What is Expatriate Coverage?
Insurance for Prevailing Wage Workers Sent for Work Abroad
In the world of government contracting, there may be instances that you will employ expatriates as part of your prevailing wage workers. Expatriate coverage can be a tricky and confusing matter, and providing them medical insurance may not be as simple. Read on to find out more on expatriate coverage and benefits.
What is an Expatriate?
Before we delve any deeper on expatriate coverage and plans, let us define who is an expatriate. An expatriate has three categories:
a) An individual with the skills and qualifications that made the employer transfer or assign an individual to the US for a specific and temporary assignment. The individual must not be a US national.
b) An individual who works outside of the US for at least 180 consecutive days in a 12 month period. The individual must be a US national.
c) An individual who is a member of a group formed for services listed in the IRS Code 501C. It can be in the US or in another country.
Only the first two categories apply to employment and group medical insurance.
What is an Expatriate Health Plan?
An “Expatriate Health Plan” is a plan offered to qualified expatriates as described above. The plans must meet the following requirements:
a. At least 95% of the primary enrollees are qualified expatriates, from day one.
b. The plan must be issued and administered by an expatriate health insurance issuer and an expatriate health plan administrator respectively.
c. The plan must cover inpatient hospital services, outpatient health services, doctors’ fees and services, and emergency services.
d. The plan must satisfy minimum value requirements.
e. The plan must provide dependent child coverage up to age 26.
Employers often provide medical insurance and coverage to US nationals assigned abroad under foreign medical insurance maintained in the locality where they work, or under special health policies of expatriates. The plan or policy must comply with local rules on medical insurance.
A self-insured health insurance offered by an employer to its employees, qualifies as minimum essential coverage, wherever the plan is located. In the case of group health plans, they can only qualify as MEC if the insurance if offered within the 50 states of the US. The Expatriate Health Coverage Clarification Act of 2014 of the ACA however, stated that any plan that qualifies as an expatriate health plan is considered to provide minimum essential coverage. And it must also meet the requirements stated above.
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