ACA penalty if unpaid COBRA

[StacheOfInnerPeace]

Instead of trying to make a generalized question, I will give you my specific situation (question) and hopefully others can learn from this too:

I have had intermittent (but most months) 1099 independent contractor income all of 2015.

I was also a W-2 employee from Jan 1 to Jun 30, 2015. This company provided health insurance until the end of my employment (Jun 30).

I moved in July from the east coast to California.

I obtained ACA compliant health insurance in the marketplace when I was in California. The coverage officially started October 1, 2015 (and the Form 1095-B I just received has check boxes in Oct through Dec).

Am I at risk for an ACA non-compliance penalty?

I was under the -- perhaps mistaken -- assumption that July and August would be "under COBRA", even though I didn't pay the COBRA fees or file the paperwork (I was only going to do so if I actually needed the coverage during the COBRA period, as I have done in the past before the ACA times).

Does anyone know the answer or have any advice?

Thanks,
SoIP

[DevoCPA]

google health coverage exemptions, I bet you qualify for one. Worst case your penalty will be small

[Altons Bobs]

There would be no penalty if you didn't have coverage for less than 3 months out of the whole year.  Your COBRA eligibility period did not count as coverage because you actually didn't have coverage.  If you didn't have coverage for 3 months or more, then you would owe the penalty.  Since you didn't have coverage in July, August, and September, you would owe penalty for the 3 months of you not having coverage.

The exemption is only for people whose MAGI was below 100% of the Federal Poverty Level, if your 2015 MAGI was above that, you would still owe the penalty.

[Axecleaver]

It's a penalty of 3/12ths of 2% of your MAGI, or 0.5% of your income. If you had been uncovered for two consecutive months instead of three, you would be covered under the short gap exemption. If you made 100k last year, and your MAGI is 80k, that's a penalty of $400.

Source: https://www.healthcare.gov/fees/fee-for-not-being-covered/

[StacheOfInnerPeace]

Thanks for the replies...unfortunately the response I expected.

SoIP