CERTIFICATION OF DEPENDENT TAX STATUS FOR PURPOSES OF COVERAGE
UNDER FEHB AND FEDVIP
The Office of Personnel Management (OPM) permits coverage under the Federal Employees Health
Benefits (FEHB) Program and the Federal Employees Dental and Vision Insurance Program (FEDVIP)
for the children of a same-sex domestic partner of a Federal employee or annuitant whom the employee
or annuitant would marry but for the fact that the law in his or her state of residence does not permit
same-sex marriage. For purposes of coverage under the FEHB and FEDVIP, and for purposes of this
document, such children are considered to be stepchildren. In order to enroll a stepchild in FEHB or
FEDVIP coverage, you must first file a Declaration of Domestic Partnership with your employing office
or retirement system. In addition, you must complete an SF 2809 form to first enroll or cover your
stepchild under an existing enrollment. Please contact your agency’s human resources office or your
retirement system for more information.
When you cover your stepchild under an FEHB or FEDVIP enrollment, the fair market value of the
stepchild's coverage, less any after-tax contributions you make toward the cost of that coverage, is
taxable income to you, UNLESS your stepchild qualifies as a dependent as defined in Internal Revenue
Code Section 152 (determined without regard to subsections (b)(1) (b)(2) and (d)(1)(B)) or a stepchild
as defined under state law who, as of the end of the taxable year, has not attained age 27, whether or not
that stepchild can be claimed as a dependent on your tax return. (See IRS guidance at
http://www.irs.gov/uac/Answers-to-Frequently-Asked-Questions-for-Registered-Domestic-Partners-and-
Individuals-in-Civil-Unions.)
(Note: there are no tax consequences for an annuitant whose stepchild is covered under FEDVIP,
because the entire premium is paid for by the annuitant with after-tax dollars.)
This additional income, referred to as imputed income, is subject to applicable Federal income and/or
employment taxes as well as state taxes. It will be reported on your annual Form W-2 or 1099-R.
Because imputed income is calculated on the fair market value of coverage provided, it will be applied
even if there is no additional monthly premium cost to you to cover your stepchild(ren) under your
FEHB or FEDVIP plan. The amount of your imputed income depends upon the plan in which you are
enrolled and the number of stepchildren covered who are not tax dependents.
(Note: Imputed income does not affect calculations for your other benefits such as life insurance or
retirement.)
If you are enrolled in premium conversion (i.e. making pre-tax employee contributions), the amount of
your premium conversion allotment will not change. However, the fair market value amount that will be
imputed to you will include that portion of your premium conversion allotment that is attributable to
coverage of your stepchild(ren) who are not your tax dependents.
Therefore, you will have imputed income and will be taxed on the amount your employing agency
or retirement system contributes to provide FEHB and/or FEDVIP coverage for each of your