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In the realm of HR and ACA compliance, employers must be diligent in considering COBRA continuants during reporting reviews. This article describes what HR professionals need to keep in mind to ensure accurate and compliant ACA reporting for individuals with COBRA continuation coverage.
For employers with fully insured plans, the communication of coverage information to COBRA continuants is facilitated through Form 1095-B provided by the insurance company. Employers with self-funded plans are responsible for furnishing coverage information directly to the COBRA continuant. HR teams must carefully code lines 14 and 16 for individuals who experience a mid-year termination or a COBRA event.
An employer’s offer of COBRA coverage due to termination of employment does not constitute an "offer of coverage" for Form 1095-C reporting. Employers completing Form 1095-C for former employees should use Code 1H, No Offer of Coverage, on line 14 for months in which COBRA was offered. Line 16 should be populated with Code 2A, Employee Not Employed During the Month, for the corresponding months, regardless of COBRA enrollment.
HR professionals are advised to scrutinize their reporting practices for COBRA continuants as part of ACA compliance preparations. By navigating these coding intricacies with precision, employers uphold compliance standards and ensure the accuracy of their ACA reporting.
For help with ACA data collection and reporting, contact your BAS account manager or email solutions@basusa.com.
Benefit Allocation Systems (BAS) provides best-in-class, online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.
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