Registering with the social security system and having healthcare expenses reimbursed as an intern

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Anyone who wishes to do an internship in an establishment or company in Luxembourg must be covered by accident insurance.

The procedures for enrolling for health and accident coverage depend on the type of internship and the intern's personal situation.

By enrolling for health insurance, interns will be entitled to healthcare benefits such as medical and dental care, the reimbursement of prescribed medication, and coverage for hospitalisation.

Who is concerned

All interns on a regulated or voluntary internship, regardless of their nationality and place of residence, must be covered by sickness, accident, and pension insurance during their internship.

However, interns are exempt from the health and pension insurance requirement if their activity as interns is only occasional (rather than habitual) and for a period determined in advance, which may not exceed 3 months per calendar year.

Prerequisites

Internships are generally covered by an internship agreement, in the case of internships done as part of a school or university programme, or by an internship contract, when the internship is voluntary.

Internships generally involve work that is essentially educational in nature. They must have an informational component, and interns must not be assigned tasks requiring output comparable to that of regular workers.

Internship contracts have no minimum or maximum duration. There is no minimum or maximum compensation, but compensation must cover housing and meal expenses incurred by the intern during the internship.

How to proceed

Compulsory internships

Compulsory internships are internships that are done in connection with a course of study and required by the educational institution. They are also known as 'regulated' internships.

These internships must be documented by a contract countersigned by the educational institution. The employer and the intern may also sign an internship contract setting out the terms of the internship in the host company.

A distinction is made between interns who reside and/or are enrolled in an educational institution in Luxembourg, and those who reside abroad and do an internship required by an institution located abroad.

Interns residing in Luxembourg and/or doing an internship required by a Luxembourg educational institution

In both of these cases, the internship is governed by a special regime such that the employer is not required to carry out any specific formalities. The employer is not required to file a new-employee declaration with the Joint Social Security Centre (Centre commun de la sécurité sociale - CCSS) or to pay social security contributions.

The intern has health and accident coverage throughout the duration of the internship.

Entitlement to this special accident insurance regime is restricted to:

  • courses of study organised by an educational institution based in Luxembourg;
  • courses of study in a foreign educational institution pursued by persons who are legal residents of Luxembourg.

For accident insurance:

  • interns are generally covered by student accident insurance;

For health insurance:

  • interns are usually covered by compulsory health insurance as co-insured parties (with the main insured person being their father or mother). Such interns are therefore entitled to health insurance benefits through their parents' insurance.
  • interns who are not co-insured and are not insured in some other capacity must enrol voluntarily with the CCSS.

The procedure applicable to interns who have co-insured status depends on whether the intern is a resident or non-resident.

Interns who are residents (co-insured or personally insured) or children of a parent who is entitled to benefits in Luxembourg will automatically receive a social security card proving their entitlement to health insurance benefits.

Interns who are residents of a Member State of the European Economic Area (EEA) or of Switzerland will receive a European health insurance card which establishes their entitlement to health insurance benefits in Luxembourg.

Interns who are not EEA or Swiss residents may apply for a certificate of coverage from the competent body in their country of origin.

Interns residing abroad and doing an internship required by a foreign educational institution

Interns residing abroad generally have accident and health insurance in their country of origin. In principle, the Luxembourg employer does not need to file a new-employee declaration for the intern with the Joint Social Security Centre (Centre commun de la sécurité sociale - CCSS).

It is up to the employer to ensure that the intern is covered by accident insurance. To that end, the employer may refer to the internship contract proposed by the foreign educational institution, or may require the intern to provide a certificate issued by the competent institution in their country of origin attesting to their accident insurance coerage.

Interns who are not covered by accident insurance in their country of residence are considered as salaried workers. The employer must therefore enrol such interns with all social security branches by filing a new-employee declaration with the CCSS.

The calculation basis for social security contributions is the social minimum wage for unskilled workers.

However, interns who engage in an activity on an occasional and non-habitual basis, and for fewer than 3 months per calendar year, are exempt from enrolling with health and pension insurance.

For example:

  • a person who works for 3 months during the holidays and then does a 2-month internship from September to October will only be enrolled for accident insurance for their holiday job, but will be enrolled with all social security branches for the duration of their internship;
  • a person who regularly works on weekends and does a 2-month internship during the summer will be enrolled with all social security branches for their weekend work and for the duration of their internship;
  • a person who does not work at all during the year and does a 3-month internship will be enrolled for accident insurance only for the duration of their internship.

For health insurance:

  • interns are usually covered by health insurance in their capacity as a co-insured party (with the principal insured being the intern's father or mother) in their country of origin. Such interns are therefore entitled to health insurance benefits under their parents' insurance. They may receive benefits in kind in Luxembourg using their European insurance card or any other document proving their insurance coverage.
  • if a foreign intern is entitled to benefits in Luxembourg because one of their parents is enrolled with social security in Luxembourg, the intern is insured as a resident and is therefore entitled to health insurance benefits without restriction.
  • if the intern does not have co-insured status, and is not insured in any other capacity, they must enrol for voluntary health insurance with the CCSS.

Voluntary internships

Voluntary internships are internships that are not regulated by an educational institution. Interns who do an internship on their own initiative must be enrolled with all social security branches (sickness, pension, accident and long-term care), like employees.

However, an employer who hires an intern to perform an activity solely on an occasional, non-habitual basis, and for a duration not exceeding 3 months per calendar year, need not enrol the intern for health and pension insurance.

Neither the amount of any compensation paid to the intern nor the intern's place of residence has any effect on the conditions for enrolment with social security.

Interns doing an internship lasting no more than 3 months

Interns engaged in an activity lasting no more than 3 months per year need only be enrolled for accident insurance in connection with that activity.

In that case, the activity in question must be occasional, non-habitual, and not last longer than 3 months.

Example:

  • a person works for 3 months during the holidays and then does a 2-month internship from September to October. will only be enrolled for accident insurance for their holiday job, but will be enrolled with all social security branches for the duration of their internship;
  • a person who regularly works on weekends and does a 2-month internship during the summer will be enrolled with all social security branches for their weekend work and for the duration of their internship;
  • a person who does not work at all during the year and does a 3-month internship will be enrolled for accident insurance only for the duration of their internship.

For health insurance:

  • interns are usually covered by health insurance in their capacity as a co-insured party (with the principal insured being the intern's father or mother) in their country of origin. Such interns are therefore entitled to health insurance benefits under their parents' insurance. They may receive benefits in kind in Luxembourg using their European insurance card or any other document proving their insurance coverage.
  • if a foreign intern is entitled to benefits in Luxembourg because one of their parents is enrolled with social security in Luxembourg, the intern is insured as a resident and is therefore entitled to health insurance benefits without restriction.
  • if the intern does not have co-insured status, and is not insured in any other capacity, they must enrol for voluntary health insurance with the CCSS.

Interns doing an internship for more than 3 months

Paid and unpaid interns must be registered with the health insurance fund in the same conditions as a salaried worker, which means with all social security branches.

The amount of social security contributions is calculated based on the amount of compensation paid for the internship. If that amount is less than the social minimum wage for unskilled workers, the minimum contribution base will be applied.

Reimbursement of healthcare expenses

Reimbursement of expenses advanced by interns

After a visit with a healthcare provider, interns must pay the provider or supplier immediately, or subsequently by bank wire.

The insured individual must then prepare a letter to be sent to the health fund with which they are enrolled:

  • for interns enrolled with a Luxembourg health insurance fund, the letter, which does not require a stamp, must mention or contain:
    • the intern's identity and national identification number;
    • the insured individual's bank account details, if it is a first-time request, or if their bank details have changed;
    • the original receipted statement of fees, or if the payment took place later, proof of payment in the form of a bank statement. It does not matter whether the bank statement is a copy of the original or has been printed from an online banking website. However, a transfer order alone is not sufficient.
      The expenses incurred by the intern will be reimbursed by wire transfer within a few weeks. The amount reimbursed depends on the contractual or statutory rate.
  • for interns with a European Health Insurance Card from another EU Member State, the application for reimbursement of healthcare expenses must be sent either to the CNS or to the health insurance fund in their country of origin.
    If an intern is requesting a reimbursement from the CNS (without having been affiliated with the CNS before), the following information/documents must be submitted together with the request:
    • proof of their identity (a copy of the ID card may be attached);
    • a bank account identification document with IBAN and BIC codes;
    • a valid copy of the European health insurance card;
    • proof of insurance covering accident risk abroad;
    • a copy of the internship contract;
    • the original receipted statement of fees, or if the payment took place later, proof of payment in the form of a bank statement. The bank statement can be either a copy of the original or printed from an online banking website. However, a transfer order alone is not sufficient.
      The reimbursement will be made by wire transfer within a few weeks. The amount reimbursed depends on the contractual or statutory rate.
  • for interns enrolled for social security in a foreign country that has entered into a bilateral social security treaty with Luxembourg, the application for reimbursement of healthcare expenses may be sent either to the CNS or to the health insurance fund in the intern's country of origin.
    If an intern is requesting a reimbursement from the CNS (without having been affiliated with the CNS before), the following information/documents must be submitted together with the request:
    • proof of their identity (a copy of the ID card may be attached);
    • a bank account identification document with IBAN and BIC codes;
    • a copy of the conventional form issued by the social security agency in the country of enrolment;
    • proof of insurance covering accident risk abroad;
    • a copy of the internship contract;
    • the original receipted statement of fees, or if the payment took place later, proof of payment in the form of bank statement. The bank statement can be either a copy of the original or printed from an online banking website. However, a transfer order alone is not sufficient.
      The reimbursement will be made by wire transfer within a few weeks. The amount reimbursed depends on the contractual or statutory rate.
  • for interns enrolled in a country that is not a member of the European Union (EU) or the European Economic Area (EEA), the application for reimbursement must be sent to the health insurance fund in their country of origin.

Direct payment by the health insurance fund

In certain cases, such as hospitalisation or medication expenses, the insured party is not required to advance the entire amount incurred. To benefit from this system of direct payment of healthcare costs by the competent health insurance fund—known as the 'third-party payment' system—insured parties will need to produce their social security card or European health insurance card.

Insured individuals are only required to pay service providers for the portion of their expenses that remains to be borne by them.

Interns who are not enrolled with a European health insurance fund must produce a valid certificate of enrolment with a health insurance scheme. This document, certifying their health insurance coverage abroad, will allow them to make use of the third-party payer system if there is a bilateral social security agreement between Luxembourg and the intern's country of origin.

Without a certificate of enrolment in a health insurance fund, such interns will be required to advance their healthcare costs and later apply to the health insurance fund in their country of origin for reimbursement.

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