"It has been said the smart people often disagree but only one is right."
Like most people in our industry today, I get a lot of e-mail linked to blog posts and many are focused on the current "hot topic" ... 1095 Filing.
Here are two answers written by two law firms to the same question about how to report COBRA events on the 1095-C. What am I missing?
This one can be found at this LINK
Q5: How is COBRA coverage reported?
A5: Under recent IRS guidance, for the first full month of COBRA coverage, Code 1H applies (No Offer of Coverage) in Line 14 and Code 2A (Employee not employed during the month) applies in Line 16. If the plan is self-insured, the same codes apply for the period of COBRA coverage, however, for the applicable months of coverage, Part III is completed showing the months the individuals are covered under the plan – either as employees or COBRA beneficiaries.
This one can be found at this LINK
Now let’s assume that our full-time employee, who previously enrolled in coverage, transfers to a part-time position on July 1, and remains a part-time employee for the balance of the year. The employee would qualify for an offer of COBRA coverage. For January through June, the reporting treatment would be the same as the previous example involving termination. For the balance of the year, Line 14 would continue to be coded 1E (an offer of COBRA coverage to a former employee is ignored, but an offer of COBRA coverage to an ongoing employee counts as an offer of coverage). On Line 15, the employer would report the self-only COBRA coverage rate. If the employee accepted the COBRA coverage, Line 16 would be coded 2C; if declined, Line 16 would be coded 2B (Employee not a full-time employee).
Yes, the second example is for an employee that moves to part-time but they lost eligibility and no offer can be made. We could fill volumes with the fuzzy nature of these reporting requirements. There are dramatic differences between what the IRS said in July and September. Our plan remains to process early and file the IRS versions a week or so before the deadlines. That gives us the best chance of complying with the last version of the interpretations of the codes and filing requirements.
Thank you to all those that have entrusted these filings to our care!
Like most people in our industry today, I get a lot of e-mail linked to blog posts and many are focused on the current "hot topic" ... 1095 Filing.
Here are two answers written by two law firms to the same question about how to report COBRA events on the 1095-C. What am I missing?
This one can be found at this LINK
Q5: How is COBRA coverage reported?
A5: Under recent IRS guidance, for the first full month of COBRA coverage, Code 1H applies (No Offer of Coverage) in Line 14 and Code 2A (Employee not employed during the month) applies in Line 16. If the plan is self-insured, the same codes apply for the period of COBRA coverage, however, for the applicable months of coverage, Part III is completed showing the months the individuals are covered under the plan – either as employees or COBRA beneficiaries.
This one can be found at this LINK
Now let’s assume that our full-time employee, who previously enrolled in coverage, transfers to a part-time position on July 1, and remains a part-time employee for the balance of the year. The employee would qualify for an offer of COBRA coverage. For January through June, the reporting treatment would be the same as the previous example involving termination. For the balance of the year, Line 14 would continue to be coded 1E (an offer of COBRA coverage to a former employee is ignored, but an offer of COBRA coverage to an ongoing employee counts as an offer of coverage). On Line 15, the employer would report the self-only COBRA coverage rate. If the employee accepted the COBRA coverage, Line 16 would be coded 2C; if declined, Line 16 would be coded 2B (Employee not a full-time employee).
Yes, the second example is for an employee that moves to part-time but they lost eligibility and no offer can be made. We could fill volumes with the fuzzy nature of these reporting requirements. There are dramatic differences between what the IRS said in July and September. Our plan remains to process early and file the IRS versions a week or so before the deadlines. That gives us the best chance of complying with the last version of the interpretations of the codes and filing requirements.
Thank you to all those that have entrusted these filings to our care!
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