This report, written by Anthony F. Shelley and Josephine Harriott, reviews how the Great-West decision continues to shape plan enforcement of and recoveries under reimbursement provisions, evaluates the subsequent Circuit split, summarizes and analyzes Sereboff, and describes how the Circuits have responded to Sereboff. It also discusses steps ERISA plans can take to achieve the best possible outcome in light of Sereboff and post-Sereboff decisions. The report also considers the application of two other related subrogation issues: the “make whole” doctrine and the “common fund” doctrine.