FEHB Plan Options: 2 Outcomes of OPM’s Review You Must Not Miss

The short answer: OPM has opened a public review of FEHB plan options and set a comment deadline of November 16, 2026. Two things can follow. OPM can leave the current three-option limit in place, or it can begin separate rulemaking to change it. Nothing changes for 2027 enrollment.

Status as of October 13, 2026. This post covers a developing matter and is not updated continuously.

What are the key takeaways?

• OPM published a request for information on FEHB plan offerings on September 15, 2026 (91 FR 58388). Comments close November 16, 2026. (Federal Register)
• Today a health benefits plan may offer three options, or two options plus a high-deductible health plan, under 5 CFR 890.201(b)(3)(i). (eCFR)
• Plan Year 2026 carries 132 plan options from 47 carriers in FEHB and 75 options from 17 carriers in the Postal Service Health Benefits Program. (OPM, in the RFI)
• A request for information is not a rule. OPM states the responses will inform whether changes are needed through future notice and comment rulemaking.
• OPM amended this same section in 2010 (75 FR 76615) and 2018 (83 FR 18399), so the route has precedent.

What did OPM actually do on September 15, 2026?

OPM published a request for information, or RFI, in the Federal Register. An RFI asks the public questions. It does not propose regulatory text, and it does not change anything on its own.

The subject is how many health plan choices a carrier may put in front of enrollees. OPM asks whether more, fewer, or different options would affect premiums, the enrollee experience, and the work of agency benefits officers. It also asks a sharper question: whether a plan should face an upper limit on premiums, and whether a plan above that limit should have to drop the offering.

What is the current limit on FEHB plan options?

Under 5 CFR 890.201(b)(3)(i), a health benefits plan is limited to three options, or two options and a high-deductible health plan. That ceiling applies per carrier, not to the program as a whole.

The program total is much larger. For Plan Year 2026, FEHB carries 132 plan options from 47 carriers, and PSHB carries 75 options from 17 carriers. So an enrollee is not choosing from three plans. They are choosing from a wide field in which each carrier is capped at three.

OPM is not asking whether to shrink the program. It is asking whether the per-carrier cap sits in the right place. For what enrollees pay under the current structure, see our guide to FEHB premiums in retirement.

What happens if OPM leaves the current rule in place?

This is the status-quo branch, and it is a real one. OPM says the information gathered will inform the agency as to whether modifications are needed. Whether is the operative word. An RFI can close with no further action.

On this branch, 5 CFR 890.201(b)(3)(i) stands unchanged. Carriers keep the three-option structure. Open Season for the 2027 plan year runs on the plans OPM has already approved, and the number of choices in front of you is the number you see in the plan comparison tool.

What happens if OPM moves to rulemaking?

On this branch, OPM takes what it learns and opens a separate proposed rule. The RFI says so directly: the information will inform the agency through future notice and comment rulemaking.

That is a multi-step path, and each step is public. A proposed rule would be published in the Federal Register with its own comment period. A final rule would follow, with its own effective date. Carriers would then build plan offerings for a future plan year under the revised text.

Timing is the useful part. Plan structure changes take effect for a plan year, not mid-year, so a rule finalized in one calendar year shows up at the Open Season after it. The precedent runs one direction so far: OPM loosened this rule in 2010, then extended that change in 2018.

Where does the review stand right now?

The RFI is open. Comments are due on or before November 16, 2026, in docket OPM-2026-0661 on Regulations.gov. OPM has not published a proposed rule on FEHB plan options, and has not said whether it will.

Nothing changes unless and until a rule is proposed, finalized, and takes effect. For the 2027 plan year, the choices on the table are the ones already set. Our breakdown of the 2027 FEHB premium increase covers what is known for that year.

What else do federal employees ask about this review?

Does this change my plan for 2027?
No. The RFI does not alter any plan, premium, or enrollment rule. The 2027 plan year proceeds under the current regulation.

Is a request for information the same as a proposed rule?
No. An RFI gathers input. A proposed rule contains regulatory text and must go through notice and comment before it can be finalized.

Could the number of FEHB plan options go down?
OPM’s questions ask about more, fewer, or different options. All three directions are on the table in the questions. None of them is a proposal at this stage.

Who can submit a comment?
The docket is open to the public. Submissions are posted at Regulations.gov as received, including any personal information in them.

Where can I read the RFI myself?
It is published at 91 FR 58388, dated September 15, 2026, and is available in full on the Federal Register site.

Want help reading your own FEHB choices?

Plan structure is one variable. Your enrollment tier is another, as our look at Self Plus One versus Self and Family shows.

Fed Pilot runs free federal retirement benefits workshops for federal employees approaching retirement, covering FEHB, FERS, TSP, and the decisions that connect them. Register for an upcoming workshop.