How is an offer of COBRA continuation coverage reported under Sections 6055 and 6056?

Author: Gloria Ju

An offer of Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage that is made to a terminated employee is reported as "no offer of coverage." However, an offer of COBRA coverage made to an active employee due to a reduction in hours is reported in the same manner and using the same code as an offer of that type of coverage to any other active employee.

An employer that sponsors a self-insured plan must report when a current or former employee's spouse or dependent (who is not an employee) receives COBRA coverage. If the spouse or dependent receives COBRA coverage because the employee has elected COBRA coverage that also covers the spouse or dependent, then they must be reported together on the same form. If the spouse or dependent is entitled to make an independent election to enroll in COBRA coverage, then they must be reported on separate forms.