Tips on Submitting a Healthy Retirement Package

Updated : Sep 04, 2019 in Articles

Tips on Submitting a Healthy Retirement Package


Phil Gardner: Good afternoon, everybody. We
apologize for being late here. We had some technical difficulties, had to move from the
auditorium to the studio, so I apologize. I like working with a crowd, but this is just
going to have to do. Welcome to tips for submitting a healthy retirement
package. You may remember we did this back in September 2012 on submitting a healthy
retirement application package. Think of this as building on that. During the webcast, since we don’t have a
live on, there won’t be any questions asked. However, if you send any questions you have
to [email protected] and in the subject line please put “Healthy Case Webinar Questions”.
We will respond to any we can right here during the telecast. And if we don’t get a chance to, we will send
out responses to at a later date. We’ll send individual emails out to you with any responses
to any questions that we weren’t able to deal with today. With that, let’s say, we get going. The purpose
of today’s webinar is to provide some additional guidance on submitting healthy retirement
application packages to OPM for adjudication. This is a follow up to our healthy retirement
package presentation from September 2012. We are going to update some things today.
First, let’s get a little definition here. A healthy retirement package is one that is
complete and accurate for OPM to process. It doesn’t have to be developed for missing,
inaccurate or incomplete information. It’s a case that we can complete. Not all unhealthy packages are as a result
of an agency error. There are some things that we have to do here at our end and are
not charged as errors to agencies, because it’s information we may already have here
or we are procedurally required to get. We are going to focus today largely on some
new error definitions, but, real quick, let’s take a little refresher. We started doing the audit of agency retirement
application packages in 2009. We did the first one in 2008. It was more of a test audit.
We didn’t really provide the results to anybody. The first one we did in 2009. It was an annual
audit, it was based on a six week period, and the cases were reviewed by our legal administrative
staff, who reviewed and did the results based on cases they first touched on any given day. So agencies were provided with their results.
We did training on different various things we found. Now, the audit is performed monthly. We started
this back in 2012, it’s done monthly, and it is now performed in a new group here at
Opium, the Retirement Development Section, and it is based on the development checklist
that they use to go and screen the cases. We provide the agencies results monthly. Each
month, I try to present a message to try to help work with identifying problem areas,
we look for trends, give some tips on avoiding some of the common errors, so we’re continuing
to do that. Now this represents the average fiscal year
error rate over the last five years, as we first started doing this. You’ll see when
we first did this in 2009; it was a 31.5 percent error rate. That reduced incrementally through
2013. You’ll notice in 2012, we changed to the monthly
audit. So that the 2009, ’10, and ’11 audits were based on just the six month test period.
Starting in 2012, we went to the monthly audits. The fiscal year 2013, we were very proud to
see the error rate dip to 8.4 percent, however there was a footnote to that. You’ll see in
2014, the error rate has jumped up to an average of 18 percent. This is based on new error
definitions that we’ve put in place on October 1st. So again, starting in April 2012, we started
to search in the FERS development checklist and case development logs. We were systematically
screening all the incoming cases, documenting the healthy and unhealthy cases, and we were
documenting the developing actions that needed to be taken. We were taking the data directly from these
checklists, and using them for the retirement application audit. The checklist and audit
definitions, we shared in BAL 12-103, which was dated early May or June of 2012. We also shared them in some of the audit reports,
and we shared them through Chico council. In 2013, October to be exact, we revised those
error definitions and essentially, we added error definitions, they were expanded more
adequately reflect the conditions that we found that were delaying adjudication. It would appear that the error rate is always
been somewhere up around that 18 percent rate. It’s just that a large number of those errors
weren’t charged as errors because there wasn’t a category to charge them for. With these new definitions, we provided an
[inaudible 05:57] message back in late October 2014. They went out with the October 2014
and November 2014 audit reports. The data from these revised checklists is now what
we’re using for the retirement application audit. In this first section, we’re going to talk
mostly about these revised checklists. What I want to do is cover these new error definitions
that were added by the new checklist, and focus in on just the new definitions. Later
we will go to just the overall most common error types. In this first section, we are going to specifically
look at the new error definitions. The first category was miscellaneous errors. These were
things that weren’t necessarily service history; they were more things having to do with documenting
reduction force actions, VERA, VSIPs, that kind of thing. The first new error was that the name, social
security number and date of birth do not match the documents in file. Why is that important?
Sometimes we find that the wrong information is in a case for a different person. We have
another person’s documents mixed in in the case, which causes potentially unnecessary
development actions. We do look to makes sure that name, social
security number and the date of birth do match all through the files. We don’t accidentally
give someone credit for services someone else perform, for instance. The next thing in the
miscellaneous that we added was air-traffic controllers requiring that their retirement
SF50 be submitted with the retirement package. This has sent the new requirement. We’ve always
required this, there however did not used to be an error category for this. We need
the SF50 to get certain information about an air-traffic controller off of it, that’s
why we require. The next error category is service errors.
This would be missing service, pay rates not documented, et cetera. The new error definition
for that one is earnings required for USPS non-deduction service. We used to not charge
in errors as long as a piece of development was done and initiated at the Human Resources
Service Center down at Greensbourgh. If they sent out the PS316 form which they
use to obtain the earnings from the National Personnel Record Center, we didn’t charge
an error as long as that request was initiated. Now we’re charging the error if we need the
deductions [inaudible 08:51] more than five years of non-deduction service. First, more than three months of non-deduction
service. Regardless of how much service, any WAE Intermittent Service including subs real
carriers, we need the earnings to accurately charge them their deposit. On the WAE Intermittent
Employees, we need the time worked. The second error on service that did not used
to be in error is Schedule D, the “Schedule D missing.” There were a lot of Schedule D’s
missing; it just was an error previously. Why is it an error? WE use the schedule D
to help us to review the case. The Schedule D is essentially your checklist for different
things that are in a case. We use it to go through the case, and it calls our attention
to things such as VERA VSIP authorities, air-traffic control retires, law-enforcement officer retirements. We don’t necessarily use the Schedule D for
documentation, although in one area it can be used for documentation of the OPM authority
number in a VERA case. So there are times we actually need information off of that Schedule
D, but we do use it to compare what we have in a case to what should be there. While I’m
on that subject, I just want to touch on one thing. When we review a case, we are looking
to make sure that the case makes sense, that all the documents in the case make sense with
each other. If it says on an application, for instance
you’re on Schedule D, that the person is enrolled in health benefit; we know we expect to see
health benefits enrollment form. If it says have a former spouse entitled into a share
of their annuity, we know we’re looking for that. Sometimes development errors are caused because
the documentation file doesn’t jive of what the Schedule D says or what the application
says. These are some of the things we have to look at. Let’s look at some new FEHB code
errors. One of them is the FEHB suspended documentation
not on file. That is a new error category. When we say, “Documentation not on file,”
what we’re really saying is, “If someone’s going to suspend their FEHB coverage, we need
the documentation, the proof that they can do this and still restore their coverage at
a later date.” We’re looking for evidence of a Medicare Advantage health plan. We require
that documentation reflecting the effective date of the coverage and an approved Medicare
Advantage health plan, not just Medicare A or B. We’re looking for actual proof in the effective
date of the coverage in one of these Medicare Advantage plans. Tricare, we’re looking for
a copy of the uniform services ID card, and if they’re over 65, a copy of their Medicare
card showing that they have part A and B coverage. Because they have to carry Medicare part A
and B to be eligible for Tricare once they’re over age 65. For Champ VA, we’re looking for a copy of
their Champ VAA card, or their authorization card. We need a copy of that Champ VAA card
to do the suspension. Finally, Medicaid. We’re looking for their
enrollment card, or their letter of eligibility to Medicaid. We often send out a form 79-9
for any one of these occasions. Even if the documentation is there, we may have to send
out the 79-9 just to have the annuitants concurrent that they are suspending their coverage. That
however, is not an error. Similarly, “FEHB cancelled, documentation
not on file,” that’s the official error. This would be in two different ways. One would
be if they’ve cancelled their FEHB at any point prior to their retirement, we are looking
for documentation of prior coverage. Although that in and of itself is not an error. We
can use prior coverage to indicate certain things to us, such as a former spouse or children. But we absolutely have to have that standard
form 2809 cancelling their coverage. If they’re doing it at retirement, we need a couple of
things. We need that 2809 that they have submitted to cancel their coverage at retirement. If they’re cancelling it to be covered under
the spouse’s enrollment, we need that copy of their 2809 showing the change, the family
coverage, and showing that our annuitant is now covered under the family plan of their
spouse. If they show this, they can get their coverage reinstated at some point, if they
lose coverage under that plan. Another new error in the FEHB area is “Incorrect
HB code on the HB label.” This is actually a payroll error. It must match the FEHB code
on the transfer enrollment, and this would actually be indicative of the wrong HB code
being sent to us on the data exchange gateway, which we use to start the retirement claim
and — in about 55 percent of the cases — to automatically certify or to automatically
authorize interim payments, and to transfer in the HB enrollment. The other new error is an incorrect HB on
the IRR. Again, this is a payroll error because it must match the FEHB code on that transfer
enrollment as well. Now, we’re going to move to life insurance
coverage, the new errors life insurance coverage waived or cancelled after a previous enrollment.
In other words, someone was covered at some point in time, they cancelled later. We would
like to have all of their enrollment documents for their prior coverage. Again, there’s information
we can glean off of those coverage reports. But we absolutely have to have that 2817,
where they waive their coverage. Another new error is the standard form 2819
not signed, that is the conversion privilege. You’ll notice it says, “If included.” As you
probably remember, we don’t require that the 2819 be submitted. We require that the question
on the 2821 be answered that it was done and that there be a date in there. If the form
is submitted to us, we do require that it be signed. If it’s not, it going to be an
HR error. Another new error, “Incorrect alpha code on
the IRR.” That’s again a payroll error, it must match the code on the coverage that we
actually have in the case and on the 2821. Incorrect alpha on the 2821, that also has
to match that current coverage that they have, otherwise it’s a payroll error. Now, we’re going to look at the retirement
application. As you know, we glean a lot of information from the retirement application.
Even though it’s technically completed by the applicant, the agency is responsible for
the information contained on that application. And if it’s not correct, to get it corrected,
to send it back to the applicant and get them to correct it. Some of the new errors now, is the annuitant
did not make a survivor election. That was not an error condition before, although it
was an error condition that was charged under one of the errors. So now it’s our own error.
The real deal here is that an unmarried applicant has to make an election. Most of the ones we see, where there’s no
survivor election as an unmarried applicant who doesn’t think they have to make the election.
But they could be electing an insurable interest for instance, so we don’t need an election. Question number two not answered, that is
the former spouse question. This is 10 percent of all of our error. 10 percent of all of
our errors is just someone not answering that question, “Do you have a former spouse entitled
to a portion of your annuity or survivor annuity?” On the SIRS application, it’s in Section E.
On the FERS, it’s in section C. It applies to all applicants. It doesn’t matter if they’ve
never been married, or if they’ve only been married one time in their life. We still need
them to check “No” if that’s the case. The question must be answered. “Spousal information not included.” All applicants
that are married must provide us the information for their spouse. Even if they’re separated,
they’re still married, and we must have the spouse information. Another new error listing
is “proof of common-law marriage not included.” As you know, we need the marriage certificate
for a retiring employee, and if it’s a common-law marriage, we’re looking for a couple different
things. They can either have a certificate from their state, and again, this would be
in a state that recognizes common-law marriages. We’d be looking for a certificate, order,
or a judgment issued by their state of domicile. Or we would be looking for sworn affidavits
— when we say sworn affidavits, that means they have to be notarized — from the applicant
and two other individuals with knowledge of the facts. One related to the spouse and one unrelated.
Then we’d want corroborating evidence, such as copies of naturalization certificates,
immigration records, deeds, insurance policies, passports, children’s birth certificates,
joint bank accounts, joint tax returns, church or other sorts of club records. Anything showing that they have presented
themselves as man and wife. It could be bills. It could be an electric bill in their joint
names. Phone bill in joint names. This is what we’re looking for, for common-law marriage.
This is not common, to see common-law marriages, but nevertheless, if there is one there, this
is what we need to see. A couple, few last points on the retirement
application. Spousal consent forms are a problem. We’ve had a lot of problems with them. Anytime
an annuitant elects less than a full survivor annuity, they must have their spouse’s consent
to do this. That spousal consent form has some requirements.
It has to be notarized by a notary public. It has to be notarized by a notary public
whose commission hasn’t expired. It can’t have unacceptable corrections. Now, what are
acceptable corrections? Think about it logically. I’m going to show you a slide next that has
what the acceptable corrections are, but think about it. We need to know that when that spouse
signed their consent, that the notary saw them sign the consent for the same election
that is on the application. Corrections that don’t affect our ability
to determine whether the spouse actually signed that form in front of a notary is what we’re
looking for. Here are some examples. Acceptable white-outs and corrections. They can include the applicant’s name, their
date of birth, and Social Security Number. In a CSRS, if they correct Part 1A or C to
a greater amount, we can accept it. If they correct Part 1B to 1C, we can accept it. FERS,
if they correct Part 1A to a greater amount, we can accept it. FERS, if they Part 1B to
1C, D, E, or F, we can accept it. We do want to see, when there’s a correction,
when there’s a white-out, the annuitant should be initialing that correction and it still
must correspond with whatever election was made on the application. It could be an acceptable
white-out because it’s initialed, but we might, instead, be charging an error for a mismatch
between the election made on the application and the election that the spouse has consented
to. Military service. New military error. DD 214
or military order does not note character of service. This was not an official error
previously, although it was often charged if, under the error “No DD 214 submitted,”
we would often charge this for when the “Did not note the character of service or lost
time.” Generally speaking, that Member 4 copy is
the one that’ll have the character of service, meaning honorable, dishonorable, general,
whatever it is. We have to be able to tell it was active, honorable service. That Member
4 copy is the one that generally shows that. On the post-’56 IRRs, “Dates and lost times
do not match the DD 214 or the orders.” In other words, the dates that person says
that they’ve paid for in their military service are different than the evidence that we have
on file verifying that active service. Be it the DD 214 or their military orders. That
is a payroll error. Post-’56 IRRs not marked “paid in full.” That’s a payroll error. It should only be charged if that IRR was
submitted with the retirement application, however. We are not trying to hold you responsible
for a post-’56 IRR that was submitted with a prior agency. This is where I normally ask for questions,
and I suppose I could ask if there are any burning questions right now. Clyde is standing
at the ready, on the Internet, and looking for your questions. If you have any questions
about anything we’ve discussed so far, you can shoot them to Clyde. I’ll take a moment and see if anything comes
in. If not, we’re going to move on to the most common errors identified by the audit.
We will have a question period at the end. Once I finish this presentation, any questions
that we have, time permitting, I will answer as many as I can. Any that I don’t have time
to answer, I will answer individually by email. We will try to do a Q-and-A document. That
may be difficult. We will see. I’m going to move on to the next section,
which are the common errors we see. You’re probably tired of seeing this FERS error.
“Documentation of five years’ FEHB.” As you know, an annuitant must have, to be eligible
to continue their FEHB coverage into retirement; they must have been covered for the five years
immediately to retirement. Or if it’s less than five years, they must
have been covered during all periods of entitlement, and since first opportunity. It’s really five
years, or since first opportunity and during all periods of eligibility. It’s an HR error.
What’s acceptable proof of coverage? Obviously, a 2809 and a 2810 that might be in the case. But as you know, several years back, we went
to a lot of online enrollment systems where you could do your open-season change online.
You could do certain changes online. The problem is some of these history reports, the screenshots
that we receive from these online systems, don’t reflect everything we need to dot the
line between the old plan, the new plan, and the effective date. Anything you submit to us for documentation
must show the old plan, and the new plan, and the effective date. That way we can adequately
determine that this person did not have any cancellations, any terminations, et cetera,
during the intervening period of time. Other evidence we can accept. Evidence of
coverage as a family member, under another FEHB enrollment. In other words, a 2809 showing
that person was covered as a dependent under someone else’s FEHB plan. Evidence of Tricare
CHAMPVA enrollment. Including, if they were covered as a family member of someone else’s
Tricare CHAMPVA. What are we looking for? Very similar to if
it’s their own coverage. We’re looking for a copy of that uniform services ID card, or
if it’s CHAMPVA, we’re looking for that CHAMPVA authorization card, or the A-card, as they
call it. We can also accept a signed memorandum from
the agency, detailing the five years of continuous coverage. We would like with that documentation
of five years of payroll deductions to show that the person’s been covered. However, you may have noted that, about a
month ago, you may have a received a BAL from me, which is BAL 14-103. It’s not posted on
our website yet, but I did send it out on the listserv, and I sent it out with both
the January and February audit reports this year. It’s BAL 14-103. It’s documenting retiring
employees’ eligibility to continue their FEHB enrollment into retirement. It details acceptable proof of coverage, which
I just talked about a moment ago. What it really does to help you is it provides a template
for a memo that you can use to document five years of coverage when the full documentation
isn’t available. And you can certify that that person’s eligible to continue. Again, it was BAL 14-103. It had two attachments.
One attachment was the FEHB information certification memorandum that I’m referring to right now.
The other one was instructions for how to complete it. It had numbers on each area,
and then instructions. What to put in each area. Using this form, you can document those five
years of coverage when, maybe, you don’t have full documentation available. Why wouldn’t
you have full documentation available? Usually, it’s because you’ve submitted the only copies
you have. Of something from the online enrollment system is something that does not reflect
the old and new plan, and the effective date, as we require. You know you have five years there. You can
look in your system and see that. But your documentation, your visible, printed documentation
doesn’t show the old and new plan. You can use this memo. Essentially, the memo does
a couple things. A lot of you have memos you already use, that
you let us know, say, when an employee is retired and eligible to carry it, and they
were covered as a dependent under someone else’s plan. You let us know that, so we know
what we’re looking at. That kind of documentation. Sometimes, you use a memo letting us know
that they’re using CHAMPUS, Tricare, or CHAMPVA as part of their five years. You use it to
transmit an open-season change that’s effective after the retirement date. Or you’re using it to let us know that the
employee’s eligible, to certify that the employee’s eligible for a pre-approved waiver of the
five-year requirement, in a VERA VSIP case. You’re already using this memo. What I did
was I combined the samples I received from many of you. You can use this memo only when you’re going
to document five years. You can use it if you want to use it for those other situations.
But you should definitely use it when you’re documenting the five years of eligibility
and your documentation isn’t complete. Again, what you’re looking at here is a part
of the form where you enter the new plan, the old plan, the effective date of the change,
and the source of your documentation. In other words, what are you looking at that you’re
getting this information from? Is it a 2809? Is it a screenshot where you can see the old
and new plan, or you know from your history that there are no other enrollments, but the
printed documentation doesn’t support it? Again, you would do this for any change over
that final five years. The new plan, the old plan, the effective date, the source of that
documentation. Be it a 2809, employee express, or any one of the other online enrollment
systems. Or maybe out of clear system. Or from payroll records. Whatever that source
is, you put in there. Make sure you sign and date the memo, because
that’s essentially your certification, the fact that you signed and dated it. We’re really
hopeful that if you start using this template, that we can really do away with that error
of not documenting the five years. That’s 20 percent of all errors are not fully documenting
the five years. We really hope that by providing this template, we can bring that down into
single digits. Moving on. The next section where we see a
lot of errors is just the retirement application, in general. Again, I know the annuitant often
completes this. Sometimes, they complete it, however, on your online form, and it is your
responsibility to make sure that the application is full and complete. 10 percent of the time,
the former spouse question is not answered. 10 percent of all IRRs, rather. Former spouse question not answered. One simple
check mark and it’s an error. In CSRS, it’s Section E. In FERS, it’s Section C. It applies
to all applicants, even if they were only married once or they were never married. We
don’t know that. We need the answer. We need the question answered, then we can
take the appropriate actions, depending on the answer. If it’s no, we’re fine. If it’s
yes, we would expect to see a court order. Either already here at OPM and approved, or
submitted with the package. The spousal consent form. Again, we talked
about this earlier. I’m just going to touch back on it again. Another good 15 percent
of errors are just made on the spousal consent form. Usually, it’s because it’s not signed
by either the annuitant, or the notary, or the former spouse. It’s not notarized, which it has to be. Or
the notary commission has expired. Or it’s not notarized on the same day as the spouse
signed. Now, keep in mind, that is not an acceptable correction, to correct that date.
We have no idea if that correction was done in front of the notary, or if it was done
after the notary. No corrections on that date that the spouse
and the notary sign it. Just a brief note on the notary commission expired. It shouldn’t
have been expired at the time they notarized the document. If it’s two months later, three
months later, when we receive the document, we’re not going to return it because the notary’s
commission is now expired, as long as it was valid at the time it was signed. Maybe the form contains unacceptable corrections.
We’ll just go over those acceptable corrections again. The applicant’s name, date of birth,
and Social Security Number. Corrections there are OK. CSRS, Part 1A or 1C can be corrected
to a greater amount. CSRS, Part 1B to 1C is acceptable. FERS, Part 1A corrected to a greater
amount is acceptable. FERS, Part 1B is OK to change to 1C, D, E, or F. Corrections, white-outs, should be initialed
by the annuitant and, again, as I said before, it must correspond with the election on the
application. Let me go back here, one more time. It must correspond with the election
on the application. That’s another common error on the forms is that the election made
on the application and the election the spouse has consented to are not the same. Again, proof of five years of coverage, now
for life insurance is still a problem area. It is not as big as FEHB. It’s maybe only
a five to seven percent error, but nevertheless, it is a very common error. Generally, we need
those 2817s, or if it’s a real old case, the 176, to document the five years of coverage
for basic life and or optional insurances. Now, as you know, for both FEHB and FEGLI,
we would like all of the enrollment forms. We would like them all, because there’s different
information we can glean from those enrollment forms. However, we absolutely have to have
the proof of the five years, or first opportunity and during all periods of eligibility. In lieu of that 2817 or an old 176, you could
submit SF-50s documenting five years of whichever coverage you need to document. Be it an optional
coverage or the basic coverage. Or we can take sufficient payroll records to document
the five years of coverage. We would like those enrollment forms, but
if they’re just not available, we can use the 50s. Now, let me address one thing. As
you know, some years back, we put out a communication telling you no longer had to do a default
2817. It used to be the practice that if someone
did not return their form, and was therefore enrolled by default in basic only. The instructions
used to say to do a 2817, saying that the employee declined to submit the form. And
they were essentially being enrolled in basic only by default, because you’re automatically
covered by basic. If you have one of these cases where the person
declined to submit a form, so they’re in basic only, and it’s since we told you to stop the
practice of doing the default 2817s. You’re saying, “Great. You told me not to do one
of these, and now I don’t have evidence of those five years.” You can send us a 50 that goes back at least
5 years. Or you could send us a 50, if you did the default 50 or whatever. Something
from at least 5 years ago, showing the person had basic only, and the retirement SF-50,
which would also show that the person has basic only. I just wanted to address that.
Some other common life insurance errors. The SF-2821. Sometimes it’s missing. Sometimes
it’s not signed by either HR or payroll. If it’s not signed, that error is assigned to
who didn’t sign it. It would be an HR error, if they didn’t sign it. Payroll error, if
payroll didn’t sign it. Box five completed and there’s no 2823 attached.
Box five, you’re telling us there’s a designation of beneficiary. If you’ve checked box 5 and
there’s no valid 2823 attached, it’s going to be an error. Box nine doesn’t match the
date on the 2819. Or box nine is not completed. Again, we don’t need the 2819 submitted to
us on a retirement case. We need to know that it was sent, because
it is required by law. We need to know that the person was given their conversion privilege.
And if you do include the 2819, it’s going to A, need to be signed, as we discussed earlier,
as a new error. Or it needs to match that date on box nine.
If a 2819 is in there, it needs to be signed and match the date on box nine. If it’s not
there, we just need box nine completed. Another common error. Coverage doesn’t match the most
recent 2817 or SF-50. Again, you’re certifying coverage to us that is not supported in the
case file. It has to match that most recent 2817 or SF-50 that we have on file. Next one is “The alpha code doesn’t match
the IRR and the coverage in the case.” This is a payroll error. This would mean the alpha
code on the 2821 is wrong. That’s a payroll error. Still going in life insurance, but
now moving to the standard form 2818. Sometimes, that 2818 is missing. That’s an HR error. Sometimes, it’s not signed. That’s HR. I’m
sorry, it says “or payroll,” but I don’t believe payroll’s responsible for a 2818. The elected
coverage exceeds the permitted coverage. That means you’re letting someone elect to keep
four times their option B, for instance, when they only had three times. That’s a very common
error. In military service, the DD 214 or other documentation,
such as orders, is either missing. The character of service isn’t noted, and again, that’s
usually on that Member copy four. Or the post-’56 IRR, if it’s submitted with the package, is
not marked paid in full. Again, very common errors we see. With that, I believe I’ve presented everything
I would like to present. We’re going to hang on a few minutes and see if any questions
come through from Clyde. If I have questions, he’s going to read them to me. I’m going to
read them back, and we’ll answer them. If you think of questions later, still send
that same email box we showed earlier. Tell you what. I’m going to flash back to the email
box, just so you know where to send the questions. Or maybe not. Again, if you want to submit
a question, either now, to have me answer now, or if you want it to be answered later,
just send it to [email protected], with the subject line “Healthy Case Webinar Questions.” Clyde: First question up. “Can an employee
completely cancel their health insurance at retirement, for any reason?” Phil: The question is, “Can the employee cancel
their health insurance for any reason at retirement?” The answer is “Yes.” However, it either needs
to be done on an OPM 2809, or we have to send them a 79-9. Why? Because we want them to verify that they
want to cancel, and that it’s not because they’re going to be enrolled in someone else’s
plan, or because they’re actually suspending for one of the other programs. Medicare, Medicaid,
or Tricare. We want them to undersign the statement, saying
they understand if they cancel for a reason other than being covered by a spouse’s enrollment,
FEHB enrollment, that they understand that they’ll never be able to get the coverage
back. Unlike an employee. An employee can cancel
and later re-enroll. The danger of that is if they retire before they’ve been re-enrolled
for five years, they won’t be eligible to continue. An annuitant cannot cancel and re-enroll,
unless they’re canceling to be on someone else’s FEHB program. Yes, they can do it for
any reason. If it’s any reason except that, we need them to sign and say they understand
they can’t get it back. Clyde: What’s the name and number of the form
used for USPS non-deduction service? Phil: What is the name and the form number
used? USPS sends one of their own forms, called a PS-316. If it comes to us, and we don’t
still have those earnings, or let’s say you’re a non-postal agency, you can go to NPRC, request
the earnings search. I can tell you you’ll need to give them the period of service you
need searched. The position, because it’s very important to know the position. For instance, a sub-rural carrier, they have
to search more documents. It helps to have the location of the post office where they
worked. I don’t know what forms agencies have to do that. I know we have an RI form — I
apologize, I don’t know it off the top of my head — available on our website that we
send to the NPRC to get those. You need to go through whatever vehicle you
go through, to go to the NPRC, request the earnings. They need the employee’s name, Social
Security Number, period of service, the position or positions held, and the location of the
post office. Clyde: If part of an employee’s FEHB history
includes coverage under an already retired federal spouse’s FEHB plan, what’s the best
way to obtain proof of that coverage? Phil: The question is “If part of their coverage
for five years under FEHB includes a period of time when they were covered as a family
member of an annuitant?” If you can get a copy of that enrollment form
from them, that’s great. Otherwise, provide us with the other individual’s name, and if
you have it, their CSA claim number, or their date of birth, or their Social Security Number.
Then we can pull it out of their case. Clyde: Does a notary’s commission have to
extend past the retirement date? Phil: “Does the notary’s commission have to
extend past the retirement date?” No. It just has to have been active and valid at the time
the form was signed. Now, that said, about one year is stale-dated. If we get a notary
that was done more than a year before the date we received the package, and are reviewing
it, then it’s going to be stale-dated. Let’s say the notary signed something on November
30th. Person got their application in early, they signed on November 30, 2013. The person
retires December 31, 2013, and the notary expires sometime after they signed it, that’s
OK. Clyde: For common-law marriages, what if the
employee uses a common-law marriage to add a spouse to FEHB, but notates “not married
or never married” on the retirement application? Phil: The question is “What if someone enrolled
in FEHB and added a spouse, noting that it was a common-law, and then when they retire,
there is no spouse listed?” Keep in mind that a common-law marriage is a legal marriage. There’s no such thing as a common-law divorce.
You can’t just suddenly decide you’re no longer married. If you have legally established a
common-law marriage, it has to be annulled or a divorce, just like any other type of
marriage. Now, the question is, how do they respond
to that question? Do you have a former spouse entitled to either a share of your retirement
or a survivor annuity? They’re not. It can still be checked “no.” We might ask if someone’s
married, but the bottom line is, at the time of death, it could be a problem. If there was a prior spouse listed, person
dies, and now they’ve remarried, but never had a divorce from the common-law. I guess
my best advice here is to address that with them. Say, “I see that you had a common-law
marriage here that you put on the FEHB. What happened to that marriage?” If they say, “We just broke up,” if they didn’t
get legally divorced, then they are obligated to say they are legally married on the retirement
application, and to give that spouse’s information. And that they’re electing less than full annuity
to provide spousal consent. This is so much easier when there are actual people in front
of me. Clyde: This one’s a cousin of the other question.
“Is it considered an error if a marriage certificate is not submitted with the retirement application
for a married applicant?” Phil: I’m going to have to defer on that.
It shouldn’t be, because it’s not on our checklist. What’s done in practice and what’s on the
checklist, however, are two different things. I will defer on that, and double check with
our retirement development section to make sure of what we’re actually doing. That was
the chicken’s way out. [laughs] Clyde: One error is that the earnings are
required for USPS non-deduction service. If the information is not documented in the employee’s
personnel file, how would we obtain the information to ensure their healthy retirement package? Phil: Person has undocumented postal service.
You treat it like any other period of undocumented service. You would need to attempt to verify
the service. I can tell you for postal service, the best way to document it is to go to the
National Personnel Records Center and ask for an earnings search. Again, they need the name, Social Security
Number, position title, location of post office, and the period of service in question. If
you can’t get verification that way, you could do an OPF search, or you could do a records
search at NPRC. If the person still claims they have the service,
but it’s not verified, they can go to secondary evidence. Secondary evidence means that there’s
no documentation available. To do secondary evidence, they need an affidavit from themselves,
an affidavit from, say, a coworker, and a supervisor, and then any other sort of verification
that you can provide. Such as earnings from Social Security. Now,
earnings from Social Security alone won’t do it, because it doesn’t verify the actual
dates of the period of service. But if you had the earnings from Social Security records
in conjunction with affidavits that establish the date, then you could submit that. Unless we have any further questions that
come through in the next minute or so. Again, send your questions to [email protected] Subject
line “Healthy Case Webinar Questions.” We will respond individually to any that we don’t
get to during the webcast, or any that come in after the webcast. I want to thank everybody for bearing with
us, as we started late. I didn’t expect to end early, frankly, but without a live audience
there’s less questions, and kind of get to go right through the material. Again, I want
to thank everybody. My name’s Phil Gardner. I’m with the benefits office training and
development group, suppose should’ve told you that upfront. I’ve been a human resources
specialist here for over 10 years, but I’ve been in retirement for almost 37 years now. Again, be more than happy to answer any questions
that you have, just sent them to [email protected] with that subject line, “healthy case webinar
questions.” With that, thank you very much and have a very pleasant rest of your day.

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