DATE: Monday, October 5, 2026
What’s New
The Office of Personnel Management (OPM) Benefits Administration Letter 26-202, states that beginning with Open Season for Plan Year 2027, Human Resource Offices must verify 100 percent of Open Season elections in which a family member is added. This includes reviewing appropriate proof-of-relationship documentation and verifying the eligibility of each newly added family member before enrollment is finalized. The new verification requirements also apply to qualifying life events (QLEs) and Initial Opportunity to Enroll (IOEs).
We will share additional details about Open Season, which runs November 9 – December 14, as it becomes available, including changes to Employee Express for verification purposes.
Existing FEHB Eligibility Obligations
Employees are responsible for ensuring that all covered family members meet FEHB eligibility requirements. You should review the eligibility of anyone currently covered under your plan by visiting BENEFEDS, Employees Express, and your carrier’s portal.
If any family member is no longer eligible, you must promptly request removal through an Employee Benefits Assistant or your FEHB carrier. Eligibility documentation can be requested at any time, and knowingly covering an ineligible family member may violate federal law, including penalties under 18 U.S.C. § 1001.
Why This Matters
Failure to verify eligibility can lead to improper payments, increased premiums for the group, and potential legal consequences. Under the new process, HR will notify employees if documentation does not support eligibility, and corrections may be required before enrollment can be processed. Documentation will be retained according to established procedures.
Below is a summary of which family members are eligible for coverage. For full details, please visit the Family Members section of the FEHB Handbook.
Which family members may I cover?
Your current spouse
If you are in a valid marriage or common law marriage, then your spouse is eligible for FEHB coverage. A common law marriage must be initiated in a state that recognizes common law marriages for the marriage to be considered valid.
By law, you cannot cover a former spouse under your enrollment in an FEHB Program plan, even if there is a court order requiring you to provide health insurance. See information regarding former spouses in the “Which family members are not eligible?” section below.
Your children under age 26
Your children under the age of 26 are eligible for FEHB coverage if they are your biological children, legally adopted children, stepchildren, foster children for whom you are the primary source of financial support and with whom you have a parent-child relationship (you cannot add a foster child without appropriate approval from your Employee Benefits Assistant).
- In the case of a stepchild, the birth certificate must list your current spouse as parent, and you must also verify your spouse’s eligibility even if you are not enrolling your spouse. In most cases, your stepchild loses coverage after your divorce or annulment from, or the death of, the parent.
- Your married child is eligible to be covered under your FEHB plan, but their spouse and/or children are not eligible to be covered under your enrollment.
- Except as noted below, once your child reaches age 26, they are no longer eligible as a family member and must be removed from your FEHB enrollment.
- Note: Your disabled child, over the age of 26, who is incapable of financially supporting themselves because of a physical or mental disability, is eligible for FEHB coverage if their physical or mental disability existed before the age of 26 and their disability is expected to continue for at least a year.
Which family members are not eligible?
- Your former spouse is not eligible once your divorce is finalized.
- Your children are no longer eligible upon their 26th birthday (unless determined to be incapable of self-support).
- Your parents are not eligible.
- Grandchildren are not eligible unless they meet the requirements to be considered a foster child.
- Domestic partners are not eligible.
What do I do if one of my family members is no longer eligible?
You must notify your HR Office or your FEHB Carrier within 60 days of a family member becoming ineligible. Your Employee Benefits Assistant will inform you of your family member’s option to enroll in FEHB for themselves under Temporary Continuation of Coverage (TCC) or as a Former Spouse. In addition, you may also have the opportunity to change your plan or enrollment type.
How do I verify that my family member is still eligible?
You can find more details about how to verify your family member’s eligibility in the Family Members section of the FEHB Handbook on OPM’s website.
Resources
- OPM's Frequently Asked Questions – Family Member Eligibility Verification During Open Season
- Readiness assessment of 100% verification of Open Season elections when a family member is added (BAL 26-202)
- FEHB Handbook
Questions
- Contact your assigned Employee Benefits Assistant.