Understanding Form 1095-C Reporting for Employees on COBRA Continuation Coverage

Introduction: The Complexity of 1095-C COBRA Reporting

Reporting health coverage information on Form 1095-C becomes significantly more complex when employees elect COBRA continuation coverage. When an employee's active employment ends but they continue health coverage through COBRA, employers face a unique reporting challenge that requires understanding both ACA requirements and COBRA regulations simultaneously. The question of how to properly complete 1095-C for employees on COBRA generates more confusion than almost any other ACA reporting scenario.

COBRA, the Consolidated Omnibus Budget Reconciliation Act, allows employees and their dependents to continue group health coverage after a qualifying event such as termination, reduction in hours, or other life events. For Applicable Large Employers (ALEs), this creates a situation where former employees may remain covered by the employer's health plan for up to 18, 29, or 36 months depending on the qualifying event, even though active employment has ended. Properly documenting this coverage on Form 1095-C is essential for ACA compliance.

The stakes for getting 1095-C COBRA reporting wrong are substantial. Incorrect reporting can trigger IRS penalty notices, create issues with employee tax returns, and potentially expose the employer to employer shared responsibility penalties under Section 4980H. For tax year 2025, information return penalties range from $60 to $330 per form depending on when corrections are made, with maximum penalties reaching $3,783,000 for large employers who fail to file correctly.

This comprehensive guide explains exactly how to fill out 1095-C for employees on COBRA. We will cover the correct Line 14, 15, and 16 codes to use, when to complete Part III for self-insured plans, how COBRA affects full-time employee status, and the differences between employer-sponsored COBRA and third-party COBRA administrators. Whether you are an HR professional, benefits administrator, or using ACA compliance software, this article provides the complete picture for accurate COBRA reporting.

Key topics covered in this guide:

  • COBRA fundamentals: Understanding continuation coverage and ACA requirements
  • Line 14 codes: Which offer codes apply during COBRA continuation
  • Line 15 reporting: Premium amounts for COBRA participants
  • Line 16 codes: Safe harbors and coverage enrollment indicators
  • Part III completion: Self-insured plan reporting for COBRA enrollees
  • Full-time status: How COBRA affects employee classification
  • Termination scenarios: Coding for different COBRA qualifying events
  • State filing: COBRA implications for state ACA reporting

Understanding COBRA and Its Relationship to ACA Reporting

What is COBRA Continuation Coverage?

COBRA is a federal law that gives employees and their families the right to continue group health coverage after certain qualifying events that would otherwise result in loss of coverage. Before understanding how to complete 1095-C for employees on COBRA, employers must understand the basics of COBRA continuation coverage and how it interacts with ACA reporting requirements.

COBRA qualifying events include:

  • Voluntary or involuntary termination: Except for gross misconduct, employees who lose their job can elect COBRA for up to 18 months
  • Reduction in hours: Employees whose hours are reduced below the threshold for benefits eligibility
  • Employee death: Dependents can continue coverage for up to 36 months
  • Divorce or legal separation: Covered spouses can continue for up to 36 months
  • Medicare entitlement: Dependents can continue for up to 36 months when the employee becomes Medicare eligible
  • Loss of dependent child status: Children aging out of coverage can continue for up to 36 months
  • Disability extension: Disabled individuals may extend COBRA to 29 months

Employers with 50 or more full-time employees (including full-time equivalent employees) in the prior year are subject to COBRA requirements and must also file ACA information returns. When these two obligations intersect—an ALE with employees on COBRA—the 1095-C COBRA reporting requirements come into play.

How COBRA Affects ACA Employer Mandate Compliance

A critical aspect of 1095-C COBRA reporting is understanding that COBRA coverage satisfies the employer's obligation to offer minimum essential coverage during the COBRA period. Under the ACA's employer shared responsibility provisions, an ALE must offer coverage to substantially all full-time employees to avoid penalty assessments. COBRA continuation coverage counts as an offer of coverage for ACA purposes.

Key points about COBRA and ACA compliance:

  • Offer obligation satisfied: When a former employee elects COBRA, the employer is considered to have offered coverage for ACA purposes
  • Not a full-time employee: Former employees on COBRA are generally not counted as full-time employees for purposes of the 4980H penalty calculation
  • Minimum value preserved: COBRA coverage maintains the same plan design, so if the original plan met minimum value, COBRA does too
  • Affordability not required: COBRA premiums can be up to 102% of the full premium cost, which typically exceeds the affordability threshold, but this does not trigger penalties for former employees

The distinction between active employees and COBRA participants is essential for accurate 1095-C COBRA reporting. The form must reflect the actual employment status and coverage offer during each month of the tax year.

Who Must Receive Form 1095-C When on COBRA?

Understanding who receives Form 1095-C is foundational to COBRA reporting. Every individual who was a full-time employee for at least one month during the tax year must receive a Form 1095-C, regardless of whether they later went on COBRA, terminated employment, or had any other status change during the year.

Form 1095-C is required for:

  • Former employees on COBRA: If the individual was full-time for any month before going on COBRA
  • Current employees who were previously on COBRA: Such as those rehired after a COBRA period
  • Employees with mid-year COBRA elections: Full-time employees who experience a qualifying event mid-year
  • Part-time employees on COBRA (self-insured plans only): May receive a 1095-C with Part III completed even if Part II shows no coverage offer as a full-time employee

The critical point is that an individual's COBRA status alone does not determine whether they receive a Form 1095-C. The full-time employee status during active employment is the primary trigger for 1095-C reporting.

Line 14 Codes for COBRA Participants: What Coverage Was Offered?

Understanding Line 14 Offer Codes

Line 14 of Form 1095-C reports the type of coverage offered to the employee during each month. For 1095-C COBRA reporting, the Line 14 code depends on whether the individual was an active full-time employee during the month or whether they were a former employee continuing coverage through COBRA.

The Line 14 codes most relevant to COBRA situations include:

Code Description When to Use for COBRA
1A Qualifying offer (affordable MV coverage to employee, MEC to spouse/dependents) Months of active full-time employment before COBRA
1B Minimum value coverage offered to employee only Months of active employment if employee-only coverage offered
1E Minimum value coverage offered to employee, spouse, and dependents Months of active employment if full family coverage offered
1G Offer to non-full-time employee enrolled in self-insured coverage COBRA months for self-insured plans when individual is no longer full-time
1H No offer of coverage COBRA months for fully-insured plans (see explanation below)

Line 14 for Fully-Insured Plans During COBRA

For employers with fully-insured health plans, the 1095-C COBRA reporting approach differs from self-insured plans. During months when a former employee is continuing coverage under COBRA and is no longer a full-time employee, most employers use code 1H (no offer of coverage) on Line 14.

This may seem counterintuitive since the individual is actually receiving coverage, but the reasoning is sound:

  • No full-time employee status: Line 14 reports the offer made to full-time employees. A former employee on COBRA is not a full-time employee.
  • COBRA is not an employer offer: COBRA continuation is a federal right, not a new offer of coverage from the employer.
  • Coverage reported elsewhere: For fully-insured plans, the insurance carrier reports the actual coverage on Form 1095-B.

Example scenario for fully-insured COBRA:

An employee worked full-time from January through June 2025, then terminated and elected COBRA for July through December. The Line 14 entries would be:

  • January - June: Code 1E (or appropriate code for the coverage offered during active employment)
  • July - December: Code 1H (no offer of coverage as a full-time employee)

Line 14 for Self-Insured Plans During COBRA

For employers with self-insured health plans, the reporting of 1095-C COBRA participants requires additional consideration. Because self-insured employers must complete Part III to report actual enrollment, there is a specific code for non-full-time individuals enrolled in the employer's self-insured plan.

Code 1G is used on Line 14 when:

  • The individual is not a full-time employee during the month
  • The individual is enrolled in the employer's self-insured coverage during the month
  • The employer needs to complete Part III for this individual

Example scenario for self-insured COBRA:

An employee worked full-time from January through March 2025, terminated, and elected COBRA for April through December under a self-insured plan. The Line 14 entries would be:

  • January - March: Code 1E (minimum value coverage offered to employee, spouse, and dependents)
  • April - December: Code 1G (offer to non-full-time employee enrolled in self-insured coverage)

Using code 1G signals that while no offer was made as a full-time employee, the individual is enrolled and Part III must be completed to document their coverage.

Line 15 Reporting: Premium Amounts During COBRA

Understanding Line 15 Requirements

Line 15 of Form 1095-C reports the employee's required contribution for the lowest-cost self-only minimum value coverage offered. This line is used by the IRS to determine whether the employer's coverage was affordable. For 1095-C COBRA reporting, Line 15 entries depend on the individual's employment status during each month.

Key rules for Line 15 during COBRA periods:

  • Active employment months: Enter the employee's monthly share of the lowest-cost self-only premium during full-time employment
  • COBRA months (code 1G or 1H): Leave Line 15 blank for months when the individual is not a full-time employee
  • No affordability test for former employees: COBRA premium amounts do not factor into affordability calculations

The reason Line 15 is left blank during COBRA months is that affordability is only tested for full-time employees. Once an individual is no longer a full-time employee, the employer has no affordability obligation to that individual, and reporting a COBRA premium amount would be misleading.

Premium Entry Examples for COBRA Situations

Example 1: Employee transitions to COBRA mid-year

An employee was full-time January through August, with a monthly employee contribution of $150 for self-only coverage. They terminated and elected COBRA for September through December.

Month Line 14 Line 15 Explanation
Jan - Aug 1E $150.00 Full-time employee with coverage offer
Sep - Dec 1H or 1G (blank) Former employee on COBRA

Example 2: Employee rehired after COBRA period

An employee worked January through March, elected COBRA April through July, was rehired August and worked through December.

Month Line 14 Line 15 Explanation
Jan - Mar 1E $175.00 Initial full-time employment
Apr - Jul 1H or 1G (blank) COBRA continuation period
Aug - Dec 1E $175.00 Rehired as full-time employee

Line 16 Codes: Safe Harbors and Coverage Status During COBRA

Understanding Line 16 for COBRA Participants

Line 16 of Form 1095-C provides additional context about the coverage offer and enrollment status. The Line 16 codes serve multiple purposes: indicating safe harbor methods for affordability, showing enrollment status, and explaining certain circumstances. For 1095-C COBRA reporting, the Line 16 code changes based on whether the individual is an active employee or a COBRA participant.

Line 16 codes commonly used in COBRA situations:

Code Description COBRA Application
2A Employee not employed during the month Used for months after termination if individual is not enrolled in self-insured coverage
2C Employee enrolled in coverage offered Used during active employment months when employee was enrolled
2D Employee in Limited Non-Assessment Period (waiting period) May apply if employee terminated during a waiting period
2F W-2 Safe Harbor Used during active employment months to demonstrate affordability
2G Rate of Pay Safe Harbor Used during active employment months to demonstrate affordability
2H Federal Poverty Line Safe Harbor Used during active employment months to demonstrate affordability

Line 16 During COBRA Months

The appropriate Line 16 code during COBRA months depends on the plan type and whether the individual is enrolled:

For fully-insured plans:

  • Use code 2A (employee not employed) during COBRA months
  • This indicates the individual is no longer an employee, which explains the 1H code on Line 14
  • The insurance carrier will report actual coverage on Form 1095-B

For self-insured plans when individual is enrolled in COBRA:

  • Use code 2C (enrolled in coverage) during COBRA months when using Line 14 code 1G
  • This combination indicates a non-full-time individual enrolled in the self-insured plan
  • Part III must also be completed to document the covered individuals

For self-insured plans when individual declines or ends COBRA:

  • Use code 2A (employee not employed) if the individual is not enrolled in any coverage
  • Line 14 would show 1H for these months

Safe Harbor Codes and COBRA Transitions

During months of active employment before a COBRA qualifying event, employers should use the appropriate safe harbor code (2F, 2G, or 2H) to protect against penalty assessments. The safe harbor demonstrates that coverage was affordable during the employment period.

Example of safe harbor and COBRA transition:

An employee worked January through September, with the employer using the Federal Poverty Line safe harbor. The employee elected COBRA for October through December.

Month Line 14 Line 15 Line 16
Jan - Sep 1E $113.00 2H (FPL Safe Harbor)
Oct - Dec 1G or 1H (blank) 2A or 2C

Part III Completion: Self-Insured Plans and COBRA Enrollment

When to Complete Part III for COBRA Participants

Part III of Form 1095-C is only completed by employers with self-insured health plans. This section lists all individuals who were actually enrolled in the employer's coverage during the year, along with their Social Security Numbers and months of coverage. For 1095-C COBRA situations, Part III is essential for documenting continued coverage.

Part III must be completed when:

  • The employer offers a self-insured health plan
  • The individual (employee, former employee, or dependent) was enrolled in that plan during any month of the year
  • COBRA participants continuing in self-insured coverage must be included in Part III

Part III is NOT completed when:

  • The employer has a fully-insured plan (the insurance carrier files Form 1095-B instead)
  • The individual was never enrolled in coverage during the year
  • Coverage was through a different entity such as a multiemployer plan

Part III Data for COBRA Enrollees

For former employees continuing coverage through COBRA in a self-insured plan, Part III should include:

Information required for each covered individual:

  • Name: Full legal name of the COBRA participant and any covered dependents
  • SSN or DOB: Social Security Number (or date of birth if SSN is unavailable)
  • Coverage months: Check the boxes for each month the individual was covered, including COBRA months

Example Part III for COBRA:

An employee and two dependents were covered January through March during active employment, then continued on COBRA April through December.

Covered Individual SSN Jan-Mar Apr-Dec
John Smith (employee) XXX-XX-1234 Checked Checked (COBRA)
Jane Smith (spouse) XXX-XX-5678 Checked Checked (COBRA)
Tim Smith (child) XXX-XX-9012 Checked Checked (COBRA)

All 12 months would be checked for each individual, reflecting continuous coverage from active employment through COBRA continuation.

Part III When COBRA Coverage Ends

If a COBRA participant's coverage ends mid-year (due to non-payment, obtaining other coverage, or exhausting the COBRA period), Part III should only show coverage for the months the individual was actually enrolled.

Example: An employee terminated in February and elected COBRA, but stopped paying premiums after June.

  • Part III coverage months: January through June only
  • Line 14 for July through December: Code 1H (no coverage offered, individual no longer enrolled)
  • Line 16 for July through December: Code 2A (not employed)

Specific COBRA Scenarios and How to Report Them

Scenario 1: Voluntary Termination with COBRA Election

The most common 1095-C COBRA scenario involves an employee who voluntarily resigns and elects to continue coverage. Here is how to complete the form:

Facts: Sarah was a full-time employee from January through July 2025. She resigned effective July 31 and elected COBRA coverage for herself starting August 1. The employer has a self-insured plan. The employee contribution during employment was $200/month.

Form completion:

Month Line 14 Line 15 Line 16
Jan - Jul 1E $200.00 2C (enrolled)
Aug - Dec 1G (blank) 2C (enrolled in COBRA)

Part III: Complete with Sarah's name, SSN, and all 12 months checked.

Scenario 2: Involuntary Termination with COBRA Declined

When an employee is terminated and does not elect COBRA, the reporting reflects the end of both employment and coverage.

Facts: Michael was terminated on April 15, 2025 after working as a full-time employee since January. He was offered but declined COBRA. The employer has a fully-insured plan.

Form completion:

Month Line 14 Line 15 Line 16
Jan - Apr 1E $175.00 2C (enrolled through April)
May - Dec 1H (blank) 2A (not employed)

Part III: Not completed (fully-insured plan).

Scenario 3: Reduction in Hours Triggering COBRA

When an employee's hours are reduced below the full-time threshold, they may experience a loss of benefits eligibility and be offered COBRA.

Facts: Jennifer worked full-time January through May 2025. Her hours were reduced to part-time effective June 1. She elected COBRA and continued coverage for the remainder of the year. The employer has a self-insured plan.

Form completion:

Month Line 14 Line 15 Line 16
Jan - May 1E $150.00 2C (enrolled as FT employee)
Jun - Dec 1G (blank) 2C (enrolled via COBRA)

Part III: Complete with Jennifer's information showing coverage for all 12 months. Include any covered dependents as well.

Scenario 4: COBRA for Dependents Only (Employee Does Not Elect)

Sometimes an employee does not elect COBRA for themselves but their dependents do continue coverage. This creates a unique 1095-C COBRA reporting situation.

Facts: Robert terminated in March 2025. He obtained coverage through a new employer but his spouse and child elected COBRA to continue coverage through December. The employer has a self-insured plan.

Form completion:

The employee (Robert) still receives a Form 1095-C because he was a full-time employee during January through March.

Month Line 14 Line 15 Line 16
Jan - Mar 1E $180.00 2C (enrolled)
Apr - Dec 1G (blank) 2A (not employed) or 2C if dependents still enrolled

Part III:

  • Robert: January through March only
  • Robert's spouse: All 12 months (COBRA continuation)
  • Robert's child: All 12 months (COBRA continuation)

Common Mistakes in 1095-C COBRA Reporting

Errors to Avoid

Accurate 1095-C COBRA reporting requires attention to detail. The following are common errors that can trigger IRS notices or penalty assessments:

Mistake 1: Using active employee codes during COBRA months

  • Error: Continuing to use Line 14 codes 1A-1E during COBRA months
  • Problem: These codes indicate an offer to a full-time employee, which is inaccurate
  • Correct approach: Use code 1G (self-insured) or 1H (fully-insured) during COBRA months

Mistake 2: Entering COBRA premium amounts on Line 15

  • Error: Reporting the COBRA premium (102% of full cost) on Line 15
  • Problem: Line 15 is for affordability testing, which only applies to full-time employees
  • Correct approach: Leave Line 15 blank during COBRA months

Mistake 3: Forgetting to complete Part III for self-insured COBRA

  • Error: Leaving Part III blank when COBRA participants are enrolled in self-insured coverage
  • Problem: Fails to document minimum essential coverage for the individual
  • Correct approach: Complete Part III with all enrolled individuals and their coverage months

Mistake 4: Not issuing 1095-C to former employees who were full-time

  • Error: Failing to send Form 1095-C to employees who terminated early in the year
  • Problem: Every full-time employee for any month must receive a form
  • Correct approach: Issue forms to all individuals who were full-time for at least one month

Mistake 5: Using code 2C without corresponding coverage in Part III

  • Error: Reporting Line 16 code 2C (enrolled) but not completing Part III
  • Problem: Creates inconsistency that may trigger IRS review
  • Correct approach: Ensure Part III reflects any months where 2C is used (self-insured plans)

How to Correct COBRA Reporting Errors

If errors are discovered after filing, employers should file corrected forms promptly. The IRS provides reduced penalties for corrections made within 30 days of the filing deadline.

Correction process:

  • Check the "CORRECTED" box at the top of the form
  • Enter the correct information on all applicable lines
  • Transmit the corrected form through the IRS AIR system
  • Provide a corrected copy to the affected individual

Deadlines and Penalties for 1095-C COBRA Reporting

Key Filing Deadlines

The deadlines for 1095-C COBRA reporting are the same as for all Form 1095-C filings. For tax year 2025, the deadline to furnish forms to individuals is March 3, 2026. The IRS electronic filing deadline is March 31, 2026. Paper filing (available only for fewer than 10 forms) is due February 28, 2026.

Employers can request an automatic 30-day extension using Form 8809. The extension applies to the IRS filing deadline but does not extend the deadline to furnish forms to individuals.

Penalties for Incorrect or Late Filing

The IRS penalties for incorrect or late 1095-C filing apply equally to COBRA-related forms. Penalties range from $60 per form (if corrected within 30 days) to $330 per form (if not corrected by August 1), with maximum penalties reaching $3,783,000 for large employers. Intentional disregard carries penalties of $660 or more per form with no cap.

These penalties apply separately to both the filing requirement (to IRS) and furnishing requirement (to individuals). An employer who fails to file and fails to furnish could face double penalties.

State Filing Requirements for COBRA Participants

States with Individual Mandate Reporting

Several states have enacted their own individual health insurance mandates and require employers to submit health coverage information. These state requirements apply to 1095-C COBRA reporting as well:

  • California: Requires 1095-C data submission to the Franchise Tax Board
  • New Jersey: Requires 1095-C data submission to the Division of Taxation
  • Rhode Island: Requires 1095-C data submission to the Division of Taxation
  • District of Columbia: Requires 1095-C data submission to the Office of Tax and Revenue
  • Massachusetts: Uses separate Form 1099-HC for health coverage reporting

Employers with COBRA participants in these states must include them in state filings just as they would for federal filings. The same codes and reporting approach apply.

Frequently Asked Questions About 1095-C COBRA Reporting

What Line 14 code do I use for COBRA participants?

For fully-insured plans, use code 1H (no offer of coverage) during COBRA months because the individual is not a full-time employee. For self-insured plans, use code 1G (offer to non-full-time employee enrolled in self-insured coverage) if the individual is enrolled in COBRA. The key distinction is whether the employer has a self-insured plan requiring Part III completion.

Should I complete Part III for COBRA participants?

Yes, but only if you have a self-insured health plan. Part III documents actual enrollment in the employer's coverage, which includes COBRA continuation coverage. List the COBRA participant and any covered dependents with their SSNs and check the boxes for all months they were enrolled. For fully-insured plans, the insurance carrier reports coverage on Form 1095-B, so you leave Part III blank.

Do I leave Line 15 blank during COBRA months?

Yes. Line 15 reports the employee's share of the lowest-cost premium for affordability testing purposes. Affordability is only tested for full-time employees. Since a COBRA participant is a former employee (not currently full-time), Line 15 should be left blank during COBRA months regardless of what the COBRA premium actually is.

What Line 16 code applies during COBRA coverage?

For self-insured plans with the individual enrolled in COBRA, use code 2C (employee enrolled in coverage offered). For fully-insured plans or when the individual is not enrolled, use code 2A (employee not employed during the month). The Line 16 code provides context to explain the Line 14 entry.

Does a COBRA participant receive Form 1095-C?

A former employee on COBRA receives Form 1095-C only if they were a full-time employee for at least one month during the tax year. The form will show their active employment months with appropriate offer codes and their COBRA months with codes reflecting their former employee status. If someone was never a full-time employee (such as a dependent who elected COBRA), they do not receive their own 1095-C but may be listed in Part III of the employee's form.

How do I report COBRA for dependents when the employee doesn't elect?

When an employee terminates but dependents elect COBRA, the employee still receives Form 1095-C (assuming they were full-time). In Part III (self-insured plans only), list the dependents with coverage for all months they were enrolled, including COBRA months. The employee's own coverage months should reflect only the months they were actually enrolled.

What if COBRA coverage ends mid-year due to non-payment?

If a COBRA participant stops paying premiums and coverage terminates, update the reporting accordingly. Part III should only show coverage months through the last month of actual enrollment. Line 14 would show 1G or 1H for remaining months depending on plan type, and Line 16 would show 2A for months after coverage ends. The form should accurately reflect the actual coverage situation.

Can I use the qualifying offer method (code 1A) for COBRA?

No. Code 1A is specifically for offers made to full-time employees where the coverage meets qualifying offer standards. Since COBRA participants are former employees, not current full-time employees, code 1A does not apply during COBRA months. Use 1A only during months of active full-time employment when the qualifying offer criteria are met.

Do safe harbor codes apply during COBRA months?

No. Safe harbor codes (2F, 2G, 2H) demonstrate affordability for offers made to full-time employees. Since COBRA participants are not full-time employees, safe harbors do not apply during COBRA months. Use safe harbor codes only during months of active full-time employment when the employer wants to demonstrate affordability.

What if an employee is rehired after being on COBRA?

The Form 1095-C should reflect the complete picture for the tax year. Show the initial employment months with appropriate offer codes and safe harbors, the COBRA months with 1G or 1H (depending on plan type), and the rehired months with new offer codes and safe harbors. Part III should show continuous coverage if the individual remained enrolled throughout.

How does third-party COBRA administration affect reporting?

Using a third-party COBRA administrator does not change the employer's 1095-C reporting obligations. The employer remains responsible for accurate Form 1095-C filing. The COBRA administrator may provide data to help complete the forms, but the employer must ensure the information is correctly reported. For self-insured plans, Part III must still be completed by the employer.

Do I need to report COBRA participants in state filings?

Yes. States with individual mandate reporting requirements (California, New Jersey, Rhode Island, D.C., Massachusetts) require the same coverage information reported to the IRS. COBRA participants who resided in these states during the tax year must be included in state filings with the same coding approach used for federal filings.

How BoomTax Simplifies 1095-C COBRA Reporting

Accurately completing 1095-C for employees on COBRA requires tracking employment status, coverage enrollment, and plan type for each month of the year. BoomTax streamlines this complex process with features designed specifically for ACA compliance:

  • Intelligent Code Selection: BoomTax guides you through selecting the correct Line 14, 15, and 16 codes based on the employee's status each month. The system understands COBRA scenarios and suggests appropriate codes like 1G for self-insured COBRA participants.
  • Automatic Part III Generation: For self-insured plans, BoomTax automatically populates Part III based on enrollment data you provide. COBRA continuation coverage is captured accurately across all months of enrollment.
  • Data Validation: Before filing, BoomTax validates your data against 500+ IRS business rules. The system catches inconsistencies like using code 2C without corresponding Part III entries, helping you avoid penalty-triggering errors.
  • IRS E-Filing: BoomTax transmits your 1095-C forms directly to the IRS AIR system. No need to obtain your own Transmitter Control Code or navigate IRS technical requirements.
  • Print and Mail Services: BoomTax can print and mail 1095-C copies to all employees and former employees, including COBRA participants. Track delivery and meet furnishing deadlines with confidence.
  • State Filing Support: File with California, New Jersey, Rhode Island, D.C., and Massachusetts from the same platform using the same data.
  • Unlimited Corrections: If you discover COBRA reporting errors after filing, correct and refile at no additional charge. BoomTax includes free unlimited corrections.
  • Bulk Data Import: Upload employee and COBRA participant data from Excel, CSV, or integrate with payroll and HRIS systems. Handle hundreds or thousands of forms efficiently.

Ready to simplify your COBRA reporting? Get started with BoomTax today and ensure accurate 1095-C filing for all your employees and COBRA participants.

Conclusion: Mastering 1095-C COBRA Compliance

Completing 1095-C for employees on COBRA requires understanding the intersection of COBRA continuation coverage rules and ACA reporting requirements. The key is recognizing that COBRA participants are former employees whose coverage status changes the applicable codes and reporting approach on Form 1095-C.

Key takeaways for 1095-C COBRA reporting:

  • Line 14 codes: Use 1G for self-insured plans (non-full-time enrolled), 1H for fully-insured plans (no offer to full-time employee)
  • Line 15: Leave blank during COBRA months—affordability only applies to full-time employees
  • Line 16 codes: Use 2C for enrolled COBRA participants (self-insured), 2A for non-employed status (fully-insured or not enrolled)
  • Part III: Complete for self-insured plans only, showing all months of actual enrollment including COBRA
  • Former employees: Issue 1095-C to anyone who was full-time for at least one month, even if they terminated early and elected COBRA
  • Deadlines: March 3, 2026 to furnish to individuals; March 31, 2026 to file with IRS (electronic) for tax year 2025
  • State filing: Include COBRA participants in state filings for CA, NJ, RI, DC, and MA as required

Accurate COBRA reporting demonstrates compliance with both ACA information reporting requirements and protects the employer from penalty assessments. By using the correct codes and completing all applicable sections, employers document that coverage was offered during active employment and continued through COBRA, satisfying their ACA obligations.

References and Additional Resources

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