Prove your right to Puma healthcare levy exemption

With regard to the bills – the first to be sent out since healthcare changes in 2016 – it is likely that you need to supply proof including the period 2016-2017. This means you will need to show proof of having had cover from the UK and not France in these years.

Several readers contacted us with issues surrounding the recent bills for cotisation subsidiaire maladie (also known as a ‘Puma’ cotisation) and so Connexion sought advice from the French Urssafs (bodies charges with recovering the levy) and the UK’s Department for Work and Pensions (DWP).

The first thing to note is that Puma cotisations should not be payable by anyone who is a UK state pensioner, with no connection to French sécurité sociale, and who therefore has their French healthcare paid by the UK under the EU’s reciprocal S1 scheme.

Nor should you pay one of these levies if you are working in France and therefore paying into a French social security caisse via social charge cotisations from work (unless your earnings are very low – see below).

Nor should you pay them if you have healthcare entirely via a comprehensive private policy.

Those who should be paying them include notably early-retirees (with no UK state pension), as long as they are deemed to have ‘income from capital’ over a certain amount (€9,807 in 2017, €9,654 in 2016). Connexion has seen no exhaustive definition of ‘income from capital’ for this purpose, but it appears it is being applied in a broad sense to most incomes apart from ones from work. People to whom this applies can expect to pay the charge at 8% over the ceiling, and this is comparable to the former system called CMU de base.

There is a grey area concerning other people who may be deemed to have any connection with the French system such as a right to a small French pension or having done work of any kind in France. Reportedly some Urssafs may be seeking to apply the ‘no connection rule’ as strictly as possible. However, notably if you are not actually drawing any French pension and the UK is paying for your healthcare via the S1, you may wish to query whether you may not nonetheless be exempt on these grounds.

Finally, Connexion has discovered a possible complication for any UK state pensioners who have been doing occasional part-time self-employed work. This is because the Puma rules state that in order for workers to pay no cotisation they should earn more than 10% of a set annual figure used by the social security system known as the PASS (plafond de la sécurité sociale), which was €39,228 in 2017 and €38,616 in 2016.

The latest round of Puma bills related to cover for 2017 and would have been based on the 2017 income declarations of 2016 income. Hence, workers needed to have annual earnings of 10% x €38,616 in 2016, that is €3,862, in order to pay no Puma charge (unless they were living with a spouse or civil partner who was earning at over this level or who had a French pension or incapacity benefit).

Due to a sliding scale calculation, those with earnings just under this level could expect to pay a cotisation at a much reduced amount while those with only earnings of half of this could expect to pay the full amount.

If you need to prove to your Urssaf that you are (/ were) covered by the UK

• The ideal way is with a copy of your S1 from the DWP. As such it is always recommended that when you are issued with one of these on becoming a UK state pensioner (or recipient of Employment and Support Allowance) you take a copy of it before presenting it to your Cpam to register it with them. S1s include an issue date and a start date on them
• If you do not have one, DWP say they cannot replace them because the forms are generated by their system in an automated way with an issue date and the name of the issuing agent. An alternative may be to request the DWP to issue you a letter saying you have been covered by the UK for your healthcare since such and such a date. The DWP did not confirm to Connexion that they will do this, but one reader reported having received one. The DWP also said French authorities can write to the DWP’s Overseas Healthcare Team if they need such confirmation.
• Acoss, the national body for the Urssafs, said that people could alternatively ask the Cpam to which they gave their S1 for a similar attestation. They added that if you do have a letter from the DWP then it should not have to be translated to French. This is in keeping with an EU rule that says that documents for social security formalities should not need translating if they are in an official EU language.