Health Share Transparency Act of 2025
The Health Share Transparency Act of 2025 would add a new Part F to Title XXVII of the Public Health Service Act to impose broad disclosure and transparency requirements on health care sharing ministries (HCSMs). The bill requires HCSMs to annually report extensive financial and operational data to the Secretary of Health and Human Services, the Commissioner of Internal Revenue, and the Director of the Consumer Financial Protection Bureau, and to publish similar information for public consumption. It also mandates disclosures to prospective and current enrollees about complaints processes, legal recourse, cost-sharing realities, and the differences between HCSMs and traditional health coverage. In addition, the bill imposes minimum contract standards for enrollment entities, and creates enforcement mechanisms including civil penalties. The Federal Trade Commission would also begin regular public disclosures of consumer complaints about HCSMs. The overall aim is to increase transparency and consumer protection around HCSMs, which are faith-based groups that share medical costs and are not traditional insurance. Potential impacts include greater public visibility into the finances and operations of HCSMs, more informed enrollment decisions, and higher compliance burdens on HCSMs and their enrollment contractors. Critics may argue the requirements could be costly or administratively heavy for smaller ministries, while supporters may view the bill as vital for consumer protection and accountability.
Key Points
- 1Establishes a new Part F (Health Care Sharing Ministries) in Title XXVII of the Public Health Service Act requiring annual disclosures to the Secretary, IRS Commissioner, and CFPB Director, plus public publication of the information.
- 2Disclosure scope includes detailed financial and operations data (e.g., financial reserves, spending on claims vs. administrative costs, enrollment numbers, total premiums paid, average out-of-pocket costs, provider contracts, denial rates, and claim reimbursement times) and the states/counties where enrollees can participate; this information is published on a public website.
- 3Requires information disclosures to prospective and current enrollees, including complaints/appeals processes, arbitration or other legal recourse, lack of guaranteed reimbursement, comparison with ACA plans, average payments, and lists of non-reimbursable items; disclosures must be prominent, multilingual, provided before enrollment, and readable (14-point font or read aloud if enrolling by phone).
- 4Sets entity enrollment requirements for contractors that enroll individuals or receive remuneration, including explanations of potential tax credits (IRC 36B), eligibility for state plans or Medicare/Medicaid, a comparison of ministry benefits to required protections, and a clear disclaimer that the ministry is not guaranteed health coverage.
- 5Enforcement: Civil penalties up to $100 per day per affected individual for noncompliance, with penalties subject to related provisions in current civil penalty law.
- 6FTC role: Publicly disclose, twice yearly, consumer complaints about HCSMs, including the number of complaints, general categories, and details about ministry ownership/operation and leadership; timing starts after enactment (first disclosures 90 days after enactment).