Expatriate health plans (or “Expat Health Plans”) have led to much confusion ever since the ACA came into effect in 2010. Simply put, expats (or anyone living/working abroad) struggled with how they would be adequately covered while not residing in the United States.
When the Expatriate Health Coverage Clarification Act (aka the Expat Act or EHCCA) was announced in 2014, the goal was to elaborate on where expats fit into the ACA paradigm for health coverage.
It was further impacted in 2015 by the Consolidated and Further Continuing Appropriations Act, where funding came into question. However, the scope of expat coverage was still a rollercoaster, where expat plan exemptions and minimum essential coverage couldn’t see eye to eye.
Things are looking up. In June, the Federal Register released information on proposed changes from the U.S. Department of Labor’s Employee Benefits Security Administration, the U.S. Department of Treasury, and the U.S. Department of Health and Human Services.
Changes are as follows:
Further clarity is provided on plan exemptions and what “qualified expatriates” entails. These would be what are called “inpatriates,” or those who temporarily travel abroad for employment purposes based on specific skill. The other are expats working abroad for 12 consecutive months for at least 180 days. Further, “qualified expatriates” cannot be U.S. nationals, require health care beyond one country abroad, and are covered for other employee benefits like certain out of country expenses.
Other terms like “substantially all” are explained, as only if less than 5% of expats are not qualified. “Primary enrollees” are expats qualified for coverage and not a dependent or spouse of an eligible expat. “Minimum value” is defined as coverage of at least 60% of allowed health care costs.
For more information on proposed regulations and their 2017 effect if cleared, click here.