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The Family Member Eligibility Verification (FMEV) is OPM’s required process for ensuring that only eligible family members are enrolled in FEHB and PSHB health plans. It requires agencies to request and review documentation proving eligibility whenever family members are added during:
Initial Opportunity to Enroll (IOE),
Qualifying Life Events (QLEs), and
Open Season.
Agencies will report verification results annually to OPM. The process helps safeguard program integrity and ensure compliance with federal law and Benefits Administration Letters (BALs) such as 21‑202, 24‑204, and 26‑201, which outline verification rules, required documentation, and reporting procedures.
FEHB Protection Act of 2025
This information provides answers to common questions about implementing the FEHB Protection Act of 2025 family member eligibility verification requirements.
The FEHB Protection Act of 2025 (Sec. 90101, Public Law 119-21, 139 Stat. 362) signed July 4, 2025, requires verification of a family member to a plan during Open Season.
This requirement is in addition to existing eligibility verification requirements that employing offices perform for Initial Opportunity to Enroll (IOE) or Qualifying Life Events (QLEs). This does not replace current employing office responsibilities.
*Note: For brevity, and unless specifically stated otherwise, the FEHB Program includes the Postal Service Health Benefits (PSHB) Program.
The employing office should verify the relationship of a family member at the time it adjudicates Open Season election.
With the passage of the FHEB Protection Act, employing offices should verify a family member's eligibility whenever an enrollee adds a family member to FEHB coverage, including during:
Initial Opportunity to Enroll (IOE)
Open Season
Qualifying Life Events (QLE)
Other enrollment actions that add eligible family members
Covered family members added to FEHB Program coverage include the enrollee's spouse and children under the age of 26 such as biological children, adopted children, stepchildren, and foster children. A disabled child age 26 or older who is determined by the employing office to be incapable of self-support because of a physical or mental disability that existed before their 26th birthday is also a covered family member.
Employing offices are required to verify new family members being added to a FEHB Program enrollment.
Although it is not required or prohibited to conduct re-verification of family members, if the enrollee has already provided documentation deemed acceptable as proof of eligibility for a family member during the plan year, no additional documentation will be required for that family member, per BAL 24-204. If the documentation was received outside of the plan year, verification may be required again.
Agencies should make every effort to verify new family members within 30 days of receiving the acceptable documents from the enrollee. If this verification occurs after the effective date of coverage and the family member is determined to be ineligible, the employing office will remove that individual in accordance with 5 CFR 890.308(f).
Enrollees must provide documentation that indicates eligibility for the Qualifying Life Event (QLE) as well as proof of eligibility when adding a family member to the FEHB Program enrollment to the employing offices, Carriers, or OPM.
If an enrollee has already provided documentation deemed acceptable as proof of eligibility for a family member for a QLE election during the plan year prior to Open Season verification request, per BAL 24-204, no additional documentation is necessary for family members that were verified previously.
The employing office should verify eligibility when it processes the Open Season election.
The employing office must ensure that it has verified eligibility when it processes the final Open Season election. If verification of a family member's eligibility was performed during a previous election during the same Open Season, the employing office does not need to re-verify.
Yes, these are enrollment records and should be retained in accordance with the employing office's regular procedures. Current record retention requirements have not changed.
Yes. Existing FEHB Program Carrier processes remain in effect while complying with the new verification requirements. This means that before adding a family member to an existing Self and Family enrollment, an FEHB Carrier must require that the enrollee provide proof of that family member's eligibility for coverage through the FEHB Program.
OPM does not manage employing office enrollment systems. Questions regarding system functionality should be directed to the employing office's Shared Service Provider.
Employing offices should continue working with their Shares Service Providers regarding system capabilities and implementation.
Questions regarding document upload capabilities should be directed to the Shared Service Provider.
