1094-B Electronic Filing Handoff to a Transmitter

Identify whether the transmitter will receive reviewed source data for transformation or already generated electronic files for transmission. Those arrangements require different acceptance checks. State who generates the final AIR files, who reviews them and who resolves source-data questions.

Record the filer, reporting year, internal handoff ID, version and intended filing operation. When the work follows an earlier attempt, include the actual outcome and relevant prior references instead of describing everything as a new original batch.

The third-party transmitter guidance in Publication 5165 addresses submissions filed on an organization's behalf. Your operational handoff should identify the exact scope within that arrangement, while the transmitter confirms its applicable channel and technical readiness.

This manifest is an internal handoff document. It does not replace an IRS XML manifest or establish the transmitter's file format. Confirm the actual import contract and supported workflow with the receiving team.

Ask the transmitter to acknowledge the received version and reconcile its parsed or generated return inventory with the handoff. The 1094-B line 9 instructions concern accompanying Forms 1095-B, excluding continuation sheets. Preserve separate covered-person totals if they help review the transformation, but do not substitute them for return totals.

When the transmitter transforms supplied data, obtain a reviewable output or reconciliation report tied to that transformation version. A successful import count alone may not show whether a statement was duplicated while another was omitted.

If any source or output changes after approval, identify the changed scope and repeat the affected review. Use the preflight checklist before recording the final release decision. Never infer permission to submit a different population from a review of an earlier file.

Publication 5165's third-party filing checklist calls for obtaining the electronic records in each submission, the associated transmission receipt, the completed processing status and error data when the status is other than Accepted. Set a protected location and named recipient for those artifacts.

Separate the receipt from the acknowledgment result. A receipt establishes that the file reached the IRS; the processing outcome establishes acceptance or rejection. The retrieval procedures in Publication 5258 support the transmitter's acknowledgment workflow.

Specify who will interpret errors, request source repairs and communicate subsequent outcomes. Also identify the contact who can retrieve evidence if the primary operator is unavailable. Preserving the actual electronic records and references supports future follow-up without relying entirely on a dashboard that may later become inaccessible.

Fictional example: Marsh Hollow prepares handoff MH-09 version 4 for 2025, containing 110 approved returns. An older version 3 contains 108. The review team has approved version 4 and supplied a protected link, but the transmitter's local download is still version 3.

The receiving acknowledgment reports 108 parsed returns. The reconciliation identifies two missing statement references, both included in version 4's inventory. The difference is 110 - 108 = 2, and the actual references confirm which records explain it.

The transmitter retrieves version 4, repeats the applicable parsing and validation checks, and reports the expected 110-return inventory. The release decision remains attached to version 4, and the obsolete local copy is marked superseded in the control history.

After the actual filing, the organization obtains the receipt and processing evidence for that transmitted version. A receipt associated with the older scope would not satisfy the handoff's completion record merely because it was received on the same day.

The sending team should confirm what was released; the transmitter should confirm what was transmitted and what the IRS returned. Capture both in the batch control log and submission tracker.

Keep unresolved errors or evidence gaps assigned until their actual follow-up is reviewed. If the transmitter has completed its agreed technical work but the source team still owes a correction decision, state that remaining responsibility explicitly.

Finally, record recipient-delivery and state-filing responsibilities separately when included in the service arrangement. Federal AIR evidence answers the federal transmission question. Completion of additional outputs depends on their own scope, delivery records and applicable requirements, so the handoff should not imply they occurred automatically.