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Attachment 2: Process Enrollment Actions 

Agency Benefits Officers’ Responsibilities for Processing 

FEHB Enrollment Actions 

1. Prompt Processing – It is important that you process Open Season 

enrollments and enrollment changes promptly. Payroll offices should 

process enrollee and carrier copies of Standard Form (SF) 2809 daily. 

2. Please be sure copies of the SF 2809 are transmitted to both the 

gaining and losing carriers. In many cases, the agency sends the SF 

2809 only to the gaining carrier. This results in the losing carrier 

continuing to expect premiums to be paid for the enrollees and family 

members and causes the carrier to make erroneous payment of claims 

and provision of services. 

3. Verification of Employee Coverage – Employees become concerned 

when they do not receive their identification cards from a new plan within 

a short time after the end of Open Season. Many health plans offer 

temporary cards that employees may obtain from their plan’s website or 

employees may contact their plan directly for more information. If an 

employee asks you about this, you must contact the payroll office to 

determine when the carrier was notified of the change. It is important 

that payroll offices send daily enrollment transactions to ensure that 

employees get identification cards before the effective date of coverage. 

If more than three weeks have passed since the payroll office sent the SF 

2809 to the carrier, contact the carrier to determine the reason for the 

delay and relay the employee’s request for identification cards. 

An employee may need to verify their coverage under their plan before a 

carrier has processed the enrollment or enrollment change. Employees 

may obtain temporary identification cards from their health plans directly. 

You should confirm that the employee is covered under the plan and 

inform the requesting party (e.g., carrier, doctor, and hospital) of the 

effective date of coverage. You should also remind employees that their 

copy of the SF 2809 is acceptable as proof of enrollment until they 

receive their identification cards from the plan. Employees who make 

Open Season changes using an agency electronic enrollment system and 

who do not receive new identification cards by the effective date of the 

change may obtain a letter confirming their coverage by calling the Help 

Desk at their agency’s self-service system or by requesting your help. 
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FEHB Enrollment Cancellations 

Cancellation of FEHB – An Open Season cancellation is effective at the end of 

the day before the first day of the first pay period that begins in the next 

year. 

Note: Cancellation can have serious consequences. To continue FEHB 

coverage after retirement, an employee must have been covered under the 

FEHB Program continuously for the five years of service immediately before 

retirement or, if less than five years, for all periods of service during which 

they were eligible for FEHB coverage. 

If an employee is canceling their FEHB enrollment to be covered as a family 

member by a spouse’s FEHB Open Season enrollment, be sure to coordinate 

the effective date of the cancellation with the effective date of the spouse’s 

enrollment to prevent a break in coverage. Coverage under a family 

member’s FEHB enrollment counts towards the “five-year rule” for 

continuing coverage into retirement. 

Processing Qualifying Life Events (QLE) During Open 

Season 

An employee may experience a QLE during Open Season. The effective date 

of an enrollment or enrollment change due to a QLE may differ from the 

effective date of an Open Season enrollment or enrollment change. Be sure 

to process these actions correctly as QLE elections and not Open Season 

elections. If you have questions regarding the employee’s intent, check with 

your employee to verify whether they are seeking a QLE election or an Open 

Season election. Counsel your employees on the impact and differences 

between elections. 

FEHB Enrollment Reconciliation 

The large number of FEHB enrollment actions made during Open Season 

increases the chance of errors by employing offices or by carriers in updating 

records. Any errors will be identified as discrepancies through the 

Centralized Enrollment Reconciliation Clearinghouse System (CLER) during 

the March 2022 reconciliation cycle. It is very important that employing 

offices work with the carriers to correct these discrepancies. 

The reconciliation process is critical to ensure that carriers receive the proper 

premium payments and that enrollees are properly reflected on the carriers’

records for accurate provision of services and claims payment. 
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Belated Enrollment Actions 

Employing offices do not have the authority to extend the Open Season for 

employees or a group of employees, even if the agency did not provide 

adequate notice or information regarding the Open Season. 

1. FSAFEDS – Employing Offices do not have the authority to 

approve belated enrollments. HealthEquity (the provider for 

FSAFEDS) makes these decisions. Employees who are unable to enroll 

during the entire Open Season for reasons beyond their control may 

qualify for a belated enrollment. Not knowing about Open Season is not 

an acceptable reason for a belated enrollment. They must submit the 

Belated Enrollment Form (available at www.FSAFEDS.com ) to Health 

Equity within 30 days after Open Season ends. Instructions are on the 

form. Belated enrollments are effective the day after FSAFEDS receives 

the employee’s form if approved by Health Equity. 

2. FEDVIP – Employing Offices do not have the authority to approve 

belated enrollments. BENEFEDS makes these decisions on behalf of 

the FEDVIP carriers. The time limit for enrolling or changing an 

enrollment may be extended for up to 3 months after the end of Open 

Season, only if the employee provides evidence to BENEFEDS that they 

were unable to enroll or change enrollment in a timely manner due to 

circumstances beyond their control. Not knowing about Open Season is 

not an acceptable reason for a belated enrollment. This includes 

receiving incorrect information from the agency. The employee must 

enroll or change enrollment within 30 days after BENEFEDS notifies them 

that the belated enrollment is approved. 

For approved belated FEDVIP enrollments or belated changes in 

enrollments, the effective date will be retroactive to January 1, 2022. 

BENEFEDS will begin withholding premiums prospectively from the 

enrollee’s pay and will then bill the enrollee directly for the retroactive 

premiums on the next billing cycle. If an enrollee does not pay the 

retroactive premiums timely, their enrollment will be cancelled 

retroactively as if it never existed and they will be responsible for 

repaying any benefits received. 

3. FEHB – Employing offices have the authority to accept individual 

late elections if you determine an employee was unable to submit 

the election on time due to circumstances beyond the employee’s 

control. While we normally encourage you to make limited use of this 

authority, we recommend that you take a liberal view in cases where an 
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employee’s plan is terminating its FEHB participation or reducing its 

service area. 

If you decide to accept an employee’s late election, write “Belated Open 

Season enrollment/change” in the “Remarks” section of the SF 2809. You 

must attach the employee’s statement explaining why they could not 

enroll or change on time (or add your own note if the reason was an 

agency problem) to Copy 1 (the Official Personnel Folder copy) of the SF 

2809. If you decide the delay in filing was not due to a cause beyond the 

employee’s control, do not accept the employee’s late request. You must 

notify the employee in writing that you are not approving the late 

enrollment. You should give the reason for your denial and include a 

statement of the employee’s right to request reconsideration within 30 

days after the date of your notice. 

An accepted belated FEHB Open Season enrollment is effective retroactive 

to the first day of the first pay period which begins on or after January 1, 

2022. This effective date is the same as that of an Open Season change 

filed on time. If the belated change is from “not enrolled” to “enrolled,”

the requirement of having been in pay status during the preceding pay 

period must also be met. 

As with all enrollments, belated Open Season enrollment actions are 

automatically subject to premium conversion (unless participation in 

premium conversion is waived). If premium conversion is not waived, the 

effective date of premium conversion cannot be retroactive since Internal 

Revenue Service (IRS) rules do not allow for retroactive adjustments to 

taxable income. This means any additional withholding for retroactive 

premiums that are due must be made with after-tax dollars.