European Council Regulation 1408/71 underpins the right of EEA Nationals to work in another EEA State in keeping with the principle of the free movement of labour enshrined in the Treaty of Rome and subsequent treaties.
The free movement of labour can only be realistic if social benefits can also be transferred, including health cover.
Forms are used that act as a certificate of entitlement to health care in another EEA country, provided courtesy of the social security authorities in your home country.
Since May 2010 the previous 'E' Forms have been replaced by 'A' and 'S' Forms.
The forms mean that you will not need to pay French health insurance service contributions for the duration of the period stated on the form.
The main forms that are available to for cross-border workers/self-employed persons are 'A1' and 'S1'. These enable you to take advantage of health arrangements in France whilst maintaining social security contributions in your home country.
Form A1 - Issued to those who are employed or self-employed, working on a temporary basis in another EEA country for one year, renewable for another year.
The A1 form certifies which social security legislation applies to the holder of the form where you, as an employed or self-employed person, have a connection through your employment or self-employment with more than one EU country.
The A1 is issued by the country to whose legislation you are subject and confirms that you are not subject to the legislation of any other country you are connected with – in other words you will have no obligation to pay social security (including health insurance) contributions in the other countries.
Form S1 - Issued to those who are resident in one EU country but work in another. The form is used to obtain health cover where your family lives and is delivered per person, not per family.
The issue of such Forms is not automatic, and each case is judged on its merits. Care must be taken in completing the application form.
Health cover is restricted to that of any other French resident and, therefore, only a proportion of health costs are covered (typically 70%).
The final decision on which form to use (for those from the UK) lies with the HM Revenue and Customs.
We can distinguish two different circumstances:
I. Temporarily Working in UK and Resident in France II. Permanently Working in the UK - Family Resident in France
If you and your family are living in France, but one of you temporarily commutes across the border to the UK to work, then an A1 is normally available for health cover in France for a year, renewable for a further year.
Accordingly, you will continue to pay your national insurance contributions in the UK.
You will be covered for health cover in France through a European Health Insurance Card (EHIC).
Those from the UK can download an A1 application form.
Where one of the spouses permanently works and lives in the UK, whilst the family is resident in France then the form normally used is the S1.
You are eligible to obtain an S1 from HM Revenue and Customs. The form should be presented to your local health authority in France, called the Caisse Primaire d’Assurance Maladie (CPAM).
The postal address for HMRC is:
HMRC, Charity, Assets and Residence, Room BP1301, Benton Park View, Newcastle upon Tyne, NE98 1ZZ
The use of the Form S1 will enable you and your family to obtain continuing medical cover in France.
No health care contributions will be payable in France, as you will pay social security contributions in your home country.
Those from the UK can download an S1 application form.
There are also special rules for civil servants and mariners, and transport workers, which we do not consider here.
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