The FEGLI Lawyer™
FEGLI Life Insurance Appeal Lawyer
A FEGLI denial letter is not a final answer. It is the beginning of the process that matters most — the administrative appeal that determines what a court can ever see.
You have received a FEGLI life insurance denial from OFEGLI or MetLife.
Federal law gives you the right to a full and fair administrative appeal.
You have 90 days from the denial letter date. That window is everything.
The appeal is not a second bite at the apple. In most FEGLI cases, it is the only bite — because what goes into the record now is what a federal court will see if it comes to that.
FEGLI appeals are governed by federal law. The administrative record assembled during the claim and appeal process is typically the complete record for any federal court litigation that follows. Building that record correctly is not optional — it is the work.
What a FEGLI Life Insurance Appeal Actually Is
Under the FEGLI statute and OPM regulations, a beneficiary who receives a denial has the right to request a reconsideration — an administrative appeal reviewed by OFEGLI. This is not merely a formality. It is the designated mechanism for challenging a denial, and it is the stage at which the administrative record is open for supplementation.
The appeal must be submitted in writing within 90 days of the date of the denial letter. There is no grace period and no informal extension. FEGLI provides for a "full and fair review" of any denial — but that review is only as strong as the record built to support it.
An appeal that simply restates the original claim, or that asks OFEGLI to reconsider without adding evidence or legal argument, misses the opportunity that the 90-day window provides. OFEGLI is not required to find facts that the claimant did not put before it.
The appeal is not a letter. It is a strategic document that must anticipate every argument a court would need to rule in the claimant's favor.
The Closed Record: Why the Appeal Window Is the Real Fight
Federal courts reviewing a denied FEGLI claim operate under a principle that most beneficiaries do not know until it is too late: they review the administrative record. Not new evidence. Not arguments that were not made to OFEGLI. The record assembled during the claim and appeal process is, in most cases, the entire record for the life of the dispute.
Once the appeal window closes, the record is generally closed with it. What was not submitted cannot be added. What was not argued cannot be raised. The exclusion defenses OFEGLI relied upon, the evidence it says was missing, the procedural deficiencies in how it conducted its review — all of it must be addressed while the record is still open.
This is the core of how we approach every FEGLI appeal: we ask, from the first conversation, what a court would need to see to rule in the claimant's favor — and we build the record to support that outcome. Not the appeal that is easiest to write. The appeal that sets up everything that follows.
Common Grounds for Overturning a FEGLI Life Insurance Denial
FEGLI life insurance denials arise from a specific set of recurring problems. Each has legal vulnerabilities that a well-constructed appeal can exploit.
- Enrollment and Coverage Disputes OFEGLI denies claims when it concludes the employee did not have coverage in force. The question is often whether the agency properly processed the enrollment election. An agency's administrative failure to process or transmit accurate enrollment information may not be chargeable to the employee — or to the beneficiary.
- Agency Administrative Errors Employing agencies are responsible for processing FEGLI elections, maintaining accurate records, and transmitting correct information to OPM. Where an agency error caused a gap or denial of coverage, federal regulations and case law provide pathways to equitable relief that a properly constructed appeal can invoke.
- Coverage Lapse During Leave Without Pay FEGLI coverage can be affected during periods of leave without pay (LWOP) unless the employee took specific steps to continue it. Whether coverage lapsed, and whether the agency provided accurate notice of the employee's options, are questions the appeal record must address.
- Beneficiary Designation Disputes When OFEGLI pays or proposes to pay benefits to someone other than the claimant — or refuses to pay because of a competing designation — the appeal is the opportunity to challenge that determination and establish the legal basis for the claimant's entitlement.
- Procedural Deficiencies in OFEGLI's Review OFEGLI is required to conduct a full and fair review of every denial. Where its process was deficient — where it relied on incomplete information, failed to consider evidence the claimant submitted, or applied the wrong legal standard — those deficiencies belong in the appeal record, documented precisely, so they are available for a court to evaluate.
How We Build a FEGLI Life Insurance Appeal
Every appeal we file starts from the same question: what would need to be in this record for a federal court to rule in the claimant's favor? That question shapes every decision — what evidence to obtain, what legal arguments to make, what deficiencies in OFEGLI's process to document, and what the denial letter itself reveals about the insurer's reasoning.
We obtain the administrative claim file — the complete record of what OFEGLI reviewed and relied upon in issuing the denial. We compare what OFEGLI says it considered against what was submitted and what the file contains. We identify the specific exclusions or factual conclusions it relied upon, examine the legal standard those conclusions must meet, and build the appeal to address each point with precision.
An appeal submitted before the 90-day window closes is not a guarantee of success. What it does guarantee is that the record exists to support the best possible outcome — on appeal, and if necessary, in federal court.
If you have received a FEGLI denial letter, the clock is running. A free case evaluation takes stock of exactly where you stand.
Free Case EvaluationIf Your Appeal Has Already Been Denied
If OFEGLI has denied a properly filed appeal, federal court litigation is the next available remedy. The record built during the appeal process becomes the record for that litigation. We represent FEGLI claimants in federal court when the administrative process has been exhausted and the denial must be challenged under federal law.
Frequently Asked Questions About FEGLI Life Insurance Appeals
What is the FEGLI life insurance appeal process?
After receiving a FEGLI life insurance denial, a beneficiary may request a reconsideration — a formal administrative appeal — from OFEGLI. The appeal is a written submission that must be filed within 90 days of the denial letter date. OFEGLI is required under federal law to conduct a full and fair review of the denial, consider any additional evidence or argument submitted with the appeal, and issue a decision. If the appeal is denied, federal court litigation is the next available remedy.
How long do I have to appeal a FEGLI life insurance denial?
90 days from the date of the denial letter. This deadline is set by the FEGLI regulatory framework and is not extended by informal follow-up, additional correspondence, or a general sense that the matter is still "in progress." If you have received a denial letter, the 90-day clock began on the date of that letter.
What happens if I miss the 90-day appeal deadline?
Missing the deadline generally forecloses the administrative appeal right. OFEGLI treats a failure to appeal within 90 days as acceptance of the denial, and the claim is closed. Whether any avenue of relief remains after that point depends on the specific circumstances — the nature of the denial, the reason for missing the deadline, and whether any equitable basis for late filing applies. This is one of the most important reasons to act promptly after receiving a denial letter.
What should a FEGLI life insurance appeal include?
A FEGLI life insurance appeal should include a written statement identifying the specific grounds for challenging the denial, any evidence that was not submitted with the original claim or that directly addresses the basis for denial, legal argument addressing the applicable FEGLI statutory and regulatory standards, and documentation of any deficiencies in OFEGLI's claims handling process. An appeal that simply restates the original claim without adding evidence or argument is unlikely to be successful and misses the strategic opportunity the 90-day window provides.
What is the "closed record" problem in FEGLI appeals?
Federal courts reviewing denied FEGLI claims typically do so on the administrative record — the record assembled during the claim and appeal process. They do not take new evidence. They do not consider arguments that were not made to OFEGLI. Once the appeal window closes, the record is generally closed. This means that evidence not submitted, arguments not made, and deficiencies not documented during the appeal are typically unavailable if the case proceeds to federal court. Building the appeal record with this in mind is not a secondary concern — it is the primary strategic objective.
Can OFEGLI actually reverse its own denial on appeal?
Yes. OFEGLI does reverse denials on appeal when the appeal presents evidence or argument that demonstrates the denial was incorrect. Whether an appeal is likely to succeed at the administrative level depends on the specific grounds for the denial, the quality of the record that can be built in response, and the nature of any deficiencies in OFEGLI's original review. Not every appeal is reversed at the administrative stage — but the appeal is the required step before federal court, and how the appeal is built affects everything that follows.
My employer made an error that affected my family member's FEGLI coverage. Can I raise that in an appeal?
Yes, and this is among the most important appeal grounds available. Employing agencies are responsible for processing FEGLI enrollment elections and maintaining accurate records. Where an agency error — a failure to process an election, an incorrect coverage entry, or a failure to notify the employee of enrollment rights — caused or contributed to the denial, federal regulations and case law provide a basis for relief that must be raised in the administrative record. These arguments should be supported with documentation from the agency and OPM records, which we obtain as part of building the appeal.
Do I need a lawyer to file a FEGLI life insurance appeal?
You are not required to have legal representation to file a FEGLI appeal. However, the value of an appeal is determined by what it contains — the evidence, the legal arguments, and the documentation of OFEGLI's procedural failures. An appeal that misses the grounds that would have carried the case, or that fails to build the record a federal court would need to rule in your favor, cannot be re-submitted. The appeal window is a finite and non-repeatable opportunity. Whether that opportunity is fully used is largely a function of how the appeal is prepared.
The Clock Started on the Date of That Letter.
A free case evaluation takes stock of exactly where your appeal stands — what the denial says, what grounds exist to challenge it, and what the record needs to support the strongest possible outcome. No cost. No obligation.
Speak with a FEGLI Lawyer