A non-employee who is offered COBRA coverage will only receive a 1095 form from an ALE (employer) if the ALE is self-insured and the non-employee enrolled in the COBRA coverage. If the employer is fully-insured, or the non-employee waived the COBRA coverage, the employer is not required to file a 1095 form for the individual.
If the COBRA recipient was not employed by the ALE for any month of the calendar year, code 1G on the 1095-C will be used in the “All 12 Months” or in each individual month box of line 14. Lines 15 and 16 will be left blank.
The ALE may file a 1095-B form for a non-employee who is enrolled in COBRA in place of a 1095-C if preferred.
If a non-employee individual enrolls in the coverage under a self-insured health plan, all family members that are covered individuals due to the non-employee’s enrollment must be included on the same 1095 form who is enrolled in the COBRA coverage.