Global regulations for international private medical insurance (IPMI) can be in constant flux, creating challenges and potentially opportunities for insurance providers and brokers.
One of the most pressing issues in the international insurance market is the wide variety of regulations being introduced around the world.
This complexity creates both challenges and opportunities, with some regions experiencing more dramatic shifts than others.
This article will consider the key regulatory developments in the some of world’s most important IPMI markets, including views from the UK, Hong Kong, Singapore and the Middle East, and look at how this is prompting changes from insurers and advisers, and what it will mean for business levels.
UK
According to Kieran Brown, managing director UK at SIP Medical Family Office, says: “Regulatory change in the international PMI markets is arguably the most important topic that impacts everyone in our industry daily and strategically for the long term.
“As an intermediary, day-to-day we need to assess whether or not we may be able offer a solution to prospects or continue to support our existing clients from renewal.
“Of course we can support the vast majority of enquiries but where regulatory changes impact we need to be sure we and the insurer partner we work with remain compliant.
“Frustratingly there have been regulatory changes that mean we may not be able to offer a solution or work with some partners based on factors such as; country of residence, whether our client is a local national or expatriate, whether we as the intermediary are compliant to trade in certain locations and so on.”
But some areas are going through greater changes than others.
Brown says: “The most notable locations we need to be careful in recent times due to regulation are; USA, European Union, UAE & Qatar. Increasingly we’re seeing regulatory changes in Africa too.
“Brexit caused its own issues, but SIP took the strategic decision to expand its compliant capabilities internationally, so that it it was unable to offer a solution due to the impact of regulation – it would have a partner or two who could.”
Brown says: “For regulatory purposes in some locations it is critical that the both insurer and intermediary are licenced to trade and so it is increasingly difficult for multi-nationals to find one insurer partners who can truly offer one consolidated solution in all countries around the world.”
Brown says: “Since Brexit and strategically, we found most UK intermediaries may not be as confident or feel they have the expertise, due to regulatory changes – and this has been a key motivation to growing our business in the UK so we can help other partners navigate these challenges so there is still an option for their clients.”
Hong Kong
But Hong Kong has had to navigate even more recent regulation changes than those caused by Brexit.
Amelie Dionne-Charest, co-founder and managing director of Alea Insurance, a Hong Kong-based broker, says: “The most significant regulatory reform in HK in regards to private medical insurance was the launch of the Voluntary Health Insurance Scheme (VHIS) in April 2019.
“Participating insurance companies offer certified individual indemnity hospital insurance plans for HK residents to purchase voluntarily. VHIS’ objective is to provide the public affordable health insurance to encourage usage of private sector and relieve pressure on HK’s public healthcare system.
“That has created two similar but different products, each with its own market – but with VHIS eating into the IPMI market.”
Dionne-Charest says: “VHIS is primarily aimed at the local population in Hong Kong, including individuals and families who want more affordable and standardized health insurance coverage.
“It focuses on providing comprehensive coverage for basic medical services within Hong Kong’s public and private healthcare system.
“On the other hand, IPMI is designed for expatriates, high-net-worth individuals, and global nomads who require more extensive coverage that extends beyond Hong Kong’s borders.”
There is also a difference in coverage, as VHIS is less broad in what it has to offer, compared to IPMI.
“VHIS offers standardised policies with a specific set of benefits and coverage limits,” she continues.
“It focuses on essential healthcare services, including hospitalisation, outpatient care, and prescribed drugs.
“IPMI, on the other hand, typically offers broader coverage that includes not only basic healthcare services but also specialised treatments, international coverage, and additional benefits such as dental, vision, and maternity care.”
And another difference is network accessibility, Dionne-Charest says.
“VHIS policies generally allow policyholders to access both public and private healthcare providers in Hong Kong,” she points out. “IPMI, on the other hand, often provides access to a global network of healthcare providers, allowing policyholders to receive treatment in their home country or in other countries around the world.”
And finally there is the issue of pricing, with VHIS costing substantially less than IPMI, she says.
“VHIS policies aim to provide more affordable options for the local population in Hong Kong.
“The premiums for VHIS policies are regulated and standardised based on age bands, ensuring that they are more accessible to a wider range of individuals. IPMI policies, on the other hand, are typically more expensive due to the broader coverage and international access they offer.
“While there may be some overlap in terms of coverage and services, VHIS and IPMI cater to different market segments and have different value propositions. VHIS focuses on providing affordable and standardized coverage within Hong Kong, while IPMI offers more comprehensive coverage and international access for a specific demographic.”
Middle East
Changes in regulations are also an issue in the Middle East.
Amber Musson-Thorp, group commercial director for Lifecare International based in Qatar, says: “Regulation in the MEA region is ever evolving and continues to be a considerable part of our day-to-day life as insurance consultants. “Regulation changes in different markets can greatly impact our annual strategy for the good or bad and can often be very last minute.
“Regulatory changes can result in the need to find new insurer partners or products and may require the need to form new strategic broker partnerships if the jurisdiction changes to ensure that we secure our clients and our revenue.”
Brown agrees and points out that providers need to keep up with everchanging requirements, especially in the Middle East.
He says: “In a few territories such as UAE, we saw the introduction of compulsory health insurance. For international PMI providers to remain compliant they have to meet the minimum requirements. In order to do so, providers must really adapt their business model and the plan design is just one component of that. “
But regulations can go beyond that level as well as Musson-Thorp points out.
“On top of the more common jurisdiction or product regulation we even see regulation impacting service.
“At the beginning of 2024 we saw regulatory changes in the UAE that payments to members for reimbursement claims must be made by the insurer/fronter rather than the third-party administrator (TPA) which resulted in some of our clients seeing three-month delays in their payments whilst the insurers found a solution.
“This is completely outside of our control as advisers and causes problems for our clients.
“Part of our day-to-day role as a specialist intermediary is to stay ahead of the upcoming changes and be able to try and predict what is coming down the line.
“This is only possible by having strong relationships and vast experience of the market by engaging in regular dialect with regulators, partners and insurers and this is how we add value to our clients and can give solutions and advice in a timely manner.”
Singapore
But brokers are expected to keep their clients informed of any regulation changes in Singapore as well.
Peter Whittington, head of international people solutions in the Asia Pacific region for Aon. says: “Clients rely on us to provide them with accurate and relevant advice at all times.
“They expect us to be aware of any upcoming regulatory changes even before they are implemented by regulators.
“As such, in a fast changing regulatory landscape we have to ensure that we are up-do-date on what this means to our clients and respond quickly to help our clients navigate these complexities and remain compliant.”
He too has seen a shift in the type of PMI plans that are being offered due to changes in regulations.
“There are some insurers who are looking to broaden their offering to include key local nationals on a non-admitted basis, wherever this is possible while, some are looking to purchase local licenses to allow them to provide a wider offering on a regulated basis and finally, there are other insurers who will decline opportunities if they feel they cannot provide the correct level of cover.
“We are therefore working closely with our insurance partners to support innovation and ideas on how their products should respond to both regulatory changes and the changes in the globally mobile workforce.”
Aon also drives benefit by having offices around the globe.
Whittington says: “As a global firm we can leverage our local offices for assistance with local placement if required and also being current on ongoing regulatory changes to enable us to keep up with requirements.
“These updates need to be immediately assessed and explained to our clients along with any actions that they, the insurers or Aon needs to take.”
