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Medical Loss Ratio Rules Impact Employers with Fully Insured Health Plans
Quarles & Brady LLP Link to more items from this source
[Guidance Overview]
Dec. 11, 2011

The rebate raises other concerns for employers. For example, if an employer receives the rebate, the rebate may be a 'plan asset' that should be held in trust. DOL Technical Release 2011-04 provides relief from the trust requirement, but only if the rebate is used within three months of the employer receiving the rebate. Employers will likely want to closely monitor this three-month 'window' to ensure the funds are used in that time.

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