I attended a seminar this week in which I learned that EAPs, if counseling is included, are subject to COBRA. My problem is determing the premium to charge for COBRA. We have an annual administration fee plus a set charge for each case with an annual maximum charge. We have about 60 employees eligible for the EAP, so the administration fee is easy. However, what's the best way to calculate the counseling part of the premium? I've come up two possibilities: 1) Assuming no one would elect continuation unless they anticipated needing it, I'd divide the counseling fee by 12 and that would be added to their premium; or 2) Divide the maximum charge by 60 and 1/12th of that would be the premium. I'm inclined towards the first option. Anyone have an opinion, experience, or other suggestion?

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