Employers with insured group health plans may soon receive a medical loss ratio (MLR) rebate from their health insurance issuers. Issuers who did not meet the applicable MLR percentage for 2023 must provide rebates to plan sponsors by Sept. 30, 2024. These rebates may be in the form of a premium credit or a lump sum payment.
HIGHLIGHTS AND ACTION STEPS
Issuers who did not meet their MLR percentage for 2023 must provide rebates by Sept. 30, 2024. As a general rule, an employer who receives a rebate should use it within three months to avoid ERISA’s trust requirement. For rebates received on Sept. 30, 2024, this three-month deadline is Dec. 30, 2024. This deadline should be adjusted for rebates received before Sept. 30, 2024. Employers who receive MLR rebates should also be prepared to answer questions from employees about the rebate and how it is being allocated.
MLR RULES
The MLR rules require health insurance issuers to spend a minimum percentage of their premium dollars on medical care and health care quality improvement. This percentage is 85% for issuers in the large group market and 80% for issuers in the small and individual group markets. States may set higher MLR standards than the federal 80%/85% thresholds. Issuers must report to the federal government how they spent their premium dollars for each calendar year by July 31 of the following year. Issuers who do not meet the applicable MLR standard must provide rebates by Sept. 30, following the end of the MLR reporting year. Issuers who issue rebates must provide plan sponsors and participants with a notice explaining the rebate and how it was calculated.
Related Blogs
Employee Benefits
PUBLISHED
September 22nd, 2026
High-Cost Claims: Why a Small Number of Members Drive Most Healthcare Costs
Alina Junkermeier
Healthcare costs often feel unpredictable—but when you break down the data, a clear pattern emerges. Across nearly every employer population, a very small percentage ...
Read More
Employee Benefits
PUBLISHED
September 16th, 2026
Why Group Captive Insurance Is Helping Employers Control Rising Healthcare Costs
Byron Shultz
Rising healthcare costs are forcing employers to rethink how they fund and manage employee benefits. As specialty drug spending, high-cost claims, and medical inflation ...
Read More
News and Updates
PUBLISHED
September 14th, 2026
The MJ Companies Hires Viridiana Schoenfeld as Employee Benefits Consultant
The MJ Companies
Leading business and financial services firm expands employee benefits consulting capabilities with strategic hire in Phoenix office PHOENIX (Sept. 14, 2026) – The MJ ...
Read More
Compliance
PUBLISHED
September 10th, 2026
Implementing a Trump Account Contribution Program
The MJ Companies
Trump Accounts are a new tax-advantaged savings program for children under the age of 18, effective for tax years beginning in 2026. These accounts ...
Read More
Retirement
PUBLISHED
September 9th, 2026
Making it Easy Could Lead to Poor Outcomes
Doug Prince
Making things easier is usually a good thing: easier enrollment, easier reporting, easier access to benefits. But when it comes to retirement plans, sometimes making a ...
Read More
Compliance
PUBLISHED
August 28th, 2026
IRS PROPOSES RULES FOR DEPENDENT CARE FSA NONDISCRIMINATION TESTING
Bryan Gross
On Aug. 11, 2026, the IRS issued proposed rules addressing nondiscrimination testing requirements for dependent care flexible spending accounts (FSAs). This marks the first ...
Read More