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You nailed it. OEP is over. Dropping COBRA doesn't trigger an SEP. They had an SEP when they lost their group benefits, but once they enrolled in COBRA that SEP is over. As you said, they should have shopped before electing COBRA.
on another note... should COBRA disappear as an option? The major reason COBRA was enacted was for people with PRE X to continue on and now that reason is gone. I believe many will feel trapped once they realize what just happened.
My .02