When a company has a self-funded plan, they need to report on anyone enrolled in this plan. This includes not only employees, but dependents, COBRA participants, and retirees enrolled in the self-funded plan. This enrollment information is reported either in Part III of an employee's 1095 form or as a B series form (Covered Individuals section).
Employee Navigator has put significant effort into generating the Covered Individual section for each employee's 1095 form based on your company's enrollment information in a self-funded plan. However, there may be special circumstances where the enrollment information is not reporting correctly in the Covered Individuals section. Because of this, we have created the Covered Individuals tool that allows you to override the enrollment information that is reported on Part III of the 1095-C form or on the B series forms (small self-funded groups).
The Covered Individuals Override is located on the 1095-C or 1095-B form itself. The Covered Individual section is only reported on an employee's 1095 form when an employee or their dependents are enrolled in a self-funded plan. If an employee and/or their dependents are enrolled in a fully insured plan, then they do not have a covered individual sections generated on their 1095 form because that enrollment information does not need to be reported on in Part III. However, this tool will show even if the group has fully insured plans. If a group has a fully insured plan, they should not be using this tool.
NOTE: This override will not change the enrollment record on the employee's data sheet where this information is originally being pulled.
To use the tool, navigate to the 1095 form, and select "Override" next to the employee or dependent enrollment that you wish to change under the Covered Individual section. You are able to reflect "Yes" an individual is enrolled, or "No" an individual is not enrolled under the Covered Individuals Section.
Example 1: An employee has an incorrect demographic change date that impacts the Covered Individuals Section of the 1095-C Form.
Jason works for a car dealership. For the first half of the year, he works at the Bethesda location and 9/1/17, he moves to the Rockville location. This employee is enrolled in a self-funded plan. The expectation is that Jason will receive two 1095 forms, one from Bethesda and one from Rockville reporting on his coverage and his enrollment information under the covered individuals section. When HR makes the demographic change to move the ee from Bethesda to Rockville, HR accidentally makes the change effective 11/1/18, not 9/1/2018.
What we see on the employee's 1095-C Form:
- Bethesda Auto: Covered Individual Section reflects that Jason's enrollment is Jan-Oct.
- Rockville Auto: Covered Individual Section reflects that Jason's enrollment is Nov-Dec.
EN is reflecting the Covered Individuals Section as expected based on the demographic change date of 11/1/18. However, this date is incorrect and we need to change the Bethesda Auto form to reflect the Covered Individual Section to be Jan-Sept and the Rockville Auto to reflect Oct-Dec. Using the Covered Individuals override, we are able to change enrollment information for Jason to reflect Jan-September on the Bethesda form and Oct-December on the Rockville form. We are now displaying the proper dates on the ee's forms and we will transmit those months to Nelco.
Example 2: Employee and dependent are enrolled in self-funded COBRA that rolls into a fully insured COBRA plan. They are a small employer and the B Series form is being produced.
EE: Carell, Steve; Dependent: Carell, Nancy
Steve and Nancy are enrolled in a Self-Funded plan. Steve is terminated 10/01/2018 and elects COBRA. Nancy is also on COBRA. Starting 12/01/2018, Steve and Nancy's COBRA began in a fully insured plan. However, in the system, we only show COBRA enrollments as self-funded. Using the Covered Individual Override, we are able to mark December as blank.
Example 3: Employee is enrolled in a self-funded plan for the first half of the year, and enrolled in a fully insured plan for the second half of the year and it is not reflecting it on the 1095-C form.
Mindy enrolled in a self-funded plan from 10/01/17 with no end date. Starting 10/01/18 Mindy enrolled in a fully insured plan. Because there is no end date on the self-funded enrollment, we are reflecting under the Covered Individuals section that Mindy is enrolled all 12 months. In this scenario, we would want to use the Covered Individual override tool to override Y in Oct-Dec to blank.
Example 4: Employee is enrolled in a fully insured plan.
John is enrolled in a fully insured plan for the 2018 reporting year. His enrollment information is reported on Line 16. While the Covered Individuals section is displaying on John's form, it will NOT be transmitted to Nelco. The Covered Individuals override should NOT be used, be John is not enrolled in a self-funded plan.