States’ options for addressing regulatory concerns and consumer complaints about health care sharing ministries (HCSMs) are limited. Thirty states have “safe-harbor” rules that exempt HCSMs from state insurance regulations. Many HCSMs use features that are very similar to insurance and may therefore mislead consumers into thinking they are enrolling in coverage that guarantees payment for a covered claim. If HCSMs draw healthier individuals out of the ACA-compliant market, it will help create smaller and sicker risk pools in that market, with higher premiums and fewer plan choices.
