Question: Let’s say a group currently offers coverage and the renewal date is September 1. Let’s also say that the coverage they offer does not currently meet the affordability test but that they plan to make changes so that it will meet the affordability test come 9/1/14. Are the employees of that group eligible to receive a subsidy on the exchange from 1/1/14 through 8/31/14?
Answer: Yes. The employees of your hypothetical group can be eligible for advance premium tax credits in the individual exchange as long as they do not have access to affordable coverage,