Employer MLR Rebates Are Approaching

Employers with insured group health plans may soon receive a medical loss ratio (MLR) rebate from their health insurance issuers. These rebates may be in the form of a premium credit or a lump sum payment.

Highlights and Action Steps:

SEPTEMBER 30, 2026: Issuers who did not meet their MLR percentage for 2025 must provide rebates to plan sponsors by this date.

As a general rule, employers who receive a rebate should use it within three months to avoid ERISA’s trust requirement.

DECEMBER 30, 2026 is the three-month deadline for rebates received on September 30, 2026. This deadline must be adjusted for rebates received before September 30th.

Employers who receive MLR rebates should be prepared to answer questions from employees about the rebate and how it is allocated.

Using MLR Rebates

Employers with Employee Retirement Income Security Act (ERISA) plans should not assume they can simply retain an MLR rebate.

In general, unless an employer pays the entire cost of health coverage without any employee contribution, at least a portion of the rebate will be a plan asset under ERISA.

Any rebate amount that qualifies as a plan asset must be used for the exclusive benefit of the plan’s participants and beneficiaries.

Below is a table of the carriers offering MLR rebates in 2026 and how employers will be notified of such rebates:

Carrier	Offering MLR Rebates?	How Employer Will Be Notified
Aetna	Yes	Checks will be mailed by 9/30. 2025 MLR Experience Year Rebate Pools
BCBSMN	No	N/A
BCBSNE	No	N/A
HealthPartners	No	N/A
Medica	No	N/A
UnitedHealthcare	Yes	Checks will be distributed starting in mid-September, and fully insured customers that are qualified to receive rebates will receive their checks by 9/30. Brokers with customers in aggregation sets scheduled to receive a rebate will receive this information via the October BrokerConnect. The information will also be posted on the broker and customer news pages on uhc.com in September. Brokers and customers can call the broker and employer service line at 866-802-8602 if they have questions related to the rebate payout. 2026 MLR Finaly Payout Report