1. Home
  2. |Insights
  3. |OPM Publishes FAQ on FEHBP Medical Loss Ratio

OPM Publishes FAQ on FEHBP Medical Loss Ratio

Client Alert | 1 min read | 08.30.12

The U.S. Office of Personnel Management (OPM) published a letter and FAQ for federal employees regarding the ACA-mandated Medical Loss Ratio (MLR) for Federal Employees Health Benefits Program (FEHBP) plans in an August 22, 2012 Benefits Administration Letter. The FAQ explains the basic framework of the MLR standard and clarifies that:

  • whether an FEHBP plan owes a rebate is determined based on all of a carrier’s line of business (e.g., large group) within a given state;
  • any rebated owed by an FEHBP plan shall be paid directly to OPM, the policyholder for all FEHBP plans, as required by FAR §31.201;
  • any rebate paid by an FEHBP plan shall be deposited into the contingency reserve of that health plan and shall be used to directly reduce the cost of the next year’s premiums for that plan; and
  • FEHBP enrollees will receive a notice from their plan indicating whether the plan did or did not meet the MLR standard.

Insights

Client Alert | 2 min read | 02.03.26

CMS Doubles Down on RADV Audit Changes

On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025....