Interim guidance, expatriate health insurance and expatriate health plans

Interim guidance, expatriate health insurance

The IRS today released an advance version of Notice 2015-43 providing interim guidance with respect to application of provisions of the Affordable Care Act with respect to expatriate health insurance issuers, expatriate health plans, and employers that are plan sponsors of expatriate health plans.

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Notice 2015-43 [PDF 58 KB] states that proposed regulations are expected to be issued to implement and provide guidance for expatriate health plans (generally defined as an insured group health plan for which enrollment is limited to primary insured who reside outside of their home country for at least six months of the plan year and any covered dependents and its associated group health insurance coverage).

Notice 2015-43 requests comments on clarifications that may be needed with respect to definitions of the terms “expatriate health plan” and “qualified expatriate” as well as other guidance. Comments are due no later than 90 days after today, June 30, 2015.

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