Two requirements must be checked together
The first requirement is retirement status: the employee must be entitled to retire on an immediate annuity under a civilian retirement system. OPM includes FERS MRA+10 in that statement. The second requirement is the coverage history immediately before the annuity begins.
Continuous coverage can move among FEHB plans and enrollment types. The rule does not require five years in the same carrier, the same option, or enrollment in the employee's own name. Time covered as an eligible family member under another person's FEHB enrollment can count.
| Question | What to verify |
|---|---|
| Immediate annuity | Retirement system and annuity start date qualify under OPM rules |
| Coverage window | Continuous FEHB coverage for the last five years of service, or every opportunity if shorter |
| Evidence | Enrollment records, family-member coverage, breaks in service, and eligible substitute coverage |
| Decision maker | Employing office makes a tentative finding; OPM or the applicable retirement system makes the final determination |
What can count as continuous coverage
OPM's handbook says coverage as a family member under another person's FEHB enrollment counts. Certain periods under TRICARE, CHAMPVA, or the Uniformed Services Health Benefits Program can count when the employee is enrolled in FEHB at retirement and meets the associated transition rule. Medicare coverage by itself does not count toward the FEHB continuity requirement.
A break in federal service does not automatically erase the earlier covered service. OPM says breaks are not treated as interruptions in the five-year service test when the person reenrolls within 60 days after returning to federal service. The dates and records still need to be reconstructed rather than assumed.
- Collect SF 2809 and SF 2810 forms or equivalent electronic election records.
- Document coverage as a spouse or other eligible family member when it was not in your own name.
- List every break in service and the reenrollment date after return.
- Ask the benefits office to identify any period it does not believe counts before the retirement date is final.
MRA+10, postponed annuities, and waivers need special care
An employee eligible for an immediate MRA+10 annuity can meet the first gate. If the person postpones the annuity, regular FEHB ends at separation, but OPM says coverage may be resumed when the postponed annuity begins if the continuation requirements were met. That is different from a deferred retirement after leaving before immediate-annuity eligibility.
OPM has statutory authority to waive the enrollment requirement only when denial would be against equity and good conscience. The handbook describes exceptional circumstances, circumstances outside the employee's control, intent to maintain retirement coverage, and reasonable action to protect that right. A waiver is not a routine alternative to planning and should never be assumed.
This guide owns the FEHB enrollment-history question, not the broader decision to retire, resign, or accept a RIF retirement option. Use the retirement-transition or RIF owner for the separation path and obtain a written benefits determination.
Questions about this FEHB decision
Do I need five years in the same FEHB plan?
No. OPM's test is continuous coverage under any FEHB plan or qualifying family-member coverage, not five years with one carrier or option.
Does Medicare count toward the FEHB five-year rule?
No. OPM's handbook says Medicare coverage does not count in determining continuous FEHB coverage.
Can coverage under my spouse's FEHB enrollment count?
Yes. OPM says time covered as a family member under another person's FEHB enrollment is included in continuous coverage.
Can OPM waive the five-year requirement?
OPM has limited waiver authority for exceptional circumstances when its stated equity-and-good-conscience standard is met. The employee should not rely on a future waiver in place of confirming coverage before retirement.
Primary sources
Reviewed August 25, 2026. Each source below is an official federal page used for the claims on this resource.
- OPM FEHB handbook for annuitants (opens in a new tab)
Immediate-annuity and continuous-coverage requirements, examples, breaks, and waiver standards.
- OPM FEHB eligibility (opens in a new tab)
Reader-facing statement of the retirement-continuation requirements.
This is general educational information, not legal, tax, financial, medical, or enrollment advice. OPM, your employing office or retirement system, the carrier brochure, Medicare, and the plan administrator control your actual eligibility, timing, costs, and coverage.