United States 

Office of 

Personnel Management 

The Federal Government’s Human Resources Agency 

 

Benefits Administration Letter 

Number 10 - 202 Date: October 8, 2010

Subject: Resolving FEDVIP Dual Enrollments NEW PROCESS, and UPDATED 

QLE chart 

Background 

This letter provides information on the new process for resolving FEDVIP dual 

enrollments that are discovered by BENEFEDS, the FEDVIP carrier, OPM or an 

employing agency. 

An eligible individual may be enrolled or covered under a FEDVIP dental plan and a 

separate FEDVIP vision plan at the same time; this is not a dual enrollment. 

Dual enrollment occurs when an individual is covered under more than one FEDVIP 

dental plan or more than one FEDVIP vision plan at the same time. Generally, dual 

enrollment is prohibited (5 U.S.C. Sec. 8956 and 8986) except when elimination of the 

dual enrollment would cause a covered person to lose coverage. See the section below 

entitled “When Dual Enrollment is Allowed.” Dual enrollment is not intended to allow 

double coverage for any one individual, but rather, to avoid an eligible enrollee or family 

member’s loss of coverage. No enrollee or family member may receive benefits as both 

an enrollee and as a dependent under more than one FEDVIP dental enrollment or more 

than one FEDVIP vision enrollment at the same time. 

Eliminating a Dual Enrollment 

As noted in the first FEDVIP Benefits Administration Letter, BAL 06-602, if 

BENEFEDS and/or a FEDVIP plan discovered an unauthorized dual enrollment, one of 

the enrollments would have been canceled prospectively from the date the dual 

enrollment was discovered. The enrollee would not have been required to refund any 

benefits paid under the cancelled enrollment, and the carrier would not have refunded any 

premiums paid. 

Effective 01/01/2011, any dual enrollments discovered by BENEFEDS, OPM, an 

enrollee’s agency and/or a FEDVIP plan will be cancelled retroactively to the effective 

date of the dual enrollment. The premiums paid for the cancelled enrollment will be 

refunded to the enrollee and the FEDVIP plan may request that the enrollee repay any 

benefits paid under the cancelled enrollment. 
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Example: A Federal employee and his/her Federal spouse have their own children and 

also stepchildren who live with the employees in a regular parent-child relationship. 

Because all of the children live with the employee, only one Self and Family enrollment 

is needed in order to cover all eligible family members. If both the employee and his/her 

spouse are enrolled in separate Self and Family plans, then the spouse and the children 

are automatically covered under both policies. This is considered a dual enrollment and 

must be eliminated. Also, the spouse may not elect to enroll in his/her own Self Only 

plan as he/she is already covered under their spouse’s Self and Family enrollment. 

When Dual Enrollment is Allowed 

There are rare instances when dual enrollments are allowed in order to prevent an eligible 

person from losing coverage. These must be authorized by BENEFEDS and will only be 

allowed when the enrollee or an eligible family member would otherwise lose coverage. 

Some examples of allowable dual enrollment include when: 

• An enrollee and spouse legally separate and both of them retain custody of their 

children by prior marriages. Those children of the covered spouse lose coverage 

under the enrolled spouse when they leave the household, so the covered spouse 

would be allowed to enroll. 

• An enrollee and spouse have children from prior marriages who do not live with 

them. The covered spouse’s children would not be covered unless a dual 

enrollment applied. 

• An enrollee is under age 22, and covered by his/her parent's enrollment as a 

dependent. That enrollee becomes a parent, and enrolls in order to provide 

coverage to his/her child. 

If a dual enrollment is allowed, the enrollee is required to notify BENEFEDS as to which 

family members will be covered under each of the two enrollments. 

BENEFEDS will continue to work with enrollees to resolve dual enrollments. If the 

enrollee and spouse are unable to agree on which enrollment to continue, the enrollment 

of the spouse with a court order to provide coverage for the children will be continued. 

Otherwise, the second (later) enrollment must be cancelled since it is the enrollment that 

caused the dual enrollment to occur. 

If BENEFEDS authorizes a dual enrollment, the enrollee may be covered and receive 

benefits only under his/her own enrollment. If the enrollee or a family member receives 

benefits under more than one plan, it is considered fraud and the enrollee is subject to 

disciplinary action. 
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Health Care Reform 

The Patient Protection and Affordable Care Act (PPACA) does not apply to FEDVIP, 

which is a stand-alone, enrollee pay-all program. Children of FEDVIP enrollees are not 

eligible for coverage up to age 26. In general, a dependent child will no longer be 

covered upon his/her 22nd birthday.

Qualifying Life Event UPDATE 

Below is a list of possible FEDVIP enrollment changes outside of Open Season. This 

replaces the listing found in BAL 06-602, and includes updates from the FEDVIP 

Regulations Amendment dated April 20, 2010.

QLE that may permit a 

change in enrollment 

From 

Not 

Enrolled 

to 

Enrolled 

INCREASE from Self 

Only to Self Plus One or 

to Self and Family or 

from Self Plus One to 

Self and Family 

DECREASE from Self 

and Family to Self Plus 

One or to Self Only or 

From Self Plus One to 

Self Only 

Cancel 

CHANGE 

from one 

plan to 

another 

Acquiring an eligible family 

member No Yes No No No 

Losing a covered family 

member No No Yes No No 

Losing other dental/vision 

coverage (eligible or covered 

person) 

Yes Yes No No No 

Moving out of regional plan's 

service area No No No No Yes 

Leaving pay status due to 

deployment to active military 

duty (enrollee or spouse) 

No No No Yes No 

Returning to pay status from 

active military duty (enrollee 

or spouse) 

Yes No No No No 

Annuity or Compensation 

restored Yes No No No No 

Transferring to an eligible 

position with a Federal 

agency that provides dental 

and/or vision coverage with 

50 percent or more employerpaid premiums. 

No No No Yes No 
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The time frame for requesting a QLE change is from 31 days before to 60 days after the 

event. There are a few exceptions: 

- No time limit for a change based on moving from a regional plan’s service 

area 

- No time limit for a change based on losing a covered family member 

- An individual cannot request a new enrollment based on a QLE before the 

QLE occurs, except for enrollment because of the loss of dental or vision 

insurance. He/She must make the change no later than 60 days after the event. 

William Zielinski 

Associate Director 

 for Retirement and Benefits