Small employers offering an ICHRA must file Form 1094-B and Form 1095-B with the IRS and provide Form 1095-B to each employee who was enrolled in the ICHRA for at least one month during the calendar year.
What tax forms are required for a small business offering ICHRA?
If your business is not an Applicable Large Employer (ALE), you must:
File Form 1094-B with the IRS (transmittal form)
File Form 1095-B for each employee covered under the ICHRA
Provide a copy of Form 1095-B to each employee who had ICHRA coverage for at least one month in the calendar year
These forms report that your organization provided Minimum Essential Coverage (MEC) through an ICHRA.
Who counts as a small employer for ICHRA reporting?
You are generally considered a small employer if you have:
Fewer than 50 full-time equivalent employees (FTEs)
Small employers are not subject to ALE reporting rules and do not file Forms 1094-C or 1095-C.
What does Take Command provide for reporting?
If you had an active ICHRA during the plan year, Take Command will provide:
A downloadable reporting spreadsheet
Employee eligibility and coverage data
Information required to complete Forms 1094-B and 1095-B
This data is available in your admin portal’s documents or reports section.
Item | ICHRA |
W-2 reporting | No W-2 reporting for the ICHRA benefit itself |
ACA filing | Small employers generally file Forms 1094-B and 1095-B for employees covered under the ICHRA |
PCORI fee | Usually Form 720 is required to pay the PCORI fee |
Form 5500 | May apply depending on plan structure and ERISA rules |
On the spreadsheet, we list your eligible employees and the required information that should be reported on the Forms 1095-B, according to our records. It’s up to the ICHRA plan administrator (that’s you!) to review the data to make sure that the eligible employee list and required information are complete and accurate. (Hint: if not, it means our records don't match yours, but that's ok! Let us know and we can help get it up to date!)
📌 Note
If you are no longer a Take Command Health client, you can still access your Reimbursement Statements in the member portal. Even if your HRA is no longer active, these records remain available for your reference and reporting needs.
When & how do I file these forms?
You will need to file your 2026 Form 1094-B and Form 1095-Bs no later than:
February 28, 2027, if filing on paper, or
March 31, 2027, if filing electronically.
You'll need to furnish the Forms 1095-B to your employees no later than March 3, 2027. You can find specific filing instructions and additional requirements in the Instructions for Forms 1094-B and 1095-B.
Please note: If you're required to file 10 or more information returns, you must file electronically. The 10-or-more requirements apply in the aggregate to certain information returns. Accordingly, a filer may be required to file fewer than 10 Forms 1094-B and 1095-B but still have an electronic filing obligation based on other kinds of information returns filed. The electronic filing requirement does not apply if you request and receive a hardship waiver. The IRS encourages you to file electronically even if you’re filing fewer than 10 returns.
What information is reported on Forms 1094-B and 1095-B?
These forms include:
Employer identifying information
Employee identifying information
Months of ICHRA coverage
Confirmation that Minimum Essential Coverage (MEC) was offered through the ICHRA
Covered dependents (if applicable)
This reporting is used by the IRS to confirm health coverage compliance.
Will Take Command file my tax forms for me?
No.
Take Command does not file IRS Forms 1094-B or 1095-B on your behalf.
Instead, Take Command provides:
A reporting spreadsheet with employee-level coverage data
Required details to complete IRS forms
Exportable reports from your admin portal
You are responsible for final review, completion, and filing (often with a CPA or payroll provider).
What should I do after receiving the reporting file?
Follow these steps:
Download the ICHRA reporting spreadsheet from your admin portal
Review employee data for accuracy (coverage months, eligibility, demographics)
Complete IRS Forms 1094-B and 1095-B using the spreadsheet data
Provide Form 1095-B copies to applicable employees
File completed forms with the IRS by the applicable deadline
What if employee data is incorrect or missing?
If you notice errors in the reporting file:
Update employee coverage or eligibility information in your system
Regenerate or refresh the reporting file if needed
Ensure discrepancies are resolved before filing IRS forms
What if I have more than 50 employees?
If you are an Applicable Large Employer (ALE):
You must file Forms 1094-C and 1095-C instead of 1094-B and 1095-B
You must also report offers of coverage for full-time employees under ACA employer mandate rules
ALE reporting is separate from small employer ICHRA reporting requirements.