Part of: Your coverage

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.

Still not sure? Use the coverage type finder or read how to find out what kind of plan you have.

The appeal steps, in order

These are the general rules. Your notice or plan document controls if it gives you more time, and your state may add to them. Check the date on your notice.

  1. 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
  2. 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
  3. 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

Work out my dates

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

Find help by state and coverage

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

Official and primary sources used on this page. Checked 2026-11-12.

  1. 42 U.S.C. 300gg-91, definitions — Government Publishing Office
  2. Know your rights when using insurance — Centers for Medicare & Medicaid Services
  3. 45 CFR 144.103, definitions including short-term, limited-duration insurance — Electronic Code of Federal Regulations
  4. Statement on enforcement of the short-term, limited-duration insurance definition (7 August 2025) — Departments of Labor, Health and Human Services, and the Treasury
  5. 45 CFR 148.220, excepted benefits — Electronic Code of Federal Regulations
  6. 42 U.S.C. 300gg-63, excepted benefits — Government Publishing Office
  7. 26 U.S.C. 5000A, definition of health care sharing ministry — Government Publishing Office
  8. State insurance departments directory — National Association of Insurance Commissioners
  9. Patient Advocate Foundation case management — Patient Advocate Foundation

Group: Student, short-term or other. General information, not legal advice.

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