Specifically, Section 6 of the executive order directs the Secretary of Treasury to propose a new regulation that would make expenses related to health care sharing ministries eligible medical expenses in the United States Code. If the Treasury strictly follows the directive, we could soon see a regulation that makes enrollment in these ministries more attractive to consumers, as ministry members would now be allowed to fund their ministry "shares" or other expenses through a tax-advantaged Health Savings Account (HSA). Changing this incentive structure may boost ministry enrollment, which, in all likelihood, will further increase consumer confusion over the distinction between these cost-sharing arrangements and regulated health plans.
Health care sharing ministries operate cost-sharing funds that help members pay for medical expenses. Members generally pay a fixed monthly share that is either pooled into a general account or allocated directly toward another individual's medical bill. As members, individuals can submit medical bills to the fund to share the cost among the group.
As we've previously covered, these cost-sharing arrangements are not regulated health plans and are therefore not required to pay a member's medical bill. The distinction, however, is not always clear to ministry members, and media coverage often profiles patients who assume their health care sharing ministry would cover the care, only to be left with a medical bill when the ministry fails to pay the claim on time, or at all.
Implications for the revenue cycle leader
If the Treasury's proposed regulation does classify these ministry expenses as HSA-eligible medical expenses, the likely boost in health care sharing ministry enrollment will make pre-care financial conversations for patients under such arrangements even more important. By connecting patients who belong to a health care sharing ministry with a financial counselor, hospitals can help ministry members understand the distinction between their arrangement and a traditional health plan. Counselors should explain that payment through their ministry isn't legally guaranteed, and proactively connect patients with payment plans and other hospital resources to help patients pay their medical bills.
By offering additional financial resources before care delivery, revenue cycle leaders will not only decrease patient financial stress, but also mitigate bad debt that may come from a patient whose claim was denied by his or her health care sharing ministry.
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