As of January 1, 2014, the Act’s “individual mandate” requires individuals who are not otherwise exempt to either maintain MEC for themselves and their non-exempt family members, or pay a shared-responsibility payment with their federal tax returns (the “Mandate Payment”). MEC includes coverage under an eligible employer-sponsored plan (an “Eligible Plan”), such as a group health plan. An individual may be unable to enroll in coverage by January 1, 2014 under an Eligible Plan with a non-calendar plan year if the plan prohibits mid-year enrollments absent the occurrence of a designated change-in-status event. The IRS recently issued Notice 2013-42, which provides relief from the Mandate Payment for certain individuals who are eligible to enroll in an Eligible Plan with a non-calendar plan year that begins in 2013 and ends in 2014.
A copy of IRS Notice 2013-42 is available here.