Dual US/German citizen - health insurance retirement question

Go Back   Expat Forum For People Moving Overseas And Living Abroad > Europe > Germany Expat Forum for Expats Living in Germany

Germany Expat Forum for Expats Living in Germany Have you made Germany your new home? Are you thinking about making Germany your new country of residence? If you want meet like minded Expats living in Germany then you have come to the right place.

Dual US/German citizen - health insurance retirement question


Reply
 
Subscribe to this Thread Thread Tools
  #1 (permalink)  
Old 25th July 2019, 07:45 PM
New Member
 
Join Date: Jul 2019
Posts: 16
Rep Power: 0
Rixlari is on a distinguished road

Default Dual US/German citizen - health insurance retirement question

My husband and I are hoping to retire to Europe in the next few years. Were both US Citizens, but I was able to get German citizenship through my father. Ive always lived and worked in the US, never in Germany. We currently live in very costly Los Angeles but hope to find somewhere cheaper to live in retirement so that our money goes further. Im 61 and my husband is 59.

Health insurance is a big concern. I understand we can pay for private health insurance. If we retire to Germany would we be able to access the public health system to save some money. Would there be any age limitations or pre-existing condition concerns if we do? Thanks!

Reply With Quote Quick reply to this message
  #2 (permalink)  
Old 27th July 2019, 04:07 AM
Moderator
 
Join Date: Oct 2011
Location: Austria
Posts: 5,404
Rep Power: 442
kaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond repute
1791 likes received
771 likes given

Users Flag! Originally from australia. Users Flag! Expat in austria.
Default

Quote:
Originally Posted by Rixlari View Post
My husband and I are hoping to retire to Europe in the next few years. We’re both US Citizens, but I was able to get German citizenship through my father. I’ve always lived and worked in the US, never in Germany. We currently live in very costly Los Angeles but hope to find somewhere cheaper to live in retirement so that our money goes further. I’m 61 and my husband is 59.

Health insurance is a big concern. I understand we can pay for private health insurance. If we retire to Germany would we be able to access the public health system to save some money. Would there be any age limitations or pre-existing condition concerns if we do? Thanks!
My understanding is that if you're over 55 you can't automatically get public health insurance, unless you are a German Citizen and have worked in Germany in the past (maybe pre-2009? Can't remember).

Same for Non-German, and even if you have worked there years ago, that must have been for over 12 months, and there are some other awkward conditions too, such as having continuous cover since that point.

So you're left with about 3 options.

1. Get private insurance if you're fairly healthy, without significant major pre-existing conditions - look around and find the best policy - often an insurance broker can help with this. May not be much more than public cost, and may have better cover and actually be better overall value - if you have no serious pre-existing conditions.

2. If you have pre-existing conditions, private cover will often be very expensive indeed, even if you can get it. But, there is a level of protection for people with health issues that private insurers can't actually deny, although some may try. They are obliged to offer you the "Basistarif" - comprehensive but average-level cover to anyone, and they can't exclude you due to ANY pre-existing conditions.

You may need the support of a free independent adviser (but probably not a broker) to get this, but really it should be possible. Trouble is, the Basistarif is about 700 Euros per month per person, so if both couldn't get ordinary public cover, a couple will pay 1400 Euros a month. Ouch!

3. The remaining option might be to go and live in another EU country, join their health system and after at least 12 months in that country, you could move to Germany and transfer into the normal German public health insurance as you are transferring from another EU country's public health system.

These other countries will often require you have full private health insurance for at least a few months, until you become eligible to become a resident, and join their public health scheme.

Since one of you has EU citizenship, you could live in say France, Ireland, Austria and maybe a few others - countries where you can become a resident and get public health cover, then move and transfer later to Germany.

After much investigation on the net, and paying a little in fees to a professional advisor/broker in Germany that made enquiries on our behalf with a "friendly" krankenkasse that they often work with, this information seems to be confirmed. However, I'm always a bit conservative and careful, so when we arrive in Germany one of the first things we'll do is check with a free independent advisor to confirm it all: https://www.patientenberatung.de/de

We're planning to do this in a few months time - our house here in Australia is on the market so we should be in Germany before Christmas.

My German wife can rejoin the public system, but I can't, (annoys me as Australia lets Germans of any age join our public system, and we've always been in that, and been privately insured too!) so we'll go to Germany, but only for a few weeks, then to Austria and rent a place there for perhaps 18 months, then move to Germany permanently. Anyone can join the Austrian public system but there is no cover for the first 6 months.

When we go back to Germany after that, we will transfer into the German public system from another EU country's public system, having been in that system for at least 12 months - all good!


Last edited by kaju; 27th July 2019 at 05:06 AM.
Reply With Quote Quick reply to this message
  #3 (permalink)  
Old 27th July 2019, 08:43 PM
New Member
 
Join Date: Jul 2019
Posts: 16
Rep Power: 0
Rixlari is on a distinguished road

Default

Thank you very much! This is very helpful! So it sounds like we could live in France for three months and then apply through PUMA for French public health. After a year we could move to Germany and the public health would transfer and allow us to be covered by German public health? Would France have to issue us an S1 form or EHIC card in order to do this? Would France continue to pay for our healthcare and reimburse Germany for our expenses even though we aren't French citizens and only lived there a year? If it can work that way, I'm all for it.

Reply With Quote Quick reply to this message
Sponsored Links
Advertisement
 
  #4 (permalink)  
Old 27th July 2019, 09:23 PM
Bevdeforges's Avatar
Super Moderator
 
Join Date: Nov 2007
Location: deepest, darkest Essonne
Posts: 45,974
Rep Power: 23261
Bevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond repute
9589 likes received
1273 likes given

Users Flag! Originally from usa. Users Flag! Expat in france.
Default

I don't think it works that way here in France. In France, you can indeed enroll in the public health care system after establishing your residence in France - however, if you are retired and receiving a pension (US SS, for instance) you won't have to pay for the national health care system.

The "catch" is that in France, the national system only covers a part of your health care expenses. You're expected to then purchase a "top up" insurance, called a "mutuelle" that pays the remainder of the health care charges, depending on what level of policy you buy and pay for.

I don't believe that you can get an S1 to automatically transfer to German (or any other EU country) health care system. Each national program has its own requirements (and levels of cover) depending on your level and sources of income. It's a relatively recent development here in France that they have extended coverage in the national system to just about all retirees receiving a pension and I believe that provision is unique to France. It might be possible to transfer coverage to another EU country if you were drawing a French pension, though I'm not sure of that. That is based on the idea that you "pay for" your health cover in the years while you work.

Reply With Quote Quick reply to this message
  #5 (permalink)  
Old 28th July 2019, 03:13 AM
Moderator
 
Join Date: Oct 2011
Location: Austria
Posts: 5,404
Rep Power: 442
kaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond repute
1791 likes received
771 likes given

Users Flag! Originally from australia. Users Flag! Expat in austria.
Default

Quote:
Originally Posted by Rixlari View Post
Thank you very much! This is very helpful! So it sounds like we could live in France for three months and then apply through PUMA for French public health. After a year we could move to Germany and the public health would transfer and allow us to be covered by German public health? Would France have to issue us an S1 form or EHIC card in order to do this? Would France continue to pay for our healthcare and reimburse Germany for our expenses even though we aren't French citizens and only lived there a year? If it can work that way, I'm all for it.
I don't think an S1 form or EHIC Card would be acceptable. A German krankenkasse would want to see evidence that you had public health cover in another EU country for at least 12 months continuously in the last 5 years. I suspect that often, your health insurance membership card will be enough for the gaining krankenkasse to confirm your membership of over 12 months.

Once you join the German system your contributions go to Germany, and Germany pays your claims, there is no involvement for France - you leave the French system when you go to Germany and enter the German system.

Reply With Quote Quick reply to this message
  #6 (permalink)  
Old 28th July 2019, 04:13 AM
Moderator
 
Join Date: Oct 2011
Location: Austria
Posts: 5,404
Rep Power: 442
kaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond repute
1791 likes received
771 likes given

Users Flag! Originally from australia. Users Flag! Expat in austria.
Default

Quote:
Originally Posted by Bevdeforges View Post
I don't think it works that way here in France. In France, you can indeed enroll in the public health care system after establishing your residence in France - however, if you are retired and receiving a pension (US SS, for instance) you won't have to pay for the national health care system.

The "catch" is that in France, the national system only covers a part of your health care expenses. You're expected to then purchase a "top up" insurance, called a "mutuelle" that pays the remainder of the health care charges, depending on what level of policy you buy and pay for.

I don't believe that you can get an S1 to automatically transfer to German (or any other EU country) health care system. Each national program has its own requirements (and levels of cover) depending on your level and sources of income. It's a relatively recent development here in France that they have extended coverage in the national system to just about all retirees receiving a pension and I believe that provision is unique to France. It might be possible to transfer coverage to another EU country if you were drawing a French pension, though I'm not sure of that. That is based on the idea that you "pay for" your health cover in the years while you work.
The pre-requisite to register in a "new to you" EU country's public health insurance as an incoming former EU resident is that you must have been in your original EU country's public health system for 12 months continuously in the last 2 years, or 24 months not necessarily continuously in the last 5 years. The requirement does not depend on whether you hold any mutuelles, or whether you have to pay for public health cover or not, simply that you were covered under the basic public health insurance for your original country.

You can't transfer anything in this situation, you lose entitlement to anything from France as you are simply moving from one country's public health insurance system to another's as you are becoming a resident in your new country. Once you change countries (after being in the French health system for a provable 12 month minimum) you would leave the French system and start in the German system.

Some EU countries public health systems are more difficult to get into for some people, even with EU partners.

So, the system in the EU country that you're planning to use to get into the EU system must actually let you join that system first, of course. You couldn't join the German system for 12 months to transfer to another EU country's system, because Germany wouldn't let you join to start with, if you see what I mean! What you need is an EU country that permits universal public health fund membership with conditions that you can meet. France seems to be ok, as you should be able to join, the other obvious countries are Ireland and Austria which both make it simple to join their public health systems.

For Rixlari:

Actually, since you have German Citizenship but have never worked/lived/been in their health system, you do have grounds for them to let you join - but your husband does not. So you could simply roll up in Germany and join. Although oddly enough, you couldn't join the German public system on this basis if you have ever been self-employed or freelance in the country you grew up in.

Your husband however, could not join, as he's not German. He could probably be added onto your insurance as your dependent if his income was less than about 425E a month, otherwise, it would be private insurance, or the Basistarif for him - unless he/both of you have been a member of another EU public health system for 12 months. If you join German private health insurance at all, you forfeit your right to join the German public health system.

The German requirement is actually fairly straightforward: https://www.sozialgesetzbuch-sgb.de/sgbv/9.html

and https://www.sozialgesetzbuch-sgb.de/sgbv/5.html (see number 13)


Public health systems do vary significantly from one EU country to another. But the common thread is that someone who has been covered for at least 12 months (in the last 2 years) by one EU country's public health system can (subject to the normal requirements for entry to that new system) move into another EU country's health system.

It is absolutely imperative to apply in Germany within 3 months of registering your residence - after that point, the public health system is not compelled to insure you, even if you have 12 months in another EU country's public health system.

The really important thing to remember is that you can't live in Germany without either public or private health cover.

Rather than rely on information posted by me or others, or from single sources, for your own safety, I'd be inclined to investigate more until you are absolutely sure of your situation.

This may also include getting professional-level advice from a versicherungsberator or two - they may not be willing or able to advise you much as they may mostly deal with private health insurance, but they may help you find out about and even register for public cover for a fee. Or if you both agree that can't be done, they might be able to get you into the Basistarif with a reluctant krankenkasse, or find good private health insurance, for a fee of a few to several hundred euros, or they may able to direct you to someone else.

The link I provided to free public support in my first post may also provide help and confirmatory evidence of what would be acceptable for your situation, but you might have to be there to get that support.

I would caution too that there may be significant and far-reaching changes to the German health insurance system over the next few years - if you are not planning to arrive in the quite near future, requirements may well change. There have been strong political rumblings about this for some time in Germany now - the SPD in particular want the health system changed to become more universal. However, their support nationally is not what it used to be. Then again, maybe a deal will be done with the CDU (who they don't really like too much at the moment) which may include this, so that the CDU can try and retain power. Who knows, especially after Merkel goes and AKK holds the reins?

Given freedom of movement is an essential right for EU Citizens, I don't see that the ability to change countries and transfer to a new public health insurance system will change, but the necessary requirements to join your first EU country's system might!

In most countries, the rules sometimes change (often very significantly) over several years. Things may become harder or easier for your particular circumstances, and indeed your circumstances can change over time too! So if you're planning to move say in a few years, sure, get a feel for the requirements now, but check again closer to the time of your proposed move too.


Last edited by kaju; 28th July 2019 at 09:57 AM.
Reply With Quote Quick reply to this message
  #7 (permalink)  
Old 28th July 2019, 08:59 AM
Moderator
 
Join Date: Jan 2012
Location: Berlin
Posts: 1,530
Rep Power: 281
ALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond reputeALKB has a reputation beyond repute
288 likes received
152 likes given

Users Flag! Originally from germany. Users Flag! Expat in germany.
Default

Quote:
Originally Posted by kaju View Post
Some EU countries public health systems are more difficult to get into for some people - for example, if you were in the UK, you need to be a resident and there might be a fairly high income requirement before your non-Citizen partner could live there, so for some people, going there to get 12 months cover might not work. If you can get into the NHS system, then sure, Germany will accept 12 months NHS membership to transfer into the German system - but that won't work if you can't get into the NHS!
There is no income requirement for EU citizens and their non EEA family members, at least until Brexit. All I (and my then non-EEA husband) needed to join the NHS was proof of address. I called the council right after arriving and registered on the electoral roll, two days later I had official correspondence to use for registering with a GP, opening a bank account, and applying for a NINO.

Of course, GP practice staff are just as confused about Brexit as everyone else and I have heard stories about registering getting harder because everyone is scared to make mistakes. Also, depending on how Brexit will go down, the option to move to the UK could come to an end abruptly in as little as three months.

__________________
I am not a regulated immigration advisor. I am offering an opinion and not advice. Check here for professional help: https://www.gov.uk/government/organi...s-commissioner

I have disabled my DM function. I have been unwell and can't guarantee to be able to respond in a timely manner. Please post questions to the forums.
Reply With Quote Quick reply to this message
  #8 (permalink)  
Old 28th July 2019, 10:11 AM
Moderator
 
Join Date: Oct 2011
Location: Austria
Posts: 5,404
Rep Power: 442
kaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond reputekaju has a reputation beyond repute
1791 likes received
771 likes given

Users Flag! Originally from australia. Users Flag! Expat in austria.
Default

Quote:
Originally Posted by ALKB View Post
There is no income requirement for EU citizens and their non EEA family members, at least until Brexit. All I (and my then non-EEA husband) needed to join the NHS was proof of address. I called the council right after arriving and registered on the electoral roll, two days later I had official correspondence to use for registering with a GP, opening a bank account, and applying for a NINO.

Of course, GP practice staff are just as confused about Brexit as everyone else and I have heard stories about registering getting harder because everyone is scared to make mistakes. Also, depending on how Brexit will go down, the option to move to the UK could come to an end abruptly in as little as three months.
Clearly wrong information on my part, although the requirements will apparently change in 2020 or 2021. The UK was a bad choice to talk about anyway as who knows what will happen! I've edited my previous post accordingly, thanks!

What I can say is that not all EU countries will let non-EU partners (especially older ones) join their public health insurance systems. Given that non-EU partners would need 12 months membership to transfer to the German public health system, interested people need to check carefully what countries public health systems would accept them for this 12 month period.


Last edited by kaju; 28th July 2019 at 10:15 AM.
Reply With Quote Quick reply to this message
  #9 (permalink)  
Old 29th July 2019, 08:00 PM
New Member
 
Join Date: Jul 2019
Posts: 16
Rep Power: 0
Rixlari is on a distinguished road

Default

Thank you all for all this information. I shall try to digest it all. At this point, I'm trying to do research and get all the information I can to guide us toward the right destination for retirement. And we so appreciate the information we're getting! Once we have a better sense, we'll explore the country at bit more and start learning the language. Hopefully within 4-5 years we can move with the confidence there won't be TOO many surprises! However, we understand nothing in life is guaranteed so it's become clear to us that no matter where we go, we should have several backup options if things don't go according to plan, including moving back to the US to a cheaper area than Los Angeles.

One question to kaju. You said:

Quote:
Originally Posted by kaju View Post

Actually, since you have German Citizenship but have never worked/lived/been in their health system, you do have grounds for them to let you join - but your husband does not. So you could simply roll up in Germany and join. Although oddly enough, you couldn't join the German public system on this basis if you have ever been self-employed or freelance in the country you grew up in.
I grew up in the United States. When you say "country you grew up in" did you mean the country where I may move first and qualify for public health, such as France? I am self-employed in the U.S. and was considering continuing to be self-employed for a while when moving to Europe!

Thanks!

Reply With Quote Quick reply to this message
  #10 (permalink)  
Old 29th July 2019, 09:33 PM
Bevdeforges's Avatar
Super Moderator
 
Join Date: Nov 2007
Location: deepest, darkest Essonne
Posts: 45,974
Rep Power: 23261
Bevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond repute
9589 likes received
1273 likes given

Users Flag! Originally from usa. Users Flag! Expat in france.
Default

Quote:
Originally Posted by Rixlari View Post
I grew up in the United States. When you say "country you grew up in" did you mean the country where I may move first and qualify for public health, such as France? I am self-employed in the U.S. and was considering continuing to be self-employed for a while when moving to Europe!

Thanks!
Just be careful - I think you'll find that "self-employment" as such doesn't really exist in most european countries. If you're working for and by yourself, you normally have to register some sort of "business entity" (certainly in France, but I think also in Germany) so that you pay all your taxes and social insurances.

And generally speaking, you do have to pay into the retirement system, even if you are past "retirement age" in the country. You may or may not get any benefit from those payments - though usually there is a "social security" agreement that allows you to count your US working time toward accumulating benefits in your new country of residence.

Reply With Quote Quick reply to this message
Reply


Quick Reply
Message:
Options

Register Now

In order to be able to post messages on the Expat Forum For People Moving Overseas And Living Abroad forums, you must first register.
Please enter your desired user name, your email address and other required details in the form below.
User Name:
Password
Please enter a password for your user account. Note that passwords are case-sensitive.
Password:
Confirm Password:
Email Address
Please enter a valid email address for yourself.
Email Address:
Location
Where you live
Expat From Country
Please select the country you originate from. This will appear as a flag when you make posts on the site.
Expat To Country
Please select the country you have either moved to or want to relocate to. This will be presented on the site when you make posts.

Log-in


Thread Tools

Posting Rules
You may post new threads
You may post replies
You may not post attachments
You may not edit your posts

BB code is On
Smilies are On
[IMG] code is On
HTML code is Off
Trackbacks are Off
Pingbacks are Off
Refbacks are Off


FORUM PARTNERS

ExpatForum.com is owned and operated by VerticalScope Inc.

Retiring Overseas Guides | Moving Overseas Guides | Cost of Living | Health Care Guides


All times are GMT. The time now is 01:33 AM.


Powered by vBulletin®
Copyright ©2000 - 2019, vBulletin Solutions, Inc.
Search Engine Friendly URLs by vBSEO
vBulletin Security provided by vBSecurity v2.2.2 (Pro) - vBulletin Mods & Addons Copyright © 2019 DragonByte Technologies Ltd.