The U.S. Office of Personnel Management (OPM) has told federal agencies that, starting with this year’s Open Season, they must verify 100 percent of elections in which a family member is added to Federal Employees Health Benefits (FEHB) or Postal Service Health Benefits (PSHB) coverage. The requirement, laid out in a July 2026 benefits administration letter, is the latest step in OPM’s years-long effort to identify and remove ineligible family members from the federal health insurance programs.
Here is what changed, why, and what federal employees and retirees should do this Open Season.
In Benefits Administration Letter (BAL) 26-202, dated July 15, 2026, OPM notified agencies that employing offices “must verify 100 percent of Open Season elections in which a family member is added,” for coverage effective Plan Year 2027. Agencies were asked to complete a readiness survey by July 31, 2026, so OPM could identify implementation obstacles before Open Season begins.
This isn’t a brand-new documentation requirement. OPM finalized a rule effective July 2, 2026, requiring enrollees to submit proof of eligibility, such as marriage certificates, birth certificates, or tax returns, for any family member added to FEHB or PSHB coverage, including during Open Season. What BAL 26-202 changes is how thoroughly agencies must check that documentation. Under prior guidance, most recently BAL 24-201 in 2024, agencies were required to review only a minimum 10 percent sample of Open Season family-member additions, while a full review was merely recommended. BAL 26-202 makes 100 percent verification mandatory, not just recommended, and roots that requirement in statute rather than agency guidance.
The law behind the mandate
The 100 percent standard stems from Section 90101 of the FEHB Protection Act of 2025, enacted as part of Public Law 119-21, which requires eligibility verification whenever an enrollee adds a family member during Open Season.
The push traces back to a Government Accountability Office report that found OPM lacked a reliable mechanism to identify and remove ineligible family members from FEHB coverage. Claims tied to ineligible family members have been estimated to cost the program roughly $1 billion a year, a cost ultimately shared by enrollees and the government through higher premiums.
What documentation you’ll need
Employing offices must request and evaluate proof-of-relationship documents for every Open Season election that adds a family member. In general, that means a marriage certificate for a spouse, a birth certificate for a child, or an adoption certificate for an adopted child. A disabled adult child (age 26 or older) also needs documentation of the disability. Your employing office can confirm exactly which documents it will accept.
The same full-verification standard applies to qualifying life events too, such as a marriage or birth: as of July 4, 2026, 100 percent of those additions must also be reviewed and verified, not just spot-checked.
What happens if a family member can’t be verified
If the required documentation isn’t provided, or doesn’t establish eligibility, the employing office, OPM, or the carrier can deny or remove the family member from coverage. The enrollee must be notified of the determination, and generally has 60 days to request reconsideration from the employing office or OPM. That reconsideration decision is final.
In practical terms: incomplete documentation won’t just draw a warning. It can hold up, or unwind, the enrollment of the family member you were trying to add.
Open Season timing
This year’s Open Season is expected to run November 9 through December 14, 2026, for the 2027 benefits year. OPM typically posts official confirmation in early-to-mid October.. The verification requirement applies to every election made during that window in which a family member is newly added.
What federal employees and retirees should do now
If you plan to add a spouse or child to your FEHB or PSHB coverage during this year’s Open Season, the most useful step you can take is to gather your documentation before the window opens rather than waiting until you make your election. Locate your marriage certificate, birth certificates, or adoption paperwork now, and check with your employing office if you’re unsure exactly what will be accepted, especially for a disabled adult child or a spouse you’ve been married to for over a year.
Download the checklist
To help you get ready, we put together a free one-page checklist covering which documents you’ll need to add a spouse, child, adopted child, or disabled adult dependent to your FEHB or PSHB coverage this Open Season. Download the checklist here.