Following enactment of the Affordable Care Act (ACA) in 2010, there was considerable uncertainty about how the law applied to employees covered under expatriate health plans (for example, how the ACA applies to expatriates employed by a company who are sent on assignment to work abroad). In response to these questions, the Expatriate Health Coverage Clarification Act of 2014 (EHCCA), enacted in December 2014, provided an exemption from many ACA requirements for expatriate health plans. In 2015, the IRS issued initial guidance to implement EHCCA.

To learn more about how the ACA and EHCCA apply to expatriate plans, see Practice Note, Expatriate Health Plans under the ACA and EHCCA.