I'll need it, as will the rest of the nation's employers, as we try to catch all these fastballs coming at us from every direction. They come bearing names like "economic stimulus" and "health care reform." If we're caught unaware, they'll pop us on the head.

President Obama barely had finished taking the oath of office when the American Recovery and Reinvestment Act was rolled out, including the COBRA expansion that allowed involuntarily terminated employees to continue or re-enroll in their employer's health plan at 35% of the cost for nine months.

This was no doubt a great relief to an estimated 7 million Americans who've found themselves casualties of the worsening economy, but it's a further burden to employers during a time when they're already strapped for cash.

As you know, the COBRA subsidy requires employers to initially front the cost and has the potential to cause considerable administrative headaches. Earlier this spring, employers were scrambling to calculate the new premiums, notify eligible former employees and learn how to chase earmarked funds via quarterly payroll adjustments.

This was a bit tricky in a local government setting, where there is a line item for everything, and every line item is in its place. In Palm Beach County, for example, payroll is administered by a separate constitutional officer. I've spent a considerable amount of time scratching my head, wondering how I'm going to get those payroll deductions back into my health insurance fund. At press time, I'm still scratching.

It's not just those refundable tax deductions that have me scratching my head, but also the question as to what my reserve balance will look like at the end of the plan year. What kind of claims costs will this new benefit bring to the plan?

For a self-insured employer like Palm Beach County, a mid-year plan change in benefits has the potential to drive costs that could beat the plan actuary's crystal-ball attempt to project them. It is quite possible that claims filed by the new COBRA enrollees will exceed the sum of the premiums collected from the participant and Uncle Sam.

Also, COBRA vendors are asking for fees as high as $20 per employee to provide notifications on behalf of the employers they serve, representing another unanticipated cost.

So Palm Beach County quickly formed a committee with benefits and payroll employees; we're local government, committees are what we do best. We also enlisted the folks in HR to train the department payroll coordinators to be more specific with the system's reason codes. Employees that leave for "personal reasons" must now open up to us a little more because their eligibility for the subsidy depends on it.

For example, if they've been told their position is to be eliminated at the end of the fiscal year but choose to resign early, we have determined the subsidy would apply for that voluntary resignation. We just hope the feds agree with us when it comes time to get those dollars back.

Everyone has their marching orders, but many gray areas remain. Among them, Florida law requires public-sector employers to allow retirees the opportunity to continue in their former employer's group health plans. Some of these retirees may have been told that their positions would be eliminated at fiscal year-end, and they are retiring early. We're still not sure if this is considered voluntary or involuntary from a subsidy eligibility standpoint.

We chose to take the position that retirees are not eligible for the COBRA subsidy because they are eligible to continue in the county's group plan under Florida law. However, they must pay the full cost of coverage, which is hundreds of dollars more than the subsidy premium, so we expect we'll here from some very unhappy retirees.

Also, it was necessary to determine if our stop-loss coverage would be in place for subsidy recipients who chose to re-enroll into COBRA beyond a 63-day absence from the plan. Cigna responded that they "thought so."

As employers scrambled to meet the obligations of the COBRA expansion, the Obama administration confirmed its commitment to reform the health care system, despite the gloomy economic condition of the country. Although employers have been invited to the table and have been asked to keep an open mind, it is hard to tell how the administration will meet its goals without further burdening American businesses.

My advice to employers is to keep an eye on the ball. A new plan will be put into play, and it will be up to the employers to catch the result.

Contributing Editor Nancy Bolton is the director of risk management for the Palm Beach County Board of County Commissioners in West Palm Beach, Fla.