The Affordable Care Act (ACA) reporting season for the 2025 tax year is approaching quickly. The IRS has issued final versions of Forms 1094-B (Transmittal of Health Coverage Information Returns) and 1095-B (Health Coverage), along with the accompanying instructions.
Who Is Receiving This Notice?
You are receiving this communication because your health plan covers fewer than 50 participants. Please note, however, that reporting requirements are based on the number of full-time equivalent employees, not just covered participants.
If your organization has 50 or more full-time equivalent employees, please refer to the large employer reporting forms, 1094-C and 1095-C, for your reporting requirements.
Overview of Forms 1094-B and 1095-B
Forms 1094-B and 1095-B are used by providers of minimum essential coverage, including health insurers and employers sponsoring self-insured health plans for smaller employers (those with fewer than 50 full-time equivalent employees), to report health coverage information as required under Internal Revenue Code §6055.
The forms remain largely unchanged from prior years. However, the updated instructions clarify that small businesses with average gross receipts of $5 million or less may qualify for reduced penalties. They also note that the penalty per return has increased to $680 for intentional disregard of filing or furnishing requirements, with no annual maximum limitation.
For additional details, please review the official IRS instructions and forms using the links below:
Who Must Report?
These forms must be filed by health insurers and employers sponsoring self-insured health plans (other than large self-insuring employers) to report coverage information in accordance with Code §6055 of the Internal Revenue Code and as mandated by the Affordable Care Act.
Section 6055 Reporting Compliance
Under §6055, all self-funded employers are required to report the following information annually to the IRS and covered employees:
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Name and address of each covered employee
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Tax ID (Social Security Number) of each covered individual (including dependents)
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Months of coverage for each covered individual
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Employer’s name, address, and tax ID number
This same information must also be provided to employees along with the employer’s contact details.
Note: Employers may not have SSNs for dependents. Regulations require “reasonable collection efforts,” typically documented by making at least two requests for this information.
What Are the Deadlines?
Deadline for Furnishing Statements to Individuals
Employers must furnish Forms 1095-B to individuals by March 2, 2026, upon employee request.
Deadlines for Filing Returns with the IRS
Employers must file Forms 1094-B with the IRS by the following dates:
February 28, 2026, for paper filing
March 31, 2026, for electronically filing
Filers may request an extension of these deadlines by submitting Form 8809 to the IRS.
How Will MedCost Assist?
MedCost will generate ACA reporting data and make reports available to our clients as early as the week of December 15, 2025. These reports will be posted to the secure Employers Portal on our website.
Additional details, including instructions for accessing and using the reports, will be provided in a future communication.
For small employers (fewer than 50 FULL-TIME EQUIVALENT EMPLOYEES), these reports will include nearly all information necessary to complete the required forms.
Optional Form Preparation Service
MedCost is offering an optional form preparation service for a fee of $500. This service includes preparation of the B Forms (1094-B and 1095-B) for both employees and the IRS, and secure electronic delivery of draft forms to your designated benefits contact by February 2025.
To participate, please submit the Request Form to [email protected] by December 31, 2025.
This service does not include filing or delivery of forms to the IRS or individuals. Additional details are available on the Request Form.
Please contact your MedCost Account Manager or the Compliance Department at [email protected] for more information.