When the allowance decision opens the right to a free policy, and when it can take it away
The inclusion allowance and supplementary health insurance are governed by different acts and decided by different bodies — the allowance by the Croatian Institute for Social Work, the policy by the Croatian Health Insurance Fund. In practice they are closely linked: the same inclusion allowance decision can open the right to a policy paid from the state budget, but it can also take it away. Which of the two happens depends on the basis on which the policy is claimed.
Two routes to a state-funded policy
The Voluntary Health Insurance Act provides that the state pays the supplementary insurance premium for certain groups of insured persons. For inclusion allowance beneficiaries two routes matter, and they differ substantially:
- On the basis of impairment — for persons with disabilities with 100 % bodily impairment, persons in whom more than one type of impairment has been established, and persons with a physical, mental, intellectual or sensory impairment that prevents them from independently performing activities appropriate to their age. Income is not examined on this route.
- On the basis of income — for persons whose total income in the previous calendar year, expressed monthly per family member, does not exceed the prescribed threshold. The threshold is adjusted every year.
When the inclusion allowance costs you the free policy
The Inclusion Allowance Act provides that the allowance is not considered income — but it ties that exception to the social welfare legislation. For supplementary insurance, income is determined under the Voluntary Health Insurance Act, which also counts receipts obtained under special regulations. The Croatian Health Insurance Fund therefore takes the position that the inclusion allowance is counted as income when the right to the policy is assessed on the income basis.
The consequence is that a beneficiary who until now had the policy because of low income may, once the allowance is granted, exceed the threshold and lose the right — even though their health has not changed and their medical costs have not fallen. Where the allowance amounts to several hundred euros a month, this is a common outcome, especially in smaller households.
When the inclusion allowance decision opens the right
The other side of the same story is favourable. The impairment route does not depend on income, and impairment is precisely what is established by expert evaluation in the inclusion allowance procedure. According to the Fund’s position, an inclusion allowance beneficiary in whom the expert evaluation body has established a third or fourth degree of impairment of functional abilities obtains the policy at the expense of the state budget regardless of the amount of the allowance and of the family members’ income. Likewise, the mere fact that the decision establishes more than one type of impairment is a basis for recognising the right.
This is where the two systems meet directly. An adult receiving the inclusion allowance at the first, second or third support level already has a third or fourth degree of disability severity established, because that is a condition for those levels — so the income threshold is usually not needed at all. For most categories at the higher support levels an additional difficulty is also required alongside the main impairment, so the findings regularly establish more than one type of impairment as well.
The most exposed are beneficiaries at the fourth and fifth support levels, especially those with a second degree established. For them the impairment basis often does not cover the case, while the allowance is counted as income — so they depend on the income threshold, which the allowance itself may have brought them close to or pushed them over.
The allowance decision is not an automatic policy
The right to the policy does not arise merely because an inclusion allowance decision has been issued. The Fund decides on it in a separate procedure, on application, and the applicant must show the basis relied on. The inclusion allowance decision and the findings and opinion of the expert evaluation body are key evidence here: they show the degree of impairment and the number of types of impairment established.
That is why it matters to claim the policy on the right basis. Anyone who out of habit keeps relying on low income, while having a third or fourth degree or more than one type of impairment established, risks a refusal that was never necessary.
In practice
- If the policy ended after the inclusion allowance was granted, check the reason — whether the right was assessed on the income basis.
- In the findings and opinion of the expert evaluation body, check the degree of impairment established and whether more than one type of impairment was established.
- If so, apply on the impairment basis and attach the inclusion allowance decision and the findings and opinion.
- A support level or degree of impairment set too low affects not only the amount of the allowance but also the right to the policy — an additional reason to appeal in the inclusion allowance procedure.
- Against a Fund decision refusing the application, the remedies of administrative procedure are available, followed by an administrative dispute.
If your supplementary insurance policy ended after the inclusion allowance was granted, or your application was refused, our office can assess on which basis you can obtain the right and prepare the appropriate remedy.