Employer reporting is hard enough! But, employer reporting when there has been a COBRA qualifying event revives images of coiled snakes striking out.
Final 2015 instructions for completing forms 1094-C and 1095-C changed some of the rules related to reporting COBRA offers of coverage.
Example for Termination at end of month
Facts or Assumptions:
- Employer offers insured plan
- Coverage for lowest cost employee premium is $300
- Offer of COBRA to employee who lost coverage as a result of termination on last day in February and former employee enrolled in coverage
- Assumes MEC/MV coverage was also offered to former employee’s spouse and dependents as well as the former employee and only the former employee enrolled.
Example for Termination during month
Facts or Assumptions:
- Employer offers insured plan
- Coverage for lowest cost employee premium is $300
- Offer of COBRA to employee who lost coverage as a result of termination mid-February and former employee enrolled in coverage
- Assumes MEC/MV coverage was also offered to former employee’s spouse and dependents as well as the former employee and only the former employee enrolled.
Compliance NOW! 