Last reviewed: 6 October 2026
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Health care sharing ministries and insurance: how federal law, a Florida statute and the Texas Department of Insurance describe the difference
The short answer: the Texas Department of Insurance (TDI) describes health care sharing ministries as a non-insurance arrangement in which members agree to make monthly payments to pay other members' medical expenses.[1] Federal tax law gives a specific definition of a ministry for one purpose, and Florida's statute exempts an organization that meets its conditions from the Florida Insurance Code, including by providing amounts that participants may contribute "with no assumption of risk and no promise to pay."[2][3] This page reports what those sources say. It does not rate any organization.
The short version
- In its section on other health coverage that is not insurance, which lists subscription plans, discount plans, agricultural organization plans and health care sharing ministries, TDI says these arrangements are not insurance and, because they are exempt from regulation, TDI usually cannot help if you have a complaint. That sentence covers the whole category, not only ministries.[1]
- Florida's statute requires a written disclaimer stating that the organization is not an insurance company and that whether anyone assists you with your bills is totally voluntary.[3]
- The federal tax code's definition has five parts, including a 501(c)(3) tax status, shared beliefs, and continuous sharing since at least December 31, 1999.[2]
- A state's rules can differ. This page reads Texas and Florida only.
What TDI says
- Texas law "allows some other ways to pay for health coverage that are exempt from most state regulations and federal protections. These aren't insurance."[1]
- Health care sharing ministries "limit membership to people of a similar faith. They're a non-insurance arrangement where members agree to make monthly payments to pay for other members' medical expenses."[1]
- TDI says some spend a high percentage of member contributions on administrative expenses, that they often exclude pre-existing conditions and are not regulated by the state or federal government, and that if one does not pay a member's claim the member has no legal protection.[1]
- TDI says Texas has taken enforcement actions against some of them for violations of the Texas exemption law.[1]
The federal tax-code definition
Section 5000A of the Internal Revenue Code, the minimum essential coverage provision, excludes from "applicable individual" a person who is a member of a health care sharing ministry for the month. It defines a health care sharing ministry as an organization:[2]
- described in section 501(c)(3) and exempt from tax under section 501(a);
- whose members share a common set of ethical or religious beliefs and share medical expenses among members in accordance with those beliefs, without regard to the state in which a member resides or is employed;
- whose members retain membership even after they develop a medical condition;
- that, or a predecessor, has existed at all times since December 31, 1999, with medical expenses of its members shared continuously and without interruption since at least that date; and
- that conducts an annual audit by an independent certified public accounting firm in accordance with generally accepted accounting principles, made available to the public on request.[2]
That definition is written for the tax provision. It is not a finding that any organization is or is not insurance, and it does not itself regulate how an organization operates. Separately, in section 5000A the applicable dollar amount of the payment is $0 ((c)(3)(A)) and the percentage-of-income amount is zero percent for taxable years beginning after 2015 ((c)(2)(B)(iii)); the amendment notes say the $0 change applies to months beginning after December 31, 2018. So the payment that section describes is currently zero. Some states have their own coverage requirements, which this page does not cover.[2]
Florida's statute: the conditions for exemption from the Insurance Code
Section 624.1265 of the Florida Statutes says a nonprofit religious organization is not subject to the Florida Insurance Code if it meets all of these conditions:[3]
| Condition (Fla. Stat. 624.1265(1)) | What it requires |
|---|---|
| Tax status | Qualifies under section 501 of the Internal Revenue Code.[3] |
| Membership | Limits participants to members who share a common set of ethical or religious beliefs.[3] |
| Role | Acts as a facilitator among participants who have financial, physical or medical needs, in accordance with criteria the organization establishes.[3] |
| How needs are met | Provides for needs through contributions from other participants, or through payments directly from one participant to another.[3] |
| Risk | Provides amounts that participants may contribute, with no assumption of risk and no promise to pay.[3] |
| Reporting | Provides a monthly accounting of the total dollar amount of qualified needs actually shared in the previous month.[3] |
| Audit | Conducts an annual audit by an independent certified public accounting firm in accordance with generally accepted accounting principles, made available by copy on request or posting on its website.[3] |
| Agents | Does not market or sell health plans through agents licensed under chapter 626 of the Florida Insurance Code.[3] |
The statute also says a participant may limit the needs eligible for payment, and the organization may cancel a membership when a participant fails to meet the conditions of membership for more than 60 days. It requires a written disclaimer on or accompanying all applications and guideline materials. The disclaimer must read in substance that the organization "is not an insurance company," that membership is not offered through an insurance company, that the organization "is not subject to the regulatory requirements or consumer protections of the Florida Insurance Code," that whether anyone chooses to assist you "will be totally voluntary," and that you are "always personally responsible for the payment of your own medical bills."[3]
Why the agent condition matters for this site
One of Florida's exemption conditions is that the organization does not market or sell health plans through licensed insurance agents.[3] That is a statement of a Florida condition, not a rule for every state. If someone who holds an insurance license presents a sharing arrangement to you as insurance, our guides on checking a license and filing a complaint explain how to verify who they are. For other products that look like insurance but are not, see discount medical plans.
How to verify this yourself
Read the TDI page "Shopping for other ways to get a health plan? Choose wisely," Florida Statute 624.1265 and 26 U.S.C. 5000A(d)(2)(B). Then read the disclaimer on the organization's own application or guidelines and compare it with the notice your state requires. Ask your state insurance department whether it regulates the arrangement and whether you could complain to it.
What this page does not cover
We do not name or rate any organization, say whether any specific arrangement meets a state's or the federal definition, or advise on whether to join one. We do not cover other states' statutes, tax consequences, short-term or limited-benefit plans, or how a state's individual coverage requirement treats membership. State law differs, and one state's page is not another's rule. This is general information, not insurance or legal advice. For your own situation, ask your agent or insurer, or contact your state insurance regulator.
Your next step
If you are comparing a sharing arrangement with a health plan, read its application disclaimer and ask in writing who regulates it, who pays when a bill is not shared and what you owe if it does not. Our guide to the Summary of Benefits and Coverage shows what a regulated plan must disclose by rule.
Related checks
Our standard explains how we check an agent's license and disciplinary history. Check an agent reports our findings at category level, as a method and not a verdict. Neither reviews any insurer, plan or product. For other coverage that is not insurance, see discount medical plans. For who regulates insurance in the first place, see who regulates insurance. More plain-language guides are in the agent guides.
When we will update this page
We re-read the sources when they change. If something here is out of date, tell us. Corrections are dated on the page.
References
- [1] Texas Department of Insurance, "Shopping for other ways to get a health plan? Choose wisely" (last updated 1/7/2026), read 6 October 2026 — tdi.texas.gov/consumer/alternative-health-plans.html
- [2] Cornell Law School Legal Information Institute, text of 26 U.S.C. § 5000A(d)(2)(B) (health care sharing ministry), read 6 October 2026 — law.cornell.edu/uscode/text/26/5000A
- [3] Florida Legislature, Florida Statutes § 624.1265 (nonprofit religious organization exemption; authority; notice), read 6 October 2026 — leg.state.fl.us/statutes/.../0624.1265.html
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