MLR rebates by state and carrier, 2024

Health insurers owed $1,645,613,870 in federal medical loss ratio rebates for the 2024 MLR reporting year, according to the CMS public use file of insurer filings. The individual market accounted for $1,185,466,952 (72%), the small group market $274,036,755 and the large group market $186,110,163. 188 of 1,710 state-level issuer filings owed a rebate, in 43 of the 56 states and territories in the file. In small group, 59 of 496 filings owed rebates and Massachusetts had the largest total ($54,400,148); in large group, 82 of 679 filings owed rebates, led by Pennsylvania ($27,065,697). UNITEDHEALTH GRP, the parent group as filed, owed the most in both group markets: $94,242,955 in small group and $97,998,525 in large group.

MLR rebates by state and market, 2024

Rebates are calculated separately for each insurer in each state and market, so the state is the natural unit. Alabama had the largest total across all markets ($181,950,179). 13 states and territories had no rebates in any market: Alaska, American Samoa, Guam, Minnesota, Northern Mariana Islands, Montana, North Dakota, Oregon, Rhode Island, South Dakota, U.S. Virgin Islands, Vermont, West Virginia. Select a column heading to re-sort the table.

The state CSV adds, for each state and market, the number of issuer filings that owed a rebate, the number that reported premium, and the policyholders owed a rebate in the group markets.

Small group: which carriers owed rebates

39 insurance companies, in 15 parent groups, owed small-group rebates across 31 states and territories. Issuers reported 177,184 small-group policyholders owed a rebate; 4 filings that owed a rebate reported no policyholder count, so treat that number as a floor.

Largest small-group rebates by issuer and state

1. Blue Cross and Blue Shield of Massachusetts HMO Blue, Inc. (MA): $36,824,414
2. Anthem Insurance Companies, Inc. (IN): $21,483,952
3. Healthy Alliance Life Insurance Company (MO): $19,358,275
4. CareFirst BlueChoice, Inc. (MD): $16,702,930
5. Independence Assurance Company (PA): $15,541,048
6. UnitedHealthcare Benefits Plan of California (CA): $13,362,586
7. Community Insurance Company (OH): $13,110,003
8. UnitedHealthcare Insurance Company (FL): $12,387,565
9. Mass General Brigham Health Plan, Inc (MA): $10,756,455
10. UnitedHealthcare Insurance Company (MO): $10,254,380

Large group: which carriers owed rebates

49 insurance companies, in 15 parent groups, owed large-group rebates across 35 states and territories. The large-group standard is higher, 85% rather than 80%. Issuers reported 24,279 large-group policyholders owed a rebate; 18 filings that owed a rebate reported no policyholder count.

Largest large-group rebates by issuer and state

1. Oxford Health Insurance, Inc. (NJ): $18,428,984
2. Health Plan of Nevada, Inc. (NV): $16,830,071
3. Independence Assurance Company (PA): $14,714,491
4. Neighborhood Health Partnership, Inc. (FL): $12,919,195
5. Nippon Life Insurance Company of America (CA): $10,360,345
6. Aetna Health Inc. (a Florida corporation) (FL): $8,223,174
7. UnitedHealthcare Insurance Company (WI): $7,180,241
8. Oxford Health Insurance, Inc. (NY): $6,457,578
9. CareFirst BlueChoice, Inc. (VA): $6,418,582
10. UnitedHealthcare Insurance Company (NV): $6,263,007

Parent groups are the NAIC group affiliation each issuer entered on its filing, shown as filed. A company that filed without an affiliation is listed under its own name, even where it belongs to a larger group. The issuer CSV lists every filing that owed a rebate, with its company code.

What MLR rebates are

Section 2718 of the Public Health Service Act (42 U.S.C. 300gg-18), added by the Affordable Care Act, requires health insurers to spend a minimum share of premium on medical care and quality improvement, and to rebate the shortfall when they do not. HHS implements it in 45 CFR Part 158, and CMS administers the program.

• The standards. 45 CFR 158.210 sets the minimum medical loss ratio at 80% in the individual and small group markets and 85% in the large group market, measured for each insurer in each state.
• Three years of experience. Under 45 CFR 158.220, the ratio for a reporting year aggregates that year and the two before it, so a rebate for 2024 reflects 2022 through 2024.
• The amount. The rebate is the gap between the standard and the insurer's ratio, applied to premium after taxes and fees (45 CFR 158.240). Small blocks of business get a credibility adjustment, and very small ones are presumed to meet the standard.
• The deadline. Rebates are due by September 30 of the year after the reporting year (158.240(e)). Group rebates under $20 per policy need not be paid individually and are pooled into other enrollees' rebates (158.243).
• The recipient. In the group markets the insurer pays the policyholder, usually the employer (158.242). For an ERISA plan the portion tied to employee contributions can be a plan asset; the Department of Labor's Technical Release 2011-04 expects it to be used for participants, generally within three months of receipt.

What a broker should do with this

• Check the client's carrier and state. Find the carrier in the issuer CSV. A rebate is owed by the legal entity that issued the policy in that state and market, so match the company name on the client's policy, not just the brand.
• Work out who gets what. When a group client receives a rebate, split it between the employer and employees by their share of premium. The MLR rebate calculator does the split and the per-employee amount.
• Use it carefully at renewal. A rebate means the carrier's pooled three-year ratio in that state and market fell short of the standard. It says nothing about one group's own claims, but it is fair context when a carrier proposes a large increase; see how we approach rate negotiation and renewal analysis.
• Know which market the group is in. Small group usually means up to 50 employees, or up to 100 in some states, and that decides whether the 80% or 85% standard applies. Our small group vs large group guide covers the line, and the glossary defines MLR rebate and related terms.
• Remember self-funded plans are outside it. MLR rules apply to insured coverage. Self-funded plans, including most level-funded arrangements, file no MLR report and receive no rebate; the level-funded explainer covers the difference.

Methodology

Source. CMS Center for Consumer Information and Insurance Oversight, Medical Loss Ratio Data and System Resources, public use file for the 2024 reporting year: mlr-public-use-file-2024.zip (7,314,792 bytes, SHA-256 d2fe4d2e805cf6c6363f3406450019dc134eef23909ac608f169872de679d595), retrieved October 20, 2026. The file holds the raw MLR reports insurers submitted to CMS.

Rebate amounts. From Part4_Rebate_Disbursement.csv, row TOTAL_AMOUNT_OF_REBATES, columns cmm_individual, cmm_small_group and cmm_large_group (comprehensive major medical coverage). This is the amount CMS's own list of issuers owing rebates reports. Student health plan rebates ($323,175) and the mini-med and expatriate columns are excluded.

Aggregation. Each insurer files one report per state plus a "Grand Total" report across its states. We drop the Grand Total rows, join the state reports to MR_Submission_Template_Header.csv for the state, company name, NAIC company code and group affiliation, and sum by state and market. A "filing" is one insurer's report for one state. A filing "reports" a market when its 2024 total direct premium earned (Part1_2_Summary_Data_Premium_Claims.csv, row TOTAL_DIRECT_PREMIUM_EARNED) is above zero. Policyholder counts are row NO_OF_POLICYHOLDERS_OWN_A_REB in Part 4, as each issuer reported it. Amounts are rounded to the dollar after summing, so rows may not add to the totals by a dollar.

Reproducing it. Download the ZIP from CMS, then run node scripts/data/build-mlr-rebates.mjs --puf mlr-public-use-file-2024.zip from the Planlined site repository. The script writes the page data and both CSV files.

How these totals compare with CMS's published summary

CMS also publishes MLR refunds by state and market, which reports $1,640,091,858 for 2024 across 51 jurisdictions, the states and the District of Columbia. Our total from the public use file is $5,522,012 higher. The small-group totals match exactly. The differences are in these state and market cells; CMS does not say why its summary differs from the filings, so we report the filings as submitted.

Known limits

• Federal rebates only. Some states set their own MLR rules. CMS's list of issuers owing rebates notes that where both apply, an insurer generally owes the higher of the federal and state rebate, not both; state-law rebates are not in this file.
• Filings, not people. The figures count insurer filings and dollars. Policyholder counts are as reported and incomplete, and the file does not show which employers received a rebate.
• Insured coverage only. Self-funded plans do not file MLR reports.
• Reported, not audited. These are insurer submissions as CMS released them. CMS can revise a release, and an insurer can amend a filing after it.
• Parent groups as filed. We did not merge or rename groups, so a carrier's total can be split where some of its companies filed without a group affiliation.