Do COBRA subsidies lead to more coverage — and higher premiums?
August 21, 2009 by Jim GiulianoPosted in: COBRA, Health care, Special Report
Many wondered whether the subsidy enacted in February would spur more ex-workers to take advantage of the health coverage. Wonder no more.
The federal subsidy designed to make health insurance more affordable for laid-off workers has led to a doubling in the number of people who have opted to continue their former employer’s coverage. Those workers apparently can do the math and have figured out they’re getting a good deal.
According the the Kaiser Family Foundation, prior to passage of the subsidy, the average family was stuck paying about $1,000 a month for continued coverage under COBRA. The post-subsidy premium for the same family: $377 a month.
HR consultant Hewitt Associates analyzed COBRA coverage at 200 companies with 8 million employees and reports:
- From March through June of this year, monthly enrollment rates for eligible workers averaged 38%.
- From September 2008 through February 2009, the enrollment rate was a only about 19%.
With unemployment at a 25-year high — and no signs of a quick rebound in the job market — employers and HR offices should expect the coverage bubble to expand.
Analysts at The Segal Company, an HR consulting firm, point out that ex-workers under COBRA coverage tend to make more health claims, possibly because those people want to cram in as many services as they can while they have coverage.
Result: Companies that carry a lot of COBRA coverage may see their premiums go up.
Which sectors?
As you might expect, the biggest users of the subsidy program are workers from industries with the most widespread layoffs. For example, companies in the manufacturing industry saw an 800% increase in enrollments since the subsidy was enacted. Enrollments rose from 7% (Sept. 2008 through Feb. 2009), to 59% (March 2009 through June 2009).
Sign-ups for those who worked in the construction, leisure and retail industries tripled for the same period. The number of those taking advantage of the subsidy from the aerospace and defense; business services; food and beverage; media, and pharmaceuticals industries more than doubled for the same period.
Click here for an industry breakdown of COBRA enrollments.
Tags: COBRA, Hewitt Associates, HR, Kaiser
August 24th, 2009 at 12:59 pm
Jim Giuliano – Are you the same person who appears so often on the HR Morning blogs as “Jim”? Just wondering.
August 24th, 2009 at 1:42 pm
I find it hard to believe that claims would increase THAT much. I don’t visit the doctor JUST BECAUSE I have insurance….I go because I need to go. I think the subsidy was a great idea.
August 24th, 2009 at 1:50 pm
We haven’t seen an increase in COBRA participation at all. Even with the subsidy, some of the employees we laid off still cannot afford it. Out of the number we laid off, only 1 employee is participating with subsidy because his spouse has a medical condition. They are struggling to pay that from his unemployment check because she has no income right now.
August 24th, 2009 at 1:53 pm
I agree…I think we may have increased a little but not all that much and they aren’t the ones using the insurance the most.
August 24th, 2009 at 1:53 pm
If the claims are increasing, it is not because people have insurance. It is widely documented that the unemployed suffer from more health problems than do employed people. Further, as older, more experience workers tend to get laid off first so the employer can save more on payroll, naturally they will need more health care commensurate with their age. An employer can’t have it both ways. If an employer doesn’t want claims to go up, they should not lay off experienced staff!
August 24th, 2009 at 1:56 pm
I couldn’t agree more with the article and will have to disagree with Cindy’s response. If you are a healthy person you would not need to visit the doctor that much, but if you are an unhealthy person that needs services or a specific procedure and were offered the opportunity to have coverage, your darn right the people would try to cram as many services as they could before their cobra expired. Thus more claims to the company making premiums higher for the employees still working. I see it everyday working with insurance. Employees are terming and they come in all the time and ask when is the last day they are covered because they need to get something done or when a student is no longer eligible to be covered the parent gets all the necessary exams etc. done before the students coverage ends. It happens everyday.
August 24th, 2009 at 1:56 pm
Cindy: You maybe don’t use your insurance just because you have it; however, those getting a “deal” on COBRA tend to have higher utilization. They have treatments/services that could have waited; but rather than waiting, they take the less expensive COBRA coverage and get those things done sooner rather than later. We have seen a real spike in COBRA continuees as well as claims associated with them. My hope is that the subsidy is not extended.
August 24th, 2009 at 1:59 pm
The one person I have interested in the subsidy is planning on a back surgery. Our premiums will be affected. I think it is a nice option for those laid off, but the employer will be hit with an increase in the end.
August 24th, 2009 at 2:01 pm
Yes you are all right and one of the largest medical research institutions is completely wrong. I am sure there has not been much change in COBRA participation levels with the subsidy. Oh wait, I am a COBRA administrator and I know for a fact the number of participants has increased since Feb. I am sure the presidents popularity numbers declining is just a myth too.
August 24th, 2009 at 2:03 pm
We have seen a sharp rise in the number of COBRA participants from our manufacturing facility and quite a few of them have asked about the option of cancelling once they are treated for specific causes (i.e. after their next dental cleaning or their next eye exam). We haven’t had our insurance renewal yet, so we’re not sure how it might affect our rates, but there is no doubt that we have more people on COBRA that before.
August 24th, 2009 at 2:05 pm
I have seen a big uptick of Cobra participants. I used to average about 10 people on Cobra, now I am carrying 36 people on Cobra, with 100 regular participants on our plan, for a total of 136 plan participants. When our plan renewed, we had some backlash from the companies we were shopping our Medical plan with over the number of Cobra participants. We are in the financial industry and had a lot of layoffs earlier this year.
August 24th, 2009 at 2:08 pm
Oh I am the Christine that just posted, not the same Christine further up on the comments, sorry.
August 24th, 2009 at 2:26 pm
I understand that people need COBRA but the employers that are already struggling and having to lay off are taking the hit. This is not helping the economy turn around at all. I have heard several participants comment that they will get some surgeries that they need done since they are unemployed and will not be able to find jobs right away anyhow. Our number of COBRA participants is huge compared to what it was in January of this year. I really hope Congress and President Obama do not extend this beyond its current parameters.
August 24th, 2009 at 2:31 pm
Our COBRA participation has quadrupled since February. I know that those participating in COBRA would not have joined had there not been a medical need. Being the Benefits Administrator for our company, I received their EOB’s (we have an HRA which the company reimburses a percentage). Those needs did not go away once they were terminated. Some participants will use it heavily, while others want to have the coverage “just in case”. Construction work can be hazardous, babies arrive, etc., and life happens. In renewing our health coverage, the insurer would only do so for 1 year…makes me quake just imagining what’s going to happen next August.
August 24th, 2009 at 2:32 pm
Wait, Shelly, it is inconvienient for the employer who laid off people to have so many people on COBRA, which is their legal right, and was long before the subsidy was even conceived? I can tell you from personal experience that it is far more inconvenient to be unemployed.
August 24th, 2009 at 2:38 pm
And, yes, the subsidy is helping the economy, by helping people pay for food or rent or mortgages or utilities instead of being homeless. My family’s COBRA premium is $1400 per month. There is no way we will use that much health care. Even with the subsidy it is well over $400 and when we go to the doctor the copay frequently represents 70-90% of the total doctor bill at contracted rates. But no one is faulting the insurance companies or the health care system here, just feeling sorry for the employers. Well, boo hoo!
August 24th, 2009 at 2:43 pm
I’m with you Christine. I certainly would want the subsidy help if I was laid off….I’ve had cancer and I can’t afford to be without insurance. I also think we need healthcare reform.
August 24th, 2009 at 2:44 pm
Christine: I don’t believe Shelly (or any of us) begrudge employees their legal right to COBRA. But I can tell you this; our company provides a generous severance package (which I am certain that employees need to live on while they search for work); now the subsidy on top of that. It is a fact that our claims experience has increased since the subsidy kicked in and COBRA participation jumped. That claims experience will have a direct impact on the 2010 costs. At some point, something’s going to have to give. Do you think a terminated employee would prefer to have their COBRA costs subsidized OR have severance dollars that they can use to pay their monthly mortgage/rent and put food on the table? There may be one or two who would want the subsidy; but I’m guessing in most instances, the severance package is much more valuable and, if given a choice, the terminating employee would pick the severance.
August 24th, 2009 at 2:46 pm
Christine – I think you misinterpreted my point. What I am saying is that the way this was enacted did not take into consideration the adverse effects it would have on the employers that are being hit with the higher premiums. I DO NOT think it is “inconvenient” (as you said) to have people on COBRA. I understand the need and am very educated on it. This act was put in place to help the unemployed workers and if they are laid off or lose their job to outsourcing, it makes sense. But do you realize this act allows people who are terminated for not showing up to work, unable to do their job, etc. these same rights? The struggling employers are struggling harder now to keep more people employed and the workers that cannot perform or don’t bother to perform are getting the same “benefits” as the hard workers who were unfortunate enough to be part of a reduction.
August 24th, 2009 at 2:51 pm
Well put, Shelley.
August 24th, 2009 at 3:04 pm
The COBRA subsidy applies to people who became unemployed in a given time frame that corresponds with the largest period of layoffs. Of course there are some people who will take advantage but the majority of beneficiaries of the subsidy were terminated and did NOT receive a severance of any substance. So the choice of severance versus subsidy is simply unrealistic.
August 24th, 2009 at 3:06 pm
Shelley-EXCELLENT post. Very well put, and very true!
August 24th, 2009 at 3:08 pm
I do agree that there are people who do need the added help from the Cobra Subsidy. One problem would be that it adds extra work to manage the subsidy and when you have a reduced staff that can be a hardship. And let’s not fail to mention that the company, who is on a tight budget, has to foot the cost of the cobra subsidy until uncle sam gets around to reimbursing them.
By the way…..has anyone out there been reimbursed yet from the government. I know we haven’t!
August 24th, 2009 at 3:26 pm
Good points everyone.
August 24th, 2009 at 3:33 pm
Of course, more people are going to elect COBRA with the subsidy even if they don’t have medical issues. Just in case, or so they don’t go more than 63 days without coverage, which could subject them to exclusion for pre-existing conditions when they next apply for insurance. It also makes sense that people will have surgeries or procedures they’ve been putting off now that they have the time. I don’t begrudge it to the employees (I wish it was subsidized when I was unemployed), but this administration just doesn’t seem to be taking into account the unintended consequences of many of their proposals which realy concerns me.
August 24th, 2009 at 3:37 pm
We have tripled the number of people who normally take COBRA. I do happen to know that several of them have significant medical conditions that require a lot of extra care. I also know many of them are using the benefits as much as they can because they most likely cannot afford to stay on the COBRA coverage once their 9 months of subsidy premium reduction runs out.
The people enrolling in COBRA are usually those that need the coverage the most. I think the subsidy was a very nice thing the government did and it was nice they did help offset some of the employer’s cost via payroll tax credits. It is still a drop in the bucket compared to what it is doing to our claims experience since we are self-insured. We did not have layoffs so most everyone using the subsidy are those with performance issues who were terminated for cause.
It wouldn’t bother me if these people used the insurance like they normally would and weren’t having every discretionary procedure and test possible. Many other companies are experiencing the same thing due to the subsidy so it may not hurt us as bad with our renewal as it otherwise would. I am sure I would consider doing the same thing in similar circumstance so I don’t blame most people for making sure they can take care of health issues before they cannot afford to do so.
I am frustrated that the subsidy wasn’t thoroughly thought through before it was passed. They made up the process as they went along. It was the same with Medicare Part D. I hate to think what will happen with healthcare reform. I am sure there will be outrageous deadlines and penalties for employers with instruction and clarification lagging far behind and constantly subject to change.
Patricia
August 24th, 2009 at 3:39 pm
I’d like to see each one of your postings change if YOU were the one unemployed. I struggled to make my insurance premium each month for my family and I mean down to mac&cheeses or beans&weenies for supper several times a week. It took the average (then) of 4 months before I found another job but it was way less then my previous income. Now the average time to find a new job is way longer. The difference this sucsidy would have made in my family is incredible. We do need insurance reform, we do need to reign in health care costs too. I hope the subsidy is signed into law, and even extended to last longer. Yes, I’ll have a bit more paperwork to do but I would have appreciated someone doing it a few years ago for me! Yes, my premiums will be a bit higher too. I think the insurance companies planned on that anyway! we had an18% jump last year. Lets go after those that are really making the decisions that require a subsidy like this and it’s NOT your average employer.
August 24th, 2009 at 3:39 pm
We had a small reduction in force, but our “severance” package is two weeks’ salary (or if you’ve been here a really long time, four weeks). Not enough to pay for typical COBRA premiums for very long. So, I’m glad our terminated employees are getting a little bit of break. Many employers don’t give out severance packages large enough to cover the cost of health insurance for several months.
Tina – The reimbursement comes from the credit you claim on your quarterly payroll taxes, not from a direct check from the govt.
August 24th, 2009 at 3:40 pm
Tina, you need to take the employer portion of the 65% of the premium off your 941 for your tax filing. The government won’t send you money. You just pay less in payroll taxes each quarter. If you use a company to process your payroll, they will provide you with instruction on how to submit the tax deductions. If you have a payroll department, ask them what they need to file and what format they need from you to get the credit.
I have done it through ADP and I have seen the credit on our reports.
Patricia
August 24th, 2009 at 3:49 pm
Patricia’s last comments about the government thinking through the process first are my thoughts exactly. They did not even have the model notices or anything done when they enacted it!
Tina – Is your 65% subsidy credit greater than your payroll taxes? I am thinking that might be why you are waiting for a refund. We have been able to just reduce our payroll taxes (fortunately).
August 24th, 2009 at 4:15 pm
Our company has received reimbursement from tax overpayments…solely due to the 65% COBRA premiums. Yes, we got the check!
One way to combat COBRA abuse is to remind former employees that if they become eligible for other insurance, they must enroll in it. They are responsible for informing you of any eligiblity they have (through spouse, new job, etc.). If they don’t join the new plan, or pay COBRA at the 102% rate, they could face up to 10% in penalties from Uncle Sam (your company would not bear any fault or penalty). One of my COBRA people has been re-employed elsewhere, but they don’t offer dental insurance. He must pay the 102% COBRA rate for our company to keep him enrolled under our plan for 18 months (maximum), and is ineligible for the subsidy.
August 24th, 2009 at 6:02 pm
At our company (We are in the Manufacturing portion in the Aviation Industry along with Repair of Aircraft components), we have not seen any increase in cOBRA participation from our former employees. At seperation, I/we explain the cOBRA subsidy as well as all aspects of cOBRA coverage.
August 24th, 2009 at 6:38 pm
We are in the process of a reduction in force layoff of about 20% of our employees due to severe funding cuts. There is no severance or any other extra pay, even for people with 20+ years of service (one has 30+ years.) I certainly couldn’t blame anyone for taking the COBRA with the subsidy, and getting whatever they need done, because the premiums without the subsidy are pretty hard to afford on unemployment. As for higher premiums resulting, I’ve worked here 15 years and have seen premiums go up every single year, even though our broker shops the market each time. The insurance carriers quote usually around 12 – 14% increase and we’ve usually been able to tweak the benefits or choose slightly different plans, (less rich) or put the vision with the medical carrier to get a little break on the increase and those things have generally kept the increase to “only” 9% plus each year. So, it has just about quadrupled in those 15 years. If the subsidy causes an increase, it’s just this year’s excuse.
August 25th, 2009 at 6:13 am
THe majority of the people who took the subsidy were lay offs and some have come off already because they found other jobs. I do not see any abuse here….just a few grateful people who can afford health insurance while they are looking for a new job.
You can’t blame ONLY this administration for programs that werent thought thru well enough…it’s government…its how they operate unfortunately. The subsidy had to be put in place and fast. It was a little confusing at first but we ALL got through it. I’d want the help if it was me. Our severence is usually only two week to a month…that won’t but very much health insurance.
August 25th, 2009 at 6:51 am
I’ve just read about 3 dozen responses that beg the much larger question: Why is access to health care tied to the work place at all? Why is it that when you do have a job, you may or may not be offered access to health insurance that you still may not be able to afford anyway. Why is it that when you don’t have a job you may or may not be offered COBRA that you certainly can not afford. Why is it that every major industrial nation on the face of the earth have health care access for all their citizens and we, the richest of them all, do not? And why do we rank somewhere around 35th for life exectancy and not much better for medical outcomes? That should suggest to anyone with an open, rational mind, that we are doing something wrong. The question should not be does COBRA raise medical useage, but rather why should anyone have to depend on COBRA, or on employment in general, to have medical access when they are sick, injured, or in need of medical care?
August 25th, 2009 at 7:30 am
Our number of participants in COBRA has quadrupled since the stimulus package. We are self insured and this will cost us dearly. Our annual cost per participant is more than $7,000 greater per COBRA participant than our regular employee.
August 25th, 2009 at 7:37 am
We definitely have more Cobra participants now then prior to the subsidy.
As for getting back the 65% from the government, we take it off our weekly 941 deposits. No need to wait for a refund from the government.
August 25th, 2009 at 8:12 am
Thank you CINDYD!! That is definitely what has been missing in these threads because I sure wouldn’t want to be someone who had to pay COBRA subsidized or not! The insurance companies are going to tear every company a new one every single year no matter what your experience rating is. We have had great years and still had double digit increases and we have excellent brokers who can only do so much because the insurance company digs in their heels. They wouldn’t miss a group our size if we went to another company so theres but so much leverage. We have the Mercedes of Insurance Coverage at my job which a lot of other employers don’t even offer anymore. COBRA on any of our coverages would cost a bundle for someone suddenly unemployed.
SHELLY: Good point about the poor performing employees who are terminated and get to take advantage. They should not be able to take advantage but unfortunately, that part wasn’t thought out.
August 25th, 2009 at 9:14 am
Some of the posters on this site are what make some people refer to Human Resources as “Inhumane Resources”! Thank goodness for those that actually show compassion for their employees. I agree that the insurance rates will go up no matter what – the COBRA subsidy will just be this years excuse. I’ve been in this field for 25 years and the last 10-12 have been ridiculous with how rates increase. My son just graduated from college and you can bet I had in him in for everything he could get before he lost his insurance May 31. We shouldn’t be so quick to judge others until we look at we would do in the same situation. It’s nice to have an administration in office who actually cares about the “average guy” more than the top echelon of the corporate world for a change. It’s not a perfect plan but it had to be put in place in a hurry to help out those who needed it the most. There will always be abuse of any program, but I think in this case it has helped many more than not.
August 25th, 2009 at 9:25 am
I have been on both sides of this COBRA situation. There are goods and bads. An example, we have an ex-employee who was released several months ago and does continue his COBRA plan. BUT, we have had others who have told us this particular ex-employee is working for CASH. It has been reported to the state unemployment, but the response we have received is that they are too busy to investigate.
We have another employee who is on the COBRA plan. He states he is uneligible for his wifes insurance, but we find out through other sorces that he IS in deed eligible.
We just received our renewal for the upcoming insurance premium rates – went up 32% – their reasoning – one of the ex-employees has had two surgeries that were to fix previous injuries to when he started working for us – plus he has been on a 4 week vacation and still collecting unemployment. The other ex-employee also had one surgery.
So, my question is – our insurance rates went up because of the abuse of the two ex-employees, as a employer the rates went up as well as for those who are still employeed here – how is THAT fair??
Who is going to stop those that are abusive to the system? Sounds like they don’t have a plan for that! Instead, those who do still have jobs will PAY for those who don’t and have abused the system.
We have contacted everyone that we can think of on these two ex-employees – nobody seems to care! Sad to think that some can abuse the system that is to help those who are honest and struggling through these times, but they are doing it and everyone who we have contacted (insurance companies, unemployment, etc.) doesn’t seem or doesn’t have the resources to do anything about it. Here’s an idea for them – - – hire some of the unemployed – some of them obviously know how to cheat the system – - pay them to catch these people. Then, unemployment #’s would be down. Those that abused the system would be charged the 110%.
I thought the whole idea was beneficial to those who are struggling to find a job, but when we get news like we have on the ONLY two ex-employees who have the COBRA, well, lets just say it burns my employers butt and I have to hear about it!!!!
August 25th, 2009 at 9:38 am
Nicole:
You can’t be on vacation and still get unemployment…you have to bea available to work.
August 25th, 2009 at 9:39 am
Thanks, Kevin….you are most certainly right
August 25th, 2009 at 9:42 am
Have you reported the employee who MAY be eligible through his wife’s employer to your insurance company? I had the same situation and our company immediately investigated. No insurance company wants to pay for someone that could have coverage somewhere else.
August 25th, 2009 at 9:43 am
Cindy – They only have to call in and certify for unemployment so they can say they are available for work and still get it.
August 25th, 2009 at 9:45 am
Cindy, unemployment is one of the most abused programs we have out there. TX states you must contact just 2 employers a month. Online counts and so does a simple call to say “are you hiring”. I’m glad the state extended it because I know it’s helped a lot of people but I see abuse and outright fraud in this system more than any other INCLUDING worker’s comp.
August 25th, 2009 at 9:46 am
sorry, it’s a 2 employers a week! my mind ias already fried and it’s not even mid Tuesday!
August 25th, 2009 at 9:47 am
Nicole said: We have another employee who is on the COBRA plan. He states he is uneligible for his wifes insurance, but we find out through other sorces that he IS in deed eligible.
Dependable soruces? The only dependable source would be someone inside the wife’s company’s HR Dept who deals w/health insurance enrollments.
Nicole said: plus he has been on a 4 week vacation and still collecting unemployment.
?? is he layed off or on vacation? If he’s on vacation report him to Unemployment as an active employee.
August 25th, 2009 at 9:53 am
The people who try to Milk unemployment for every brown penny totally “Grinds my Gears”. Some will come in and ask the receptionist for a copy of my business card or the general business cards we keep up front. She has been instructed to screen them and not give it out unless they complete an employment application.
August 25th, 2009 at 10:02 am
I agree it may be the humane thing to do but it still is significantly increasing our costs because we are self insured and directly pay for claims. No matter how concerned or compassionate I am, I cannot help but think how is the guy in a coma for three months after driving drunk is going to affect our claims experience.
Companies don’t have an endless supply of money. When we get $500,000 claims, it hurts. It not only hurts the employer and the investors but all the existing employees. We have to decrease our level of coverage or charge more to active employees if expenses are high enough. An employer may eventually have to drop coverage entirely. Compassion has a price tag and we are all paying it. What good is a COBRA subsidy if it increases costs for the employer and active people so much they cannot afford insurance? What if it prices a smaller company out of the market so they entirely drop coverage?
Businesses are not always the bad guys this current administration makes them out to be. Companies need to maintain a certain level of profitability to pay employee wages and benefits. So they pass the costs to consumers who pays with higher prices but the prices can only go so high before comsumers stop purchasing. Something has to give. Every mandate placed on a struggling business has a cost attached to it and at some point the price may be too high.
I was the controller at my last company for 8 years and it was a small business with 35 employees. There were many times I held my pay to make sure our people got paid even though I wasn’t an owner of the business. I understand compassion but I can directly appreciate the cost to the small business that paid a price for its compassion.
The government makes mandates and passes these programs without having a plan in place for how to roll them out or administer them. They don’t always consider the cost implications to employers and this is one of them. Double digit increases are the norm and insurance companies will use this as one more excuse to hike up premium rates. I think the subsidy was a very compassionate thing the government did and I know it has helped many people who deserve such help. I would just like to see a government program put forth with some forethought and a plan. Before government issues more employer mandates, clean up what we have. Stop some of the outright fraud and abuse and clean up the system. I will gladly pay my fair share of taxes or employee benefit premiums but I would love to know it going to cover those in need instead of those who know how best to milk the system.
Patricia
August 25th, 2009 at 10:05 am
Very well said, Patricia.
August 25th, 2009 at 10:09 am
Not sure how you could force an employee to enroll in their spouses insurance when you offer it to all your employees. I am currently on my own insurance with my employer and my hubby carries himself. I have an HSA which I absolutely LOVE but my hubby does not because he doesn’t understand it so he does not want to be on it. He has a traditional PPO with Co-pay. If one or the other of us loses our job, we are safe. There are a lot of employees here who are enrolled in Health Insurance Separate from their spouse. Because our benefits are top of the line, the employee share premium is really expensive to carry more than 1 person.
August 25th, 2009 at 10:40 am
Kevin Baldwin brings up a good point. “Why is it that every major industrial nation on the face of the earth have health care access for all their citizens and we, the richest of them all, do not?”
People in these countries often pay 50% of their income in taxes to support these systems. Not just the rich but the common man making a regular wage. Ask your employees earning $20k to $40k per year if they would want to pay 50% tax to have public healthcare. I suspect few would even if it would work to their advantage. Everyone wants the benefits but the people who currently pay little to no income tax would have to pay a lot more in taxes than they do today to provide adequate healthcare to everyone. Everyone wants it but isn’t willing to pay for it since only those rich people should have to pay to cover the costs for everyone else. Also, almost everyone I know in Europe, Canada or NZ purchases additional private insurance if they can afford it on top of the government program they pay for with their taxes. There are benefits and drawbacks to every system but I do agree our current system is broken.
Secondly, our public healthcare system in this country is often terrible and cannot support those currently using it. I know this first hand since my brother has to be on it. He is a 51 year old uninsured diabetic and it took him two years to be allowed to see an eye doctor for his vision problems. Now all they can do is try and keep him from going blind. Who knows what they could have done two years ago if he was able to see the doctor and get the treatment he needed.
A country’s medical infrastructure does not change overnight. We don’t have the system in place to take on all those in need today let alone everyone in this country. I am not saying we shouldn’t try to get there but dumping many millions more into a system that isn’t staffed to able to handle the current volume isn’t the answer. So much focus has been on everyone needing insurance which isn’t the real issue. We need safe, affordable, accessible and timely healthcare and that isn’t being addressed.
I don’t have any great solutions but the current system is broken in many areas, especially in the areas of fraud or unnecessary or duplicate tests and procedures. What may work well for a country the size of England or France may not translate well to a country this diverse and this large. Changing laws without considering the ramifications or having a plan is unconscionable. If a healthcare bill is pushed through with lack of forethought or an implementation plan such as what we saw with the COBRA subsidy, I am very frightened.
Patricia
August 25th, 2009 at 10:44 am
My thoughts exactly Patricia!
August 25th, 2009 at 10:47 am
Here, Here, Patricia!
August 25th, 2009 at 11:09 am
The funny part to me is that it seems people are upset at the fact they have to strugle during hard times, as if hard times are somehting they should not be subject to. Nice homes, cars and steak dinners are not rights we all have, but luxeries we earn. If you fall on hard times and have to eat Ramen so be it. It is not someone elses fault that we can not stay within our means and save up for the rainy day. If you can’t afford to live where you are then move. Times are tough, and it is not someone elses fault. We all need to just cuckle down, grit our teeth and push forward. Do all you can to support your family, even if it means mac & cheese, and fight through. Our country is caught up on looking for handouts, or someone to bail us out and what we really need is to have those who aren’t taking the smart rout to suffer (wall street included).
August 25th, 2009 at 11:10 am
I am seriously beginning to believe that the government would not be able to function if it were on the up and up and ALL the fraud and corruption were gone. Sadly this has become the norm under ANY administration. We need a new party that’s not a Donkey or Elephant.
August 25th, 2009 at 11:11 am
I am seriously beginning to believe that the government would not be able to function if it were on the up and up and ALL the fraud and corruption were gone. Sadly this has become the norm under ANY administration. All we can do is hope that we don’t lose our jobs since Medical coverage is employer related and if we do, hope we will be able to keep a roof over our heads, food on the table, and be able to pay COBRA. This is a great subject.
August 25th, 2009 at 11:12 am
Just a note: The subsidy does not cover employees terminated for “cause”. It covers “involuntary terminations”. Termination for “cause”- does not fall under the guidelines.
August 25th, 2009 at 12:18 pm
Sandy – That is not the understanding we were given in the COBRA seminar attended. They said that if the employee did not initiate the termination then they were eligible for the subsidy. The only exception is for “Gross Misconduct” but you have to have that defined and legally it is hard to win cases on that.
August 25th, 2009 at 12:20 pm
Sandy: We have confirmed with multiple sources that the only involuntary term that is not subsidy eligible is anyone termed for gross misconduct (which as we all know, is very hard to prove).
August 25th, 2009 at 12:32 pm
Thanks for the feedback…Agree-Gross Misconduct can be an issue…I have not ran into this issue to date. Just wanted to make sure that it was noted.
August 25th, 2009 at 12:40 pm
“involuntary termination” and “for cause termination” can in some situations be the same thing.
August 25th, 2009 at 4:20 pm
We had a small lay off this year and was glad to see people that would otherwise not be able to afford coverage elect COBRA. I believe when your medical plan is being priced a carrier reviews how many are on COBRA so they can tell not only how many participants you have, but also if the claims experience were from those participants and how many claims (depending on diagnosis) will continue or not.
August 25th, 2009 at 4:26 pm
I am not sure if this happened to anyone else but we have a 3rd party administrator who “handles” our COBRA. We offer Domestic Partner benefits but the way they set up the data “dump” it would go over as Employee + Spouse. I took over COBRA in May and started working with this administrator – Domestic Partners don’t qualify for the ARRA subsidy. By the time I got the reports and caught it in July, we had already lost several thousand dollars because they were only charging them 35%. This is only one of their snaffus causing us to bring it back in-house so advice on resources as I develop our in-house program would be appreciated. I was supposed to have it in-house by September but that won’t be happening.
August 25th, 2009 at 4:52 pm
If an employee has turned in a time card for hours not worked is this gross misconduct?
August 25th, 2009 at 4:57 pm
If an employee submits a time card for hours that the employee did not work and is terminated would this be considered as gross misconduct. I really hate to see an ex employee receive this subsidy when they have actually committed fraud.
August 26th, 2009 at 6:21 am
FAYE: This is gross misconduct and hopefully, they were terminated. They may not be eligible for unemployment (of course Unemployment makes the ultimate decision) which according to ARRA should in turn make them not eligible for COBRA Subsidy. Falsification of Time Cards is something you can easily prove as gross misconduct.
August 26th, 2009 at 6:37 am
We have one former employee on COBRA who is going to ride it out until the end because they aren’t eligible for Medicaid yet. This person racks up VERY VERY expensive medical and pharmacy claims which affect our experience rating. This person was not eligible for the COBRA subsidy but when she took COBRA, she had to drop her spouse off the plan in order to afford the monthly payments.
August 26th, 2009 at 7:29 am
Shelly – Domestic Partners are not eligible for COBRA at all; however, if you offer it to one you must offer it to all. We outsource COBRA, too, but I do not give our vendor the domestic partner info when I send them the info on departing employees & dependents.
August 26th, 2009 at 7:51 am
We outsource our COBRA and I am glad we do. With all the regulations and such, any misstep could get your company in a lot of hot water and I don’t want to worry about that. I only send them the information on Newly Hired and Terminated employees and they do the rest.
August 26th, 2009 at 7:52 am
Marilyn – You are right. We choose to offer it to Domestic Partners but they can only elect if another qualified beneficiary enrolls according to the COBRA guidelines. I just wanted to point out to anyone else that does this that they are not eligible for the ARRA subsidy so to make sure their rates are charged correctly.
Faye – Gross Misconduct actually disqualifies them from even being offered COBRA. You just have to be careful and make sure it will hold up if they take you to court. The government does not have it defined clearly and they decide it on a case by case basis. (It was a topic at a COBRA Seminar I attended in June)
August 26th, 2009 at 8:05 am
Stacy – our outsourcing company has made a lot of errors and is very slow to respond. For that reason and to reduce expenses we are bringing it back in-house.
August 26th, 2009 at 8:09 am
Shelley- You may find it’s more expensive to have in-house if something is overlooked or handled incorrectly. You might want to see if you can find an alternative. Our adminstrator is so good; quick, efficient and always takes a conservative view of things (better to be safe than sorry). Just a thought. As things change, it’s going to be more and more difficult to cover all bases (especially for those of us operating with minimal staff internally).
August 26th, 2009 at 8:14 am
I can’t imagine bringing Cobra in-house now. Our HR Dept used to be 4, now is 1. We’ve been having many, many layoffs since Aug 08. In Jan 09 we had 10 Cobra participanats. Now we have 35. I couldn’t begin to manage it in-house by myself!
August 26th, 2009 at 8:19 am
CindyM – I totally agree with you. We were having so many problems and I opened my mouth and said that when I did it at my previous employer we never had these issues. I have learned not to open my mouth anymore. We have reduced staff and closed offices across the U.S.
Marilyn – It is really hard to imagine bringing it in-house. I have been working to get it set up since the beginning of May along with my other responsibilities and correcting the mistakes of the administrator who we have it outsourced to currently.
August 26th, 2009 at 8:22 am
I administer COBRA in-house and subscribe to an on-line service called CobraAid. Website is http://www.cobraaid.com. They are very good, provide manuals and forms, send updates, answer questions quickly. Sorry I don’t know the cost since my benefits broker pays for it, but I would highly recommend it for anyone working alone.
With regard to COBRA for domestic partners, I would suggest you also check your state laws before refusing it. Some states do have statutes which require you to provide continuation of coverage similar to COBRA.
August 26th, 2009 at 8:22 am
OK, so who is eveyone using to outsource to – happy with them or not?
We use Ceridian and I am quite happy.
August 26th, 2009 at 8:24 am
We use Infinisource; LOVE THEM.
August 26th, 2009 at 8:24 am
We use Ceridian and are quite unhappy.
August 26th, 2009 at 8:53 am
SHELLY: Quick Question…Do you distinguish your terminations with COBRA Administration? Maybe I can learn something because I have never distinguished mine, I just have the 3rd party administrator send the notices to all terminated employees.
August 26th, 2009 at 8:53 am
SHELLY: Quick Question…Do you distinguish your terminations with COBRA Administration? Just asking.
August 26th, 2009 at 8:56 am
With this new program I have to tell my 3rd party COBRA administrator if the seperation was voluntary, involuntary or for cause.
August 26th, 2009 at 9:00 am
On the weekly feed to our administrator, we indicate the reason for the termination (i.e. voluntary/involuntary).
August 26th, 2009 at 9:02 am
SHELLY: Quick Question…Do you distinguish your terminations with COBRA Administration? Just asking.
When I got the HR Manager job in 2006, my first order of business was getting a 3rd party administrator. We first used the payroll company we don’t use anymore for COBRA Administration and I didn’t like it and won’t mention their name but it’s not one of the big Three (ADP, PAYCHEX, or CERIDIAN) Then, our brokers put us on to a company that was formerly called “Process Works” and has merged with United Healthcare which is the name now they go by. I am satisfied with them and as long as I do my part, everything goes smoothly. I have given them the authority to enroll COBRA participants and Delete them if they don’t pay or when their time is up. It shows up on my billing and I take it from there. Once in a great while, we run into an issue where a COBRA participant is no longer participating and we have paid the premium in advance of COBRA payment so I have to take a credit on the billing or the exact opposite. It’s a mild annoyance compared to having to do it myself.
August 26th, 2009 at 9:02 am
Stacy: I am not sure what you are asking. I have to tell them if they were voluntarily or involuntarily terminated – we were able to do that in our export file to Ceridian. If we code them as a voluntary termination and the person tries for ARRA, we get an email asking for confirmation on if they were voluntary or involuntary. This was huge when it first came out because the people in our payroll department that were entering the COBRA event into Ceridian were not differentiating.
August 26th, 2009 at 9:03 am
Our TPA has always asked if for the reason of termination. Of course it became more important then ever with the Subsidy.
August 26th, 2009 at 9:06 am
SHELLY: Oh ok….I get that. I guess because we really haven’t involuntarily terminated anyone this year, I hadn’t run into that. I learned something today and now I know what to look for in case it comes up before the end of 2009. Thanks so much for the info Shelly!
August 26th, 2009 at 9:13 am
MARILYN: I don’t blame you for not wanting to do COBRA Administration in house. That’s how it was done BEFORE I was promoted to HR Manager. Our former brokers were good BUT, they never did tell the former HR Manager what a risky business it is to administer COBRA yourself. I think at the least, it should have been explained to her. We had another broker who had been courting us for years come to the table with a very competitive bid and we went with them. COBRA administration was the 2nd order of business. They explained to my boss and I the risky business of COBRA administration but not in such a way that they were selling us anything. They told us to shop for a 3rd party administrator and we went with our payroll company at that time. Once we found we were not satisfied with them, we went back to the broker to ask if they had any recommendations and they put us on to Process Works/United Healthcare. Our broker lived up to everything they put on their bid and more and the COBRA administration advice was the best thing we ever did.
August 26th, 2009 at 10:14 am
Shelley, with all the legal requirements around COBRA and all the changes being made, I would not want to bring it in house. We have used several vendors over the years and all of them asked the reason for termination. If a dependent lost coverage because they no longer qualify because of age or divorce, they get a longer COBRA period. If someone loses coverage because they change status to part time, they get COBRA. If someone voluntarily drops coverage and remains employed, they don’t get COBRA at all. They should always be asking for a reason for termination or terminating coverage. Due to the subsidy, it now goes a step further to distinguish if a termination was voluntary or involuntary for subsidy purposes only.
Using a COBRA vendor should also provide your company with a degree of protection from liability for the vendor’s mistakes. If you give the vendor timely and accurate info and they don’t send out a notice, the notice is out of date or it doesn’t go out in a timely fashion, they should be on the hook for whatever liability your company is charged with due to their mistake. That was my experience with Infinisource and Ceridian and other vendors. Call other vendors and find out what their responsibility is when they clearly make a mistake. If they do accept a degree of liability for their mistakes or if their notices, etc…are not compliant with the current legal requirements, you can use that as an argument with your employer as a way to just switch vendors and not take it in house. It is the same reason someone uses a payroll service. They file the payroll taxes and do whatever reporting is necessary and if they don’t do it right or on time, they have some of that liability for their mistakes.
Faye, you are going down a slippery slope. Most people don’t enroll in COBRA even with the subsidy. I have told my assistant that unless someone is murdered or there is physical violence involved, it is not worth fighting over the gross misconduct right to refuse COBRA. There is no government defined legal definition that clearly states what qualfies. If you offer the COBRA and the former employee doesn’t take it, it is no loss to your company. If you don’t offer it or deny it and they file a complaint saying they were not offered COBRA, you have to defend it and your company can be fined and required to reinstate the person’s coverage for the time it was being debated AND you may still have to offer them COBRA. No matter what, if they complain, it will cause your company legal fees and will cost you time. People do it all the time to get even with their former employer. Also, unless you have a clearly listed definition of gross misconduct and grounds for immediate termination in a handbook, policy statement, code of ethics or whatnot, it is going to be very hard to defend this as gross misconduct.
We have had multiple employees over the years come in drunk and tell us they were drunk and they qualified for unemployment after we disputed it because we didn’t drug/alcohol test them. We had someone steal a company truck and total it and they got unemployment. I would consider those reasons termination for gross misconduct but obviously Florida and Texas didn’t.
So right or wrong, we send out COBRA notices to everyone unless they were terminated for physical violence. Our legal advisor agrees. I would dispute COBRA for gross misconduct for something other than violence only if there was an expensive claim on the horizon and we felt the former employee’s reason for termination was serious enough.
We have had timecard issues and people make excuses like they were not the one to record the time or they filled out what their manager told them to or someone altered it and they are being set up or they simply made a mistake. Depending on the situation, it may not be as easy to prove as you may think.
Patricia
August 26th, 2009 at 10:21 am
Faye: Patricia is right, we have requested outside legal input (our administrator’s legal counsel agrees) and unless there is physical violence or something similar, we always offer COBRA. Even with the expense of COBRA (should they elect to take it), it’s less expensive than fighting a court battle.
August 26th, 2009 at 10:22 am
Patricia – I appreciate your feedback but unfortunately, I just have to do as the executive management team has decided. They decided to bring it back in so now I will do my best to administer it along with my other job duties. I know all the rules and regulations with time periods etc on COBRA as I have done this before and I have plenty of reference materials as well.
August 26th, 2009 at 10:33 am
SHELLY: Good Luck with your COBRA Administration, maybe you can eventually convince your Sr. Management to consider a 3rd party vendor in the near future.
We send COBRA notices to everyone regardless of why they were terminated. We haven’t had any involuntary terminated anyone for gross misconduct this year, just regular layoffs (I should have said that earlier in my posts regarding involuntary terminations). Since I have been HR Manager, 9 out of 10 people do not take COBRA anyway.
August 26th, 2009 at 10:34 am
Faye: We offer COBRA to everyone because it is cheaper than the court cost alternative. This was advised by our Legal Counsel as well.
August 26th, 2009 at 11:36 am
Shelley,
I certainly understand. We all do what we have to do even if it isn’t what we would choose. If you were still interested in outsourcing, you can ask if the health insurance carrier bundles in COBRA or would be willing to bundle it into the admin fees when you are up for renewal. That is what we are currently doing. It is nice that when we terminate someone from the health insurance administrative site, it automatically feeds COBRA instead of having to input the data or do a feed from a separate system. Same for the initial notices when we add someone. I’m not as happy with the carrier we are with currently but they are adequate. The best was the COBRA group Aetna used. The reporting was fantastic.
Maybe if you can get it bundled in with your renewal, you could sell the execs on this being a cost efficent and liability reducing way to administer these benefits. If you work closely with your broker/consultant for your benefits, s/he may have more influence with the execs as an outside expert.
The website Kathy recommended for http://www.cobraaid.com sounds like an awesome tool if it makes the most sense to keep the COBRA in house.
Good luck! Transitions are always painful but it sounds like whatever you do, it will be better than what you are dealing with now. It irks me to no end when I am paying a vendor for services that they are screwing up. Having to do the cleanup is frequently more work than if you were doing the entire process yourself.
Patricia
Patricia
August 26th, 2009 at 11:56 am
Patricia-
Thanks. Do you just have one medical carrier then? Do they do the dental too?
We are self-insured and use three different medical providers then the dental is the same. It is also a bit of a challenge because I am in charge of COBRA for the US. I don’t really know the benefits outside of our office so it has been a challenge to say the least.
August 26th, 2009 at 12:35 pm
We acquired a new branch on 01/01/2009. As a courtesy to the employees, my company left them on the benefits they currently have for 2009. When I issue a termination on their plan, the COBRA is tied in to the carrier who then issues a COBRA Notice for Dental, Vision & Health. I am probably going to have to go up there at Open Enrollment with Protective Head and Body Gear because our benefits are way better but way more expensive for the employees. They already know what’s coming but what’s better than beating up on the HR Manager in person instead of e-mail or phone? I take it all in stride, it’s challenges like these that I learn from and grow.
August 26th, 2009 at 12:48 pm
We are also self-insured and have locations in 20 states and 1000 employees. We have an ASO arrangement with one carrier and we will probably change carriers for the 2010 plan year. We have an indemnity plan in place for the handful of people that do not have adequate network access with this carrier but it is only necessary for 30 employees. Dental, COBRA and FSA are all in the same plan with our current carrier. We used to include EAP and life/disability with the same carrier when we were with Aetna. We negotiated a really good rate by offering to give Aetna all our ancillary lines in addition to all our medical. Now we use a different life/disability and EAP vendor but I will gladly dangle that carrot in the future to any health insurance carrier if we can get better rates by combining all of our benefits under one carrier.
We looked at the TPA route and it was far too confusing for everyone and we wanted one carrier across the country. You pay a few bucks more for an ASO arrangement but the big carriers can negotiate some darned good discounts. It can save you tons in administration time and effort. Everything can be centralized. One benefit enrollment kit works for the entire company. Reporting is easier and cleaner as well.
The former owners used a TPA and they were horrible. We had to do a full year of runout on the old plan because 8-9 months after leaving them, they were still processing hundreds of thousands in claims each month from the prior year. When we moved from Aetna for the 2007 plan year, Aetna had 95%+ of the claims wrapped up in 3 months. It made a huge difference. (I still love Aetna.)
We also have the most amazing Broker/Consultant group. Our execs LOVE them. In addition to RFPs for our renewal, plan design and claims reviews, we work together all year to strategize and manage the plans and come up with cost saving measures. We took our enrollment online and we do monthly benefit orientation webinars together for the field employees since we are so geographically separated. They put together all our open enrollment kits and they help me send them out to the 150+ locations. Plus we negotiated a flat fee monthly consulting payment instead a % commission on the benefit plans so we can control our costs with them and keep the plan costs down.
It has been a good arrangement with for us. It has made my life easier and the execs are happy so something seems to be working.
Patricia
August 26th, 2009 at 1:17 pm
Stacy-
So do they just send your notices or do they collect payments, track everything, etc. too?
August 26th, 2009 at 1:27 pm
Stacy: You can’t really force a person eligible for spousal insurance to take it. But, the COBRA subsidy is only available to those involuntarily laid off and who are not eligible for coverage on a spouse’s plan. So, their choices are to take the spouse’s coverage (likely with the higher premium) or take the COBRA without the subsidy, or go without insurance. I agree with many of the things Patricia, Kevin and Stacy have said and thankful to see balanced, reasonable positions and not partisan rants. Also, haven’t had time to read all the posts, but am glad to see actual helpful info being passed along re third party administrators. When we started with Conexis, we had exactly one person on COBRA, but now, with a 20% staff reduction in force layoff, I am so glad I only have to notify Conexis and they keep up with the notices. I’m anticipating at least some of those laid off will take the COBRA with the subsidy. We usually do not get much COBRA participation.
August 26th, 2009 at 1:42 pm
Shelley,
The groups we have used and those that were mentioned in this thread will do it all. When we have had COBRA paired with the insurance carrier, they also reinstate the employee’s coverage when they receive and post the employee’s payment and terminate the employee’s coverage when they don’t pay and their grace period has expired. They also provide reporting. We use a different carrier for vision and they work with the outside carrier for the vision benefits. When processing a termination, we just need to notify them that the person had vision coverage with this other provider.
Patricia
August 26th, 2009 at 1:50 pm
Are we expected to police this issue with regard to other available insurance? If a terminated employee claims he doesn’t have access to spousal insurance or it’s insufficient to cover his specific medical issues, how do we verify this? I’d be more afraid of denying the subsidy since no one knows how these issues are going to be dealt with by a court if an employee complains.
August 26th, 2009 at 1:58 pm
I don’t think we are expected to police this issue. They have to answer the question as to if they have access to “other group insurance” (which could be VA, retirement, etc.). There is no stipulation that I have found that it has to be comparable coverage. The questions are very general when asking if they have access to other group insurance. The administration probably does not have a system in place to police this though. My response to people is to keep in mind that when you are answering these questions, if you answer falsely, you could be subject to penalties and required to pay 110%.
August 26th, 2009 at 2:28 pm
SHELLY: They do every single thing. All I need to do is enter termination demographics into the website (which is better than faxing because I hated that) and they do the rest. One good thing I found out is that they are VERY strict on the timeline they give former employees to have their payments collected. If you are 1 day late, they cut your benefits off right then and there. Could that be a problem? Once in a blue moon but it’s the fault of the former employee and it takes no time for me to fix. Plus, I understand struggling to pay so it’s no biggie. We have given them the authority to add and delete coverage from our healthcare provider, that way, nothing falls between the cracks. With our former TPA, the former employee would opt for COBRA, have to send the paperwork back to them via US mail (when they got around to it), then the TPA would notify me by US Mail and it screwed up my billing because by the time all this was done, the employee would have another job and cancel. That drove me nuts!!! The only time I hear from United Healthcare is if they can’t reach a person because they can’t contact them at the address or phone number I had they call me to see if I have a cell phone number. Not sure what they do if they can’t contact but I think the send the information hoping it will be forwarded and keep the return to sender info in the file. I usually keep track what is happening with the former employee by going into the website to follow up. It couldnt’ be easier. Our fees are reasonable but at first, I had a problem with the minimum $35.00 administrative charge if you only have 1 or 3 people on the plan at $9.50 each but, it’s not a lot of money to haggle over for the convenience.
August 26th, 2009 at 2:37 pm
So true Judy, that would be sticky. I also glad to see such good information passed around about COBRA period. I have learned a lot from this thread. In reading some of the posts I empathize and sympathize with those of you who have to go this alone. My TPA has very reasonable fees and my Sr. Management didn’t need much convincing because they felf it’s a small price to pay to keep your company out of hot water.
August 26th, 2009 at 6:11 pm
I think it is possible that COBRA participants are up because the number of people laid off is up. The subsidy makes it possible for these people to retain much needed coverage. Some of the comments appear harsh; begrudging someone medical coverage when they are trying to exist on unemployment insurance seems cold. The company is not absorbing the cost of the subsidy; they are reimbursed so the costs involved would be premiums unless the company is self insured. Prior to the COBRA subsidy costly medical procedures such as organ transplant, cancer and heart surgeries did not affect our overall premiums by that much so I find it hard to believe premiums will substantially increase over the current use of COBRA. A continuation of the subsidy would not be the worst thing that could happen. These were loyal hard working employees for the most part who were caught up in a bad economy, isn’t that punishment enough?
August 28th, 2009 at 8:37 am
Roberta – I think we all understand the cost involved and aren’t blaming the people that are legitimately laid off and utilizing the COBRA subsidy. If you have not seen a significant increase in premiums due to major things such as organ transplants, cancer and heart surgeries then you are fortunate but probably in a rarity. My current company is self-funded but my previous employer was not and we saw our premiums increase every year and could directly relate it to the rise in claims based on the reports they provided to us (and knowing what some of our employees were enduring). My brother has been laid off for over 1 year and 8 months and if he did not have another source of insurance, then our family would have struggled to make sure that him and his kids had insurance coverage so I really do understand and sympathize with those in this position. I also understand that the premiums are not only increasing from the COBRA enrollees but from other external causes and current employees using the insurance. I think the frustrating thing for those of us that see both sides is that the government didn’t. They looked at this great idea for unemployed workers to get them insurance (which I agree it is nice for them) and how it effected their budgets. They just did not look at the big picture of the effect it would have on employers (which is very important too as the employers are still struggling in this economy to stay afloat and keep more people employed) – scrambling to be in compliance when DOL did not even have their letters ready for another month, educating the insurance companies to add them back on even if it was beyond the 60 days they have in their contracts, providing education or a source of complete information for COBRA administrators to read in clear language what their responsibilities are and how the impact of additional COBRA enrollees on a plan would impact the employer’s insurance rates.