Author: Bob Braunstein, Federal Benefits Specialist

The Office of Personnel Management (OPM) recently released Benefits Administration Letter (BAL) 25-102, offering important guidance for married Federal employees and annuitants navigating their Federal Employees Health Benefits (FEHB) coverage. This update is especially relevant for couples where one spouse is retiring and moving from their own FEHB coverage to coverage under their working Federal spouse.

Previously, such a coverage change required both spouses to submit FEHB SF 2809s:

• The retiring Federal employee submitted an SF 2809 cancelling their enrollment.
• The spouse continuing to work submitted an SF 2809 enrolling in FEHB coverage (including their retiring spouse as a family member).
• The coverage cancellation and enrollment were simultaneously processed ensuring continuing coverage of both parties.

This method of coverage change, while widely used and accepted, lacked formal guidance from OPM with respect to how the retiring spouse’s cancellation would be documented to preserve future eligibility to reenroll. While there’s no record of OPM outright denying reenrollment to eligible annuitants who lost coverage under a spouse’s plan, failure to follow proper procedures, delays in documentation, or lack of survivor annuity elections (even though not necessary for coverage retention), have occasionally led to temporary gaps in coverage. BAL 25-102 helps prevent these issues by formalizing the cancellation process and preserving reenrollment rights. Here is an example of how it will work:

• Bill and Marjorie are Federal employees who both have Self Only FEHB enrollments. They want to move to a Self Plus One enrollment under Marjorie when Bill retires at the end of December. The reason for this is that Marjorie will be able to retain the premium conversion option as an employee – i.e. the ability to pay FEHB premiums with non-taxable income. 

• To make this happen, Bill must complete form RI 79-9 cancelling his enrollment and also obtain a copy of Marjorie’s SF 2809 Self-Plus-One enrollment covering him as a family member. 

• Marjorie’s SF 2809 must include Bill’s full name, spousal relationship code (“01”), the FEHB plan’s three-digit enrollment code (such as Blue Cross Blue Shield Self-Plus-One Standard Code 106), the event code (if not during Open Season), and the enrollment effective date of her FEHB enrollment.

• Bill’s agency must place the cover sheet found in BAL 24-103, Attachment 1 – available at FEHB Enrollment Change Cover Sheet – on top of his RI 79-9 and a copy of Marjorie’s agency certified SF 2809, and include these documents in his retirement application package that will be sent to OPM. Once received, OPM will process Bill’s FEHB cancellation based on the effective date listed on Marjorie’s agency certified SF 2809 and document that he retains FEHB reenrollment eligibility.

According to BAL 25-102 and the FEHB Handbook, these types of coverage cancellations are treated the same way as FEHB coverage suspensions preserving the right to reenroll in FEHB when losing coverage under their spouse’s plan, such as through divorce or death, or during any subsequent Open Season.

Please note that the provisions of BAL 25-102 do not apply to U.S. Postal Service employees or annuitants covered under the Postal Service Health Benefits (PSHB) program. USPS employees must continue to use PostalEase or LiteBlue to manage PSHB enrollment changes, including switching coverage between spouses.

Bob Braunstein is a retired Federal employee who was last employed as a Senior Human Resources Consultant with the Office of the Comptroller of the Currency (OCC) at the Department of the Treasury. During his Federal career, he served in a full range of HR positions spanning recruitment, staffing, employee relations, retirement and benefits, and position classification/management disciplines.  He is a retirement and benefits instructor for NITP. 

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