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COBRA and Billing Services: 10 Providers Compared

COBRA and billing services compared: 10 administrators, what PEPM and per-notice fees really cost, and the 20-employee rule that decides if you need one.

Nick Anisimov

Nick Anisimov

FirstHR Founder

Benefits
20 min

COBRA and Billing Services: 10 Providers Compared

What the category actually covers, the 20-employee test that decides whether you are subject to it at all, the fee lines vendors leave out of a verbal quote, and honest notes on ten administrators from dedicated specialists to payroll platforms

Search for COBRA and billing services and you do not get a buying guide. You get vendor pages, because the phrase is a product name rather than a category label. WEX and several other administrators sell a bundle called exactly that, so the results are mostly service descriptions and participant login portals written for people who already made a decision.

What the phrase actually describes is two jobs sold together. COBRA administration is the compliance work triggered when someone loses coverage: notices on federal deadlines, election tracking, premium collection, carrier updates. Billing services, usually labeled direct bill or retiree billing, is the same premium collection for people off active payroll for other reasons. The mechanics overlap enough that almost nobody sells them separately.

This comparison covers ten providers a US business can realistically buy from, the fee lines that decide your actual bill, what the category costs at 10, 25, and 50 employees, and the question that comes before all of it: whether federal COBRA applies to you at all. For a business under 20 people, frequently it does not, and the answer is a different and cheaper obligation.

TL;DR
COBRA and billing services bundle COBRA compliance with premium collection from people off payroll. Federal COBRA applies at 20 or more employees, counting part-timers as fractions; below that, state mini-COBRA usually applies instead. Anuvi publishes rates from $1 per employee monthly with no minimum, and Gusto charges $30 per company monthly or nothing if it brokers your benefits. Almost everyone else is quote-only, and the monthly minimum matters more than the PEPM rate at small headcount. Outsourcing does not move the legal liability off the employer.

What COBRA and billing services actually covers

The bundle contains one legal obligation and one operational convenience, and it is worth knowing which half you are buying. COBRA carries federal deadlines and penalties. Direct billing does not carry an equivalent statutory framework; it is simply the job of collecting money from someone your payroll system no longer deducts from.

Definition
COBRA and billing services
A bundled outsourcing service combining COBRA continuation administration with premium billing for people who are not on active payroll. COBRA administration covers the initial rights notice, qualifying-event and election notices, election tracking, premium collection and remittance, carrier eligibility updates, and termination for non-payment. Billing services covers the same collection work for retirees, employees on unpaid leave, and other direct-bill populations. Also sold as COBRA administration services, COBRA and direct bill, continuation services, or benefit continuation administration.
ComponentWhat the administrator doesWho needs it
Initial rights noticeSends the general COBRA notice when someone joins the planEvery employer subject to federal COBRA
Qualifying event and election noticeSends the election notice on the federal deadline after a termination, hours reduction, divorce, death, or dependent aging outEvery employer subject to federal COBRA
Election trackingTracks the 60-day election window and the 45-day first-payment windowAnyone with turnover in a benefits-eligible role
Premium collection and remittanceCollects from the participant and sends funds back to the employer or carrierAnyone who does not want to invoice former employees by hand
Carrier coordinationNotifies carriers of adds, changes, and terminationsMulti-carrier plans, where mismatches surface as denied claims
State continuationAdministers mini-COBRA where federal COBRA does not applyEmployers under 20 employees in a state with a continuation law
Direct and retiree billingCollects premiums from retirees and employees on unpaid leaveAnyone with a leave, sabbatical, or retiree population
RecordkeepingRetains proof of what was mailed and whenEveryone, because proof of mailing is the usual defense in a dispute
Two unrelated products share the name
Searches for COBRA software also return Deltek Cobra, a project cost and earned value management product with no connection to health benefits. Several AI-generated listicles in this category mix the two and end up recommending project management tools to employers shopping for continuation coverage. If a comparison page lists scheduling software next to benefits administrators, it was not written by anyone who understands the category.

Do you have to offer COBRA at all?

This question comes before vendor selection and a surprising number of buying guides skip it. Federal COBRA applies to employers that had 20 or more employees on more than half their typical business days in the previous calendar year, per the U.S. Department of Labor. Below that line you are not subject to it.

The counting rule catches people out. Both full-time and part-time employees count, with each part-timer counted as a fraction equal to their hours divided by full-time hours. A company with 16 full-time staff and eight people at 20 hours a week is at 20 and subject to COBRA. Because the test looks back at the prior calendar year, crossing the line in one year creates the obligation for the next.

What the coverage looks like once it applies
Continuation coverage runs 18 months for termination or reduced hours and 36 months for most other qualifying events, with a possible 11-month disability extension to 29 months. The plan may charge the qualified beneficiary up to 102 percent of the plan cost, or up to 150 percent during the disability extension, per the Department of Labor employer guide. That 2 percent is the administrative surcharge most administrators keep as part of their fee.

Being under 20 employees does not mean no obligation. Around 40 states have mini-COBRA or state continuation laws creating similar rights at smaller employers, with shorter durations and different deadlines. Texas, for example, historically ran a six-month state continuation period against the federal 18. For a company of 5 to 50 people this is often the rule that actually governs, and it is the part most national guides handle worst. Several administrators on this page cover state continuation; at least one does not.

Your situationWhat appliesWhat to buy
20 or more employees last year, group health planFederal COBRAFull COBRA administration
Under 20 employees, state has continuation lawState mini-COBRA onlyAn administrator that covers your state, or handle it with your carrier
Under 20 employees, no state law appliesNo continuation obligationNothing, until headcount crosses the line
Crossed 20 employees this yearFederal COBRA starting next calendar yearLine up an administrator before January, not after the first termination
Staff on unpaid leave with coverage continuingNo COBRA, but premiums still need collectingDirect billing only, which is a smaller purchase
Retirees on a post-employment planRetiree billingRetiree billing, usually sold with direct bill

One more distinction worth drawing before you shop. If your real problem is that two people on unpaid leave still owe premiums and nobody is invoicing them, you need billing services and not COBRA administration. That is a materially smaller and cheaper purchase, and buying the full compliance bundle to solve it is overkill.

The fee schedule nobody publishes

Almost every vendor in this category quotes a per-employee-per-month rate and stops there. The PEPM rate is rarely what you pay. At small headcount the monthly minimum sets the price, and the per-event charges set the variance.

FeeWhat it isWhy it matters at your size
Base administration feePer benefit-eligible employee per month (PEPM), or per participant per monthThe headline number. Note whether it counts every benefit-eligible employee or only enrolled COBRA participants, because the two differ by an order of magnitude
Monthly minimumA floor that applies when your PEPM total falls below itThis is what actually sets the price for a small employer. A $50 floor at 12 eligible employees is roughly $4 per employee, not the quoted rate
Implementation or setupOne-time charge to build the plan in the vendor systemSome vendors waive it. Ask in writing, because it is the fee most often omitted from a verbal quote
TakeoverMoving existing COBRA participants from a prior administratorSeveral vendors waive this to win the business. If yours does not, it can make switching cost more than a year of service
Per-notice and per-eventMailing initial rights notices, election notices, rate changes, terminationsPay-as-you-go plans are built almost entirely from these. They can be cheaper at low turnover and much more expensive at high turnover
Returned payment and reinstatementFailed ACH, bounced check, reinstating a terminated participantSmall individually, but they land in the months when a participant is already causing work
The 2 percent surchargeFederal law lets the plan charge up to 102 percent of the plan costMost administrators keep this. It is paid by the participant, not by you, and it partly funds the service
Fee categories compiled from vendor proposal documents and service descriptions published by administrators in this comparison, August 2026. Not every vendor charges every line. The point is to ask about each one by name before signing, because a PEPM rate alone does not describe what you will pay.
Ask which population the PEPM counts
The same number means very different things depending on the base. Some administrators invoice per benefit-eligible employee, so a 30-person company pays on 30. Others invoice per active COBRA participant, so the same company might pay on one or two. Ameriflex, for instance, documents that it invoices on employees enrolled in the group health plan and includes outside dental and vision carriers at no extra charge. Get the base and the minimum in writing before comparing any two quotes, because otherwise you are comparing numbers that measure different things.

10 COBRA and billing providers at a glance

The table covers both groups: dedicated administrators that do this and adjacent compliance work, and payroll platforms that bundle COBRA into a broader package. The columns are the ones that actually differ, since the notice-and-collect workflow is close to identical everywhere.

ProviderTypePricing modelState continuationRetiree or direct billPublic priceMinimum group
CobraHelpDedicated administratorPEPM or pay-as-you-goNone stated
AnuviDedicated administratorFrom $1 PEPMNone stated
TASCDedicated administratorPEPM, multi-year term1 eligible
WEXDedicated administratorPEPM or monthly minimumNot published
Benefit ResourceDedicated administratorQuote onlyNot published
AmeriflexDedicated administratorPer enrolled employee20 participants
BASICDedicated administratorQuote only20 eligible
GustoPayroll platform$0 or $30 per companyNone stated
PaychexPayroll platformBundled or standaloneNone stated
ADPPayroll platformQuote onlyNot published
State continuation marks whether the provider administers state mini-COBRA alongside federal COBRA. Retiree or direct bill marks premium collection from people who are not on active payroll, such as retirees and staff on leave. Public price marks a rate the vendor publishes without a sales call. Minimum group reflects what each vendor or its listing states; None stated means no minimum was published, not a guarantee that none applies. Verified August 2026; confirm current terms directly, since most of this category is quote-only and terms change.

How we evaluated these providers

Feature lists in this category are nearly interchangeable, because federal law defines the work. We applied four tests instead, weighted toward what a US employer of 5 to 50 employees without a dedicated HR person needs.

Will they sell to a small employer?
Documented minimums were recorded and stated plainly. BASIC is listed at a 20-eligible entry point and Ameriflex documents tailored pricing for groups of 20 or more participants, while TASC lists a minimum group size of one. A vendor a 12-person company cannot buy does not belong on its shortlist, however good the service is.
Do they administer state continuation?
For an employer under the 20-employee federal threshold, mini-COBRA is the actual obligation, so a federal-only service solves nothing. Most providers here cover both. Ameriflex materials state its COBRA service does not include state continuation, which is a meaningful exclusion for this audience even though it does not affect larger employers at all.
Can you learn the price without a sales call?
Two of the ten publish a rate: Anuvi from $1 per employee per month, and Gusto at $30 per company per month or nothing when Gusto brokers the benefits. Everyone else quotes. That is normal for this category, but pricing opacity is a real cost when the evaluation is being run by someone doing three other jobs.
What is genuinely missing or restricted?
Every provider carries a cons block naming specific limits: minimums, exclusions, bundling requirements, or the absence of published pricing. We did not rate service quality, because this category has no comparable review base at meaningful volume and vendor-supplied testimonials are not evidence.
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Dedicated COBRA and billing administrators

These providers do continuation coverage as a core business, usually alongside pre-tax accounts and other compliance services. If COBRA is your only problem and you do not want it tied to a payroll contract, start here.

CobraHelp
Best specialist for small employers with no published minimum
Pricing: Quote only; two packages offered, structured as PEPM or pay-as-you-goCovers: Federal COBRA, state continuation, retiree billingBest for: Small and mid-sized employers who want a specialist rather than a module

CobraHelp was founded in Denver in 1984 as an insurance brokerage and pivoted to COBRA administration when the law took effect in 1986, which makes it close to as old as the obligation itself. It does continuation coverage and nothing else, and the positioning shows: dedicated account managers rather than a call center, notices tailored to your plan structure, and transfer of existing participants from a prior administrator at no added cost.

Two things make it a reasonable default for this audience. The pay-as-you-go option prices the service around events rather than headcount, which suits a company with low turnover and a handful of benefits-eligible staff. And it administers state continuation, including for employers below the federal threshold, which several larger platforms treat as an afterthought. The trade-off is that everything is quoted, and a narrow specialist means one more vendor relationship if you also want pre-tax account administration.

Pros
No published minimum group size, unusual among dedicated administrators
Pay-as-you-go pricing suits low-turnover small employers
Administers state continuation as well as federal COBRA
Takeover of existing participants at no added cost
Dedicated account managers rather than a general support line
Cons
No published pricing; every engagement is quoted
COBRA-only scope means a separate vendor for FSA, HRA, or HSA administration
Smaller organization than the platform players, with less integration breadth
No self-serve signup or trial to evaluate before committing
Anuvi
Best for published per-employee pricing with no minimum
Pricing: From $1 per employee per month, no implementation fee, no monthly minimumCovers: Federal COBRA and state continuation; carrier enrollment confirmationBest for: Small employers who want a knowable price and fast setup

Anuvi is the newest name here and the only one that publishes a rate you can act on: from $1 per employee per month, with no implementation fees and no monthly minimums, and a stated 96 percent of new groups fully operational within one day of contract signature. It is also the administrator running COBRA behind Gusto, so a large number of small businesses already use it without knowing the name.

The product is built around the parts of COBRA that go wrong: next-day electronic notification instead of mail-only, mobile-first election and payment for participants, and explicit confirmation of adds, changes, and deletions with the carrier rather than assuming the file landed. It integrates with common small business HR platforms to pull employee data nightly. The honest caveat is track record: it is a younger operation than the administrators that have been doing this since the 1980s, and in a category where the value is proof of compliance over years, that is a real consideration rather than a formality.

Pros
Published pricing from $1 per employee per month
No implementation fees and no monthly minimums
Setup measured in days rather than weeks
Carrier enrollments confirmed rather than assumed
Nightly data sync with common HR platforms
Cons
Shorter operating history than the long-established administrators
Narrow scope; no pre-tax account or broader compliance administration
Smaller integration and carrier footprint than the large platforms
Published rate is a starting point, so confirm your quote in writing
TASC
Best for groups down to a single eligible employee
Pricing: Quote only; base price quoted per year on a three-year term, with discounts of 10 to 20 percent for bundling multiple productsCovers: Federal COBRA, state continuation, retiree billing, direct billingBest for: Employers who want continuation plus pre-tax accounts from one administrator

Total Administrative Services Corporation was founded in 1975 in Madison, Wisconsin and describes itself as the largest privately held third-party benefits administrator in the country, serving close to 80,000 employers. Continuation services sit on MyTASC alongside more than 50 other benefit account types, which is the pitch: one portal, one app, one card for COBRA, FSA, HSA, ICHRA, and the rest.

Its listed minimum group size of one eligible employee is the most permissive on this page, which matters because several competitors quietly exclude companies this size. TASC also retains the 2 percent administrative surcharge where state law permits, which is standard practice worth knowing. The structural trade-off is commitment: pricing is quoted against a multi-year term with bundling discounts, so the cheapest configuration is the one where you consolidate several services and stay put. That is good value if you want consolidation and expensive optionality if you do not.

Pros
Listed minimum group size of one eligible employee
Covers COBRA, state continuation, retiree billing, and direct billing
Single platform for continuation and more than 50 benefit account types
Long operating history and very large employer base
Cons
Pricing quoted against a multi-year term rather than month to month
Best rates require bundling several services together
No published pricing for COBRA as a standalone service
Retains the 2 percent participant surcharge, as most administrators do
WEX
Best for integration breadth across carriers and payroll systems
Pricing: Quote only; PEPM fee or monthly minimum, with no separate implementation, renewal, or takeover chargesCovers: COBRA, direct bill, retiree billing, premium reconciliationBest for: Employers with multiple carriers or an existing HRIS to integrate

WEX is the company whose product naming created this search term, and it is the largest operation on the page. It reports more than 25 years administering COBRA, integrations with over 350 payroll, HRIS, and benefits administration partners and more than 225 insurance carriers, and more than 330 carrier connections using EDI 834 files to update eligibility automatically. Employers work in the LEAP portal; participants get a COBRA and direct bill mobile app with one-time ACH, recurring ACH, check, and card payment options.

The commercially useful detail is what the fee does not include. WEX states that customers pay the PEPM fee or the monthly minimum with no additional charges for implementation, renewal, member paperwork, carrier notifications, or takeover from a prior administrator. In a category where per-event fees are how quotes drift upward, that is a genuine simplification. Two caveats: nothing is published, so the PEPM and the minimum are both unknown until you ask, and WEX has been consolidating acquired brands including Chard Snyder and UnifyHR onto its platform, so employers arriving through those relationships have been going through a migration.

Pros
No implementation, renewal, takeover, or carrier notification fees on top of PEPM
Broadest carrier and payroll integration footprint in this comparison
Automated eligibility updates to carriers via EDI file feeds
Participant mobile app with four premium payment methods
Cons
No published pricing; both the PEPM and the minimum require a quote
Ongoing platform migration for employers from acquired brands
Scale means less personal account handling than a boutique administrator
Participant reviews cite payment convenience fees, which land on former employees
Benefit Resource
Best for COBRA bundled with pre-tax benefit accounts
Pricing: Quote onlyCovers: COBRA, direct billing, FSA, HRA, HSA, commuter benefitsBest for: Employers consolidating continuation and pre-tax accounts with one vendor

Benefit Resource, usually written BRI, was founded in 1993 in Rochester, New York and has administered COBRA for more than 15 years alongside its pre-tax account business. Employers get a single BRIWEB login covering both, with single sign-on into the COBRA and direct bill management portal, an assigned account manager, and phone support from 8am to 8pm Eastern. Participants get a portal and a mobile app for one-time or recurring premium payments.

Its client range runs from small businesses to Fortune 100 companies, which cuts both ways: the platform is proven at scale, and a 15-person employer is not the center of the product. The clearest reason to pick BRI is consolidation. If you already want tax-advantaged account administration and continuation coverage handled together, running both through one account manager removes a coordination problem that otherwise surfaces every time a participant elects COBRA for a plan tied to an FSA or HRA.

Pros
Single login and account manager for COBRA and pre-tax accounts
Participant mobile app with recurring payment support
More than three decades in benefits administration
Extended support hours compared with most administrators here
Cons
No published pricing
Small employers are not the primary segment
Value case weakens if you do not also want pre-tax account administration
No self-serve evaluation path before a sales conversation
Ameriflex
Best for employers who want contractual indemnification
Pricing: Quote only; invoiced on employees enrolled in the group health plan, with tailored pricing documented for groups of 20 or more participantsCovers: Federal COBRA; retiree and individual billing sold separatelyBest for: Employers of 20 or more who want risk transfer written into the contract

Ameriflex reports more than 20 years in COBRA administration and leads with risk rather than features: it states that employers are held harmless for any negligence on its part, backs the service with an in-house compliance team and an ERISA attorney, and commits to responding to client emails in under six hours. Notices go out the day after it receives employee data, which starts the 60-day election clock as early as possible. It is a named COBRA partner for Aetna and a preferred partner for Humana.

Two limits matter for a small employer. Ameriflex materials state that its COBRA service does not include state continuation, so an employer below the federal 20-employee threshold governed by mini-COBRA is not served by the core product. And its published pricing structure is documented for groups of 20 or more participants. Both restrictions point the same direction: this is a strong option once federal COBRA clearly applies to you, and the wrong shape before that.

Pros
Contractual indemnification against administrator negligence
In-house compliance team and ERISA attorney supporting the service
Notices issued the day after employee data is received
Invoices include outside dental and vision carriers at no extra charge
Stated six-hour response commitment on client email
Cons
Materials state state continuation is not included in the COBRA service
Pricing documented for groups of 20 or more participants
Retiree and individual billing sold as a separate service
No published pricing
BASIC
Best single platform for COBRA, state continuation, and retiree billing
Pricing: Quote onlyCovers: COBRA, state continuation, retiree billing, direct billing, FSA, HRA, HSA, FMLA, ACA reportingBest for: Employers of 20 or more consolidating several compliance obligations

BASIC was founded in 1989 in Portage, Michigan, has more than 35 years in benefits administration, and supports over 15,000 employers across FSA, HSA, HRA, COBRA, ACA reporting, ERISA services, and FMLA administration. Its Consumer Driven Accounts platform combines COBRA, state continuation, and retiree billing with active benefit accounts behind a single sign-on, which removes the usual annoyance of switching systems mid-task.

The participant side is unusually well built for this category: a single app covers all BASIC accounts and COBRA plans, and participants can pay premiums from a MyCash balance, by card, or on autopay. The constraint is the entry point. BASIC is listed at a minimum of 20 eligible employees, which excludes a meaningful share of the businesses reading a page like this. If you are above that line and want one vendor covering several compliance obligations rather than four, it is a strong consolidation play.

Pros
COBRA, state continuation, and retiree billing on one platform
Single sign-on across active benefits and continuation
Participant app with autopay and multiple payment methods
Broad compliance coverage including ACA reporting and FMLA
Cons
Listed minimum of 20 eligible employees excludes smaller teams
No published pricing
Breadth means a longer implementation than a COBRA-only specialist
Consolidation value is limited if you only need continuation coverage
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Payroll platforms that bundle COBRA

The qualifying event that starts COBRA is almost always a termination, and terminations are already recorded in payroll. That adjacency is the entire argument for buying COBRA from your payroll provider: one less file transfer, one less place for a date to be wrong.

Gusto
Best for small businesses already running payroll on Gusto
Pricing: No separate charge when Gusto brokers your health benefits; $30 per company monthly with the broker integrationCovers: Federal COBRA and state continuation, administered by AnuviBest for: Companies of 5 to 50 already using Gusto for payroll and benefits

Gusto has the cleanest commercial terms in this comparison, which is rare enough to note. If Gusto brokers your health benefits, COBRA administration is included at no additional cost and you are onboarded automatically. If you keep your own broker and use the broker integration, it is $30 per company per month, flat, regardless of headcount. Anuvi does the administration; Gusto syncs employee and eligibility data daily and election notices go out two to three days after a qualifying event.

For a business of 5 to 50 this is frequently the cheapest correct answer, and the flat structure means the cost does not move as you hire. The real cost is elsewhere. COBRA here is a consequence of a payroll and benefits decision, not an independent one: the broker integration itself runs $6 per eligible employee per month on top, and switching payroll later means switching COBRA administrator too. If your benefits administration is going to sit somewhere else, the bundle argument weakens considerably.

Pros
Published, flat pricing that does not scale with headcount
No separate COBRA cost when Gusto brokers your benefits
Covers state continuation as well as federal COBRA
Termination data flows from payroll without a manual file
Daily eligibility sync with the administrator
Cons
Requires Gusto payroll, so not available as a standalone service
Broker integration adds $6 per eligible employee monthly on top
Switching payroll later forces a COBRA administrator change
Administration is delivered by a partner, adding a party to any dispute
Paychex
Best bundled into a broader small business HR package
Pricing: Quote only; included in HR Pro, HR Partner, and PEO packages, also sold standaloneCovers: Federal COBRA and state continuationBest for: Employers who want HR support and COBRA from the same provider

Paychex added COBRA administration in 2006 and has run it as a small and mid-sized business service since. It sets up and maintains both federal COBRA and state continuation programs, sends notices, collects participant payments and reimburses the employer twice monthly, and runs a toll-free line that both employers and participants can call. Optionally it will track terminations from payroll and send you a reminder.

The distinguishing feature is packaging rather than product. COBRA is included in HR Pro, HR Partner, and the PEO offering, which means the buying decision is usually about the HR package, with COBRA arriving as one line among many. That is efficient if you want the package and opaque if you do not, because there is no published standalone rate to compare against a dedicated administrator. Paychex does sell it standalone if the underlying group health plan exists.

Pros
Included in several existing HR packages at no separate line item
Handles federal COBRA and state continuation
Optional termination tracking pulled from payroll
Toll-free support for both employers and participants
Cons
No published pricing, standalone or bundled
Hard to compare against a dedicated administrator quote
Best value assumes you want the wider HR package
Employer reimbursement runs twice monthly rather than continuously
ADP
Best for organizations standardized on ADP payroll and HR
Pricing: Quote onlyCovers: COBRA administration integrated with ADP payroll and benefits; marketplace partners availableBest for: Companies already running ADP that want one vendor and one audit trail

ADP offers COBRA services alongside its payroll and benefits administration, with event triggers coming from terminations and hours reductions recorded in the platform, model notices, and an audit trail attached to the same employee record. For an organization already standardized on ADP, that continuity is the argument: fewer file transfers, fewer timing errors, one place to look when someone asks what was sent and when.

Two things to check before assuming it is included. ADP is a large portfolio rather than one product, and the COBRA offering varies by which platform and service tier you hold; ADP Insurance Agency states plainly that it does not handle COBRA administration itself and will connect you with a partner. Several third-party administrators, including Benefit Resource, also distribute through ADP Marketplace rather than being native ADP services. Confirm in writing who the actual administrator is, because that determines who is accountable when a notice is late.

Pros
Event triggers come straight from payroll terminations and hours changes
Single audit trail alongside the employee record
Marketplace partners available where the native service is not the right fit
Built for scale and for organizations with formal compliance reporting
Cons
No published pricing
Offering varies by ADP platform and service tier
The insurance agency arm does not administer COBRA and refers to partners
More platform than a company of 15 needs for continuation coverage alone

What COBRA administration costs at 10, 25, and 50 employees

The table below models monthly administration cost at three small-company sizes. It is deliberately sparse, because most of this category does not publish rates, and a table full of invented numbers would be worse than an honest one full of the word quote.

OptionPricing model10 employees25 employees50 employeesNotes
Gusto, benefits brokered by GustoIncluded in the planIncludedIncludedIncludedNo separate COBRA charge; you pay for payroll and the insurance premiums
Gusto, broker integrationFlat per company$30$30$30Plus $6 per eligible employee monthly for the broker integration itself
Anuvi, directFrom $1 PEPMFrom $10From $25From $50States no implementation fees and no monthly minimums
Typical dedicated administratorPEPM plus a floorFloorFloor to PEPMPEPMBroker guidance puts small-group PEPM near $1 with minimums often around $50
Paychex, ADPBundled or quotedQuoteQuoteQuotePriced inside an HR or payroll package rather than as a standalone line
Ameriflex, BASICQuote onlyNot availableQuoteQuoteBoth are documented at a 20-participant or 20-eligible entry point
Monthly administration cost only, verified August 2026, excluding insurance premiums, per-notice charges, and add-on services. Employee counts refer to benefit-eligible employees, which is how most administrators invoice, not to COBRA participants. Rows marked Quote reflect vendors that publish no rate. The typical-administrator row is broker and industry guidance rather than a vendor quote, and your own number will depend on headcount, plan count, and turnover.

Two observations. First, the absolute numbers are small relative to the risk being managed: a service in the range of tens of dollars a month sits against penalty exposure measured in hundreds of dollars per day. Second, at 10 to 25 employees the monthly minimum, not the PEPM rate, is what you are buying, which is why the two vendors that publish flat or minimum-free pricing look disproportionately good at this size and unremarkable at 500 employees.

Price against your turnover, not just your headcount
A 30-person company that loses two benefits-eligible people a year and a 30-person company that loses twelve are different customers, even though the PEPM quote is identical. Pay-as-you-go pricing favors the first; flat and PEPM pricing favors the second. Before you collect quotes, count how many qualifying events you actually had over the last two years, including hours reductions and dependents aging off the plan, not just terminations. That number changes which pricing model wins.

Outsourcing does not move the liability

This is the most important thing on the page and the thing vendor content is least eager to say clearly. Under ERISA, the plan administrator is whoever the plan document designates, and where the document designates nobody, it is the plan sponsor, which is normally you. Contracting a third-party administrator to perform the work does not change who the statute holds responsible. ADP states the same in its own compliance guidance: employers remain responsible for benefits compliance even when using brokers, third-party administrators, or payroll providers.

ExposureAmountSource
ERISA notice penaltyUp to $110 per day per affected participantERISA section 502(c)(1), assessed by a federal court
IRS excise tax$100 per day per qualified beneficiary, $200 per day if more than one family member is affectedInternal Revenue Code section 4980B, self-reported on Form 8928
Excise tax floor after auditMinimum $2,500 where the failure is discovered on examinationInternal Revenue Code section 4980B
Excise tax cap, unintentional failuresLesser of 10 percent of prior-year group health spend or $500,000Internal Revenue Code section 4980B
Correction windowExcise tax generally does not apply to failures corrected within 30 days of discoveryInternal Revenue Code section 4980B
Medical claims liabilityUnbounded; the cost of claims a beneficiary incurred while wrongly uncoveredCivil litigation, plus attorney fees

The last row is the one that should shape your decision. Statutory penalties are capped; a serious claim incurred by someone who should have had coverage is not. What a good administrator buys you is not immunity but evidence: proof of what was mailed, on what date, to what address. Some vendors go further and offer contractual indemnification against their own negligence, which is worth asking about by name, but indemnification is a private contract between you and the vendor and it does not bind the IRS or a court.

The practical implication is that your side of the workflow still matters. The administrator can only act on the qualifying event once you report it, so the gap between someone's last day and the date that reaches your vendor is your exposure, not theirs. That makes a reliable offboarding process part of the compliance chain rather than an administrative nicety.

Before you choose

FirstHR does not administer COBRA. It does not send election notices, collect premiums, or remit to carriers, and nothing on this page should be read as suggesting otherwise: for continuation coverage you need one of the administrators above or an equivalent. What FirstHR does is the layer that feeds them, as an HR platform for US teams of 5 to 50 covering employee records, offboarding workflows, document management, and e-signature at a flat $98 to $198 per month.

That distinction matters for one specific reader: the employer under 20 people who arrived here assuming they needed a COBRA vendor and discovered they are governed by state continuation instead. If your actual problem is that terminations are tracked in three places and nobody is certain when someone's last day of coverage was, a COBRA administrator does not fix that, because it can only act on what you report to it.

How to choose a COBRA and billing provider

Five questions settle this faster than any feature grid, and the first two eliminate most of the market before you take a call.

Are you subject to federal COBRA, state continuation, or neither?
Count last year: 20 or more employees on more than half your typical business days, with part-timers counted as fractions of full-time. Above the line, you need federal COBRA administration. Below it, check your state continuation law, because roughly 40 states have one and not every administrator covers them. This single question determines whether half the vendors on this page are even relevant to you.
What is the monthly minimum, and what population does the PEPM count?
Ask both in the first email. At 10 to 30 benefit-eligible employees the minimum is what you pay, so a low PEPM with a high floor is worse than the reverse. Then confirm whether the rate counts benefit-eligible employees or active COBRA participants, because the same number produces bills that differ by a factor of ten depending on the base.
Which fees exist beyond the base rate?
Name them individually: implementation, takeover from your current administrator, per-notice mailing, rate change notices, returned payments, reinstatements, and renewal. WEX states it charges none of these on top of PEPM; other vendors build entire pay-as-you-go plans from them. A quote that answers only the PEPM question is not yet a quote.
How many qualifying events did you actually have last year?
Count terminations, hours reductions below the eligibility threshold, divorces reported to you, and dependents aging off the plan. Low event volume favors pay-as-you-go pricing; steady volume favors flat or PEPM. Most employers guess this number badly in the direction that costs them money, because they remember terminations and forget everything else.
Who reports the qualifying event, and how fast?
The administrator cannot start the clock until it knows. Map the path from a manager saying someone is leaving to the vendor receiving the date, and count the days. If that path involves remembering to send an email, it will fail eventually. Bundled payroll options shorten it structurally, which is often worth more than a better PEPM rate.

A closing note on sequencing: before you sign anything, ask your prospective administrator to walk through a real qualifying event from your last year and tell you exactly which notices would have gone out, on which dates. Vendors that answer that question precisely are the ones you want. It costs nothing and it predicts the relationship better than any feature list.

Key Takeaways
Federal COBRA applies at 20 or more employees, counting part-timers as fractions of full-time. Below that line roughly 40 states have mini-COBRA laws instead, and not every administrator covers them.
The phrase COBRA and billing services is a vendor product name covering two jobs: federal COBRA compliance and premium collection from people off active payroll. Only the first carries statutory penalties.
At small headcount the monthly minimum sets your price, not the PEPM rate. Ask for both, plus implementation, takeover, and per-notice fees, before comparing any two quotes.
Two of the ten providers publish a rate: Anuvi from $1 per employee per month with no minimum, and Gusto at $30 per company monthly or nothing when it brokers your benefits. The rest are quote-only.
Minimums exclude smaller employers more often than the category admits. BASIC is listed at 20 eligible employees and Ameriflex documents pricing for 20 or more participants, while TASC lists a minimum of one.
Outsourcing does not transfer the legal obligation. The employer is normally the ERISA plan administrator, and penalties run up to $110 per day under ERISA plus $100 to $200 per day in excise tax.

Frequently Asked Questions

What are COBRA and billing services?

A bundled service combining COBRA continuation administration with premium billing for people not on active payroll. COBRA administration covers notices on federal deadlines, election tracking, premium collection, carrier updates, and termination for non-payment. Billing services, sold as direct bill or retiree billing, is the same collection work for retirees and staff on unpaid leave. Vendors bundle them because the mechanics are nearly identical, and several use the phrase as a product name.

Does my business have to offer COBRA?

Only with 20 or more employees on more than half your typical business days in the previous calendar year. Part-time employees count as fractions of full-time, which catches employers who assume the test means full-time headcount. Below the threshold, around 40 states have mini-COBRA laws creating similar rights with different durations and deadlines, so the answer for a smaller business is usually not federal COBRA but often something.

How much do COBRA administration services cost?

Most charge per benefit-eligible employee per month with a monthly minimum that is what a small employer actually pays. Anuvi publishes rates from $1 per employee monthly with no minimum and no implementation fee. Gusto is free when it brokers your benefits or $30 per company monthly otherwise. Expect possible charges for implementation, per-notice mailings, returned payments, and reinstatements on top of the base rate.

What is the difference between COBRA and direct bill?

COBRA is a federal obligation with fixed deadlines and penalties. Direct bill is an operational service with no equivalent statutory framework. Both collect premiums from someone off active payroll, which is why they are sold together, but only one carries regulatory risk. If your only need is invoicing two people on unpaid leave, you need billing services rather than COBRA administration, and that is a smaller purchase.

What happens if we get COBRA wrong?

Two penalty regimes apply at once: up to $110 per day per participant under ERISA section 502(c)(1), and a $100 per day excise tax per qualified beneficiary under Internal Revenue Code section 4980B, capped at $200 per day where more than one family member is affected. The excise tax generally does not apply to failures corrected within 30 days of discovery. The larger exposure is usually liability for medical claims incurred while someone was wrongly uncovered.

Can our payroll provider handle COBRA?

Often yes, and for a small team it is usually the least painful route, because the qualifying event already lives in payroll. Gusto includes it when it brokers your benefits and charges $30 per company monthly otherwise. Paychex includes it in HR Pro, HR Partner, and PEO packages. ADP offers it alongside its payroll platform. The trade-off is that bundled pricing is hard to compare, and switching payroll later means switching administrators.

What is mini-COBRA and does it apply to us?

Mini-COBRA is the informal name for state continuation laws extending COBRA-like rights at employers too small for the federal rule, and roughly 40 states have one. Duration is often far shorter than the federal 18 months, notice deadlines differ, and some states apply only to fully insured plans. For a business of 5 to 50 people this is frequently the rule that governs, so confirm in writing that your administrator covers your state.

Does outsourcing COBRA remove our legal liability?

No. Unless your plan document designates otherwise, the ERISA plan administrator is the plan sponsor, which is normally the employer, and courts can assess notice penalties against you even where a third party was contracted to do the work. A good administrator reduces the chance of failure and documents what was sent and when. Some offer contractual indemnification against their own negligence, but that is a private contract and does not bind a regulator.

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