Comment from Tom O'Meara
AnonymousSupportIndividual
Summary: The commenter supports the proposed action but suggests specific improvements to the form's design to enhance clarity and reduce the administrative burden on federal employees. They recommend splitting beneficiary tables, removing the witness requirement, enabling electronic signatures, and reconsidering the necessity of collecting Social Security numbers for beneficiaries.
OPM should redesign the form to enhance the clarity of the information provided and minimize the burden of the collection of information. If OPM is unable to minimize the collection burden, it should update the estimated time required to comply with the information request.
First, OPM should redesign the form to enhance the clarity. It is unclear how to distribute FEGLI benefits among multiple contingent beneficiaries. It is quite common for individuals with multiple siblings or step-parents to want to break up contingent beneficiaries.
OPM should redesign the form and break up the single beneficiary table for all situations into three different beneficiary tables to allow individuals to accurately and confidently designate primary and contingent beneficiaries or trust account beneficiaries. This change would allow judges and courts to more accurately understand the FEGLI participant’s designations if issues arise after a claim is made.
The first table would allow individuals to only designate primary beneficiaries. The second table would only allow individuals to designate contingent beneficiaries. The third table would allow individuals to designate a primary trust or will. The instructions would clearly state how individuals should fill out the primary or trust tables as well as the contingent beneficiaries table.
Secondly, OPM should consider whether 5 CFR 870.802 should be modified to remove the witness requirement. Most private sector employers don’t require employees to have witnesses to change beneficiary forms. This requirement hinders the ability of individuals to update their forms following major life events. This barrier has become even larger as telework has become more prevalent.
Thirdly, OPM should ensure the form has electronic signature capabilities.
Fourthly, OPM should consider whether Social Security numbers should be required for beneficiaries. Individuals are more cautious than ever regarding their SSNs and potential beneficiaries might not trust OPM following recent data breaches with this data. Name, relationship, date of birth, and address should be sufficient for OPM and any courts to determine who should receive any life insurance benefit.
Finally, OPM should update the burden to account for the time necessary to sign the form with two witnesses.