Can federal employees enroll in or change dental and vision insurance plans during a shutdown?
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Executive summary
Federal employees generally can only enroll in or change FEDVIP dental and vision plans during the annual Open Season (mid-November to mid‑December) unless they experience a qualifying life event; Open Season for 2025 ran Nov. 10–Dec. 8 and FEDVIP elections become effective Jan. 1, 2026 [1] [2]. Regulations and agency guidance say FEDVIP coverage continues through a lapse in appropriations, and statute extends continuation of dental/vision contracts during shutdowns (5 CFR Part 894 citing Pub. L. 116‑92) [3] [4].
1. Open Season is the primary way to start, stop or change FEDVIP
Federal guidance and multiple agency pages make clear that the Federal Employees Dental and Vision Insurance Program (FEDVIP) uses the annual Federal Benefits Open Season as the standard window to enroll in, cancel, or change dental and vision elections; Open Season dates in 2025 were Nov. 10–Dec. 8 and changes become effective Jan. 1, 2026 [1] [2]. Agency instructions and BENEFEDS — the FEDVIP administrator — direct employees to use BENEFEDS during Open Season to make elections and note that if satisfied, no action is required because enrollments rollover [1] [5].
2. Shutdowns don’t automatically strip FEDVIP coverage — continuation rules exist
Several sources explain that if the government lapses in appropriations, FEDVIP coverage continues through the shutdown/reopening period and statutes require continuation protections for dental and vision contracts entered into on or after Dec. 20, 2019 [3] [4]. BENEFEDS and OPM guidance told enrollees they did not need to act immediately in response to a shutdown and that coverage would continue during the government reopening period [3] [6].
3. Exceptions: qualifying life events and special re‑instatement rules
Outside Open Season, federal employees may change coverage only for qualifying life events (marriage, birth, loss of other coverage) or under special agency-specific reinstatement rules. Agency help pages reiterate Open Season is the main period to alter FEDVIP and note qualifying life events are the usual exceptions [7] [5]. Delta Dental’s FEDVIP page also instructs employees who return to active pay status after a break to contact BENEFEDS to request reinstatement, showing some administrative pathways exist outside Open Season [8].
4. Payroll and premium mechanics during a lapse can complicate enrollment changes
OPM and agency notices stress that premiums for FEDVIP are typically withheld from salary on a pre‑tax basis, and that payroll allotments (for example FSAFEDS) may be paused or otherwise affected by a lapse in appropriations; agencies urged employees to consult BENEFEDS or HR if pay/status changes affect coverage [2] [6]. That administrative reality can limit the practical ability to change or start coverage during a shutdown even when rules allow continuation or reinstatement [6] [2].
5. Legal backstop: federal regulation preserves coverage during appropriations lapses
The Code of Federal Regulations (5 CFR Part 894) explicitly incorporates the National Defense Authorization Act provision that continuation of coverage during a lapse in appropriations applies to dental and vision contracts entered into before, on, or after Dec. 20, 2019 — a legal backstop protecting FEDVIP enrollees in shutdowns [4]. That regulation is the strongest textual support for continuity of benefits when funding lapses.
6. Where reporting is silent or mixed — what sources don’t say clearly
Available sources do not mention a universal, agency‑wide process allowing employees to newly enroll in FEDVIP for the first time during a shutdown outside Open Season absent a qualifying life event; agency pages instead emphasize Open Season or specific reinstatement after return to pay status [1] [8]. Sources also do not provide a single, uniform step‑by‑step checklist for employees to initiate emergency enrollment changes during a shutdown beyond contacting BENEFEDS or HR [3] [6].
7. Practical advice and competing perspectives
The practical guidance across OPM, BENEFEDS and agency HR pages converges: use Open Season to make plan changes; if a shutdown occurs your existing FEDVIP coverage generally continues and statutory/regulatory language protects contracts [1] [3] [4]. However, agency notices also warn about website or HR service interruptions during lapses in funding, meaning that while coverage continues on paper, administrative access and payroll withholding can be disrupted [7] [6]. For any immediate action or if your employment/pay status changed, contact BENEFEDS at 1‑877‑888‑3337 or your HR office for case‑specific instructions [8] [9].
Limitations: this analysis uses only the provided agency pages and regulation excerpts; it does not include any independent legal interpretations or later agency memos beyond these sources [4] [3].