Non-calendar year health coverage exemption

Taxpayer began working for an employer in late 2013 that offered a health plan that ran 6/1/2013-5/31/2014. Taxpayer chose not to enroll in the plan, left that employer in the middle of May 2014, joined another employer the same month, and after a typical waiting period was covered under the new employer's health plan as of July 2014. Taxpayer therefore had minimum essential coverage only July-Dec 2014, but had enrolled in such by June.

If I understand correctly, the taxpayer is eligible for exemption H on Form 8965 for at least some months of 2014: "You were eligible, but did not purchase, coverage under an employer plan with a plan year that started in 2013 and ended in 2014." Is that your understanding also?

The question is, which months does the exemption apply to? I would think the months the plan ran, i.e. Jan-May. (But what if the taxpayer left the employer in January and never got coverage elsewhere? Would the H exemption still run through May?)

Does June count as minimum essential coverage, as the taxpayer had enrolled in coverage and was just waiting for it to start? The taxpayer would not have been able to go to the doctor during June and have it covered under the plan, so I wouldn't consider it "coverage".

If June is neither eligible for the H exemption, nor counts as minimum essential coverage, then does the B exemption apply for that month? I would think not, by the plain language of that exemption: "You went without coverage for less than 3 consecutive months during the year." However, the software I'm using automatically generates a B exemption for June with no apparent way to remove it, when I put in an H exemption for Jan-May, and minimum essential coverage July-Dec.

Either the software has a bug, or its authors interpret the B exemption as "without coverage or exempt from coverage for less than 3 months". How do you interpret it?

Thanks, Lee

Reply to
Lee Choquette
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You are correct. It is transition relief for 2014 only. It was published in IRS Notice 2013-42 at

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The relief is for the period up to the end of the plan year. In this case it would be for Jan. thru May.

The exemption does not cover June.

The Notice clearly states that "Any month in 2014 for which an individual is eligible for the transition relief provided by this notice will not be counted in determining a continuous period of less than 3 months for purposes of the short coverage gap exemption described in § 5000A(e)(4). Therefore, The month of June is less than 3 months and is eligible for the short-gap exemption.

Reply to
Alan

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