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, 2025: Issuers who did not meet their MLR percentage for 2024 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, 2025 is the three-month deadline for rebates received on September 30, 2025. 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 2025 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. 2024 MLR Experience Year Rebate Pools
Allstate	Yes	Groups are notified via email.
BCBSMN	No	N/A
BCBSNE	No	N/A
HealthPartners	No	N/A
Medica	No	N/A
UHC	Yes	Checks will be mailed to employers between 9/15–9/30. Letters are sent to members whose groups will receive a check, generally 3-4 days following the employer letter and check. Brokers may go to the broker portals on or after 9/17 to see check amounts. OCI will also send notification to brokers with affected groups.