Health Care Sharing Ministry Tax Deduction: IRS Rules and Pending Bill

Payments to a health care sharing ministry are not deductible on your federal income tax return. The IRS does not treat the monthly share as a health insurance premium or as a direct medical expense, so no health care sharing ministry tax deduction is available under current law, whether you itemize, take the standard deduction, work for an employer, or work for yourself. A bill pending in Congress would change that, but it is not law yet.

Why the Monthly Share Isn’t a Deductible Medical Expense

The medical expense deduction covers amounts paid for diagnosis, treatment, and prevention of disease, plus premiums for insurance that covers those services.1Office of the Law Revision Counsel. 26 U.S. Code 213 – Medical, Dental, Etc., Expenses A monthly ministry share is neither. It isn’t a payment for treatment you received, and it isn’t an insurance premium, because the arrangement is structured as voluntary sharing among members rather than a contract that transfers risk to a regulated insurer.

IRS Publication 502, which lists the insurance premiums you can include as medical expenses, doesn’t mention health care sharing ministries at all.2Internal Revenue Service. Publication 502 – Medical and Dental Expenses The publication covers premiums for hospitalization, surgical services, prescription drugs, dental care, and long-term care. Ministry membership doesn’t produce a policy or a contract of insurance, which is why it doesn’t appear.

Even if the shares did qualify, the math rarely helps. Unreimbursed medical expenses are only deductible to the extent they exceed 7.5% of your adjusted gross income, and only if you itemize.3Internal Revenue Service. Topic No. 502, Medical and Dental Expenses Most households don’t accumulate enough itemized deductions to beat the standard deduction in the first place.

One related point worth keeping straight: if the ministry does share toward one of your medical bills, you can’t deduct that same expense yourself. The medical expense deduction only reaches costs you paid out of pocket and were not reimbursed for, by anyone, including a sharing ministry.3Internal Revenue Service. Topic No. 502, Medical and Dental Expenses

The Self-Employed Health Insurance Deduction Doesn’t Reach Shares

Self-employed people get an above-the-line deduction for health insurance premiums that doesn’t require itemizing. The statute limits it to amounts paid “for insurance which constitutes medical care.”4Office of the Law Revision Counsel. 26 USC 162 – Trade or Business Expenses Because a health care sharing ministry isn’t an insurance product, your monthly share doesn’t qualify.

This is where self-employed members feel the gap most. A self-employed person paying $500 a month for a traditional health insurance policy can deduct $6,000 a year directly from gross income. A self-employed person paying $500 a month to a sharing ministry gets no deduction, even though both payments serve the same practical purpose.

Not a Charitable Contribution Either

Your monthly share isn’t deductible as a charitable contribution, even if the ministry is a tax-exempt nonprofit. Charitable deductions require a gift to a qualified organization without expecting something of roughly equal value in return.5Internal Revenue Service. Charitable Contribution Deductions When you pay the share, you’re participating in a system meant to cover your own future medical costs and those of other members. That expected material return disqualifies the payment as a charitable gift.

Some ministries do accept separate, voluntary donations above the required share. If the ministry holds 501(c)(3) status, those extra donations may qualify as deductible charitable contributions.6Internal Revenue Service. Exemption Requirements – 501(c)(3) Organizations The line sits between a payment tied to the sharing arrangement and a genuinely unrestricted gift. Only the second has any chance at deductibility.

What About Money the Ministry Pays Toward Your Bills?

Federal tax law doesn’t explicitly address whether funds you receive from a sharing ministry to cover medical bills are taxable income. Neither the Internal Revenue Code nor IRS publications contain a clear rule. In practice, most tax professionals treat these payments much like gifts between individuals, which are generally not taxable to the recipient. Because the arrangement isn’t insurance, the payments aren’t treated as insurance reimbursements under the tax code either.

The practical result: if the ministry shares $5,000 toward your surgery, you most likely don’t owe income tax on that $5,000. But you also can’t deduct that $5,000 as a medical expense, because you didn’t bear the cost. You can only deduct what you actually paid out of pocket, assuming you itemize and clear the 7.5% AGI floor.1Office of the Law Revision Counsel. 26 U.S. Code 213 – Medical, Dental, Etc., Expenses

HSAs and Employer HRAs

A Health Savings Account offers deductible contributions, tax-free growth, and untaxed withdrawals for qualified medical expenses. To contribute, you must be enrolled in a high-deductible health plan.7Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts Sharing ministry membership alone is not a high-deductible health plan and does not make you HSA-eligible.

Some members pair the ministry with a separate low-cost high-deductible plan specifically to open an HSA. If you take that route, HSA dollars can pay for qualified medical expenses like doctor visits and prescriptions, but they can’t pay your monthly share. The IRS considers ministry membership fees a non-qualified expense, so an HSA withdrawal used for them is taxed as income and hit with a 20% penalty if you’re under 65.7Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts

Employer-side arrangements run into a similar wall. If your employer offers a Qualified Small Employer Health Reimbursement Arrangement, your out-of-pocket medical expenses may be reimbursable, but your monthly ministry fee itself is not an eligible expense. There’s also a tax wrinkle: a QSEHRA reimburses tax-free only when the employee has minimum essential coverage. A sharing ministry doesn’t count as minimum essential coverage, so any QSEHRA reimbursements you receive must be included in your gross income, which erases much of the benefit.

The ACA Exemption Isn’t a Deduction

Membership in a qualified ministry provides an exemption from the Affordable Care Act’s requirement to maintain minimum essential coverage.8Office of the Law Revision Counsel. 26 U.S. Code 5000A – Requirement to Maintain Minimum Essential Coverage That is a separate question from deductibility. Federal recognition of the ministry for ACA purposes does not convert your monthly shares into a deductible expense. A handful of states (including California, Massachusetts, New Jersey, Rhode Island, and the District of Columbia) run their own individual mandates with penalties, and whether ministry membership exempts you from a state penalty depends on that state’s law.

A Pending Bill Could Change the Answer

Treasury and the IRS have previously issued proposed regulations that would treat ministry membership fees as amounts paid for medical care, making them deductible on the same footing as insurance premiums. Those proposed regulations were never finalized.

In the current Congress, H.R. 2062 would amend the Internal Revenue Code to explicitly allow ministry membership amounts, including both medical expense shares and administrative fees, as deductible medical expenses.9Congress.gov. H.R.2062 – 119th Congress (2025-2026) If enacted, it would open the door to deductions through the self-employed health insurance deduction, medical expense itemization, or both.

Neither the proposed regulations nor the pending bill is current law. For the 2026 tax year, monthly ministry payments remain non-deductible. Keep clean records of what you pay so you’re ready to claim the deduction if the law shifts in a later year.