In Boddicker v. Esurance, Inc., a participant resigned while on FMLA leave but did not receive his COBRA election notice until after he filed suit against his employer because the third-party administrator (TPA) sent the notice to a post office box he no longer maintained. The participant argued that the employer had a duty to oversee the plan administrator or to follow up with the plan administrator to ensure participants receive their COBRA election notices. The district court disagreed, holding that because the employer had designated the third-party administrator as plan administrator, the employer was not responsible for providing the COBRA election notice. Where, as here, the court continued, the employer uses an outside plan administrator, responsibility for COBRA notification is bifurcated: the employer must notify the plan administrator when a qualifying event occurs, but the plan administrator is ultimately responsible for providing the COBRA election notice.