1. Introduction – What is Form 1094-B?
IRS Form 1094-B, officially titled “Transmittal of Health Coverage Information Returns,” is an official federal transmittal cover return administered by the Internal Revenue Service (IRS), an agency of the U.S. Department of the Treasury.
It is authorized under Internal Revenue Code (IRC) Section 6055, enacted as part of the Affordable Care Act (ACA). Form 1094-B is used by health insurance carriers, small self-insured employers, and government coverage providers as a transmittal cover sheet when submitting batches of Forms 1095-B (“Health Coverage”) to the IRS.
2. Purpose of the Form – Why Does Form 1094-B Exist?
Under ACA Section 6055, entities that provide “minimum essential health coverage” (MEC) are required to report annually to the IRS which individuals maintained qualifying health insurance coverage during the calendar year.
While Form 1095-B details month-by-month health coverage for each insured individual or family member, the IRS requires a master summary sheet when processing batches of these information returns.
Form 1094-B serves as this master transmittal cover return. It identifies the reporting coverage provider, verifies the total headcount of attached Forms 1095-B, provides primary administrative contact details, and certifies that health coverage reporting satisfies federal ACA compliance rules.
3. Who Needs to File This Form
Form 1094-B is completed at the health coverage provider or small employer level. You must complete and file Form 1094-B if your organization acts as a minimum essential health coverage provider under IRC Section 6055:
- Health Insurance Issuers & Carriers: Commercial health insurance companies providing individual or group health insurance policies.
- Small Self-Insured Employers (<50 FTEs): Small business employers with fewer than 50 full-time equivalent employees that sponsor self-insured health plans for their workers.
- Government Agencies & Sponsors: Federal, state, or local government agencies providing government-sponsored health coverage (such as Medicare, Medicaid, CHIP, or VA health benefits).
- Multi-Employer Health Plans: Multi-employer plan sponsors providing health benefits to union members or collective bargaining groups.
4. Who Is Exempt / Not Required to File
You do not need or are not permitted to file Form 1094-B if your organizational situation falls into any of these exempt categories:
- Applicable Large Employers (ALEs): Employers with 50 or more full-time equivalent employees file Form 1094-C and Form 1095-C instead under ACA Section 6056.
- Employers with Fully Insured Health Plans: Small employers that offer fully insured commercial group plans where the insurance carrier, rather than the employer, files Form 1094-B.
- Individual Policyholders & Employees: Insured individuals and workers do not file Form 1094-B (they receive Form 1095-B for their personal tax records).
- Employers Offering No Health Coverage: Businesses that do not provide or sponsor health insurance benefits.
5. When to File
Form 1094-B is an annual transmittal form tied directly to the health coverage calendar year (January 1 through December 31).
Filing deadlines depend on whether the transmittal is submitted on paper or electronically:
| Submission Method | Form 1094-B / 1095-B Filing Deadline |
|---|---|
| Paper Filing (Fewer than 10 returns) | February 28 following the coverage year |
| Electronic Filing (AIR System) | March 31 following the coverage year |
Coverage providers requiring additional 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.
6. Where and How to File
Under the Taxpayer First Act, electronic filing is mandatory for any coverage provider filing 10 or more information returns in aggregate.
Electronic transmittals are processed through the IRS ACA Information Returns (AIR) system using approved XML software. Small filers submitting fewer than 10 paper forms (under an approved waiver) mail signed Form 1094-B directly on top of Copy A of paper Forms 1095-B to the specific IRS service center address as per instructions for Form 1094-B.
7. Step-by-Step Instructions to Fill the Form
Form 1094-B is a streamlined 1-page transmittal sheet that captures coverage provider details, contact information, and total form counts. The table below outlines the core lines on the form.
| Form Line | Line Name | Instruction / Description |
|---|---|---|
| Line 1 | Filer / Provider Name | Enter the full legal business name of the health insurance carrier, small employer, or government sponsor. |
| Line 2 | Employer Identification Number | Enter the coverage provider’s nine-digit federal Employer Identification Number (EIN). |
| Lines 3–8 | Contact Person & Address | Enter primary contact person’s name, daytime telephone number, and mailing address. |
| Line 9 | Total Forms 1095-B Enclosed | Enter the exact total headcount of paper or electronic Forms 1095-B transmitted with this cover sheet. |
| Lines 10–18 | Employer Information | Complete only if the coverage provider is a small self-insured employer (reporting employer EIN and address). |
| Signature Block | Authorized Officer Signature | Requires the signature, official title, and date of the authorized coverage provider officer. |
Detailed Filling Steps
- Enter Coverage Provider Details (Lines 1–8): Enter your organization’s legal business name, nine-digit EIN, street address, and the name and phone number of the administrative contact person handling ACA inquiries.
- Report Form 1095-B Count (Line 9): Count the total number of individual Forms 1095-B transmitted in this batch and enter the exact headcount on Line 9.
- Complete Small Self-Insured Employer Section (Lines 10–18): If you are a small self-insured employer (under 50 FTEs) providing coverage to your workers, complete Lines 10 through 18 with your business details. If you are an insurance carrier, leave Lines 10 through 18 blank.
- Sign and Submit: An authorized corporate officer, plan administrator, or trustee must sign, date, and enter their official title.
- Transmit with Forms 1095-B: Submit Form 1094-B electronically via the AIR system or place the signed paper cover sheet loose on top of paper Copy A Forms 1095-B before mailing.
8. Required Documents/Information Needed Before Filling
To ensure an accurate Form 1094-B submission, gather the following organizational and healthcare records before preparing the form:
- Coverage Provider EIN: Nine-digit federal Employer Identification Number for the insurance carrier, employer, or government sponsor.
- Complete Batch of Forms 1095-B: Verified Copy A records for all covered primary insured individuals and family members.
- Batch Headcount Tallies: Final count of all Forms 1095-B transmitted in the filing batch.
- AIR System TCC Credentials: Transmitter Control Code (TCC) login details if transmitting electronically via the IRS AIR system.
9. Common Mistakes to Avoid
Errors on Form 1094-B can cause IRS transmittal rejections and late-filing information fines. Watch out for these frequent mistakes:
- Filing Form 1094-B Instead of Form 1094-C: Filing Form 1094-B when your business is an Applicable Large Employer (ALE with 50 or more FTEs). ALEs must file Form 1094-C and Form 1095-C.
- Paper-Filing Over the 10-Return Limit: Mailing paper Forms 1094-B/1095-B when filing 10 or more total information returns in aggregate, which violates federal e-filing mandates.
- Mismatched 1095-B Form Counts: Entering a number on Line 9 that fails to equal the exact headcount of attached Forms 1095-B.
- Stapling Paper Cover Sheets: Stapling Form 1094-B to underlying paper Forms 1095-B, which damages forms during automated IRS machine scanning.
- Submitting as a Standalone Form: Transmitting Form 1094-B without enclosing or transmitting the underlying Forms 1095-B.
10. Penalties for Non-Filing or Errors
Failing to submit Form 1094-B or filing inaccurate transmittals carries strict information return penalties under IRC Section 6721:
- Information Return Failure Penalties (IRC Section 6721): Fines for late or unfiled Form 1094-B/1095-B transmittals range from **$60 per return** (if filed within 30 days) up to **$310+ per return** for late filings, with fines exceeding **$630+ per return** for intentional disregard!
- Electronic Filing Mandate Penalties: Submitting paper forms when required to e-file electronically incurs penalty fines under Section 6721 for improper format filing.
- State ACA Reporting Penalties: Several states with individual healthcare mandates enforce separate state-level filing deadlines and penalties for unfiled health coverage transmittals.
11. Related Forms or Schedules
Benefits managers and plan administrators handling Form 1094-B frequently interact with these related federal tax forms:
- Form 1095-B: Health Coverage.
- Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns (for ALEs).
- Form 1095-C: Employer-Provided Health Insurance Offer and Coverage.
- Form 8809: Application for Extension of Time To File Information Returns.
- Form SS-4: Application for Employer Identification Number.
12. Frequently Asked Questions
1. What is IRS Form 1094-B used for?
Form 1094-B is a federal transmittal cover sheet used by health insurance carriers, small self-insured employers, and government coverage providers to submit batches of Forms 1095-B to the IRS.
2. What is the difference between Form 1094-B and Form 1094-C?
Form 1094-B is used under ACA Section 6055 by insurance carriers and small self-insured employers (<50 FTEs). Form 1094-C is used under Section 6056 by Applicable Large Employers (50+ FTEs).
3. Do small self-insured employers file Form 1094-B?
Yes. Employers with fewer than 50 full-time equivalent employees that sponsor self-insured health plans file Form 1094-B and Form 1095-B to report minimum essential coverage.
4. What is the deadline to file Form 1094-B?
Form 1094-B is due February 28 for paper filers and March 31 for electronic filers submitting via the AIR system.
5. Can Form 1094-B be e-filed?
Yes. Form 1094-B can be e-filed electronically using IRS-approved software via the IRS ACA Information Returns (AIR) system, and e-filing is mandatory for entities filing 10 or more information returns.
6. Do covered employees receive a copy of Form 1094-B?
No. Form 1094-B is sent exclusively to the IRS. Covered employees receive individual Form 1095-B statements for their personal records.
13. Conclusion – Key Takeaways
IRS Form 1094-B is an essential annual transmittal return for health insurance carriers, small self-insured employers, and government agencies providing minimum essential health coverage under ACA Section 6055. By serving as a master cover sheet that reconciles transmitted Forms 1095-B, Form 1094-B ensures that health coverage records are accurately processed by IRS systems. Verify your organization’s FTE headcount to confirm 1094-B eligibility, tally attached 1095-B forms accurately, meet the March 31 AIR e-filing deadline, and protect your organization from costly information return penalties.
