It’s not consumer advocacy when the Freedom From Religion Foundation (FFRF) warns Americans to “beware” of Health Care Sharing Ministries. It’s ideological advocacy that clearly targets the First Amendment.
But FFRF, an atheist-affirming group, is correct about one thing: Health Care Sharing Ministries are not insurance. That fact has never been hidden. It’s the legal foundation on which these ministries exist.
For decades, federal and state law have explicitly recognized Health Care Sharing Ministries as religious, nonprofit mutual-aid organizations — not insurance companies. Congress carved out a specific statutory recognition of these ministries in the Affordable Care Act. Thirty-four states define them in law, recognizing that they are not engaged in the business of insurance and thus are not subject to the Insurance Code.
They are voluntary religious associations. And the Constitution protects them as such.
FFRF demands that the government treat these ministries as if they were commercial insurers — forcing them into regulatory frameworks designed for profit-driven corporations, which would compel disclosure of internal operations, ministry relationships and communications, and subjecting religious communities to intrusive oversight that goes far beyond fraud prevention.
That’s not neutral regulation. That’s religious targeting.
The First Amendment does not only protect the right to hold beliefs in private. It protects the free exercise of religion, the right of association, and the right of religious communities to organize their internal affairs without excessive government entanglement.
Health Care Sharing Ministries are a modern expression of an ancient religious practice: believers voluntarily bearing one another’s burdens. Members commit morally — not contractually — to help meet medical needs. They pray. They encourage. They give. They form communities structured around shared convictions about stewardship, personal responsibility, and care for the suffering.
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More than 1 million Americans participate in these ministries today. Together, they share more than $1 billion each year to help families facing cancer, catastrophic injury, and life-altering illness.
This is not commerce. It is a religious community.
Yet FFRF insists on mischaracterizing these ministries as “masquerading,” “swindling,” and inherently deceptive — not because of demonstrated systemic fraud, but because they operate outside a secular insurance paradigm and reflect religious moral commitments.
Is this framing intentional or uneducated? These opponents know that fraud is already illegal in every state. State attorneys general possess broad enforcement authority. They have used it. Bad actors have been shut down under existing law.
Instead, this organization objects to the existence of religious alternatives.
The group’s own symposiums and legislative campaigns make this clear. FFRF and its allies are actively coordinating model bills, lobbying state officials, and pressuring regulators to impose sweeping reporting and registration schemes that force ministries to disclose vendor contracts, internal communications, operational structures, and associational relationships — the very type of compelled exposure the Supreme Court has repeatedly warned can chill religious exercise and freedom of association.
No insurance company is asked to open its internal community life to this level of inspection. No secular nonprofit is subjected to this degree of ideological suspicion. But religious ministries are.
That is precisely what the First Amendment forbids.
The group argues families are being “misled.” But Health Care Sharing Ministries make their nature unmistakably clear. Members affirm in writing that participation is voluntary, that ministries are not insurance, that no contractual obligation exists, and that members remain responsible for their own medical bills.
This is not hidden in footnotes. It is central to the model.
FFRF’s position ultimately rests on the idea that government must protect adults from making voluntary, religiously motivated choices that do not conform to bureaucratic health-care structures. That impulse — to erase lawful alternatives in the name of “protection” — is not consumer advocacy. It is coercion.
The Constitution forbids this use of government force in such a voluntary association as joining a Health Care Sharing Ministry instead of buying insurance. It protects the right of Americans to structure their lives around convictions the government may not share.
Health Care Sharing Ministries are not for everyone. Insurance can be the right choice. Direct-pay care is often the right choice. But the First Amendment exists precisely to protect minority practices from being regulated out of existence by ideologically driven majorities.
FFRF has a protected right to oppose religious belief. This does not give it the authority to enlist the regulatory state to suppress religious communities.
The Alliance of Health Care Sharing Ministries supports transparency, honest marketing, and accountability. It has consistently called for consumer education and enforcement against anyone who misrepresents these programs.
The Alliance opposes — and the Constitution forbids — the weaponization of regulatory power to burden religious associations simply because they are religious.
Health Care Sharing Ministries are lawful. They are recognized. They are voluntary. And they are protected.
The legislative campaign against Health Care Sharing Ministries is not about informing consumers. It is about narrowing the space religious Americans are permitted to occupy.
The First Amendment does not allow that. And neither should we.
Catherine Snow is the deputy director for the Alliance of Health Care Sharing Ministries.
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