Health Care Sharing Ministries: What Are The Risks To .

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ISSUE BRIEFAUGUST 2018Health Care Sharing Ministries:What Are the Risks to Consumersand Insurance Markets?JoAnn VolkEmily CurranJustin GiovannelliResearch ProfessorGeorgetown University Center onHealth Insurance ReformsResearch FellowGeorgetown University Center onHealth Insurance ReformsAssociate Research ProfessorGeorgetown University Center onHealth Insurance ReformsABSTRACTKEY TAKEAWAYSISSUE: Health care sharing ministries (HCSMs) are a form of healthcoverage in which members — who typically share a religious belief —make monthly payments to cover expenses of other members. HCSMs donot have to comply with the consumer protections of the Affordable CareAct and may provide value for some individuals, but pose risks for others.Although HCSMs are not insurance and do not guarantee paymentof claims, their features closely mimic traditional insurance products,possibly confusing consumers. Because they are largely unregulated andprovide limited benefits, HCSMs may be disproportionately attractiveto healthy individuals, causing the broader insurance market to becomesmaller, sicker, and more expensive. Regulators lack data to assesshealth care sharing ministries’role in their states and may beconstrained in their options foraddressing regulatory concernsand consumer complaints.GOAL: To understand state regulator perspectives on regulation ofHCSMs and the impact of these arrangements on consumers and markets.METHODS: Analysis of state laws governing HCSMs in all states;interviews with officials in 13 states; and review of the membershiprequirements and benefits of five HCSMs.FINDINGS AND CONCLUSIONS: State regulators voiced concernsregarding the potential risks of HCSMs to consumers and their individualmarkets. However, in the absence of reliable data describing HCSMenrollment, regulators cannot adequately assess harm. Though limitedresources and political constraints have made oversight difficult, allstates, regardless of their regulatory approach to HCSMs, should obtaindata to better understand the role of HCSMs in their markets. Many HCSMs use features thatare very similar to insuranceand may therefore misleadconsumers into thinking theyare enrolling in coverage thatguarantees payment for acovered claim. If HCSMs draw healthierindividuals out of the ACAcompliant market, it will helpcreate smaller and sicker riskpools in that market, withhigher premiums and fewer planchoices.

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?BACKGROUND2Under the ACA, members in HCSMs are exempted fromthe federal individual mandate, but the law does notdictate whether and how states may regulate them.4In particular cases, courts have concluded that HCSMpractices constitute the business of insurance, but no statecurrently treats these entities as insurers.5 Thirty stateshave enacted “safe-harbor” rules that exempt HCSMsfrom state insurance regulation (Exhibit 1, Appendix 1).Under the safe harbor, as long as an HCSM meets therequirements of the exemption, such as providing awritten disclaimer and a monthly statement of memberpayment requests and contributions, it is, by definition,not engaged in the business of insurance and cannot berequired to comply with standards and requirementsotherwise applicable to health insurers.In a health care sharing ministry (HCSM), membersfollow a common set of religious or ethical beliefs andcontribute — typically monthly — a payment, or share, tocover the qualifying medical expenses of other members.1An HCSM will then either match paying members withthose who need funds for health care costs or pool all ofthe monthly shares and administer payments to membersdirectly.2 HCSMs have long maintained that they arenot health insurance companies and do not guaranteepayment for members’ medical claims.3 Since they do notmeet the federal definition for health insurance, they arenot subject to the consumer protections of the AffordableCare Act.Exhibit 1Exhibit 1. State Laws Governing Whether Health Care Sharing Ministries Are Exempt from StateState Laws Governing Whether Health Care Sharing Ministries Are ExemptInsurance Codes, 2018from State Insurance Codes, 2018State law explicitly exempts healthcare sharing ministries(30 states)WANHMTState law does not contain anexplicit exemption for health caresharing ministries(20 states and LData: Authors’ analysis of state laws governing health care sharing ministries.Note that states that have not explicitly exempted health care sharing ministries from the state insurance code do not necessarily regulate them.Data: Authors’ analysis of state laws governing health care sharing ministries.Note that states that have not explicitly exempted health care sharing ministries from the state insurance code do not necessarily regulate them.Source: JoAnn Volk, Emily Curran, and Justin Giovannelli, Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?(Commonwealth Fund, Aug. 2018).commonwealthfund.orgIssue Brief, August 2018

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?HCSMs have long been an alternative for certain religiouscommunities that object to traditional insurance. Thearrangement allows them to share health care costburdens. Since the passage of the ACA, HCSMs have beenmarketed more broadly, reaching people who otherwisemight not have considered membership.6 While HCSMsmay provide value for some people, they also have thepotential to create confusion for others, as they closelymimic traditional insurance products, but do not providethe same consumer protections.7 Most HCSMs requirepayments resembling deductibles, monthly premiums,and copayments, and define a benefits package. Many useprovider networks, while some pay broker commissionsfor selling memberships or offer tiers of coverage similar3to ACA-compliant products (i.e., gold, silver, and bronzeplans).8 At the same time, because HCSMs are not requiredto comply with the ACA’s consumer protections, coveragefor preexisting conditions may be limited or excluded,medical benefits are typically far more limited than inACA-compliant plans, and members are never guaranteedpayment, even for covered services.9 As with otherarrangements that pair low monthly payments withlimited benefits, like short-term plans, HCSMs pose a riskof attracting a disproportionate share of currently healthyindividuals. If HCSMs draw these consumers out of theACA-compliant market, they help to create smaller andsicker risk pools in that market, with higher premiums andfewer plan choices (Exhibit 2).Exhibit 2. Consumer Protections in ACA Plans Compared to Health Care Sharing MinistriesConsumer protectionACA plansIncludes coverage for preexistingconditions?YesBans charging higher rates basedon health status?YesCovers essential health benefits?YesCovers benefits without dollar capson health care services?YesCaps out-of-pocket expenses forconsumers?YesHCSM coverageNot usually. Most HCSMs will share costs for preexistingconditions only if the condition was cured and a year or morehas passed without symptoms or treatment (e.g., SamaritanMinistries: for heart conditions, enrollee must be symptom/treatment free for five years).No. HCSMs may charge a higher rate based on health status andsome will deny membership to those who can’t pass a medicalscreen (e.g., Medi-Share Christian Care Ministry: membersare required to enroll in higher-cost membership level if theyexperience significant weight gain).No. HCSMs do not have to comply with any health benefitrequirements and usually exclude treatment for mental andbehavioral health and substance use disorders, and preventiveand wellness services; and limit or exclude prescription drugs,in addition to other restrictions (e.g., Christian HealthcareMinistries: silver and bronze members cannot submit anyprescriptions or doctors’ bills, except doctors’ bills incurred whilea hospital inpatient or outpatient).Not usually. Several HCSMs set monthly, annual, and lifetimelimits on coverage (e.g., Altrua Ministries: members enrolled inbronze plans have a lifetime limit of 1,000,000 and a 50,000limit per calendar year).No. HCSMs often limit the amount members can share andmembers are responsible for bills exceeding that limit; no HCSMguarantees payment for bills, even those eligible for sharing (e.g.,Sedera Health: in months where needs exceed shares, membersmay only receive a prorated amount of funds needed).Data: Review of the guidelines of five health care sharing ministries: Altrua HealthShare, Christian Healthcare Ministries, Medi-Share Christian Care Ministry,Samaritan Ministries, and Sedera Health. For more information, see Appendix 2.commonwealthfund.orgIssue Brief, August 2018

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?4Though HCSMs have grown in popularity andare limited in scope and do not include enrollmentsophistication, consumers’ experiences with them andnumbers. Some states have attempted to gauge HCSMHCSMs’ effects on the traditional insurance marketspopularity by tracking local news reporting, combingare not well understood. We gathered state regulators’through HCSM newsletters, or using an HCSM’s totalperspectives on the regulation of HCSMs and data onreported medical cost needs and expected memberthe impact of these arrangements on consumers and“shares” to infer potential enrollment. In one instance, ainsurance markets. We interviewed officials in 13 statesstate obtained enrollment data directly from an HCSMand also examined membership requirements andthat is cooperating with an investigation into deceptive10coverage options offered by five HCSMs (Appendix 2).11,12broker practices. Aside from these ad hoc approaches,respondents said they have no mechanisms for solicitingFINDINGSRegulators Lack Data to Understand HCSMOperations and Impactsinformation. Many suspected that enrollment is growingbased on the number of consumer inquiries, prevalence ofHCSM advertising, and sporadic news reports.15 However,no state can pinpoint this trend definitively.None of the officials we interviewed could say for surewhich HCSMs are active in their state or how manyindividuals are enrolled. Given that HCSMs are typicallyMarketing and Insurance Features Contribute toConsumer Confusionunregulated and unlicensed, officials have understandablyNearly all respondents believed at least one HCSM wasfound it difficult to gain even basic information aboutoperating in their states. Most expressed concern thatthem. Often, officials become aware that an HCSMsome appeared to be functioning in ways that differedis operating through consumer, broker, or providerfrom their original intent. Nearly all respondents whocomplaints. Respondents said that such complaints havenoted such concern said that many HCSMs use featuresbeen rare, but also said that few consumers are aware ofthat are very similar to insurance and may thereforethe option to complain to state insurance regulators.13mislead consumers into thinking they are enrolling inA few states learned of HCSMs when the groups startedcoverage that guarantees payment for a covered claim.actively marketing following the implementation ofthe ACA. Others noted an uptick in marketing duringthe latest open-enrollment period. States found this tobe particularly concerning and received an increase inconsumer calls during this time, mostly from people whoincorrectly believed they had purchased insurance. Asidefrom anecdotal evidence, states report that they havefew avenues for identifying HCSMs in their areas; as onerespondent lamented, “they operate [without oversight]until we find them.”Since enactment of the ACA, enrollment in HCSMs hasreportedly spiked, growing from fewer than 200,000Respondents noted that HCSMs have a defined monthlycontribution and claims are reimbursed according toa schedule of payment for specific benefits, akin to aninsurance contract that requires premiums and paysclaims based on covered benefits. Features such aspreferred provider networks and marketing duringopen enrollment — sometimes with the help of paidbrokers — also contribute to consumer confusion. A fewalso noted that some HCSMs were marketing to employergroups — in one case, to a municipal government plan —an approach one respondent suggested was “antitheticalto the concept” of the HCSM arrangement.before 2010 to perhaps 1 million today.14 These estimatesare self-reported; there are no independent data availableA Potential Driver of Market Segmentationto identify either national or state-level membership.In states with active HCSMs, some respondents voicedSix states require HCSMs to issue annual audits toconcerns about the potential for the arrangements tocomply with their safe-harbor rules, but these reportsdraw healthy individuals from the ACA-regulated market.commonwealthfund.orgIssue Brief, August 2018

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?5Generally, respondents suggested there could be risk ofOne state in this study is working with an HCSM to reinmarket segmentation in the future. Most speculated thatin deceptive broker activity, while others suggested theymembership was too low to have much of an impact;could refer fraudulent activity to the state attorney generalothers said that the HCSMs were likely attracting peoplefor investigation and potential action.who have already been priced out of marketplace coveragebecause they don’t qualify for premium subsidies. Alaskastood out as an exception. Regulators said health caresharing ministry membership is significant (estimatedat about 10,000) in the state relative to the individualmarket (20,000).16 If affordability remains a problem,regulators said that membership in HCSMs could growbig enough to potentially adversely affect the individualmarket risk pool, particularly in conjunction with othernon-ACA coverage options, such as short-term andassociation health plans, that are expected to draw greaterenrollment.But most respondents said their options for addressingregulatory concerns and consumer complaints arelimited, even in states unconstrained by a safe harbor.One respondent, from a state without a safe harbor,investigates consumer complaints for unpaid claims, butlacks authority to compel an HCSM to respond unlessthere is evidence of fraud. Other respondents in safeharbor states suggested it could be difficult for regulatorsto exercise oversight if legislatures have afforded HCSMsa wide berth. Political support for HCSMs and resourceconstraints have limited their options for intervening,respondents added.States Can Perform Oversight, but Options AreConstrainedSome regulators described a reluctance to pursue actionWhether or not a state has exempted HCSMs fromnoted that even incremental or preliminary action caninsurance regulation, regulators may act under certainbe met with strong opposition. Regulators in one statecircumstances to safeguard consumers. Four respondentshad begun taking action against an HCSM for doingfrom states with safe-harbor rules said a thresholdbusiness without obtaining a license, but the legislatureconsideration was whether the HCSM was in complianceresponded by passing a safe harbor. Another respondentwith their safe-harbor criteria. For example, if an HCSMsaid that legislation to strengthen their safe harbor’sfails to provide required notice to consumers or violatesnotice requirement had been defeated, making regulatorsthe condition to have a religious component, respondentsdoubtful they could obtain even modest protections forsaid they would review the HCSM for activity indicatingconsumers. Following regulatory scrutiny of an HCSM’sit was doing business as an unlicensed insurer. One stateoperations, a third state’s legislature expanded theissued a cease-and-desist order for an HCSM that failed todefinition of HCSMs exempt from state regulation, makingcomply with the religious component of their state’s safethe HCSM’s operations legal under the revised safe harborharbor, rendering membership marketing comparabledefinition.without consumer complaints demonstrating harm andto doing business as an unlicensed insurer. But short offinding an HCSM out of compliance with the safe harbor,regulators were reluctant to take action against it.DISCUSSIONSome individuals may find value in HCSMs and viewRegardless of a state’s safe-harbor status, if a brokerthem as an alternative to ACA coverage. In particular, formisrepresents that an HCSM is insurance or claims thatconsumers who do not receive marketplace subsidies,it provides a guarantee of payment, states have the toolsHCSM have lower up-front costs. Yet these arrangementsand authority to act. Respondents pointed to the state’scarry risks. They may produce unforeseen consequencesauthority under their unfair trade practices statutes orfor members who do not understand what they are buyinga broker suitability standard, which requires brokers toand who find coverage too skimpy to cover their costs. Inensure a product is appropriate for a consumer’s needs.addition, consumers in the ACA-compliant market willcommonwealthfund.orgIssue Brief, August 2018

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?6experience rising premiums and fewer plan choices ifshould collect data — for example, by using audits toHCSMs and other alternative coverage options undermineobtain membership numbers or monitoring the use ofthe risk pool. But it has been difficult to evaluate how thesebrokers — to better understand the scope and magnitudearrangements have worked in practice, given competingof HCSMs in their states. States without an exemption maypriorities, limited resources, and political constraints. Inwant to go further and review the regulatory frameworkthe absence of reliable data on HCSM enrollment, stateunder which HCSMs operate.regulators cannot adequately assess the potential effectson consumers or their individual markets.While HCSMs may have previously served a nichemarket — providing some financial assistance for peopleAt least one reason people consider HCSMs for coverage —who share religious beliefs — many have transformedlower up-front costs than ACA plans — will likely persist,to give the appearance of traditional insurance. Asand increasingly broader marketing of these arrangementsthese entities grow, so too do the risks of consumercan capitalize on that to drive even greater enrollment.confusion, financial exposure, and market segmentation.In light of the expansion of non-ACA-compliant plansStates should more closely scrutinize whether theseavailable to individuals buying coverage,17 all states,arrangements are hewing to their original purpose andregardless of whether they have a safe harbor for HCSMs,the role HCSMs play in a regulated market.commonwealthfund.orgIssue Brief, August 2018

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?7NOTES1. Defined in 26 U.S.C. § 5000A(d)(2)(B) (2012). Theinformation and examples provided in this report arebased on a review of the guidelines of five health caresharing ministries. Four ministries attest that they meetthe ACA exemption: Altrua HealthShare, ChristianHealthcare Ministries, Medi-Share Christian CareMinistry, and Samaritan Ministries. The fifth, SederaHealth, specifically markets to small employers. TheAlliance of Health Care Sharing Ministries, a trade grouprepresenting Samaritan Ministries, Medi-Share ChristianCare Ministry and Christian Healthcare Ministries,reports that these three ministries represent the largestenrollment in the United States. See Altrua HealthShare,Membership Guidelines (Altrua, Jan. 2018); ChristianHealthcare Ministries, Guidelines Version 1, 2018 (CHM,2018); Medi-Share, Program Guidelines and FrequentlyAsked Questions (MediShare, Nov. 2017); SamaritanMinistries, Guidelines for Health Care Sharing (Samaritan,July 2018); and Sedera Health, Select MembershipGuidelines (Sedera, Mar. 2018).2. See note 1.3. See note 1.4. Defined in 26 U.S.C. § 5000A(d)(2)(B) (2012).5. See, e.g., Rowden v. American Evangelical Associationand its Division of Christian Care Ministry d/b/a MediShare, Montana First Judicial District Court, Order onVarious Motions, Cause No. BDV-2006-109, Jan. 2007;Commonwealth of Kentucky, Appellant v. E. JohnReinhold (d/b/a American Evangelistic Association),Medi-Share, and Christian Care Ministry, Appellees, No.2008-SC-000839-DG.6. Kimberly Leonard, “Christians Find Their Own Way toReplace Obamacare,” U.S. News & World Report, Feb. 23,2016.7. See note 1.8. We use the term “broker” to include licensed insuranceagents and producers. See Tony Leys, “More IowansOpting for ‘Health Sharing Ministries’ as Alternativecommonwealthfund.orgto Increasingly Pricey Insurance,” Des Moines Register,updated Dec. 10, 2017.9. See note 1.10. Laura Santhanam, “1 Million Americans Pool Moneyin Religious Ministries to Pay for Health Care,” PBS NewsHour, Jan. 16, 2018; Laura Turner, “There’s a ChristianAlternative to Health Insurance, But It’s Not for Everyone,”BuzzFeed News, June 1, 2017; and Leonard, “ChristiansFind,” 2016.11. See note 1.12. We interviewed nine states with safe harbor laws —Alaska, Florida, Maine, Nebraska, New Hampshire,Pennsylvania, Texas, Utah, and Washington — and fourstates that do not have a safe harbor law — Massachusetts,Minnesota, Rhode Island, and West Virginia. Our studystates draw more heavily from those with a safe harborsince they represent the majority of states and werechosen to represent geographic diversity.13. A 2015 survey by Consumer Reports found that 87percent of privately insured Americans were unawareof what agency or department in their state is taskedwith handling complaints about health insurance and83 percent have never complained to a governmentagency about any issue ever. See Consumer ReportsNational Research Center, “Surprise Medical Bills Survey,”Consumer Reports, May 5, 2015.14. See note 1.15. See, e.g., Stephanie Armour, “More People Turn toFaith-Based Groups for Health Coverage,” Wall StreetJournal, Jan. 4, 2016.16. Figure reflects state-reported data. See also AnnieFeidt, “Alaskans Opt Out of Insurance, Turn to Health CareSharing Ministries,” Alaska Public Media, Nov. 9, 2015.17. Kevin Lucia et al., State Regulation of Coverage OptionsOutside of the Affordable Care Act: Limiting the Risk to theIndividual Market (Commonwealth Fund, Mar. 2018).Issue Brief, August 2018

Health Care Sharing Ministries: What Are the Risks to Consumers and Insurance Markets?8ABOUT THE AUTHORSACKNOWLEDGMENTSJoAnn Volk, M.A., is a research professor at the Centeron Health Insurance Reforms, Health Policy Institute,McCourt School of Public Policy at GeorgetownUniversity. Her work is focused on regulation of privatehealth insurance under the Affordable Care Act and theeffect of health coverage reform on access, affordability,and adequacy of coverage for consumers. Ms. Volk holdsa master’s degree in public policy from Johns HopkinsUniversity, with a concentration in health policy.The authors thank the state officials who shared their timeand valuable insights with us. We are also grateful to TimJost for his thoughtful review, and to Christina Goe andKevin Lucia for their review and contributions throughoutthe research for this brief.Emily Curran, M.P.H., is a research fellow at theGeorgetown University Health Policy Institute’s Center onHealth Insurance Reforms. Her research focuses on privatehealth insurance and the effects of the Affordable CareAct, with emphasis on the implementation of the federaland state health insurance marketplaces. Curran receivedher M.P.H. in health policy from George WashingtonUniversity’s Milken Institute School of Public Health.Justin Giovannelli, J.D., M.P.P., is an associate researchprofessor at the Georgetown University Health PolicyInstitute’s Center on Health Insurance Reforms. Hisresearch focuses primarily on the implementation ofthe Affordable Care Act’s market reforms and healthinsurance exchanges at the federal and state levels.Giovannelli received his law degree from the New YorkUniversity School of Law and his master’s degree in publicpolicy from Georgetown’s Public Policy Institute.For more information about this brief, please contact:JoAnn Volk, M.A.Research ProfessorCenter on Health Insurance ReformsGeorgetown University Health Policy InstituteJoAnn.Volk@georgetown.eduAbout the Commonwealth FundThe mission of the Commonwealth Fund is to promote a highperforming health care system that achieves better access,improved quality, and greater efficiency, particularly forsociety’s most vulnerable, including low-income people, theuninsured, and people of color. Support for this research wasprovided by the Commonwealth Fund. The views presentedhere are those of the authors and not necessarily those of theCommonwealth Fund or its directors, officers, or staff.Editorial support was provided by Deborah Lorber.commonwealthfund.orgIssue Brief, August 2018

The CommonwealthHealthCare Sharing Ministries:FundWhat Are the Risks to ConsumersHowandHighInsuranceIs America’sMarkets?Health Care Cost Burden?9APPENDIX 1. STATE SAFE HARBOR STATUTES APPLICABLE TO HEALTH CARE SHARING MINISTRIESHealth care sharing ministry (HCSM) defined as niaColoradoConnecticutDelawareDistrict of kaNevadaNew HampshireNew JerseyNew MexicoNew YorkNorth CarolinaNorth DakotaOhioOklahomaOregonPennsylvaniaRhode IslandSouth CarolinaSouth est VirginiaWisconsinWyomingHCSMs exemptfrom stateinsurancecode?A written disclaimerthat the organizationis not an insurancecompanyA written monthly statement to participants listing:(a) the total dollar amount of qualified needssubmitted to the HCSM; and (b) the amountassigned to participants for their XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXAn annualauditXXData: Authors’ analysis of state laws governing health care sharing ministries.commonwealthfund.orgIssue Brief, August 2018

The CommonwealthHealthCare Sharing Ministries:FundWhat Are the Risks to ConsumersHowandHighInsuranceIs America’sMarkets?Health Care Cost Burden?10APPENDIX 2. KEY FEATURES OF HEALTH CARE SHARING MINISTRIESFeaturesAltrua Ministries/Altrua HealthShareChristian HealthcareMinistriesMedi-Share ChristianCare Ministry (CCM)Samaritan MinistriesSedera HealthPaymentsto coverministry’sadministrativecostsPart of members’monthly contributionsare used to runmembership and supportqualified charitiesNone indicatedMembers pay a monthlyadministrative portionfrom each monthly sharefor CCM’s administrativeexpensesOne month share fromeach member annuallysupports administrativeservicesEach month, 9.9% ofmedical cost-sharingdollars are retained foradministrative costs;Sedera may retain upto the first 90 days ofnew members’ monthlyshares to cover programexpenses and costsrelated to expanding thecommunityBased on sharing (metal)level and number ofmembers in householdBased on age and numberof members in thehousehold; additionalmonthly charge forHealth Partners, aprogram for those athigher risk for diseaseor who have significantweight gainBased on age, numberof members in thehousehold, andmembership levelBased on each memberin the household’sdependent status,age, and employercontribution, if anyOther fees include: 100 annual membershipfee and a requested 25annual donation to AlturaMinistriesMonthlycontributionsBased on age, numberof members in thehousehold, plan metallevel and type: standardor advantageHouseholds with one ormore tobacco users aresubject to higher monthlyshare rateCoveragelevelsGold, silver, bronze levels,with option to enroll instandard or advantageprogram for eachGold, silver, bronze levels,with option to enroll inPlus program for eachto obtain additionalcoverageMembers select anannual householdportion (AHP) level forthe amount that mustbe paid toward eligiblemedical bills before anybill may be shared amongmembersClassic and basicmembership levelsVary by initialunshareable amount(IUA)Paymentsthat act asdeductiblesMember responsibilityamounts (MRA) rangefrom 500– 4,000 per“need” (i.e., expensesrelated to the samemedical condition),depending onmembership levelPersonal responsibilitypayments range from 500 (gold) to 1,000(silver) to 5,000 (bronze)per “need” (i.e., expensesrelated to the samemedical condition)AHPs range from 1,000– 10,500 and arereset annually*Initial unshareableamounts range from 300 for classic to 1,500for basic per “need” (i.e.,expenses related to thesame medical condition)IUA of 500– 1,000 per“need” (i.e., expensesrelated to the samemedical condition)Gold/silver: Lifetime limitof 1,000,000;Gold, silver, bronze: 125,000 per illness(can be increased withparticipation in “Brother’sKeeper” program)Limited to 50,000 in firstmonth of membership,but then no annualor lifetime limit forshareable expenses 250,000 for eachmedical need in classic, 236,500 in basicGold Plus: Unlimited perillnessService-specific limitsinclude: up to 36 sessionsfor cardiac rehabilitation;up to 20 visits combinedfor physical therapy oroccupational therapy perreferralPrior medical conditions(with 36-month lookback), if shareable,are subject to limits of 25,000 or 50,000depending onmembership tenure(and fully shareable with37-month tenure orlonger)SharinglimitsBronze: Lifetime limitof 1,000,000, witha 50,000 limit percalendar year**Service-specific limitsinclude: 6 office orurgent care visits peryear; no more than acombined 20 visi

sharing ministries (20 states and D.C.) State law explicitly exempts health care sharing ministries (30 states) State Laws Governing Whether Health Care Sharing Ministries Are Exempt from State Insurance Codes, 2018 Exhibit 1 Data: Authors’ analysis of state laws g

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