ACA COBRA Data Requirements

This article provides instructions and a template that will help you provide Namely with any COBRA enrollments that are not currently in our system, but must be imported for the purpose of ACA reporting.

OVERVIEW

If you have self-funded medical plans, then you must report on COBRA elections for your terminated employees and dependents as part of your ACA Reporting requirements. This means we'll need to collect COBRA data from you to import it into Namely in advance of your ACA filing.

TIP:

You should consult with your broker to confirm if this is a filing requirement for your company. 

ACA COLLECTION SHEET

Data should be provided to Namely on this spreadsheet (a preview will not be available when you download this .xls file). It's important to follow the instructions and formatting noted on the spreadsheet to ensure the data is successfully imported.

Note: You will only be asked to provide Terminated Employee Info (on the fourth sheet of the file) for employees who are not currently listed in your Namely site; otherwise, we already have the personal and demographic information required for your former employees.

CASE SUBMISSION INSTRUCTIONS

COBRA data should be provided to the Namely via the Help Community for importing.

  1. Click Submit a Case.

  2. Click I need help with something else.

  3. Use the following Case Taxonomy:

  • Product Name: Benefits Administration

  • Product Feature: ACA

  • Function: Import Employee Data

  • Subject: ACA COBRA Import

  • Description: Provide some context and additional information that can help our consultants assist you.

  1. Click Upload File to attach your completed spreadsheet containing all COBRA data for terminated employees and their dependents.

  2. Click Submit.

FREQUENTLY ASKED QUESTIONS

Why do I need to provide COBRA medical information in order to file for ACA Reporting?

COBRA medical information needs to be reported on when you are filing as either a Self Funded or Level Funded Group. If you are not sure if either of these funding types apply to you, we recommend connecting with your Managed Benefits team or third-party broker to confirm. 

Is it possible to have a COBRA plan created to manage COBRA reporting requirements in Namely? I'd prefer to do that instead of importing COBRA participants in advance of ACA reporting.

Having a COBRA medical plan available year round for terminated employees would not address this issue. Once an employee is terminated, you will no longer see them listed as an option under the enrollment section in Namely Payroll.The only way to have COBRA participants show during ACA is by completing the spreadsheet and having them imported. 

How is COBRA medical information reported on the Forms 1094 and 1095?

COBRA medical information will only be reported on Form 1095.On Form 1095-C, Part III will indicate the months of coverage that an employee elected into a medical COBRA plan, along with any dependents covered. If Form 1095-B is used instead of Form 1095-C, then Form 1095-B, Part IV will be populated with the COBRA medical information.