“Although the exemption is extensive, expatriate plans must continue to meet certain ACA requirements,” said Brian Pinheiro, Chair of Ballard Spahr’s Business and Finance Department and the Practice Leader of the firm’s Employee Benefits and Executive Compensation Group. “For example, the employer mandate continues to apply, but the coverage provided by an expatriate plan will be deemed to be minimum essential coverage for purposes of complying with the mandate (and for purposes of the individual mandate). Reporting requirements relating to the employer and individual mandates will apply, although electronic distribution of applicable forms will be permitted without participant consent.”

Related Practices

Business and Finance
Employee Benefits and Executive Compensation