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Policy Checklist  |  Action Guide

What Should a Christian Employer
Review in Their Policies Right Now?

One EEOC charge. One DOL audit. One IRS inquiry. Any one of the three can cost you hundreds of thousands of dollars before you ever set foot in a courtroom. Here is where you start.

Here is the hard part. Most Christian employers do not find out where they are exposed until the letter arrives. By then, it is too late to fix it quietly. So fix it now, while it is still your choice.

You feel the pressure. You know something is off. You just do not know where to start. This is where you start. Six checks. Each one an action, not an idea. Work through them this week.

Check 1 of 6

Health Plan Exclusions

Pull your plan documents. Right now.

Abortifacient Exclusion

Look for a clause stating that emergency contraceptives (such as Plan B and Ella), abortifacients, and IUDs used for contraception are not covered. Is it actually in the document? If it is not written down, it is not in force.

Gender-Transition Exclusion

Look for language excluding services or procedures rendered on the basis of gender identity, gender reassignment, or gender transition, including hormone treatment and surgical procedures. If your plan is silent, your convictions are unprotected on paper.

A conviction you never documented is a conviction a regulator can ignore.

CEA members can request that their insurer insert both exclusions. The federal courts already ruled these exclusions lawful for members. CEA v. Azar (2019) secured the abortifacient exemption. CEA v. EEOC/HHS (2024) secured the transgender exemption. Both are permanent. But the clause still has to live in your document.

Check 2 of 6

Employee Handbook

Read your handbook as if a hostile investigator wrote the questions.

  • Does it state your biblical convictions on sex and gender clearly, or does it stay quiet to dodge conflict?
  • Does it address bathroom and facility use, pronoun expectations, and conduct standards, or does it leave those gaps for someone else to fill?
  • Does it connect your policies back to your faith mission, or do they float free with no stated reason?

Silence is not neutrality. A handbook that ducks the hard topics is a handbook that cannot defend you when one of those topics becomes a complaint. Say what you believe. Write it down. Root it in your mission.

Check 3 of 6

Hiring and Onboarding Policies

Your right to hire for faith rests on stating that faith out loud.

  • Is your religious mission written into your hiring materials, job descriptions, and offer letters?
  • Do your onboarding documents make clear that faith commitment is part of the role, where the role calls for it?
  • Does your structure support the ministerial exception for positions that carry your mission?

The ministerial exception is a legal protection that lets faith-based organizations choose who carries out their religious mission, free from government second-guessing. But it only shields roles you have clearly tied to that mission. A mission you mention only in conversation will not hold up when it counts. Faith-based hiring protection is strongest when the mission is explicit, written, and consistent.

Check 4 of 6

Accommodation Policies

Have a written process before the request arrives.

  • Do you have a documented procedure for handling religious accommodation requests?
  • Does one person own that process, or does every request get handled a different way?
  • Are your decisions recorded so you can show a consistent, good-faith pattern?

Regulators look for inconsistency. A documented, evenly applied process is one of the strongest protections you can build. And it costs you nothing but an afternoon.

Check 5 of 6

Government Inquiry Readiness

Know your first move before the letter lands.

  • If an EEOC charge arrives, do you know the response deadline and who handles it?
  • If a DOL audit opens (wage-and-hour, FMLA, ERISA, Form 5500), do you know which documents they will demand?
  • If an IRS or ACA inquiry hits (1094-C/1095-C reporting, a Letter 226-J penalty notice), do you know how to respond accurately and on time?

The clock starts the day the letter arrives, not the day you figure out what to do. Panic is expensive. Readiness is cheap. Decide now who opens the envelope, who pulls the records, and who makes the call.

Check 6 of 6  —  The One That Decides the Others

CEA Membership Status

Are you a current CEA member today? Right now? This minute?

Because CEA's permanent federal court injunctions protect current and future members. Not former members. Not lapsed members. Not almost-members. Current members.

Critical

You can document every exclusion and write the perfect handbook. But the injunction protection from the abortifacient mandate (CEA v. Azar) and the transgender mandates (CEA v. EEOC/HHS) only shields you while your membership is active. Lapse, and the shield lapses with you.

Two Paths. One Choice.

You just found the gaps. Now look at the two roads in front of you.

Without CEA Membership

  • Defend your convictions alone
  • Years in court
  • Hundreds of thousands in legal fees
  • Your business exposed the entire time

With CEA Membership

  • Permanent federal court injunctions
  • No solo lawsuit
  • No crushing legal bill
  • Protection active from day one

The distance between those two roads is measured in years, in hundreds of thousands of dollars, and in your freedom to lead your business by faith without fear.

Don't Wait for the Letter

A checklist protects you only if the protection behind it is active. The government does not wait. The mandates do not pause. The next agency inquiry is already being drafted somewhere.

You built your business on conviction. Close the gaps. Then stand on ground already won in federal court.

Secure My Business