RFI for FEHB Protection Act.pdf

Request for Information: FEHB Protection Act of 2025

Through this Request for Information (RFI), the U.S. Office of Personnel Management (OPM) seeks industry collaboration in evaluating potential options for implementing the FEHB Protection Act of 2025. Please submit your responses by December 15, 2025 no later than 5:00 pm Eastern time to cep@opm.gov.

This RFI is issued for information and planning purposes only. This IS NOT A REQUEST FOR PROPOSALS (RFP) and does not restrict the Government as to its ultimate acquisition approach. The Government will not reimburse respondents for any costs incurred in preparation of a response to this notice.

A. BACKGROUND

OPM administers the Federal Employees Health Benefits (FEHB) Program, which is the largest employer-sponsored health benefits program in the country with approximately 8.3 million covered lives, including about 1.9 million spouses and 2.1 million children.1 The FEHB Program covers employees across the Executive, Legislative, and Judicial branches; the United States Postal Service; retirees under multiple retirement systems; survivor annuitants; former spouses; temporary continuation of coverage (TCC) enrollees; employees of eligible Tribal organizations; and other eligible groups.

Under the FEHB Protection Act, OPM must conduct a comprehensive audit (between July 4, 2026 – July 4, 2029) to verify the eligibility of family members covered under the FEHB Program. OPM is also responsible for implementing an ongoing process to ensure the veracity of any qualifying life event or Open Season election whereby an enrollee adds a family member to his or her plan. Family members eligible under the FEHB Program are defined in law at 5 U.S.C.

8901 and 5 C.F.R. 890.302. The documentation required to verify family members is listed on OPM’s website.

Enrollment in the FEHB Program is complex and decentralized as it relies on employing offices, payroll providers, and FEHB Carriers to process enrollments. Enrollment in the PSHB Program occurs in a centralized platform, the PSHB System. OPM is seeking an automated verifications solution to ensure consistent and timely verification of family member eligibility for purposes of both a centralized baseline audit and continuous verifications. Such an approach would leverage automated processing and artificial intelligence (AI) to verify the large volume of family members that are covered under the FEHB Program.

B. PRELIMINARY OPTIONS AND MARKET RESEARCH OBJECTIVES

Preliminarily, OPM is evaluating several approaches to strengthen FEHB program integrity and streamline family member verification. Potential approaches under consideration include:

1 For purposes of this RFI, the term “FEHB Program” includes the Postal Service Health Benefits (PSHB) Program established under 5 U.S.C. 8903c. The approximate number of covered lives includes covered lives under both the FEHB Program and the PSHB Program.

https://www.congress.gov/119/plaws/publ21/PLAW-119publ21.pdf#page=292 https://www.congress.gov/119/plaws/publ21/PLAW-119publ21.pdf#page=292 mailto:cep@opm.gov https://www.opm.gov/retirement-center/publications-forms/benefits-administration-letters/2021/21-202a2.pdf

1. Engaging a single vendor to deliver an end-to-end, comprehensive audit solution that leverages automated verification. The vendor could exercise one or more sources of information: existing OPM data2 that contain information on enrollees and family members; data from FEHB carriers; or a secure portal that allows enrollees to upload supporting documentation.

2. Procuring modular components, such as separate automated verification services that can be integrated in real-time through open standards (e.g., APIs or web services).

3. Building a centralized, OPM-managed platform that incorporates vendor-provided automated verification (e.g., integrating data and process automation, data matching, or AI capabilities) in OPM’s environment.

Across all approaches, OPM is particularly interested in solutions that integrate AI, computer matching with authoritative data sources, and continuous verification to ensure cost-effective, sustainable, data-driven oversight.

OPM is conducting market research to identify qualified vendors with capabilities to support the approaches noted above. OPM seeks information on vendor capabilities to:

1. Conduct large-scale automated verifications for purposes of family member eligibility verification audits (also known as dependent verification audits) across different populations, including employees and annuitants (retirees), that submit a variety of documents.

2. Implement automated verification technologies, including AI, document recognition, and real-time or batch data matching.

3. Connect with federal and external data sources (e.g., Social Security Administration, Internal Revenue Service, vital records offices) to help augment or verify family member data in both real-time or batch.

4. Provide and configure web portals, including workflows or case management capabilities, for enrollees or family members to upload documents. Administrators should have the capability to monitor automated verifications, verify documents manually if needed, and process reconsideration requests (or appeals).

5. Integrate web portals with Identity and Access Management systems supporting Identity Assurance Level 2 (IAL-2) access provisions.

6. Provide member support and conduct any outreach as needed.

7. Generate and mail notices to members as required to submit verification documents.

8. Scan any mailed in paper documents and use Optical Character Recognition (OCR) to digitize and index these documents.

9. Integrate with OPM systems to extract latest data, record successful verifications and transmit terminations to Carriers and employing offices.

10. Software or any services must be delivered in the United States (workforce and servers on

United States soil).

C. REQUESTED INFORMATION (Provide if applicable)

1. Company Profile

2 For example, see OPM/Central-23 FEHB Program Enrollment Records.

https://www.federalregister.gov/d/2024-20061

• Legal name, corporate address, business size, unique entity identifier (UEI), and North American Industry Classification System (NAICS) code(s).

• Key contacts’ name, title, email address, and telephone number.

• If applicable, indicate GSA Multiple Award Schedule (MAS).

2. Audit methodology: How would you design and execute a three-year comprehensive audit (July 4, 2026 – July 4, 2029) that contemplates all FEHB family members?

3. Technical Capabilities:

• Description of current or past work performing automated verifications for large-scale clients, including family member eligibility verification.

• Description of AI and automation tools used for document classification, verification, anomaly detection, and communication. Please highlight any examples of real-time verification capabilities.

• Description of the type of automated verifications exceptions encountered and approaches to identify and handle exceptions including the ability to enhance automation. Description of automated verifications exception management, human review processes, and audit trail features as well as any feedback loops and ability to self-correct to enhance automation.

• Description of web portals, including workflows or case management capabilities, for enrollees or family members to upload documents. Administrators should have the ability to monitor automated verifications, verify documents manually if needed, and process reconsideration requests (or appeals).

• Description of identity and access management strategies to safeguard customer information in accordance with Federal standards while making customer login as frictionless as possible.

• Description of customer engagement services and tools used to support automated verifications. For example, send customer notices or reminder alerts, field incoming calls, make outgoing calls if follow-up is needed.

• Description of unified communication channels that facilitate communication with enrollees, employing offices, carriers, and OPM.

• Description of how mailed-in paper documents are handled and fed into the Automated Verifications process (e.g., scanning, OCR, indexing).

• Description of how automated verifications solution can be integrated with other OPM systems to extract latest data, record successful verifications and transmit terminations to Carriers and employing offices.

• Description of automated verifications hosting and managed services options as well as ability to deploy the solution (or parts of the solution) in OPM’s cloud. Please describe current security compliance levels including FedRAMP for services hosted in vendor’s cloud environment.

• Description of automated verifications dashboards, reporting tools and analytics used to track verifications progress with example KPIs.

4. Data Sources and Integration

• Partnerships or access to authoritative data sources (Social Security Administration, Internal Revenue Service, vital records offices, or commercial verification databases).

• Methods used for secure data exchange (such as API, batch, SFTP).

• Compliance with data privacy and security standards including but not limited to

Federal Information Security Modernization Act (FISMA), FedRAMP, NIST SP 800‑53 Rev 5, NIST SP 800-63, and Privacy Act of 1974.

5. Audit management

• Experience designing and managing large-scale verification programs, including family member eligibility verification audits.

• Methodologies for ensuring accuracy, minimizing false rejections, and documenting audit results.

• Dashboards or reporting tools.

6. Implementation approach

• Typical implementation timeline and key milestones.

• Typical vendor staffing model and key resource requirements.

• Vendor expectations for OPM resource requirements and support needed.

• Scalability considerations for populations throughout the United States, including its territories, along with populations having foreign duty stations.

• Lessons learned from previous large-scale family member verification efforts.

• Customer service and human-centered design elements employed to enhance the customer experience and minimize customer abrasion.

7. Verification Application

• OPM is interested in solutions capable of operating in concert with OPM infrastructure, security, privacy, accessibility, and network policies. Describe how you would design and implement a custom-built verification application and include information about the architecture model. Please assume that OPM will own all new intellectual property rights for this application, instead of paying a subscription fee for the application.

8. Pricing

• High-level pricing structure (e.g., per transaction, per record, per audit, or fixed fee).

• Licensing fees if any.

• Cost drivers and variables affecting pricing.

• Rough order of magnitude pricing ranges.

D. SUBMISSION INSTRUCTIONS

By December 15, 2025 at 5 pm Eastern, respondents should submit a single pdf file with a total suggested length of ≤15 pages + appendices. Clearly mark proprietary content. OPM will protect such information consistent with applicable laws and regulations. Email the file to cep@opm.gov with subject “RFI Response – FEHB Protection Act – [Company Name]” by December 15.

Each file should have the following elements:

1. Cover Page (1 page): Company information and points of contact(s)

2. Executive Summary (≤2 pages)

3. Capabilities (≤12 pages)

4. Appendices (optional): Case studies, architecture diagrams, sample dashboards, references.