Expert's View

Is there any federal employee who doesn’t know that you have to be covered by the FEHB program for the five consecutive years before you retire – or from your first opportunity to enroll – to carry that coverage into retirement? If so, why am I writing about it now? It’s because OPM just issued a Benefits Administration Letter (No. 14-103) to provide guidance to agencies on how to document a retiree’s eligibility to continue his or her FEHB coverage.

Here’s OPM’s reason for issuing the BAL. After conducting audits on agency retirement application packages for the last four years, it found that “the single most common error found in retirement packages continues to be the agency’s failure to fully document whether an employee meets the requirements to continue FEHB coverage into retirement…Often the problem is that the documentation of electronic enrollment changes reflects the new plan and effective date, but not the old plan. Therefore, even though the 5 years may appear to be fully documented, OPM cannot accurately determine the full coverage history of the 5 years of service immediately prior to retirement form the documentation submitted.”

Ideally, OPM would prefer documentation of an employee’s coverage for their entire career. Lacking that, it “must have proof of coverage during the 5 years of service immediately prior to retirement (or if less than 5 years, during all service in which the employee was eligible for FEHB).”

From their point of view, acceptable proof of coverage includes:

* a Standard For 2809 (Health Benefits Election Form) or other enrollment form;

* a Standard Form 2810 (Notice of Change of Health Benefits Enrollment);

* history reports from on-line enrollments or screen shots that show both the old plan and new plan, and the effective dates for each change;

* evidence of coverage as a family member under another’s FEHB enrollment;

* evidence of TRICARE/CHAMPUS enrollment, including evidence of coverage as a family member; or

* a signed memo from the agency detailing the continuous coverage of the employee to prove that he or she meets the 5-year requirement and was covered under FEHB on the retirement date, with corroborating documentation showing payroll deductions for at least 5 years of service immediately before retirement.

If it’s your agency’s responsibility to do this, why am I telling you? Because not every personnel office that processes retirement applications will get the word or, if they get it, manage to carry out the requirements successfully. And if they don’t, the payment of your annuity will be delayed.

You can help yourself greatly by gathering up supporting documentation yourself for the five years before you retire, and having that handy in case you need to prove your eligibility. Keeping the Standard Form 2809, Health Benefits Election Form, that would show when you first enrolled, which would be a good start. Also helpful would be pay records that would show that deductions were taken out of your pay for FEHB coverage.