Tag archives: Church

Is it Time for Churches to Reopen?

by David Closson

August 13, 2020

Since the beginning of the coronavirus pandemic, churches have had to make difficult decisions. Now, as states reopen, church leaders are deciding whether to reopen for public services or continue providing live-streams and smaller, home-based ministry. Considerations such as protecting the health of worshippers, the public witness of the church, the spiritual and physical needs of members, and complying with government mandates are all a part of the conversation.

Across the country, churches are coming to different conclusions on these questions. In California, Pastor Jack Hibbs decided to reopen his megachurch on May 31. In late July, John MacArthur and the elders at Grace Community Church in California decided that the state and local government had overstepped their authority and opened the church for worship on July 26. Three days later, the church received a letter from a Los Angeles County attorney demanding the church stop holding indoor worship services. The letter threatened fines and imprisonment for noncompliance. On August 12, in an effort to block the state from enforcing its regulations, Pastor MacArthur and Grace Community Church filed suit against California Governor Gavin Newsom and Los Angeles Mayor Eric Garcetti. 

Conversely, J.D. Greear, pastor of Summit Church in North Carolina and current president of the Southern Baptist Convention, announced at the end of July that his church would not hold public worship services for the remainder of the year and instead will facilitate home-based gatherings. Greear cited the biblical admonition of neighbor-love as a reason for his decision.

Which approach is best? Should churches resume holding public worship services, or should they be cautious and wait to fully reopen?

Complicating matters are the strict reopening policies some overreaching state and local governments have ordered churches to follow. In some states, governors and mayors have appeared to single out churches for unfair treatment, and as a result, pastors in these areas are beginning to defy unconstitutional and overreaching mandates from the authorities. These incidents have raised questions about how pastors should respond to the government when it oversteps its authority. For example, can the government prohibit churches from holding worship services? Does a governor have the right to tell churches they can’t sing? More generally, what is the proper posture government should have towards religion? These questions have prompted further reflection on the theological rationale for civil disobedience.

How Churches Have Responded to the Pandemic

Before answering the question of how churches should navigate reopening amid a pandemic, it is important to recall how churches have responded thus far.

In early March, virtually all churches suspended in-person worship services and other activities in response to the pandemic. Throughout the spring and early summer, churches almost universally complied with government mandates. This is important to remember, especially considering the media’s hostile and misleading reporting about churches. For example, on July 9, the New York Times published an article with the alarming headline “Churches Open Doors, And the Virus Sweeps In.” Ominously, the writers reported, “More than 650 coronavirus cases have been linked to nearly 40 churches and religious events across the United States since the beginning of the pandemic.” While the report initially sounds distressing, an objective, clear-minded analysis of the total number of cases shows that 650 cases represent an incredibly small percentage of the overall confirmed 4.75 million cases of COVID-19 in the United States (as of July 9). While every case is serious, the disproportionate attention on cases emerging from churches betrays an underlining animus toward people of faith.

Churches were quick to follow initial guidance from federal, state, and local authorities. According to an April study by LifeWay Christian Resources, 99 percent of Protestant churches gathered for worship on March 1. By March 29, only seven percent were still meeting. Notably, most churches ceased in-person gatherings before most states instituted stay-at-home orders (only nine states had stay-at-home orders as of March 23; by then, 90 percent of churches had adopted the CDC’s non-binding recommendation to suspend in-person gatherings). Therefore, anyone arguing that churches were obstinate or unwilling to obey the governing authorities from the outset of the pandemic is wrong. With very few exceptions, pastors across the country followed the Bible’s teaching in Romans 13 to honor the governing authorities.

Constitutional and Legal Considerations: The Unequal Treatment of Churches

Churches have served their members and local communities in creative ways throughout the spring and early summer—including live-streams and “Drive-In” services. However, now that their respective states have reopened, many churches have resumed or wish to resume in-person meetings and services. But churches in some states and localities have been ordered by the governing authorities not to reopen, despite implementing health and safety measures consistent with CDC guidance. What are we to make of the legal restrictions and gathering bans being imposed on churches?

According to the Becket Fund for Religious Liberty, as of July 27, worship services are prohibited or currently subject to unequal treatment (compared to nonreligious activities) in six states (California, Nevada, Washington, Maine, New Jersey, and Connecticut). Another 14 states have broad but equally applicable restrictions that limit churches’ ability to gather for worship or other activities.

Many of these restrictions are likely unconstitutional under the First Amendment’s Free Exercise Clause, which generally bars government from discriminating against religious entities in its policies and practices. For example, Nevada churches—regardless of size—are prohibited from admitting more than 50 people. Meanwhile, Nevada casinos can admit 50 percent of their maximum occupancy, allowing thousands of people inside. One church, Calvary Chapel, sued the state but was denied injunctive relief by the U.S. Supreme Court in a 5-4 decision. In his dissent, Justice Neil Gorsuch quipped, “In Nevada, it seems, it is better to be in entertainment than religion.” Justice Brett Kavanaugh, also in dissent, added, “COVID–19 is not a blank check for a State to discriminate against religious people, religious organizations, and religious services.”

In California, two-thirds of the state’s 58 counties are on a “county monitoring list.” Churches in these counties are not allowed to hold indoor services. Churches in counties not on the monitoring list are only allowed to admit 25 percent of their building’s capacity or up to a maximum of 100 people. As of July 29, California churches have been ordered to “discontinue indoor singing.” Notably, the same prohibition on chanting and singing did not extend to secular activities hosted indoors, including daycare centers, entertainment, schools, music, television and film production, and, most notably, public protests. In fact, Governor Newsom refused to ban protesters from chanting or singing, despite the risks posed by large gatherings in confined spaces.

Restrictions like those imposed on churches in California, Nevada, and elsewhere are even further problematic because the First Amendment gives religion a “privileged status” due to the societal good it provides and out of respect for the conscience of the citizenry. In his legal commentary regarding the First Amendment, Justice Joseph Story wrote, “It is the especial duty of government to foster, and encourage [religion] among all citizens and subjects.” The government is not to curtail religious exercise unless it demonstrates a compelling interest in doing so, and even then, the curtailment must occur in the narrowest way possible. This strong standard is in place in part because religion is something the American Founders knew ought to be safeguarded. Religion undergirds our nation and provides a vibrancy that must be preserved.

The First Amendment puts religious activity in a special category, and requires that it be protected. As Justice Kavanaugh noted in the recent Calvary Chapel case, even in a pandemic, the U.S. Constitution does not allow for casinos to receive privileged treatment over churches. As Kavanaugh explained, unlike gambling, the free exercise of religion is explicitly protected by the Constitution, and state laws that reflect “an implicit judgment that for-profit assemblies are important and religious gatherings are less so,” violate the Constitution. In America, religious liberty is often referred to as our “first freedom” because it is foundational to our other freedoms. Craps and poker simply do not merit the same protection.

Theological Considerations: The Christian Response to Religious Liberty Violations

What is a proper Christian response to what appears to be blatant religious discrimination and an unjust usurpation of authority by several states? Although Scripture teaches that government is a legitimate, God-ordained authority, is there a different calculus that pastors and church leaders need to make if it is clear the government has transgressed its constitutionally and divinely prescribed authority?

In a word, yes. In Romans 13, Paul teaches that the governing authorities are responsible for maintaining societal order and keeping the peace. However, God has not granted the government jurisdiction over the doctrine, liturgy, or practice of the church; pastors and elders, not magistrates, have been entrusted with this authority. In fact, there is biblical precedent for not obeying rulers who overstep their authority. When the corrupt religious authorities in Jerusalem ordered the apostles to stop preaching, Peter responded, “We must obey God rather than men” (Acts 5:29). Christians should honor the governing authorities as long as they are operating within their God-ordained role, but if the government is defying higher authority by imposing unconstitutional requirements on churches that want to reopen, pastors should seriously consider moving forward with plans to reopen their churches as safely as possible.

The roles of the church and state are complicated by the unique circumstances of a global pandemic. However, six months into the pandemic, we are faced with another type of health crisis. Experts are now warning of a mental health crisis due to the fear and anxiety sparked by the virus. According to preliminary data, depression, substance abuse, PTSD, drug overdoses, and suicide are all on the rise. A phenomenon that health experts refer to as a “shadow pandemic” is following the virus, manifesting itself in a variety of serious mental health concerns. For example, in Fresno, California, suicides were 70 percent higher in June this year compared to last year. According to the medical examiner’s office in Cook County (Chicago area), there have already been 58 suicides this year compared to 56 for all last year. And finally, the National Alliance on Mental Illness HelpLine has seen a 65 percent increase in calls and emails since March. Mental health experts have cited economic stress, social isolation, and, importantly, reduced access to church and worship services as factors driving this trend. Considering these factors, it is very reasonable to question whether the state and local governments truly have a compelling interest to impose on religion in the way they have.

How to Safely Reopen Your Church

Each church should ask themselves: What are the spiritual and practical consequences of remaining closed? What is the cost of only reopening a fraction of our outreaches and ministries?

Of course, in places where the virus has inflicted significant damage, churches should be wise and exercise good judgment. But most churches likely should move toward reopening, with safety precautions in place. This is true in states like California and Nevada, where churches appear to have been treated poorly with no justifiable reason. Churches within these states should continue to press their case—both at the local level and with the Department of Justice—that their constitutional rights are being violated. Constitutionally and theologically, churches have the right to continue the work they’ve been called to do. It is critical to our democracy that the government recognize and proactively protect the vital role religion plays in society. The pandemic does not alter this principle. As seen by the mental health epidemic, the need for the spiritual support of the church is only enhanced in the coronavirus era. It seems increasingly clear that by not opening, congregations and communities are at risk from other maladies besides the coronavirus.

Finally, safely reopening churches will require pastors and church leaders to exercise courage and faith, especially in areas where government officials have demonstrated hostility toward them. But Scripture reminds us that it is precisely for these moments that God gave us a spirit not of fear but of power and love and self-control (2 Tim. 1:7). According to Ohio State Representative Jena Powell, this is exactly what we need from our church leaders today. As Powell explained, “Right now, we need pastors with courage to stand up against government overreach, which is blatantly usurping the power that God has given to His church alone. We need pastors who are unafraid to boldly follow the commands of Scripture, and lead their churches in discipleship, evangelism, and serving their neighbors. I’m grateful for the many pastors who are shepherding well and hope more follow their example.”

To help churches safely reopen, Family Research Council has released a resource titled Guidelines for Reopening Your Church, which outlines the best sanitation practices advised by the CDC. It also provides guidance on other precautions churches can take, such as providing masks for those who attend services, ways to hygienically collect tithes and offerings, tips for administering the ordinances such as the Lord’s Supper, ideas for seating configurations, and ways pastors can set the tone for their congregations.

For further discussion about reopening churches and how Christians can think about responding to overreaching government authorities, listen to my recent interview with Tony Perkins on Washington Watch. And don’t forget to take advantage of all of FRC’s COVID-19 and The Church Resources.

Kaitlyn Shepherd, a legal intern with Policy & Government Affairs at Family Research Council, contributed legal research for this blog.

All 9 Months and Beyond: Let’s Be Truly Pro-Life

by Hayden Sledge

July 8, 2020

I am a woman. I am also pro-life. Unfortunately, many people today see these identities as contradictory and antithetical. Over the past few decades, society has tried to force many women into a box: If you are a woman who is proud of your womanhood, you should support and advocate for abortion. If not, how can you be a true advocate for women? Supporting women has become synonymous with supporting abortion.

But truth be told, abortion is devastating to women. Abortion can cause physical and psychological complications to the woman obtaining the abortion and affect her ability to successfully carry future pregnancies to term. Not only that, but many of abortion’s unborn victims are female.

These considerations lead to an important question: What does it truly mean to advocate for women?

A true advocate for women supports God’s design for women

God specially designed women with the capacity of bringing life into the world. In the creation mandate given in Genesis 1:28, the first human couple was charged to fill the earth and exercise dominion. While both the husband and wife play a role in conceiving life, the woman has the privilege and responsibility of bringing the new life into the world. Thus, while not all women will be mothers, many will, and motherhood should be seen as a high calling worthy of respect, rather than an impediment needing to be overcome.

Unfortunately, the abortion industry presents a narrative that women can only assert control over their lives if they have the option to abort their children. However, God is ultimately sovereign over all aspects of our lives, including the pregnancy journey, the mother’s life experiences, and the development of unborn children. God’s hand is entirely evident throughout the process.      

Thus, as Christians we should support women in the unique callings God has given each of them, whether that calling includes a career, motherhood, or both. We should appreciate the variety of ways God works in and through each woman.

A true advocate for women helps women facing hardship

God is active during times of celebration and suffering. He reminds us that we will all experience suffering during our time on earth. In fact, Romans 8:22 tells us that the all of creation “groans” due to the curse of sin.  

We all experience various forms of hardship, which can include familial loss, illness, financial stress, mental illness, infertility, miscarriage, or unexpected pregnancy. The church ought to come alongside and help people in their most vulnerable stages of life. This includes actively loving and protecting mothers who have made the brave and courageous decision to keep their babies despite pressure to abort.

Many women experience confusion, shame, and difficulty throughout their pregnancies, especially if those pregnancies are unexpected or unwanted. Although pregnancy is ideally a time of celebration and rejoicing in a new God-given life, it is important to remember that many mothers need care and comfort during and after their pregnancy. It is not an easy journey and is even more difficult for single mothers who are already lacking support.

A true advocate for women supports mothers before and after pregnancy

The church should love and care for women in one of the most life-altering and vulnerable stages of life: the time during and after pregnancy. We should continuously remind mothers of Jesus’ steadfast love as we walk alongside them.

Too often, churches encourage mothers in the early stages of pregnancy but neglect to stand with them after birth. Although pregnancy can be a difficult time, there are a host of challenges that can arise after birth as well. So, it is important that we seek to encourage and help the mother and baby after birth.

In honoring the Lord, we are to care for all mothers and their unborn children, reminding them of God’s truth that they are—or by faith can become—the beloved daughters of a loving heavenly Father.

Here are some resources that seek to help mothers during their pregnancy and beyond. Although an online resource cannot address all the complexities and possible difficulties surrounding pregnancy, these are helpful places to start.

Hayden Sledge is a Coalitions intern at Family Research Council.

Charity: Who Does It Best?

by Connor Semelsberger, MPP , Jeremy Pilz

July 7, 2020

One of the most well-known passages in the Bible is Matthew 25 where Jesus teaches his followers about charity. In this text, Jesus distinguishes between “sheep” and “goats.” On one hand are the sheep who are commended for selflessly serving those in need while on the other hand are the goats, those who are condemned for not caring for the naked, thirsty, or hungry. In a shocking statement, Jesus tells his disciples that how one treats the needy reflects their love for him.

Taking Jesus’ admonitions to heart, the Christian church has historically been on the front lines of performing charitable acts. However, recently the government continues to encroach on this space, expanding its role in providing a social safety net consisting of mostly large, impersonal programs. But instead of overtaking the important role of the church when it comes to practicing charity, the government should work to supplement and not supplant this vital calling of charitable organizations. 

Within the pages of the Bible, one can see many other references to the practice of charity. In fact, the word “charity” that is found in the Bible text is a translation of the Greek word “agape,” also meaning “love.” 1 Corinthians 13 suggests that charity is love when Paul writes: “If I give all I possess to the poor and give over my body to hardship that I may boast, but do not have love, I gain nothing.” The direct command to love and be charitable can be found in Matthew 22:39 when Jesus states that we are to love our neighbor as ourselves. Practicing charity by loving our neighbor is not only the responsibility of individual Christians, but of the church as a whole. Recently, Senator Josh Hawley (R-Mo.) echoed these thoughts on the Senate floor by stating that “as religious believers we know that serving our fellow citizens, of whatever their religious faith…aiding them, working for them, is one of the signature ways that we show a love of neighbor.”

This calling from Scripture has also been voiced by Christian leaders on Capitol Hill. Senator James Lankford (R-Okla.) recently spoke about how non-profit organizations are a crucial part of our society during a Joint Economic Committee hearing on charitable giving. Churches and non-profits are the initial components of our social safety nets. Since churches and non-profits are often on the front lines of serving needy communities, they must take the lead when it comes to formulating public policy to address many of our nation’s social ills.

So why should the government allow the faith-based community and nonprofit sector to take the lead in this area?

First, the church and other non-profits have already proven that they can make significant contributions to society. Using a national survey of religious congregations in the United States, Duke Divinity School professor Mark Chaves found that 83 percent of congregations have some sort of program to help needy people in their communities. Religious organizations also provide approximately 35 percent of the country’s volunteer hours. Furthermore, Catholic nonprofits provide between 17 and 34 percent of all private social services, and, according to recent research by Brian Grim, President of the Religious Freedom & Business Foundation, religious institutions contribute $1.2 trillion to society and the United States economy every year, more than the top 10 tech companies’ contributions combined.

Even during the current coronavirus pandemic, the church and non-profits have stepped up. As Rev. Steve Woolley recently explained, “The important work of being Christ in the community, of feeding the hungry, clothing the naked and healing the spiritually broken has continued through alternate pathways. Congregations have been able to funnel resources and time toward organizations like the Christian Aid Center, Homeless Alliance, Catholic Charities, United Way and others to see that needs continue to be met as best as can be done under the circumstances.”

Second, churches and non-profits can provide more well-rounded assistance for the people of the United States than the government at all levels. Churches and non-profits have the ability and means to provide more personal, one-on-one social services. As Pastor Gilford T. Monrose noted, “Each church can provide effective ministries and outreach services…” [filling] “a void only the church can.” Unlike many government programs that seem to just throw money at individuals or families, churches and non-profits invest physically, emotionally, and often spiritually in the lives of the people they minister to.

The government needs to supplement the charity work of churches and other non-profits, not supplant them. This is because of the church’s historic track record, the well-rounded services they provide, and out of respect for the call and command that Christians in particular have to practice charity. In the words of social welfare policy expert Michael Tanner, “We do have a responsibility to help the poor and those in need. That means taking care of them yourself—giving money yourself, giving your time, your efforts, not someone else’s.”

Connor Semelsberger, MPP is the Legislative Assistant at Family Research Council.

Jeremy Pilz is a Policy & Government Affairs intern at Family Research Council.

Be Not Wise in Your Own Eyes

by Molly Carman

June 26, 2020

Like many other Christians around the world, I am realizing more and more that we are in strange and trying times, and it can be difficult to consider how to react to various situations. Whether it is the coronavirus, unrest about race relations, or recent Supreme Court decisions, there are so many issues that demand our attention and require us to think deeply about how Christians should respond.

In every season of violence, disease, death, and civil unrest, one passage of Scripture remains particularly relevant. Proverbs 3:5-6 says, “Trust in the Lord with all your heart, and lean not on your own understanding, in all your ways acknowledge Him and He will make your path straight.” Throughout history, believers have faced the violence of war, the scourge of disease, and civil and political unrest. We are not the first and we will not be the last.

In order to respond appropriately to the various situations we find ourselves in, we must seek wisdom. Wisdom is knowledge that is rightly applied to daily life. Wisdom is essential to honoring God with our lives and teaches us how to respond during the ever-changing times. The apostle Paul (the author of 1 Corinthians) gives us this encouragement: “For the foolishness of God is wiser than men, and the weakness of God is stronger than men.” But how do we discern what is wise? How do we evaluate our lives to identify where wisdom is needed?

Because wisdom is so essential to our daily lives and growth as Christians, there are several means by which we may grow in wisdom. First, God has given us His Word to teach us and guide us in the ways we should go. Second, we can ask the Father for wisdom directly through prayer. Third, we grow in wisdom by cultivating a humble spirit and learning to discern God’s voice.

Scripture

When it comes to growing in wisdom, God’s Word is our greatest resource. Through it we learn about God’s character, attributes, and works. We also learn about ourselves, our sinful nature that separates us from a holy God, and how we can be reconciled to Him. In particular, the book of Proverbs is a collection of wise sayings that can help us order our lives. Proverbs 9:10 says, “The fear of the Lord is the beginning of wisdom.” A primary way that we show a healthy fear of the Lord is by reading and applying His Word to our lives. This year, Family Research Council began a two-year Bible reading plan called Stand on the Word. This is an opportunity to be held accountable to being in the word daily. It is easy to think that we can read one verse of Scripture a day and be spiritually full; however, wisdom calls us to spend time in God’s Word through meditation and memorization. Reading Scripture takes time because learning wisdom takes time and cannot be rushed.

Prayer

God in His grace desires to have a personal relationship with all His children, and He invites us into this relationship through prayer. Prayer is a personal conversation with God that all believers are called to. We are called to praise God with thanksgiving in our hearts (Psalm 109:30), to confess and repent of our sins (I John 1:9), and to go to God with our needs and desires (Matthew 21:22). As we spend more time in God’s Word, we will also grow in our prayer life. James 1:5 says, “If any of you lacks wisdom, let him ask God, who gives generously to all without reproach, and it will be given.” The prime example of this promise being fulfilled is in the life of King Solomon. Solomon prayed for wisdom and he was deemed the wisest man in his day (see I Kings 3).

Listen and Learn

While anyone can read the wisdom of the Bible, or pray to God for wisdom, the challenge comes in having a teachable spirit that not only seeks wisdom but applies it to their lives. Therefore, wisdom is applied knowledge. It can be easy to learn things, but we are called to listen carefully to God’s Word, be faithful in prayer, and courageously live out the knowledge that we have learned. In order to apply the work of wisdom in our lives, we must humble ourselves. This means being quick to listen and slow to speak (James 1:19). When we are students of the Word and faithful servants in prayer, we are better prepared to apply God’s wisdom during the trials and opposition that we face.

One practical way to actively grow in wisdom by incorporating all three of these principles is to join and become active in a local church. Unfortunately, many believers think they can grow spiritually by themselves; however, the Christian life is not meant to be walked alone. We need each other. The Apostle Paul teaches this throughout his writings, particularly in 1 Corinthians 12 and 14. Thus, we should seek to live in community with other believers who are also seeking to grow in wisdom.

Therefore, when we are faced with the difficult decisions or situations before us—like COVID-19, protests, and a bitter election season—and we do not know what to say, what to choose, or how to act, we must seek wisdom. Proverbs 4:7 says, “The beginning of wisdom is this: get wisdom, and whatever you get, get insight.” Rather than spending our days worrying about all of the problems in the world that are beyond our control, let us seek Christ, who is wisdom incarnate, and allow Him to guide our steps. 

Molly Carman is a Policy and Government Affairs Intern at Family Research Council whose research focuses on developing a biblical worldview on issues related to family and current events.

Be a Discipler

by Brooke Brown

June 25, 2020

Though God has appointed unique purposes for each of his children, as Christians, we all share a common purpose, and that is to make disciples and make the gospel known to all nations (Matthew 28:16-20). When we make the life-altering decision to lay down our lives and follow Christ, we can expect hardship, we can expect persecution, and we can expect for the enemy to wage war against us to keep us from spreading the Good News.

Sharing the gospel rarely makes the news. But one woman by the name of Gail Blair caught the media’s attention recently when she was banned from a public park in Rhode Island for two years for sharing the gospel with a passersby. Blair suffers from retinitis pigmentosa, a medical condition that has made her blind. This has never stopped her from boldly sharing her faith, offering people a copy of the Gospel of John, or striking up conversations with people about Jesus. What did stop her, however, was a clear bias against Christians from exercising their First Amendment rights and freely practicing their faith.

The reality is that we are fighting against principalities, power, and darkness (Ephesians 6:12). As the Civil Rights Act of 1964 was just revised to include “gender identity” and “sexual orientation,” it seems as though Christians with sincerely held biblical beliefs about sexuality will now face even more discrimination in public settings. In Blair’s case, local authorities told her that she was “trespassing” on public property. But it is clear that the only “crime” Blair is guilty of is witnessing to beliefs that are being suppressed under the pretext of “trespassing.”

Not only was Blair’s right to freedom of speech violated, her freedom of religion was abridged as well. Blair, a former nurse, believes sharing the gospel is a way she can still care for people despite her physical impairment. When the Police Department dug deeper for evidence of violating guidelines expected by park goers, it was found that there was no reasonable cause for Blair to be banned by The Memorial and Library Association. Threatening to arrest her if she enters the park again is nothing less than a clear violation of her First Amendment rights.

If anyone knows persecution, it is Jesus, who was mocked, beaten, stoned, and killed on a Roman cross. Of course, what we face as Christians today does not compare to the pain Jesus endured during the crucifixion. However, as his image bearers and followers, we are called to follow him, even to the point of death if required (Matthew 16:24). In fact, Christians in closed countries around the world regularly face intimidation, threats, and physical persecution because of their faith. In the United States we are blessed with religious liberty, and we should never take this right for granted.

However, it is also important to recognize that the religious freedom we have in this country is under assault. Christians should not sit idly by while the world attempts to strip us of these rights which help us carry out the Great Commission. We must put on the “full armor of God” (Ephesians 6:11), equip ourselves by reading and applying God’s Word to our lives, allow Scripture to be the cornerstone on which we live and breathe, and be ready to give an answer to everyone who asks (1 Peter 3:15). Just as God is our defender, we are also his defendants during our time on earth. He deserves all the glory and praise as our Creator for giving us mouths to speak, ears to listen, eyes to see, and hearts to connect.

Blair is not backing down from her beliefs and her rights, and neither should we. Sharing the gospel can be a daunting, exhilarating, nerve-wracking experience. We are bound to face rejection, just like Blair. But it is through rejection, ridicule, and through looking different that we will grow and become more and more like Jesus. Our fear of man should weigh much less than our fear of the Lord. Easier said than done, yes. But, when we have the power of the Holy Spirit dwelling within us, the same power that rose Jesus from the grave, we can conquer great things in the Lord’s name.

Is it upsetting that one of our own sisters in Christ has been banned from visiting her nearby public park for simply sharing the Good News? Absolutely. So, what is our defense? Jesus and prayer. We follow a God that is just, a God that sees all things on earth. We are called to bear one another’s burdens (Galatians 6:2). Therefore, we should link arms with Blair in prayer for her and for this country. This world is in desperate need of our Savior. It is our responsibility to be the salt and light (Matthew 5:13-16), to reflect God’s heart by speaking his truth accompanied by love to those we encounter.

As believers, we must stand united to defend our religious freedom and to share the heart-transforming gospel with people. Only through the power of God can we make a difference for his Kingdom. Equip yourselves with his word, step out of the boat in full faith (Matthew 14:22-23), invite a friend or coworker to church this weekend, and be a discipler.

Brooke Brown is a Brand Advancement intern at Family Research Council.

What is the Role of the Church Amidst Troubling Times?

by Samantha Stahl

June 18, 2020

According to Scripture, Christians have a responsibility to share the hope of the gospel (Mat. 5:14-16). Jesus made this clear in the Great Commission when He commissioned His disciples to spread His message to the ends of the world. Today, Americans are experiencing trying times. Amidst a virus that is frightening people and tearing apart economies, church celebrations that remain suspended, and riots that put vengeance as the answer to cases of unjust police violence, it can be hard to see God working. However, through the darkest points in history, God has raised up people of strong faith. Right now, God is calling upon the church to lead His people, and to not be silent. The church can give answers to today’s questions of how to proceed.

As controversial as it may be today, Christians are called to bear witness to the truth. This is not easy, but it is important to allow oneself to be guided by what is right and not by fear. Prayer is greatly needed for leaders and for the community. Even when it seems God is not immediately answering our prayers, we are still called to pray (1 Tim. 2:2). Leaders of the church must not be silent and must continue to speak bold messages of hope and support during these times.

As we’ve seen throughout the last three months, Christians should continue to serve those in their communities by offering them encouragement. Serving one’s community can be as simple as making a call or writing a letter, or something practical such as running an errand or safely praying with them. The best way to be a light of God is to be a light to others in His name. For a list of resources including ideas to serve your community, check out FRC’s church resource page at frc.org/church.

Christians must also not be silent during these times, especially as churches are still closed. When the church cannot worship together, the whole Christian community and beyond is affected by a lack of sharing the gospel. Christ’s command to “proclaim the good news to the whole creation” is greatly hindered if Christians cannot come together to worship (Mark 16:15). Many have fallen and will fall into a spiritual slump due to months of being unable to gather for public worship. Peace and joy have been fading as violence and hate settles in among people. The world needs the church now more than ever as it is greatly feeling the lack of messages of hope and guidance previously brought by open churches. Christians must be able to again partake in the communal worship of God in order to best be a light for this world.

Christians can help America get through the violent riots and the ensuing destruction. This is accomplished specifically by supporting the good in people. Peaceful protests represent the proper use of American freedom. However, when violent riots ensue (which do not honor the memory of George Floyd and others unjustly killed), it becomes an abuse of freedom.

As Christians, speaking out with love in the face of anger will change the response to violence. An example of such Christian leadership can be found in the words of Rep. Mike Johnson (R-La.) during a recent Congressional hearing on police brutality, where he stated that everyone is made in the image of God, despite skin color. He called for a defense of the people upholding truth and justice, while not condoning those who obstruct those values. Elsewhere, many people have reached out to communities struck by violent riots, cleaning up the mess as best they can. For example, according to CNN, a truck driver in Houston, Texas named Brian Irving spent hours cleaning up after a riot destroyed parts of the city. Such examples of Christians living out the principles of their faith are shining beacons in these dark times, and they ought to be emulated. The church has a unique opportunity to bring these moments of good to light, and show the world there are indeed good people.

When the church is at work during a time of crisis, God does not fail to turn that work into something beautiful. Setting an example of prayer and peace in a time of pandemonium will help bring stability. Christians must rise together and bring the truth of Christ to a world that is searching for truth. God is calling the church to be that beacon of light for the world.

Samantha Stahl is Policy/Government Affairs intern at Family Research Council.

Online Outreach: How to Continue Fulfilling the Great Commission During the Coronavirus

by Worth Loving

April 21, 2020

Over the last month, most churches in America have been forced to cancel all of their normal services and activities due to the coronavirus outbreak and government-imposed lockdowns. Because pastors and churches rely very much on face-to-face interaction to effectively minister to their congregants, the current crisis has presented a unique challenge unlike any we have ever faced in modern times.

With most churches closed to the public, many are opting to livestream their services online through their website or through platforms like Facebook and YouTube. Pastors are giving messages from their living rooms or simply broadcasting their sermon from an empty church auditorium. And while it’s certainly not the same as meeting in person, online outreach has proven to be incredibly effective.

Allow me to give a personal example. I’m privileged to attend GraceWay Baptist Church in Washington, D.C., just east of Capitol Hill. After being forced out of our rented facility due to the coronavirus, online outreach has become our only means of airing our services. Our pastor, Brad Wells, says, “The apostle Paul brought the good news of the Gospel of Jesus Christ to an ancient marketplace. So whether it’s an ancient marketplace, a modern marketplace, or a virtual marketplace, Christ’s disciples need to have the gospel prominent.”

Over the last few weeks, we have witnessed our online outreach explode. We’ve been developing our online ministry over the past few years, particularly with livestreaming services through our website and Facebook. Before the coronavirus pandemic, our livestream averaged reaching anywhere between 500-1,500 people on a given Sunday. Now, over a month into completely livestreamed services after the virus forced us to cancel in-person services, our reach has soared to 6,000 as of Sunday, April 6th! Similarly, our peak viewers on March 8th, the Sunday before the lockdown began, was only five on our Facebook page. On Sunday, March 29th, that number surged to 64! At the start of the quarantine, the livestream of our morning service was shared just eight times and received only 17 comments. On Easter Sunday, April 12th, our Facebook livestream was shared 42 times. The following Sunday, April 19th, saw 251 comments! We have received comments from people watching all over the country and around the world. We have even had people call in to request prayer.  

Another example of the effectiveness of online outreach comes from my home church, Parkers Chapel Free Will Baptist Church in Greenville, North Carolina. Like GraceWay, Parkers Chapel has been gradually developing their online ministry as well. Before the coronavirus pandemic forced them to cancel regular services, the number of people who engaged with the Parkers Chapel Facebook page averaged around 100 or fewer. As of Sunday, April 12th, that number had surged to 2,000! Similarly, Parkers Chapel’s Facebook livestream reached around 100 or fewer people before the pandemic. But on Sunday, April 12th, the reach peaked at over 12,000! Pastor Gene Williams praised the effectiveness of Parkers Chapel’s online ministry: “It has been amazing to watch the opportunity that the Lord has given to us through this adversity to reach so many. It is not the size of the audience alone, but their appetite to know the truth that has been changed. Our online platform has enabled us to stay connected not only with our church but also with our community and even beyond that.”

I share these examples to encourage other pastors and churches who may be discouraged about not being able to meet in person. Yes, our present circumstances are far from ideal, but that doesn’t negate our responsibility to continue fulfilling the Great Commission. Just because we are not able to meet like normal does not mean we still cannot spread the gospel. God has provided us an incredible tool in the form of livestreaming that previous generations never had. In fact, we are likely able to reach even more people now than ever before because so many more are watching services online. Facebook usage has soared by over 50 percent since mandatory quarantines have forced so many to stay at home.

We each have our own social media networks that no one else has access to. It’s likely that many of the people in your network look up to you in some way and value what you post. What an incredible opportunity to reach them by sharing your church services on your personal page. For example, after sharing GraceWay’s services over the past few weeks on my personal social media, I’ve had numerous friends and family members, some who are unsaved, reach out to me to say what a blessing the service was to them. These are people who likely never would have been reached had I not shared the service on my own page.

Consider this also. One of the most disastrous implications of the virus is the tremendous toll that mandatory business lockdowns are taking on the economy. Some people are becoming desperate and hopeless because they have lost their jobs. In fact, the most recent numbers from the Labor Department show that more than 22 million people have applied for unemployment benefits in just the last month, likely bringing the unemployment rate close to 20 percent. Domestic violence is increasing as well. Many families that are not typically together during the workweek find themselves at home all day, which is leading to more arguments and abuse. We are also seeing an increase in drug and alcohol abuse as people become more depressed and isolated. Pornography use is up as well as many in isolation seek an outlet for their anxiety and depression. Perhaps most concerning of all is the increase in suicides.

With many people in desperate situations spending so much time online, now is the time appointed by God to develop your church’s online ministry. We are living in unprecedented times. But with that comes an unprecedented opportunity to reach thousands of unbelievers through social media with the lifesaving power of the gospel. There will be hopeless people mindlessly scrolling through their Facebook feed who need to hear your message!

So pastors, be encouraged. Yes, these are far from ideal circumstances, but God has provided us an incredible opportunity to spread the gospel. In fact, this is an opportunity that previous generations have not had. So take advantage of whatever God has given you this Sunday. It doesn’t have to be perfect. Even if you just livestream singing a few songs on the guitar with your family or giving a brief devotion from your living room, I promise you God will bless it. There are people out there who are more desperate now than they have ever been before, people longing for the hope that is found only in Jesus. God has promised that His Word will not return void (Isaiah 55:11), so boldly proclaim the truth that God has given you with whatever means He has given you.

We have not been given the spirit of fear (2 Timothy 1:7), so may we always be able to give a reason of the hope that is within us! (I Peter 3:15)

If you need help developing your church’s online outreach, here are some practical guides and websites to help you get started:

Open the Doors? The Vast Majority of Churches are Not Defying Government Orders

by Quena Gonzalez , David Closson

April 9, 2020

On Sunday, the Washington Post ran a story on churches that are continuing to meet despite most states having banned assemblies of more than 10 people. The article cites only seven churches, yet suggests a nationwide pattern of recalcitrant Protestants who are defying government orders and continuing to meet.

But is this portrait accurate?

At first glance, the Post’s claims seem to be backed up by data from a respected polling firm. The article cites LifeWay’s recent report on whether Protestant churches are meeting. To be fair, the top-line numbers in LifeWay’s chart are striking; one religion reporter cited the 7 percent figure and mused, “if this is still happening in areas that have had outbreaks, it’s a serious, serious issue.”

Three questions need to be answered: Did Protestant churches defy government bans on public gatherings? Are a large number of churches continuing to meet in person? And, if not, what are they doing instead?

Did Churches Defy Government Orders?

The answer is, by and large, no. A quick search for recent news stories reveals that most of the headlines are traceable to a handful of high-profile churches, some of which (including at least two churches featured in the Washington Post article) stopped meeting weeks ago.

These findings are backed up by the LifeWay report, which notably only covers the month of March. Many states did not impose bans on public gatherings until only very recently, and according to the Washington Post, “more than a dozen states” exempted churches from stay-at-home orders as late as April 5th. State orders lagged behind the CDC’s March 15th recommendation to pause all gatherings of more than 10 people. Even so, the LifeWay data show that the sharpest drop-off of in-person meetings was on Sunday, March 22nd, suggesting that most churches took the CDC’s nonbinding recommendation (announced the previous Sunday night) seriously.

State bans on public gatherings were soon followed by stay-at-home orders, but according to a New York Times timeline, only nine states had a stay-at-home order as of Monday, March 23rd. By then, 89 percent of Protestant churches had stopped meeting. Furthermore, many state bans on public gatherings were amended several times and would have initially applied only to large churches. For example, Maryland initially banned gatherings of more than 250 people on March 12th; its March 16th order banning gatherings larger than 50 would not have applied to churches with fewer than 250 attendees that met on Sunday, March 15th.

This is an easily-overlooked point: Small congregations, which make up the vast majority of American churches, tend to be overlooked in media reporting in favor of megachurches. The Hartford Institute for Religion Research, for example, cites research indicating that half of all churches have an attendance of less than 75, that 59 percent of non-Catholic/Orthodox churches have less than 100 attendees, and that the average church size for all churches is 186. The Hartford Institute also estimates that there are 314,000 Protestant churches in the U.S., of which less than 1 percent are megachurches.

Stay-at-home orders rolled in throughout March: By Thursday, March 26th, 21 states had stay-at-home orders. By the following Monday, March 30th—one day after 93 percent of Protestant churches did not meet in-person—20 states still did not have statewide stay-at-home orders.

The study cited by the Washington Post does not necessarily support the notion that a significant number of Protestant churches were meeting in defiance of government orders.

Are a Large Number of Churches Continuing to Meet?

Less data exists on how many churches are currently meeting. However, despite the implication by the Washington Post story that this is a national phenomenon, the available data suggests that an overwhelming majority of churches are abiding by the CDC’s recommendation and are not holding in-person services.

LifeWay’s report only covers the month of March, but a deeper dive into their data is instructive. According to the report, 64 percent of churches met in-person on March 15th, 11 percent on March 22nd, and 7 percent on March 29th. Significantly, the report also shows that only 45 percent of churches with more than 200 attendees met on the 15th, fewer than 1 percent met on the 22nd, and 0 percent met on the 29th.

In other words, more than half of all churches with congregations numbering 200 or more had ceased meeting in person by the middle of March, 99 percent of them were not meeting by the fourth Sunday, and a statistically negligible number were meeting by the last Sunday of the month.

Clearly, churches still meeting after the end of March are statistical outliers. Yet the Washington Post story suggests that a significant number of churches are still meeting in defiance of government orders, despite strong evidence to the contrary. The very few churches that are still meeting are attracting outsized attention from the media.

How are Churches Adapting?

Instead of flaunting the government’s orders and continuing to meet in large groups, churches across the country are adapting to serve their congregations and communities in creative ways. For example, many churches are using live-streaming technology such as Zoom, YouTube live, and other streaming platforms to hold weekly services and prayer meetings with their members. Others, such as 3D Church, in Lithonia, Georgia, Genoa Church in Westerville, Ohio, and Highview Baptist Church in Louisville, Kentucky, are holding “Drive-In” services where members stay in their cars and listen to a message delivered by their pastor from a small stage (or even from a forklift!) near the front of the parking lot. These services allow churches to meet while still maintaining social distance and honoring the government’s ban on public gatherings.  

Churches are also looking outward, seeking ways to serve their communities in tangible ways despite limitations on public meetings. For example, Faith Life Church in New Albany, Ohio, has delivered lunch to nurses and doctors and has provided meals to needy people in the community. Resurrection Lutheran Church, in Juneau, Alaska, and Canyon Hills Friends Church in Yorba Linda, California, are running food pantries in their communities, and I-Town Church in Fishers, Indiana, set up a pantry at a local school. Trinity Church in Temple, Texas, set up a “prayer tent” and prays and ministers to anyone who pulls into the parking lot. OpenDoor Church, in Burleson, Texas, created a national hotline for people to call in to receive prayer or to submit requests for help with grocery shopping. Even smaller church plants, such as the Oaks Church in Cincinnati, Ohio, are providing free childcare to healthcare workers and buying groceries for those in need. 

Other churches are focusing on helping vulnerable people groups. St. Paul Lutheran Church in Albuquerque, New Mexico, is serving refugees with their food bank, and River City Church in Montgomery, Alabama, is providing showers and laundry services to the homeless. Still others, like the Church of the Highlands in Birmingham, Alabama, are serving their community by opening a virus testing site at one of their church campuses.  

These stories, and many others like them, represent the response of the vast majority of churches to the pandemic. Although the hearts of believers around the country are heavy because they cannot meet with their brothers and sisters on Easter, it is encouraging to see so many congregations walking in obedience to our risen Lord while also obeying Scripture’s mandate to honor governing rulers (Rom. 13:1-7).

Prayer Point #7: Pray for a Spirit of Generosity

by David Closson

April 8, 2020

The world is reeling from the threat of the coronavirus (COVID-19). For many, our entire way of life has been upended by a novel virus that health experts say presents a particular risk to our elderly and immunocompromised friends and neighbors.

As Christians, we know that one of our greatest spiritual weapons is prayer (Eph. 6:18). But what exactly should Christians pray about amidst these trying times? FRC’s President, Tony Perkins, recently released nine prayer points to guide us in prayer. Each point provides a specific way for Christians to pray during the ongoing crisis.

Over the last few weeks, churches have responded to the coronavirus in heroic and creative ways. Across the country, churches have hosted “Drive-In” worship services, purchased meals for nurses and doctors, provided groceries for needy families, and ministered to their hurting neighbors. In this dark hour, God’s people have sacrificially served one another and their communities and demonstrated remarkable faith. As the pandemic continues to disrupt our normal rhythms of life, opportunities for the church to meet practical needs are increasing. While the government is providing support to churches in the form of forgivable loans (for more information about these loans, see our full analysis), churches are beginning to feel the pinch as charitable giving and tithing declines. Therefore, especially over the next few weeks, Christians need to pray for a spirit of generosity. Here are a few specific ways to pray.

First, pray that Christians will be faithful to give to their local churches. According to a recent poll from LifeWay Christian Resources, 52 percent of pastors have already reported a decrease in giving due to their church’s limited ability to gather. Of those who have seen a giving decline, 60 percent say it has dropped by at least 25 percent. This decline is significant because, according to a recent LifeWay study, 26 percent of churches only have enough operating reserves to cover seven or fewer weeks. For many churches, a sharp decline in giving represents an enormous challenge. Therefore, during these trying times, Christians should commit to praying for and financially supporting their churches.

Second, pray for ministry opportunities. Many people have fallen on hard times: unemployment claims are up, workers are being let go or furloughed, and there is a pervading uncertainty in many communities. As tens of millions of Americans comply with stay-at-home orders and practice social distancing, many are finding themselves lonely, afraid, and uncertain about the future. Amid this social context, the church has an opportunity to serve people and share with them the hope of the gospel. We should pray for Christians to think of creative, outside-the-box ways to generously meet the physical and spiritual needs of their friends and neighbors.

Incredibly, in many places, people are coming to faith as the result of church members thinking outside the box. For example, Trinity Church in Temple, Texas, has seen people put their trust in Christ after a member of the congregation suggested setting up a “prayer tent” in the church parking lot. Over the last two weeks, members of the community have pulled into the parking lot for prayer and counsel. As Senior Pastor Ed Dowell recently told me, “People have given their life to Christ” as a result of the prayer tent ministry.

Third, believers should remember what the Bible says about generosity. In the Old Testament, the prophet Malachi spoke for God when he said, “Bring the full tithe into the storehouse, that there may be food in my house. And thereby put me to the test, says the Lord of hosts, if I will not open the windows of heaven for you and pour down for you a blessing until there is no more need” (Mal. 3:10). A similar promise is found in Proverbs 11:25: “Whoever brings blessing will be enriched, and one who waters will himself be watered.” In the New Testament, Jesus tells His followers, “[G]ive, and it will be given to you. Good measure, pressed down, shaken together, running over, will be put into your lap. For with the measure you use it will be measured back to you.”

Of course, Christians should reject the empty promises of the “prosperity gospel,” which falsely guarantees financial blessing in exchange for sowing a seed in a particular ministry. However, Scripture is clear that God honors the generosity of His people. Although some churches and ministries have tragically misunderstood, abused, and exploited these promises, we should not blunt the message of Scripture, which is that God honors and blesses those who are generous. As Christians are able, we should strive to give to our churches and other ministries engaged in gospel work.

Finally, in his second letter to the church in Corinth, Paul addresses the issue of generosity and financial giving. He says, “The point is this: whoever sows sparingly will also reap sparingly, and whoever sows bountifully will also reap bountifully. Each one must give as he has decided in his heart, not reluctantly or under compulsion, for God loves a cheerful giver. And God is able to make all grace abound to you, so that having all sufficiency in all things at all times, you may abound in every good work” (2 Corinthians 9:6-8).

As the country grapples with the realities of the coronavirus, Christians have opportunities to serve their neighbors and communities. In many of these communities, churches are on the front lines of meeting practical needs. Let’s pray for a spirit of generosity among God’s people, so the courageous, creative, and winsome witness of the church may continue to go forth during these uncertain times.

Coronavirus Relief: What Churches and Nonprofits Need to Know About Accessing SBA Loans

by Travis Weber, J.D., LL.M. , Connor Semelsberger, MPP

April 4, 2020

On April 3rd, lenders began processing Paycheck Protection Program (“PPP”) relief loans around the country. As authorized by the “Phase 3” coronavirus relief legislation known as the CARES Act, the $349 billion PPP program will grant forgivable Small Business Administration (“SBA”) loans to small businesses and nonprofits for hardship they have suffered under the coronavirus-inflicted economic shutdown. These loans will cover eight weeks of necessary expenses during the coronavirus crisis.

In conjunction with the launch of the program, the SBA published an interim final rule, effective immediately, with further guidelines for lenders and borrowers—including guidance on religious freedom. SBA also issued an interim final rule on affiliation clarifying that faith-based organizations are exempt from SBA affiliation rules if those rules burden religious exercise. Finally, the SBA published a list of Frequently Asked Questions (“FAQs”) regarding the ability of faith-based organizations to access these loans—and Economic Injury Disaster Loans (“EIDL”). These FAQs bring significant clarity to many of the issues discussed below.

What follows are some key considerations for churches to understand and think through when applying for these loans.

Church Eligibility

The final text of the CARES Act and subsequent guidance make clear that a tax-exempt nonprofit organization—described in section 501(c)(3) of the Internal Revenue Code (IRC)—is eligible to apply for relief. Under IRS guidance, the 501(c)(3) definition generally includes churches—even if they have not registered with the IRS—as long as they meet 501(c)(3) requirements. Members of Congress wanted to ensure the program included all churches and houses of worship, even those unregistered churches without a letter of determination from the IRS. To make this clear, a bipartisan group of members headed by Republican Whip Steve Scalise (R-La.) and Representative Mike Johnson (R-La.) sent a letter to key agencies to clarify that these churches are included within the program. Based on the most recent guidance, we can now say they are included.

Some questions have come up about church eligibility for different types of loans under the CARES Act. The PPP created a new SBA loan program based on existing Section 7(a) small business loans, which changed eligibility to include all 501(c)(3) nonprofits, including churches, which previously were not eligible for these small business loans. It had appeared that EIDL loans, which provide working capital for organizations during a time of declared disaster, were only available for small businesses and private nonprofits, which does not include public charities like churches.

However, the FAQs make clear that faith-based entities can receive both EIDL and PPP loans, and do not need a determination letter from the IRS to do so.

The bottom line: All churches, even unregistered ones, can qualify for both EIDL and PPP loans.

Religious Liberty Concerns for Churches and Religious Nonprofits

Based on the most recent guidance in the interim final rules and FAQs, virtually all religious liberty issues in this loan program have been addressed.

One of the concerns had been requirements reflected on the SBA loan application: “All businesses receiving SBA financial assistance must agree not to discriminate in any business practice, including employment practices and services to the public on the basis of categories cited in 13 C.F.R., Parts 112, 113, and 117 of SBA Regulations. All borrowers must display the ‘Equal Employment Opportunity Poster’ prescribed by SBA.” Certain of these religious and sex nondiscrimination provisions in the SBA code, based on the way courts have interpreted such provisions, could run counter to church statements of faith and hiring practices and violate their faith.

The interim final rule addresses these concerns in part by reiterating religious liberty protections, stating that “all loans guaranteed by the SBA pursuant to the CARES Act will be made consistent with constitutional, statutory, and regulatory protections for religious liberty, including the First Amendment to the Constitution, and the Religious Freedom Restoration Act.” The rule also provides for the application of 13 C.F.R. 113.3-1h, an SBA regulation which states that “[n]othing in [SBA nondiscrimination regulations] shall apply to a religious corporation, association, educational institution or society with respect to the membership or the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution or society of its religious activities.”

The problem was that while 113.3-1h is helpful, it does not cover all relevant religious liberty concerns. As attorney Ian Speir, whose practice at Nussbaum Speir Gleason PLLC specializes in churches and religious nonprofits, points out: 13 C.F.R. 113.3-1h mirrors the Section 702 exemption in Title VII. That exemption has largely been interpreted to permit religious preferences in hiring, but not tolerate practices deemed to be other forms of “discrimination.” And “sex discrimination” may include firing an employee for out-of-wedlock pregnancy or for sex-related lifestyle choices contrary to the employer’s faith. Further, if a ministry has fewer than 15 employees, it’s not currently subject to Title VII; but if it takes SBA funds, it will be subject to the SBA’s regulations—so this ministry may find itself subject to new mandates as a result of accepting aid.

In the final analysis, however, any such outstanding concerns remain minimal.

The FAQs make expressly clear that:

  • Faith-based organizations can receive the loans regardless of whether they provide “secular social services.” (As the FAQs say, “no otherwise eligible organization will be disqualified from receiving a loan because of the religious nature, religious identity, or religious speech of the organization.”);
  • The religious instruction limitation referenced in 13 CFR 120.110 will not be applied, and will thus not inhibit religious organizations in how they use these loans;
  • Faith-based organizations can use the loans for anything that a secular organization can (no “additional restrictions on how faith-based organizations may use the loan proceeds”);
  • Churches are “not required to apply to the IRS to receive tax-exempt status” in order to access the loans; and
  • Faith-based organizations will not be required to sacrifice their “independence, autonomy, right of expression, religious character, and authority over [their] governance” in order to access these loans.

The FAQs also make clear that religious liberty protections are to be comprehensively applied throughout the loan program:

Consistent with certain federal nondiscrimination laws, SBA regulations provide that the recipient may not discriminate on the basis of race, color, religion, sex, handicap, age, or national origin with regard to goods, services, or accommodations offered. 13 C.F.R.§113.3(a). But SBA regulations also make clear that these nondiscrimination requirements do not limit a faith-based entity’s autonomy with respect to membership or employment decisions connected to its religious exercise. 13 CFR §113.3-1(h). And as discussed in Question 4, SBA recognizes the various protections for religious freedom enshrined in the Constitution and federal law that are not altered or waived by receipt of Federal financial assistance. SBA therefore clarifies that its regulations apply with respect to goods, services, or accommodations offered generally to the public by recipients of these loans, but not to a faith-based organization’s ministry activities within its own faith community. For example, SBA’s regulations will require a faith-based organization that operates a restaurant or thrift store open to the public to serve the public without regard to the protected traits listed above. But SBA’s regulations do not apply to limit a faith-based organization’s ability to distribute food or clothing exclusively to its own members or co-religionists. Indeed, SBA will not apply its nondiscrimination regulations in a way that imposes substantial burdens on the religious exercise of faith-based loan recipients, such as by applying those regulations to the performance of church ordinances, sacraments, or religious practices, unless such application is the least restrictive means of furthering a compelling governmental interest.”

A few remaining concerns: It should be noted that these loans do constitute “federal financial assistance” and thus obligate the borrower to comply with any attendant requirements. However, as explained above, the religious liberty concerns regarding those requirements are almost all addressed, and the FAQs make clear that such requirements do not extend beyond the life of the loan in any event.

However, churches may be obligated by state and local nondiscrimination requirements due to taking these loans, a point also observed by attorney Ian Speir. This is likely something that churches will have to consider based on consultations with their attorney or other professionals familiar with the legal landscape in their state.

The bottom line: While a few, smaller concerns remain, churches and other faith-based entities can be generally confident their religious freedom will be protected in this loan program.

What to Know When Applying for These Loans

After weighing all these considerations, churches and nonprofits with fewer than 500 employees (or those who qualify under the interim final rule on affiliation) that want to apply for PPP loans can find information on the SBA website. To begin, interested organizations must find a local bank or credit union that is eligible to administer these loans. The SBA is working on adding many new lenders to expand the reach of the program. To apply with the lender, the organization must fill out this application form and provide payroll documentation. If approved, the lender will work to administer the funds promptly, with the goal of them being available the same day.

This program is administered as a loan, but if the funds are used on essential payroll expenses, it will essentially act as a grant, and the loan amount will be forgiven in full. Churches considering applying for the PPP loan should keep these key facts in mind:

In order to get forgiveness, the organization must use the loan for:

  • Payroll costs, including benefits;
  • Interest on mortgage obligations, incurred before February 15, 2020;
  • Rent, under lease agreements in force before February 15, 2020; and
  • Utilities, for which service began before February 15, 2020.

Payroll costs include:

  • Salary, wages, commissions, or tips (capped at $100,000 on an annualized basis for each employee);
  • Employee benefits including costs for vacation, parental, family, medical, or sick leave; allowance for separation or dismissal; payments required for the provisions of group health care benefits including insurance premiums; and payment of any retirement benefit;
  • State and local taxes assessed on compensation.

Requests for loan forgiveness will be submitted to the lender. They will include documents that verify the number of full-time equivalent employees and pay rates, as well as the payments on eligible mortgage, lease, and utility obligations. An organization will owe money on the loan if it is used for anything other than payroll costs, mortgage interest, rent, and utility payments over the eight weeks after getting the loan. No more than 25% of the forgiven amount may be for non-payroll costs.

There are also requirements to maintain payroll and staff:

  • Number of Staff: Loan forgiveness will be reduced if the number of full-time employees is reduced.
  • Level of Payroll: Loan forgiveness will be reduced if salaries and wages are reduced by more than 25 percent for any employee that made less than $100,000 annualized in 2019.
  • Re-Hiring: Employers have until June 30, 2020, to restore full-time employees and salary levels for any changes made between February 15, 2020, and April 26, 2020.

If the organization must pay back any loan amount, it will be paid back with 1 percent interest. All payments are deferred for six months; however, interest will continue to accrue over this period. The loan will be due in two years.

EIDL loans are another option for nonprofit organizations to consider if they have been met with financial hardship. This program provides eligible organizations with working capital loans of up to $2 million that can provide necessary economic support. Eligible organizations that need immediate help replacing lost revenues, can receive an advance of up to $10,000 that will not have to be repaid. Those interested in applying for EIDL loans can do so here.

It can be challenging to determine whether it is in your organization’s best interest to apply for federal financial programs like the Paycheck Protection Program. The coronavirus crisis has brought the American economy to a standstill, and many nonprofit organizations are struggling with financial instability. However, government aid programs that may help organizations financially may also come with some unintended consequences. Fortunately, Congress has intended to make the PPP open to religious organizations in the same way small businesses are—without additional government stipulations that dramatically change how religious organizations operate. The FRC team will continue to work alongside allied organizations to ensure that the congressional intent of the CARES Act (to not discriminate against religious organizations for financial aid) is carried out when implementing programs like the PPP.

To help the church navigate these and other challenges we are confronted with due to the coronavirus, we have created a resource page at FRC.org/church. Please visit us there and let us know how else we can be of help.

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