What Is Form 1094-B and Who Is Required to File?

Form 1094-B is a transmittal document, or cover sheet, used when filing health coverage information with the Internal Revenue Service (IRS). It accompanies Form 1095-B, which details an individual’s health coverage. The primary function of Form 1094-B is to summarize the batch of 1095-B forms being sent to the IRS. It provides a consolidated overview for the tax agency, indicating the total number of individual forms included in the submission. This process is part of the reporting requirements established under the Affordable Care Act (ACA).

Who Is Required to File Form 1094-B

The responsibility for filing Form 1094-B falls to specific entities that provide minimum essential health coverage. This primarily includes health insurance issuers and carriers for fully insured plans. Another group required to file this form consists of small employers with self-insured health plans. These are businesses with fewer than 50 full-time equivalent employees that are not classified as Applicable Large Employers (ALEs).

A common point of confusion is the distinction between the “B” series and “C” series of ACA reporting forms. While insurance providers and small self-insured employers file Forms 1094-B and 1095-B, Applicable Large Employers must file Forms 1094-C and 1095-C. An ALE is an employer with 50 or more full-time employees. The C-series forms serve a different purpose, focusing on the employer’s offer of coverage to its full-time workforce and compliance with the employer mandate of the ACA.

Information Needed for Form 1094-B

To accurately complete Form 1094-B, a filer must gather several pieces of information. The form itself is a one-page summary and requires the filer’s legal name, Employer Identification Number (EIN), and full mailing address. The form is available on the official IRS website.

Additionally, the filer must designate a contact person and provide their telephone number. The most significant data point on the form is the total count of Forms 1095-B being transmitted with it. This number must precisely match the quantity of individual 1095-B forms included in the batch.

How to File Form 1094-B

Once Form 1094-B is completed, filers must submit it to the IRS by specific annual deadlines. For those filing by paper, the deadline is February 28th of the year following the coverage year. For electronic filers, the deadline is extended to March 31st. Filers who are required to file a combined total of 10 or more information returns—including forms like W-2s and 1099s—must file electronically.

Paper forms should be mailed to the IRS address specified in the form’s instructions. For electronic submission, filers must use the IRS Affordable Care Act Information Returns (AIR) system. Filers who anticipate needing more time can request an automatic 30-day extension by submitting Form 8809, Application for Extension of Time to File Information Returns, on or before the original due date.