Office for Domestic Preparedness 

U.S. Department of Homeland Security 

Washington, DC 20531

 

ODP Information Bulletin 

No. 141 November 19, 2004 

TO: All State Administrative Agency Heads 

 All State Administrative Agency Points of Contact 

 All State Homeland Security Directors 

FROM: C. Suzanne Mencer 

 Director 

SUBJECT: Clarifying Overtime and Backfill Policies for Part-time Employees and 

Volunteers 

ODP has received the following policy clarifications from the Department of Homeland Security 

Office of General Counsel on using ODP grant funds to cover overtime and backfill expenses for 

part-time and volunteer emergency response personnel participating in ODP training and 

exercises. This guidance applies to current and previous fiscal year funding for ODP grant 

programs. 

A. Part-Time Personnel 

If an agency has budgeted employees to work less than a full-time schedule, the time that these 

employees spend traveling to and attending ODP training and exercises above and beyond their 

regularly scheduled hours can be considered overtime and therefore covered along with backfill 

costs using ODP grant funds. For example, if an agency budgets an individual for 20 hours per 

week but ODP training and/or exercise activities require that person to work 25 hours in a week, 

the 5 extra hours spent in training and/or exercises could be covered by ODP grants. 

B. Paid-For-Call, Paid-On-Call, and Paid-Per-Call Volunteer Personnel 

If an agency relies upon paid-for-call, paid-on-call, and/or paid-per-call volunteer personnel and 

opts to include them in ODP training and exercises, grantees can use ODP grant funds to pay 

volunteers for their attendance at these activities in accordance with established processes, to 

include both hourly and flat-rate payment. 

C. Stipends for Volunteer Firefighter Personnel 

Stipends for purely volunteer firefighters to attend ODP training and exercises are allowable 

when volunteers are completely unpaid and no legal agreement exists to support pay for training 

and exercise activities, provided that ODP receives written justification establishing: 1) the 

difficulty states/locals are facing getting responders to participate as unpaid volunteers, and 2) 

why volunteers who are already willing to provide time without pay are unwilling to give extra 

time for training and exercises. The justification must be based on a finding that paying 

volunteers is a primary factor in enticing them to participate in training and exercise activities. 
The justification must explain how participation in ODP-approved training and exercises makes 

participants better at the work they perform during their regular volunteer duties. Finally, the 

state should develop a policy stating the standardized stipend amount to be provided for 

participation in training and exercises. 

This justification and policy should be provided in writing to ODP through your Preparedness 

Officer. 

D. Reimbursing Wages for Volunteer Responder Personnel 

If volunteer responders are required to take off time from work in order to participate in ODP 

training and exercises, grant funds can be used to reimburse lost wages provided that certain 

requirements are met. First, ODP must receive written justification establishing the amount of 

wages lost by each volunteer responder participating in the training or exercises, including time 

and rate of pay. Second, the written justification for such costs must outline how paying 

volunteers is a primary factor in enticing them to participate in training and exercise activities. 

Third, reimbursement funds must be provided directly to the employer for pass-through to the 

volunteer. Finally, the state should develop a policy stating the reasonable maximum 

reimbursement amount (on either an hourly or annual basis) and submit to ODP. 

This justification and reimbursement policy should be provided in writing to ODP through your 

Preparedness Officer. 

For further information on these policies, please contact your Preparedness Officer or the ODP 

Helpline at 1-800-368-6498.