Third Country National Insurance Issues: WARNING, avoid the temptation to automatically throw them together with U.S. Expatriates and a separate expatriate handbook may be needed:
Certainly, if you have 20 U.S. expatriates and you have hired two Irish Nationals to work in Spain (TCNs), there is no need to completely start from scratch and do things special for two individuals. However, consider the following below and if the group sizes are large enough, U.S. expatriates and TCNs do not have the same needs and may need separate programs, and separate policy and procedures.
A Third Country National is generally considered a politically incorrect term that has never been replaced. There was an attempt years ago to use the term non-U.S. expatriate but it never gained much traction. A TCN is, from a home country perspective, an employee of one country hired to work in another, who is not a resident of the parent country. A simple example is more appropriate.
"...For example, a TCN is a German citizen hired by an American company to work in India. A 3 country triangle"
What concerns are unique to TCNs, TCN insurance:
TCNs many not need the same employee benefit package extended to U.S. expatriates. First U.S. expatriates need a HIPAA compliant medical policy with U.S. provisions that conform to U.S. benefits and labor law, do TCNs? We don't think so.
TCNs DO NOT NEED: COBRA extension of benefits, a HIPAA plan, an ERISA plan, elective care in the U.S., dependent care in the U.S., and they may not request or expect Long Term Disability or even Dental Insurance. We are not suggesting these benefits should not be offered, perhaps in many areas they should receive the same benefits as the U.S. citizens they work along side. However, the matter should be considered and before companies overspend by thousands on their employee benefit programs for Third Country Nationals, all factors and options should be considered.
What else is unique to the TCN employee from an expatriate handbook perspective?
Many Third Country Nationals will need an offshore pension benefit to supplement lost pension by leaving their country of citizenship. Of course, TCNs will not be able to be enrolled in U.S. qualified plans like the 401K as the U.S. expatriates will. However, if home country pension is no longer being funded while they are working out of country, an offshore pension will need to be funded and established.
If Third Country National Employees are enrolled in an international group medical program just for the TCN group, that does not provide elective care in the U.S. it should provide emergency care. If there is no care offered in the U.S., it would be easy to arrange for travel coverage for each case where a TCN employee needed to come into the U.S. on business, perhaps to visit the home office. Overall, this would still be much less expensive than granting TCNs elective U.S. medical care.
