* * *
My name is
At Insurance Solutions I work almost exclusively with self-employed business owners. The majority of my clients do not qualify for a subsidy under the Affordable Care Act (ACA). A successful small business owner earns too much to be eligible for the tax benefits built into ACA plans making the plans overly expensive. My professional responsibility is to help each client find an effective solution, but this is exceedingly challenging to accomplish when many plans are priced at
In an attempt to find solutions that better fit my clients and myself, I've spent time exploring healthcare sharing ministries. While they are not insurance plans, health care sharing ministries are a legitimate way for employers and individuals to cost-effectively manage health care expenses. HCSMs can be a good fit for many of my clients. And at the end of the fiscal year, offering membership in a health care sharing ministry typically ends up being significantly less expensive for employers than traditional health insurance.
Today, I have a hard time marketing and selling medical cost sharing memberships to my clients for two reasons.
* First, one of my biggest sales tools is reminding self-employed individuals that they are eligible to fully deduct the cost of their insurance premiums for tax purposes. This incentive does not currently exist for contributions to health care sharing ministry memberships. The lack of tax benefits associated with HCSMs typically results in a net cost that is ~30% greater than it would be if a tax benefit were available.
* Second, many health care sharing ministries limit their memberships to members of certain religions or denominations. From an employer's point of view, it is unreasonable to assume that all employees share the same religious beliefs associated with one health care sharing ministry.
The second obstacle I discussed can be addressed with a simple revision to the proposed rule's definition of a health care sharing ministry. As the rule is currently written, only organizations founded before and continually sharing medical expenses since
Some newer, financially sound, health care sharing ministries do not restrict membership based on religious beliefs and are instead united by ethical beliefs, which the definition otherwise allows; but the proposed rule unfairly excludes them from eligibility for tax benefits. I strongly believe that health care sharing ministries are a valuable tool for individuals and employers to have at their disposal, and a simple amendment to the proposed rule would ensure that people of all faiths or of no religious affiliation will be able to take advantage of the tax benefits offered by this rule change.
In summary, I am asking the
* Remove the 1999 requirement from the proposed rule's definition of health care sharing ministries interpreting eligible expenses under Section 213(d) of the
Thank you for taking the time to read through my comments. I strongly encourage the
* * *
The proposed rule can be viewed at: https://www.regulations.gov/document?D=IRS-2020-0016-0001
TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact