Q. Does an employer need to complete Form 1095-C for an employee who terminates employment mid-year causing a COBRA qualifying event?
A. Yes, Form 1095-C is required to be completed in the year that an employee terminates. When employment termination is the COBRA-qualifying event, COBRA is never reported as an offer of coverage – even if the former employee actually enrolls in COBRA coverage. Per the IRS’ final instructions, report as follows for the months that COBRA was offered:
- Line 14 – Always use Code 1H (no offer of coverage).
- Line 15 – Leave Line 15 blank. You do not report cost information.
- Line 16 – Always use Code 2A (employee not employed during the month).
- Part III – Employers with self-insured plans will complete this section for former employees and dependents that enroll in COBRA and will continue to report for as long as COBRA coverage is in force.
Continue reading COBRA FAQ’s for Employer Reporting
When an employer sponsors a group health plan, there are several notices you are required to provide to your plan participants and beneficiaries. Keeping track of your notice and disclosure obligations under ERISA, HIPAA, COBRA and the Affordable Care Act is certainly no simple task. Anyone who is involved with the administration of group health plans can attest to this challenge. The last few years have been filled with new regulations and stricter agency enforcement for the proper administration of employer-sponsored plans. With the ever-evolving requirements, it can be easy to “forget” some of your notice responsibilities. We’ve designed a notice and disclosure checklist to remind our clients of the requirements and due dates so you can stay compliant.
To access our complete 2015 Notice and Disclosure Checklist, click here.
The pool is closed, days are getting shorter, fantasy football is in full swing and pumpkin spice coffee is brewing already. Let’s face it, summer is over. Just as students are back to school and adjusting again to concentrate on their studies, employers should be actively turning to refocus attention to their upcoming compliance obligations for the health and welfare benefit plans they sponsor. With all of the new regulations and evolving regulatory activity, it is easy to forget some of the end of the year annual reporting and disclosures that apply to group health plans. Not to worry; below we have compiled an easy-reference checklist. Think of this checklist as the “spark notes” for your overall fall/winter compliance obligations. Should you need help with your homework, contact your Digital Consultant or Advisor.
To access our complete 2014 Compliance Checklist, click here.
Please contact your Digital Team for a comprehensive list of required notices and detailed health care reform compliance planners/checklists for 2014-2015.
And coming soon… IRS reporting for PPACA Section 6055 (providers of minimum essential coverage including self-insured groups) and Section 6056 (applicable large employers subject to the employer mandate.)