09/02/2026
Fully insured employers may soon see Medical Loss Ratio (MLR) rebates from their insurance carriers.
Under MLR requirements, carriers must spend a certain percentage of premium dollars on medical care and activities that improve health care quality. When those thresholds aren't met, affected plans may receive a rebate in the form of a premium credit or check. Carriers are required to distribute applicable 2026 rebates by September 30.
Receiving a rebate also brings important responsibilities. Employers generally must determine what portion is attributable to employee contributions, how those funds should be distributed, and what tax or communication considerations may apply. For ERISA-covered plans, participant portions of the rebate are considered plan assets and must be handled accordingly.
Employers should be prepared to review any rebate carefully and coordinate with their benefits and ERISA advisors to ensure funds are handled appropriately.