Can federal employees enroll in new health insurance plans during a shutdown?

1. What people are claiming — the core disputes that matter

Reporting and official inquiries present two competing impressions: one line asserts that federal employees retain the ability to enroll in new FEHB plans during a shutdown, including through annual Open Season, while another emphasizes operational uncertainty and potential risks to continuous coverage if premium streams pause. The claim that Open Season proceeds is supported by OPM statements and multiple previews of the enrollment season indicating scheduled dates and mechanisms for paper enrollment ^{[4] [2]}. Conversely, oversight inquiries about trust-fund solvency and questions from lawmakers suggest a legitimate concern that prolonged lapses in agency premium contributions and administrative delays could threaten timely processing or require contingency funding ^[5]. Both claims are fact-based: Open Season authority derives from FEHB trust arrangements; concern about funds arises from actual inquiries into OPM account management ^{[5] [3]}.

2. What the Office of Personnel Management and guidance say — formal rules that control outcomes

OPM guidance and shutdown-furlough documents state that FEHB coverage continues through lapses in appropriations, and employees in non-pay status may still enroll or change elections during Open Season or for qualifying life events, with agencies instructed to process FEHB transactions even when appropriations lapse ^{[3] [6]}. OPM has also described contingency procedures and the use of reserves to keep claims paid and the enrollment machinery running, and has told reporters Open Season will proceed as scheduled ^{[2] [1]}. That formal posture establishes a legal and administrative path for enrollments to occur despite a shutdown, but it relies on agency operational capacity and trust-fund mechanics rather than appropriations for immediate premium flows ^{[3] [4]}.

3. How enrollment actually happens during a shutdown — the real-world frictions

Practical reporting and guidance note that while employees can file paper SF-2809 forms and enroll during Open Season, electronic systems and HR offices may be limited if staff are furloughed, producing processing delays even when the right to enroll exists. Multiple outlets recommend that employees waiting until after a shutdown ends may avoid processing lags, though they reiterate Open Season remains legally open and paper submissions are accepted for later processing ^{[2] [4]}. CMS recall of some furloughed staff to handle open-enrollment duties demonstrates the government’s effort to mitigate those frictions, but it also signals resource constraints and ad hoc solutions that could vary across agencies and plans ^[7].

4. The financing question: trust funds, paused premiums, and solvency alarms

FEHB operates through trust funds funded by agency contributions, premium withholdings, and other mechanisms, which allows benefits to continue without immediate appropriations; yet reports and a senator’s inquiry show concern that paused premium collections from unpaid employees and delayed agency contributions could stress reserves if a shutdown persists. OPM has asserted plans currently have sufficient funds to pay claims and has contingency reserves for interruptions, but oversight queries and reporting underline that longer shutdowns could force harder choices or reliance on stopgap funding, creating potential downstream risks for plan administration ^[5]. That tension frames why officials insist Open Season continues even while watchdogs press for transparency about fund status ^{[5] [3]}.

5. Who is most affected — furloughed staff, retirees, and those needing changes now

Employees in non-pay status face two distinct challenges: immediate cash-flow problems and limited ability to change coverage outside established windows. OPM guidance confirms furloughed employees can enroll during Open Season and that qualifying life events remain valid triggers for midyear changes, but those furloughed and unpaid may struggle to meet premium obligations until pay resumes, and some agencies may not be able to process terminations or cancellations outside Open Season ^{[6] [5]}. Reporting also notes that CMS and other agencies recalled select staff to handle open enrollment, indicating differential operational capacity that may advantage some employees and disadvantage others depending on agency decisions and local HR staffing ^{[7] [2]}.

6. Bottom line and practical steps — what employees should do now

The authoritative pattern in guidance and reporting is clear: legally and administratively, Open Season and qualifying-life-event enrollments proceed during a shutdown, but practical delays, paused premium collections, and potential trust-fund stress are real risks ^{[1] [5]}. Employees should prepare by downloading and completing SF-2809 if needed, using paper submissions if systems are down, documenting filings, and consulting their agency HR and plan carriers for confirmation—while monitoring OPM updates and any statements about contingency funding or processing delays ^{[2] [3]}. Stakeholders pushing for transparency—lawmakers and watchdogs—are focused on solvency and operational continuity, while agencies emphasize that benefits remain in force; that split explains why the answer is both legally reassuring and operationally cautious ^{[5] [3]}.