Coverage type · Student, short-term or other
Short-term plan, sharing ministry and other non-compliant products
Short-term plans, sharing ministries and fixed indemnity products sit outside the Affordable Care Act appeal and independent review rules and the No Surprises Act. Your rights come mostly from the contract and state law. Options are fewer; this page says so.
On this page 7
- Who has this
- People covered by a short-term, limited-duration insurance plan, a health care sharing ministry membership, or a fixed indemnity product that pays set dollar amounts. These are often sold as cheaper alternatives to full health insurance.
- Who regulates it
- Short-term plans are sold by insurers, so your state insurance department is the place to ask. What it can do varies, and we did not confirm it for your state. We found no federal appeal or external review rule for sharing ministries, and state treatment varies and was not checked. Fixed indemnity products are outside the federal health coverage requirements.
- Can your state help?
- Partly. Often, for a short-term plan or other insurance policy: your state insurance department can answer questions and may take a complaint. For a sharing ministry, state treatment varies and was not checked, so ask your department whether it covers ministries. State help is not a federal appeal right and the department may not be able to make the company pay. Find your state.
How to tell this is your coverage
- Short-term plan: your policy says short-term, limited-duration or temporary coverage and has an end date. The federal definition requires a warning notice on the plan. Check the first pages of the policy or the application.
- Short-term plan length: the federal rule defines short-term insurance as lasting no more than 3 months, or 4 months with renewals. On 7 August 2025 the federal agencies said they do not intend to prioritize enforcing that definition while they write new rules, so a plan lasting longer may still be sold as short-term. Look at the policy, not the length.
- Sharing ministry: you are a member of an organization whose members share medical expenses according to common beliefs, not a customer of an insurer. Its paperwork describes members sharing expenses rather than an insurance policy.
- Fixed indemnity product: it pays a fixed dollar amount per day, per illness or per service, whatever the actual bill is.
- Ask the seller or the ministry in writing: Is this health insurance under the Affordable Care Act? Is it regulated by my state insurance department? If the product comes through an employer, also ask the plan administrator whether the federal employer-plan claims rules apply to it. We could not confirm that.
The appeal steps, in order
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Ask the company or ministry to reconsider
Official name: Review under the policy or the ministry's guidelines
- Who decides
- The insurer or the ministry, under your contract or the ministry's published guidelines. We found no federal appeal rule for these products (we have not confirmed whether the general federal claims rule for employer plans covers an employer-sponsored fixed indemnity product), so the company or ministry decides how many steps there are and who reviews them. Any appeal rights come from the policy and state law.
- Your deadline
- Set by your policy or the ministry's guidelines. There is no federal minimum like the 180 days for other plans. Read the denial notice and the contract now. Check the date on your notice, which controls.
- Their deadline
- Set by your policy or the ministry's guidelines. The federal 72-hour urgent appeal rule does not apply. Check the date on your notice, which controls.
- What to send
- A written request that names the claim, the denial and why you disagree, with your records, your doctor's letter and the policy or guideline wording that you believe covers the care. Ask for the full policy or guidelines, and for everything the company relied on. Keep proof of the date you sent it.
- If you lose, or hear nothing
- If the answer is no, complain to the state, and ask the doctor's office or hospital about a payment plan or financial help while you pursue it.
- The rule
- 42 U.S.C. 300gg-91, definitions excluding short-term plans from individual coverage
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Complaint to your state insurance department
Official name: Regulator complaint
- Who decides
- Your state insurance department, for a short-term plan or other insurance policy. For a sharing ministry, ask whether the department takes complaints about ministries; state treatment varies and was not checked.
- Your deadline
- We could not confirm a deadline for this step. Do not wait, and keep any deadline in your policy running while you complain. Check the date on your notice, which controls.
- Their deadline
- Set by your state; we did not confirm a response time.
- What to send
- A short written complaint with your policy or member number, the denial notice, the dates of every request you made, and what you are asking the department to look into.
- Form
- Find your state insurance department (National Association of Insurance Commissioners)
- If you lose, or hear nothing
- If the department cannot help, talk to a legal aid office or a lawyer about the contract.
- The rule
- Centers for Medicare & Medicaid Services, know your rights when using insurance
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Small-claims court, legal aid or a lawyer
Official name: Contract claim
- Who decides
- A judge. Whether you can sue and for what depends on your contract and your state's law, which we did not check. Federal employer-plan law may not apply. Some state small-claims courts hear disputes up to a limited dollar amount; the limit and the rules are set by your state, and we did not check them.
- Your deadline
- Set by your state's law and your contract. Ask a legal aid office or lawyer early. Check the date on your notice, which controls.
- Their deadline
- Set by the court.
- What to send
- Keep the contract or guidelines, every letter, the denial and the bills. Legal aid or a lawyer can tell you whether a claim is worth bringing.
- If you lose, or hear nothing
- Whatever the result, ask the provider about a payment plan or financial help with the bill.
- The rule
- Centers for Medicare & Medicaid Services, know your rights when using insurance
If waiting could harm your health
No federal rule makes these plans decide quickly. If you need care now, ask the company or ministry in writing how it handles urgent requests, tell your doctor and the hospital about the coverage dispute, and ask them about financial help and payment plans. You can also call your state insurance department.
Free help for this coverage
- Your state insurance department
Answers questions about insurance, including short-term plans. Find yours in the National Association of Insurance Commissioners directory. Ask whether it covers sharing ministries.
- Free legal aid
Legal aid offices and state bar associations can point you to a lawyer or advise you about a contract dispute. Ask about health insurance and consumer contract problems.
- Patient Advocate Foundation case management
Free one-on-one help for patients who qualify, by phone at 1-800-532-5274, Monday to Friday, 8:30 a.m. to 5:00 p.m. Eastern (hours as listed in November 2026). Case managers work on appeals, bills and payment plans. It has limits on how many people it can take each day.
Who this covers
This page is for you if your coverage is a short-term plan, a health care sharing ministry, or a fixed indemnity product. These products are not treated as full health insurance under the Affordable Care Act. The federal rules on appeals, independent review and surprise billing do not apply to them.
How to tell this is your coverage
Use the list above, then ask the seller or ministry in writing what kind of product it is. If it says it is not insurance, take that as the answer. If you believe you bought full health insurance and were sold something else, tell your state insurance department.
What does not apply to you
The federal rule on internal appeals and independent external review does not apply. Neither does the No Surprises Act. A short-term plan is excluded from the federal definition of individual health insurance coverage. A fixed indemnity product is an excepted benefit, a category the federal health coverage requirements do not reach. We found no federal claims-appeal or external-review rule for sharing ministries. This does not mean you have no options. It means they come from your contract, your state and the company’s own process.
Where people go wrong
- Assuming you can appeal “like insurance”. You can ask, but no federal rule makes the company or ministry decide, and no independent reviewer is required.
- Waiting on a decision while a deadline in the contract runs out. Read the contract for its own time limits.
- Paying the whole bill at once. Ask the provider for a payment plan or financial help first; see hospital financial assistance.
- Assuming a state complaint works like an appeal. It is a request for the state to look at the company’s conduct.
Sources
- 42 U.S.C. 300gg-91, definitions
- Know your rights when using insurance
- 45 CFR 144.103, definitions including short-term, limited-duration insurance
- Statement on enforcement of the short-term, limited-duration insurance definition (7 August 2025)
- 45 CFR 148.220, excepted benefits
- 42 U.S.C. 300gg-63, excepted benefits
- 26 U.S.C. 5000A, definition of health care sharing ministry
- State insurance departments directory
- Patient Advocate Foundation case management