What are the tax reporting requirements for a small business offering ICHRA?

ICHRA Tax Reporting as a smaller employer that is not an ALE. How do I file Forms 1094-B and 1095-B?

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Updated over a week ago

What forms do I need to report if I offered an ICHRA last year?

As an entity employing less than 50 full-time equivalent employees, current regulations require that you:

  1. File a Form 1094-B and accompanying Forms 1095-B with the IRS, and

  2. Provide a Form 1095-B to any employee who participated in the ICHRA program for at least one month during the calendar year.

The offer of coverage through ICHRA is not taxable, but it may impact an employee’s eligibility for tax credits (if any) from the Marketplace.

What will Take Command Health provide for me to complete my tax forms?

If you had an active ICHRA with us in a given calendar year, we will provide you with a spreadsheet that summarizes the information required to be reported on the Form 1094-B and accompanying Forms 1095-B. We'll make this report available in the documents section of your admin portal and send you an e-mail when it's ready.* 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 that if you are no longer a Take Command Health client, you can still access this report in your member portal, even though the HRA is no longer active.

When & how do I file these forms?

You will need to file your 2023 Form 1094-B and Form 1095-Bs no later than:

  • February 28, 2024 if filing on paper, or

  • April 1, 2024 if filing electronically.

You'll need to furnish the Forms 1095-B to your employees no later than March 1, 2024. You can find specific filing instructions and additional requirements in the Instructions for Forms 1094-B and 1095-B.


Note that the electronic-filing threshold for information returns required to be filed on or after January 1, 2024, has been decreased to 10 or more returns. Per the IRS, "The 10-or-more requirement applies in the aggregate to certain information returns that are original or corrected returns. Accordingly, a filer may be required to file fewer than 10 Forms 1094-C and 1095-C, 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 though you are filing fewer than 10 returns."

What if I have more than 50 employees?

Are you an applicable large employer (ALE) per the IRS definition? If so, please see our help article for employers with more than 50 full-time equivalent employees offering an ICHRA for more information on the tax reporting you are required to file.

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