The letter requires employing offices to validate certain Open Season elections starting with the 2024 Open Season. Image: MR.DEEN/Shutterstock.com
By: FEDweek StaffFollowing is a letter OPM has issued to agencies requiring them to sample FEHB enrollments of their employees during this fall’s open season for possible inclusion of ineligible persons, including a requirement that they remind employees of the potential legal consequences of intentionally including such persons under self plus one or family coverage.
The Federal Employees Health Benefits (FEHB) Program is highly valued by employees seeking to care for their families and agencies aiming to recruit and retain talent. OPM has a longstanding commitment to the integrity of family member enrollment in the FEHB Program to ensure that the resources dedicated to this benefit program are fairly and appropriately allocated.
This Benefits Administration Letter (BAL) requires employing offices to validate certain Open Season elections starting with the 2024 Open Season. The Family Member Eligibility Review (FMER) requires a random sampling of FEHB Open Season elections of Self Plus One and Self and Family enrollment types. Each election included in the random sampling will be subject to verification of all family members under the enrollment. If ineligible family members are found, employing offices must follow instructions in BAL 20-203 for removing an ineligible family member.
Prior Guidance
Currently, BAL 21-202 directs employing offices to request and view proof of family member eligibility for an employee’s Initial Opportunity to Enroll (IOE), and for all qualifying life event (QLE) actions. BAL 20-203 presents a process for an employing office to implement when there are questions or concerns about a family member’s eligibility for coverage under the Federal Employees Health Benefits (FEHB) Program. However, neither BAL requires employing offices or carriers to verify family members added to FEHB enrollment elections from the annual Open Season.
Scope
This BAL requires employing offices to conduct a Family Member Eligibility Review (FMER) of a random sample of processed Self Plus One and Self and Family Open Season elections. For the 2024 Open Season, employing offices will review a minimum of 10 percent of Self Plus One and Self and Family FEHB Open Season elections. Where feasible, employing offices should aim to exceed the 10 percent floor in 2024. Results of the review must be reported to OPM by July 31, 2025.
OPM will provide further guidance on verification of Open Season elections in subsequent years, including expectations for increasing the percentage of elections subject to verification. Furthermore, OPM plans to provide guidance to require all federal employees to provide eligibility documentation for family member changes during Open Season in subsequent years. Additionally, OPM will provide guidance on requests for employing offices to verify potential instances of improper enrollment identified by OPM through analyses of its Master Enrollment Index (MEI).
Employing offices that perform family member eligibility verification of 100 percent of their Open Season elections will not be required to perform this random sample review since full verification has already been done. However, these offices are still required to submit a report on the verification work performed during Open Season to OPM no later than the following July 31.
Educating Enrollees
To ensure consistent messaging to enrollees and to ease the administrative burden associated with performing this annual review, OPM has created communication materials, which will be distributed initially with this BAL, and made available on the OPM website. This messaging includes reminders to employees of the potential consequences (fines or imprisonment) of intentional false statements or willful misrepresentation leading to improper enrollment.
Sample Selection Methodology
To ensure consistency of randomization and ease of sample selection, those reviewed will be randomly selected using either the rand() function in Excel or a similar tool/method chosen by the employing office. This technique will provide each person who made a Self Plus One or Self and Family Open Season election with an equal and fair chance of being selected for the review.
Process for Removing Ineligible Family Members
Please follow the instructions for removing ineligible family members from BAL 20 203, Federal Employees Health Benefits Program: Removal of Ineligible Family Members from Enrollments.
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