Under the new rules, it is mandatory for all expats and visitors to Dubai to hold basic compliant health insurance in order to be issued with a visa, and in addition all insurance products need to be regulated by the Dubai Health Authority (DHA). Products will need to at least match mandatory benefits such as maternity coverage and non-exclusion of pre-existing conditions.

Spouse and dependents will also need to be covered by the employer or the employee themselves before a visa is granted. The Dubai government will provide health insurance cover to local nationals.

James Spencer, international corporate benefits manager for Jelf International, said: ‘There are already a number of fully compliant iPMI providers on the market as well as many local companies providing cover, so employers should take care to select a health insurance provider that meets their own as well as their employees’ requirements. Consideration needs to be given to whether you intend to meet or go beyond the basic legal requirements.’

Timeline

The new legislation was passed in 2013 but the following dates relate to the implementation of the law:

  • 31 October 2014: companies with 1,000 employees
  • 31 July 2015: companies with 100-999 employees
  • 30 June 2016: companies with <100 employees
  • 30 June 2016: dependents of sponsors including employed domestic workers (cleaners, housekeeping staff)

If employers are growing and expecting to hire further staff during this period, taking them to the next eligible category, they should implement a compliant health insurance policy before taking on further employees. Failure to do so could be regarded as a breach by the DHA under Law no 11 of 2013.

Specific employer obligations regarding PMI for employees:

  • Employers must bear the cost
  • There must be no self-funded schemes, all PMI policies must be fully insured
  • Verify that the insurance is valid for the length of the employee’s work period
  • Bear the costs in medical emergencies for any of the employees if any of them has no health insurance (which could result in further costs that were not anticipated )
  • Provide a health insurance card for all employees

Spencer concluded: ‘The penalties for non-compliance include fines, the obvious inability to physically relocate staff in to the country and potentially the cessation of business practice, all of which are seriously disruptive to any company. However, while these measures may feel like red tape, they will also have benefits for the employer who will be better able to maintain a healthy and productive workforce. While the deadlines impact those employers with largest workforces first, our advice is to ensure that the existing policy (irrespective of how many employees are covered) is fully compliant at the earliest opportunity.’

The DHA has also released a circular reaffirming its position that once a breach of the law is identified (such as employers not meeting enrolment deadlines to have insurance in place for employees) any fines that may be imposed will be backdated to the date at which the breach occurred. The 18 November circular also states that the fines have been set at levels that will outweigh any benefits that may accrue by not complying with the law.

For more information on the new legislation in Dubai, and Jelf Employee Benefits’ view on the legislation and healthcare in the Emirates please click here.