1095-C Reporting for COBRA

[Chaz]

Can anyone provide some guidance on how (or whether) a employer sponsor of a self-insured plan reports on Form 1095-C with respect to employees who terminated employment prior to 2015 but participated in the plan by reason of COBRA for all or a part of 2015? Are they reported the same way as employees who terminated in 2015 are reported for the portion of the year in which they were on COBRA? Thanks.

[GMK]

​page 10 of this help?

https://www.irs.gov/pub/irs-prior/i109495c--2015.pdf

COBRA coverage due to termination is not reported

COBRA coverage while still employed (e.g., reduced hours) is reported

[Chaz]

I don't think that the instruction is saying that a terminated COBRA is not reported. The employee IS reported, but with a Codes 1H and 2A for those months in which the COBRA offer applies. Is that how an employee (for whom may payroll providers no longer have records for) who terminated in 2014 but who elected COBRA should be reported?

[GMK]

You are correct. For the months after they terminate and are (or aren't) on COBRA, they are 1H and 2A.

If they are on COBRA (and terminated), I'm told that the coverage provider will send them a 1094-C to document their coverage.

[GMK]

​After further review (like where it says self-insured), perhaps this helps, e.g., item 10:

https://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers-about-Information-Reporting-by-Employers-on-Form-1094-C-and-Form-1095-C

and maybe this (I haven't reviewed it):

http://www.tangohealth.com/resources/blog/cobra-retirees/

[Benefits 101]

Enter 1A IF they lost coverage and offer of COBRA was made because there was a reduction of hours... i.e. the employee still works for the employer. 1H if they are eligible for COBRA because they no longer work for the employer. 2A is pretty much always right.