For Immediate Release
May 30, 2025
Contact: Court Beyer, cbeyer@americanhumanist.org
SALEM, Ore. – Yesterday, in front of Oregon’s House Committee on Behavioral Health and Health Care, health care and consumer advocates testified in support of HB 2268, which would require health care sharing arrangements to register with the Oregon Department of Consumer and Business Services and disclose information about coverage to consumers.
Fish Stark, Executive Director of the Center for Freethought Equality, offered the following testimony:
Chair Nosse, Vice Chair Javadi, Vice Chair Nelson, and Members of the Committee:
Thank you for the opportunity to testify today. My name is Fish Stark, and I serve as the Executive Director of the Center for Freethought Equality, the advocacy arm of the American Humanist Association. We work to advance public policies that uphold reason, science, and the separation of religion and government, ensuring all communities, including the nonreligious, are treated equally under the law.
I am here today on behalf of the Center for Freethought Equality to voice strong support for House Bill 2268. This legislation is a critical step forward in protecting Oregon consumers from the deceptive and harmful practices of Health Care Sharing Arrangements, which include health care sharing ministries and health care sharing organizations.
I also want to acknowledge and thank Jesse O’Brien and Angela Donley for their partnership in addressing this problem.
I’d like to start with a story of someone personally impacted by this issue: In nearby Washington, a retired electrician, Brad Fuller paid nearly $400 a month into what he believed was a legitimate health insurance plan. When he was hospitalized with a life-threatening cancer diagnosis, his plan denied the claim outright. He said, “they started checking my insurance and it didn’t cover nothing.” But, unknown to Mr. Fuller, he didn’t have insurance. He was enrolled in a health care sharing ministry. The impact? He was left with a bill totaling over $100,000, and the ministry he had faithfully paid into each month, paid nothing.
HB 2268 will not restrict health care sharing ministries from operating in the state nor will it restrict people from buying into these plans, but we do want to make sure that people, like Mr. Fuller, are not mistakenly purchasing into these organizations without the necessary information, and left with thousands of dollars of medical debt.
Let me begin with the basics.
What Are Health Care Sharing Ministries?
Health care sharing ministries, or HCSMs, are one prominent type of health care sharing arrangement that market themselves as faith-based alternatives to health insurance. They often require members to pledge adherence to specific religious beliefs and contribute a monthly fee to the organization to "share" health care costs with other members.
But unlike insurance plans, HCSMs are not legally required to pay any claims, cover essential health benefits, or adhere to basic consumer protections.
They are not insurance, but they talk like insurance, and advertise like insurance, until the moment you actually need coverage.
And that’s where the harm occurs.
Poor Alternatives to Insurance
Over the past decade, we have seen a disturbing pattern: consumers drawn in by low, affordable monthly rates, believing they’ve bought into a reliable service, only to be left with enormous medical bills when the HCSM denies coverage.
Many participants are low-income individuals who think they are getting a better deal than Marketplace coverage. A federal Government Accountability Office report found that more than 40% of one health care sharing ministry’s members had annual income below 200% of the federal poverty level. Many of these individuals qualify for free health insurance, and nearly all the rest would qualify for highly subsidized insurance, but they likely aren’t aware of these options because health care sharing ministries are not sold on state marketplaces.
And unlike insurance, there are no guarantees that ministries will cover critical health costs. For example, most health care sharing plans will deny payment for preexisting conditions, as is the policy of Samaritan Ministries–a plan operating in Oregon.
Zion Health Share, which also operates in Oregon, can make newborns wait 7 days before they can be enrolled in their parent’s plan - and if that newborn has any birth complications, those are pre-existing conditions, making the costs incurred by new parents unshareable (or ineligible for repayment) in the first year of the baby’s life.
Zion Health Share, also will not cost share for maternity care or miscarriage if a member becomes pregnant before or in the first six months of their membership.
Plans, like Liberty Health Share operating in Oregon, will not cost share for alcohol or drug use treatments, dialysis, mental health services including counseling, or psychological testing. Liberty, and most others, also will not cover most prescription medications.
Lastly, several plans set caps on coverage. Altrua Ministries, also operating in Oregon, has a lifetime limit of $1,000,000 and a $150,000 limit per calendar year on many of its plans.
These are just a few examples of the wide gaps in care. That’s to say nothing of the fact that even if a claim meets the stringent criteria for repayment, or “sharing”, there is no guarantee that it will be paid. Health care sharing ministries are not required to have funds on hand to ensure that claims are paid out or required to pay claims at all.
There are multiple states that have transparency requirements, including Colorado, which found that, in 2023, members of health care sharing ministries submitted $58.6m in claims eligible for payment–meaning claims well within the strict confines of what these organizations will cover. Of those eligible claims, less than 60% were paid out. In contrast, families with ACA-compliant insurance can trust that 100% of our qualified claims will be paid.
And whereas ACA-compliant insurers are required to spend no more than 20% on administrative costs, marketing and overhead combined, HCSMs have no such requirements. According to the GAO, one HCSM reported spending up to 40% of its members’ contributions on administrative costs alone.
I want to underscore that nothing in this bill would require these organizations to change any of these policies. But it would require them to make their restrictive policies and the involved risk clearer to consumers so that they can make a truly informed choice.
Deceptive Marketing Practices
Because the truth is - many consumers do not realize they have joined something that is not legally required to pay for their care until it is too late due to these organizations’ deceptive marketing practices.
Health care sharing ministry staff and insurance brokers alike are coached to intentionally use terms similar to insurance terms (for example, an “explanation of sharing” in lieu of an “explanation of benefits”). And name their plans platinum to bronze - just like insurers.
Mr. Fuller, the Washington resident I mentioned earlier, found his health care sharing ministry online. And given what we know, it’s unsurprising that he said he was drawn in by the low $350 a month premium. And when he called the ministry to enroll, he recalls that he was told he could get insurance, no problem.
And when plans do clarify that they aren’t insurance, it isn’t actually clear at all.
Impact Health Sharing–which operates in Oregon– misleadingly states on its website: “Health Care Sharing is different than insurance in that your money is always going to help another Member in need and not some cold and disinterested Insurance Company.”But in actuality, participants’ money does NOT necessarily go to help another member in need.
And “with Impact Health Sharing, you will find a lot of the same things you expect from typical healthcare coverage, and so much more!” But Impact Health Sharing does not offer many of the same things a consumer would expect from healthcare coverage, like coverage for pre-existing conditions. That’s not typical at all.
These statements downplay - or outright mislead about - the financial risks and limitations that come with choosing a health care sharing ministry, intentionally confusing even the most savvy of consumers.
The Real-World Harm
Oregon’s Department of Consumer and Business Services took enforcement action in 2021 against two of these organizations for misrepresenting themselves as insurance, but many continue to operate in Oregon without meaningful oversight.
Data about health care sharing ministries is mostly self-reported, leaving states to rely on anecdotal and selective information. And the full number of health care sharing ministries operating in Oregon is unknown due to the lack of any reporting requirements.
But, only because of Colorado’s transparency law, which requires ministries to share where they operate nationwide, we know of at least 10 health care sharing ministries operating in Oregon.
While we don’t know specifics for the 10 ministries we believe are operating in the state, to provide some sense of scale: 11 health care sharing organizations operating in Colorado reported collecting more than $39 million from members in 2023. But, as things stand now, neither I nor anyone here can tell us their reach in this state.
How HB 2268 Helps
We do not know how many Oregonians are enrolled in health care sharing ministries, how much money these organizations collect, what percentage of eligible claims they pay, or whether they are financially solvent enough to support their members.
House Bill 2268 is a basic consumer protection measure. It does not ban health care sharing ministries from operating in the state, or change how they operate. It simply says: if you are going to operate in Oregon, you must register with the Department of Consumer and Business Services. You must tell the state–and the public–basic facts about how you operate: How many people you cover. How much money you collect. What you pay out in claims. What coverage you exclude.
This bill also requires these organizations to be honest in their consumer-facing materials. They must clearly disclose that they are not insurance and not guaranteed to cover medical costs. They must list which services are excluded, particularly those that most often catch consumers off guard, like maternal care. And they must notify members in advance of any material changes to their benefits.
This is a common sense proposal. It follows Colorado’s lead, where a similar law has been successfully implemented, and it aligns with recommendations from national consumer advocates like the Leukemia & Lymphoma Society and Georgetown University’s Center on Health Insurance Reforms.
Why This Matters for Oregon
If someone wants to operate or join a health care sharing ministry in the state – neither we, nor this bill, would attempt to stop them. Our humanist values call us to believe that everyone should be empowered to make the choices that align with their conscience - but that they are owed truthful and comprehensive information to help them do so. We believe any legitimate health coverage provider should find it easy and agreeable to offer this basic information to consumers.
Thank you again for the opportunity to testify. I urge you to support House Bill 2268 and protect Oregon consumers from the growing risks posed by unregulated health care sharing organizations. I look forward to your questions.
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The Center for Freethought Equality (CFE) is the political and advocacy arm of the American Humanist Association. CFE is dedicated to advancing the policy interests of humanists and atheists, and politically empowering our community in the United States. Alongside its advocacy and organizing efforts, CFE has an affiliated political action committee, the Center for Freethought Equality PAC, whose mission is to achieve equality for our community by increasing the number of open humanists and atheists, and allies, in public office at all levels of government.
The American Humanist Association (AHA) works to protect the rights of humanists, atheists, and other nontheistic Americans. The AHA advances the ethical and life-affirming worldview of humanism, which—without beliefs in gods or other supernatural forces—encourages individuals to live informed and meaningful lives that aspire to the greater good of humanity.
