Generating the data for reporting Part III Covered Individuals

Run ACA COBRA, Retirees IRS Codes (BN991) in your ACA processing cycle if your organization has COBRA/Retiree enrollments in self-insured health plans. This is specified on ACA Plan Details (BN15.3). The purpose of BN991 is to generate the data for reporting Part III Covered Individuals. The BN991 is processed based on COBRA/Retiree HL enrollments in COBRA Benefit Entry (BN71) or Retiree Benefit Entry (BN72).

Type Description
COBRA

  • A COBRA participant can be an employee (HR11), or a spouse/dependent of the employee (BN70 participant record only).

  • Enrollment in ACA HL plan on BN71.
Retiree

  • A retiree must have an HR11 record.

  • Enrollment in ACA HL plan on BN72.

ACA COBRA, Retirees IRS Codes (BN991) is typically run after ACA IRS Codes Processing (BN990). BN990 is used to create the 1095 data based on the BN32 enrollments/offers for an employee’s active months.

ACA COBRA,Retirees IRS Codes (BN991) is used to update or create the data for reporting 1095-C:

  • Part I: created for employees who were terminated in the prior year with COBRA or Retiree enrollments in the reporting year

  • Part II: updated for active employees on COBRA (individuals offered coverage due to a reduction in hours making them ineligible for standard health coverage) or created for employees terminated in prior year on COBRA

  • Part III: created or updated to report COBRA/Retiree coverage by month for each covered individual (employee/participant and dependents)

BN991 processing logic depends on the type of COBRA scenario (terminated current year, terminated prior year, employee with reduced hours, or retirees).

Examples

  • A terminated employee with two dependents. Has worked during the reporting year and has elected COBRA coverage.

    Example COBRA

    • Employee offered and enrolled in HL benefit coverage from January-June (BN32)

    • Terminated June 30. HR11 Term Date populated

    • Enrolled into family COBRA coverage July-December (BN70/BN71)

    Process

    • Run ACA IRS Codes Processing (BN990) to create 1095-C data. See KB Article 1675088

    • Run ACA COBRA, Retirees IRS Codes (BN991) to update the 1095-C data for the COBRA enrollment

    COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

    Code Description
    Offer Code

    • Jan-June: 1E (from best offer)

    • July-Dec: 1H (No offer of coverage-individual is not an employee)
    Safe Harbor Code

    • Jan-June: 2C (enrolled)

    • July-Dec: 2A (Employee with term date and not employed during the month)
    Part III

    • Jan-June: X

    Code Description
    Part III

    • July-Dec: X

      Note: Record is merged with the BN990 results so that All months is marked.
    All J F M A M J J A S O N D
    Line 14 1E 1E 1E 1E 1E 1E 1E 1H 1H 1H 1H 1H 1H
    Line 15 $ 1H 1H 1H 1H 1H 1H
    Line 16 2C 2C 2C 2C 2C 2C 2C 2A 2A 2A 2A 2A 2A
    All J F M A M J J A S O N D
    Line 17 X
    Line 18 X
    Line 19 X

    Line 17 represents the employee/participant.

    Line 18, Line 19, Line 20, etc. represent dependents.

  • Terminated Employee with two dependents. Has worked in the reporting year but does not elect COBRA coverage.

    Example COBRA

    • Employee offered and enrolled in HL benefit coverage from January-June (BN32)

    • Terminated June 30. HR11 Term Date populated

    • No coverage July-December. No enrollment in BN32 and no BN70 or BN71 records

    Process

    • Run ACA IRS Codes Processing (BN990) to create 1095-C data. See KB Article 1675088

    • o Run ACA COBRA, Retirees IRS Codes (BN991)

    COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

    Code Description
    Offer Code

    • Jan-June: 1E (best offer)

    • July-Dec: 1H (No offer of coverage-individual is not an employee)
    Safe Harbor Code

    • Jan-June: 2C (enrolled)

    • July-Dec: 2A (employee not employed during the month)
    Part III

    • Jan-June: X

    Code Description
    Nothing to evaluate for this terminated employee who did not elect COBRA coverage
    All J F M A M J J A S O N D
    Line 14 1E 1E 1E 1E 1E 1E 1E 1H 1H 1H 1H 1H 1H
    Line 15 $ $ $ $ $ $
    Line 16 2C 2C 2C 2C 2C 2C 2C 2A 2A 2A 2A 2A 2A
    All J F M A M J J A S O N D
    Line 17 X X X X X X X
    Line 18 X X X X X X X
    Line 19 X X X X X X X

    Line 17 represents the employee/participant.

    Line 18, Line 19, Line 20, etc. represent dependents.

  • Terminated Employee with two dependents. Employee has not worked in the reporting year due to termination in the prior year and has COBRA/Retiree coverage in reporting year.

    Example COBRA

    • Employee offered and enrolled in HL benefit coverage from January-December (BN70/BN71)

    • Terminated June 30. HR11 Term Date populated

    Process

    • Run ACA IRS Codes Processing (BN990) to create 1095-C data. See KB Article 1675088

    • Run ACA COBRA, Retirees IRS Codes (BN991)

    COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

    Code Description
    Nothing to evaluate for an employee terminated in a prior year
    Code Description
    Offer Code

    • Jan-Dec: 1G

      Offer of coverage to employee who was not a full-time employee for any month of the calendar year. All box marked with an X
    Cost

    • Jan-Dec: blank
    Safe Harbor Code

    • Jan-Dec: blank
    Part III

    • All months box: X

    All J F M A M J J A S O N D
    Line 14 1G
    Line 15
    Line 16
    All J F M A M J J A S O N D
    Line 17 X
    Line 18 X
    Line 19 X

    Line 17 represents the employee/participant.

    Line 18, Line 19, Line 20, etc. represent dependents.

  • Terminated Employee with two dependents. Has not worked in the reporting year due to termination in prior year. Has less than all 12 months of COBRA/Retiree coverage in reporting year.

    Example COBRA

    • Employee offered and enrolled in COBRA benefit coverage from January-April (BN70/BN71), then ends COBRA coverage on April 30.

    • Terminated prior year. HR11 Term Date populated

    Process

    • Run ACA IRS Codes Processing (BN990) to create 1095-C data. See KB Article 1675088

    • Run ACA COBRA, Retirees IRS Codes (BN991)

    COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

    Code Description
    Nothing to evaluate for an employee terminated in a prior year
    Code Description
    Offer Code

    • Jan-Dec: 1G

      Offer of coverage to employee who was not a full-time employee for any month of the calendar year. All box marked with an X
    Cost

    • Jan-Dec: blank
    Safe Harbor Code

    • Jan-Dec: blank
    Part III

    • Jan-Apr: X

    All J F M A M J J A S O N D
    Line 14 1G
    Line 15
    Line 16
    All J F M A M J J A S O N D
    Line 17 X X X X
    Line 18 X X X X
    Line 19 X X X X

    Line 17 represents the employee/participant.

    Line 18, Line 19, Line 20, etc. represent dependents.

  • Full-time Employee. Moves to part-time in the reporting year.

    Example COBRA

    • Full-time Employee offered and enrolled in HL benefit coverage from January-June (BN32)

    • Employee loses company health coverage on June 30 when moved to part-time

    • Enrolled into family COBRA coverage July-December (BN70/BN71) at higher cost

    Process

    • Run ACA IRS Codes Processing (BN990) to create 1095-C data. See KB Article 1675088

    • Run ACA COBRA, Retirees IRS Codes (BN991)

    COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

    Code Description
    Offer Code

    • Jan-June: 1E Offer code from best offer plan

    • July-Dec: 1H

    Cost

    • Jan-June: $ Cost displayed if Offer Code = 1B, 1C, 1D, or 1E
    Safe Harbor Code

    • Jan-June: 2C (Employee enrolled in coverage offered)

    • July-Dec: blank
    Part III

    • Jan-June: X
    Code Description
    Offer Code

    • Jan-Dec: Offer code from COBRA/Retiree benefit plan
    Employee Cost

    • July-Dec: $$ Cost displayed if Offer Code = 1B, 1C, 1D, or 1E
    Safe Harbor Code

    • July-Dec: 2C
    Part III

    • July-Dec: X

      Record is merged with the BN990 results so that All months boxes are marked as needed.
    All J F M A M J J A S O N D
    Line 14 1E 1E 1E 1E 1E 1E 1E 1E 1E 1E 1E 1E
    Line 15 $ $ $ $ $ $ $$ $$ $$ $$ $$ $$
    Line 16 2C 2C 2C 2C 2C 2C 2C 2C 2C 2C 2C 2C
    All J F M A M J J A S O N D
    Line 17 X
    Line 18 X
    Line 19 X

    Line 17 represents the employee/participant.

    Line 18, Line 19, Line 20, etc. represent dependents.

  • Full-time Employee with two dependents. Moves to part-time in the reporting year and chooses to not elect COBRA coverage.

    An additional waive plan is required to track active employees who waive an offer of COBRA coverage. Terminated employees are covered in Example 2 and do not require a COBRA waive plan. Employees who move from full-time to part-time and waive COBRA coverage, a BN31/BN32 COBRA waive enrollment must exist for correct COBRA processing. The COBRA Waive plan is set up with the appropriate ACA parameters.

    Self-insured = No, so covered individuals are not captured for Part III. Set up the plan with a COBRA waive employee group (HR55.2) so only this type of employee is eligible for the COBRA waive.

    Example COBRA

    • Full-time Employee offered and enrolled in HL benefit coverage from January-June (BN32)

    • Employee loses company health coverage on June 30 when moved to part-time

    • Employee waives family COBRA coverage July-December (BN70/BN71) at higher cost

    Process

    • Run ACA IRS Codes Processing (BN990) to create 1095-C data. See KB Article 1675088

    • Run ACA COBRA, Retirees IRS Codes (BN991)

    COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

    Code Description
    Offer Code

    • Jan-June: Offer code from best offer

    • July-Dec: Offer code from waive COBRA offer. Only BN29 offer record for time period
    Employee Cost

    • displayed if Offer Code = 1B, 1C, 1D, or 1E
    Safe Harbor Code

    • Jan-June: 2C Employee enrolled in coverage offered

    • July-Dec: 2B Employee not a full-time employee. Automatically populated by BN990 when the only offer in BN29 is a WV offer
    Part III

    • Jan-June: X
    Code Description
    Nothing to evaluate for this full time employee who moved to part time and does not elect COBRA coverage
    All J F M A M J J A S O N D
    Line 14 1E 1E 1E 1E 1E 1E 1E 1E 1E 1E 1E 1E
    Line 15 $ $ $ $ $ $ $$ $$ $$ $$ $$ $$
    Line 16 2C 2C 2C 2C 2C 2B 2B 2B 2B 2B 2B 2B
    All J F M A M J J A S O N D
    Line 17 X X X X X X
    Line 18 X X X X X X
    Line 19

    X

    		 X X X X X

    Line 17 represents the employee/participant.

    Line 18, Line 19, Line 20, etc. represent dependents.