Q.- We are a large employer with a self-funded health plan. Do we have to send an ACA Form 1095-C to our former employees on COBRA coverage? What if just their dependents elected COBRA?
A.- Yes. A COBRA continuant must receive a Form 1095-B or C from an applicable large employer.
Each individual who elects COBRA coverage under your self-funded plan should receive a Form 1095-B or 1095-C. If the dependent receives COBRA coverage because the employee or former employee has elected COBRA coverage that also provides coverage to the dependent (e.g., family coverage), the coverage of the employee/former employee and the dependents should be reported together on the same Form 1095-C. If a dependent separately elects COBRA coverage, that coverage should be reported on a separate Form 1095-B or C mailed to the dependent.
