An American, with Irish citizenship, has questions re health care

[Gigi]

I hope someone with experience similar to ours can point us in the right direction.  We are Americans and my husband is obtaining Irish citizenship because his grandmother was born in Northern Ireland.  My husband is 68, retired and the state of his health is such that pre-existing conditions make him uninsurable. We believe that he would not be allowed to emigrate to France as an American because of diabetes and other illnesses, but we also believe that as a citizen of Ireland (E.U.) he can legally live in France.  Question #1: is that correct?

Question #2 is about his access to health care in France.  I read the FACs above about health care for British citizens and learned that having paid into the British system is required for the to obtain full care in France.  But we will not have paid into the Irish system.  Does anyone know what is involved when an Irish citizen moves to France? 

Question #3: can anyone refer me to an individual or business that can give me trustworthy, reliable information regarding this matter?

Thank you -- merci!

Gigi

 

 

 

[Gigi]

Adding to my own questions, I found this: "Si vous êtes de nationalité étrangère, vous devez en outre être en situation régulière en matière de séjour des étrangers en France" at this website: http://vosdroits.service-public.fr/particuliers/F1072.xhtml

A computer translation tells me it means: "If you are foreign nationality, you have in addition to be in uniform position regarding stay of the foreigners in France." 

What exactly does "being in a uniform position regarding stay of the foreigners in France" mean?  Sounds like Catch 22!

Gigi

 

 

[Will]

The situation as I understand it is as follows (I am sure somebody will correct me if I have got it wrong).

You, as an American citizen, will need to apply for 'titre de séjour' from your préfecture if you stay in France for three months or more. Part of this application includes proof that you can support yourself and you have health cover. You may be eligible to take out private health insurance, or you may not, depending on your situation. If not, and most people are not, you will be expected to pay into the French health system, and this will entitle you to partial refund of medical costs - typically 65% to 70% but can be considerably less in some cases. You can take out a complémentaire, or 'top-up', insurance to make up the shortfall. This will put you in a 'uniform position to other foreign nationals in France' - indeed the same position as most French residents - which I think is the requirement that the extract quoted above refers to.

Your partner, if he has Irish citizenship, is not legally required to obtain titre de séjour. However Northern Ireland is part of the United Kingdom rather than the Irish Republic. European citizens can gain access to the French health service via European social security insurance forms, also called E-forms. These are issued by your home country. The most common ones are E121, which covers those in receipt of state pensions, such as retirement pension, and E106, basically for non-working people below state retirement age. Issue of either of these depends, for most EU states, on your having contributed to the home state's health scheme - your partner may not be eligible if he has not made enough contributions. In that case, he should take proof of non-entitlement (e.g. a letter from the home social security authority) to the local CPAM (caisse primaire d'assurance maladie) office, together with proof of identity, address, income, copies of birth, marriage etc certificates (you will both need supporting documentation like this) in order to be enrolled into the system. Again, he will probably be required to contribute, depending on income, and will, like you, receive the same percentage of costs as any French resident. Although his conditions may, subject to medical recommendation and CPAM approval, be eligible for 100% cover (but only for the notified conditions).

I hope this gives some insight. There is an English-speaking CPAM helpline on +33 (0)820 904 212. You could also refer to Peter Owen at www.expathealthdirect.co.uk although I believe he deals mainly with British people in France.

[Iceni]

Gigi - My limited understanding of the French system indicates that if you have not paid anything IN to any EU health system you will have trouble taking money and services OUT. "Health migrants" seem to be unwelcome with the citizens of most countries so I fear that you will gain little support on this side of the Atlantic.

John

not

 

[Hirondelle]

If his grandmother is from Northern Ireland, your husband will be British NOT Irish. As such he can legally live (and work should he want to)  in France without applying for a titre de sejour but you as an American would still be obligated to the usual procedures regarding non-EU nationals.

[Babnik]

Being Irish or British makes no difference...both EU countries!

[Hirondelle]

I know that...I was just saying. Wouldn't want them to think there'd been a mistake when they wound up with the "wrong "nationality!

[Ron Avery]

It would if you applied to Newcastle instead of Dublin or vice versa for an E form for your Healthcover it would make a difference though.

[Tourangelle]

I thought that people in N.Ireland could have either Irish OR British

nationality, as part of the Good Friday agreement, but I am not 100%

sure on this, I remember reading something like it at the time.

[Gigi]

Actually, my husband might be able to claim British citizenship (we haven't looked into that) but we know for a fact that he can obtain Irish citizenship because we're in the process of doing that.  Because the Republic considers the northern counties to be part of Ireland they extend Irish citizenship to children and grandchildren of emigrants born in the North.  Originally we thought about living in Ireland, but because it's such a small country the level of health care available there isn't up to my husband's potential needs.  For that reason, and because we love France, we are now looking into moving to France -- which has the best health care system in the world.

Perhaps I should reiterate, what I am really hoping to find is the name of a business or consultant who knows how to wade through the bureaucracy and can give us information we can really trust enough to make plans around.  I appreciate everyone's help, but we need help to learn the facts.

Thanks again,

Gigi

 

 

[Will]

I suggest you try the helpline number and Peter Owen, as in my post above.

[Kate Campbell]

Can I just say, that Irish citizenship was not  "offered" as part of the Good Friday Agreement, as it was always a right to people who were born in the whole of Ireland and this includes North and South.

People born prior to 1922 in the 32 counties of Ireland presently bestow the right to immediate family to hold an Irish passport but not necessarily citizenship.

Please note that I am not making any political statement here but merely stating facts.

 

 

[Domi]

re: European citizens can gain access to the French health service via European social security insurance forms, also called E-forms. These are issued by your home country. ..... and E106, basically for non-working people below state retirement age.

Just to clarify that this does not apply to Irish citizens and residents.  Healthcare in Ireland is based on residency and not on the payment of contributions. A medical card which entitles holders to free visits to GP, medicines, etc, is issued to people on a very low income and to people over 70 (or 75, can't remember).

Hospital stays and surgery is basically free. However there are huge waiting lists such as, up to three years for a bypass.

E106 is issued to civil servants or employees posted abroad for periods of up to one year.

I think the E121 is issued on the same basis as the UK, ie, being in receipt of an Irish pension.

When I enquired in Ireland, I was told to use my E111/European Health Card until I was affiliated to the French Securite Sociale. This is a bit of an Irish solution to an Irish problem ....

Dominique

 

 

 

 

 

[Lori]

Not sure if this helps.  I am American (arrived with a long term

Shengen (sp?) VISA) and I have to PROVE I have health cover each year

when renewing my Carte de Sejour (which is a requirement for me). 

I have to sign a document stating I have cover and provide copies of

the policy (every year).  It isn't a problem as we do have

worldwide health coverage.  I also have to sign a document stating

that I will not apply for work here.  After 5 years (and this is

my fifth), I can apply for a different type of residency card if I wish

to work.  That is how it works for me.  Seeing that there is

some question as to whether the person will be arriving as a U.S.

citizen or an EU citizen, I'm not sure this info. is relevant.

[Gigi]

Thanks, Lori.  It's relevant for me, if not for my husband.  Do you buy a special Worldwide health insurance policy, or simply rely on an American policy, such as one from Blue Cross? 

Also, where are you living in France?  Do you know of any person whose profession is smoothing the way through the bureaucracy for Americans?

Thank you again,

Gigi

 

[Gigi]

Will,

I communicated with Peter Owen several years ago about this.  He is the source of much of my information.  It is he who told me my husband's "pre-existing conditions" cannot be insured.  That is one reason we pursued Irish citizenship for my husband, thinking that might be a way around the health care requirement.  It seems that EU citizenship allows one to live in another EU country, but does not provide all the benefits of life there.  As an American, I'm tempted to think of it as being like moving from one U.S. state to another, but I've been reminded it really still is moving from one country to another.

Incidentally, yesterday I went to the website of the UK embassy in the U.S. to try to learn whether having a UK-born grandparent makes one eligble for UK citizenship.  Not only is the information not on their website, but they use an "out-sourced" agency to answer all questions from the public -- at the rate of $2.10 (about one pound fifty) per minute!  They've obviously aclimated well to life in America!

Gigi

[Pangur]

This is cheaper than their phoneline, but no good news...

http://www.britishhighcommission.gov.uk/servlet/Front?pagename=OpenMarket/Xcelerate/ShowPage&c=Page&cid=1109171564665

 

 

 

 

[Gigi]

Thanks for finding that.  It's just the way I thought it was.  I think Ireland is uniquely generous with its citizenship offer, because of its history, but even that may change one day.

Gigi

[Lori]

Do you buy a special Worldwide health insurance policy, or simply rely on an American policy, such as one from Blue Cross?

Gigi:  We have done both.  Our situation is a bit complicated

as my husband works all over the world.  Depending upon where his

assignment is will determine what type of health coverage we use. 

We (wife and child) remain in France all the time.

We have purchased a policy through MultiNational Underwriteres -

Lloyd's Coverholder through their office in the U.S.  However, I

must say that we opted for health coverage in ANY part of the world

EXCEPT the U.S.A.  It dropped our coverage cost by half.  We

had family coverage with them - two adults (husband and wife) and one

child.  You can still get coverage with pre-existing conditions,

but you would want to read that part of the policy very closely to see

how it affects you.  We paid far less than 3000 U.S. dollars for

an annual family policy.  We did choose a 1000 U.S. dollar

deductible as we are pretty health folks.  This kept our cost

down. 

We no longer use this policy - (as of last year) as my husband's work

assignment changed and we now have worldwide coverage, including U.S.

coverage.  Cost a good bit more than the other policy we had, but

though he works for the same company, the country he is located in can

determine what type of coverage best suits us (never working in

France)....  A bit complicated.

If you would like to contact MultiNational to inquire about what they

offer, you can email them at [email protected]  or telephone them

in the States at  317-262-2132  (Indianapolis, IN).  The

policy we had was called  International Citizen Plan.

As far as fellow Americans working here.  I know of several, but

each ones situation is quite different from the other.  Most of

them have lived here for quite some time and are well into the

"system."   As I live in South-eastern France, 30 minutes

from Avignon, there is not a huge lot of work available here,

particularly if you are not fairly fluent in French.  I expect

larger cities would offer more opportunity.  Several of the

Americans I know have their own businesses.  If you wish to do

this, be sure to inquire about all the licensing fees involved in

opening and operating  your own business.  Having said all

that, I wouldn't want to be discouraging.  If you wish to look for

work, I would recommend you take a good amount of time researching the

climate (economic, etc.) in the area you wish to live, particularly

relating to the type of work in which you hope to find..  And, be

sure to do your best to understand the legal requirements of life and

work here.  That isn't always easy info. to obtain, but if you

speak some French, you can do it.  I highly recommend doing it

BEFORE you arrive.

 Hope that helps you.  Best of luck.

Lori

[mascamps.com]

There are two separate aspects to this:

1. The nationality.

British nationality law states that if you are born in a Commonwealth country (which America is not) and have a grandparent born in what was then the UK (which would include all of the island of Ireland pre-1922) then you can get a British passport by descent. Your husband is not entitled to this as he wasn't born in a Commonwealth country. For the benefit of others that may read this thread, the cost is around £600. This gets you an Ancestry Visa (ie lets you into the UK) but you need to live in the UK for five years before getting the passport.

Irish law states that if you are born in Ireland (pre-1922 that included the whole island which, of course, would then have been British too)then you are Irish (people living in Northern Ireland have the right to be "considered Irish" as per the Good Friday agreement if they wish). If you are born abroad to a parent born in Ireland (and again NI is a special case) you are Irish. In both cases you just apply for an Irish passport. If you are born abroad but have a grandparent born in Ireland (technically this only includes the whole island before 1922 but again NI is a special case) you can apply for Foreign Birth Registration (cost: 120€ or so) which gets you Irish citizenship (takes about 2 years) and after you've got that you can apply for an Irish passport. Note that obtaining Irish citizenship in this way only confers Irish citizenship on children born after the FBR.

2. Moving to France (or other European countries)

As your husband will be Irish when you are moving, you do not need to apply for a visa because you will then be the spouse of a European citizen and aren't a "visa national" (ie you don't need a visa to come to France). Within 90 days of arriving you need to apply for a Carte de Sejour Europeenne which is a non-descretionary (ie they can't refuse to give it to you) residence permit which, under European law, they must provide within 3 months (although, being France, it usually takes much longer). This gives you (and your children, their children, etc. and your parents, their parents, etc. regardless of their nationality) the right to live and work in France immediately. It is free and the only documents that they are allowed to ask for are 1) proof of ID (ie passport) and 2) proof of relationship (ie your marriage certificate).

Ref: http://europa.eu.int/youreurope/nav/en/citizens/factsheets/fr/residencerights/retired/en.html (an excellent source for information)

3. The health issue

You won't be able to take advantage of any of the "e" forms mentioned as they all require you to have paid social security contributions in another European country to take advantage of them and, of course, you haven't.

However, under European law, they also can't refuse you cover. Forget about those "international" health care plans as they will cost you an absolute fortune; just sign up for the CPAM service in France which, as an Irish citizen, both your husband and all his dependents (ie you plus children under 21 plus, potentially, your parents) are entitled to do. The cost for our entire family is under $500 so it would be less than that for the two of you (I don't think that there's an age weighting); this covers 70% of the cost of out-patient care (you can pay into a "mutuelle" to cover the other 30% if you wish) and, usually, all/most (at least 70%) of hospital cover.

 

Re the health care issue in NI: it may be a small place but it has "too many" hospitals which has the net effect that waiting lists are much shorter than in the rest of the UK. My cousin is also diabetic and recently received a kidney transplant there.

To be absolutely sure of getting a fair deal in France, the best way to make the move is to move temporarily to the UK and register with a doctor there (free) which will get you some of the documents that the French will be looking for. You can also get a residence permit there (I have one for Wendy) which is also free. In some cases, the European law is only applicable if you are moving from one European country to another one and starting off in the UK would then get you into this category.

 

Arnold

(dual nationality: British & Irish with one child who is triple nationality: British, Irish, Australian and another with quadruple nationality: British, Irish, Australian and French with, laughably, a UK residence permit as well [obtained to let Wendy, an Australian, to live there])

[Gigi]

Arnold, thanks very much for your excellent information.  It's obvious you've been through this once or twice!

You wrote:

However, under European law, they also can't refuse you cover. Forget about those "international" health care plans as they will cost you an absolute fortune; just sign up for the CPAM service in France which, as an Irish citizen, both your husband and all his dependents (ie you plus children under 21 plus, potentially, your parents) are entitled to do. The cost for our entire family is under $500 so it would be less than that for the two of you (I don't think that there's an age weighting); this covers 70% of the cost of out-patient care (you can pay into a "mutuelle" to cover the other 30% if you wish) and, usually, all/most (at least 70%) of hospital cover.

What is CPAM service?  This is the first time I've heard of it.  What do the letters stand for?  How can I learn more about it?

Thank you again,

Gigi

 

[mascamps.com]

Only 1 1/2 times so far :)

Bit more background... The French state health system is divided into three parts. 1) for self-employted people and similar 2) for farmers and 3) for everyone else (ie employed, retired, etc.). CPAM is the government department that deals with those in the third group (no idea what it stands for).

I thought some more about the issue this afternoon and if I were you, I would definitely live for a while in the UK simply to get into the health system (if you're over 65 you'll be outside the scope of the social security system). That has the benefit for you that you are then a European citizen who is moving countries within Europe when you move from the UK to France (which is definitely not as easy as moving from California to Oregon!). It also has the advantage that it will give you a bit of time to get used to a European style health system in English before you need to work out simultaneously a) how a European system works and b) ask for things in French.

One thing that probably isn't obvious to you is that the normal state health systems in Europe are quite good and, in general, people don't opt for private health insurance. This has two consequences: 1) there are relatively few private hospitals in Europe (as compared to the US); only one in Northern Ireland for instance and 2) private hospitals in Europe are rarely "full service" eg they do not provide emergency treatment in general and overall would not provide as complete a service as a state owned  hospital. As far as I know, private insurance in the UK does not cover diabetic conditions for instance, mainly (I think) because private hospitals don't, in general, treat things like that.

There is probably loads of time for you to plan this out as it takes about 2 years for a FBR application to work through the system.

We have had quite a few people who've stayed with us and bought houses here so we ran up a little guide to how to go about it which is now at : www.personallychosen.com/livinginfrance . Mainly aimed at brits moving to France but it should answer some more of your questions that you've not asked here yet.

 

Arnold