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Allocation of Medical Loss Ratio Rebates and Premium Refunds
Verrill Dana LLP
[Guidance Overview] Sept. 16, 2020 "Generally, rebates attributable to premium payments made by participants or out of trust assets will be considered plan assets, and rebates attributable to employer-paid premiums will not be considered plan assets.... [DOL] Technical Release 2011-04 recognizes three approaches to dealing with the allocation of the 'plan asset' portion of the rebate. The fiduciary can: [1] pay a direct cash refund to participants; [2] provide participants with a premium discount or premium holiday; or [3] use the assets to enhance plan benefits (e.g., add a disease management or wellness program)." MORE >> |
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