1 

United States

Office of Personnel Management

The Federal Government’s Human Resources Agency

Benefits Administration Letter

Number: 21- 203 Date: May 25, 2021 

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

Forms Processing During Disruption of Agency Operations

This Benefits Administration Letter (BAL) provides guidance to agencies on alternative methods 

to certify and process FEGLI forms during the current disruption to normal agency operations. 

Alternative methods acceptable during the pandemic to certify certain FEGLI forms include the 

use of electronic signatures such as Personal Identity Verification (PIV) cards, Common Access 

Cards (CAC), and digital signature software (such as DocuSign). OPM will also temporarily

allow the use of electronic and remote notary services to witness signatures on FEGLI forms. 

Electronic and remote notary services allows a signer to personally appear before a Notary at the 

time of the notarization using audio-visual technology over the internet instead of being 

physically present in the same room. For more information about the electronic and remote 

notary services during the COVID-19 emergency, please visit 

https://www.nationalnotary.org/notary-bulletin/blog/2020/03/states-emergency-action-remotenotarization. 

This guidance is effective through the end of the Presidentially declared COVID -19 

emergency1.

Agencies should develop a process to track FEGLI forms received by fax or email while this 

temporary process is in place. Agencies should also encourage employees to send the original 

forms in as soon as possible. 

The chart below provides temporary guidance on the acceptance of electronic signatures for the 

most commonly used FEGLI forms: 

1 See the Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) 

Outbreak
2 

Form Guidance to Process Form

Agency 

Electronic 

Signature? 

Enrollee

Electronic 

Signature?

SF 2817, Life 

Insurance Election

• Agency personnel may certify

the SF 2817 electronically.

• Agency personnel may accept

electronic signatures from the

insured to complete the SF

2817, if the agency is able to

do so.

YES YES

SF 2818, 

Continuation of Life 

Insurance Coverage 

as an Annuitant or 

Compensationer

Retiring employees must still 

provide an original “wet” 

signature and send the original by 

regular mail to their employing 

agency.

N/A NO

SF 2819, 

Notification of 

Conversion 

Privilege 

Agency personnel may certify the 

SF 2819 electronically to provide 

conversion privileges timely to 

the insured. 

Note: Separating employees 

must still use an original 

signature and mail the form to 

the Office of Federal 

Employees’ Group Life 

Insurance (OFEGLI) in order 

to obtain a conversion policy. 

YES NO

SF 2821, Agency 

Certification of 

Insurance Status

Agency personnel may certify the 

SF 2821 electronically. 

Note: OPM has suspended the 

requirement that a certifying

official cannot provide a 

facsimile signature, per BAL 20-

201. 

YES N/A
3 

Form Guidance to Process Form

Agency 

Electronic 

Signature? 

Enrollee

Electronic 

Signature?

SF 2822, Request 

For Insurance 

Agency personnel may certify the 

SF 2822 electronically. 

Note: Employees and the 

physician certifying their

medical examination must still 

provide original signatures to 

complete the form. The form 

must still be mailed by the 

employee’s physician directly to 

OFEGLI.

YES NO

SF 2823, 

Designation of 

Beneficiary 

• Agency personnel may certify

the SF 2823 electronically.

• Agency personnel must

continue to require completed

forms that are in writing, with

original signatures from the

insured and two witnesses, per

5 CFR § 870.802(b).

• Agency personnel may

witness the execution of the

SF 2823 as long as they are

not named as the beneficiary.

Agency personnel must

provide an original “wet”

signature, if signing as a

witness.

* The insured can have two

individuals witness their

signature through a virtual

environment; however, the

insured and witnesses’

signatures must be original.

YES NO* 
4 

Form Guidance to Process Form

Agency

Electronic 

Signature? 

Enrollee

Electronic 

Signature?

RI 76-10, 

Assignment of Life 

Insurance 

• Agency personnel may certify

the RI 76-10 electronically.

• All agencies must continue to

require RI 76-10 that are in

writing, with original

signatures from the insured

and two witnesses, per 5 CFR

§ 870.902(b).

* The insured can have two

individuals witness their

signature through a virtual

environment, however, the

insured and witnesses’

signatures must be original.

YES NO*

FE-6, Claim for 

Death Benefits 

Claimants should continue to sign 

their claim form with an original 

signature and send with a certified 

death certificate by mail.

N/A N/A

FE-6 DEP, 

Statement of Claim, 

Option C

Agency personnel may certify the 

FEP-6 DEP electronically. 

Note: Employees should 

continue to sign the form with 

an original signature and mail 

in a certified death certificate to 

their employing agency. 

YES NO

Agencies must submit all forms and death claim documentation with a cover sheet. Please 

see the template in Attachment A. 
5 

Common questions concerning Revised Procedures for FEGLI forms during 

Presidentially Declared COVID-19 Emergency

Can an employee use a Personal Identity Verification (PIV) or Common Access Card 

(CAC) to sign FEGLI forms? 

Employees that submit their FEGLI forms to their employing agency may only use their 

PIV/CAC cards to sign the SF 2817 electronically. The SF 2817 should contain your electronic 

signature, complete with the date it was signed. Submit this document to your employing agency 

for processing. For instructions on how to sign the SF 2817 using Adobe, please see Attachment 

B. 

Will OPM waive the requirement to have two individuals witness an insured’s signature 

for the SF 2823 due to social distancing guidelines? 

No. The SF 2823 must be signed by the insured and witnessed by two individuals as required by 

FEGLI law and regulation. The insured can have individuals witness their signature in a virtual 

environment, including but not limited to, Skype or Zoom, however, the signatures of the 

insured and their two witnesses must be original. 

How can I have my signature for the SF 2823 witnessed in a virtual environment? 

The insured can have two individuals witness their signature at the same time using their choice 

of a virtual environment (such as Skype or Zoom). The insured will then mail or deliver the 

original signed form to the witnesses and, once completed, the last witness to sign the form can 

mail it back to the insured to submit to their employing agency. 

Is the SF 2823 considered valid if received by fax or email? 

Per 5 CFR § 870.802(b), the employing agency can determine the appropriate method to accept 

the Designation of Beneficiary form. However, in all cases, the SF 2823 must include an original 

signature from the insured, contain original signatures from two witnesses, and must be received 

by the employing agency before the death of the insured. 

Agencies are strongly encouraged to remind employees that they must provide a completed SF 

2823 with original signatures as soon as possible. 

 How long does the insured have to submit the original SF 2823 to their employing agency? 

All FEGLI forms, including the SF 2823, must be submitted as soon as possible and received by 

the employing agency before the insured dies. 

What happens if the insured faxes or emails their SF 2823, but dies before the original 

form is received? 

An original completed SF 2823 must be received before the death of the insured. If the form is 

not received before the insured dies, any previous valid benefit designation on file applies. If 

there are no designations on file, benefits will be paid according to the order of precedence in 5 
6 

CFR § 870.801(a). 

Should agencies upload forms received by fax or email into the eOPF?

Agencies should develop a process to track FEGLI forms received by fax or email while this 

temporary process is in place. Agencies should include a note in the eOPF that a form was 

received by fax or email with the original to be submitted as soon as possible. 

Will the requirement for a certified death certificate be suspended? 

OPM continues to require a certified death certificate for claimants. However, for those who 

experience delays in obtaining a certified death certificate in their state, OFEGLI can accept an 

Affidavit Regarding the Death of Insured form (Attachment C) in order to expedite the claim 

while awaiting receipt of the certified death certificate. This requires claimants to have a 

mortuary service complete an Affidavit Regarding the Death of Insured form and return it 

directly to OFEGLI. The affidavit must be signed by the licensed funeral director/mortician.

Please note that all other supporting documentation, as appropriate, including court orders,

assignments, powers of attorney, birth certificates, guardianship papers, and election forms 

verifying FEGLI coverage are still required. OFEGLI must be able to verify all of the 

documentation before a claim can be paid. The claimant must provide the certified death

certificate to OFEGLI as soon as it is obtained. A failure to provide the certified death certificate

may result in the recovery of all benefit payments made to all claimants. 

Is the agency process for death claim documentation changing?

No, the agency is still required to send all original FEGLI documents to OFEGLI after the death 

of an employee. A cover sheet template must also be included. 

If you have any questions regarding this BAL, please contact the FEGLI Program Office at 

fegli@opm.gov or call (202) 606-1413. 

Sincerely,

Laurie Bodenheimer 

Associate Director

Healthcare and Insurance