Hi Carlos,
Thank you for the reply. Here's my response to your questions.
1. For the terminated employees, do you have a termination record in Actions infotype (0000)?
If so, can you confirm that employment status is not active? We have a termination record in Actions infotype (0000) with employment status withdrawn.
2. Did you configure ACA Individual Classification feature (UBAIC) to classify the
employee as a non-employee (NNE) when he or she is terminated? Yes.
UBAIC - MASSN Action Type - S6 Employee Termination - NNE
3. For the period that the employee is terminated, what is his or her status in the Check Results and Set Data for Submission to IRS transaction (HRBENUS_ACA_EVAL)? We have two
situations.
a. Terminated employees in the reporting year.
If the employee was enrolled in an active employee medical plan in the reporting year then terminates and goes on COBRA. They have an FTE, PTE etc status
for the months active in medical. They have a NEN for the months terminated and on COBRA coverage for dental and vision. That is correct. And a 1095-C should print because they had
active eligible coverage a portion of the year. The problem is the Line 14 code is 1A Coverage offered all 12 months which is incorrect because coverage was only offered when they were active. Line 16 looks correct, with a 2C for the month enrolled in active medical coverage and a 2A for the months terminated. Employees that never had active coverage in the reporting year and on COBRA dental and/or vision have a status of NEN all 12 months and are not printing a
1095-C which is also correct.
b. Dependents electing COBRA Coverage Independently regardless of reporting year.
If a dependent elects COBRA dental and/or vision independently,
in other words not under the employee’s COBRA, a 1095-C is printing. This is incorrect. Even if they were not enrolled in an active medical plan a portion of the reporting year. They have a status of NEE for the months enrolled in COBRA dental and/or vision. And NEN for the months not enrolled. Line 14 has a 1H No offer of coverage for the months enrolled in COBRA
dental and/or vision. And Line 16 is 2A not employed during the month.