What Are The Most Common Errors Of COBRA Plan Administration?

12/9/2025

The following are common COBRA management errors performed by employers and TPAs:

• Late or Incomplete Notices And Notifications:

Failure to provide timely and complete COBRA notifications to qualified beneficiaries regarding their rights to continue health coverage after a qualifying event.


• Incorrect Eligibility Determinations:

Mistakes in determining who qualifies for COBRA coverage or for how long they are eligible. This can happen due to misunderstandings of qualifying events or errors in calculating the coverage period.


• Improper Premium Calculations:

Errors in calculating the COBRA premiums, including incorrect amounts, failure to offer the appropriate payment options, or not accounting for allowable premium increases.


• Non-Compliance With COBRA Regulations:

Violating COBRA regulations regarding notice requirements, coverage duration, premium payment deadlines, and other legal obligations.


• Inadequate Recordkeeping:

Poor record-keeping practices, such as failing to maintain accurate documentation of COBRA notices sent, premium payments received, and communications with beneficiaries.


• Inadequate Training of Personnel:

Insufficient training of staff responsible for COBRA administration, leading to errors in interpreting and applying COBRA rules and regulations.


• Compliance Oversight:

Employers should regularly review their COBRA plan administration processes - especially if it "outsources" COBRA administration to a TPA (Third Party Administrator) - to ensure compliance with applicable laws and regulations.

To mitigate these errors, employers and plan administrators should invest in robust COBRA administration training, maintain meticulous records, and regularly audit their COBRA processes to ensure compliance with applicable laws and regulations.