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Health-sharing ministry's bankruptcy shows need for good standards, scrutiny, insiders say

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A faith-based ministry that aimed to help Christians share one another’s medical costs filed for bankruptcy and dissolved last year, leaving members with tens of millions of dollars in unpaid medical bills. In response, others in the health share ministry field emphasized the need for high standards.

Sharity Ministries, formerly known as Trinity HealthShare, had 40,000 members at its peak. But in recent years, the organization had faced class action lawsuits. Regulators in several states said it had been operating as an unauthorized insurance provider, Christianity Today reports.

In 2021, Sharity Ministries filed for bankruptcy and finished liquidating itself in December. By that time, its remaining membership numbered 10,000—but its unpaid claims ranged from $50 million to $300 million.

Katy Talento, executive director of the Alliance of Health Care Sharing, welcomed official scrutiny of the organization, which was never a part of the trade group for these ministries.

“The alliance stands in solidarity with a number of states that have used current authorities under state law to shut down Aliera Companies and its business partner Sharity Ministries (formerly Trinity HealthShare) and protect their citizens from further harm by these organizations and their leaders,” she said.

Unlike a health insurance company, which pools insurance premiums under company control, Sharity promised members that they could share each other’s medical bills. It appealed to Scripture passages about bearing one another’s burdens and sharing with other Christians in need.

About 1.5 million Americans are members of this kind of ministry, according to the Alliance of Health Care Sharing. Some $2 billion in medical expenses were shared through this type of ministry in 2020.  There are over 100 such organizations certified by the U.S. Department of Health and Human Services for meeting the federal law’s definition of a health sharing ministry.

Like many other health sharing ministries, Sharity restricted membership based on Christian religious belief and on pledges to avoid risky behavior. Members paid premiums into the plan to share others’ health sharing costs, with the idea that their own health share costs would be paid for—though payment is not necessarily guaranteed. The ministry claimed its programs cost about half the price of health insurance.

Court documents from October 2021 indicated over $300 million in unpaid member claims. Former Sharity president and board member Joe Guarino, who resigned in August, told Christianity Today he did not know how this figure had grown from $50 million, reported to the board months before. Sharity Ministries spent as little as 16% on premiums, a 2022 lawsuit from the State of California alleged.

Though a liquidation trust has been set up to distribute remaining money to members with unpaid bills, they are likely to receive only a fraction of the money expected.

Sharity Ministries had said its vendor Aliera acted in bad faith. Aliera, a for-profit, was found guilty of fraud in 2020 and is now in bankruptcy proceedings.

Talento told CNA the Alliance of Health Care Sharing Ministries “maintains minimum standards for member ministries in order to preserve integrity and accountability for Health Care Sharing Ministries.”

“Trinity/Sharity was never a member of the Alliance,” she said. Talento’s organization works with seven of the nine ministries that have a large, nationwide, open membership and are certified by federal officials as meeting the relevant legal definition.

“Throughout the COVID-19 pandemic, members of Health Care Sharing Ministries relied on each other as they do for other health conditions, sharing in millions of dollars of medical bills related to diagnosis and treatment of COVID-19,” Talento said.

Talento said the Alliance recommends that potential members of a health sharing ministry confirm that they have a certification letter from the U.S. Centers for Medicare and Medicaid recognizing that the ministry meets the standards of the Affordable Care Act. They should also ask if the ministry in question is a member of the alliance.

Among the Catholic-focused ministries is Solidarity HealthShare. It is under the Melita Christian Fellowship Hospital Aid Plan, a now-independent ministry which has origins in a Mennonite community in northern Ohio. Solidarity HealthShare provides plans sensitive to Catholic concerns about excluding coverage for procedures like contraception, sterilization, abortion, and assisted suicide. The organization says it allows members “to share their healthcare expenses based on need.”

“While it is disappointing to hear allegations related to some ministries that are failing, Solidarity HealthShare is working every day to provide its Members with much needed options for affordable, reliable healthcare,” Brad Hahn, CEO at Solidarity HealthShare, told CNA April 21.

Members “gain access to the healthcare providers they choose with Solidarity helping to negotiate transparent and greatly reduced costs for their medical services,” he said. According to Hahn, the health sharing group shared more than $30 million in medical expenses in 2021, at a cost savings of 67%.

“We continue to operate on sound financial footing and make any adjustments needed to ensure the long-term structural integrity of our financial operations,” he said.

 “Solidarity values transparency and accountability,” Hahn continued. “Accordingly, Solidarity has adopted several good governance and accounting safeguards to help ensure responsible operations.”

Hahn cited good governance and accounting safeguards, including management by a majority-volunteer board of directors; a compensation committee; and “annual audits by an independent auditor in accordance with accepted accounting principles.” The ministry is also taking part in an accreditation process through the Columbus, Ohio-based financial analysis firm Demotech.

Members’ monthly contributions go into member accounts at an established credit union, for which the credit union acts as a fiduciary. These funds can only be used for sharing medical expenses.

Health sharing ministries do have their critics. Joann Volk, a research professor at Georgetown University’s Center on Health Insurance Reforms, has co-authored several articles with other researchers. Some of her work is posted to The Commonwealth Fund, a New York-based private foundation that seeks to improve the health care system through independent research and grantmaking.

In a March 2, 2022 article Volk co-authored with several other researchers for The Commonwealth Fund, Volk said these ministries “have features that closely resemble insurance and may have lower upfront costs than unsubsidized marketplace plans,” but they do not follow the same rules or provide any of the protections of insurance plans.

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“Unlike traditional insurance, these entities make no promise that enrollees will be reimbursed at all, even for health care claims that meet guidelines for payment,” she said.

According to data on Massachusetts-based ministries, health care claims paid by these ministries as a percentage of members’ monthly contributions ranged from 16 to 70% in 2019 and from 28 to 111% in 2020.

Volk compared these figures to federal laws that require all health insurance plans sold to individuals to pay at least 80% of premiums to health care costs. Massachusetts law requires 88% of premiums to go to health care costs.

In a 2020 article at the Commonwealth Fund, Volk and other researchers examined the drugs and services excluded at four nationwide health sharing ministries: Samaritan Ministries, Medi-Share Christian Care Ministry, Christian Healthcare Ministries, and Liberty HealthShare.

These ministries had a set dollar limit on costs associated with a diagnosis. These ministries also excluded payment for pre-existing conditions or imposed a waiting period of up to 36 months. Eligibility for maternity services payments was restricted to those enrolled prior to becoming pregnant and to those who are married.

Additionally, the ministries excluded maintenance medications required for chronic conditions. They excluded mental health or substance-use disorder treatments “except in very limited circumstances.”

While Catholics and others have selected some health sharing ministries specifically for exclusion of contraceptive coverage, Volk and her co-authors considered this an exclusion of health care coverage for women.

The Alliance of Health Care Sharing Ministries offered its view of best practices in a December presentation to the National Association of Health Insurance Commissioners’ working group on improper marketing of health insurance.

Honest health sharing ministries should have “robust disclosure” to potential members about how membership differs from health insurance funds, which pool member funds centrally, the alliance said. Health sharing ministries should publicly report audits and administrative overhead. Further, they should have independent governance and comprehensive guidelines.

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