— ISSUE 8 —

COBRA & ACA Employer Information Reporting

As we begin 2018, the Affordable Care Act (ACA) remains the law, and staying compliant with the ACA's reporting requirements for employers is as important as ever. With the tax reporting season upon us, one such requirement is the ACA Employer Information Reporting on Offers of COBRA Coverage for applicable large employers (ALEs).

Generally, an applicable large employer is an employer that employed an average of at least 50 full-time and full-time equivalent employees on business days during the preceding calendar year.

Beginning in January 2016 (for the 2015 tax year), the Internal Revenue Code (IRC) Section 6056 under the Affordable Care Act requires ALEs to report to the IRS the details of any health coverage offered to full-time employees. IRS Forms 1094-C and 1095-C are used for Section 6056 reporting.

The Internal Revenue Service recently released new "Questions and Answers" (FAQs) detailing how employers should report Offers of COBRA Coverage on Form 1094-C and Form 1095-C. This additional guidance from the IRS provides helpful information on scenarios related to reporting offers of COBRA coverage. A link to the guidance is provided here for your convenience:


As your COBRA administrator, we are happy to assist you with your reporting needs. As part of our services, we offer a QB Detail for ACA Report via our online COBRA employer website, which you can access via this link: https://cobra-retiree.upmc.com. To access this report, simply follow these steps from the home screen:

  • Reports
  • Standard Reports
  • QB Detail for ACA Report
  • Select the Insurance Type
  • Input your Start Date and End Date
  • Select your Report Format
  • Click on Queue Report
  • At the next screen, click on Download Results

If you need assistance accessing your online COBRA employer website or with any specific report requests, our team of dedicated COBRA analysts will be more than happy to assist you. Feel free to contact your dedicated account analyst at any time, or the COBRA department in general at COBRA@upmc.edu.

HSA Tax Forms

With tax season upon us, questions may arise regarding health savings accounts (HSAs) and tax forms. There are two tax forms associated with an HSA. These tax forms are not mailed but are available electronically on the member's UPMC Consumer Advantage website. If the member has an email address on file, they will receive a notification when the forms are available.

The 1099-SA tax form is used to report all distributions made from an HSA during the 2017 tax year. HSA members can use this form when they file their taxes for 2017 if they made any distributions out of their HSA, including debit card purchases. The 1099-SA tax form is available on members' UPMC Consumer Advantage website. The 5498-SA tax form is used to report all contributions made to an HSA during the 2017 tax year. HSA members will not be required to use this form to file their 2017 taxes. The 5498-SA tax form is available on members' UPMC Consumer Advantage website. Corrections to tax forms will be made automatically if needed. Please be aware that if any contributions are made to the 2017 tax year in 2018, a corrected tax form will be generated.

Members with health savings accounts should contact their tax adviser with any questions regarding the use of the information contained in their 1099-SA and 5498-SA forms in preparing their income tax returns.

If members need assistance with locating their tax forms, our Member Services team is available to help at 1-855-492-8762.

The above information is for informational purposes only and is not legal or tax advice. UPMC Health Plan and UPMC Benefit Management Services do not provide legal or tax advice. For legal or tax advice, please contact your attorney or tax adviser.