As employers continue to overhaul their health care plans to comply with the Affordable Care Act, they should keep in mind that ACA rules don't only apply to domestic employees. Today’s employers increasingly rely on a global workforce, and some ACA rules apply to employees working abroad. Similarly, ACA rules also apply to foreign nationals working in the U.S., and if an employer is negligent in ensuring compliance for its expatriate workers, it could lead to costly penalties.

In compliance with the ACA’s individual mandate, carrying minimal essential coverage is required even for most expats working abroad. This provision is satisfied by enrolling in eligible employer plans (including grandfathered plans), government-sponsored programs and individual market plans.

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