According to IRS Notice 2013-42, for non-calendar year
Medical Plans, transition relief is available for those plans that begin in
2013 and end in 2014. If your coverage is available through an employer, depending upon when that coverage is made
available to you (or your spouse) would depend upon when you would need to
obtain coverage.
Example 1. You are eligible for enrollment in a non-calendar
year employer sponsored medical plan beginning August 1, 2013 and ending July
31, 2014. You have parent/child coverage
for you and your 10-year old son. You do
not elect coverage for yourself/son on August 1, 2013. Under this rule you would have transition
relief through July 31, 2014. If you do
not elect coverage at this time, penalties would be assessed.
Example 2. You are Married and both you and your spouse are
eligible for enrollment in a Non-Calendar Year Plan of an Employer for the
2013-2014 Plan Year and in a Calendar Year Plan with your Spouse’s Employer for
2014. Your plan begins August 1, 2013
and ends July 31, 2014. Your spouses plan
begins January 1, 2014. You do not elect
coverage for you and your spouse under your plan August 1, 2013 and your spouse
does not elect coverage for the both of you on January 1, 2014. In this example
both you and your spouse would have transition relief until your plan renewal
in August of 2014. If at this time, no
coverage was elected, penalties would be assessed.
(From IRS Notice 2013-42)
