Not really. The point of the requirement is to subsidize the health care you will get if they find you unconscious, naked in a ditch without ID and can't tell if you are wealthy enough to pay or not.

Absent insurance, that privilege is paid for by the higher prices charged to people unlucky enough to need healthcare.

Now, if you can't get plans that consider the fact that you are only in the US for < 100 days a year, then yes it's harsh.

As an American that lives abroad, whenever I visit the US I make sure I always have traveler's insurance for myself and all my dependents that are traveling with me. Last year I was in the US for a over 100 days, and my traveler's insurance was valid for every second.

It shouldn't matter how many days you are in the US or not, it should matter where you declare your tax home.

Given that the answer links to a document on tax status for expat citizens, I wouldn't be surprised if it has more conditions that work out about the same as tax status. (i didnt read the linked doc to find out).

Or the travelers insurance should count as health insurance in terms of that mandate. Does it?

Just a guess, but I don't think it will. The policy and all documents are not in English, and no reason for them to be either.

So if they make an exemption for travelers insurance, it will be hard for them to verify that it meets the criteria of the exemption.