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Over the last few days, I have received numerous questions about the CARES Act (and specifically the Payroll Protection Loan/Grant) and whether or not churches and ministries should participate in the program. So, prior to working through the definitions of the CARES Act and determining the amount of a potential loan/grant, every ministry leader must determine whether or not he or she can, in good conscience, participate in the program.

Here’s (I believe) the right question to ask: “With Biblical, ethical and constitutional concerns in mind, should my ministry participate in a federally guaranteed, forgivable loan/grant program that is administered by a local bank?”

I have received two primary responses thus far:

Position #1 No. Not now and probably not ever (Josh, have you lost your mind? You attorneys have been telling me for years not to take government funds). I have received comments from pastors and ministry leaders that take the position that they will not, as a matter of principle, take money from the government. They cite the institutional separation of church and state, note that the relationship between David and Nathan would have been different if Nathan was on David’s payroll (great point) and explain that this program will be another argument against tax exemption and religious liberty down the road. Most importantly, they state that our trust should be in God and not the federal government (Philippians 4:19). I deeply respect this opinion and share some of the same concerns about how this could affect the long-term arguments surrounding religious liberty.

Position #2 Yes. We will participate because this is an unprecedented loan/grant program that is qualitatively different than previous programs. I think we can all agree that we should not make moral decisions based on financial considerations. So, is there a Biblical and legal case to be made that a ministry can, in good conscience, participate in this program? I have wrestled with this question, and I came across a great resource that has helped me sharpen my thinking on this issue. John Stemberger, who is an accomplished attorney, Christian thought leader and President & General Counsel of the Florida Family Policy Center (an organization affiliated with Focus on the Family), published a very helpful article on this topic. John holds the opinion that ministries can, in good conscience, participate in the program. I have found his 10 points helpful in thinking through this question, and I discussed these ten points with him in this interview. I encourage you to read the article for full context, but I have listed the ten points here for ease of reference.

1. No express Biblical prohibition.
2. If churches are damaged or fail because of this crisis, the welfare state will expand further.
3. There is no such thing as government money, only taxpayer money.
4. Churches regularly use public services like roads, police, and firefighters provided by the government and paid for with taxpayer dollars.
5. Like in Eminent Domain, when the government takes away something of value, it must provide just compensation.
6. To be constitutional, Congress must provide the same aid to every nonprofit organization, including religious nonprofits and churches.
7. This is not a permanent flow of funding, causing an ongoing reliance by the church on the state.
8. This money is intended to be a loan that will be forgiven, but the loan can also be paid back.
9. There are no strings attached to these loans and no control being exercised by the government over a church’s beliefs or function.
10. The Biblical role of government is to restrain evil and promote the common good. Much of government’s response to this crisis falls within these broad goals.

Please understand my purpose in publishing this interview. My position on this issue is to defer to the conscience of ministry leaders. I am not trying to dodge a hard question here. Rather, I believe that ministry leaders need to pray about this and decide whether this program is something they can, in good faith, participate in. Most ministry leaders I know are well-equipped to make the arguments for position #1, but many ministry leaders (including this one) are still working through position #2. And, that is why I asked John Stemberger to explain his well-written opinion piece.

Resources

• John Stemberger just launched an incredible resource for churches https://covidchurchaid.org/. This website has a wealth of information about the CARES Act, church leadership during the COVID-19 crisis and the audio of a very helpful conference call with Senator Marco Rubio. I encourage you to take advantage of this resource.
• John previously represented Rifqa Bary, a Muslim teenager from Columbus, Ohio, who fled to Orlando, Florida after she was threatened to be killed by her father for not renouncing her faith after her conversion from Islam to Christianity was discovered.  Rifqa’s book Hiding in the Light is a New York Times best seller. I just heard about this story and am looking forward to reading it.
• We have previously explained the nuts and bolts of The Payroll Protection Loan/Grant in this ebook. We encourage you to pick up a copy if you land on position #2.

I hope this is helpful, and I am interested in your opinion as well! What are your thoughts? Please share in the comments below are send an email to info@goodcitizen.us.

This interview is designed to provide accurate and authoritative information in regard to the subject matter covered. It is being provided to church and ministry leaders with the understanding that The Good Citizen Project is not engaged in rendering legal, accounting, tax, or other professional services. If legal advice or other expert assistance is required, the services of a competent professional should be sought. Laws vary by jurisdiction, and the specific application of laws to particular facts requires the advice of an attorney.