Well - as explained in the letter!
Cotisations subsidiaires are due from people who meet two simple criteria: 1/ their unearned income from specified sources during 2016 was above the threshold of 9,XXX€, and the tax office can easily identify these people from their income declarations, and 2/ their healthcare cotisations during 2016 below the specified thresholds, and URSSAF can easily identify these people from its own records. David’s link in post 3 explains that the tax office has now shared information with URSSAF, hence putting URSSAF in a position to identify the people who meet both critera.
Maybe it seemed like a good idea to set up a special helpline for queries on this specific matter, rather than tie up the general enquiries switchboard?
Well, each to their own opinion. If people doubt the letter but are curious, they can always check out article L 380-2, R 380-3 380-8 380-1 of the code de la sécurité sociale, as referred to in the letter. Or they can ignore it altogether and the only consequence might be that they will have less time in which to budget for the bill when it arrives. And then no doubt there will be folks complaining that they should have been given prior warning, despite the fact that all this information was put in the public domain in January 2016 when PUMA was first launched and a circular which they didn’t like the look of, was sent round.
I do take your point about being careful, but since the contents of this letter appear to be informative and entirely correct, and are basically inviting you to familiarise yourself with French legislation, common sense suggested to me that it might be worth taking notice of it, so I’ll wait to be proved wrong.
I had the same letter as you in the post and am worried about the situation. I took it to my local CPAM and they helped me draft an email to reply, stating that I held an S1. We are in a similar situation to you in that my husband commutes back to UK for work and we organise an S1 annually. We also had a tax issue for first time this year where they wrongly charged social charges on UK rental income that we had to get reimbursed. I was wondering if this was linked.
I did manage to speak to a lady on the phone line yesterday. All she would say was that I had to wait as the central office was deciding on who was liable for the cotisation or not and that I would be contacted.
Have you had any further developments that could shed some light? I had been working on what I would do if England stopped issueing the S1’s because of Brexit, for situations like mine, not that France would potentially stop accepting them.
I also don’t understand how they calculate the 8%. It doesn’t seem to make sense on the URSSAF website. If it is simply 8% of gross declared income that we give from earnings in the UK then it is very worrying.
Thank you very much David for sending the link. The information is reassuring and I hope my email stating we hold a valid S1 will be sufficient and an invoice letter will not be sent. Fingers crossed!
Aquitaine David Martin
November 28 |
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In Reply To
CStreet Claire Street
November 28 |
Dear Guy I had the same letter as you in the post and am worried about the situation. I took it to my local CPAM and they helped me draft an email to reply, stating that I held an S1. We are in a similar situation to you in that my husband commutes back to UK for work and we organise an S1 annually…
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It’s a mailshot and not everyone has had it so if you chat with people who have had it, you might be able to figure out the mailshot criteria
The relevant poeple to receive it in my view would be:
anyone who was on the old CMU - they will have missed a year of cotisations because CMU ceased to exist when PUMa came in. They won’t pay the same cotisations as before and maybe even none at all because under PUMa, pension income isn’t taken into account, only capital income (capital gains and rental income).
anyone who has earned income or business income below the lower threshold of around 4000 euros but also has capital income above the higher threshold of 9654 euros per annum and nobody else in the houshold pays cotisations based on income higher than that threshold will now get a supplementary cotisations bill.
This only affects people ‘a la charge de France’ for healthcare - so people who are in the system with an S1 from the UK won’t be liable for these cotisations, just as they weren’t liable for CMU cotisations.
I’d have thought they’d only mailshot the above people and not include people on S1s so if anyone with an S1 who isn’t working (which they shouldn’t be, as if you’re working you shouldn’t still have the S1) has received it, it’s obviously an error. I’d have guessed that the error might be that they may have mailshotted anyone with capital income above the relevant amount, using info from our tax returns - except if that was the case I’d have had the letter myself and I haven’t!
It does actually say that it only refers to people who have their fees ‘prise en charge’ and who haven’t got a French pension and have never paid any cotisations so I don’t know how they managed to not exclude all S1 holders in that, only some. If you’ve had the letter and you’re on an S1 it’s probably safest to inform them of the existence of the S1 in case it hasn’t been noted properly on your file with CPAM. As each CPAM is departmentally independant and as usual, departments do things differently, I’d be interested to know if anyone else on an S1 in the Charente has received this letter.
It’s still only talking about people who have their fees paid by France though, Anna, which people on S1s don’t. I’d think it was a general mailshot to let people know in case they plan to work and therefore lose their S1 cover - except as I said, I haven’t had this letter myself. I can only think that some CPAMS don’t have people’s S1s correctly registered.
I can’t think of how else they’ve made the error because if I didn’t have an S1 I’d certainly fit the criteria that should have been set for those who should receive this mailshot.
Just because you have the right to have your fees paid by France by virtue of stable residence - it doesn’t mean you have or have to. They mention the EU bit in relation to Swiss cross border workers but not those in the EU S1 situation - presumably because there is no doubt that S1 holders don’t have their fees paid by France whereas Swiss cross border workers can choose either way. Maybe they think all S1 holders will give up their S1s and decide to contribute to France instead?
Whatever - if I’d had the letter my response would be to reply and tell them I have an S1 and am therefore not under France’s charge for healthcare and not liable for supplementary cotisations to PUMa.
Another interesting thing to know would be whether other EU Citizen S1 holders (ie non British) have had the letter. If not, maybe it’s a preparation for brexit to let you know that whatever happens with that, you can still be covered by France for healthcare? If that was the case though, I would again have thought I would have had the letter.
I still don’t particularly see it as an error, nor anything sinister. As you say it’s a circular, all it’s doing is explaining the rules, it’s not like people have been sent erroneous bills. This is the first year of the scheme so you would expect a few teething problems, and if in doubt better to send the information to too many people rather than too few, no? Presumably in between sending the circular and issuing bills they’re busy running various cross-checks to sift out the “special cases” that weren’t identifiable from the raw data they got from the tax office…
No that’s true but you do have to have health cover one way or another if you live permanently in France. Anyone who lived here in 2016 and wasn’t signed up to PUMa and didn’t have an S1 or private cover,will presumably be picked up - living here and relying on a UK EHIC won’t work any more. Though I have no clue what they will do if they find people in that situation, they can’t charge them for PUMa healthcare in 2016 if they weren’t registered for PUMa in 2016.
It’s not anything sinister but it IS an error because not everyone who is in the health system has received the letters and not every one who has an S1 has received one - but some have, which is why I think they must not be registered correctly as having an S1 by their local CPAM. In which case it’s best to respond to explain that you have an S1.
As far as I’ve seen it’s only people who are already in the health system one way or another who have received the letter so it’s not connected to picking up people who aren’t registered and who have been using an EHIC card. Surely anyone who did that wouldn’t make a tax return anyway, so their info wouldn’t be passed on?
I think you have hit the nail on the head Guy in that the scam is in the premium rate number.
I notice that in the actual circular letter the number is given as 0 810 594 267 whereas surely any French person typing a phone number would automatically type it as 08 10 59 42 67.
I also see that the letter states that bills will be sent out in November, but I don’t see any comments on this thread from anyone who has actually received a bill and I would have thought that someone would have said something by now if they had received one.
My vote is that it’s a scam with money being made from calling the premium rate phone number.
They’re pretty dozy scammers then - 081x are the lowest cost premium numbers, max 6 cents per minute and capped at 15 centimes surcharge per call, so even if every recipient made two calls each, it would nowhere near cover the costs of sending out the letters! If I’d been doing the scam I would have at least chosen an 089x number when I could have netted 80 cents a minute or 3 euros per call, though I probably still wouldn’t have covered costs.
Before we get too carried away with conspiracy theories - in fact all URSSAF’s contact numbers are surtaxed. Their main 4-digit number 3957 costs around 12 cents per minute. Obviously they don’t want you to bother them unless you’re desperate.
Following on from this, both Mr. H. and I received bills from URSSAF yesterday for over 1000 euros each. So rang URSSAF, who have had several calls about this, and they said I must write and produce the S1. I told them the S1 was with CPAM but they insisted they have sight of this or a copy. So rang Newcastle who said they don’t send out copies at all and have no access, according to them it is with CPAM. So rang CPAM who said they need to speak to an ‘expert’ about this and will get back to me. Explained the urgency, as the bills are due for payment mid January and URSSAF won’t cancel without an S1. CPAM say they are “looking into it”. Rang URSSAF back and asked if they could just get the document from CPAM … non madame, impossible! So stuck between two creaking French bureaucracies at the moment … oh joy, happy days. Wish me luck!
