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.
© 2017 KPMG Audit LLC, the Mongolian member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
Flash Alert is an Global Mobility Services publication of KPMG LLPs Washington National Tax practice. The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.