How do the nondiscrimination rules apply to self-funded church plans like GuideStone's?

The IRS has not issued guidance on how nondiscrimination rules would apply to church self-funded health plans, despite a directive from Congress more than 20 years ago to do so. The nondiscrimination regulations currently in the tax law refer to provisions that do not apply to most church self-funded health care plans such as GuideStone's medical plans. Additionally, the ACA has made no accommodations for the unique structure of church plans, despite having made church plan accommodations in previous legislation. 

GuideStone is not aware of a church self-funded health plan of a major denomination that has attempted to apply these rules given the technical and practical impediments to doing so.

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