Mastering Form 1094-B: The Essential Guide

Form 1094-B, Transmittal of Health Coverage Information Returns, is purely a transmittal form — also known as a cover sheet or summary form. Form 1094-B must be filed to the IRS along with Forms 1095-B. Together, Forms 1094-B and 1095-B are used to report health coverage information to the IRS.

Image of Form 1094-b
Image of IRS Form 1094-B, Transmittal of Health Coverage Information Returns

What is Form 1094-B?

Form 1094-B is a very simple form and only requires the filer’s name, contact information, address, and employer identification number (EIN), as well as the total number of Forms 1095-B included with the information return. It has the following boxes to report information:

  • Box 1 – Filer’s name
  • Box 2 – Employer identification number (EIN)
  • Box 3 – Name of the employer contact person
  • Box 4 – Contact telephone number
  • Box 5-8 – Employer address information
  • Box 9 – Total number of Forms 1095-B submitted with the transmittal

Why do I need Form 1094-B with Form 1095-B?

As a cover sheet, Form 1094-B contains a summary of the information being filed in Forms 1095-B. Together, these forms provide the IRS and Responsible Individuals with specific coverage information, such as dates of an individual’s or dependent’s coverage.

Form 1095-B, Health Coverage, is used to report information regarding individuals who are covered by minimum essential coverage (MEC) to the IRS. Check out our Essential Guide: Mastering Form 1095-B to get a more in-depth look at this form.

What’s the difference between Form 1094-B and 1094-C?

Both of these are transmittal forms for filings that provide health coverage information. They provide the IRS with some basic information about the filer, but that is where the similarities end.

Form 1094-B is purely a transmittal form that is included with a Form 1095-B filing. As stated above, it is a very simple form with minimal information required.

Form 1094-C is also a transmittal form, but it’s included with a Form 1095-C filing. Generally, employers with 50 or more full-time and full-time equivalent employees (Applicable Large Employers or ALEs) are subject to the employer shared responsibility provisions (ESRP). Employers subject to ESRP that sponsor self-insured health plans, including ICHRA, will generally use Part III of Form 1095-C instead of using Form 1095-B.

Form 1094-C requires the same basic data as 1094-B, such as the filer’s name, address, EIN, and so on. However, it also requires much more detailed information regarding the offer of coverage, monthly head-counts of employees, and information regarding other ALE Members of the Aggregated ALE Group (if applicable). Check out our Essential Guide: Mastering Form 1094-C to get a more in-depth understanding of this form type.

Who needs to file Forms 1094-B and 1095-B with the IRS?

Every entity that provides MEC to an individual during a calendar year must file an information return reporting the coverage. Forms 1094-B and 1095-B are typically completed by insurance companies and other coverage providers, such as small employers. When completing this filing type, filers must submit both Form 1094-B and Forms 1095-B.

Small employers that are not subject to ESRP and sponsor self-insured health plans should use Forms 1094-B and 1095-B to report information regarding covered individuals.

Who needs to file Forms 1094-B and 1095-B with the state?

Along with the federal filing and recipient furnishing requirements, some states have individual requirements as well.

California, the District of Columbia, Massachusetts, New Jersey, Rhode Island, and Vermont have Individual Mandates in place that require employers to report ACA data on the state level, as well as the federal. Review our ACA State Requirements Guide to find out more about these state requirements and deadlines.

When is the deadline to file Forms 1094-B and 1095-B with the IRS?

Traditionally, the filing deadlines for Forms 1094-B & 1095-B are as follows:

  • Submit a Paper Filing – February 28th
  • Furnish Recipient Copies – March 2nd
  • Submit an Electronic Filing – March 31st

If these deadlines fall on a weekend or legal holiday, then the due date is typically the following business day.   Check out our annually updated deadlines article for the most up-to-date information.

Can I submit a paper filing?

Employers may choose to paper file Form 1094-B and accompanying Forms 1095-Bs to the IRS if their total form count is less than the 250-form threshold. E-filing is encouraged by the IRS, but if you have less than 250 forms to file, then paper filing is an option.

When filing on paper, you must send the forms to the IRS in a flat mailing envelope without staples or paperclips. These forms can be printed on regular paper in landscape format, and special forms do not need to be ordered.

If you have many forms to send, then you can send them in conveniently-sized packages. Each package must be labeled with the filer’s name and should be numbered consecutively. The transmittal Form 1094-B should be placed in the first package along with Forms 1095-B. Additional Forms 1095-B can be included in the other packages, if applicable.

Please note that postal regulations require that packages with official tax forms must be sent via first-class mail.

Determining where to send your filing is dependent upon the filer’s address; specifically, the state. Find your state in the graphic below for the correct IRS mailing address for your filing.

1095-B IRS Addresses
IRS Addresses by State

Can I download Form 1094-B?

Yes, you can download a PDF version of this form from the IRS website. This copy can be completed virtually and printed out in landscape format with black ink to distribute to recipients and/or send to the IRS.

Can I submit an electronic filing?

Yes, of course! E-filing is encouraged by the IRS and offers many benefits. These benefits include immediate submission, quick turnaround time, status updates, and more.

E-filing can be a requirement for some filers. If you are filing more than 250 forms 1095-B, then you must submit your filing electronically.

If you choose to submit your filing electronically, be sure to find an authorized ACA software provider to make e-filing quick and easy!

What are the penalties for not filing Form 1094-B?

A provider of MEC that fails to comply with the IRS reporting and/or furnishing requirements may be subject to penalties for failure to file and/or furnish recipient statements. For the tax year 2021, the following penalties may apply:

  • Failure to file correct forms – $280 per form
  • Failure to furnish recipient forms – $280 per form
  • Failure to file electronically, when required to do so – $280 per form

Special rules apply that increase the per-return and per-statement and total penalties with no maximum limitations if there is intentional disregard of the requirement to file the returns and furnish recipient statements.

Form 1094-B Instructions

Check out the graphic below to see how quickly fines can accumulate based on a small sample size of only 10 forms the business should have filed.

Form 1095-B Penalties
IRS Potential Fine Amounts

How do I make a correction?

Form 1094-B is purely a transmittal document and does not require correction. You may have errors on your Forms 1095-B, though. That is why it’s important that you take the time to review the information you are reporting on your forms for accuracy before distributing and filing. This will minimize the risk of common errors which may result in your business incurring penalties and fines.

Even with careful reviewing, mistakes can happen! If your filing has errors, you can easily make corrections to your Forms 1095-B.

  • If you submitted your original filing electronically, then you should edit your filing accordingly with the original vendor.
  • If you submitted your original filing via mail, then you should complete a new form and include the updated information.
    •      Once this has been completed, simply check the ‘Corrected’ box at the top of the form. Always include a new transmittal Form 1094-B when mailing in corrections to the IRS.

Before you can consider your correction complete, an updated copy of the form must be provided to the recipient as well. This ensures that all parties have updated information.

Conclusion

Once you have submitted your Forms 1094-B and 1095-B to the IRS, either electronically or via mail, and have received your “Accepted” status, then you have met all of the IRS requirements for these forms.

If you’re looking for a broken-down Understanding ACA Summary Forms guide in a downloadable format, make sure to download our PDF guide.

BoomTax, The Boom Post, and its affiliates do not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors prior to engaging in any transaction.

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