MARADMIN 501/26: Marines Now File the $2,000 Adoption Reimbursement Through the PAO, Not DFAS

MARADMIN 501/26, released at 1518Z on October 15, 2026 and posted to marines.mil the next day, cancels MARADMIN 076/18 and announces "administrative process changes for Marines, Personnel Administrative Offices (PAOs) and Disbursing Officers/Finance Offices (DOs/FOs) in the reimbursement of qualifying adoption expenses." The dollar limits do not move: "up to 2,000 dollars per adoptive child or a maximum of 5,000 dollars per calendar year." Those figures are set by 10 U.S.C. 1052(e), and no message can change them. What changes is the path the claim takes. Under the 2018 message a Marine mailed or emailed the package to DFAS Cleveland. Under 501/26 the claim goes "via the Marine's chain of command to their servicing PAO," and the DO/FO "retains final approval authority" and pays it in the Document Tracking Management System. This is settled policy in force now, until it is folded into MCO 5000.12F or cancelled.

Why the Marine Corps took the claim in-house

The message's first reference is DoWI 1341.09 with Change 1, dated May 27, 2026. That change added "performance of adoption reimbursement functions through the Military Service's financial management system" to the Service Secretaries' duties, and the instruction now sends the approved claim "to the DFAS or appropriate Military Service financial management system for final approval and payment." MARADMIN 501/26 is the Marine Corps taking that option: the PAO builds the package, attaches a NAVMC 11116, "Miscellaneous Military Pay Order/Special Payment Authorization," and sends it to the DO/FO in DTMS.

What changed against MARADMIN 076/18

Two rows matter most. The DEERS rule means the dependency paperwork has to be finished before the claim can be submitted, so start DEERS the week the decree is signed. And general officer approval for a late claim is a higher bar than the FMR appendix sets for DFAS, which accepts a letter from the verifying official. For a Marine, plan on the 2-year clock being firm.

Who can claim, and until when

Paragraph 2 of the message: "Active duty and Reserve Marines who are called to active duty for 180 or more consecutive days may be reimbursed for qualifying adoption expenses for a child under 18 years of age. The adoption must be completed prior to the Marine separating from active duty." Married or single Marines can claim. If both parents serve, "only one member may be reimbursed" for the same child, and under the FMR appendix the couple shares one $5,000 calendar-year ceiling. Reserve Marines attach their active-duty orders so the PAO can verify the adoption was finalized inside a period of 180 or more consecutive days; the pay for that period is in our Reserve drill pay and basic pay tools.

The deadline is "no later than 2 years after the adoption of the child is finalized," or for a foreign adoption 2 years "from the date the certificate of U.S. citizenship is issued to the adopted child." A Marine who is separating must finalize the adoption and get the claim to the PAO before the separation date. The statute allows payment "only after the adoption is final," so a placement that has not reached a decree pays nothing yet, even though the child can already be in DEERS and TRICARE.

What the $2,000 can cover

The reimbursable list in paragraph 4 matches the statute and the FMR appendix: public and private agency fees, including foreign agencies; placement and counseling fees; legal fees and court costs; medical expenses "for the biological mother and medical care of the child to be adopted"; and temporary foster care charges required before placement. Paragraph 5 excludes "travel expenses and items such as clothing, bedding, toys, and books." Every claimed dollar needs "itemized receipts, cancelled checks, or agency letters." A $3,000 agency fee is fully documentable and still pays $2,000, because the cap is per child, not per expense.

1. 1DD Form 2675, one per child, from the Executive Services Directorate forms site named in the message.
2. 2The final adoption decree, certificate or court order, with an English translation if needed.
3. 3Proof the adoption was handled by a qualified or licensed agency: placement agreement, agency letter, or receipts that show the agency's status.
4. 4Itemized receipts, cancelled checks or agency letters for every expense claimed.
5. 5For a foreign adoption, proof of the child's U.S. citizenship.
6. 6For Reserve Marines, active-duty orders covering 180 or more consecutive days.

What $2,000 is worth by grade

The reimbursement is flat, so it is worth more to a junior Marine than to a field-grade officer. The table measures the $2,000 per-child payment and the $5,000 calendar-year cap against 2026 monthly basic pay from the DFAS table in our basic pay tool, using one-thirtieth of the monthly rate as a day of pay.

For a Lance Corporal the payment is two-thirds of a month's basic pay. It arrives as a single special payment, not on the mid-month or end-of-month pay, so it will not show as a recurring line when you check an LES in the LES Auditor.

The tax side of the same dollars

Section 137(c)(1) of the tax code treats "an adoption reimbursement program operated under section 1052 of title 10" as an adoption assistance program, the provision that keeps employer adoption benefits out of gross income, so the $2,000 is not added to taxable wages. The other side is section 23(d)(1)(D): the federal adoption credit counts only expenses "which are not reimbursed under an employer program or otherwise." For tax years beginning in 2026, Rev. Proc. 2025-32 sets that credit at qualified expenses up to $17,670 per adoption, $5,120 of it refundable, phasing out between $265,080 and $305,080 of modified adjusted gross income. The Sergeant above would carry $8,500 toward it. Check the withholding effect in our federal tax calculator.