United States 

Office of Personnel Management 

The Federal Government’s Human Resources Agency

Benefits Administration Letter

Number: 16- 204 Date: March 17, 2016

Subject: Federal Employees’ Group Life Insurance Program (FEGLI) 

Life Insurance Open Season Guidance 

Purpose 

The FEGLI Program will have a life insurance Open Season from September 1, 2016 through 

September 30, 2016. 

The purpose of this Benefits Administration Letter (BAL) is to provide detailed guidance about 

conducting the FEGLI 2016 Open Season. 

ELIGIBILITY FOR PARTICIPATION 

Who Is Eligible to Participate in the Open Season? 

All employees who are eligible for the FEGLI Program can participate. 

Who is Not Eligible to Participate in the Open Season? 

Employees excluded from FEGLI coverage by law or regulation on or after September 1, 2016 

cannot participate. If you need more information about exclusions, please consult the FEGLI 

Handbook at www.opm.gov/life. 

Can Annuitants and Compensationers Participate? 

It depends. 

Annuitants cannot participate in the Open Season unless they are reemployed in a position which 

conveys FEGLI eligibility. 

It is important to note that FEGLI coverage obtained under a dual pay appointment such as a 

FEPCA appointment cannot be used for retirement purposes. A dual pay reemployed annuitant 

cannot continue coverage elected during the open season into retirement. 
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Compensationers cannot participate in the Open Season unless they are still insured as employees 

(i.e., during the first 12 months in nonpay status). However, as with any other employee in nonpay 

status, any coverage that compensationers elect during the Open Season will not become effective 

until they are back in pay and duty status. The effective date of the new coverage and pay and duty 

status requirements are discussed below. 

Compensationers who are reemployed on a part-time basis are also eligible to participate, unless 

their position is excluded by law or regulation. 

Can Employees Who Elect Phased Retirement Participate? 

Yes. Employees who elect phased retirement are Federal employees who work a part-time tour of 

duty while receiving partial retirement benefits. They are eligible to elect FEGLI coverage or 

changes, the same as other full-time employees. 

Can Employees in Nonpay Status Participate? 

Yes. Employees in nonpay status can participate in the Open Season. However, any coverage they 

elect during the Open Season will not become effective until they are back in pay and duty status. 

The effective date of new coverage and pay and duty status requirements are discussed below. 

ELECTIONS AND COVERAGE 

What Kinds of Elections Can Employees Make? 

Employees who are not enrolled in the FEGLI Program can elect Basic and any or all of the 

optional coverages. Employees who are already enrolled in the FEGLI Program can increase their 

coverage, up to the maximum available, or change their coverage. 

Do Employees Have to Prove Insurability? 

No. Employees can elect coverage during this Open Season without having to prove insurability, 

pass a physical exam, or answer health questions. 

What Form Should Employees Use to Elect Coverage? 

Employees can use the SF 2817, Life Insurance Election, to make FEGLI 2016 Open Season 

elections. Alternatively, employees can use their agency’s online human resources portal if their 

agency offers a portal that allows online FEGLI election changes. 

If an employee uses the SF 2817 for an Open Season election, then in Box 6, Number of Event 

Permitting Change, the agency must enter the number 6. If the agency’s online human resources 

portal includes a similar event code field, the code for Open Season must be entered. 

Please note that employees making an Open Season election must sign on the form for ALL 

coverage they wish to have – not just the new coverage they are electing during the Open Season. 
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Any coverage not signed for on the SF 2817 will be cancelled/waived, effective with the effective 

date of the Open Season election. 

Is Positive Reenrollment Required? 

No. Only employees who want to enroll or change coverage need to complete an election form. 

An employee who takes no action during the Open Season will keep the same coverage he/she had 

before the Open Season. Any coverage previously waived will remain waived. 

Have the Types of Coverage Changed for the FEGLI 2016 Open Season? 

No. The types of coverage available during the FEGLI 2016 Open Season will be the same as 

currently available. 

What Are the Types of Coverage? 

 Basic – coverage on the employee’s life equal to the employee’s annual rate of basic pay, 

rounded up to the next even $1,000, plus $2,000. 

 Plus three types of Optional insurance: 

o Option A – Standard covers the employee’s life for $10,000

o Option B – Additional covers employee’s life for one, two, three, four, or five times 

the employee’s annual rate of basic pay rounded up to the next $1,000 

o Option C – Family covers the lives of the employee’s spouse and eligible children. 

An employee can elect one, two, three, four, or five multiples of Option C coverage. 

Each multiple is equal to $5,000 of coverage on the life of a spouse and $2,500 of 

coverage on the lives of each eligible child 

An employee must elect or already have Basic to elect any Optional insurance. 

For more information on the types of coverage available, including information on Accidental 

Death and Dismemberment coverage (part of Basic and Option A) and the Extra Benefit for 

employees under age 45, please see the “Your FEGLI Life Insurance – For Federal Employees” 

video at www.opm.gov/life. 

EFFECTIVE DATES 

When Will Open Season Elections Become Effective? 

Open Season elections become effective on the first day of the first pay period that: 

 begins on or after October 1, 2017, and 

 follows a pay period during which the employee met the pay and duty status 

requirements described below. 
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For most employees on a biweekly pay period, this will be October 1, 2017 (October 14, 2017 for 

Postal employees). 

What Are the Pay and Duty Status Requirements? 

A full-time employee on a biweekly pay period must be in pay and duty status for at least 32 hours 

during the pay period right before the one in which the coverage is to become effective. 

A full-time employee on a monthly pay period must be in pay and duty status for at least 64 hours 

during the pay period right before the one in which the coverage is to become effective. 

A part-time employee must be in pay and duty status for one-half of the regularly-scheduled tour of 

duty shown on his/her current SF 50. 

An intermittent employee or an employee without a regularly-scheduled tour of duty who is eligible 

for FEGLI coverage must be in pay and duty status for one-half of the hours customarily worked in 

a pay period. Employing offices can determine the number of hours customarily worked by totaling 

the number of hours worked in the calendar year quarter ending June 30, 2016, and dividing that by 

the number of pay periods in that quarter. 

Please note that sick leave, annual leave, donated leave, or any other kind of leave, whether paid or 

unpaid, does not qualify as pay and duty status. 

New coverage does NOT begin until the employee meets the pay and duty status requirements, even 

if that is after October 2017. For some employees, new coverage will never begin because they 

will never meet the pay and duty status requirements. 

Are There Any Exceptions To The Pay And Duty Status Requirements? 

No. However, employees may meet the pay and duty status requirements at the following 

employment sites: 

 at an employee organization while on leave-without-pay to work there full-time; 

 at an international organization while on detail to work there; or

 at a State, local, or Indian tribal government; institution of higher education; or 

other organization eligible under the Intergovernmental Personnel Act of 1970, 

while on temporary assignment to work there. 

PROCESSING OPEN SEASON ELECTIONS 

How Should We Process FEGLI 2016 Elections? 

The employing office must enter the date of receipt in Box 6 of the SF 2817 election form or its 

electronic equivalent. An authorized agency official must verify that the employee is in a position 

which conveys eligibility for FEGLI coverage. 
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The employing office must give a copy of the SF 2817 or its electronic equivalent to the employee 

as verification of receipt on a timely basis during the Open Season. (A second copy must be 

provided to the employee after the election becomes effective.) 

Agencies must develop a system for holding the election forms or their electronic equivalent until 

they are processed and become effective. Whether you put them in the Official Personnel Folder 

(OPF) or its electronic equivalent, or maintain them separately, you should flag the OPF/equivalent 

in some way to indicate that the employee made an Open Season election. 

Before coverage will become effective, an authorized agency official must verify that employees 

meet the pay and duty status requirements discussed earlier. 

When Do Employees Start Paying Premiums for Open Season Coverage? 

Employees will start paying premiums for their new coverage only when that coverage becomes 

effective, but not sooner than October 1, 2017 (October 14, 2017 for Postal employees). 

What Happens if an Employee Retires before the New Coverage Becomes Effective? 

If an employee makes an Open Season election but retires before the new coverage becomes 

effective, he/she never had the new coverage. Therefore, the employee cannot continue the newly 

elected coverage into retirement. 

The same is true if the employee starts receiving compensation before the effective date of the new 

coverage. 

In both cases, you should void the SF 2817 or its electronic equivalent and indicate in the “remarks” 

section that the employee retired or started receiving compensation before the open season effective 

date. Any SF 2821 Agency Certification of Insurance Status must show only the “old” coverage.

What Happens if an Employee Transfers to Another Agency before the New Coverage 

Becomes Effective? 

If an employee who made an Open Season election transfers to another agency before the election 

becomes effective, attach the SF 2817 to the OPF or its electronic equivalent when you send it to the 

employee’s new agency. The new agency must process the Open Season election at the appropriate 

time, but not sooner than October 1, 2017 (October 14, 2017 for Postal employees). 

What Happens If An Employee Leaves Federal Service Before The Effective Date? 

If an employee makes an Open Season election but leaves Federal service before the new coverage 

becomes effective (October 1, 2017; October 14, 2017 for Postal), he/she never had the new 

coverage. The agency must certify the “old” coverage, if any, on the SF 2821, Agency Certification 

of Insurance Status. The employee can only convert the “old” coverage, and not the new coverage. 

What Happens if an Employee or Family Member Dies before the New Coverage Becomes 

Effective? 
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If an employee makes an Open Season election but dies before the new coverage becomes effective 

(October 1, 2017; October 14, 2017 for Postal), he/she never had the new coverage. The agency 

must certify the “old” coverage, if any. Benefits will be paid based on the “old” coverage, not the 

new coverage. 

The same is true if an employee elects or increases Option C coverage and a family member dies 

before the new coverage goes into effect (October 1, 2017; October 14, 2017 for Postal). 

CONTINUING COVERAGE 

Can Employees Continue New Open Season Coverage if They Retire or Become Insured as 

Compensationers? 

It depends. The FEGLI 2016 Open Season is not the first opportunity for electing coverage. 

Therefore, an employee must have the new coverage for the five years of service immediately 

before retiring or starting to receive compensation to continue that coverage as an annuitant or 

compensationer. There is no waiver of this five year requirement. 

So the very earliest most employees can retire or start receiving compensation and carry new 

coverage from the FEGLI 2016 Open Season into retirement or compensation is October 1, 2022 

(October 14, 2022 for Postal employees). 

Here’s an example: 

Eric currently has Basic and one multiple of Option B, which he elected when he was hired 

back in 2010. He elects four more multiples of Option B and five multiples of Option C 

during the FEGLI 2016 Open Season. He signed an SF 2817 Open Season election form for 

Basic, five multiples of Option B, and five multiples of Option C. He retires in 2020. 

He can carry Basic and one multiple of Option B into retirement. Eric cannot carry into 

retirement the four new multiples of Option B or the five multiples of Option C he elected 

during the 2016 Open Season because he did not have that coverage from his first 

opportunity (which was in 2010) nor for the five years of service immediately before his 

retirement. 

The agency will complete the SF 2821 Agency Certification of Insurance Status showing the 

coverage that Eric had on his retirement date. He cannot carry the four multiples of Option 

B or the five multiples of Option C elected during the FEGLI 2016 Open Season; however, 

he can convert that coverage to a private policy. 

COMMUNICATING INFORMATION ABOUT OPEN SEASON TO EMPLOYEES 

How Will Employees Hear About the Open Season? 

You will provide information to your employees. We will provide sample emails and FAQs that 

agencies can distribute to employees. We also intend to produce an educational video and flyer 
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about the FEGLI 2016 Open Season. Information about these materials will be distributed in the 

BenefitsInfo Listserv and at www.opm.gov/life. 

If Employees Ask Us Now, Can We Tell Them There Will Be an Open Season? 

Yes, please tell employees about the FEGLI 2016 Open Season. OPM announced the Open Season 

in BAL 15-203. More information will follow. 

MISCELLANEOUS INFORMATION 

Can Employees Make Belated Open Season Elections? 

Yes, under certain circumstances. You may accept a belated Open Season election through 

March 31, 2017, if you determine that the employee was unable to make a timely election due to 

circumstances beyond his/her control. The employee has 60 days after you have made that 

determination to make his/her Open Season election on an SF 2817 or its electronic equivalent. Use 

the “Remarks” section of the SF 2817 or its electronic equivalent to indicate that you have 

authorized a belated Open Season election. 

The effective date for a belated Open Season election is the same as that for a timely election. The 

employee must also meet the pay and duty status requirements already discussed. 

Can Employees Make Elections By Submitting Evidence of Medical Insurability or Due to a 

Life Event During the Open Season? 

Employees can still make regular elections during the Open Season period. None of those rules 

have changed. Employees may elect Basic, Option A, and/or up to five multiples of Option B based 

on satisfactory medical evidence of insurability using SF 2822 Request for Insurance. Employees 

may elect Basic, Option A, up to five multiples of Option B, and/or up to five multiples of Option C 

within 60 days of a qualifying life event. 

Regular elections will become effective in the same timeframe that they always do. Be sure to use 

the appropriate “Number of Event Permitting Change” code in Box 6 of the SF 2817 or its 

electronic equivalent to distinguish a regular election (and its effective date) from an Open 

Season election.

What Happens if an Employee Makes an Open Season Election and Later Makes a “Regular” 

Election on an SF 2817? 

If an employee is electing coverage on an SF 2817 (e.g., based on a life event) after he/she has 

submitted an Open Season election, but before the Open Season election becomes effective 

(October 1, 2017; October 14, 2017 for Postal), the employing office must process it in the normal 

way as a “regular” election. 

The subsequent “regular” election supersedes the Open Season election. Void the Open Season 

election and use the “Remarks” section to indicate that the employee elected coverage on [specify 

date] based on a life event or physical exam. 
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What if an Employee Cancels His/Her Life Insurance? 

If an employee cancels all coverage on an SF 2817 after he/she has submitted an Open Season 

election, but before the Open Season election becomes effective (October 1, 2017; October 14, 

2017 for Postal), the employing office must process it in the normal way for a cancellation. 

The subsequent “regular” SF 2817 cancelling coverage supersedes the Open Season election.

Void the Open Season election and use the “Remarks” section to indicate that the employee 

subsequently cancelled all coverage on [effective date].

Can an Employee Change His/Her Open Season Election? 

Yes. If it is still within the Open Season period, he/she can simply submit a new Open Season SF 

2817. The employing office should void the previous Open Season election form and process the 

one with the later date. At the end of the Open Season period, the SF 2817 with the latest date 

should be processed. 

The employee cannot make an Open Season election after Open Season has ended unless you allow 

a belated Open Season election as discussed above. 

After the Open Season is over and before the effective date of the Open Season coverage (October 

1, 2017; October 14, 2017 for Postal), an employee can notify the employing office in writing that 

he/she wishes to reduce the amount of coverage elected during Open Season or to void the Open 

Season election completely. You must document this action in the employee’s OPF or its electronic 

equivalent. 

DATA NEEDS 

We will need to know how many employees submit FEGLI 2016 Open Season elections. So please 

start thinking about how you can capture that information and report it to us. We will discuss this 

need for data in more detail in a future Benefits Administration Letter. 

FUTURE BENEFITS ADMINISTRATION LETTERS (BALs) 

Open Season Material and Notice to Employees 

As the FEGLI Open Season approaches we will issue additional BALs providing resources for 

human resources officers, such as sample emails to send to employees, FAQs, and a web video. 

Data Needs 

We will issue a BAL discussing the need for Open Season data. 

Processing FEGLI 2016 Open Season Elections 
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We have purposely not included in this BAL all of the varied scenarios that may come up in 

processing FEGLI 2016 Open Season elections. We will issue another BAL, closer to the 

effective date of coverage in 2017, containing additional questions/answers on what you will 

need to do in 2017 (and perhaps beyond) to process Open Season elections. 

If you have any questions regarding this Benefits Administration Letter please contact the 

FEGLI Program Office at fegli@opm.gov or call (202) 606-1413. 

 Sincerely, 

 

John O’Brien

Director