If you run a COBRA administration business, you already know the uncomfortable truth: the service you provide is increasingly commoditized, and the revenue model you depend on is under pressure from every direction.

Employers are waking up to the real cost of COBRA. Benefits consultants are advising clients to explore alternatives. TPAs with broader service portfolios are bundling COBRA admin into larger deals and squeezing standalone providers out. And the individuals electing COBRA? Many of them are doing it because they don't know how to evaluate their options — not because it's actually the best choice.

None of this means COBRA administration is going away. But it does mean that the administrators who survive and grow will be the ones who evolve from compliance processors into something more valuable: strategic partners who help employers manage post-employment healthcare costs.

That evolution is exactly what a partnership with When enables.

The revenue problem nobody wants to talk about

COBRA administration revenue is directly tied to participation rates. More people elect COBRA, more premiums flow through, more admin fees get collected. The math is simple.

The problem is that this creates a fundamental misalignment with your employer clients. They want fewer people on COBRA — because COBRA participants, particularly for self-funded employers, generate two to three times the claims costs of active employees. Every person who stays on COBRA when a marketplace plan or other suitable coverage would serve them better is driving up the employer's claims experience, inflating renewals, and increasing stop-loss exposure.

So your employer clients are asking you to help them reduce COBRA costs while your business model depends on COBRA enrollment staying high. That tension is sustainable until it isn't. And increasingly, it isn't.

Employers are starting to look for solutions that actively guide departing employees toward coverage alternatives. If that solution doesn't come from you, it will come from someone else — a benefits TPA adding it to their bundle, a consultant recommending a direct relationship, or an employer going direct to the marketplace themselves.

The question isn't whether COBRA participation rates will decline. It's whether you'll be the one driving that conversation or reacting to it.

What changes with When

When is a licensed insurance broker and Healthcare.gov partner that helps departing employees navigate their full range of coverage options — not just COBRA, but ACA marketplace plans, Medicare for eligible individuals, and other alternatives that often cost 40-60% less than COBRA premiums.

For COBRA administrators, partnering with When does three things that matter.

First, it replaces any declining COBRA revenue with a new income stream. When partners with COBRA administrators  through a revenue share model based on the same PEPM structure you're already familiar with. For every employee enrolled in a COBRA-eligible benefit, When shares a portion of that PEPM with you as the partner. This creates a new revenue stream on top of your existing COBRA administration fees.

This isn't about steering employees away from COBRA—it's about ensuring they end up in the coverage that's actually right for them. Many employees would be better served by a marketplace plan than by paying COBRA premiums for coverage they don't need. When they make that choice with proper guidance, everyone benefits—including you.

Second, it transforms your client relationship. Right now, most employer clients see COBRA administration as a necessary compliance function. It's important, but it's not strategic. When you bring a solution that actively reduces employer healthcare costs — a solution backed by data showing how adverse selection from COBRA participants inflates claims — you're no longer a vendor processing paperwork. You're a partner helping them manage risk. That's a fundamentally different conversation, and it changes how defensible your position is when the next RFP comes around.

Third, it addresses a population that nobody else is serving. Most COBRA alternative solutions only work for new terminations. When also provides outreach to existing COBRA participants — the people already on your rolls who may not realize they have better options. That means immediate impact for your employer clients, not just forward-looking improvements.

How it works in practice

The partnership model is designed to be operationally light for COBRA administrators. When handles the licensed broker work, carrier appointments, and enrollment compliance. You're not adding headcount or regulatory burden.

At the point of COBRA election, departing employees are introduced to When's AI-powered marketplace, Jamie, which walks them through their coverage options in a conversational format. For those who need more support, When provides white-glove concierge service — a real person who helps them compare plans, understand subsidies, and enroll.

The experience can be co-branded so it feels like a seamless extension of your service, not a handoff to a third party. Your employer clients see you as the provider of this capability. The departing employee gets better guidance than they've ever had during a stressful transition. For your existing COBRA population, When can conduct outreach to active participants who may benefit from switching to marketplace coverage. This is particularly powerful for self-funded employer clients who are feeling the claims impact of high-utilization COBRA members right now and can't wait 18 months for natural attrition to solve the problem.

Leading the conversation

The COBRA administration market is at an inflection point. Employers increasingly understand that high COBRA take rates aren't just an administrative issue — they're a cost issue. The administrators who get ahead of this shift will be the ones who bring solutions rather than waiting for clients to find them elsewhere.

Partnering with When positions you to lead that conversation. You keep your compliance expertise and your client relationships. You add a revenue stream that actually grows as the market evolves. And you move from being a cost line on your client's benefits budget to being a strategic partner who demonstrably reduces their healthcare spend.

The alternative is waiting for someone else to make the introduction — a competitor, a consultant, or the employer's own research. By then, you're not leading the conversation. You're defending your relevance in it.

If you're a COBRA administrator exploring how to evolve your service model, reach out to When's partnership team to start the conversation.