DHP Legislation & Plan Model
Below are the resolutions passed by the 76th and 77th General Conventions establishing and affirming the Denominational Health Plan and the Plan Model.
Resolved, the House of Deputies concurring, That this church establish The Denominational Health Plan of this church for all domestic dioceses, parishes, missions and other ecclesiastical organizations or bodies subject to the authority of this church, for clergy and lay employees who are scheduled to work a minimum of 1,500 hours annually, in accordance with the following principles:
- The Denominational Health Plan shall be designed and administered by the Trustees and officers of The Church Pension Fund, following best industry practices for comparable plans;
- The Denominational Health Plan shall provide that, subject to the rules of the plan administrator, each diocese has the right to make decisions as to plan design options offered by the plan administrator, minimum cost-sharing guidelines for parity between clergy and lay employees, domestic partner benefits in accordance with General Convention Resolution 1997-C024 and the participation of schools, day care facilities and other diocesan institutions (that is, other than the diocese itself and its parishes and missions) in The Denominational Health Plan;
- The Denominational Health Plan shall provide benefits that are comparable in coverage to those benefits currently provided by the domestic dioceses and parishes of this church;
- The Denominational Health Plan shall provide equal access to healthcare benefits for eligible clergy and eligible lay employees;
- The Denominational Health Plan shall provide benefits through The Episcopal Church Medical Trust, which shall be the sole plan sponsor for such benefits and continue to be operated on a financially sound basis;
- The Denominational Health Plan shall have a church-wide advisory committee that is representative of the broader church and appointed by The Church Pension Fund, and such church-wide advisory committee shall receive an annual report about the status of The Denominational Health Plan;
- For purposes of this Resolution, the term "domestic" shall mean ecclesiastical organizations and bodies located in the United States, including the Dioceses of Puerto Rico and Virgin Islands;
- The Church Pension Fund shall continue to work with the Dioceses of Colombia, Convocation of American Churches in Europe, Dominican Republic, Ecuador Central, Ecuador Litoral, Haiti, Honduras, Micronesia, Taiwan and Venezuela to make recommendations with respect to the provision and funding of healthcare benefits of such dioceses under The Denominational Health Plan; and
- The implementation of The Denominational Health Plan shall be completed as soon as practicable, but in no event later than by the end of 2012; and be it further
Resolved, That Canon I.8 shall be amended as follows:
Sec. 1. The Church Pension Fund, a corporation created by Chapter 97 of the Laws of 1914 of the State of New York as subsequently amended, is hereby authorized to establish and administer the clergy pension system, including life, accident and health benefits, of this Church, substantially in accordance with the principles adopted by the General Convention of 1913 and approved thereafter by the several Dioceses, with the view to providing pensions and related benefits for the Clergy who reach normal age of retirement, for the Clergy disabled by age or infirmity, and for the surviving spouses and minor children of deceased Clergy. The Church Pension Fund is also authorized to establish and administer the denominational health plan of this Church, substantially in accordance with the principles adopted by the General Convention of 2009 in Resolution A177, with the view to providing healthcare and related benefits for the eligible Clergy and eligible lay employees of this Church, as well as their eligible dependents.
Sec. 3. For the purpose of administering the pension system, The Church Pension Fund shall be entitled to receive and to use all net royalties from publications authorized by the General Convention, and to levy upon and to collect from all Parishes, Missions, and other ecclesiastical organizations or bodies subject to the authority of this Church, and any other societies, organizations, or bodies in the Church which under the regulations of The Church Pension Fund shall elect to come into the pension system, assessments based upon the salaries and other compensation paid to Clergy by such Parishes, Missions, and other ecclesiastical organizations or bodies for services rendered currently or in the past, prior to their becoming beneficiaries of The Church Pension Fund. For the purpose of administering the denominational health plan, The Church Pension Fund shall determine the eligibility of all Clergy and lay employees to participate in the denominational health plan through a formal benefits enrollment process, and The Church Pension Fund shall be entitled to levy upon and collect contributions for healthcare and related benefits under the denominational health plan from all Parishes, Missions, and other ecclesiastical organizations or bodies subject to the authority of this Church with respect to their Clergy and lay employees.
Resolved, the House of Deputies concurring, That the 77th General Convention acknowledges and commends the 94% of domestic dioceses (United States, Puerto Rico and the U.S. Virgin Islands) which have already enrolled in the Denominational Health Plan, and further commends those dioceses which have achieved parity between clergy and lay employees; and be it further
Resolved, That the 77th General Convention reaffirms that all domestic dioceses, parishes, missions, and other ecclesiastical organizations or bodies subject to the authority of this church be enrolled in The Episcopal Church Medical Trust by December 31, 2012; and be it further
Resolved, That the 77th General Convention commends The Episcopal Church Medical Trust for progress made toward containing healthcare premium costs, and urges it to continue to reduce the disparity in those costs among dioceses; and be it further
Resolved, That The Episcopal Church Medical Trust continues to explore alternative strategies to arrive at a more equitable sharing of healthcare premium costs, including alternative means of achieving such equity by December 31, 2015, and that The Episcopal Church Medical Trust make an annual written report to the Executive Council, the House of Bishops, the Board of Directors of The Episcopal Church Medical Trust, and the Board of Trustees of The Church Pension Fund detailing continuing progress in containment of costs and achievement of such equity; and be it further
Resolved, That within each diocese, parity in cost-sharing shall be achieved between their clergy and lay employees as soon as possible, but no later than December 31, 2015.
This Denominational Health Plan (DHP) model for The Episcopal Church (TEC) is presented to the Healthcare Coverage Feasibility Study Advisory Group for their consideration. It provides solutions to five issues. The first is it increases potential savings by leveraging The Episcopal Church’s aggregated size for the large scale purchasing of healthcare benefits. Secondly, it attempts to balance the Church’s financial constraints with the cost of providing adequate employee healthcare benefits. Thirdly, it addresses equity in coverage between clergy and lay employees who are regularly scheduled to work 1,500 or more hours per year. Fourthly, it attempts to provide for diocesan/group level control so that dioceses, agencies and institutions have the flexibility to make decisions about healthcare benefits that reflect local polity and preferences. Finally, it provides access for all eligible1 employees, according to the rules of The Episcopal Church Medical Trust (MT), of participating employers to purchase healthcare benefits at a group rate, even if their employers are not required by canon to fund the coverage.
1. DHP Savings through Collective Purchasing
Using a single plan sponsor for healthcare benefits will enable the Church to leverage its aggregate size and obtain lower unit costs. Healthcare plans for TEC employers included in the canon will be administered by a single plan sponsor, The Episcopal Church Medical Trust.
2. Diocesan/Group Level Control and Choice
- Plan Design Options - The DHP will provide Participating Groups, i.e., agencies, institutions, and dioceses and their congregations, with a number of plan options from which to choose. Participating Groups may offer one or more of the available options. Additionally, Participating Groups may change plans annually. Likewise, employees will have the ability to make an annual enrollment decision, i.e., open enrollment.
- Cost Sharing – The Episcopal Church Medical Trust will establish an annual process by which Participating Groups will adopt a group-wide level of employee contributions for health benefits coverage. Examples of cost-sharing levels are: 85% of Family coverage, 100% of Individual coverage, 100% of Family coverage, etc. The cost sharing requirements will be the same for both clergy and lay employees, within a Participating Group, who work 1,500 or more hours per year and be implemented no later than the end of 2012.
- Domestic Partner Benefits: Participating Groups will determine whether or not to offer domestic partner benefits. Domestic partner benefits will be administered in accordance with General Convention Resolution 1997-C024.
- Schools, Day Care Facilities and other Diocesan Institutions: The Episcopal Church Medical Trust will establish a process by which dioceses will, on an annual basis, adopt a policy as to whether or not schools, day care facilities and other diocesan institutions must participate in the DHP. The diocesan policy will apply to employees of said school, daycare facilities and institutions who would otherwise be required to participate in the DHP. The policy will provide that qualified clergy and lay employees working for these employers are treated in the same way.
3. TEC employers required by canon to participate in the DHP
- Domestic U.S. dioceses, including Puerto Rico and the Virgin Islands. The study of non-domestic dioceses (Colombia, Convocation of Churches in Europe, Dominican Republic, Ecuador Central, Ecuador Litoral, Haiti, Honduras, Micronesia, Taiwan, and Venezuela) has occurred through data collection and meetings with their diocesan representatives during spring 2008. Efforts to create a Province IX benefits council for all employee benefits are currently underway with Province IX leadership.
- Congregations – Includes all cathedrals, parishes, missions and chapels. As of the 2007 parochial data, 7,055 entities are in this category. This number includes Puerto Rico and other U.S. territories.
- Official ecclesiastical organizations or bodies (subject to the authority of the General Convention) which are defined as The Domestic and Foreign Missionary Society, The Church Pension Fund, Episcopal Relief and Development, Forward Movement, The General Theological Seminary and the Archives.
- Any other societies, organizations, or bodies in the Church may participate on a voluntary basis.
4. TEC employees required by canon to be covered by the DHP
- Clergy regularly scheduled to work at least 1,500 hours per year for one or more TEC employers and receiving a W-2. There are an estimated 5,900 active clergy in this category, of which an estimated 1,000 have medical coverage through non-TEC sources, e.g., spousal coverage, Tricare, Medicare, etc. (Note: Non-stipendiary clergy and retired clergy serving in congregations are eligible but not required to participate.)
- Diocesan and congregational lay employees regularly scheduled to work at least 1,500 hours per year for one or more TEC employers receiving a W-2. An estimated 6,950 lay employees are in this category, and approximately 4,450 (65%) are covered through their TEC employer, 2,150 (31%) have medical coverage through non-TEC sources, and an estimated 350 (4%) of them have no medical benefit coverage.
- Lay employees of official ecclesiastical organizations or bodies regularly scheduled to work at least 1,500 hours per year for one or more TEC employers and receiving a W-2. There are an estimated 1,400 employees in this category who have medical coverage through TEC sources.
- Lay employees of any other societies, organizations, or bodies of the Church may participate on a voluntary basis if their employer chooses to participate in the DHP.
5. Employee Opt Out Option
Clergy and lay employees who have health benefits through approved sources will be allowed to waive coverage under the DHP (“opt out”) and may choose to maintain their healthcare benefits through Tricare, or coverage from a previous employer.
6. Employee Registration/Enrollment Process
The Church Pension Fund will provide an employee registration process through which employees will enroll in the DHP.
7. Church-wide Advisory Board
A Church-wide Advisory Board will be established and its members selected from participating employer groups and employees.
1 Currently, the guidelines of The Episcopal Church Medical Trust generally provide that those hourly employees routinely scheduled to work 20 or more hours per week and all salaried employees are eligible.
The Denominational Health Plan (DHP)
A Church-wide program of healthcare benefit plans authorized by General Convention and administered by The Church Pension Fund (CPF), with benefits provided through The Episcopal Church Medical Trust (the Medical Trust). Find out more about the DHP.
Employers are required to provide all eligible clergy and lay employees with equal access to and parity of funding for healthcare benefits, to be provided through the Medical Trust. Under the terms of this resolution, an eligible employee is someone who is scheduled for at least 1,500 hours of compensated work annually for any domestic diocese, parish, mission, or other ecclesiastical organization or body subject to the authority of the Church.
The Lay Employees’ Pension System and the Denominational Health Plan are two separate canonical requirements. Although they are independent of each other, all dioceses, parishes, and missions are required to comply with each.
Clergy and lay employees required to participate in the Medical Trust’s health plans are those who are scheduled to work at least 1,500 compensated hours per year for any domestic diocese, parish, mission, or for any other ecclesiastical organization or body subject to the authority of the Church (and whose diocese has determined it must participate.)
The Medical Trust’s eligibility rules relating to part-time employees currently remain the same as before the formation of the DHP. This means that clergy and lay employees of any Episcopal institution who are regularly scheduled to work between 1,000 and 1,499 hours per year are eligible to participate voluntarily.
Currently, non-stipendiary clergy are not eligible to participate in the Medical Trust Plans, with a few exceptions as noted in the administrative guidelines.
Non-parochial clergy employed by Episcopal institutions that offer healthcare benefits through the Medical Trust are eligible to participate if they are regularly scheduled to work at least 1,000 hours per year. Non-parochial clergy (working more than 1,500 compensated hours annually) employed by diocesan institutions may be eligible or required to participate at the option of the diocese.
Each diocese will decide individually whether or not to offer healthcare benefits to same-sex domestic partners, opposite-sex domestic partners, or both.
The DHP does not address seminarian healthcare benefits coverage. Seminaries traditionally obtain their student coverage outside of diocesan medical plans. Many Episcopal seminaries use the Medical Trust’s seminarian program.
Although the Medical Trust plans are exempt from the Employee Retirement Income Security Act of 1974, as amended (ERISA), we do offer an Extension of Benefits (EOB) program that will cover existing employees receiving COBRA benefits through the end date that is currently in place at the time they transition to the Medical Trust Plans. Once an employer participates with the Medical Trust, the EOB program will be available to departing employees.
Plans, Products & Vendors
No. Only medical benefits are required under the DHP. The Medical Trust does offer three dental plans using the Cigna dental network.
The DHP requires that each diocese establish, on a diocesan-wide basis, the minimum required employer cost-sharing policy for healthcare benefits. That means that a diocese can require employers to cover all or a portion of the contribution (premium) for employees and their families. “Parity” refers to the requirement that the diocesan policy regarding employer cost-sharing must be the same for all eligible clergy and lay employees scheduled to work at least 1,500 compensated hours per year. In other words, all clergy and lay employees who are scheduled to work at least 1,500 compensated hours per year must receive the same minimum level of funding — such as a percentage of the premium cost, a flat dollar amount, or a coverage level (i.e., single, family, etc.) — for healthcare benefits.
January 1, 2013 was the deadline for full implementation of the DHP. The deadline for parity was extended to December 31, 2015 by Resolution B026 passed at the 77th General Convention.
Examples of canons/resolutions or policies that other dioceses have developed are available upon request from your Benefits Relationship Manager.
No. By December 31, 2015, all clergy and lay employees who are scheduled to work at least 1,500 compensated hours per year must be treated equally with regard to cost-sharing of the medical plan premiums, no matter when they were hired.
Yes. The DHP requires that all clergy and lay employees who are scheduled to work at least 1,500 compensated hours per year be treated equally with regard to the cost-share of medical plan premiums. Employers are free to provide a different cost-share to their part-time employees.
The diocese is the primary partner in implementing the DHP within that diocese. The diocese must establish canons, policies, rules, or guidelines to determine:
- Whether institutions under its authority (schools, day care facilities, social service agencies, etc.) are required to participate
- Whether the diocese wishes to provide healthcare benefits to domestic partners
- A cost-sharing policy that is the same for clergy and eligible lay employees
- Which Medical Trust plans will be offered in that diocese. The diocese makes this decision annually.
The rules governing the ECCEBT’s status as a VEBA require that only eligible employees of Episcopal institutions be allowed to participate in the Medical Trust’s plans. The Medical Trust has developed a document, “Questions to Consider When Determining if an Organization is Subject to the Authority of the Church,” to assist dioceses in determining which of its diocesan institutions are considered Episcopal institutions, according to these stipulations.
No, but the Medical Trust will work with all employers to find plans that are economically viable for their specific situations and populations. It is important that all required groups participate with the Medical Trust to ensure optimal leverage in negotiating services from our contracted vendors.
Participation in a Medical Trust plan is required by the canon enacted by the General Convention of The Episcopal Church and is enforced in the same manner that any canon is enforced. It is the individual diocese’s responsibility to ensure compliance with Resolution A177, as it is with all canons. The Medical Trust will not enforce compliance.
Before the annual enrollment period begins, the diocese should communicate specific information to its parishes and other participating institutions regarding its plan selections, associated rates, and plan design changes so that employees can make informed decisions about their specific healthcare options. During annual enrollment, the Medical Trust communicates directly with employees to provide information about how to review their plan selection choices, the resources and references available to them.
Under the terms of the DHP, clergy and lay employees who have medical benefits through approved sources will be allowed to waive medical coverage under the DHP (“opt out”) and choose to maintain their medical benefits through the approved source. Examples of approved sources include coverage through a spouse’s or partner’s employment, medical benefits through a government-sponsored program such as Medicaid or TRICARE, or coverage from a previous employer. The list of approved sources is subject to change based on the federal healthcare reform law.
An employee may elect to waive coverage at the initial point of employment, during annual enrollment, or at the time of any significant life event. The employee will need to reaffirm the election to waive coverage on an annual basis, as determined by the Medical Trust.
Declaration of the individual waiver will occur on an annual basis during annual enrollment. The employee will need to reaffirm the election to waive coverage on an annual basis.