Guide to Data Reporting

Introduction

The Affordable Care Act (ACA) is a health care reform law making insurance coverage more affordable and accessible for all citizens of America. By offering subsidies to those who buy health insurance through the Health Insurance Marketplace and by expanding Medicaid coverage, the law allows more people to have access to affordable health care.

What is ACA Compliance?

ACA is a law that mandates that companies with 50 or more full-time employees offer health insurance to 95 percent of their workforce or risk facing fines. Companies must also provide an annual confirmation of benefits provided by using Form 1095-C, which is a description of plans, employee expenditures, and the benefits and coverage options. 

Certain employees must be given access to health insurance, and certain employers must comply with the Affordable Care Act. Applicable Large Employers (ALE's) are companies that must comply with ACA. A company with 50 full-time equivalent employees or more on average is called an ALE. An employee is deemed full-time if they put in at least thirty hours a week on average. A person who works fewer than thirty hours per week is considered a part-time employee.

In order to deter firms from circumventing the Affordable Care Act (ACA) by solely hiring part-timers, it considers full-time equivalent workers. This is the total number of full-time workers plus a small portion of the part-time workforce. By dividing the total number of hours worked by all part-timers by 30, you can convert the number of part-timers to full-time equivalents.

*For example, if you employ 40 full-time workers and 15 part-time workers that combined work 300 hours a week, you would have 50 full-time equivalent workers (40 + 300/30 = 50) and be required to offer health insurance coverage to eligible employees.

Furthermore, it is not necessary to provide health insurance to every employee. For instance, workers who put in fewer than thirty hours a week are not regarded as full-time workers and are not required to be offered health insurance. Workers who have been employed by a company for less than three months are likewise exempt from having to be offered health benefits.

How can ACA Track Help with Compliance?

ACA Track requires information about employees and their eligibility for health insurance coverage throughout the current reporting year (January 1 - December 31) to generate 1095C forms. 

ACA TRACK will calculate the monthly code combinations for each of your eligible employees based on   the details of their job status and health insurance coverage changes that may occur throughout the year.  To simplify the data collection process, you can download information from your HRIS System directly into our user-friendly template This guide will walk you through the details of the information required, providing examples for reporting various employment or coverage change scenarios that occur throughout the year.  

What Information Do We Need?

To complete a 1095C form for each of your eligible employees, you will need to provide information regarding their Employment History and Health Insurance Coverage History.

Employment History

To determine an employee’s eligibility for insurance under the Affordable Care Act, the IRS requires employers to track their employees’ Job Status (ie, Full-Time, Part-Time, Leave, Non-Employee) during each month of the year.

If an employee changes their job status during the year, those status changes need to be reported in your data for ACA Track to calculate the eligibility codes.

Health Insurance Coverage History

The Health Insurance Coverage History describes the nature of eligibility and coverage type that an employee has throughout the year. Since these may change during the year, often because of changes in an employee’s Job Status, companies are required to track these changes for each employee, primarily to show if an employee is eligible or ineligible.  

Job Status and Coverage Changes

Many of your employees will have the same job status and coverage type (insured or waived) over the course of the year. However, it is not uncommon for employees to change these statuses (sometimes multiple times). 

For instance, a part-time (referred to the IRS as "variable hour") employee may be promoted to a full-time position. Or an employee may experience a qualifying life event, which results in a mid-year change to their health insurance coverage type.

Since any status change can potentially impact an employee’s eligibility for health insurance under the Affordable Care Act, the IRS requires employers to document any status change that impacts their eligibility for health insurance throughout the year.

Fortunately, ACA TRACK simplifies this process for Clients. Rather than tracking each employee’s month-by-month status, you simply record the date(s) of any change(s) that occurred during the year. Once that information is uploaded into the ACA TRACK system, we will assign the proper status to each employee for each month of the year.

Creating Your Employee Datasheet

Understanding the Data Fields

To develop the required month-by-month codes for employees, ACA TRACK needs details regarding each employee, their job status, and their coverage type.

We have developed an easy-to-use Employee Data Template, to provide this information. On the spreadsheet, we have listed several key fields that are required.

Understanding these fields, and how to report unique scenarios, will help ensure a smooth reporting process. In the section below, you will find an explanation for each field, as well as any special requirements or guidelines that should be followed when filling them in.

Personal Information

For each employee on the file, we need personal information including Social Security Number, Name, Address and Country Code. All fields marked with an asterisk (*) are required fields.

Employee SSN* (Social Security Number)

1. Formatting Requirements:  SSN can be entered with or without the dashes: 123-45-6789 OR 123456789. You must include all 9 digits.  If the SSN begins with 0, please format accordingly. 

Last Name*, First Name*, Middle Initial

1. These fields should contain the employee’s full legal name, exactly as it is recorded with their government issued identification.

1. Formatting Requirements:  These fields should contain text only; special characters will be rejected by the ACA Track System and the IRS. 

Address*, Address 2, City*

1. Formatting Requirements: These fields will accept any combination of numbers and letters.  Proper capitalization is recommended for best results.
   

1. There is a maximum length of 22 characters for City: 35 characters for Address and Address2. 

State*

1. Formatting Requirements:  Use the two-digit state abbreviation code ONLY. Do not spell out the state’s name.

Zip/Post Code*

1. Formatting Requirements:  Five or nine-digit format. If nine-digit, dash is required (12345-6789).

Country Code *

1. Formatting Requirements:  For US-based employees, enter “US”. Otherwise, enter the approved country code (see Appendix 3).
   

Employment History

The employment history section allows ACA Track to capture and code any changes in Job Status throughout the year. 

Hire Date – This can refer to the employee’s original date of hire, rehire date, or the date an employee changed to a new division (or EIN) within your company.

1. Requirements: If the record is for an employee, this field is required. If the record is for a non-employee, the field should be left blank.
   

1. Formatting Requirements:  mm/dd/yyyy

Term Date – For the purpose of this guide and ACA TRACK data collection, “Termed” or “Terminated” is used in cases of both voluntary and involuntary termination of employment. This field is also used to track certain job changes, such as moving to a new division within your company.

1. Requirements: If the employee is no longer with your company, this field is required. If the employee terminated in a year prior to the current reporting year, they may be excluded.

1. Formatting Requirements:  mm/dd/yyyy
   
1. Special Note: The Term Date MUST be more recent than the Hire Date.

Status Begin Date* –The start date for the employee’s Job Status (FT, PT, Leave, or Non-Employee.).  In most cases, this will be the same as the hire date, unless the employee experienced a change in the current reporting year.

1. Formatting Requirements:  mm/dd/yyyy
   

1. Handling Changes: If an employee has experienced a Job Status change during the year, this will require multiple data rows. The “Status Begin Date” should be adjusted for each new entry. (see Capturing Changes starting on page 14 for examples)

Job Status* – The employee job status during the time of employment must be reported to properly apply codes to the 1095c form. The following common values represent the types of job status that must be reported:

1. Full-Time:   An employee who works on average at least 30 hours of service per week, or 130 hours of service per month.  
   

1. Variable-Hour: An employee whose hours are uncertain or variable, making it difficult for their employer to determine if they work at least 30 hours per week on average. This definition is based on the facts and circumstances at the start date of the employee's service.
   

1. Leave: Used only for employees that lose benefit eligibility (Unprotected Leave). Protected leave should be reported as full-time or variable hour, based on the employee’s circumstances. 
   

1. Non-Employee: Individuals not employed by your company at any point during the current reporting year but who were the primary insured subscriber: spouses, severance recipients (terminated in previous year), retirees, and COBRA primary dependents. Non-employee cannot be used for someone employed at any point in the reporting year. 

1. Conversion:  Since companies may have their own internal Job Status codes, employers are not required to use the standard codes in your data file.  ACA TRACK will convert your codes to the IRS standard status codes. This “mapping” process will be handled later, using the ACA TRACK software. 

1. Formatting Requirements:  This field accepts any combination of alphanumeric characters
   

Division* – For reporting purposes, Division refers to each separate tax entity (EIN) within your company where individuals may be employed.

1. Formatting Requirements:  This field accepts any combination alphanumeric characters. 
   

1. Conversion: Division codes on your spreadsheet do not need to match the division names used within the ACA TRACK software (they will be “mapped” later), but they should be consistent.

Health Insurance History

The Health Insurance History section allows us to track and report any changes to each employee’s health insurance coverage or eligibility throughout the year. 

Plan ID – The lowest-cost health-care plan offered to the respective employee.

Coverage Begin Date* – The start date for the coverage specified on the respective data row. 

1. Formatting Requirements:  mm/dd/yyyy
   

1. Note: If the coverage began in a prior year, you may enter 1/1/20xx (current reporting year), however dates prior to the start of the year are accepted too.

Coverage End Date – The date a specific coverage, or coverage type ended. If the employee was not eligible or waived coverage, and that changed, this row would still need a coverage end date.

1. Requirements: If the employee’s coverage changed during the year, a Coverage End Date is required for all previous coverage types.
   

1. Formatting Requirements:  mm/dd/yyyy
   

1. Special Note: The date listed in this field MUST be after the date listed in the corresponding “Coverage Begin Date” field.

Coverage Type* – The type of health insurance coverage (or non-coverage) provided during the specified time period. The following common values represent the types of coverage that must be reported:

1. Insured:  Employee was eligible for company health insurance and elected coverage.

1. Waived: Employee was eligible for health insurance, but waived or declined the coverage.
   

1. Not Eligible: Employee was not eligible for health insurance. (Example: They are not full-time.)
   

1. COBRA Not Employed: Termed employee or covered dependent elects COBRA coverage. This is only reported on self-insured plans.
   

1. COBRA Reduction in Hours: Employee elected COBRA coverage after experiencing a reduction in hours (ex. moving from full-time to variable hour), 
   

1. COBRA Waived: Employee was offered COBRA coverage due to a change in job status (such as full-time to part-time) due to a reduction in hours, and waived COBRA coverage. Cobra Waived SHOULD NOT be used for terminated employees. 
   

1. Union Provided: Health insurance benefits were provided by an employer-sponsored union.
   

1. LNAP: Limited Non-Assessment Period. This is the term used for an individual that is in a waiting period until coverage can begin.
   

1. Eligible No Offer Given: Employee was eligible for coverage, but it was not offered

1. Conversion:  Since companies may have their own internal Coverage Types, employers are not required to use the standard codes in your data file.  ACA TRACK will convert your codes to the IRS standard status codes. This “mapping” process will be handled later, using the ACA TRACK software. 

Unaffordable Coverage Offered

If the lowest-cost, single-only health plan monthly contribution is unaffordable; meaning that it does not meet the requirements of any of the three allowable Affordability Safe Harbor Methods (W-2, Rate of Pay, or Federal Poverty Level), it is the employer’s responsibility to report the offer as unaffordable coverage.  

1. Requirements: This field is optional and only required If the lowest-cost, single-only health plan offered is unaffordable.  
   

1. Formatting Requirements: This field accepts “Yes” or blank.

Employee Contribution and Total Individual Premium 

*Only Required for unique situations, discuss with your ACA Reporting Specialist if applicable.

Employee Contribution and Total Individual Premium (Employee/Employer)

If a plan’s cost varies due to an employee’s age, salary, location, or other variable, you should report specific plan costs on your Employee Datasheet, rather than in the Plan Information section of the ACA Track system.

The costs being reported in this section, if applicable, should be the costs associated with the monthly contributions and premiums associated with the lowest cost medical plan offered to the employee and not the costs associated with the medical plan or coverage tier that the employee may or may not have elected.

For more information on setting up Employee-based contributions and premiums, contact your ACA Reporting Specialist.

1. Requirements: This field is optional and only required if medical plan contributions and premiums vary by employee. 
   

1. Formatting Requirements: These fields accept numeric characters or blank. 

State Reporting

If you have employees that were residents of California, District of Columbia (DC), New Jersey or Rhode Island at any point during the reporting year, you may be required to complete reporting at the state level, as well as the federal level. ACA Track offers reporting options for these states, so please contact your ACA Reporting Specialist for further information.

1. Requirements:   This field is optional and only required if an employee requires state filing services; the reporting requirements vary between the states, please contact your ACA Reporting Specialist for individual state requirements  
   

1. Formatting:  This field accepts “NJ, DC, CA or RI” state abbreviations; If the employee needs to be reported in more than one state, then list multiple two-digit state abbreviations separated by a comma (","). For example: “CA, NJ”
   

1. If the employee does not reside in CA, DC, NJ or RI, or if you have not elected state reporting services; leave this field blank

Entering Your Employee Data

What to Include

Your employee data sheet must include information for any employees that were eligible for health insurance at any point during the reporting year

Fully Insured Plans:

Any employee (Full Time or Variable Hour) who was actively employed by your company, and eligible for health insurance at any point in the current reporting year.  This includes the following employee categories that are often over-looked:

1. Employees on Leave
   

1. Terminated Employees
   

1. Waived Employees
   

1. Union Employees

Self-Insured (Level Funded) Plans:

Any employee (Full Time or Variable Hour) who was actively employed by your company, and eligible for health insurance through your company at any point in the current reporting year.  This includes the subsets of employees noted above, with some additions.  Self-insured plans have some additional categories to capture:

1. Employees on Leave
   

1. Terminated Employees
   

1. Waived Employees
   

1. COBRA participants 
   

1. Dependents enrolled in health coverage
   

1. Retirees and surviving spouses who are covered by the employer sponsored plan with primary coverage.
   

If an employee has had no changes to their job status, EIN/Division or insurance coverage over the course of the year, you only need to provide a single line of information, detailing their personal information, hire date, job status, coverage begin date and coverage type.

The same information is reported for new employees as well, provided there are no further changes to their job status, EIN/Division or coverage type during the current calendar year.

Below are common examples for reporting various employment scenarios on the ACA Track Template.

*Note: To increase readability, we have hidden several of the Personal Information fields from these examples. These hidden fields are still required when filing your employee data

Full-time, Waived Coverage

Variable-hour (Part-time), Not-Eligible for Coverage

Optional, a 1095c form is not required to be issued if an employee is not eligible for health insurance during the entire reporting year. Employees that are eligible for health insurance coverage at any time during the year must be reported.

1. Plan ID: Leave this field blank, since they are not eligible for coverage.
   

Full-time, Insured Employee – Hired Mid-year

Employees hired AND eligible for coverage during current reporting year: 

When entering new employee data, pay close attention to:

1. Coverage Begin Date: This will depend on your company’s waiting period and coverage start date. The example above assumes a 60-day waiting period, with coverage beginning on the first of the following month.

Full-time, Waived Employee – Hired Mid-year

Employees hired AND eligible for coverage during current reporting year but waived the offer of coverage: 

1. Note: Even though the employee waived coverage, you must still enter the lowest-cost plan offered and the date coverage was first available to them. Additionally, the coverage begin date for a waived employee is the date they were ELIGIBLE for coverage to begin, should they have chosen to elect it.

New, Full-time Employee – Not Eligible for Coverage Until Next Year 

Optional, a 1095c form is not required if an employee is not eligible for health insurance during current reporting year

If your company requires a waiting period before new employees are eligible for coverage, and that employee will not be eligible until the next calendar year, you have two options: 

To report an employee as not eligible for coverage because they are still in the waiting period, simply leave the Plan ID blank and code the Coverage Type as LNAP (Limited Non-Assessment Period):  

Employees with Job Status, Division and / or Coverage Changes

Since the IRS requires a month-by-month breakdown of every employee’s Eligibility for coverage (reflected by their Job Status) as well as their Coverage Status, it is necessary to track any of these changes that may occur throughout the year. 

When recording Job Status changes that have occurred during the reporting year, only include those job status changes that have resulted in a change to health insurance eligibility. 

For example, if an employee changed from Full-time -32 hours a week to Full-time 40- hours a week, but the health insurance eligibility and plans remain the same, this does not need to be reported. 

Status Change

When an employee moves from variable hour (part-time) to full-time, or from full-time to variable hour, it could affect their eligibility for health insurance, and this will need to be reported to the IRS.

Full-time to Variable Hour (Part-time)

When a full-time employee is moved to variable hour (part-time), or their hours drop to part-time level, they will typically no longer be eligible for health insurance. In this case, they should have the option to elect COBRA Coverage for a period of time.

To properly report this, you will need to provide details of the change, and to note whether the employee accepted or waived the COBRA coverage:

1. Status Begin Date: This should reflect the employee’s first day as a variable hour(PT) employee.
   

1. Job Status: In this scenario, the employee is moving from FT (full-time) to VH (variable hour). 
   

1. Note: Your company may use different codes. ACA TRACK will convert those to IRS standard codes based on any mapping values you provide.
   

1. Plan ID: This field should remain unchanged since the employee did not switch to a different medical plan when they reduced hours.
   

1. Coverage Type: Be sure to specify whether the employee elected (COBRA Reduction in Hours) or waived (COBRA Waived) coverage. 
   

1. Coverage Type Dates: It is essential that the original Coverage End Date and the new Coverage Begin Date do not overlap. In most cases, the new Begin Date (line 2) will be the day following the original End Date (line 1).

Variable Hour (Part-time) to Full-time

When variable hour employees are moved to full-time, or their hours increase to full-time levels, they normally become eligible for health insurance benefits. The examples below show how your data would be represented based on no waiting Period (eligible immediately) and a waiting period:

No Waiting Period - If employees are not subject to a waiting period when moving to full-time: 

1. Status Begin Date: This should reflect the employee’s first day as a full-time employee.
   

1. Job Status: In this scenario, the employee is moving from VH (variable hour) to FT (full-time). 
   

1. Note: Your company may use different codes. ACA TRACK will convert those to IRS standards based on a mapping you provide.
   

1. Plan ID: Because the employee was not eligible for coverage before, there is no Plan ID in the first line. Now that they are eligible, you need to enter the Plan ID for the lowest cost plan offered as a result of becoming eligible.
   

1. Coverage Type: Enter “Insured” if they elected coverage, or “Waived” if they waived coverage.  
   

1. Note: Your company may use different codes. ACA TRACK will convert those to IRS standards based on a mapping you provide.
   

1. Coverage Type Dates: Make sure your coverage dates do not overlap. In most cases, the new Begin Date (line 2) will be day following the original End Date (line 1).
   

Waiting Period - If employees are subject to a waiting period, insert an additional data row for the time the employee was full-time but not yet eligible for health coverage:

4. Status Begin Date: Line 2 should note the day the employee changed to full-time. Line 3 should use the same date, since there was no further change to the employee’s Job Status.
   

1. Plan ID: Since the employee does not have coverage until the waiting period ends, you do not enter the Plan ID until the third line.
   

1. Coverage Type: During the waiting period (line 2), the employee’s Coverage Type should be listed as LNAP (Limited Non-Assessment Period). Once the waiting period is over (line 3), enter “Insured” or “Waived”, depending on whether the employee accepted coverage.
   

1. Coverage Type Dates: It is very important that these dates do not overlap and there is no gap in coverage. Notice above, each new Begin Date is the day following the previous End Date. 
   

Division Changes

If your company has multiple divisions (EIN's), it is not uncommon for employees to transfer from one division to another. When they do, it is necessary to enter a change line, so the IRS is notified they are now receiving health insurance through another tax entity. This change is represented by entering a termination date on the old EIN/Division and a hire date on the new EIN/Division. With this change in division, the employee may or may not be eligible for the same plan:

Division Change with the Same Plan

If the employee remains on the same plan, it is necessary to add a data row in order to capture the division change and change in coverage dates (since it is being provided by a different tax entity):

Here are the key details you’ll need to capture:

1. Term Date: For reporting purposes, the Term Date field is used to represent the date the employee “left” their first division. 
   

1. Hire Date: The line 2 Hire Date should be the date the employee began at the new division.
   

1. Status Begin Date: This should match the Hire Date in the second line. Even though the employee still has the same Job Status, their location changed, so we need to note it here.
   

1. Division: The first line should refer to the employee’s original division, while the second line should list their new division.
   

1. Coverage Type: Be sure to select whether coverage was “Insured” or “Waived” both before (line1) and after (line 2) the change.
   

1. Coverage Type Dates: Make sure your coverage dates do not overlap. In most cases, the new Coverage Begin Date (line 2) will be day following the original Coverage End Date (line 1).
   

Division Change with a New Plan 

If the employee is moving to a division that offers a different low-cost plan, note the employee’s plan change as well:

1. Plan ID: List their original plan in line 1, and their plan at the new division in line 2.
   

1. Everything else in this scenario should be coded in the same way as a Division Change with the Same Plan (above).

Leave

There are certain instances where you need to report an employee Leave of Absence to the IRS. The exact coding will vary, depending on whether they are eligible for benefits during their leave. If the employee is on leave but still eligible for the same coverage and remains insured or waived, there is no action needed. If an employee is on a leave in which they are no longer eligible for coverage, this change should be recorded:

Leave – Keeps Insurance Benefits

If there were no changes to an employee’s coverage while on leave, there is no need to document it on your spreadsheet. List them the same as you would any other employee:

Leave – Keeps Insurance Benefits, Then Returns Part-time

Employee returns to work part-time, note the change in Job Status and Coverage Type. 

Typically, these employees will become ineligible for health insurance coverage through the employer, and may be eligible for COBRA, based on a reduction in hours. However, if the employee was not insured prior to the leave, then the Variable Hour row would have a coverage type of Not Eligible.

1. Line 1: This line represents both active employment and the period of leave for which the employee was covered under insurance (since is it not necessary to report covered leave differently).
   

1. Coverage End Date: This is the day the employee’s insurance coverage ended (because they became VH). In the example above, this occurs at the end of the month. This could also happen immediately, depending on your company policy. 
   

1. Line 2: This represents the employee’s return to work.
   

1. Coverage Begin Date: Make sure the Begin Date in line 2 is later than the End Date in line 1. Typically, this will be the next day.

Leave – Initially with Coverage, but then Coverage is Lost (COBRA Offered)

There are times when an employee who is initially offered coverage during a leave period may elect to extend that leave beyond their eligibility period. In this situation, the employee may become eligible for COBRA during their Leave period:

1. Line 1: This line represents both active employment and the period of leave for which the employee was covered under insurance (since is it not necessary to report covered leave differently).
   

1. Coverage End Date: This is the day the employee’s insurance benefits ran out (while they were on leave).
   

1. Line 2: There are a few unique entries here:
   

1. Status Begin Date: This is the day the employee began their leave.
   

1. Job Status: Because the employee is changing Coverage Type, it is now necessary to update their Job Status to “Leave.”
   

1. Coverage Begin Date: Make sure this date is after the Coverage End Date from line 1. Typically, it will be the very next day.
   

1. Coverage Type: Enter “COBRA Reduction in Hours” or “COBRA Waived” depending on the selection.
   

Leave – Extends Leave Beyond Coverage Period, Waives Cobra, and Returns FT with Waiting Period

In this more complex example, an employee extends their leave past the protected period, losing coverage. At this point, the employee is offered COBRA, but waives coverage. When they return to work full-time, they are subject to a waiting period.

1. Line 1: Represents their FT employment AND the part of leave they remained insured.
   

1. Coverage End Date: This is the date their coverage expired (while still on leave).
   

1. Line 2: Because the employee extended their leave past the protected period, they lose coverage and are offered COBRA.
   

1. Status Begin Date: This is the date they first went on leave.
   

1. Coverage Begin Date: This is the day they were no longer eligible for health insurance coverage (should be 1 day after the Coverage End Date from Line 1). 
   

1. Line 3: When the employee returns to work, they enter a waiting period. In this scenario, because they waived COBRA coverage, they have no insurance during this period, so:
   

1. Plan ID: Leave this field blank.
   

1. Coverage Type: Use LNAP (Limited Non-Assessment Period).
   

1. Line 4: Following their waiting period, the employee is once again eligible for health insurance coverage. 
   

1. Status Begin Date: Since their Job Status has not changed since Line 3 (when they returned to work full-time), use the same date from Line 3.
   

1. Coverage Begin Date: This is the first day they were again eligible for health insurance coverage. It should be 1 day after the Coverage End Date from Line 3.

Termed Employee

When employment ends during the current reporting year, whether voluntary or involuntary, the termination date must be documented for 1095C form code purposes 

Full-time Employee Ends Employment – Fully Insured Plan

When Full-time employees terminate during the calendar year, add the Termination (Term) Date and the Coverage End Date:

1. Term Date: This should be the employee’s last day of work.
   

1. Coverage End Date: This will vary, depending on whether your company offers coverage through the end of the month, or ends coverage immediately.
   

1. IMPORTANT NOTE: Even if the employee has waived coverage, it is still important to enter a Coverage End Date to document when the Waived status ended.

1. COBRA: Fully insured employers do not need to document COBRA coverage due to a termination. Your insurance carrier will report that information on a 1095B form.
   

Full-time Employee Ends Employment, Elects COBRA – Self Insured Plan

If your company is self-insured, and the employee elects COBRA coverage after the termination date, you must add that information:

1. Term Date: The Term Date should match for both entries.
   

1. Coverage Type Dates: The COBRA coverage should begin immediately following the end date for the employee’s traditional coverage. 
   

1. Coverage Type: If the employee elected COBRA benefit after termination, enter “COBRA Not Employed.” If the employee waived COBRA benefits, DO NOT enter a COBRA line on your spreadsheet. 

Rehires

It is not uncommon for a terminated employee to be rehired at a later date. If that happens in the same reporting year, document the termination, and then add the rehire details:

1. Term Date & Hire Date: Make sure there are no overlaps. The Term Date in the first line must be earlier than the Hire Date in the second line.
   

1. Coverage Type Dates: Make sure there are no overlaps. The Coverage End Date in the first line must be earlier than the Coverage Begin Date in the second line.
   

1. End Date: The initial Coverage End Date (first line) will vary depending on whether benefits are extended through the end of the month or end immediately.
   

1. Begin Date: The new Coverage Begin Date (second line) will vary depending on whether your company requires a waiting period. 
   

Note: If the termination and rehire did not result in a break in coverage (usually the termination and rehire are in 

the same month), the change does not need to be recorded).  If your company is self-insured, and the employee elected COBRA after the Termination, you also need to capture that information:

1. Term Date & Hire Date: The Term and Hire Dates in the first two lines should match, since they refer to the same period of employment. The third line refers to their new employment, so the Hire Date should be later than the previous Term Date.
   

1. NOTE: If there are additional lines from the original employment period (ex. Employee moved from FT to VH), the Term Date should be included in ALL lines prior to the rehire.

1. Coverage Type Dates: Make sure there are no overlaps. The Coverage Begin Date for each new line should be later than the Coverage End Date in each preceding line.
   

1. End Date: The initial Coverage End Date (first line) will vary depending on whether benefits are extended through the end of the month or end immediately.
   

1. Begin Date: The rehire Coverage Begin Date (third line) will vary depending on whether your company requires a waiting period in rehire scenarios.
   

Note: In this example, the employee continued COBRA until the end of their rehire waiting period, so there was no gap in coverage. If they ended COBRA before then, the Line 2 Coverage End Date should be updated to reflect their gap in coverage. 

Appendix 1: Common Data Errors

Below is a list of the most common data errors, to help you avoid them and to streamline the reporting process.

Blank Cells 

A blank cell in any of the columns marked “Required” will cause a validation error and need to be corrected.

Before uploading your data sheet, make sure that all fields marked with an asterisk (*) are filled in for all employees.

Overlapping Time Periods

When an employee changes coverage (due to a Plan change or Coverage Type change), the original Coverage End Date must occur prior to the new Coverage Begin Date, or it will be viewed as an overlap in coverage. 

Missing or Incorrect Country Code

The country code field is required this year, and it must be filled in with an IRS-approved code. For a complete list of approved country codes, see Country Codes list at the bottom of this guide.

A Country Code is required for ALL employees, even those who live in the United States (US). 

Missing Division Code

A Division Code is required for all lines of employee data, even if your company only has one division. 

Additionally, the division code listed must match the appropriate Division Code you provided to ACA Track.

Missing Plan ID

1. A Plan ID is required for all lines of employee data, even if your company only has one health insurance plan. The only times a Plan ID is not required is when the Coverage Type is LNAP, Union Provided, or Not Eligible.
   

1. A Plan ID is required even if the employee waived coverage.
   

1. The Plan ID listed must match the appropriate Plan ID you provided to ACA Track.
   

Invalid Job Status

The Job status field should only be used to report whether an employee was Full-time, Variable Hour, Leave, or Non-Employee (your exact codes may vary, depending on the mapping information you provided).

Active/Terminated are NOT valid Job Status codes. 

Missing Job Status for Termed Employees

For terminated employees, you must still enter the Job Status they had while actively employed.

Missing Coverage Dates for Employees Who Waived Coverage

Coverage Dates are required for all employees, even if they waived coverage. The coverage begin date is the date the employee was eligible to receive coverage. The coverage end date should be blank unless they are no longer eligible for coverage, and then it should be the date eligibility ended.

Invalid Formatting or Interpretive Formatting

When entering employee data, all information must be explicitly provided using the designated columns and following the guidelines outlined in this Employee Data Guide 

Note that:

1. Any colored highlighting or formatting will be ignored.
   

1. Notes of any kind will be ignored or result in a data error.
   

Appendix 2: Field Requirements Grid

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