September 2025 Sun Mon Tue Wed Thu Fri Sat 30 A B A Provide SAR to Plan Participants B Watch for MLR Rebates (Fully- (Calendar-year Plans Only) if Form Insured Health Plans Only) 5500 Deadline Was Not Extended Employers with insured health plans might receive rebates Provide a summary annual report (SAR) to plan if their issuers did not meet their medical loss ratio (MLR) participants by Sept. 30, 2025, for calendar-year plans if percentage for 2024. Rebates must be provided by Sept. the employee benefit plan’s Form 5500 deadline is not 30 following the end of the MLR reporting year. Employers extended. The SAR must be provided within nine months who receive rebates should consider their legal options of the close of the plan year unless the plan’s Form 5500 for using the rebate. Any rebate amount that qualifies as a deadline is extended. Plans exempt from the annual 5500 plan asset under ERISA must be used for the exclusive filing requirement are not required to provide an SAR. benefit of the plan’s participants and beneficiaries. Also, Unfunded welfare plans are also generally exempt from as a general rule, plan sponsors should use the plan asset the SAR requirement. portion of the rebate within three months of receiving it to avoid ERISA’s trust requirements.
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