Form 15345

The first time I helped a health insurance carrier work through their annual MEC reporting submission, I underestimated how much the transmittal document mattered. The carrier had prepared all of the individual 1095-B statements correctly, but the transmittal – Form 15345 – had an incorrect count of returns and a mismatched EIN for one of the subsidiary entities. The IRS rejected the entire batch. We had to reprocess the transmission two weeks before the deadline, which created unnecessary pressure for a filing that, done right, is entirely mechanical. That experience is why I treat the transmittal as seriously as the underlying statements.

Download Form 15345 PDF

Key Takeaways

• Form 15345 is the transmittal document accompanying the annual health coverage certification package submitted by providers of minimum essential coverage (MEC) under IRC § 6055.
• It is the companion to Form 15344 (the certification itself) and to Form 1094-B (the standard transmittal for Form 1095-B), functioning in the same role as Form 1096 does for paper information returns.
• Filers include health insurance issuers, self-insured employers, government agencies sponsoring health programs, and other MEC providers who are not subject to the IRC § 4980H employer mandate (non-ALE self-insured plans use 1094-B/1095-B; ALEs use 1094-C/1095-C).
• The transmittal must accurately reflect the total number of returns filed and the provider’s identifying information; a mismatch causes IRS to reject the entire batch submission.
• Quick rule: complete Form 15345 last, after all individual certifications are finalized, so the return count is confirmed before the transmittal is signed.
• Information reporting penalties under IRC §§ 6721 and 6722 apply to incorrect or late transmittals at $310 per return (2026 indexed amount), with maximum annual caps based on entity size.

What Form 15345 Is and When to Use It

Form 15345, Transmittal for Annual Certification of Health Coverage Provider, is the cover document that accompanies Form 15344 (Annual Certification of Health Coverage) when MEC providers submit their annual certification package to the IRS. It serves the same functional role as Form 1096 for paper 1099 filings or Form 1094-B for 1095-B filings: it summarizes the batch, identifies the filer, and certifies the count and completeness of the attached returns.

The statutory basis for MEC provider reporting is IRC § 6055, which requires every person who provides minimum essential coverage to report that coverage to the IRS and to covered individuals. The IRS uses this data to administer the individual shared responsibility provisions and to verify whether individuals who claimed the premium tax credit actually had MEC coverage for the periods in question. Form 15345 is the administrative instrument that delivers that data.

The distinction between Forms 1094-B/1095-B and Forms 15344/15345 can cause confusion. Generally: fully insured group health plans report on 1094-C/1095-C (if the employer is an ALE) or 1094-B/1095-B (if the employer is not an ALE). Self-insured non-ALE employers and other MEC providers – including government-sponsored programs like Medicaid, CHIP, and Medicare Part A – use the 1094-B/1095-B series. Forms 15344/15345 are used in specific IRS compliance programs and certification contexts tied to the health coverage provider framework. Always confirm the applicable form series with the specific IRS program or examination context in which the filing is being made.

From my side of the desk: if you are working with a third-party administrator, health insurance issuer, or government program administrator on their Section 6055 reporting, the transmittal is where small errors create large processing failures. Treat it as the control document it is designed to be.

How to Complete Form 15345

Form 15345 is structured to capture the filer’s identity, the volume and type of returns being transmitted, and a certification of accuracy. Complete it after all individual certification forms (Form 15344) are finalized, so the count is confirmed.

Section / Field	What It Captures	Practitioner Tip
Provider / Filer Name	Legal name of the MEC provider submitting the transmittal	Use the exact legal name on file with the IRS; for insurers or government entities, use the name associated with the reporting EIN
EIN	Employer Identification Number of the filer	If a third-party administrator or reporting agent files on behalf of the provider, use the provider’s EIN, not the TPA’s EIN, unless the TPA is the designated filer of record
Address	Mailing address for IRS correspondence	Must match the address associated with the EIN; if recently changed, update address with IRS on Form 8822-B before filing
Calendar Year	Tax year to which the certification relates	Confirm this matches the plan year on the individual certifications; do not mix plan years in a single transmittal batch
Total Number of Forms 15344 Filed	Count of individual certification forms included in this batch	This is the field most frequently wrong; count completed, e-filed or attached certifications before entering; the IRS validates this count against the batch submission
Type of Filing	Original, corrected, or void	Corrected transmittals require a separate batch; you cannot correct individual certifications by attaching them to the original transmittal after it is processed
Signature and Date	Authorized officer signature certifying accuracy	The person signing is personally certifying the accuracy of the certification data under penalties of perjury; do not delegate without appropriate authorization documentation

One process rule I always follow: the transmittal is completed by the same person who reviews the final batch count, not by the person who prepared the individual certifications. The review step catches count discrepancies before they become batch rejections.

Deadlines, Penalties, and Filing Requirements

Event	Deadline	Notes
Form 15344 (certification) furnished to covered individuals	January 31	Individual statement furnishing deadline; electronic delivery permitted with consent; 30-day extension available via Form 8809
Form 15345 transmittal filed with IRS – paper	February 28	Paper filing only if fewer than 10 returns; most providers must e-file
Form 15345 transmittal filed with IRS – electronic	March 31	E-file through IRS FIRE system; ACA transmitter control code (TCC) required; obtain TCC well in advance of filing season
Extension for filing with IRS	File Form 8809 before due date	Automatic 30-day extension available; one additional 30-day extension may be granted for hardship (not automatic)
IRC § 6721 penalty (failure to file correct information return)	Per return	$310 per return for 2026; reduced to $60 if corrected within 30 days, $120 if corrected by August 1; maximum annual caps apply based on entity size
IRC § 6722 penalty (failure to furnish correct payee statement)	Per statement	$310 per statement for 2026; same tiered reduction for timely correction
Intentional disregard penalty	No cap	$630 per return or statement (2026) with no annual maximum if the IRS determines failure was intentional; document good-faith compliance efforts

The MEC Provider Reporting Framework: IRC § 6055

Form 15345 sits within the broader Section 6055 reporting regime, which was enacted as part of the Affordable Care Act to give the IRS visibility into who has minimum essential coverage and when. Understanding the framework helps practitioners advise clients on the full scope of obligations – not just the transmittal form, but the underlying data management that makes accurate reporting possible.

Who Is a “Provider” Under Section 6055?

Section 6055 defines providers of minimum essential coverage to include:

• Health insurance issuers for fully insured group health plans and individual market coverage
• Self-insured employers for their self-funded group health plans (non-ALE employers use 1094-B/1095-B; ALE self-insured employers use 1094-C/1095-C and also satisfy Section 6055 through that filing)
• Government agencies sponsoring government-sponsored MEC programs: Medicare Part A, Medicaid, CHIP, TRICARE, veterans programs, and state health benefit programs
• Exchanges for qualified health plans (QHPs) sold through the Marketplace
• Other MEC providers as defined in Treasury Regulation § 1.6055-1(c)

What the IRS Does With This Data

The IRS uses Section 6055 reporting data for two primary purposes: (1) administering the premium tax credit by verifying that individuals who claimed the credit did not also have employer-sponsored or other MEC available to them at less than the applicable percentage of household income, and (2) enforcing the individual shared responsibility provision (which, while the penalty amount was reduced to $0 at the federal level after 2018, remains relevant in states with their own individual mandates).

This data also has compliance audit implications. When the IRS conducts an employer mandate examination and reviews 1095-C filings, it cross-references the insurer’s Section 6055 data to verify coverage periods. Gaps between what the employer reports and what the insurer reports can generate follow-up inquiries for both parties.

The Relationship Between Form 15345 and Form 1094-B

For most practitioners, the standard transmittal for Section 6055 reporting is Form 1094-B (Transmittal of Health Coverage Information Returns), which accompanies Forms 1095-B. Form 15345 serves a parallel function in specific IRS compliance and certification program contexts. When IRS instructions or an applicable IRS program direct the use of Form 15345 specifically, it supersedes the standard 1094-B. Always follow the program-specific instructions rather than defaulting to the standard form series without confirming applicability.

Corrected Filings and Substitute Statements

Errors in MEC reporting are common and the IRS has established procedures for correcting them. Understanding the correction process before errors occur is the most practical thing I can share from years of managing these filings.

When a Corrected Transmittal Is Required

A corrected Form 15345 transmittal is required whenever any of the following occur after the original filing:

• The total count of individual certifications changes (additions or deletions)
• The provider EIN or legal name was incorrect on the original
• The calendar year field was wrong on the original
• A corrected batch of individual certifications is being submitted

The corrected transmittal must indicate “Corrected” on its face. Do not submit a corrected transmittal with a mix of original and corrected certifications in the same batch; submit corrected certifications as a separate batch with their own corrected transmittal.

Correcting Individual Certifications (Form 15344)

When an individual certification has an error in coverage dates, covered individuals, or other data fields, issue a corrected Form 15344 to the covered individual with “Corrected” checked. File a corrected Form 15345 transmittal covering only the corrected returns. The IRS e-file system processes corrections through a specific correction indicator in the transmission file; work with your e-file software or TPA to ensure the correction indicator is set properly.

Substitute Statements to Covered Individuals

The IRS permits providers to use substitute statements in lieu of the official Form 15344 format for furnishing to covered individuals, as long as the substitute meets the requirements in the applicable IRS Publication (generally Publication 5165 for electronic filing specifications). Substitute statements must include all required data elements and must contain the OMB number and form number prominently displayed. Do not reduce or eliminate required fields in a substitute format – the penalty for a deficient substitute statement is the same as for a missing statement.

Common Mistakes That Slow Things Down

• Completing the transmittal before finalizing the individual certifications – fix: always complete Form 15345 last, after the final certification count is confirmed. Entering an estimated count and then submitting a different number causes batch rejection.
• Using the TPA’s EIN instead of the provider’s EIN on the transmittal – fix: the EIN on Form 15345 must belong to the MEC provider, not the reporting agent or administrator, unless the TPA is the designated filer of record under a valid reporting agent authorization. Confirm the filing arrangement before the first submission.
• Missing the March 31 electronic filing deadline by starting the e-file process too late – fix: obtain the IRS FIRE system TCC well before January. The TCC application process can take several weeks, and FIRE has maintenance windows during filing season.
• Submitting corrected certifications with the original transmittal instead of a separate corrected batch – fix: maintain separate batches for original and corrected submissions. Mixing them causes processing errors that are time-consuming to untangle.
• Failing to furnish corrected statements to covered individuals when corrections are filed with the IRS – fix: the obligation to furnish runs separately from the obligation to file with the IRS. A corrected IRS filing without a corrected individual statement is still a Section 6722 violation.
• Not documenting the e-file transmission confirmation – fix: retain the IRS FIRE system acknowledgment file and the batch submission confirmation for at least 6 years. If the IRS later claims non-receipt, the transmission confirmation is your proof of filing.
• Ignoring state MEC reporting requirements – fix: several states (California, Massachusetts, New Jersey, Rhode Island, Vermont, and others) have their own individual mandate reporting requirements with separate filing deadlines and transmittal forms. A federal MEC filing does not satisfy state obligations.

Practical Checklists You Can Reuse

Copy these into your internal wiki or SOP.

Pre-Submission Transmittal Review Checklist

• ☐ Confirm the provider EIN matches the IRS records for the reporting entity
• ☐ Confirm the legal name on Form 15345 matches the EIN registration
• ☐ Verify the calendar year field matches all individual certifications in the batch
• ☐ Count all completed Form 15344 certifications; confirm total matches the Form 15345 count field
• ☐ Confirm filing type: original, corrected, or void
• ☐ For corrected batches: confirm these are a separate batch from any original submissions
• ☐ Obtain authorized signature on Form 15345 from an officer of the provider entity
• ☐ Confirm FIRE system TCC is active and valid for the current filing year
• ☐ Schedule e-file submission at least 5 business days before the March 31 deadline to allow for FIRE system issues
• ☐ Retain the FIRE system transmission acknowledgment and confirmation file

Annual ACA Reporting Timeline Checklist

• ☐ Q3 of prior year: confirm TCC is active; renew or obtain if needed
• ☐ November: pull coverage and enrollment data from plan administrator or HRIS
• ☐ December: complete data cleanup; reconcile coverage periods against payroll records
• ☐ January 10: begin preparation of individual certifications (Form 15344)
• ☐ January 31: furnish completed certifications to covered individuals
• ☐ February 15: finalize individual certification data; begin e-file preparation
• ☐ February 28: paper transmittal deadline (if applicable)
• ☐ March 15: complete Form 15345 transmittal; submit to FIRE system test environment if first-time filer
• ☐ March 31: electronic transmittal deadline; submit and retain confirmation
• ☐ April 15: process any rejected returns; resubmit corrected batches if needed
• ☐ Review state MEC reporting deadlines and file separately as required

For Accounting Firms – Keep Delivery Smooth While You Scale

MEC provider reporting – collecting data from plan administrators, preparing individual certifications, managing the FIRE system submission, and handling corrected filings – is a high-volume, deadline-sensitive compliance task. For firms that manage this process for multiple clients – insurance carriers, government program administrators, or self-insured employer plans – the January-through-March window becomes a significant capacity bottleneck precisely when tax season is also in full swing.

Accountably works with CPA and EA firms to add structured delivery capacity for compliance-heavy engagements, including information reporting workpaper preparation, data staging, and submission support. We keep this mention brief on purpose, your process comes first.

FAQs About Form 15345

This article is educational, not tax advice. Rules change, and states differ. Confirm thresholds, deadlines, and elections against the current IRS instructions for your year and facts.