Can We Give Additional Income to a Church Employee Who Opts Out of Our Medical Plan?

Understand the rules for offering a medical stipend to church employees who opt out of coverage and how to ensure compliance with IRS and ACA regulations.

Last Reviewed: January 31, 2025

Q: My church has an employee who is covered by his spouse’s medical insurance plan. Is it okay to give a stipend to an employee who declines our plan so long as it is reported as taxable income?


The answer is maybe. Employers, including churches, cannot offer a cash or benefit option to employees who opt out of group health insurance as a general choice. Doing so—providing an increased paycheck in lieu of participation—may jeopardize the tax benefits of your medical plan for all employees.

How Can a Church Structure an Opt-Out Payment?

  • The opt-out payment should be structured in compliance with the Affordable Care Act (ACA) and should not disrupt the benefits of those who remain in the plan.
  • It must be coordinated properly to avoid making the benefit taxable for all employees.
  • The church should consider placing the opt-out payment within a Section 125 cafeteria plan to preserve tax benefits.

When Is the Opt-Out Payment Taxable?

Unless structured within a Section 125 plan, the opt-out payment is taxable. Churches should work with a tax professional to ensure compliance with federal regulations.

FAQs About Church Employee Medical Stipends

Can churches offer cash payments to employees who decline medical coverage?

Yes, but only if structured correctly within a compliant benefits plan to avoid negative tax implications.

Does an opt-out stipend impact other employees’ benefits?

Potentially, yes. If not handled correctly, it may make the employer’s entire group health plan taxable for all employees.

What is a Section 125 cafeteria plan?

A Section 125 plan allows employees to receive certain benefits pre-tax, preserving tax advantages for both the employer and employees.

Should churches consult a tax professional before offering an opt-out stipend?

Yes, it is essential to consult a tax or benefits expert to ensure compliance with ACA regulations and IRS guidelines.

By structuring an opt-out payment correctly, churches can ensure they remain compliant while supporting employees with alternative medical coverage options.

Elaine L. Sommerville is licensed as a certified public accountant by the State of Texas. She has worked in public accounting since 1985.

This content is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought. "From a Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations." Due to the nature of the U.S. legal system, laws and regulations constantly change. The editors encourage readers to carefully search the site for all content related to the topic of interest and consult qualified local counsel to verify the status of specific statutes, laws, regulations, and precedential court holdings.

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