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France: New reimbursement requirements for employer health insurance aim to lower insureds’ expenses


April 25, 2019

France’s new three-year program, 100% Health, aims to reduce the current level of out-of-pocket spending required of insured persons.


The Ministry of Solidarity and Health’s (Ministère des Solidarités et de la Santé – MSS) three-year program aims to make hearing, vision and dental care more affordable for individuals who are insured under mandatory employer health insurance. It reduces the current level of out-of-pocket (OOP) spending required of insured persons.

Since 2016, all employers have been required to ensure a minimum level of medical coverage for all staff (certain exemptions apply for short-term and part-time staff).


Details of the “100% Health” (100% Santé), which started to roll out on January 1, 2019, include:

  • The MSS reform takes a two-pronged approach to reducing end-user OOP costs. First, it seeks to implement negotiated rates for specific services and materials. Traditionally, while most common health care services have been subject to social security-negotiated rates and cost caps, the application of such an approach has been rather limited in the areas of hearing, dental and vision where many services are not subject to cost restrictions.
  • Also, the specific minimum coverage requirements for mandatory employer health insurance relating to these areas will be broadened to cover more treatment forms and provide higher levels of reimbursements. Adjustments in reimbursement will be shouldered jointly by social security and mandatory employer insurance.
  • The reforms will be rolled out in steps, summarized as follows:
    • 2019: Negotiated rates and cost caps will be gradually introduced for hearing and dental. The annual reimbursement for hearing aids will be increased by 100 euros.
    • 2020: OOP spending will be eliminated for vision- and dental-related care and equipment covered under the 100% Health program. For hearing, negotiated rates and cost caps will be fully in place. In addition, the annual cost ceiling for hearing care will be reduced by €200 while reimbursement will be increased by €50.
    • 2021: OOP spending will be eliminated for covered hearing-related care and equipment. Certain adjustments relating to specific dental reimbursements will continue to be adjusted until 2023.


The 100% Health program will have employer cost implications, in terms of both increasing the cost of insurance and an expected increase in employee utilization of services, and have significant OOP spending implications for the consumer. For example, MSS data suggest that currently the cost of hearing aids (an estimated €850 in OOP spending) deters about two-thirds of individuals who need them from getting them.

Employers should review the expected cost implications on their current insurance arrangements in addition to complying with the new health coverage requirements and communicating the changes to staff.

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