I have received a number of additional inquiries about IRS Notice 2013-14. Specifically, readers want to know if under the Notice, the affected employees are still required to complete IRS Form 8850 on or before the day they are offered a job.
Answer: I do not know for sure but until further guidance is given must assume that, Yes, employees with hire dates affected by Notice 2013-14 are still required to have completed the form on or before the day of their job offer.
Having said that, I am looking further into this issue.