But then your statement that the Secretary doesn't recognize the NHS as minimum essential coverage isn't really relevant. It's not that NHS coverage doesn't count as coverage for overseas citizens. It's that a US citizen living overseas must meet the requirements to be exempted from the penalty.
Yes, I think you understand. It's relevant since it is important that others understand meeting the requirements of Section 911 (Bona Fide residence or Physical Presence) and filing form 8965 is needed to avoid the penalty, and that NHS coverage does not constitute "minimum essential coverage" (tick box on line 61) for a 1040 return.
It's a curious situation since those submitting a form 2555 (FEIE) would meet the requirements of Section 911, but they still need to file a 8965 for ACA (?).
Others may have continuing coverage from an ACA qualified US employer plan and can tick the box on line 61, 1040 (retired with continuing coverage, for example).