Consider a common blind date scenario. The couple meets for a dinner date, and everything is going great until the bill comes. Who will pay?

Health plans face a similar situation when an individual has dual coverage, especially when COBRA is involved. Coordination-ofbenefits (COB) rules and other regulations come into play. The COB rules provide a standard order-of-benefit determination (OBD), a priority list, if you will. The challenge for employers is that the COB rules are in accordance with state law, and states have adopted different versions of the Model COB Regulation, issued by the National Association of Insurance Commissioners. Because
the COB rules are based on state law, they do not apply to self-funded health plans because of ERISA preemption (although most plans follow the OBD in the COB rules). In addition, Medicare Secondary Payer (MSP) rules also come into play.

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