In 2015, employers with 100 or more full-time employees are required to offer affordable, minimum value health insurance to their full-time employees and dependents.  On May 13, 2014, the IRS released FAQs detailing employer requirements for offering dependent coverage.

An employer will be liable for a shared responsibility penalty only if a full-time employee enrolls in coverage through an exchange, and receives a subsidy to help pay for exchange coverage.  An employer is not liable if a full-time employees’ dependents enroll on the public exchange and receive a subsidy.

Additionally, an employer that takes steps during the 2014 and 2015 plan years to offer dependent coverage will not be subject to a penalty for failing to offer dependent coverage for that plan year.

This transitional relief only applies to employers that do not currently offer dependent coverage, only coverage not considered minimum essential coverage is offered to dependents, or dependent coverage is offered to some but not all dependents.  This relief is not allowed for employers that previously covered dependents in the 2013 or 2014 plan year and subsequently dropped that offer of coverage.