Introduction
The Office of Personnel Management (OPM) announced on October 23, 2025, a 30-day public comment period for renewing the information collection associated with the Federal Employees Dental and Vision Insurance Program (FEDVIP) Enrollment System. Published in the Federal Register, Volume 90, Number 203, this notice seeks approval from the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1995. The system, known as BENEFEDS, serves as a secure online platform for eligible federal employees, retirees, and their families to enroll or modify coverage in dental and vision insurance plans. This renewal is essential for OPM to continue administering FEDVIP as mandated by 5 U.S.C. chapters 89A and 89B, and implementing regulations in 5 CFR part 894. The significance lies in ensuring efficient management of federal benefits while minimizing administrative burdens, with public input invited to assess the collection's necessity and accuracy.
Background and Legal Framework
FEDVIP was established to provide supplemental dental and vision insurance to federal employees, annuitants, and certain family members, complementing the Federal Employees Health Benefits Program. The program's enrollment is handled through BENEFEDS, an OPM-sponsored website that processes enrollments annually or during qualifying life events. This information collection, assigned OMB Control Number 3206-0272, requires periodic renewal every three years under the Paperwork Reduction Act (PRA) of 1995, as amended by the Clinger-Cohen Act. The PRA aims to reduce paperwork burdens on the public by requiring agencies to justify the need for data collection and estimate its impact.
OPM's current renewal request follows a 60-day comment period that ended on June 24, 2025, after an initial notice on April 25, 2025. During that phase, two comments were received. One addressed OPM's proposed changes to align forms with Executive Order 14168, issued by President Biden on June 26, 2024, which directs federal agencies to use binary sex markers (male or female) on forms and avoid requesting gender identity information. The commenter raised concerns about potential discrimination, mental health impacts, health equity, labor rights, digital accessibility for low-income and rural communities, enforcement transparency, and effects on federal workers' dignity. OPM acknowledged the input but noted its obligation to comply with the executive order's Section 3(e). The second comment suggested adopting a national health care system and banning private insurance, which OPM deemed outside the scope of this PRA activity.
This process underscores the PRA's role in balancing administrative efficiency with public accountability, drawing on precedents like the act's requirements for OMB oversight to prevent unnecessary data demands.
Key Players and Process
OPM acts as the primary agency responsible for federal employee benefits, including FEDVIP administration. The OMB reviews and approves information collections to ensure they meet PRA standards, focusing on practical utility, burden accuracy, information quality, and burden minimization. Public stakeholders, including federal employees and advocacy groups, participate through comment periods.
The renewal involves estimating the collection's burden: OPM projects 502,347 respondents annually, each taking about 7.03 minutes, totaling 58,775 burden hours. This data supports OPM's functions but invites scrutiny on whether automated technologies could further reduce this load. Comments are directed to reginfo.gov, with a deadline of November 24, 2025, allowing input on necessity, accuracy, quality enhancement, and burden reduction.
Implications and Perspectives
In the short term, approval would maintain seamless FEDVIP operations, ensuring millions of federal personnel retain access to benefits without interruption. Long-term, it could influence how agencies handle sensitive data like sex markers, especially amid debates on inclusivity versus standardization. Perspectives vary: proponents of E.O. 14168 argue it streamlines federal forms and aligns with biological definitions, potentially reducing confusion in benefits administration. Critics, as reflected in the received comment, view it as regressive, possibly exacerbating discrimination and mental health issues for non-binary or transgender individuals.
Broader political forces include ongoing tensions between executive directives and legislative oversight. For instance, similar PRA renewals have faced challenges in court, such as in cases where agencies were required to better justify burden estimates (e.g., precedents under 44 U.S.C. 3506). Without endorsing views, this renewal highlights debates on equity in federal policies, with potential ripple effects on other benefits programs.
Forward-Looking Conclusion
This OPM notice represents a routine yet critical step in federal benefits management, emphasizing compliance with paperwork reduction laws while incorporating public feedback. Key takeaways include the program's scale, the handling of executive order-driven changes, and opportunities for burden minimization through technology.