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Transmittal of Health Coverage Information Returns

Form 1094-B is a transmittal form used by entities reporting health insurance coverage under the Affordable Care Act (ACA), serving as a cover sheet for Form 1095-B. It provides summary information about the reporting entity and the associated Form 1095-B returns, facilitating the IRS's understanding and processing of the information.

What is ACA Form 1094-B?

, officially titled “Transmittal of Health Coverage Information Returns,” is the cover sheet that accompanies every batch of returns sent to the IRS. Although the transmittal itself does not list individual employees or dependents, it summarizes the entire 1095‑B filing and identifies the organization responsible for providing minimum essential coverage (MEC).

  • Who must file: Health insurance issuers, government‑sponsored programs, and self‑insured employers that are not Applicable Large Employers (ALEs) use Form 1094‑B whenever they furnish 1095‑B statements.
  • Relationship to Form 1095‑B: Each 1094‑B “covers” a stack of 1095‑B returns. The 1095‑B shows the months in which specific individuals had MEC, while the 1094‑B aggregates that information and certifies it for IRS processing. (See .)
  • Key data reported:
    • Name, EIN, address, and contact info for the reporting entity.
    • Total number of 1095‑B forms transmitted in the batch.
    • Point‑of‑contact information the IRS can use to resolve errors.
    No personal health information is included on the 1094‑B itself.
  • Deadlines:
    • Recipient copies (1095‑B): Generally due to covered individuals by Friday, January 31st, 2025 of the year following the coverage year.
    • IRS filing:
      • Paper filers: Friday, February 28th, 2025.
      • Electronic filers: Monday, March 31st, 2025.
      If you transmit 10 or more combined information returns (W‑2, 1099, 1094/1095, etc.) you must e‑file.
  • Penalties for non‑compliance: Late, inaccurate, or missing 1094‑B/1095‑B filings can trigger IRS penalties of up to $310 per return (2025 rates), capped annually, plus separate penalties for failing to furnish recipient copies. See .

In short, is the IRS’ snapshot of your entire 1095‑B submission. Together, the two forms allow the Service to verify compliance with the individual‑mandate reporting rules and to match coverage data to taxpayers’ returns.

What is the difference between 1094-B and 1094-C?

1094-B and 1094-C are transmittal forms used to transmit information returns to the IRS. While they share a common function, they are used by different entities and have distinct purposes:

  • :
    • Who Files: Filed by insurance providers, including self-insured employers that are not Applicable Large Employers (ALEs).
    • Associated Form: Transmits Form 1095-B, providing information about individuals covered by minimum essential coverage.
    • Purpose: Serves as a cover sheet for the 1095-B returns, providing summary information about the provider.
  • :
    • Who Files: Filed by ALEs, which are typically employers with 50 or more full-time employees (including full-time equivalent employees).
    • Associated Form: Transmits , providing information about the health insurance coverage offered to full-time employees.
    • Purpose: Serves as a cover sheet for the 1095-C returns, providing summary information and details about the employer's offer of coverage.

While both forms play a crucial role in ACA compliance, Form 1094-B is focused on reporting minimum essential coverage provided by insurers and certain small employers, while Form 1094-C is centered on reporting offers of coverage by larger employers. Understanding the distinct requirements and purposes of these forms is essential for proper .

Can employers submit a paper filing for ACA Form 1094-B?

Employers and other entities responsible for filing have the option to submit a paper filing, subject to certain conditions:

  • Threshold: Paper filing is generally allowed if the entity is filing fewer than 10 forms. If submitting 10 or more information returns, electronic filing is typically required.
  • Method: Paper filing involves completing and mailing the physical Form 1094-B to the IRS, along with the associated Form 1095-B returns.
  • Deadlines: The deadline for paper filing may differ from the electronic filing . The paper filing deadline is was usually at Friday, February 28th, 2025.
  • Considerations: While paper filing is an option, electronic filing can provide benefits in terms of efficiency and accuracy. Entities should carefully evaluate their needs and the applicable rules to determine the most appropriate .
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Who is required to file Forms 1094-B and 1095-B with the IRS?

Forms 1094-B and 1095-B are used to report information related to health insurance coverage in compliance with the . Here's who is required to file these forms:

  • Form 1094-B:
    • Insurance Providers: Health insurance carriers that provide minimum essential coverage must file as a transmittal form with their Forms 1095-B.
    • Self-Insured Small Employers: Employers that are not Applicable Large Employers (ALEs) and provide self-insured health coverage must file Form 1094-B.
  • Form 1095-B:
    • Insurance Providers: Health insurance carriers must file to report coverage information for each individual enrolled in minimum essential coverage.
    • Self-Insured Small Employers: Employers that are not ALEs and provide self-insured health coverage must file Form 1095-B for each covered individual.
    • Government-Sponsored Programs: Entities administering government-sponsored programs (e.g., Medicaid, Medicare) must also file Form 1095-B to report coverage information.

Filing Forms 1094-B and 1095-B ensures compliance with the 's individual mandate, providing the IRS with information about who had minimum essential coverage.

Why is 1094-B required to be filed with a 1095-B?

Form 1094-B is required to be filed with Form 1095-B as part of the framework, fulfilling a specific role in the reporting process:

  • Transmittal Form: Form 1094-B acts as a transmittal or cover form for Form 1095-B, essentially serving as a cover sheet for the individual returns.
  • Summary Information: Form 1094-B provides summary information about the reporting entity and the associated , including details like the name, address, and Employer Identification Number (EIN) of the entity.
  • Contextual Details: It may include additional details that provide context for the IRS, such as the total number of Form 1095-B returns being submitted.
  • Compliance Requirement: The joint submission of Forms 1094-B and 1095-B is a compliance requirement under the ACA. Failing to include Form 1094-B with the 1095-B returns could lead to and complications in the reporting process.
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What basic information is required when filing out a 1094-B?

Form is a transmittal form used in conjunction with Form 1095-B, and it requires specific information for proper completion:

  • Entity Information: Details such as the name, address, contact person, and Employer Identification Number (EIN) of the entity responsible for filing.
  • Total Number of Forms: The total number of Form 1095-B returns being submitted with the 1094-B.
  • Contact Details: Name and contact information of a person whom the IRS can contact for more information, if needed.
  • Signature: Form 1094-B typically requires a signature to certify the information provided.

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