March 27, 2009
Question of the Week: What Information Do We Need to Keep to Document the COBRA Credit?
Filed under: News
Vision Payroll

This week’s question comes from Sandy, an HR manager. We’ve just had our first employee sign up to receive the COBRA premium subsidy. What information do we need to keep to document the COBRA credit? Answer: Employers reimbursing employees for 65% of the eligible COBRA continuation premium must maintain specific documentation. This information is not to be submitted with the Form 941, Employer’s QUARTERLY Federal Tax Return, but must be maintained and presumably presented to the Internal Revenue Service or Department of Labor upon request. The required information is:

  1. Information on the receipt, including dates and amounts, of the assistance eligible individuals’ 35% share of the premium.
  2. In the case of an insured plan, copy of invoice or other supporting statement from the insurance carrier and proof of timely payment of the full premium to the insurance carrier required under COBRA.
  3. In the case of a self-insured plan, proof of the premium amount and proof of the coverage provided to the assistance eligible individuals.
  4. Attestation of involuntary termination, including the date of the involuntary termination (which must be during the period from September 1, 2008, to December 31, 2009), for each covered employee whose involuntary termination is the basis for eligibility for the subsidy.
  5. Proof of each assistance eligible individual’s eligibility for COBRA coverage at any time during the period from Sept. 1, 2008, to Dec. 31, 2009, and election of COBRA coverage.
  6. A record of the social security numbers of all covered employees, the amount of the subsidy reimbursed with respect to each covered employee, and whether the subsidy was for one individual or two or more individuals.
  7. Other documents necessary to verify the correct amount of reimbursement.

Earlier posts have discussed the COBRA premium subsidy in further detail. Click the COBRA tag for more information or contact Vision Payroll.


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