This GMS Flash Alert reports that since 31 May 2016, insurance companies have been obliged to apply new voluntary medical insurance certificate issuance rules to foreign nationals working or planning to work in Russia with a work permit or a patent.
Since 31 May 2016, insurance companies have been obliged to apply new voluntary medical insurance certificate (“VMI”) issuance rules to foreign nationals working or planning to work in Russia with a work permit or a patent.1
Some insurance companies may be issuing VMIs that have less of a validity period than is allowed under Highly Qualified Specialist or “key personnel” work permits, which can be valid up to three years. If this is the case, immigration authorities may issue a work permit whose validity period coincides with the VMI validity period but not necessarily for the requested period. Compliance is key to assuring the foreign national meets his or her employment-related obligations under Russian law and is able to work in Russia.
Employers should check in advance that the medical insurance obligations of their foreign national employees coming to Russia to work under a work permit or patent are properly met.
The rules, established by a Central Bank of Russia decree (hereinafter “the CB Decree”), set forth the following minimum requirements:
— An insurance company’s VMI programme for foreign national employees must guarantee the provision of primary health care and specialised medical care in case of emergency;
— The validity period of the VMI contract and certificate is to be determined by the expected validity period of the foreign national’s work permit or patent;
— The minimum insurance coverage for the validity period of the VMI contract has been established at RUB 100,000 for each insured person.
Currently, only a few insurance companies in Russia issue VMI contracts and certificates with a validity period of three years, which is relevant in cases concerning those who have applied for Highly Qualified Specialist or “key personnel” work permits.
It is recommended, therefore, that you confirm with your insurance company the maximum validity period of their VMI programmes for foreign national employees, and consider the option of changing providers, if applicable.
In addition to this, we would like to remind employers that they should stipulate information about VMI contracts and certificates, along with the conditions of providing medical care, in writing in employment contracts and addenda with foreign employees for the entire period of their employment with the company.
1 These new requirements are stipulated in the Central Bank of Russia’s Decree of 13 September 2015, No. 3793-U “On the minimum (standard) requirements on the terms and processing of VMI provision to foreign citizens and stateless persons staying in Russia for the purpose of work” (hereinafter, “the CB Decree”).
For further information or assistance, please contact your local KPMG Global Mobility Services (GMS) or People Services professional*, or one of the following professionals with the KPMG International member firm in Russia:
Tel. +7 (495) 937 44 77 (ext. 12987)
Tel. +7 (495) 937 44 77 (ext. 14214)
* Please note KPMG LLP (U.S.) does not offer immigration services.
The information contained in this newsletter was submitted by the KPMG International member firm in Russia.
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