Attachment 3: Process Enrollment Actions 

Agency Benefits Officers’ Responsibilities for FEHB

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 SF 2809 daily. 

2. You must notify gaining carriers of new enrollments so they can complete the 

paperwork necessary to provide coverage for the employee and covered family members 

and issue identification cards as promptly as possible. 

3. You must notify losing carriers as soon as possible of enrollment changes or 

cancellations so they do not guarantee or provide benefits to ineligible employees or 

family members. 

4. 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. If an employee asks you about this, you must contact the payroll office to 

determine when the carrier was notified of the change. 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 verification of coverage under his/her plan before the 

carrier processes the enrollment or enrollment change. You should verify the employee 

is covered under the plan and inform the requesting party (e.g., carrier, doctor, 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 (except for prescription drugs) until they 

receive their identification cards from the plan. Employees who make Open Season 

changes electronically using an agency self service 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 center or by 

requesting your help. 

Enrollment Reconciliation (FEHB)

The large number of enrollment actions made during Open Season increases the chance of errors 

by agencies or by carriers in updating records. Any errors will be identified as discrepancies 

through the Centralized Enrollment Reconciliation Clearinghouse System (CLER) during the 

March 2010 reconciliation cycle. It is very important that agencies work with the carriers to 

correct these discrepancies. 

Please be sure copies of the SF 2809 are sent 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 person(s) and often the erroneous payment of 

claims and provision of services. 

1
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 

or claims payment. 

Belated Actions 

1. FEHB – You do not have the authority to extend the Open Season for your 

employees or a group of your employees even though your agency may not have 

provided adequate notice or information regarding the Open Season. However, you 

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 employee’s plan is terminating 

its FEHB participation. If you decide to accept an employee’s late election, write 

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

must attach to Copy 1 (Official Personnel Folder) of the SF 2809 the employee’s 

statement explaining why he/she could not enroll or change on time or add your own note 

if the reason was an agency problem. If you decide the delay in filing is 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 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. 

2. FEHB – Effective Date of FEHB Open Season Enrollments – Effective retroactive to 

the first day of the first pay period which begins on or after January 1, 2011. 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. Belated Open Season enrollment 

actions are automatically subject to premium conversion. 

Since Internal Revenue Service (IRS) rules allow for no retroactive adjustments to 

taxable income, the effective date of premium conversion cannot be retroactive. This 

means any additional withholding for retroactive premiums that are due must be made 

with after-tax dollars. For an example of the impact of a belated change on taxable 

income, please visit www.opm.gov/insure/health/faq/premconversion/03.asp.

3. FEDVIP - Agencies do not have the authority to approve FEDVIP belated 

enrollments. BENEFEDS makes these decisions on behalf of the FEDVIP carriers and 

will only allow belated enrollments and changes in exceptional circumstances. The time 

limit for enrolling or changing an enrollment may be extended for up to three (3) months 

after the end of Open Season, if the employee provides evidence to BENEFEDS that 

he/she was unable to enroll or change enrollment timely due to circumstances beyond 

his/her control. Not knowing about Open Season is not an acceptable reason for a belated 

enrollment. The employee must enroll or change enrollment within 30 days after 

BENEFEDS notifies him/her the belated enrollment is approved. 

2
3

For approved belated FEDVIP enrollments or belated changes in enrollments, the 

effective date will be retroactive to January 1, 2011. 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, his/her enrollment will be cancelled retroactively as if it 

never existed and he/she will be responsible for repaying any benefits received. 

4. FSAFEDS – Agencies do not have the authority to approve FSAFEDS belated 

enrollments. Employees who are unable to enroll during the entire Open Season for 

reasons beyond their control may qualify for a belated enrollment. They must submit the 

Belated Enrollment Form available at www.FSAFEDS.com to SHPS 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. 

Cancellations 

FEHB Only – 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. Outside of Open Season, employees 

who participate in premium conversion may only cancel their FEHB enrollment due to a 

QLE. Employees who waived participation in premium conversion may cancel their FEHB

enrollment at any time without waiting for a QLE or an Open Season. 

Note: Cancellation can have serious consequences. In order 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 he/she was eligible for FEHB coverage. 

If an employee is canceling his/her FEHB enrollment in order 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 “fiveyear rule” for continuing coverage into retirement.