A recent decision of the United States Court of Appeals for the Fifth Circuit stands as a harsh reminder that careful drafting of employee benefit plan documents can be essential to avoiding unanticipated liability. In LifeCare Hospitals v. Health Plus of Louisiana, No. 04-30422, 2005 U.S. App. LEXIS 14640 (5th Cir. July 20, 2005), the insurer of an employer-sponsored health care plan was required to pay more than $250,000 in medical claims on behalf of a former employee of the plan sponsor, even though the former employee arguably had failed to elect COBRA continuation coverage within sixty days of his termination of employment and receipt of COBRA election forms, because the plan document did not specify when the COBRA election period for the plan would end. The Fifth Circuit rejected the carrier's argument that when the plan document fails to define the end of the election period, the election period is limited to the 60 day minimum period required under the statute.