IRS Announces More Church Audits Regarding ACA Compliance

Last month, the IRS announced that its initiating hundreds of church exams to test compliance with the Affordable Care Act (ACA). While many provisions only apply to churches with 50 or more full-time equivalent employees (FTEs), even smaller churches could potentially violate provisions applicable to health benefit plans with as few as 2 plan participants.

Examination notices are expected to be sent out through the remainder of the year. While most ministries won’t be affected by these audits, church leaders should see this as an opportunity to double check whether their ministries are compliant.

What Parts of the Affordable Care Act Apply to My Ministry?

The most important point to understand is that churches and ministries are not specifically exempt from ACA requirements. There is a distinction in the ACA between large and small employers. Depending on the number of individuals your church or ministry employs, you will need to consider different requirements.

To determine your church’s exposure, read this article by Brotherhood Mutual that outlines some high-level conditions that large and small ministry employers should consider as they assess ACA requirements.

What If My Church Is Audited?

If your church is contacted by the IRS, then your leaders should work with a licensed tax professional who is experienced representing churches in exams conducted by the IRS.

Even if your church is not audited by the IRS, your church should audit itself for ACA compliance. Frank Sommerville, attorney and CPA, and editorial advisor for Church Law & Tax, recommends each church at least take the following two defensive steps:

  • Perform a self-audit or hire someone independently to conduct a compliance audit to verify compliance; and
  • If the church discovers noncompliance, then the church should immediately correct the problem areas.

MinistryWorks® by Brotherhood Mutual provides ACA reporting services for churches and related ministries. If you have questions about your church’s potential exposures, visit or call 866.215.5540.