Employee Benefits Compliance, Reporting & Disclosure, Reporting Requirements

IRS Revising its Answer on 1095-C Codes for Employees on COBRA

What to put on lines 14 – 16 (of form 1095-C) for former employees who elect COBRA? And for ongoing employees who elect COBRA (because they change from full-time to part-time)?

If you have found this confusing, join the club!  Apparently the IRS also found it confusing, as did the rest of us.   The IRS recently updated the COBRA Q&As (numbers 16 & 17) on its webpage on Information Reporting.

The new answer to both questions on COBRA and information reporting?

The answer to this question is currently being revised.  Please check back later for the updated response.

Below are the questions and answers from the IRS webpage.  We will update this article as soon the IRS publishes its revised answer.

Reporting Offers of COBRA Coverage

16.  How should an ALE member complete Part II of Form 1095-C for a full-time employee who terminates employment during a calendar year and receives an offer of COBRA continuation coverage?

The answer to this question is currently being revised.  Please check back later for the updated response. (02/22/2016)

17. How should an ALE member complete Part II of Form 1095-C for an ongoing employee who receives an offer of COBRA continuation coverage due to a reduction in hours?

The answer to this question is currently being revised.  Please check back later for the updated response. (02/18/2016)