The IRS has provided interim guidance in Notice 2015-43 on the application of certain provisions of the Affordable Care Act to expatriate health insurance issuers, expatriate health plans, and employers in their capacity as sponsors of expatriate health plans. The interim guidance is effective for policies that are issued or renewed on or after July 1, 2015, and for plan years that start on or after July 1, 2015. We discussed ACA issues for U.S. expatriates and expatriate health plans in an earlier post.
As background, the regulatory agencies issued temporary relief in FAQs XIII and FAQs XVIII that exempted certain expatriate health plans from some of ACA’s market reforms if they complied with a number of pre-ACA mandates. The FAQs applied only to insured plans with enrollment limited to primary insureds who live outside their home country or outside the U.S. for at least 6 months during a 12-month period and their dependents. The FAQs provided no relief for self-insured plans.
Continue Reading Interim Guidance for Expatriate Health Plans