FAQs - Dependent Eligibility Verification

Project Background
Determining Eligibility
Amnesty Period
Verification Period
Supporting Documentation
Enrollment Scenarios
Disenrollment Process
More Information

Project Background

What is the Dependent Eligibility Verification project?

The Dependent Eligibility Verification (DEV) project is an effort to verify the eligibility of currently enrolled dependents receiving CalPERS health benefits. The DEV project requires active employees and retirees to provide documentation to our contracted vendor, HMS Employer Solutions (HMS), supporting their dependents' eligibility for CalPERS health coverage. Prior to the verification period, CalPERS offered an amnesty period for subscribers to voluntarily disenroll any ineligible dependents from their plans. Amnesty ended June 30, 2013.

Why is the DEV project important to CalPERS and employers?

CalPERS is sensitive to the rising costs of health care for its employers and subscribers. Removing ineligible dependents from coverage will help CalPERS contain health care cost increases and promote the sustainability of our health benefits.

Who is conducting the DEV project?

CalPERS has contracted with outside vendor HMS on this project. HMS will verify dependent eligibility by reviewing supporting documentation submitted by subscribers. HMS is an independent company that specializes in verifying health plan eligibility for some of the largest employers in the United States. HMS has performed more than 800 verifications and reviewed documentation for more than 3.3 million dependents.

Who is required to participate in the DEV project?

All active and retired CalPERS health plan subscribers with one or more dependents will be required to participate.

Determining Eligibility

Who are, and are not, eligible dependents?

Eligible Dependents:

  • Current spouse/registered domestic partner
  • Natural, adopted, step or registered domestic partner's children up to age 26
  • Disabled children of any age if they were enrolled prior to age 26
  • Children up to age 26 for whom the subscriber has assumed a parent-child relationship and is considered the primary care parent. Note: CalPERS will ask subscribers to supply various forms of documentation to certify this relationship.

Ineligible Dependents:

  • Former spouse/registered domestic partner even if the subscriber was court ordered to provide ex-spouse/former domestic partner with health coverage
  • Children age 26 and older
  • Children of former spouses/registered domestic partners
  • Disabled children age 26 or over who were not enrolled prior to age 26
  • Relatives such as grandchildren, grandparents, parents, aunts, uncles, nieces, nephews, etc.
  • Foster children
  • Anyone already enrolled in a CalPERS health plan through another subscriber
  • Spouses/domestic partners of adult children
  • Live-in boyfriend or girlfriend and his/her children.

Amnesty Period

What is an amnesty period?

An amnesty period is a specified period of time, prior to dependent verification, when active and retired health plan subscribers could identify any ineligible dependents to be removed from their health plan on a prospective (future) basis. California Code of Regulations (CCR) section 599.506 (d) provided the CalPERS Board of Administration (Board) the authority to grant amnesty to CalPERS members who removed ineligible dependents prior to June 30, 2013; however, amnesty does not limit an employer from taking further action, if applicable.

When is the amnesty period?

The amnesty period ended June 30, 2013.

What if an employee has an ineligible dependent who is currently receiving ongoing medical treatment? How can the employee prevent a lapse in health coverage for their dependent?

CalPERS will offer COBRA coverage for dependents removed during the amnesty and verification periods. The employee, or their dependent, will be responsible for payment of all premiums, including administrative costs, for COBRA coverage.

Verification Period

What is the verification period?

The DEV period is a specified period of time during which active and retired health plan subscribers will be asked to provide supporting documentation for all dependents enrolled in their health plan.

When does the verification period begin and end?

Due to the large volume of enrolled dependents, verification will occur over nine cycles between July 2013 and the spring of 2015. Participating agencies for each cycle are selected at random. When your agency's verification cycle starts, HMS will send a detailed verification letter to your employees with instructions and due dates for submitting supporting documentation for their enrolled dependents. The dates for the nine cycles are outlined below:

Category Cycle # Date HMS Letter
Will Be Mailed
Deadline to Submit
Documents to HMS
State Actives Cycle 1
Cycle 2
Cycle 5
Jul 26, 2013
Sep 17, 2013
Apr 1, 2014
Sep 12, 2013
Oct 31, 2013
May 20, 2014
State Retirees Cycle 3
Cycle 4
Dec 2, 2013
Feb 4, 2014
Jan 21, 2014
Mar 24, 2014
Public Agency Actives Cycle 6
Cycle 7
Jun 2, 2014
Aug 1, 2014
Jul 21, 2014
Sep 19, 2014
Public Agency Retirees Cycle 8 Oct 1, 2014 Nov 20, 2014
School Actives & Retirees Cycle 9 Dec 1, 2014 Jan 20, 2015

Note: This timeline may be subject to slight changes.

How can employers prepare for the upcoming verification period?

Employers should log into my|CalPERS to verify that their HBO contact person is listed under "Contact Type" in my|CalPERS as either a "General" or a "Health Benefits Officer" contact, with email addresses and contact information. HMS will use this information to create a log in for your designated staff to access the project website. From this website, employers will be responsible for downloading reports, such as those identifying ineligible dependents to be disenrolled, so it is important that all your HBO contact information is updated and current before your verification cycle begins.

Will employers be provided with training regarding the disenrollment process during the verification period?

Yes. Prior to the start of your agency's verification cycle, HMS will offer in-depth training webinars to give you more detailed information about the verification process; walk you through how to navigate HMS's secure web portal; show you how to download termination reports and track the status of your verification; and prepare you to answer employee questions. In advance of these webinars, HMS will email your designated contacts, listed under "Contact Type" in my|CalPERS as either a "General" or a "Health Benefits Officer," with cycle-specific webinar dates and information on how to register. Any staff needing access to the DEV website must be listed in my|CalPERS with up-to-date email addresses and contact information. To ensure that HBOs are notified of these webinars and are able to access the project website, employers should update their HBO's name and email address in my|CalPERS.

How can we help employees prepare to verify their enrolled dependents?

You can advise employees to begin gathering supporting documentation for all eligible dependents enrolled in their health plan. Employees will be asked to provide this documentation during the verification period.

Supporting Documentation

What are the required documents that employees must provide during the verification period?

The table below indicates the required documents for each eligible dependent. All required documents MUST include date and/or year, employee's name and dependent's name.

Eligible Dependents Required Documentation
Current spouse A copy of the employee's marriage certificate AND one of the following: a copy of the front page of the employee's 2013 federal or state tax return confirming the dependent is their spouse OR a document dated within the last 60 days showing current relationship status such as a recurring household bill or statement of account. The document must list the employee's name, their spouse's name, the date and their mailing address. Note: Proof of common residency is for the purpose of establishing current relationship only. Common residency is not a CalPERS requirement for health benefits eligibility.
Current registered domestic partner A copy of the employee's Declaration of Domestic Partnership AND one of the following: a copy of the front page of the employee's 2013 state tax return OR a document dated within the last 60 days showing current relationship status such as a recurring household bill or statement of account. The document must list the employee's name, their partner's name, the date and their mailing address. Note: Proof of common residency is for the purpose of establishing current relationship only. Common residency is not a CalPERS requirement for health benefits eligibility.
Natural, adopted, step or domestic partner's children up to age 26 A copy of the child's birth certificate (or hospital birth record) or adoption certificate naming the employee or their spouse as the child's parent OR a copy of the court order naming the employee or their spouse as the child's legal guardian.
Note: For a stepchild the employee must also provide documentation of their current relationship to their spouse or domestic partner as requested above.
Children up to age 26 if the employer has certified that the employee has assumed a parent-child relationship and is the primary care parent A copy of the front page of the employee's 2013 federal or state tax return confirming the dependent OR a copy of the court order naming the employee or their spouse as the child's legal guardian OR day care receipts or school records which indicate the child resides at the employee's current mailing address, if applicable.
Certified disabled dependent children of any age Not applicable. CalPERS will not be asking for documentation for these dependents during the DEV project.

Does the employee need to send original documents?

No. Please do not have the employee send original documents; copies are sufficient.

During the verification period, what happens if employees submit supporting documentation to their Human Resources office?

Employees should submit the documents directly to HMS. Since this is an independent verification, employers are instructed to direct all calls and inquiries to HMS, and to destroy all documentation submitted directly to their HR department. HMS will send employees a letter asking for supporting documentation, and will follow up with them throughout the verification process.

What will HMS do with the employee-provided documents?

HMS will scan employee documentation into a secure database and check that employees have submitted the necessary documentation for all dependents. Once this is complete, HMS will shred the copies through a certified destruction process. At the end of the project, HMS will securely remove and destroy all documents saved in the database.

What happens if documentation is not provided for an employee's dependent(s) during the verification process?

If employees do not submit proper dependent verification documentation within the alotted timeframe, employers are to remove their dependent(s) from their health plan.

How will employers know which dependents are to be disenrolled from coverage?

Once HMS collects supporting documentation from health plan subscribers to verify dependent eligibility, they will develop an Ineligible Dependent Report identifying those dependents that are not eligible and should be disenrolled from coverage. Employers will be able to access these reports from HMS's secure website. Based on the reports, HBOs are responsible for removing ineligible dependents of active employees in a timely manner; CalPERS will remove ineligible retiree dependents.

What happens if an employee provides documentation after the dependents are disenrolled?

If employees have documentation to submit after their cycle ends, they must submit it to their employer. If the employee provides acceptable documentation, they may re-enroll their verified dependent(s) using the new DEV reason code 219, “Dependent Eligibility Verification Re-Enrollment,” available as of January 26, 2014. Or, upon the employee’s request, CalPERS can rescind the health enrollment transaction if documentation is provided within 90 days of the disenrollment to prevent a lapse of coverage. If documentation is received after 90 days of the disenrollment, the employer must process a re-enrollment of the dependent for the employee on a prospective basis.

How can employees communicate with HMS about the DEV project?

Once an employee's specific verification cycle begins, they can refer back to their verification letter for HMS's contact information. They can contact HMS through a secure employee website, by mail at P.O. Box 1587, Jeffersonville, IN 47131-9980 or through their customer service center. However, employees should wait until they receive their verification letter before attempting to contact HMS.

Once a verification letter is received, employees are encouraged to log into the HMS secure website, where they can obtain answers to their questions, find out how to locate required documents, review statuses, complete forms and upload documents. Once on the website, employees should provide HMS with their email address, so that they can communicate directly with an eligibility verification specialist and send and receive communications in a secure and timely manner.

Are employers being assessed as part of the DEV project?

No. This project will focus on the dependents of CalPERS health plan subscribers only, not on employers.

We are a public agency or school district and recently completed a dependent eligibility verification on our employees. Can we be exempt from CalPERS verification?

No. We are no longer accepting employer exemption requests. In order to have qualified for an exemption, CalPERS needed to review the Employer Exemption Request form and the data from your audit prior to the start of the public agency and school cycles. As the public agency cycles have started, we can no longer honor requests for exemptions.

Note: CalPERS reserves the right to make the final decision whether to exempt an employer from the DEV project.

Enrollment Scenarios

What should I do if my child will turn 26 during the verification period (July 1, 2013 – Spring 2015)?

It depends on when your child will turn age 26 during the verification period. If your child's birthdate coincides with your verification cycle, then s/he will be automatically disenrolled upon turning age 26 and no documentation is needed. If your child's birthdate is after your verification cycle (e.g., 6 months after your verification cycle), you will need to provide supporting documentation now to ensure s/he does not get deleted from health coverage prior to turning age 26.

During this verification, one of my dependents obtained health coverage through another provider and I wish to remove him/her from my health plan. What should I do?

If you need to remove a dependent(s) because of a “permissive qualifying event” (e.g., family member obtains other group coverage, family member enters military, custody change for child under age 18, or child reaches age 18), active employees should contact their HBO immediately and retirees should contact CalPERS. Your dependent should be removed due to a qualifying permissive event and not due to ineligibility found during the verification period.

I have a parent-child relationship dependent and just received a request from CalPERS to recertify my parent-child relationship. Do I need to resubmit an Affidavit of Parent-Child Relationship (HBD-40) as supporting documentation for my dependent?

No. The DEV project is separate and distinct from the recertification process for dependents in a parent-child relationship. If you have received a recertification notice, please follow those steps and submit it to your employer or CalPERS accordingly. For the DEV project, current tax records, court orders, and day care receipts are sufficient forms of documentation to support the eligibility of your parent-child relationship dependent.

I have a dependent that I need to remove from my health benefits plan due to a qualifying event and have received a verification letter from HMS to remove any ineligible dependents. What should I do?

Active employees should notify their HBO immediately of any qualifying event that occurs during the verification period, such as divorce, family member enters military, or custody change for child under age 18. Retirees should notify CalPERS of any qualifying event. In these instances, your dependent should be removed due to a qualifying event and not due to ineligibility found during the verification period.

Disenrollment Process

What are the DEV project reason codes?

  • Code 326 (Amnesty Disenrollment) – Used by employers through June 30, 2013 to disenroll dependents at the employee's request. Note: This code is deactivated now that amnesty has ended.
  • Code 327 (Dependent Eligibility Verification) – Available to employers from July 1, 2013 through June 30, 2015 to disenroll ineligible dependents based on verification findings. HMS will provide reports that identify ineligible dependents via their secure website.
  • Code 173 (COBRA Dependent Eligibility Verification) – Available to employers and CalPERS staff from the start of the amnesty period through June 30, 2015 to enroll dependents in COBRA coverage who were disenrolled through codes 326 and 327.
  • Code 219 *NEW* (Dependent Eligibility Verification Re-Enrollment) – Available to employers from January 26, 2014 through June 30, 2016 to re-enroll only dependents who had been disenrolled during their verification cycle under the “Dependent Eligibility Verification” reason code (RC 327) and whose supporting documentation has since been accepted by the employer.

What disenrollment dates should be used to remove dependents?

  • Verification Period

    • Event date and received date (for disenrollments)* = Date the HBO receives the Ineligible Dependent Report from HMS
    • Event date and received date (for rescissions and re-enrollments)* = Date the HBO receives dependent verification documentation
    • Effective date (for disenrollments and re-enrollments) = First of the month following the date received

    *We understand there may be various qualifying events identified during the verification period. In those circumstances (e.g., divorce, dissolution of domestic partnership) the existing reason codes in the system may be used to remove ineligible dependents. This will be on a case-by-case basis at the discretion of the HBO. Employees will be asked to contact HBOs if they have permitting enrollment events outside of the verification process.

  • COBRA Enrollment

    • Event date = Date of disenrollment
    • Received date = Date of disenrollment
    • Effective date = Date of disenrollment

When disenrolling an ineligible dependent from health coverage, should the ineligible dependent be disenrolled from dental and vision coverage, as well?

Yes. The ineligible dependent for health benefits will also be ineligible for dental and vision benefits and must be disenrolled from the dental and vision benefit programs. HBOs must process these disenrollments per PML 2013-020, issued by CalHR on July 9, 2013.

More Information

Where can I get more information on who is eligible and ineligible for the CalPERS Health Benefits Program?

More information is available in the "Eligibility and Enrollment" section of the CalPERS Health Program Guide for 2014 (HBD 120) (PDF, 285 KB).

If I have further questions, who can I contact?

You may email HMS. You may also contact HMS through a secure website, or by mail at P.O. Box 1587, Jeffersonville, IN 47131-9980.

Dated: 07-28-2014