Every carrier knows what COBRA participants do to a risk pool. It's why employer census data submitted for quoting requires COBRA participants to be identified. It's why underwriters flag it. It's baked into how you price stop-loss, how you evaluate group renewals, and how you assess the overall health of a book of business.

The problem has never been awareness. Carriers have been underwriting around COBRA adverse selection for decades. The problem has been that until recently, there was no practical way to reduce it. You could price for it. You could reserve for it. But you couldn't actually influence the composition of the COBRA pool in a way that improved outcomes for everyone involved.

That's what's changed.

You're the risk bearer. Start there.

There are multiple reasons a health plan should care about COBRA adverse selection — and the conversation should start with the most direct one: your own financial exposure.

When you're underwriting stop-loss for a self-funded employer, COBRA participants represent a concentrated source of risk. These individuals generate claims at roughly three times the rate of active employees. They skew older — 33% are 55 or older compared to 21% of the active population. They carry chronic conditions at significantly higher rates. And they elect COBRA specifically because they anticipate needing care, which is the textbook definition of adverse selection.

That translates into specific stop-loss claims hitting attachment points, potential lasering of known high-cost COBRA claimants, and elevated aggregate claims experience that pushes corridor pricing higher. Poor COBRA-driven claims experience doesn't wash out in a single year either — it carries forward into renewal negotiations and impacts your book for multiple cycles.

On your fully insured book, the exposure is even more straightforward. COBRA participants pay 102% of the full premium, but when they're generating two to three times the average claims cost, that 2% admin surcharge doesn't come close to covering the gap. Every high-utilization COBRA member sitting in your risk pool is eroding your medical loss ratio in a way that's predictable, identifiable, and — with the right partner — addressable.

Reducing the number of high-cost lives that default into COBRA directly protects your underwriting performance. That's not an employer benefit story. That's your story.

Then there's the employer relationship

Beyond protecting your own book, there's a significant strategic value in helping your ASO and fully insured clients manage a cost driver they've historically had no tools to address.

For ASO clients, COBRA-driven adverse selection inflates their claims experience, drives up their stop-loss premiums, and makes renewal conversations harder than they need to be. You see it in the data. Their benefits consultants see it in the data. But when the renewal meeting happens, COBRA costs are usually treated as an inevitability — something everyone acknowledges and nobody addresses.

Now imagine bringing a proactive solution to that conversation. Not just identifying the problem, but actively reducing it. That's the kind of initiative that changes how an employer thinks about their carrier relationship. It shifts you from claims processor to cost management partner — and it makes it a lot harder for a competitor to unseat you on pricing alone when you're delivering value they aren't.

For fully insured clients, the story reinforces itself. You're protecting your loss ratios while simultaneously demonstrating to the employer that you're working to keep their renewal increases as low as possible. Both sides win, and both sides know it.

What When actually does

When is a licensed insurance broker and Healthcare.gov partner that guides departing employees through their full range of coverage options — ACA marketplace plans, Medicare for eligible individuals, spousal coverage, and Medicaid where applicable. These alternatives often cost 40-60% less than COBRA premiums, which means the individuals who transition get better-fit coverage at lower cost while the employer's plan sheds the high-utilization lives it was never designed to carry long-term.

The mechanics matter here. At the point of COBRA election, departing employees are introduced to When's AI-powered marketplace, Jamie, which walks them through their options in a conversational format. For those who need more support, When provides concierge service from licensed agents who help them compare plans, understand subsidies, and complete enrollment. When handles all broker licensing and carrier appointments — there's no regulatory burden pushed to the health plan.

Critically, When doesn't just work with new terminations. The platform also reaches existing COBRA participants — the people already on your clients' plans generating disproportionate claims right now. For a carrier underwriting stop-loss on a self-funded group, or managing MLR on a fully insured group, that means immediate impact on the current population, not just a forward-looking improvement.

Embed it. Don't bolt it on.

Here's where the model gets particularly compelling for health plans: When can sit inside your existing cost structure rather than being something your employer groups have to adopt separately.

Instead of asking each employer client to evaluate, budget for, and implement a COBRA alternative on their own, you embed When into your ASO fee structure or your fully insured premiums. The employer gets the benefit automatically. You move the needle across your entire book without putting the adoption burden on each individual group.

This is the difference between a point solution that a handful of your most sophisticated clients might pursue and a platform-level capability that improves outcomes across your portfolio. It becomes part of how you do business, not an optional add-on that requires employer-by-employer evangelism.

You've always known the problem. Now deliver the solution.

Carriers have been pricing for COBRA adverse selection for as long as COBRA has existed. The census data, the claims analysis, the underwriting adjustments — it's all been there. What hasn't been there is a practical, scalable way to actually change the outcome.

When provides that. It protects your underwriting performance on stop-loss and fully insured business. It strengthens your employer relationships by addressing a cost driver nobody else is solving. It embeds into your existing cost structure so adoption scales across your book. And it positions you as the carrier that doesn't just identify risk — you actively manage it.

The employers who understand COBRA's impact on their health plan costs are already looking for solutions. The question is whether they find it through you or through someone else.

Connect with When's partnership team to explore how the model works inside your cost structure.