $100 per day for each individual affected. That could add up quickly and provides a real incentive for compliance.

Furthermore, the Federal Trade Commission (FTC) gets a new role. Twice a year, the FTC must publicly disclose on its website (and report to HHS and the IRS) the number of consumer complaints received about HCSMs, the general categories of these complaints (e.g., claim denials, misleading information), the name of the ministry involved, and even details about its ownership and executive leadership. This public reporting means that, much like checking restaurant health grades, you'll be able to see which ministries are drawing consumer complaints, adding another layer of transparency and accountability to the system.