Shutdown Guidance for Benefits: The Dec. 11 Deadline
Federal funding runs through Dec. 11, 2026, mid open season. OPM shutdown guidance for benefits: what happens to FEHB, FEGLI, FEDVIP and FSAFEDS.
By Shawn McCoy7 min read
Federal funding runs through December 11, 2026, which falls in the middle of Open Season. This shutdown guidance for benefits offices covers what OPM says would happen to FEHB, FEGLI, FEDVIP, FSAFEDS and long-term care coverage if appropriations lapse on December 12. The short answer is that coverage continues, open season transactions keep moving, and premiums catch up when pay resumes. Nobody knows yet whether Congress will act in time. Your office can still prepare employees now so they are not caught off guard.
The December 11 funding deadline
According to the Congressional Research Service report R49353, the Continuing Appropriations and Extensions Act, 2027 (P.L. 119-103, H.R. 6500) was signed on September 2, 2026. It provides continuing appropriations for all 12 regular appropriations bills through December 11, 2026, a period of 72 days. If Congress does not pass full-year appropriations or another continuing resolution, a funding gap would begin December 12, 2026.
Open season runs November 9 through December 14, 2026. A lapse would overlap the last few days of the season, which is when many employees make their elections.
What OPM shutdown guidance for benefits says
OPM's Guidance for Shutdown Furloughs, dated January 2026, answers the benefits questions employees ask most. Here is a summary by program.
FEHB and FEGLI transactions keep moving
Agencies continue to process FEHB and FEGLI transactions during a lapse. OPM explains that the law treats processing these transactions as emergency services that must continue under the Antideficiency Act, so the employees who handle them must be excepted. Benefits offices should confirm now which staff are designated to do this work.
FEHB coverage continues
An enrolled employee stays covered even if the agency cannot pay premiums on time. When the employee returns to pay status, the accumulated share of premium is withheld from pay. If premiums are not taken from retroactive pay for an excepted employee, one additional payment is withheld each pay period until the balance is repaid.
Employees cannot cancel to save money
OPM says employees in a shutdown furlough cannot terminate or cancel FEHB outside open season or a qualifying life event. They can, however, enroll or change enrollment if they have a qualifying life event, and they can make changes during open season.
Open season effective dates do not move
If an open season change was submitted to the health plan and processed before a lapse, OPM says the effective date is still the first day of the first full pay period in January. For most non-postal employees in 2027, that is January 10. If an employee's plan is terminating, the old plan covers services until the new plan begins.
Other benefits during a furlough
| Program | What OPM says happens |
|---|---|
| FEGLI | Coverage can continue for up to 12 months in non-pay status. |
| FSAFEDS health care FSA | Payroll deductions stop. Claims incurred during non-pay status are not reimbursed until the employee returns to pay status. Claims for earlier dates of service are paid normally, up to the annual election. |
| FSAFEDS dependent care FSA | Eligible expenses may be reimbursed up to the account balance. |
| FSAFEDS enrollment | The effective date of an enrollment is not affected. |
| FEDVIP | Coverage continues and cannot be canceled for nonpayment due to a lapse. Accumulated premiums are withheld later. The open season effective date is not affected. |
| FLTCIP | Coverage continues and cannot be canceled for nonpayment due to a lapse. Claim benefits are not reimbursed until past-due premiums are paid. |
A note on FSAFEDS timing
The FSAFEDS rules matter in December. An employee who incurs a health care expense during a furlough will wait for reimbursement until pay resumes. Employees with large planned expenses, such as dental work, may want to know that in advance.
How a lapse would overlap open season
If funding lapses on December 12, the last three days of open season would fall inside the lapse: Saturday, December 12, Sunday, December 13 and Monday, December 14. Many employees wait until the final weekend to enroll, so the overlap is not trivial.
What stays the same
- The open season dates themselves are set by OPM and do not depend on a lapse.
- OPM's guidance says FEHB transactions continue to be processed, and furloughed employees may still make open season changes.
- FEDVIP and FSAFEDS enrollment effective dates are not affected.
What could be harder
- Furloughed employees may not have access to agency systems, email or HR staff, depending on their agency's shutdown plan.
- Benefits offices may be operating with a small excepted team, which slows answers to individual questions.
- Employees who need help with documents, such as proof of a family member's eligibility for a new enrollment, may find it harder to reach someone.
The practical advice is simple: encourage employees to finish their elections early, and do not let December 14 become the plan.
What benefits staff should document now
If a lapse does occur, clear records reduce cleanup later. Before December 11, benefits offices can:
- Note which open season transactions are pending and which have been submitted to plans.
- Confirm how excepted staff will receive and process FEHB and FEGLI forms.
- Keep a list of employees who have asked for help but have not finished enrolling.
- Save a copy of OPM's shutdown guidance and any agency-specific instructions where staff can find them offline.
Questions employees will ask
"Will I lose my health insurance?" No. OPM says FEHB coverage continues.
"Should I still make my open season election?" Yes. Open season changes continue to be processed, and the effective date does not change once a change is processed. Encouraging employees to finish their elections before December 11 reduces risk.
"Will I owe premiums later?" Yes. Your share of FEHB and FEDVIP premiums accumulates and is withheld after you return to pay status.
"Can I drop coverage to save money during a furlough?" Not for FEHB, unless you have a qualifying life event or make the change during open season.
Retirees and annuitants
Annuitants are paid from the Civil Service Retirement and Disability Fund rather than annual agency appropriations, and FEHB coverage for retirees is not tied to an employee's pay status. Retirees may still call benefits offices with questions when shutdown headlines appear. A one-line answer helps: the furlough guidance on premium catch-up and non-pay status applies to employees, not to people already receiving an annuity. Annuitants should direct questions about their own open season choices to OPM Retirement Services.
A preparation checklist for benefits offices
- Confirm which benefits staff are excepted to process FEHB and FEGLI transactions.
- Move your open season reminder schedule earlier, with a push before December 11.
- Prepare a short FAQ for employees, using OPM's guidance, to send if a lapse begins.
- Brief supervisors so they can answer basic questions or refer employees.
- Keep OPM's guidance and your agency's shutdown plan easy to find.
For the full list of open season dates, see our post on 2027 open season effective dates. Our open season communications checklist covers timing for the rest of the season.
Helping employees plan for uncertainty
A possible furlough is a financial stress point, especially near the holidays. FEBA's financial wellness programs help employees build an emergency cushion and understand how their benefits behave in non-pay status. To arrange a briefing for your workforce, see our agency services or contact our team.
Questions
- When does current federal funding expire?
- The Continuing Appropriations and Extensions Act, 2027 (P.L. 119-103), signed September 2, 2026, funds all 12 regular appropriations bills through December 11, 2026. Without further action, a funding gap would begin December 12, 2026.
- Does FEHB coverage continue during a shutdown?
- Yes. OPM's shutdown guidance says an employee's FEHB coverage continues even if the agency cannot make premium payments on time. The employee's share accumulates and is withheld from pay after the employee returns to pay status.
- Will open season changes still go through if there is a shutdown?
- OPM says agencies continue to process FEHB and FEGLI transactions during a lapse in appropriations, and that a fully processed open season change keeps its normal effective date, the first day of the first full pay period in January.
- Can a furloughed employee cancel FEHB to save money?
- No. OPM says employees in a shutdown furlough cannot terminate or cancel FEHB outside of open season or a qualifying life event. They can still make changes during open season or after a qualifying life event.
- What happens to FSAFEDS claims during a furlough?
- Health care FSA claims for expenses incurred during non-pay status are not reimbursed until the employee returns to pay status. Eligible dependent care expenses may be reimbursed up to the account balance.
Federal Employee Benefits Advocates is an independent educational organization. This article is not a government publication and is not official guidance from OPM or any federal agency.
