Medical Insurance Requirements for Work Permit and S Pass Holders

If you employ foreign staff on Work Permits or S Passes, buying work permit medical insurance is not optional. The Ministry of Manpower (MOM) makes it a condition of the pass, and getting it wrong can leave your business exposed to large hospital bills, penalties and problems renewing passes. This guide explains what MOM requires, how the coverage and co-payment rules generally work, what employers remain responsible for beyond the policy, and how to manage it in practice.

It is general information, not legal or insurance advice. MOM reviews these requirements from time to time, so check the current rules on the MOM website and read your policy wording carefully. Separate rules apply to migrant domestic workers, which we cover in our guide to mandatory medical insurance for your domestic helper.

What MOM Requires From Employers

For Work Permit and S Pass holders, employers must generally:

• Buy and maintain medical insurance for each worker that meets MOM’s minimum coverage for inpatient care and day surgery, for the whole period the worker holds the pass.
• Pay the insurance premiums themselves. You cannot pass the cost of the premium on to the worker or deduct it from their salary.
• Bear the cost of the worker’s medical treatment, generally including treatment not fully covered by the insurance, subject to the co-payment rules MOM allows.
• Make sure the policy is in place before the pass is issued or renewed, as MOM checks this as part of the application.

MOM enhanced the minimum coverage requirements in 2023, raising the amount of coverage required and introducing a co-payment structure between insurers and employers for larger bills. The exact minimum amounts, the threshold above which co-payment applies and the share each party pays are set by MOM and may change, so confirm the current figures on the MOM website and with your insurer before you buy or renew.

How Coverage and Co-Payment Work in Practice

The mandatory policy is mainly about inpatient and day surgery costs, the large bills that come from a hospital stay or procedure. Outpatient visits, such as a GP consultation for flu, are generally not what this mandatory insurance is designed for, even though employers usually remain responsible for those costs under the pass conditions.

Key ideas to understand:

• Annual limit. The policy pays up to a minimum annual amount per worker. Bills above that are generally the employer’s responsibility.
• Insurer and employer co-payment. For larger claims, MOM’s framework sets out how much the insurer must pay and how much the employer bears. Check your policy schedule for the exact split.
• Employee co-payment. Employers may, in limited circumstances, ask workers to share some medical costs, but only within strict limits set by MOM and only if properly agreed, typically in the employment contract. You cannot make a worker pay for the insurance premium itself, and any co-payment must not exceed MOM’s caps. Read MOM’s guidance closely before including any co-payment clause.
• Exclusions. Policies list conditions or situations they do not cover. Your obligation to pay for the worker’s necessary medical treatment may continue even if an item is excluded, so understand the gaps.

The Different Insurances Employers Often Confuse

Employers of foreign staff often deal with several types of cover. They serve different purposes and are not substitutes for one another.

Type of cover	Who it typically applies to	What it is for
Mandatory medical insurance (MOM)	Work Permit and S Pass holders	Inpatient and day surgery costs, as a condition of the pass
Work injury compensation insurance (WICA)	Employees doing manual work, and non-manual employees earning up to a salary threshold set under the Work Injury Compensation Act	Compensation and medical costs for work-related injuries and diseases
Primary Care Plan	Certain migrant workers, such as those living in dormitories or working in specified sectors	Access to primary care such as outpatient consultations and telemedicine, through MOM-approved providers
Security bond	Non-Malaysian Work Permit holders (and some other cases)	A guarantee to MOM that the employer will meet pass conditions, not a health insurance

A few points to note:

• WICA is separate. If a worker is injured on the job, the Work Injury Compensation Act (WICA) process applies, not the mandatory medical insurance. Check MOM’s guidance on who must be covered.
• The Primary Care Plan applies only to specific groups, so check whether your workers fall within it.
• The security bond is not insurance. See our guide to the Work Permit security bond for how it works.

Setting Up and Managing Cover Properly

A simple, repeatable process reduces the risk of lapses:

1. Compare policies from insurers that offer MOM-compliant plans. Check that the plan meets MOM’s current minimum coverage and co-payment structure, and compare exclusions, claims processes and hospital panels, not just premiums.
2. Buy cover before applying for or renewing the pass. Align the policy period with the pass validity.
3. Keep records. Store policy numbers, schedules and renewal dates for every worker in one place. A simple spreadsheet or HR system reminder helps.
4. Brief your workers. Tell them they are covered, what to do if they need hospital care, and who to contact in the company. Provide information in a language they understand.
5. Handle claims promptly. Hospitals may ask for a letter of guarantee from the insurer or employer before admission. Know your insurer’s process so treatment is not delayed.
6. Review on renewal. Check whether MOM requirements have changed and whether your plan still meets them.

If a worker changes employer, cancels their pass or is repatriated, follow MOM’s procedures, and check with your insurer how the policy ends and how any ongoing treatment is handled.

Common Mistakes Employers Make

• Assuming insurance covers everything. Employers usually remain responsible for necessary medical treatment beyond what the insurer pays, within MOM’s framework.
• Deducting premiums from salary. This is not allowed and can lead to enforcement action.
• Letting a policy lapse between pass renewals, leaving a gap in coverage.
• Mixing up WICA and medical insurance, leading to delays when a worker is hurt at work.
• Ignoring outpatient and dental needs. Even if not covered by the mandatory policy, your workers still need access to care. Some employers add outpatient cover as a benefit to support wellbeing and retention.
• Not reading the policy wording. Exclusions, panels and claim deadlines vary between insurers.

Where This Fits With Other Pass Requirements

Medical insurance is one part of the wider set of conditions for employing foreign staff. Workers may also need a medical examination as part of their pass application, and you must comply with levy, quota and housing rules where they apply. Our guides to health checkups for work pass holders and Work Permit eligibility and conditions explain these related obligations.

For the most up-to-date requirements, check the Work Permit and S Pass sections of the MOM website, speak to your insurer or broker, and keep your own records current. Getting work permit medical insurance right protects your workers, your cash flow and your ability to keep hiring the staff your business depends on.

Official sources: Ministry of Manpower (MOM)