Federal Employees News Digest

Understanding the Eligibility Rules for Continuing FEHB Health Benefits After Retiring from Federal Service

Each year, during the benefits “open season,"employees and annuitants make decisions regarding which health, dental and vision insurance plans they want to be covered by during the upcoming plan year that starts in early January. Employees are eligible to continue their Federal Employee Health Benefits (FEHB) coverage throughout retirement. This column is the third of eight columns discussing choices that employees and annuitants have to make during the upcoming benefits “open season” which runs from Nov. 11 through Dec. 9, 2019 and discusses the requirements that employees must fulfill to keep their FEHB program health insurance benefits throughout retirement.

Employees are eligible to continue health benefits coverage upon retiring from federal service if they fulfill the following two requirements:

· The employee is entitled to retire on an immediate annuity under either a CSRS or FERS retirement. The FERS “Minimum Retirement Age + 10” retirement option is also included.

· The employee has been continuously enrolled (or covered as a family member) in any FEHB program plan(s) for the five years of service immediately before the date the annuity starts, or for the full period(s) of service since the employee’s first opportunity to enroll (if less than five years).

It is important to understand that when an employee keeps his or her FEHB health benefits throughout retirement, the federal government continues to pay on average 72 to 75 percent of the annuitant’s FEHB health insurance premiums, as it did when the annuitant was an employee. The annuitant can also change FEHB health insurance plans annually during the annual benefits “open season”, as well as continue full FEHB coverage on eligible family members (spouses and children under the age of 26).

Note that when an employee elects to either not enroll or to cancel his or her enrollment, the employee must certify by his or her signature on the Health Benefits Election form (Form SF 2809) that he or she understands the effect it has on eligibility to carry coverage into retirement.

What Does Service Time Include for Purposes of FEHB Program Requirements?

For purposes of continuing FEHB coverage into retirement, “service time” means time in which an individual served in a position in which the individual was eligible to be enrolled. The individual is not required to have been an enrollee continuously, but the individual must have been continuously covered by an FEHB enrollment. Continuous coverage includes:

· Time covered as a family member under another person’s FEHB enrollment;

· Time covered under the Uniformed Services Health Benefits Program, also known as TRICARE, CHAMPUS, or CHAMPVA, as long as the individual was covered under an FEHB enrollment on the day of retirement.

Breaks in service are not counted as interruptions when the five years of service requirements is determined, as long as the individual reenrolls within 60 days after his or her return to federal service. The following two examples illustrate:

Example 1. Jeff elected FEHB coverage on Feb. 11, 2011 and had a break in service from Jan. 1, 2015 through Jan. 1, 2017. Upon his return to service, he again elected to enroll. He retires on Dec. 31, 2018. He is eligible to continue his to continue his FEHB health benefits into retirement since he has been continuously enrolled for the five years prior to retirement.

Example 2. Carol elected not to enroll in the FEHB program upon her employment. She left federal service early in 2015 and was rehired later in 2015. When she retired in 2018, she was not eligible to continue health benefits into retirement since she was not covered for the five years of service before her retirement. Her 2015 rehire date does not count as her first opportunity to be insured because of her prior employment in which she elected not to enroll.

Other Issues That May Affect Eligibility to Retain FEHB Enrollment in Retirement

1. Late election. Any individual is considered to have been continuously enrolled when allowed to make a late election after the employing office determined that the individual was not able to timely enroll for reasons beyond the individual’s control. The following example illustrates:

Albert’s employing office notified him on March 20, 2013 that he could make a late election to enroll in the FEHB program. He promptly enrolled and on Jan. 31, 2018 he retired. He is eligible to continue his health benefits into retirement since March 20, 2013 is considered to be his first opportunity to enroll.

2. Eligibility as a temporary employee. An individual’s decision not to enroll as a temporary employee eligible for coverage under 5 United States Code 8906a does not affect the individual’s future eligibility to continue coverage as a retiree. Only service time for which the federal government contributes toward the cost of health benefit counts in determining whether the individual has met the five years of service, or first opportunity to enroll, requirements to continue coverage as a retiree. Since the federal government does not share in the cost of a temporary employee’s enrollment, eligibility to enroll under 5 United States Code 8906a is not considered the first opportunity for purposes of continuing health benefits coverage into retirement.

3. Eligibility under temporary continuation of coverage. Enrollment or eligibility for enrollment as a former employee under the FEHB temporary continuation of coverage (TCC) provisions is not considered in determining whether an individual meets the five years of service requirement to continue coverage as a retiree.

At retirement, an employee’s employing office will tentatively determine if the employee is eligible to continue FEHB enrollment in retirement. OPM’s Office of Retirement Programs will review the retirement and health benefits documents and make a final determination of the employee’s eligibility to continue the FEHB enrollment into retirement.

Edward A. Zurndorfer is a Certified Financial Planner, Chartered Life Underwriter, Chartered Financial Consultant, Certified Employee Benefits Specialist and IRS Enrolled Agent in Silver Spring, MD. Tax planning, Federal employee benefits, retirement and insurance consulting services offered through EZ Accounting and Financial Services, located at 833 Bromley Street Suite A, Silver Spring, MD 20902-3019 and telephone number 301-681-1652.

Reader comments

Please post your comments here. Comments are moderated, so they may not appear immediately after submitting. We will not post comments that we consider abusive or off-topic.

Please type the letters/numbers you see above


Edward A. Zurndorfer Certified Financial Planner
Mike Causey Columnist
Tom Fox VP for Leadership and Innovation, Partnership for Public Service
Mathew B. Tully Legal Analyst

Free E-Newsletter


I agree to this site's Privacy Policy.

Stay Connected

Latest Forum Posts

Ask the Expert

Have a question regarding your federal employee benefits or retirement?

Submit a question