Health Care Sharing Ministry Tax Deduction: IRS Rules and HSAs

Payments you make to a health care sharing ministry are not tax deductible on your federal return. The IRS does not treat monthly shares as health insurance premiums or as payments for medical care, so they don’t fit any category that produces a health care sharing ministry tax deduction. That’s true whether you itemize or take the standard deduction, and whether you’re an employee or self-employed. A bill in Congress would change this, but it isn’t law yet.

Why HCSM Shares Don’t Qualify as a 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 HCSM monthly shares are neither. They aren’t payments for treatment you received, and they aren’t insurance premiums, because a sharing ministry is a voluntary arrangement among members rather than a contract of insurance with a regulated carrier.

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

Even if shares were deductible under Section 213, the arithmetic would rarely help. You can only deduct unreimbursed medical expenses 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 For 2026, the standard deduction is $16,100 for single filers and $32,200 for married couples filing jointly.4Internal Revenue Service. IRS Releases Tax Inflation Adjustments for Tax Year 2026 Most households don’t clear those thresholds with itemized deductions in the first place.

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

Self-employed filers get an above-the-line deduction for health insurance premiums under Section 162, and it doesn’t require itemizing. But the statute limits it to amounts paid “for insurance which constitutes medical care.”5Office of the Law Revision Counsel. 26 USC 162 – Trade or Business Expenses Because an HCSM is not an insurance product, monthly shares don’t qualify.

This is where self-employed members feel the difference most. A self-employed filer paying $500 a month for traditional health insurance can deduct $6,000 a year directly from gross income. The same person paying $500 a month to an HCSM gets nothing, even though both payments cover the same practical need.

Charitable Contributions Don’t Work Either

Your monthly share isn’t a charitable contribution, even if the ministry itself holds tax-exempt status. A charitable deduction requires a gift to a qualified organization without expecting something of roughly equal value back.6Internal Revenue Service. Charitable Contribution Deductions Paying your share buys you a spot in an arrangement that will cover your future medical bills, which is a material return.

Some ministries accept separate voluntary donations on top of the required share. If the ministry has 501(c)(3) status, an unrestricted donation of that kind may qualify as a deductible charitable contribution.7Internal Revenue Service. Exemption Requirements – 501(c)(3) Organizations What matters is the line between a payment tied to sharing and a genuine gift.

Bills the Ministry Pays for You

If the HCSM shares in one of your medical bills, you can’t turn around and deduct that same bill on your return. The medical expense deduction only covers costs you paid out of your own pocket and were not reimbursed for, by anyone, sharing ministries included.3Internal Revenue Service. Topic No. 502, Medical and Dental Expenses Only the portion you actually paid counts toward the 7.5% AGI threshold, and only if you itemize.

Money you receive from the ministry to cover a bill sits in a gray zone at the federal level. Neither the Internal Revenue Code nor IRS publications address it directly. Most tax professionals treat these payments the way they treat gifts between individuals, and don’t report them as taxable income to the recipient. The sharing amount isn’t an insurance reimbursement either, because the arrangement isn’t insurance.

HSA Interaction

Health Savings Accounts give you a deduction for contributions, tax-free growth, and tax-free withdrawals for qualified medical expenses. But you have to be enrolled in a high-deductible health plan to open one and contribute.8Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts HCSM membership on its own is not an HDHP and doesn’t make you HSA-eligible.

Some members pair a sharing ministry with a separate low-cost HDHP to unlock HSA eligibility. If you do that, HSA dollars can pay for qualified expenses like doctor visits and prescriptions, but they cannot pay your monthly HCSM share. The IRS treats sharing ministry fees as a non-qualified expense, so an HSA withdrawal used for them is taxed as income and, if you’re under 65, hit with a 20% penalty.8Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts

One Boundary Worth Noting

Membership in a qualifying HCSM does give you an exemption from the Affordable Care Act’s requirement to maintain minimum essential coverage.9Office of the Law Revision Counsel. 26 U.S. Code 5000A – Requirement to Maintain Minimum Essential Coverage That’s a coverage question, not a deduction question. Federal recognition of your ministry for ACA purposes does not convert your monthly share into a deductible expense.

A Pending Bill That Would Change the Answer

Treasury and the IRS have previously issued proposed regulations that would treat HCSM shares as amounts paid for medical care, opening them up to the same deduction rules as insurance premiums. Those proposals were never finalized.

H.R. 2062 in the current Congress would amend the Internal Revenue Code to allow HCSM membership amounts, including both shared medical expenses and administrative fees, as deductible medical expenses.10Congress.gov. H.R.2062 – 119th Congress (2025-2026) If enacted, it would potentially reach the self-employed health insurance deduction, the itemized medical expense deduction, or both.

Neither the proposed regulations nor the pending bill is current law. For the 2026 tax year, monthly HCSM payments are not deductible. Keep your payment records anyway. If the law changes, you’ll want them.