Employers that offer an ICHRA must file ACA information returns (Form 1094 and 1095 series) with the IRS and provide the required employee statements based on whether they are an Applicable Large Employer (ALE) or a small employer.
What forms are required for ICHRA reporting?
ICHRA reporting depends on employer size:
Small employers (<50 full-time equivalent employees)
You must:
File Form 1094-B with the IRS
File Form 1095-B for each employee who had ICHRA coverage for at least one month
Provide Form 1095-B to applicable employees
These forms report Minimum Essential Coverage (MEC) provided through the ICHRA.
Applicable Large Employers (50+ full-time equivalent employees)
You must:
File Form 1094-C with the IRS
File Form 1095-C for full-time employees
Provide Form 1095-C to employees as required
ALE reporting also includes employer shared responsibility (ACA mandate) information in addition to coverage reporting.
What does ICHRA reporting confirm to the IRS?
ICHRA reporting is used to confirm:
The employer offered Minimum Essential Coverage (MEC) through an ICHRA
Which employees were eligible for coverage
Whether coverage was offered and available by month
Enrollment information for covered individuals
This reporting helps the IRS validate ACA compliance and employee tax credit eligibility.
Does ICHRA count as health insurance for reporting purposes?
Yes. An ICHRA is treated as a self-insured health plan for ACA reporting purposes.
That means:
Employers must report coverage even if employees purchase their own individual health insurance
Reporting applies regardless of whether employees reimburse premiums or medical expenses
Coverage is reported monthly per employee
Do employers have to file forms even if employees don’t participate?
Yes. If an employee is offered ICHRA coverage and is enrolled for at least one month, reporting is required.
For small employers:
Only employees with at least one month of coverage must receive Form 1095-B
For ALEs:
Full-time employees must be reported even if they decline coverage
What does Take Command provide for ACA reporting?
Take Command provides:
A downloadable employee-level reporting file (CSV or spreadsheet)
Coverage months and eligibility data
Information needed to complete IRS Forms 1094 and 1095
Plan-year reporting data from the admin portal
This data is used to complete IRS forms but is not itself the official filing.
Will Take Command file my 1094/1095 forms for me?
No. Take Command does not complete or submit IRS forms.
Employers are responsible for:
Reviewing reporting data for accuracy
Completing Forms 1094 and 1095 (B or C depending on employer size)
Filing forms with the IRS
Distributing employee statements
Employers typically complete filing with a CPA, payroll provider, or ACA reporting vendor.
What are the filing deadlines for ICHRA reporting?
Typical IRS deadlines are:
Small employers (1094-B / 1095-B)
Furnish employee statements: early March (varies by year)
File with IRS: late February (paper) or late March (electronic)
ALEs (1094-C / 1095-C)
Furnish employee statements: early March
File with IRS: late February or late March (depending on filing method)
Exact deadlines may vary each tax year based on IRS updates.
Does ICHRA affect employee taxes?
Yes, but indirectly.
ICHRA reimbursements are not included in employee W-2 wages
Coverage may affect eligibility for ACA Marketplace premium tax credits
Employees may need Form 1095-B or 1095-C when filing personal taxes
What if employee data is incorrect in reporting files?
If reporting data is incorrect:
Review employee eligibility and coverage records in your portal
Update missing or inaccurate employee information
Regenerate reporting files if needed
Confirm accuracy before filing IRS forms
Employers are responsible for ensuring final submitted data is correct.
What happens if I don’t file ICHRA reporting forms?
Failure to file or furnish ACA forms may result in IRS penalties.
Common risks include:
Penalties for late filing
Penalties for missing or incorrect employee statements
Compliance issues related to ACA reporting obligations
Employers are expected to file even if no employees enroll.
What if I’m not sure which forms I need to file?
Use this rule:
Under 50 employees → Forms 1094-B and 1095-B
50+ employees (ALE) → Forms 1094-C and 1095-C
If you are unsure whether you are an ALE, consult your tax advisor or payroll provider for confirmation.