Proving FEHB Eligibility in Retirement

Can You Prove You Meet the Requirements to Continue Your Health Insurance in Retirement?

I had the opportunity to talk to Sarah (not her real name) while attending a Federal employees’ resource group national training over the summer. When she heard about my new venture with Federal TransFERS, LLC, she had to share her The Office of Personnel Management (OPM) delayed my retirement package “war story.”

Sarah retired January 3, 2015 with 37 years of service. All of her time was with the same agency, without an interruption in service. It should have been easy for the OPM to confirm her service dates; and there was no complication related to a service credit deposit. She enrolled in the Federal Employees Health Benefits (FEHB) program when she entered on duty in 1977. She had never discontinued her benefits or even changed carriers so was covered by FEHB for many more than five consecutive years prior to retirement enabling her to carry her coverage into retirement.

So what caused the delay in processing Sarah’s retirement package?

Sarah’s agency did not provide adequate proof that met the requirements to continue her FEHB.

Sarah was fortunate that she had never changed health insurance carriers and that her insurance identification card showed the effective date of her plan. She was able to provide OPM a copy of her insurance card and prevent a lengthy delay.

In 2014, OPM conducted an audit and found that the most common error made by agencies when preparing retirement packages was failing to document that the employee meets the requirements to continue health coverage. Part of the problem is that electronic enrollment systems display the current coverage, but don’t always display or even retain the previous coverage. OPM would prefer documentation of FEHB enrollment throughout an employee’s career, but absent that, they will accept the following as proof of coverage during the 5 years of service immediately before retirement:

  • OPM Standard Form 2809, Health Benefits Election Form, or other enrollment form
  • OPM Standard Form 2810 Notice of Change of Health Benefits Enrollment
  • Reports or screen shots from on-line enrollments or 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 the employee 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

While it’s your Agency’s responsibility to provide OPM the documentation of your eligibility to continue FEHB, not all human resource offices carry out their responsibilities equally, so it’s important for you to retain the documentation you’ll need.

You can help prevent what happened to Sarah from happening to you by collecting the information that shows your FEHB coverage for the past five years (or earlier) now and continuing to retain documentation until you retire. If you can’t find your Standard Forms 2809 for your entire career, be sure you have the leave and earnings statements showing your payroll withholding for FEHB coverage for the past five years, starting now, and continue to keep them so you will have the proof of your eligibility if your agency doesn’t provide adequate documentation.