More than one plan or policy: keep each rebate with the plan that earned it.
Employers with separate policies can receive separate rebate checks. The Department of Labor guidance does not let one plan’s rebate benefit another plan’s participants.
What the letters and the guidance say.
One Plan’s Rebate Stays With It
The Department of Labor states that a rebate from one plan cannot be used to benefit participants of another plan.
Rebates Are Figured Per Policy
Carrier letters state that each policy sits in a pool and that the rebate share is based on the policyholder’s premium. The letter identifies the policy number it relates to.
Separate Letters, Separate Decisions
Each check and letter should be reviewed on its own, with its own premium history, participants and plan documents.
Three steps for the employer.
Match Each Check to a Policy Number
Use the policy number on each letter to tie the check to the right plan, carrier and year.
Track Allocation Per Plan
Keep a separate record of the premium split, method and payments for each plan so nothing is blended.
Keep Records Separate
File each carrier letter with the documents for its own plan and keep a simple index of all rebates received.
Three questions to settle first.
Which Policy Does Each Check Belong To?
Ask your carrier to confirm the policy number and market segment for each rebate.
Are the Participant Groups Different?
Ask HR whether the plans cover different groups of employees and how that affects allocation.
Are the Records Kept Apart?
Ask finance and benefits to confirm each rebate is tracked against its own plan.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program: cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →
Cookies on This Site
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.
- Essential: needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics: tell us which pages get read, so we know what is worth writing more of.
- Advertising: set by third parties such as ad and social platforms to measure and target campaigns.