Frequently Asked Questions
With an international health plan from IMG, you have medical coverage worldwide. Our plans give you the freedom to choose your own health care provider wherever you are in the world.To view IMG's exclusive provider list, visit the Find A Doctor page in the myIMG member area.
To qualify as an “expatriate health plan,” substantially all of the primary enrollees must be “qualified expatriates.” A “qualified expatriate” is a primary insured meeting all of the following:
Qualified Expatriates in the U.S.:
The individual’s skills, qualification, job duties, or expertise is of a type that has caused the employer to assign him to the U.S. for a specific temporary purpose or assignment tied to employment; and
In connection with such transfer or assignment, the plan sponsor reasonably determines that the individual will require access to health insurance in multiple countries, and is offered other multi-national benefits on a periodic basis (e.g., tax equalization benefits, cross-border moving expenses, compensation to enable the expatriate to return to his home country);
Qualified Expatriates Outside of the U.S.:
The individual is working outside the U.S. for a period of at least 180 days in a consecutive 12-month period that overlaps with the plan year. For purposes of the definition, “U.S.” includes the 50 states, D.C., and Puerto Rico.
There are also special provisions for members 501(c)(3) and 501(c)(4) organizations who are traveling or relocating internationally for the organization, including students and religious missionaries.
Expatriate Health Plans are Minimum Essential Coverage
Expatriate health plans qualify as minimum essential coverage. This means that an expatriate health plan will satisfy the employer mandate and the enrollee’s individual mandate.
Employers are Still Subject to §6055/§6056 Reporting and Cadillac Tax on Certain Expatriates
The exemption from ACA requirements does not apply for the new health information reporting requirements for the beginning of 2016.
However, the information statements (primarily the Forms 1094-C and 1095-C for employers) may be provided electronically to individuals covered under an expatriate health plan even if the individual has not consented to electronic distribution (as long as the individual has not explicitly refused electronic distribution).
Expatriate health plans will be exempt from the §4980I excise tax on high cost employer-sponsored health coverage (generally referred to as the “Cadillac tax”) that is scheduled to take effect in 2018, except for expatriates assigned to work in the U.S.
These provisions related to expatriate health plans apply to expatriate health plans issued or renewed on or after July 1, 2015.
"Expatriate health plans" are defined as a group health plan or health insurance coverage offered in connection with a group health plan meeting all of the following:
- Substantially all of the primary enrollees are "qualified expatriates" (see below). Primary enrollees do not include individuals who are not U.S. nationals residing in the country of their citizenship;
- Substantially all of the benefits provided by the plan are not excepted benefits (e.g., not limited-scope dental/vision, health FSA, fixed indemnity);
- The plan provides coverage for inpatient hospital services, outpatient facility services, physician services, and emergency services;
- The plan sponsor reasonably believes that the plan’s benefits provide minimum value (i.e., the percentage of the total allowed costs of benefits provided under the plan is no less than 60 percent);
- If the plan provides dependent children coverage, such coverage is available until the adult child turns age 26;
- The plan is administered by an administrator that has licenses to sell insurance in more than two countries, maintains a number of related international standards specified in the law, and offers reimbursement for items or services in the local currency in eight or more countries; and
- The plan satisfies a number of coverage requirements set forth in the Public Health Service Act (PHSA), Internal Revenue Code, and ERISA, other than those added by the ACA (e.g., NMHPA, MHPAEA, WHCRA, Michelle’s law).
This definition includes both fully insured and self-insured plans. Prior transitional relief had applied only to insured expatriate plans.
The "Patient Protection and Affordable Care Act," commonly known as PPACA, was first introduced as a measure to deal with rising healthcare costs and numbers of uninsured.
The heart of PPACA consists of three provisions: guaranteed issue (insurers must offer coverage regardless of the applicant's health status or pre-existing conditions), community rating (insurers must offer policies within a given territory at the same price regardless of health status, age, gender, or other factors), and an individual mandate. The individual mandate assures that everyone has a minimum amount of coverage: those above a certain annual income are required to purchase coverage or incur a tax penalty; those who cannot afford it will have their coverage paid for by the government.
As PPACA continues to be implemented and challenged throughout the country, understanding the issues and implications for the international insurance industry and your business becomes all the more important.
Insurance prices are regulated by the government - you won't find a better price on IMG insurance plans anywhere else.
If you are applying for coverage under the Patriot series of plans, IMG will process your application and send your ID card and other documents within one business day. If you are applying for coverage under the Global or Group series, IMG will process your application within three to four business days following the receipt of all required information, and your materials will be forwarded the same day coverage is approved. Every attempt will be made to process your application timely. The specific time frame depends largely on the type of coverage for which you are applying.
You are eligible for our Global Medical insurance plan if you reside outside of the U.S. or have a good faith intent to reside outside of the U.S. for six months or more in a calendar year. Please note that IMG’s Global Medical Insurance Plan does not meet the definition of “minimum essential coverage” under PPACA. GMI is not intended to provide U.S. citizens residing in the U.S. with health insurance. While your GMI plan for worldwide coverage will not be affected by PPACA, you should review the information below to see if you are exempt from the requirements of PPACA or not, and whether you will have to pay a tax penalty or not. Under PPACA, all U.S. citizens, nationals and resident aliens will be required to purchase minimum essential coverage (PPACA compliant coverage), unless they are exempt. Exempt U.S. citizens include U.S. citizens who reside outside of the U.S. The exemption applies to a U.S. citizen who has a tax home (main place of work or employment, or if you don’t have a main place of work or employment, your main residence) in a foreign country, and is a bona fide resident of a foreign country. See details under the IRS foreign earned income exclusion test. If a person was required to purchase minimum essential coverage and did not, she/he would be required to pay a tax penalty for not purchasing PPACA coverage (if she/he files a U.S. tax return). In many cases, this tax is far less than the premiums that a person would pay for obtaining PPACA coverage.
The information provided above is for general informational purposes only. While we have attempted to provide current, accurate and clearly expressed information, this information is provided "as is" and IMG makes no representations or warranties regarding its accuracy or completeness. The information provided should not be construed as legal or tax advice or as a recommendation of any kind. External users should seek professional advice from their own attorneys and tax advisers with respect to their individual circumstances and needs.