USPS ELM Revision: Special Circumstances Affecting Health Insurance Coverage

Effective September 12, 2019, the Postal Service™ is revising the Employee and Labor Relations Manual (ELM), sections 525.1 and 525.2, to align with updates dictated by the Office of Personnel Management (OPM).

Other revisions include updating references to the Human Resources Shared Service Center (HRSSC) and the Self Plus One enrollment option.

Although the Postal Service will incorporate these revisions into the ELM at a later date, the standards are effective immediately.

Employee and Labor Relations Manual (ELM)

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5 Employee Benefits

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520 Health Benefits Program

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525 Special Circumstances Affecting Health Insurance Coverage

[Revise the text of the Reference Note to read as follows:]

Note: For additional information on subject matter in 525.1 and 525.2, see the Office of Personnel Management’s Federal Employees Health Benefits Handbook at

525.1 Office of Workers’ Compensation Programs

525.11 Requirements to Continue Enrollment

525.111 Employee

[Revise the text of 525.111 to read as follows:]

Office of Workers’ Compensation Programs (OWCP), an office within the U.S. Department of Labor, is responsible for determining employees’ eligibility to continue health benefits enrollment if employees are receiving workers’ compensation. The following rules apply:

a. Employees’ health benefits enrollment (and coverage of family members under a family enrollment), as well as enrollment of surviving beneficiaries, continue if employees enter on the compensation rolls of the OWCP, provided they meet the following requirements, according to the U.S. Department of Labor:

(1) The employee is receiving compensation (which OWCP determines).

(2) The employee is unable to return to duty (which OWCP determines).

b. If the employee meets the requirements under 525.111a, while receiving compensation, the employee may continue enrollment during the first 365 days of leave without pay (LWOP). After that period, the employee must meet participation requirements for continuing enrollment after retirement: continuous enrollment (or coverage as a family member) in any FEHB plan(s) for the 5 years of service immediately before the date compensation starts, or for the full period(s) of service since the employee’s first opportunity to enroll (if less than 5 years).

Example: An enrollee was for a time covered as a family member under the Uniformed Services Health Benefits Program.

525.112 Survivor

[Revise the text of 525.112 to read as follows:]

Enrollment of a deceased employee continues for surviving family members if the following requirements are met:

a. The deceased employee was enrolled in Self Plus One or Self and Family at the time of death.

b. At least one of the covered family members receives compensation as a surviving beneficiary under the Federal Employees’ Compensation Act.

OWCP determines whether any survivors are eligible and wish to continue the enrollment, and continues or terminates the enrollment as appropriate. If survivors elect to receive survivor annuity in lieu of compensation, OWCP transfers the enrollment to the Office of Personnel Management (OPM) for processing.

525.12 Transfer of Enrollment

525.121 Transfer to OWCP

[Revise the text of 525.121 to read as follows:]

HRSSC transfers an employee’s enrollment to OWCP when one of the following occurs:

a. OWCP requests the transfer;

b. The employee has been on leave for 10 consecutive months without pay status, and OWCP has not requested transfer; or

c. The employee separates from service before OWCP requests the transfer.

Until the enrollment transfers, the Postal Service treats the employee receiving compensation, but no salary, as any other employee in nonpay status, for health benefits purposes. Enrollment continues up to and including 365 days. Then HRSSC terminates enrollment if the employee is not eligible to be transferred to OWCP.

525.122 Transfer Back to Employing Office

[Revise the text of 525.122 to read as follows:]

When an employee who transferred to OWCP returns to pay status, OWCP transfers the employee’s enrollment to the employing office. OWCP will transfer the enrollment by letter, transmitting the health benefits documentation and providing the date compensation ended.

If the employee is eligible for continued coverage, the enrollment transfer will include a completed SF 2810, Notice of Change in Health Benefits Enrollment. The effective date of the transfer is the day after compensation terminated. If the employee is not eligible for continued coverage, HRSSC will complete a SF 2810, terminating the enrollment effective on the date that compensation ended.

525.13 Withholding and Contribution by OWCP

525.131 Effective Dates

[Revise the text of 525.131 to read as follows:]

Whether or not OWCP requests enrollment transfer, OWCP makes health benefits withholdings and contributions from the date compensation began, or the date following that on which the employing office withholdings and contributions ceased, whichever is later. OWCP makes no withholdings or contributions when an employee receives compensation for less than 29 days.

However, the employee is still responsible for payment of the premiums. Withholdings and contributions cease when an enrollment is terminated because the person has been in nonpay status for 365 days. After that period, the employee is not eligible to continue enrollment.

525.132 Health Benefits Refund Program

[Revise the text of 525.132 to read as follows:]

The following provisions apply:

a. Explanation. The Health Benefits Refund Program is designed to reimburse injured employees for an overdeduction of health benefits premiums by the OWCP. For the first year of compensable disability, OWCP deducts health benefits premiums at the Postal Service rate. Thereafter, the deduction is made at the standard rate that the Office of Personnel Management (OPM) applies for federal employees.

The OPM premium rate may be higher than the Postal Service rate. Therefore, Postal Service employees enrolled in a health benefits plan and who are in LWOP status for over 1 year and also receiving OWCP compensation may be due a refund for overdeduction of health benefits premiums.

b. Eligibility for Refund. To be eligible for a health benefits refund, the employee must meet all of the following criteria for the period of compensable disability:

(1) The employee must be in a LWOP or injury-on-duty status. Employees who are separated from the Postal Service are not eligible.

(2) The employee must receive OWCP compensation payments with health benefits premiums deducted at the OPM rate.

(3) At least 1 year must have elapsed since the U.S. Department of Labor initially placed the employee on OWCP compensation.

c. Verification of Eligibility. The Postal Service uses the Injury Compensation Performance Analysis System (ICPAS) Health Benefits Report to verify information in a completed PS Form 202, Health Benefits Refund Payment Authorization.

d. Refunds. After verifying an employee’s eligibility, Health and Resource Management (HRM) must take the following steps to process the refund:

(1) Initiate quarterly a PS Form 202, Health Benefits Refund Payment Authorization (see Exhibit 525.132). In calculating the amount of refund to be paid, ICPAS will subtract the difference between the OPM health benefits premium rate and the Postal Service rate of the health benefits plan that the employee chose.

(2) Print the PS Form 202, verify the information, and obtain the district manager’s or designee’s approval.

(3) Complete PS Form 2551, Non-Goods and Services, using the current online process.

(4) Submit completed PS Forms 2551 and 202 for payment to the Eagan Accounting Service Center, using General Ledger Account (GLA) 51209, H.B. Premiums — Workers Comp Claimants.

(5) File the original PS Form 202 in the employee’s “Injury Compensation” file and send one copy to the employee.

(6) The Eagan Accounting Service Center will forward the refund to the employee.


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