Employers must provide qualified health plans from a Small Business Health Options Program Marketplace employees to qualify for the credit. Small employers may only claim the credit for two consecutive years.

If employers have locations in areas in which marketplace plans are not available, the relief enables them  to claim the credit for coverage provided outside of a marketplace for the remainder of the credit period if that coverage would have qualified under the rules that applied before Jan. 1, 2014.

Guidance for calculating credits under these circumstances is made under Notice 2018-27. It does not affect previous transition relief for the credit that was separately provided for 2014, 2015, and 2016.