News + Insights

Some employers are about to get money back. Issuers who missed 2025 MLR spending requirements must send rebates by Sept. 30, 2026. Here’s what you need to know.

Step 1

Rebate Confirmation

Review your issuer’s notice to confirm the rebate amount and which plan or policy it covers. Employers may find that not all of their health plans received a share.

Step 2

Asset Classification

Check your plan documents for guidance on handling a rebate. If they don’t say, the answer often depends on who paid the premiums. Money tied to employee contributions typically counts as a plan asset, while employer-paid amounts usually do not.

Step 3

Usage Decision

Any plan asset portion must benefit participants, whether through cash payments, a premium credit or enhanced benefits. A reasonable, fair and consistent method works best.

Step 4

Distribution Deadline

Plan assets are meant to be used within three months of receipt. Staying within that window keeps things simple and avoids ERISA’s trust requirements, which most employer plans aren’t set up to handle.

Step 5

Participant Notices

Participants appreciate a clear explanation of the rebate and how it’s being used. Employee questions are common, so having answers ready helps keep the conversation simple.