RFRA and the "ministerial exception"

A few days ago, Howard Bashman blogged about an interesting, recent case in the Second Circuit.  In this case, "[t]he majority concludes that the Religious Freedom Restoration Act of 1993 may preclude a minister's federal age discrimination claim against his church, thereby eliminating any need for the Second Circuit to consider whether to adopt the controversial 'ministerial exception' to the ADEA."  Tom Berg (and many others) know more about this than I do, but I gather it is still the case that the Supreme Court has never stated clearly that the "ministerial exception" (or something like it) is required by the Religion Clause itself.