Can an HRA Reimburse Health Care Sharing Ministry Membership Donations?
Several popular Health Care Sharing Ministries have grown significantly since the passage of the Affordable Care Act. By definition, a health care sharing ministry is a nonprofit organization that facilitates sharing of health-care costs between individual members. Because these organizations are by definition and structure, not an insurance company, the way that they’re treated with regards to taxes and other benefit remibursements are different. A common question we receive is:
Can an HRA Reimburse Health Care Sharing Ministry Membership Donations?A simple answer, no. Health Reimbursement Arrangements cannot reimburse employees for their membership fees/donations (“premiums”) to a health care sharing ministry program. Why?
- IRC Section 213 governs which types of expenses and health insurance premiums can be reimbursed through these types of reimbursement plans.
- IRC Section 213 specifies in “(D) for insurance (including amounts paid as premiums under part B of title XVIII of the Social Security Act, relating to supplementary medical insurance for the aged) covering medical care referred to in subparagraphs (A) and (B) or for any qualified long-term care insurance contract (as defined in section 7702B (b)).”
- Health care sharing ministry programs are not offered by an insurance company, and the benefit is not insurance. Therefore, the membership fees/donations are not reimbursable according to IRS guidelines.