"The issue of principal concern is whether an expatriate continues to be subject to health care reform while working outside the U.S.... Another key issue is whether foreign nationals sent to work in the U.S. are subject to health care reform's requirements. Although the Departments have issued some guidance in this area (including an expatriate health plan FAQ and a summary of benefits and coverage (SBC) compliance FAQ), it is not enough to allow companies to fully address their obligations under health care reform when they send employees on international assignment."

MORE >>