# Change in Eligibility for Brits for CSS?



## Nomoss

Yesterday I tried to renew our CSS on line, but when I reached the end of the process I was told that the application could not be completed, and to contact our CPAM.
I tried again a few times, entering "European" for nationality, and changing a couple of other options but nothing made any difference.
I downloaded the claim form to submit by mail, but later saw on another forum that someone else is having a similar problem, and was told by their CPAM that 'migrants britanniques', holders of an S1, are no longer eligible to apply for CSS.
I did notice that the list of “European” countries on the claim form has changed since last year, and no longer includes Royaume-Uni, so started searching for some verification of that.

I didn't find specific mention of any change, but just read the information here, which seems to have changed since last year Complémentaire santé solidaire : qui peut en bénéficier et comment ?

The part which is relevant to our situation is:

Pour demander la Complémentaire santé solidaire, vous devez :

*bénéficier de l’assurance maladie*
et ne pas dépasser la limite maximum de ressources.

Unfortunately, as S1 holders, I suppose we are not directly affiliated to l'assurance maladie; part of our medical expenses are paid by them, but are reimbursed by the UK government, previously as EU citizens, now under the WA. We do not pay SS contributions nor CSG - CRDS on our income, and we verify this every year by ticking the appropriate boxes on our tax return.
As we have no longer been EU citizens since Brexit, we seem to have been getting CSS for the last couple of years because of a loophole which is now being closed, as our situation was apparently not covered by the WA.

Probably no-one though of it. Quelle surprise! Thank you Boris.


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## Bevdeforges

Is your S1 based on your being retired? If so, you may want to know that although retirees here in France (on foreign pensions) are entitled to free CPAM cover, they have to pay for their own mutuelle contracts. I suspect that is the change that may be affecting you here.


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## LesFroggitts

My wife and I applied for ours in January, we're retired and inactif with myself being a dependent of her State pension enabled S1. Our application was for the contributory version of CSS paying Eur 51 per month for the two of us.

The application through CPAM(16) was accepted and activated in April - only small hiccup was when they asked for clarification of an amount I drew-down on my company pension upon its start - but this was deemedby them tobe OK and not count against us as far as eligibility for the scheme.

So I'm hoping for next year that this "bug" will be resolved.


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## Nomoss

Sorry. I should have mentioned that my wife and I are British, retired, are UK OAP's, have been resident in France since 2000, have had WA Titres de Séjour since April 2021, and have been covered by CSS since we qualified for it in October 2020.


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## Nomoss

Apparently the change in the law took effect from 1/4/22 , but I have no reference for this apart from what a member of another forum was told at their CPAM office.


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## LaBatarde

ME TOO ! I have had the benefit of CMU/CSS for seven years (78 year old English widow - UK Govt pension my only income). This year it has been refused. A friend put me in touch with a local lady, similar to an Assistante Sociale, whose title is "Animatrice France Services" and she contacted my local CPAM to find out why. A similar answer came back to the one that Nomoss received. CPAM said I could challenge the decision within two months with a formal letter and I await results. 

As my CSS ran out at the end of April, I now have no mutuelle cover and the lowest I have been quoted is €60 a month. At the moment I do't see where this is going to come from, as my annual income is just over €8000 and I struggle to make that cover everything. My application for renewal of the CSS was received by CPAM on 14 April and this "new law" didn't come into effect until, I believe, 22 April, but I have still been refused. 

The very kind Animatrice hadn't heard of this change either, but proposed that I change my status, i.e. give up my Carte de Sejour Permanente, which she said would do the trick. This I'm not prepared to do. My own thought was to apply for citizenship but that apparently takes a couple of years and costs about €250 as an application fee.

I put the problem to Connexion newspaper and they replied very quickly, asking for my phone number and that of the Animatrice to get more details, and saying they would ring me today, 2 June, but so far no call. 

Does anyone have any information or clues as to how this can be reversed? I can probably cover the extra payment per month on my prescription, which at around €10 is an awful lot cheaper than a mutuelle. However that's only medications and I'm sure then to fall off my terrace, break a leg or two, succumb to some awful plague or go through a fortune in tranks trying to keep the panic down. I fully admit to being in a panic !

Any help much appreciated.


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## conky2

I think I promised to reply to Nomoss on this. Having just received my tax declaration and RFR from the impots, ameli.fr have immediately reminded me to renew my CSS expiring end of November and I am not expecting any problems. From posts I have seen on various forums , I guess that this is because I am still not in receipt of an S1 (happens next year) . I am also fortunate enough to have Irish citizenship.


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## Nomoss

Thank you conky2

Here is what I posted on this subject on another forum on July 29.

"As my application could not be made using the online system I applied by mail.
My hopes were raised when I was subsequently asked for a tax document which I had missed enclosing, but today I received the following message in my Ameli account:

_Vous avez demandé à bénéficier de la Complémentaire santé solidaire le 16/06/2022.

Après examen de votre dossier, votre demande ne peut pas être acceptée.

En effet vous bénéficiez de la prise en charge de vos frais de santé sur le territoire français au titre
d'un formulaire délivré par l’Etat compétent dans lequel vous possédez des droits. *En raison
d'une évolution de la réglementation cette situation ne vous permet pas de prétendre au
bénéfice de la Complémentaire Santé Solidaire*_

So that , I guess, is that. Thanks BoJo."


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## EuroTrash

Nomoss said:


> Thanks BoJo.


Much as I like blaming BoJo for everything I'm not sure you can lay this on at his door, since it is not UK specific. True it did happen to take effect close after Brexit but that could be coincidence. I don't think France would have decided to penalise all S1 holders including those from Spain, Italy, Germany etc, just to spite the UK. 
I would have thought it's more to do with trying to plug the hole in PUMA's finances, and I guess cutting back on "unnecessary" spending rather than injecting more taxpayers' money has to be the favoured approach in these hard times.

On a related note I'm currently being bombarded by emails about cheap mutuelles for seniors, for the last few months I've been getting several a week. I don't know what suddenly triggered them and I'm not interested at the moment because obviously I have cover through work, but is this a new thing? Has there been a change that has brought down the cost of mutuelle cover for oldies? That's what the emails seem to be suggesting but it may just be a marketing gimmick, I haven't looked into it.


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## Nomoss

EuroTrash said:


> ....................... I don't think France would have decided to penalise all S1 holders including those from Spain, Italy, Germany etc, just to spite the UK. ............................


I have yet to learn of any EU citizen resident in France who has been refused CSS cover because their health insurance is paid by another State via an S1.

I believe there are blanket reciprocal agreements on this and other benefits between EU countries, which no-one in the UK considered during the mock negotiations.


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## Crabtree

All EU citizens should be treated the same ie if a low income french person gets something then all low income EU citizens in France should get the same as well That is one of the principles of the EU.Now the UK has left the EU but is still providing S1 cover it has clearly thrown up an anomaly which presumably will end over the years as Brits moving to the EU will need to show a minimum income anyway


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## Nomoss

Crabtree said:


> All EU citizens should be treated the same ie if a low income french person gets something then all low income EU citizens in France should get the same as well That is one of the principles of the EU.Now the UK has left the EU but is still providing S1 cover it has clearly thrown up *an anomaly which presumably will end over the years* as Brits moving to the EU will need to show a minimum income anyway


Well, that's a relief, then


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## EuroTrash

Nomoss said:


> I have yet to learn of any EU citizen resident in France who has been refused CSS cover because their health insurance is paid by another State via an S1.


On the other hand do you know of any EU citizens resident in France who have been granted CSS since April this year? Though I suspect that there are more Brits with S1s in France than any other nationality.


Crabtree said:


> All EU citizens should be treated the same ie if a low income french person gets something then all low income EU citizens in France should get the same as well


But they are. The distinction is not whether they are French or not, the distinction is whether they are directly affiliated to PUMA or not. There could be, and no doubt there are, French nationals who have returned to France after working in another EU country and who hold an S1 from the country where they last worked, and are therefore not entitled to CSS even if on a low income. Equally, EU citizens who are not French but who have worked in France and therefore don't take the S1 route, will continue to be entitled. So the discrimination is not French v. non French, it's direct affiliation to PUMA v. S1, and there will be some crossover.
Though I do wonder if Brits who are directly affiliated to PUMA will continue to be eligible? Since you say the UK has been removed from the list of eligible countries, maybe we won't.


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## Nomoss

Nomoss said:


> I have yet to learn of any EU citizen resident in France who has been refused CSS cover because their health insurance is paid by another State via an S1.





EuroTrash said:


> On the other hand do you know of any EU citizens resident in France who have been granted CSS since April this year? Though I suspect that there are more Brits with S1s in France than any other nationality.


I don't know anyone at the moment, but there is an EU citizen on this forum who will shortly be reapplying.


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## Crabtree

Yes I see your argument there and can understand where it is coming from.The problem is that we do not know figures the nationalities of those afeected etc And this has all the makings of a long running court saga.Remember when Sarkozy wanted to stop all health care for non french even those that had been affiliated previously? He had to back down and likewise I suspect that those who had help previously may get it reinstated -hopefully.And what about those who have lived in France past the magic 5 year mark? I suspect that this is one of those "cunning plans" that will fail court scrutiny


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## Nomoss

Crabtree said:


> All EU citizens should be treated the same ie if a low income french person gets something then all low income EU citizens in France should get the same as well





EuroTrash said:


> *But they are*. The distinction is not whether they are French or not, the distinction is whether they are directly affiliated to PUMA or not. There could be, and no doubt there are, French nationals who have returned to France after working in another EU country and who hold an S1 from the country where they last worked, and are therefore not entitled to CSS even if on a low income. Equally, EU citizens who are not French but who have worked in France and therefore don't take the S1 route, will continue to be entitled. So the discrimination is not French v. non French, it's direct affiliation to PUMA v. S1, and there will be some crossover.
> Though I do wonder if Brits who are directly affiliated to PUMA will continue to be eligible? Since you say the UK has been removed from the list of eligible countries, maybe we won't.



That remains to be seen.

Meanwhile:

There is a couple, UK nationals with French citizenship, on another forum, whose renewal was refused, and who were advised by their CPAM to cancel their "Brexit" residence permit,

There are also a couple of Brits on other forums who already have state health cover, I'm unsure whether through working in France or through PUMA, who are wondering if registering their S1's when they reach UK retirement age will result in their CSS being cancelled..


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## EuroTrash

Nomoss said:


> There is a couple, UK nationals with French citizenship, on another forum, whose renewal was refused, and who were advised by their CPAM to cancel their "Brexit" residence permit


I saw that and I didn't really understand it. It's the S1 that's causing the issue, not their WARP. I can only think that whoever advised them that (was it CPAM? I thought it was an assistante sociale) was thinking they would then be able to apply for AME on the grounds of being in France "irregularly", but (a) I don't think you can "cancel" a residence permit, if you have obtained those rights then you have obtained those rights, and (b) it sounds rather dodgy.



Nomoss said:


> There are also a couple of Brits on other forums who already have state health cover, I'm unsure whether through working in France or through PUMA, who are wondering if registering their S1's when they reach UK retirement age will result in their CSS being cancelled..


The facts make a big difference... If healthcare is through working in France then they won't be eligible for an S1 from the UK in any case (that's my situation). If through having joined PUMA and paid cotisations, yes I guess that is a decision for them to make. At least they are in a position to make it, unlike those who already had S1s before the rules/interpretation of the rules changed.

EDIT Well I am saying it is a decision for them to make, I am not sure if that is true. If the UK becomes their competent state on retirement due to that being the last country they worked in, France may insist on them obtaining the S1.
I guess all these little twists and turns will be revealed over the next couple of years as situations arise and we see how they get resolved.


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## 1790260

Hello, I found this thread when searching the web and wanted to ask a hopefully relevant question regarding renewing CSS for non S1 holders.

I'm currently playing slow ping-pong with Ameli over our application for CSS. We'd been on CSS until June of this year and have had no problems, either originally applying for it nor with its functioning since. The issue came with the online renewal back in May. That failed and directed us to contact the local office with the necessary paperwork - which we did. Since then, I've been asked for copies of documents that I have already provided - and now I'm being asked for an 
"une déclaration sur l'honneur de vos moyens de subsistance". I can find templates for such a document, basically a self-declaration, and it's not in itself a problem BUT I'm paranoid as to what this _might _lead to. That is, in short, a questioning of our 'regular and stable' status and the removal of our residents card (i.e WARP)

We've been here 15 years, correctly registered with both impots and PUMA - paying taxes etc on savings and artisan earnings. We live mainly on savings but we do have a small income and so eligible for CSS. We had no problems in getting our original carte de sejours nor in the changing of them for the new WARP card. Officially, we have attained a right of residence through having lived here in a regular and stable manner for those initial 5 years. In theory, I believe our WARP cards cannot be revoked/renewed (not for being on CSS anyway) - but I don't really want to test that theory out.

Are there are other non S1 Brits that have recently renewed their CSS?

Many thanks for any comments


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## EuroTrash

You are correct. The income-related conditions only apply for the first 5 years. After that it doesn't matter what your income is.
I imagine they are simply checking that you don't have an income that's above the threshold for CSS.


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## 1790260

Thank you for your response EuroTrash.

Ameli ask for my "moyens de subsistance" for the year to 31/3/2022. How might you interpret that (given they ask 'subsistance' rather than 'resources')? Income only? Or income AND amount of savings? I want to give them exactly what they want.


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## EuroTrash

It's not a thing I have any experience of so I am only guessing, but if you're living mainly off savings I think you need to tell them. If you claim to be living on a few thousand a year, they will know that that is impossible.
If it were me I would list my income sources, the amount from each source, and my accessible savings accounts and any interest that they produce.


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## 1790260

EuroTrash said:


> accessible savings accounts and any interest that they produce.


All govt regulated savings (livret A etc) so no taxable interest. 

My paranoia kicked in because I wondered how the question of subsistence (i.e. our savings) is relevant to a CSS application, which is income based. It wasn't asked with our original application. I've no problem answering the question but simply wondered _why_ it was being asked. Was it just another delaying tactic?

Hence me being interested if anyone else on the forum has gone through the CSS renewal process.


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## EuroTrash

I don't think subsistence specifically means savings. A person might be in receipt of social benefits, alimony/child maintenance, all kinds of random payments that go towards their living expenses, and if so they would want to know.


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## BackinFrance

I think they need to know everything,, savings, interest, any other income And your Livret A pour which although not taxable forms part of your means. I would think it unlikely that would exclude from receiving the CSS unless your resources are significant.

The CSS is social security assistance which is why they can ask you for all this information. If you want the CSS, you supply the info.


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## 1790260

Thanks EuroTrash & BackinFrance for your responses. As it's a matter of an official definition, I've emailed Ameli to ask them _exactly_ what they need to know. We have no income other than that declared on our tax returns (which they have, twice!) I only want to make sure our application isn't delayed further.


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## conky2

Nomoss said:


> Thank you conky2
> 
> Here is what I posted on this subject on another forum on July 29.
> 
> "As my application could not be made using the online system I applied by mail.
> My hopes were raised when I was subsequently asked for a tax document which I had missed enclosing, but today I received the following message in my Ameli account:
> 
> _Vous avez demandé à bénéficier de la Complémentaire santé solidaire le 16/06/2022.
> 
> Après examen de votre dossier, votre demande ne peut pas être acceptée.
> 
> En effet vous bénéficiez de la prise en charge de vos frais de santé sur le territoire français au titre
> d'un formulaire délivré par l’Etat compétent dans lequel vous possédez des droits. *En raison
> d'une évolution de la réglementation cette situation ne vous permet pas de prétendre au
> bénéfice de la Complémentaire Santé Solidaire*_
> 
> So that , I guess, is that. Thanks BoJo."


So, I encountered the same problem online yesterday, so I have sent off a paper application for renewal today enclosing a copy of my Irish passport. I am right on the cusp income wise for eligibility and also my current Mutuelle is no longer on the approved list.....

So we will see. Ho hum.


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## Nomoss

Thanks for that, conky2. It will be interesting to see if the change applies to "non-Europeans".


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## conky2

Well Nomoss, maybe I am jumping the gun a bit, but because my last mutuelle weredelisted, I opted for CPAM to administer CSS. They can only have received my application this morning, but at 10:03 this morning, I received and nSMS from them telling me my new direct debit date.........unbelievable !


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## Nomoss

conky2 said:


> Well Nomoss, maybe I am jumping the gun a bit, but because my last mutuelle weredelisted, I opted for CPAM to administer CSS. They can only have received my application this morning, but at 10:03 this morning, I received and nSMS from them telling me my new direct debit date.........unbelievable !


I agree, unbelievable, especially for a CPAM. But that seems to confirm that the new rules apply only to Brits.

I recently had a conversation with an insurance broker, who knows a British Consul quite well.
The Consul told him that Brits are the only ones affected by the new ruling, that it is in response to Brexit, and that it is being appealed, but nothing is likely to change before next year.


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## 1790260

Nomoss said:


> I recently had a conversation with an insurance broker, who knows a British Consul quite well.
> The Consul told him that Brits are the only ones affected by the new ruling, that it is in response to Brexit, and that *it is being appealed*, but nothing is likely to change before next year.


That's very interesting @Nomoss, I'll keep track of that. Keep us updated if you hear more. I'm not an S1 holder but I know many out there are finding this new interpretation a hardship.


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## conky2

My Ameli account notification says they received my application only yesterday and it is being considered.........Hmmmm.


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## Nomoss

Oh. Then maybe the new DD schedule was for payments to your CPAM rather than t your old mutuelle?


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## conky2

Nomoss said:


> Oh. Then maybe the new DD schedule was for payments to your CPAM rather than t your old mutuelle?


No idea. I am confused. I pay my regular 25 euro to my mutuelle on the 5th of each month up to end Nov. I don't make any current payments to CPAM. The SMS I received from CPAM03 on the 5th clearly referenced payments on the 8th. 

I'll have to wait and see.....update to follow!


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## Nomoss

Another theory advanced by my insurance broker is that applications from Brits with residence permits are automatically being refused because it is being incorrectly assumed, in the case of those with WARP's, that their income must be above the CSS ceiling in order to qualify for a residence permit


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## 1790260

I can see that, yes. The assumption that 'regular and stable' means above CSS threshold. Thanks for that little snippet @Nomoss 

I recall back to when we originally arrived in France in 2007, signed up to CPAM and went about our merry way here, nobody ever asked us to prove income levels or savings or the like. It quite surprised me. Wasn't until pre Brexit and the need for a 'carte de sejour' that we were asked.


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## BackinFrance

I have no idea why people here think that Brits are being specifically targeted. The French government is of the view that people are cheating CPAM, and other public organizations and clamping down, including on French citizens. They seem to be singling out all sorts of people and definitely not just Brits.


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## EuroTrash

I suspect it may seem that Brits are being targeted here, simply because I think historically Brits were the ones most likely to adopt the "retire to another country and live off savings" model, and that is the category that is affected in this case. Not sure you can go from there to claiming that the ruling is discriminatory against Brits. The same rules can be applied to anybody that the cap happens to fit be they Italian, French, Dutch or whatever, and equally, there are plenty Brits whom the cap does not fit eg because they've worked in France, who still qualify for CSS. But it will be interesting to see what comes out of the appeal.


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## 1790260

From my perspective, the take-home I see is that the French state generally, and perhaps health system particularly, is starting to look more closely at its spending - and one could understand that in the current climate (and indeed going forward) The cost of COVID and lockdowns, now energy price subsidising, have perhaps understandably enforced belt tightening.

At least, that's the context I see it in due, in part, to my recent dealings with Ameli over CSS. I don't feel targeted in any way but it seems a more vigorous process, if I can put it like that, is in place.


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## EuroTrash

appunti said:


> From my perspective, the take-home I see is that the French state generally, and perhaps health system particularly, is starting to look more closely at its spending - and one could understand that in the current climate (and indeed going forward) The cost of COVID and lockdowns, now energy price subsidising, have perhaps understandably enforced belt tightening.
> 
> At least, that's the context I see it in due, in part, to my recent dealings with Ameli over CSS. I don't feel targeted in any way but it seems a more vigorous process, if I can put it like that, is in place.


Yes I agree. I think belt tightening is very necessary for public finances at the present time. Obviously it has to be done fairly and without discrimination. But I thought we'd established that there is no new ruling here, it's not a Brexit punishment, all that's happening is that an existing ruling is being enforced more rigorously because the public purse has to count the pennies more carefully. Presumably a "memo" has been sent round... 
(That word always makes me giggle - I once had a holiday job as an audio typist, and one of the people whose audio tapes I typed was the catering manager who was very, well in those days we used to call it "camp" but I don't know if you can say that anymore - anyway, he always pronounced it "meemo". His tapes always started, "And now, a meemo to..."


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## 1790260

My apologies, I wasn't intending to imply that there was a new ruling. My feeling is that it is, as you say, a more rigorous process. Perhaps the process previously had a more liberal/lax application? I don't know. Perhaps that 'meemo' has been sent around! I'm sure we've all come across instances of the law and the application the law; the law doesn't change but it starts being policed (or whatever) differently.


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## Nomoss

EuroTrash said:


> I suspect it may seem that Brits are being targeted here, simply because I think historically Brits were the ones most likely to adopt the "retire to another country and live off savings" model, and that is the category that is affected in this case. Not sure you can go from there to claiming that the ruling is discriminatory against Brits.* (1) The same rules can be applied to anybody that the cap happens to fit be they Italian, French, Dutch or whatever, and equally, *(2)* there are plenty Brits whom the cap does not fit eg because they've worked in France, who still qualify for CSS.* But it will be interesting to see what comes out of the appeal.


(1) As far as I know, it still remains to be see whether any other EU nationals have been refused renewal of CSS.
(2) This suggests you know these people - is that the case?

*ET and appunti.*
You both seem to agree that there has been no new ruling, but the relevant text, below, of the refusal notice I received from l'Assurance Maladie suggest that there is a new ruling.
That is, unless you don't regard "_une évolution de la réglementation_" to be a euphemism for a change in the same.

_Vous avez demandé à bénéficier de la Complémentaire santé solidaire le 16/06/2022._
_Après examen de votre dossier, votre demande ne peut pas être acceptée._

_En effet vous bénéficiez de la prise en charge de vos frais de santé sur le territoire français au titre d'un formulaire délivré par l’Etat compétent dans lequel vous possédez des droits. *En raison d'une évolution de la réglementation* cette situation ne vous permet pas de prétendre aubénéfice de la Complémentaire Santé Solidaire.

En cas de désaccord avec cette décision, vous pouvez la contester en formulant dans un délai de deux mois à compter de cette notification un recours auprès de la commission de recours amiable à l’adresse suivante :

Secrétariat de la Commission de Recours Amiable ..................................._


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## Nomoss

I started this topic on May 31st.

In the 3 1/2 months since then there has been no evidence produced that any other EU nationals have had renewals of CSS refused, nor that any Brits who worked here have had renewals accepted.

If I can obtain such evidence I will appeal the decision to the _Secrétariat de la Commission de Recours Amiable, _by the procedure mentioned in the last paragraph of the refusal letter, which I have just added to my previous post, whether or not this is within the 2 month period mentioned.


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## 1790260

Nomoss said:


> *ET and appunti.*
> You both seem to agree that there has been no new ruling, but the relevant text, below, of the refusal notice I received from l'Assurance Maladie suggest that there is a new ruling.That is, unless you don't regard "_une évolution de la réglementation_" to be a euphemism for a change in the same.


I can only speak for myself obviously but I wouldn't _necessarily_ read that phrase as meaning a change in the law. I do see that interpretation however. The truth is that I do not know. 

I would be very interested in the result of the any appeal. That would certainly shed some light on the matter.


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## conky2

Accepted Nomoss. That is as a dual UK born and Irish citizen not yet in receipt of an S1. Bon.


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## Nomoss

conky2 said:


> Accepted Nomoss. That is as a dual UK born and Irish citizen not yet in receipt of an S1. Bon.


Great news for you, and thanks for the info'.

However, as you are are not covered by an S1, I realise now that you are in a different category from ours, although it's odd you were refused when you applied as a Brit.

Are you directly affiliated to the Sécu, either by working in France, or paying the appropriate charge on your foreign income?


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## conky2

Nomoss said:


> Great news for you, and thanks for the info'.
> 
> However, as you are are not covered by an S1, I realise now that you are in a different category from ours, although it's odd you were refused when you applied as a Brit.
> 
> Are you directly affiliated to the Sécu, either by working in France, or paying the appropriate charge on your foreign income?


OK. You are getting a bit technical now Nomoss Firstly to my knowledge I have never been refused as a Brit. I don't recall saying so, but if I did I apologise. The one time I was turned down was because I was deemed to be above the threshold 

Letters written to me tell me that I am affiliated to a régime. I have never worked in France, but at one time did have enough savings to incur a charge, but that ended in 2019.


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## Bevdeforges

I strongly suspect that the phrase you're referring to: "une évolution de la réglementation" may very well be a euphemism for BREXIT. That would certainly explain the claim that "In the 3 1/2 months since then there has been no evidence produced that any other EU nationals have had renewals of CSS refused," plus the notion that far more folks who come from EU countries move to France are working folks, who would be fully enrolled in CPAM and a mutuelle through their employers.

It is also entirely possible that CPAM made a mistake in turning down the CSS renewal because someone saw the "British national" designation, perhaps too soon after having read through the new instructions. If that is the case, it can and will be rectified - but things will go faster if you treat it as a possible mistake rather than a potential "discrimination" against the Brits. Everyone is trying to work their ways through the changes to the regulations that Brexit has caused.


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## conky2

Just as an aside.....I haven't been to see a doctor since I arrived here in 2013. Do CPAM look at the record of your claims when assessing your eligibility ? Kind of like a no claims bonus really. If your just paying in but not taking anything out.......just wondered .


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## Nomoss

conky2 said:


> OK. You are getting a bit technical now Nomoss Firstly to my knowledge I have never been refused as a Brit. I don't recall saying so, but if I did I apologise. The one time I was turned down was because I was deemed to be above the threshold
> 
> Letters written to me tell me that I am affiliated to a régime. I have never worked in France, but at one time did have enough savings to incur a charge, but that ended in 2019.


Sorry conky2, I mistakenly thought that, when you said you had sent a copy of your Irish passport, this was because your previous application was as a Brit. and had been refused because of that.
Looking back at the posts, I now realise that, as happened to me, the online application didn't work, so you applied by mail, as I also did.
I'm not sure why you sent the passport copy, though.

I think the online system only works if the CPAM is able to check all one's sources of income. If not, or if there is any doubt, the system recommends a written application.

Bev.
There is nothing on the CSS application form to indicate nationality except the choice of ticking "française", "europénne", or "autre".

However, our Attestations de Droits show the Code gestion as "70", which indicates we are are covered through our affiliation to the health system of another country, without specifying which country, and there must be a record somewhere there of which country it is.

In fact we both worked longer and paid more health contributions in Spain than in the UK, so I don't understand why our S1's were issued by UK, and not Spain. I'm unsure whether that makes any difference anyway.


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## Bevdeforges

Nomoss:
It's a bit of an oddity for some of us, coming from different backgrounds, but the records here in France really do seem to be much better cross referenced in the State's various computer systems than anything back where I came from. Obviously, they're really only interested in the French/European/Other part - if you check European they can get back to you if they have to.

Where and how long you paid the health system contributions is only of interest as far as the last system you were in before moving to France. It's akin to the idea that you draw your retirement pension through the retirement service of the (European) country you are living in at the time you retire. (Have to admit that, as totally FUBAR'd things are with these "services" in the US, I'm seriously impressed with how well they are coordinated here in the EU.)


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## 1790260

Bevdeforges said:


> I'm seriously impressed with how well they are coordinated here in the EU.


Ditto. I don't know if it extends across Europe but certainly in France. It's all just 'joined up' behind the scenes. I see some might have Big Brother concerns but I see the advantages - and I say that as one, like millions of others - who will be receiving a cheque d'énergie towards the end of the year without having to apply etc.


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## philip17

EuroTrash said:


> On the other hand do you know of any EU citizens resident in France who have been granted CSS since April this year? Though I suspect that there are more Brits with S1s in France than any other nationality.
> 
> But they are. The distinction is not whether they are French or not, the distinction is whether they are directly affiliated to PUMA or not. There could be, and no doubt there are, French nationals who have returned to France after working in another EU country and who hold an S1 from the country where they last worked, and are therefore not entitled to CSS even if on a low income. Equally, EU citizens who are not French but who have worked in France and therefore don't take the S1 route, will continue to be entitled. So the discrimination is not French v. non French, it's direct affiliation to PUMA v. S1, and there will be some crossover.
> Though I do wonder if Brits who are directly affiliated to PUMA will continue to be eligible? Since you say the UK has been removed from the list of eligible countries, maybe we won't.


We have been entitled to CSS since it started and were eligible for its predecessor. We applied to renew it this year, our current mutual contract ends 31.01.2023. We received a letter informing us that our application had been refused. Despite two phone calls to our CPAM they are sticking to their decision even though I explained to them our situation had not changed since our last renewal. I am looking at contesting the decision by writing to the Commission de Recours Amiable, has anyone any more information or ideas. I phoned the embassy in Paris but they were their usual useless self.


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## EuroTrash

philip17 said:


> Despite two phone calls to our CPAM they are sticking to their decision even though I explained to them our situation had not changed since our last renewal.


No, but what has changed, is CPAM's application of the eligibility critera. Their decision in your case seems to be in line with current policy. Which from what one gathers, came down from above and no longer gives discretion for regional decisions.
So I suppose what you would have to do is challenge either the validity the criteria themselves, if you can find some international convention or agreement that you think is being violated, or CPAM's interpretation of those criteria although looking at the wording I thnk it would be hard to make a case. And even if you did argue that the current wording doesn't support their intepretation, then if the conditions for allocation of CSS are a purely domestic decision and not subject to any international obligations then all France has to do is tweak the wording.
Good luck but I don't see there being a quick fix and I'm not sure if the odds are worth turning this into a crusade. You may need to be prepared to let this one go.


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## BackinFrance

EuroTrash said:


> No, but what has changed, is CPAM's application of the eligibility critera. Their decision in your case seems to be in line with current policy. Which from what one gathers, came down from above and no longer gives discretion for regional decisions.
> So I suppose what you would have to do is challenge either the validity the criteria themselves, if you can find some international convention or agreement that you think is being violated, or CPAM's interpretation of those criteria although looking at the wording I thnk it would be hard to make a case. And even if you did argue that the current wording doesn't support their intepretation, then if the conditions for allocation of CSS are a purely domestic decision and not subject to any international obligations then all France has to do is tweak the wording.
> Good luck but I don't see there being a quick fix and I'm not sure if the odds are worth turning this into a crusade. You may need to be prepared to let this one go.


It's unwinnable now because a, there is no available funding, b, the government has now pushed everything related to CPAM through via s. 49.3, and c, it's not just Brits who are negatively impacted. Indeed I could come up with other reasons if I took the time to put my head around it.

France is actually already very generous in providing CPAM cover to anyone who has been in France legally for 3 months, but also applies the same requirement to French citizens returning to live in France if they don't qualify for cover via a French pension.

Why anyone would even want to push the issue at a time when the French health system is in total crisis is beyond me.


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## Bevdeforges

Be careful on this one. I see lots of references to tweaking specific wording and parsing the language of the regs to try to squeeze through. French law simply does not work that way. 

And BiF has a very valid point. The current budget for CPAM and the health services is set in stone for the time being and is already recognized as being inadequate for the biggest "challenges" facing the system. There is a quick and fairly simple solution to all this and that is to enroll in a standard mutuelle cover asap. You can contact your bank (which would just LOVE to sell you this sort of insurance) or an insurance agent or broker. That will at least give you cover for the coming year while you research what your options are.


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## EuroTrash

And there was me trying to sugar coat the pill and let the poster down gently 

But yes it's probably best to be blunt. France simply can't afford to carry on being generous to people who are technically the responsibility of a different national health serviceand who don't and never have (or not lately) contribute(d) to the French system.
Be glad of past generosity, rather than feeling bitter that it has come to an end


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## Nomoss

As I believe I have said before, France should be able to reclaim the cost from the UK for CSS for Brits, as the UK engages to pay the health costs of Brits with S1's at the same level as a French person who has contributed would be covered.
Any such French person is automatically entitled to this extra cover from l'Assurance Maladie if their income is below a certain amount, so billing the cost to the UK for Brits with similar incomes seems to be covered in fact and in the spirit of the agreement.
The ability of the French system to cover the cost is not relevant.


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## BackinFrance

Nomoss said:


> As I believe I have said before, France should be able to reclaim the cost from the UK for CSS for Brits, as the UK engages to pay the health costs of Brits with S1's at the same level as a French person who has contributed would be covered.
> Any such French person is automatically entitled to this extra cover from l'Assurance Maladie if their income is below a certain amount, so billing the cost to the UK for Brits with similar incomes seems to be covered in fact and in the spirit of the agreement.
> The ability of the French system to cover the cost is not relevant.


Did you make that up, or are you not aware that there is an agreement between France and the UK that sets out a fixed payment for each S1 holder as opposed to paying the actual health care costs of each S1 holder?


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## EuroTrash

Nomoss said:


> As I believe I have said before, France should be able to reclaim the cost from the UK for CSS for Brits, as the UK engages to pay the health costs of Brits with S1's at the same level as a French person who has contributed would be covered.


The flaw in that argument though is that the majority of people who have paid in to PUMA, are not entitled to this benefit. They either have a mutuelle via their employment, or they fund their own, or they simply take the standard reimbursement, 70% or whatever, and pay the rest out of their own pocket. Under current legislation he French national healthcare system PUMA operates on the basis of copayments. So it rather depends on how you define 'at the same level as..." (I don't think you can say "at the same level as a French person" though, because it's not about nationality).
CSS is a separate benefit with a separate application process. It doesn't change people's entitlements under PUMA, it complements them. CSS could be withdrawn altogether, or replaced by something else, or even enhanced to cover more people, without affecting PUMA's legislative framework. So, whether other EU states can be obliged to reimburse for a benefits scheme set up by France outside the framework of PUMA, would I suppose depend on the wording of the agreement which I haven't read. Does it apply to all costs related to healthcare whether directly or indirectly, or does it apply only to actual direct healthcare costs provided for under the national healthcare framework?

BiF, I do seem to recall reading that the agreement between the UK and France (? dunno whether with all EU states or just bilaterally with Frace) was renegotiated some years back so that these days actual costs are reimbursed, rather than the fixed annual per person payment that other EU countries continue to operate. But I couldn't say with any confidence whether this is still the case, or indeed ever was.


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## Nomoss

BackinFrance said:


> Did you make that up, or are you not aware that there is an agreement between France and the UK that sets out a fixed payment for each S1 holder as opposed to paying the actual health care costs of each S1 holder?


No madame, I didn't make that up.
The UK used to pay a fixed amount until a few years ago when France negotiated a new agreement where the UK paid the actual costs.
I notice that ET has just made the same point whilst I was replying.


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## conky2

Nomoss said:


> No madame, I didn't make that up.
> The UK used to pay a fixed amount until a few years ago when France negotiated a new agreement where the UK paid the actual costs.
> I notice that ET has just made the same point whilst I was replying.


I'm sure BiF is typing out her most humble apology as we speak and has disengaged her lawyer.


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## BackinFrance

Nomoss said:


> No madame, I didn't make that up.
> The UK used to pay a fixed amount until a few years ago when France negotiated a new agreement where the UK paid the actual costs.
> I notice that ET has just made the same point whilst I was replying.


Well that must be a major bureaucratic nightmare that costs more to put the information together and attach the justifying documents than France would actually receive from the UK (once the payment is actually made by the UK and which of course would necessarily be in arrears. 

Anyway the CSS would not fit under the heading of actual health care costs and that is very likely why it is being denied.


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## Nomoss

BackinFrance said:


> Well that must be a major bureaucratic nightmare that costs more to put the information together and attach the justifying documents than France would actually receive from the UK (once the payment is actually made by the UK and which of course would necessarily be in arrears.
> 
> Anyway the CSS would not fit under the heading of actual health care costs and that is very likely why it is being denied.


I agree, but It's very French, and also the comment several people made on forums, possibly including this one, when the change was made, I think going on 10 years ago.
It does have the advantage of helping provide employment for the bureaucracy though.

Re actual health care costs, that is exactly what l'Assurance Maladie pays direcly to the health provider via CSS.


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## conky2

conky2 said:


> I'm sure BiF is typing out her most humble apology as we speak and has disengaged her lawyer.


Or perhaps not.


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## EuroTrash

Nomoss said:


> Re actual health care costs, that is exactly what l'Assurance Maladie pays direcly to the health provider via CSS.


Ah maybe I have misunderstood CSS then, because I thought that basically it operated by arranging a complementary assurance for you with a selected provider who will reimburse copayments in full, with the annual affiliation premium either fully absorbed by CSS or with a small contribution from the insured, depending on income. But if that was correct, then assurance maladie would not be paying actual healthcare costs direct to the healthcare provider, the payments would be made by the CSS organism which is different I think. Isn't it a bit of an oxymoron to say that something is paid "direct" "via"?
As distinct from ALDs where you are also covered 100% but ALD cover is provided within the PUMA framework, assurance maladie does indeed pay the full costs to the health provider direct and not via a different caisse, and can reclaim them from the competent state. So there's no question of S1 holders getting their ALDs.

I had assumed that that is why France has been unable to recover these costs (because presumably they would if they could, and presumably they have tried and been knocked back, otherwise why would they have adopted this policy)..
So how does CSS work, please?



Nomoss said:


> I agree, but It's very French


Is this a specific Fr-UK thing? Or is it an arrangement between the UK and all EU states, or between France and all EU states?
I must admit that I assumed it was at the request of the UK, simply because it used to tend to be the UK that wanted special arrangements and exceptions.


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## BackinFrance

Nomoss said:


> I agree, but It's very French, and also the comment several people made on forums, possibly including this one, when the change was made, I think going on 10 years ago.
> It does have the advantage of helping provide employment for the bureaucracy though.
> 
> Re actual health care costs, that is exactly what l'Assurance Maladie pays direcly to the health provider via CSS.


No, CSS is assistance with health care) mutuelle) insurance and not health as SD such. It is a very different thing.


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## BackinFrance

If people aren't happy, perhaps they should take it up with the UK government. But the UK government is silent about the CSS on it's website - dig deep enough and they just tell you that you can take out top up insurance, but no reference at all to the CSS.


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## Nomoss

BackinFrance said:


> No, CSS is assistance with health care) mutuelle) insurance and not health as SD such. It is a very different thing.


The CSS is not a mutuelle. The co-payments are made by L'Assurance Maladie directly to the care providers.
The redacted copy of an AM statement below shows the total cost being paid directly to the providers by AM.

Because of the mechanism for dealing with co-payments, where the providers bill the co-payments separately, there is a mechanism where they are charged to AM as if it were a mutuelle. The paperwork for this can be handled by a mutuelle provider or directly by one's CPAM, a choice made by the individual covered by CSS.

The advantage of choosing a mutuelle to handle the co-payments is that if the individual subsequently ceases to be covered by CSS, the mutuelle is obliged to offer cover at "a preferential rate". Read "we will pass business to the mutuelle".



BackinFrance said:


> If people aren't happy, perhaps they should take it up with the UK government.


I agree (!)
I'm hoping the people I mentioned in my post no.29 are doing just that.


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## EuroTrash

I think I understand what you are saying but I cannot see how the document confirms that.
It says clearly at the top Ce document regroupe les paiements effectués par votre caisse d'assurance maladie et ceux de votre organisme complémentaire, which seems to me to be saying that it is combining payments from two sources, Then the payments are shown in two columns, one being the percentage covered under PUMA, which is paid by CPAM, and the other being the copyament not covered by PUMA, and since the payments column is headed montant comp (presumably short for complémentaire); one would assume this column to be a list of payments made by the organisme complémentaire. You are saying that in fact all the payments are funded by CPAM but unless I'm missing something there is nothing on this document to indicate that. 

The sticking point for me though continues to be the fact that there are copayments. Copayments - regardless of who pays them - are by definition costs that PUMA does not cover, aren't they? So if the agreement is limited to costs that covered by PUMA, then these are not. If the agreement extends to all healthcare costs, then I agree they should be covered.


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## Nomoss

My "mutuelle" is the Complémentaire Santé Solidaire which is a government entity funded through l'Assurance Maladie.
To me that means it is part of the French Social Security system.
That is why the payments are combined and paid by the same organisation.

The heading on the statements is l'Assurance Maladie, not PUMA, which is presumably another government entity within the SS system..

To clarify another point, "CPAM" is the Caisse Primaire d'Assurances Maladies - the local department level of the national health insurance administration, there are separatee CPAM's in each department. So when referring to them one should say "your, my, etc." CPAM


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## BackinFrance

PUMA is not an entity, it is merely the term applied to the system run by CPAM. 

BTW I think you need to be aware that income streams taken into account for determining eligibility to the CSS have become extremely broad and include such things as interest from non taxable livrets, all government payments you receive including at least most of those that are means tested, etc.


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## EuroTrash

Nomoss said:


> The heading on the statements is l'Assurance Maladie, not PUMA, which is presumably another government entity within the SS system..


PUMA isn't an entity, it's the name of the national health service "dispositif" defining the rules under which all the CPAMs and other various caisses operate.

I thought CSS was also a scheme rather than an entity. If you say it is an entity, that probably goes some way to explaining why we haven't been seeing eye to eye.

Are you sure it is funded 100% by the government, do you have a source for this? because the below link rather suggests otherwise








Taxe Covid, Complémentaire Santé Solidaire : la Mutualité Française alerte sur la situation des Français les plus fragiles


Alors qu’un 1er bilan de la complémentaire santé solidaire (CSS) vient d’être dévoilé, la Mutualité Française alerte sur le financement de ce dispositif et rappelle qu’elle s’est toujours opposée à toute forme de taxe Covid qui pèserait sur le budget des Français dans un contexte de crise...




www.mutualite.fr




"La Mutualité Française souligne que la CSS, qu’elle soit participative ou non, est financée à 100% par les complémentaires santé via une taxe de 13,27 euros pour 100 euros de cotisations, et par les efforts des mutuelles gestionnaires en raison d’un financement insuffisant de l’accompagnement des bénéficiaires."

The same press release also seems to be saying that participative CSS means mutuelle cover
"Fin mars 2021, 1,4 million de personnes étaient couvertes par la CSS avec participation financière, un dispositif qui permet aux bénéficiaires d’avoir accès à une couverture complémentaire santé à moindre coût."

Anyway I'm done thinking about this now, I don't know why I'm even looking it up apart from curiosity to drill down into how it all works, but please post back with any news, it'll be interesting to see how it turns out. Happy New Year y'all.


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## Nomoss

Thank you ET. That does cast light on the financing of the CSS and why they want to reduce it.

It may also explain why the _mutuelle gestionnaire_ previously handling our CSS is no longer willing to do so.

It also seems that now, we have not only been refused the CSS, but are helping fund it to the tune of 13.27% of the payments for our mutuelle.


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## BackinFrance

I'm done with this too. Happy New Year to one and all, let's hope it's a better one than 2022


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## Bevdeforges

And with that, I'm going to close out this thread.


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