In a statement the German Social Accident Insurance (DGUV) as the umbrella organization of German labor insurances contributes to the proposed revision of regulations (EC) No. 883/2004 and No. 987/2009 by the European Commission.
The regulations and their predecessors are coordinating the European social security systems (in particular the health, accident, pension and unemployment insurances). Concerning the accident insurance the proposal focuses on the medical treatment of posted workers in other Member States and the invoice procedures between the liaison offices.
The proposal of the European Commission takes into account the areas of
Concerning the services in case of long-term care, the proposal focuses on the creation of an own Chapter and adjustments in the procedures.
According to the DGUV, the introduction of a Chapter for regulations on long-term care however counteracts the efficient applicability of the coordinating European law, since claims from long-term care insurances in case of work accidents and occupational diseases can still be coordinated under the Chapter for work accidents and occupational diseases. Also, due to the newly created legal procedures, the effective implementation of the Electronic Exchange of Social Security Information (EESSI) would be hindered.
Further remarks towards the proposal are concerning the abbreviation of the deadlines (from 18 to 12 months) set for the refund of service expenses advanced by an EU-foreign social insurance. This way, for instance a worker from another EU Member State, who is insured in his home country, can receive medical treatment by the DGUV’s liaison body (Verbindungsstelle) in case of social accident if posted in Germany. The expenses then are reimbursed by the corresponding insurance in his home country.
With the aim of reaching legal security and certainty, the DGUV supports amongst others that for pupils, students and interns the Certificate of Coverage A1 shall be issued, as well.