Wednesday, June 15, 2016
Reporting COBRA Coverage
What is COBRA Coverage?
COBRA stands for the Consolidated Omnibus Budget Reconciliation Act, which was passed in 1986. The act amended existing laws by giving certain former employees, retirees, spouses, and dependents the right to temporary continuation of health coverage at group rates. COBRA coverage is offered when the employee loses access to coverage under a group plan, due to voluntary or involuntary termination or a reduction in their hours of employment.
Reporting COBRA Coverage on Part II of Form 1095-C
If you’ve offered COBRA coverage to a terminated employee (generally anyone whose employment didn’t end because of gross misconduct), you won’t report it as an offer of coverage on line 14 of Form 1095-C. Instead, use code 1H, no offer of coverage, for any month the continued coverage applies.
If you need to report COBRA coverage for an active employee, say, someone whose hours were reduced and is, therefore, ineligible for plan coverage, you’ll report it in the same manner as an offer of that type of coverage to any other active employee.
Self-Insured Plans and COBRA Coverage
Under self-insured COBRA plans, spouses and dependents can elect to receive the continued coverage independently of the employee (i.e., if the employee declines coverage or is deceased). Employers who sponsor these plans will still need to report coverage offered to each non-employee spouse and dependent on a separate Form 1095-B or 1095-C from the employee. If a spouse and dependents elect to receive COBRA coverage along with the employee, you can report them on the same form.
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