August 26, 2025
🏥MLR Rebate Deadline Approaching for Employers
Employers with fully insured group health plans may receive a Medical Loss Ratio (MLR) rebate from their health insurance company by Sept. 30, 2025. Rebates may come as a lump sum or a premium credit.
Key Dates
- July 31, 2025 – Health insurance companies report 2024 MLR data
- Sept. 30, 2025 – Rebates must be distributed
- Dec. 30, 2025 – Deadline to use rebate funds (if received Sept. 30)
ERISA Reminder
If employees contributed to premiums, part of the rebate is likely a plan asset under ERISA and must:
- Be used for the participants’ benefit
- Be used within 3 months to avoid trust rules
- Be fairly allocated (e.g., premium reductions, benefit enhancements)
What Employers Should Do
- Review how to use the rebate
- Prepare to communicate with employees
- Follow ERISA rules for plan assets
If you have any questions about what to do if you receive a rebate, give us a call at (520) 721-4848.
