Because there is no transfer of risk, as defined in applicable insurance rules and regulations, with respect to Zion Health’s medical cost sharing program, no “claim” is ever owed by a Zion Health on behalf of any member. When members incur medical expenses, they experience medical needs that may or may not be eligible for reimbursement from the Benevolent Fund. Providers can send bills directly to Zion Health using standard electronic correspondence tools in the medical industry (EDI). If not sent directly from then provider, Zion Health members are required to submit proof of their medical expenses to Zion Health. Zion Health then evaluates each submission for eligibility or ineligibility based on the Member Guidelines. Eligible needs are designated for sharing using the funds accumulated through monthly member contributions.