--- title: Approaching Deadline for Employer Use of MLR Rebates description: Employers must use any ERISA plan asset portion of an MLR rebate for participants within three months of receipt. image: https://blog.nisbenefits.com/hubfs/blog-headers/mlr-rebates-25-b.jpg --- ![medical icons](https://blog.nisbenefits.com/hubfs/blog-headers/mlr-rebates-25-b.jpg) # Approaching Deadline for Employer Use of MLR Rebates - Home - [Employee Benefit News for School, City and County Employers](https://blog.nisbenefits.com) - Approaching Deadline for Employer Use of MLR Rebates [ Paige Moen ](https://blog.nisbenefits.com/author/paige-moen) 12/01/2025 [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news) [0 Comments ](https://blog.nisbenefits.com/approaching-deadline-mlr-rebates#postComment) 1 Minutes Employers with insured health plans may have received a medical loss ratio (MLR) rebate earlier this year. If an issuer did not meet the required MLR percentage for 2024, rebates issued either as a premium credit or lump-sum payment were provided by September 30, 2025. If any part of an MLR rebate is considered a plan asset under ERISA, it must be used solely for the benefit of plan participants and beneficiaries. Employers can meet this requirement by equitably distributing the rebate among participants or, if direct payment is not practical, by applying the rebate toward future premium payments or enhancing plan benefits. If the rebate qualifies as a plan asset under ERISA, it must generally be held in trust unless the employer uses the plan asset portion within three months of receiving the rebate. Employers should be aware of this deadline, as it may be approaching based on the timing of their MLR rebate.   ## **Key Points** - The Affordable Care Act requires insurers to allocate a set portion of premiums directly to medical care and quality improvements. - If an insurer does not meet these standards, they are required to issue rebates to consumers. - Employers receiving MLR rebates should determine if any portion qualifies as a plan asset under ERISA. - Plan assets are exclusively for the benefit of plan participants and their beneficiaries.   ## **Deadlines** **September 30, 2025 –** Deadline for issuers to distribute 2024 MLR rebates. **Three Months After Receipt -** Any ERISA plan asset rebate must be used within three months of receipt.   ## **Action Steps** Employers receiving MLR rebates must follow ERISA rules when using rebate funds. Any portion considered a plan asset must be used solely for the benefit of plan participants and beneficiaries. Employers are prohibited from keeping or using this portion for their own purposes. To comply with ERISA, the plan asset portion must be used within three months of receipt—for example, if a rebate is received on September 30, 2025, it must be used by December 30, 2025. Download the [bulletin](https://blog.nisbenefits.com/hubfs/blog-supporting-docs/bulletin-deadline-er-mlr-rebates.pdf) for more details. [![Medical Savings Accounts](https://no-cache.hubspot.com/cta/default/3325505/db91a97a-b568-44ce-8a0d-c75dd4717dbc.png)](https://cta-redirect.hubspot.com/cta/redirect/3325505/db91a97a-b568-44ce-8a0d-c75dd4717dbc)   --- #### Tag: [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions) [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news) #### Share: - [Follow us on Facebook ](http://www.facebook.com/share.php?u=https://blog.nisbenefits.com/approaching-deadline-mlr-rebates) - [Follow us on Twitter ](https://twitter.com/intent/tweet?url=https://blog.nisbenefits.com/approaching-deadline-mlr-rebates&text=Approaching%20Deadline%20for%20Employer%20Use%20of%20MLR%20Rebates) - [Follow us on Linkedin ](http://www.linkedin.com/shareArticle?mini=true&url=https://blog.nisbenefits.com/approaching-deadline-mlr-rebates) - [Follow us on Pinterest ](http://pinterest.com/pin/create/button/?url=https://blog.nisbenefits.com/approaching-deadline-mlr-rebates&text=Approaching%20Deadline%20for%20Employer%20Use%20of%20MLR%20Rebatesdescription=Employers%20with%20insured%20health%20plans%20may%20have%20received%20a%20medical%20loss%20ratio%20(MLR)%20rebate%20earlier%20this%20year.%20If%20an%20issuer%20did%20not%20meet%20the%20required%20MLR[...]&media=https://3325505.fs1.hubspotusercontent-na1.net/hubfs/3325505/blog-headers/mlr-rebates-25-b.jpg) --- [ #### Americans Rate Health Care as Average ##### Previous Post ](https://blog.nisbenefits.com/americans-rate-health-care-average) [#### Honoring Leadership: Aaron Casper Named to Minnesota’s All-State School Board ##### Next Post ](https://blog.nisbenefits.com/aaron-casper-minnesota-all-state-school-board) ### Leave a Reply This is a search field with an auto-suggest feature attached. - There are no suggestions because the search field is empty. ### Category - [Legislative News (1149)](https://blog.nisbenefits.com/topic/aca-other-legislative-news) - [Health Insurance Solutions (504)](https://blog.nisbenefits.com/topic/health-insurance-solutions) - [COVID-19 (209)](https://blog.nisbenefits.com/topic/covid-19) - [Ancillary Benefits (175)](https://blog.nisbenefits.com/topic/ancillary-benefits) - [Mental Health (122)](https://blog.nisbenefits.com/topic/mental-health) ### Popular Posts [ Steve Smith ](https://blog.nisbenefits.com/author/steve-smith) 02/16/2024 [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions) [ Understanding Embedded vs. Nonembedded Deductibles ](https://blog.nisbenefits.com/understanding-embedded-nonembedded-deductibles) [ Erin Woulfe ](https://blog.nisbenefits.com/author/erin-woulfe) 02/09/2026 [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news) [ IRS Releases 2027 Health Plan Cost-sharing Limits ](https://blog.nisbenefits.com/2027-health-plan-cost-sharing-limits) [ Valerie Ortiz ](https://blog.nisbenefits.com/author/valerie-ortiz) 02/17/2026 [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ The Administrator's Corner](https://blog.nisbenefits.com/topic/the-administrators-corner) [ 4 Employee Wellness Trends You Can’t Ignore in 2026 ](https://blog.nisbenefits.com/2026-employee-wellness-trends) [ Dina Lubben ](https://blog.nisbenefits.com/author/dina-lubben) 11/14/2025 [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news) [ Trump Administration Unveils Plan to Make GLP-1 Drugs Affordable ](https://blog.nisbenefits.com/trump-administration-plan-glp1-drugs-affordable) --- ## Related Posts [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news), [ The Administrator's Corner](https://blog.nisbenefits.com/topic/the-administrators-corner) [ Valerie Ortiz ](https://blog.nisbenefits.com/author/valerie-ortiz) 07 July, 2026 #### [New CMS Report: Healthcare Spending Trends Through 2034](https://blog.nisbenefits.com/healthcare-spending-trends-through-2034) New projections from the U.S. Centers for Medicare and Medicaid Services (CMS) Office of the… [Read More](https://blog.nisbenefits.com/healthcare-spending-trends-through-2034) [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news), [ The Administrator's Corner](https://blog.nisbenefits.com/topic/the-administrators-corner), [ Mental Health](https://blog.nisbenefits.com/topic/mental-health) [ Steve Smith ](https://blog.nisbenefits.com/author/steve-smith) 06 July, 2026 #### [New HHS Rule Expands Catastrophic Coverage Access](https://blog.nisbenefits.com/new-hhs-rule-expands-catastrophic-coverage-access) The U.S. Department of Health and Human Services’ (HHS) Notice of Benefit and Payment Parameters… [Read More](https://blog.nisbenefits.com/new-hhs-rule-expands-catastrophic-coverage-access) [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news) [ Mari Wagner ](https://blog.nisbenefits.com/author/mari-wagner) 25 June, 2026 #### [Federal Court Blocks Key ACA Exchange Restrictions](https://blog.nisbenefits.com/federal-court-blocks-key-aca-exchange-restrictions) A recent federal court ruling blocked stricter ACA Marketplace eligibility and enrollment… [Read More](https://blog.nisbenefits.com/federal-court-blocks-key-aca-exchange-restrictions)