ACA COBRA Reporting

All of our termed and retired colleagues are all offered COBRA coverage.  Our COBRA program is administered by a third party vendor.  According to the IRS a full time colleague with healthcare who terms or retires mid-year should receive a 1095-C to reflect their active colleague healthcare offering as well as the accepted COBRA coverage.  Please see the following link (Specifically questions 16, 17 and 18.) 

https://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers-about-Information-Reporting-by-Employers-on-Form-1094-C-and-Form-1095-C#Reporting Offers of COBRA Coverage

According to the Oracle webcast on 12/8 it states that you will only be providing an interface for colleagues who receive COBRA due to a reduction in hours and terms should receive a 1095-B.