Reciprocal healthcare fraud

Fraudulent use of European Health Insurance Cards (EHICs), Global Health Insurance Cards (GHICs), Provisional Replacement Certificates (PRCs) and various other reciprocal healthcare arrangements. Also, false representation during the application stage.

Reciprocal healthcare encompasses fraudulent use of European Health Insurance Card (EHIC), Global Health Insurance Cards (GHIC) Provisional Replacement Certificates (PRCs) and various other reciprocal healthcare arrangements. It also includes false representation during the application stage which can enable the card / certificate holder to benefit from a reciprocal healthcare agreement.

The financial vulnerability estimate has been improved through a continued collaborative approach with policy holders to maintain a more accurate and up-to-date figure. The estimate only encompasses EHIC, GHIC and PRC expenditure, it does not include the S1p scheme, the smaller S2q scheme or other reciprocal healthcare agreements.

The claims issued, the costs of an EHIC/GHIC application and percentage of fraud and error have increased when compared with the previous year.

£824,000

vulnerable from an expenditure of £154.8 million

Strategic intelligence picture

It is likely that some individuals, although eligible at the time of application, will fail to declare their change in circumstances when they move abroad permanently and will continue to use their UK issued EHIC/GHIC, including for planned care upon refusal of an S1 or S2.

Submitting a fraudulent application for a GHIC was also probable, with applications being made using the details of another individual.

It is likely for applications for EHIC/GHICs to come from individuals without eligibility who are permanently residing outside of the UK. This is likely enabled through use of a UK address to prove ordinary residence and a location to which the card can be dispatched, whilst an associate still residing at the address can pass on letters and parcels. As a result, the individual will be provided with UK insured healthcare for up to 5 years through an UK EHIC / GHIC whilst permanently residing abroad.

There is a realistic possibility that a trust may receive a fraudulent email impersonating an Overseas Visitor Manager (OVM). Individuals may attempt to falsely present to the trust that an OVM has confirmed the cost of care would be covered by the patients EHIC.

It is almost certain that the European Union (EU)/European Free Trade Association (EFTA) will reject some UK invoices due to fraud or error because of incorrect or missing information on the E125 form, and in some cases the individual cannot be identified. Duplications of claims or invoices are also reported to be a problem. In some cases, EHICs have expired, and individuals are not insured during all or some of the treatment period.

Information reports received for reciprocal healthcare fraud

The change in the number of fraud reports received in relation to reciprocal healthcare from 2020 - 2021 to 2024 - 2025 is illustrated in the below chart:

Table showing the annual reporting trends for reciprocal healthcare fraud between 2020 - 2025
2020 - 2021 2021 - 2022 2022 - 2023 2023 - 2024 2024 - 2025
2020 - 202121 2021 - 202211 2022 - 20234 2023 - 20247 2024 - 20256

Horizon scanning

It is likely applications for UK EHIC/GHICs have previously been made from outside the UK even though it is a scheme based on ordinary residence unless there is an exemption. Tariffs imposed on trading partners by the United States of America could impact on healthcare costs, causing them to increase and be passed on to USA patients. Therefore, although, the threat is considered low, as cards would need to be sent to a UK address and applicants provide false evidence of UK residency, there is the potential for false GHIC/EHIC applications from those who are ordinarily resident in the USA.

Additionally, the media reports that the pharmaceutical industry is profoundly reliant on USA trade, with ingredients for life-saving medicines travelling between the USA, UK and EU. Tariffs on medical items could cause charges which are not factored into pricing caps within the NHS, potentially leaving the NHS further out of pocket when someone falsely represents themselves as entitled to care under a reciprocal healthcare agreement.

  1. Provides healthcare to eligible individuals living in an EU or EFTA country and constitutes the majority of reciprocal healthcare expenditure.
  2. Provides planned treatment in EU or EFTA countries for UK residents.

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