Can federal workers make changes to FEDVIP dental and vision plans outside open season due to a shutdown?
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Executive summary
A government shutdown does not create a new window for changing FEDVIP dental or vision elections beyond the normal Open Season and established qualifying life‑event (QLE) rules; agency and benefits guidance repeatedly says Open Season proceeds during a lapse and that furloughed employees may still submit Open Season changes during a shutdown [1] [2] [3]. Public reporting and benefit‑administrator guidance emphasize continuity of coverage and post‑shutdown premium reconciliation rather than any expansion of midyear enrollment rights [4] [5].
1. Open Season still runs and is the normal path for annual plan changes
Federal guidance and reporting make clear that the annual Federal Benefits Open Season continues “as normal” during a lapse in appropriations, and that enrollments and Open Season changes will be processed and take effect at the start of the next plan year (Jan. 1) even if a shutdown is underway [1] [3] [4]. Multiple agency and benefits‑website pages for 2025/2026 Open Season reiterate that FEDVIP and FEHB Open Season activities are not delayed by a shutdown and that employees and annuitants should act by posted deadlines to enroll, change, or cancel coverage [6] [2] [7].
2. Furloughed employees can submit Open Season changes during a shutdown, but that is not the same as a new midyear right
Operational guidance specifically permits furloughed employees to submit FEHB and FEDVIP Open Season elections during a shutdown because Open Season activity is treated as an excepted function, meaning the process remains available even when staff are in non‑pay status [2] [4]. That allowance maintains the annual enrollment window; it does not create an additional, separate opportunity to change FEDVIP elections outside the statutory Open Season framework [4] [3].
3. Midyear changes still rely on qualifying life events — reporting does not show a shutdown creates new exceptions
The sources show that routine Open Season processing and QLE handling continue through a shutdown and that if a QLE application was submitted and processed it will have its normal effective date, but none of the reporting documents a policy that a lapse in appropriations itself grants midyear enrollment or cancellation rights for FEDVIP outside Open Season [8] [4]. OPM‑based FAQs and contemporaneous coverage emphasize that Open Season and QLE rules remain the governing authorities for when enrollments may change [8].
4. Coverage continuity and premium handling during a shutdown
FEDVIP coverage continues through a lapse in appropriations even if payroll deductions are paused; beneficiaries who are furloughed will have missed payroll deductions collected after the shutdown ends (usually via withholding from retroactive pay or subsequent pay periods), and benefit administrators warn enrollees to check for withheld retroactive premiums or double deductions once pay resumes [4] [5] [3]. Benefit portals and insurers likewise advised that FEDVIP enrollments roll over into the next year unless changed during Open Season [7] [9].
5. Where the record is thin and what cannot be concluded from current reporting
No provided source asserts that a shutdown creates an independent right to alter FEDVIP dental or vision elections outside Open Season or QLE rules; reporting and agency notices instead stress processing continuity and premium reconciliation [1] [4] [8]. If an agency or OPM issued a novel emergency rule allowing midyear FEDVIP changes specifically because of a shutdown, that change is not reflected in the materials cited here — the available documents only confirm that Open Season remains open and that normal QLE processes continue [2] [3].
6. Practical takeaway and recommended checks for affected employees
Practically, the record shows that federal employees and retirees must rely on Open Season or qualifying life events to change FEDVIP coverage, can submit Open Season choices even while furloughed, and should monitor BENEFEDS, employer HR announcements, and OPM guidance for any specific administrative details about premium collection after a lapse [5] [10] [4]. For definitive answers about an individual case (for example, a processed but unsubmitted change or agency‑specific HR procedures during a shutdown), the cited agency and BENEFEDS pages are the primary sources to consult because the public reporting summarized here does not enumerate any new midyear exceptions created solely by a shutdown [2] [5].