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August 1, 2024

Return to Sender: What to do with insurance premium refunds and discounts

Insurance carriers will soon issue 2023 Medical Loss Ratio rebates to fully insured policyholders, as mandated by the Affordable Care Act. While money back is always useful for employer plan-sponsors, there are rules governing what employers are able to do with these amounts. This Alert distinguishes between different types of premium refunds and discounts applicable to fully insured health and welfare plans and addresses what employers can do with these amounts. We will also briefly discuss how the rules differ for refunds and discounts related to self-insured group health plans.

This Alert is relevant for all employers sponsoring group health plans, but it is most relevant for employers with fully insured medical plans.