Since 1 January 2016, companies have been required to offer their employees a minimum level of supplementary social protection. By 1 January 2020 they will be required to revise their employment agreements and other documents concerning their employees’ coverage of health costs. Two decrees, dated respectively 11 January 2019 and 31 January 2019, have provided details concerning the “100% health” reform that is included in the law to finance social security for 2019.

A minimum basket of health care provisions will need to provide for enhanced coverage

• Vision: If the policyholder purchases a device that belongs to a category designated as enhanced coverage, the coverage must be at least equal to the value of the policyholder’s contribution (up to the limit of the price set for this category). All other devices must be covered in compliance with the minimums/maximums set by the Social Security Code.

• Hearing aids: The acquisition of hearing aids is covered at 100% if they come under a category designated as enhanced coverage, or up to € 1,700 in other cases.

• Prosthetic dental care: The charges advanced by the policyholder are covered up to the fees limit that is set by the national convention of dental surgeons (“CNCD”).

These provisions apply for contracts entered into or renewed starting from:
– 1 January 2020 for vision and prosthetic dental care (except for exceptions);
– 1 January 2021 for hearing aids.

The mandatory minimum coverage must include the enhanced coverages

From now on, the minimum coverage must provide:
– the coverages imposed on the insurance policies referred to as “contrats responsables” by the Social Security Code (Art. R.871-2);
– a fixed coverage fee for vision expenses that are reimbursed by the health insurance when they do not correlate to a category providing enhanced coverage. This fixed fee must comply with the minimums that vary according to the degree and type of correction of the lenses;
– coverage at the rate of 125% of the base fees of health insurance services for the costs of prosthetic dental care and dentofacial orthopaedic services (for acts other than those referenced above).

Support for companies

The Social Security Department (“DSS”) has explained that tools were put in place in January 2019 intended for employers and unions to assist in bringing the collective bargaining agreements into compliance.

On the social security web portal, a dedicated area summarises the information that will enable companies to come into compliance. A dedicated email address will also enable employers and unions to add to a “frequently asked questions” page that is available to companies.

We are entirely available if you have any further queries about the issues discussed in this newsletter or about any other accounting, tax, social security or law related topic.