"Loss of the COBRA subsidy is not a HIPAA special enrollment event to enroll in another employer's plan mid-year. It may therefore be less costly for employees to immediately enroll in their new employer's plan or a spouse's plan because the subsequent full COBRA premium cost can outweigh the initial subsidized savings.... Employers that choose to offer COBRA subsidies should be cautious to consider the potential nondiscrimination issues that can arise, particularly under Section 105(h) for self-insured (including level funded) plans."  MORE >>