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By now, most smaller churches and ministries across America are probably aware they are exempt from the employer mandate of the Affordable Care Act (ACA) because they have fewer than 50 full-time equivalent employees (FTEs). That’s the good news.

The bad news: Without even knowing it, many of these same organizations may be subjecting themselves to penalties of up to $100 per employee, per day, per violation for making voluntary healthcare payments on behalf of employees (i.e., for individual policy premiums or for other out-of-pocket medical costs) that do not comply with ACA market reforms. These onerous penalties became effective for health plan years beginning on or after January 1, 2014, so care must be taken now to understand and follow the existing guidance.


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