Question for Auditors

Hi Chimane,

We have a question for ACA Auditors.

There is a scenario in one of the company and we are not sure which codes should be displayed in such scenarios.

Employee is retired in the year 1987 and his benefits are present from 01/01/2015 to 10/31/2015 in Retiree plan with $0 cost.This plan is not self insured plan.He has other retiree plan qualifying offers which are from 01/01/2015 to 12/31/2015
So which codes should be displayed in this scenario on Line 14 and Line 15.
Currently,the codes displayed are 1A on Line 14 for all 12 months and on line 16,2C from 01/01/2015 to 10/31/2015 and 2A for the months Nov-Dec.
This leads to invalid code combination in the month Nov-Dec

IRS Site states that :
"Coverage of Non-Employee: This part may be completed by an employer offering self-insured health coverage for any other individual who enrolled in the coverage under the plan for one or more calendar months of the year but was not an employee for any calendar month of the year, such as a non-employee director, a retired employee who retired in a previous year, a terminated employee receiving COBRA continuation coverage who terminated employment during a previous year, and a non-employee COBRA beneficiary (but not including an individual who obtained coverage through the employee’s enrollment, such as a spouse or dependent obtaining coverage when an employee elects COBRA continuation coverage that is family coverage). If the Form 1095-C is used with respect to an individual who was not an employee for any month of the calendar year, Part II must be completed by using code 1G in the “All 12 Months” box or the box for each month of the calendar year. "

But in this case,Employee is enrolled in plan that is not self insured.
So which codes are expected in this case.

Also,another question we have is,
We were marking all medical plans as ACA plan in ACA customization.These medical plans include,Active,Cobra and Retiree plans.
On further analysis,we unmarked the ACA plan flag of cobra plans because IRS site mentions that
"An offer of COBRA continuation coverage that is made to a former employee upon termination of employment should not be reported as an offer of coverage on line 14. For a terminated employee, code 1H (No offer of coverage) should be entered for any month for which the offer of COBRA continuation coverage applies. "
"Do not enter code 2C in line 16 for any month in which a terminated employee is enrolled in COBRA continuation coverage (enter code 2A)."

So now,if any terminated employee is enrolled in cobra plans,they will get codes as 1H and 2A.
What should happen in the case of retiree employee?
What should be the codes if a retired employee is enrolled in retiree continuation coverage and/or a retired employee has offer of coverage of retiree plans.

Regards,
Ramya Tantry