When a former employee says a COBRA notice never arrived, courts don’t ask whether it was received. They ask whether you can prove it was sent. A recent federal decision shows what that proof looks like.

On July 23, 2026, the Department of Labor published a proposed rule that would give group health plans a new, additional way to furnish required ERISA disclosures electronically. It adds to the existing 2002 “wired at work” safe harbor rather than replacing it.

In the first article, we looked at what “carrier-provided COBRA administration” typically includes—and where gaps can occur when responsibilities are unclear or handoffs are inconsistent. Here we address two more considerations employers and brokers should weigh before making a change: carrier transitions and the real meaning of “FREE” COBRA administration. We close with a practical checklist you can use at renewal or during a carrier change.

We understand why employers ask this question—particularly fully insured employers evaluating carrier-provided COBRA administration. A carrier may offer to “handle COBRA,” and on the surface it can sound like one less vendor to manage. Before making a change, however, it is important to confirm what is included, what is not, and which responsibilities may shift back to the employer’s HR team or broker.

When it comes to COBRA administration, timing matters.

A qualifying event may seem straightforward: an employee leaves the company, loses coverage and becomes eligible for COBRA continuation coverage. But behind that event is a series of notices, election periods and payment deadlines that must be handled correctly.

For HR teams, missing a step or acting too late can create unnecessary compliance risk. And because responsibility for certain deadlines may fall on the employer, the COBRA Administrator, or the or qualified beneficiary, knowing who needs to act, and when is essential.

COBRA compliance is often viewed as a routine administrative task until an investigation or legal claim reveals costly mistakes. While there is no formal federal "COBRA audit program" that randomly reviews employers, COBRA compliance does get reviewed during broader DOL/EBSA benefit plan investigations, and it can also surface through IRS/excise tax exposure and lawsuits.

COBRA is one of those benefits that’s critically important, but widely misunderstood. For employees, it often shows up during stressful life moments like job loss or reduced hours. For employers, that confusion can quickly turn into frustration, compliance risks, and an increase of questions your HR team has to field.

COBRA administration is detail-driven, deadline-sensitive, and highly visible to participants. When it runs smoothly, it builds confidence. When it doesn’t, it creates confusion fast.

COBRA may not be glamorous, but the penalties are very real. The good news is that most costly COBRA problems come from a handful of small mistakes. Tighten these up, and you dramatically lower your risk!

As we close out the year, HR professionals managing COBRA face unique challenges—finalizing participant records, ensuring compliance, and preparing a seamless transition into the new year. At iTEDIUM, we’re committed to supporting you every step of the way. Here’s what you can do this December to ensure your COBRA administration is in top shape: