Does Foreign insurance Count as Minimum Essential Coverage?

You don't need Minimum Essential Coverage unless you are filing a tax return in the US. There are two criteria that qualify you as having minimal essential coverage (even if you choose to be uninsured) if you are filing in the US, but primarily live abroad:

1. If you spend at least 330 days outside the country, you are exempt. This is called the Physical Presence Test (PPT)
2. If you are considered a bona fide resident in a foreign country for the entire tax year, you are exempt. Many dual citizens who primarily live abroad will be able to or already have established residency in a foreign country. This is called the Bona Fide Resident Test (BFR)

Certain foreign insurance counts as minimum essential coverage if it meets certain criteria.

A self-insured group health plan (like from an employer) is considered minimal essential coverage for the months you are living abroad no matter where the plan is located, so long as it is regulated by the foreign government. It is also considered minimal essential coverage for the months you are in the US if it provides health benefits to you when you are within the US. However, the insurance plan's sponsors or government agency must apply for recognition from Health and Human Services, and that means the insurer should know if they are recognized.

As of September 2016 a number of foreign insurers have been approved:

• Swiss National Health Insurance System
• Bermuda - WellAway Limited
• Canada - Aetna Life Insurance Company (Canadian Branch)
• Guernsey - Cigna Global Insurance Company Limited
• Belgium (Switzerland and Singapore) - Cigna Europe Insurance Company S.A. - N.V.
• Belgium - Life Insurance Company of Europe S.A. - N.V.
• Hong Kong - Worldwide Life Insurance Company Limited

Foreign nationals who live in the United States for a short enough period and usually do not become resident aliens for federal income tax purposes. They are not subject to the individual shared responsibility payment even though they may have to file a U.S. income tax return.

You only owe the fee for months you didn't have coverage but were required to based on the criteria above. However, there are additional options:

• You may also be exempt due to income.
• There is also a three-month coverage gap exemption for up to 3 months in a row without coverage.
• You can also consider applying for a Hardship exemption or Special Enrollment period because of moving so you can get covered through the Marketplace when you'll be in the US.
• Consider Catastrophic insurance if you qualify for a Hardship exemption or are under 30. Especially if you are not planning to be located within a specific coverage network for any length of time, but you still want coverage for emergency and urgent care. Plans must cover emergency care out of network. You also get preventative care before the deductible, so you'll want to consider getting a plan whose network includes your primary care provider or one whose network is near the family or friends you would depend on in a Catastrophic health situation.

Generally, travelers insurance won't count as the minimum essential coverage.

If you have foreign coverage that counts as minimum essential coverage, you probably won't be eligible for cost assistance on Marketplace plans.

On that same note, if you are required to get coverage, but don't have access to the minimum essential coverage, you can use the Marketplace and be eligible for cost assistance.

Feel free to call HealthCare.Gov for more information:

Call to start or finish an application, compare plans, enroll or ask a question.

1-800-318-2596
TTY: 1-855-889-4325

Available 24 hours a day, 7 days a week. Closed Memorial Day, July 4th, and Labor Day.

You can also see the IRS Q&A on the mandate for more information.

You can also find more information on minimum essential coverage in Publication 974 Premium Tax Credit (PTC)