RELIGIOUS 

COMPENSATORY 

TIME

Office of Personnel 

Management Action 

Needed to Clarify 

Policies for Agencies

Report to the Chairman, Committee on 

Homeland Security and Governmental 

Affairs, U.S. Senate

October 2012

GAO-13-96

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-96, a report to the 

Chairman, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate

October 2012

RELIGIOUS COMPENSATORY TIME

Office of Personnel Management Action Needed to 

Clarify Policies for Agencies

Why GAO Did This Study

Since 1978, federal agencies have 

been required to allow employees to 

adjust their work schedules to engage 

in religious observances, to the extent 

that such modifications do not interfere 

with the efficient accomplishment of an 

agency’s mission. As requested, this 

report

What GAO Recommends

identifies the similarities and 

differences in policies of selected 

agencies concerning compensatory 

time off for religious observances for 

law enforcement officers (LEO) and air 

transportation safety and security 

(ATSS) personnel and describes their 

rationale for adopting the policies. 

GAO selected seven agencies for this 

review based on their substantial 

concentrations of LEO and ATSS 

personnel. GAO evaluated the 

agencies’ policies and interviewed 

agency officials.

GAO recommends that OPM (1) 

establish time frames for finalizing 

proposed revised regulations for 

compensatory time off for religious 

observances and (2) work with CBP to 

ensure its policies and practices on the 

disposition of unused compensatory 

time off for religious observances is in 

compliance with statute and OPM’s 

implementing regulations. OPM agreed 

with the overall findings and 

recommendations. The Department of 

Homeland Security (DHS) agreed with 

the recommendation and will work with 

OPM. OPM, DHS, and the 

Departments of Justice, 

Transportation, and Treasury provided 

technical comments that GAO 

incorporated where appropriate.

What GAO Found

All seven of the agencies in GAO’s review—U.S. Customs and Border Protection 

(CBP), Federal Aviation Administration, Federal Bureau of Investigation, Federal 

Bureau of Prisons, U.S. Immigration and Customs Enforcement (ICE), Internal 

Revenue Service (IRS), and Transportation Security Administration—have 

written policies supporting an employee’s ability to earn and use compensatory 

time off for religious observances. GAO identified several similarities in agency 

policies and supporting documents in the categories of: (1) employee eligibility, 

(2) applicability across geographic locations, (3) schedule planning, and (4) 

implementation. These similarities generally support greater flexibility for 

employees to seek compensatory time off for religious observances. For 

example, all agencies have policies that apply to all occupational groups of the 

agencies’ geographical locations and facilities, regardless of a facility’s size or 

the number of employees who work there. In most cases, officials said the 

agencies followed existing federal rules when developing policies and that they 

wanted to provide their employees with additional scheduling flexibility. However, 

IRS introduced additional controls to monitor excessive accumulation of unused 

compensatory time off for religious observances based on findings by IRS’s 

Inspector General. 

GAO identified differences in the way agencies administer their policies on 

compensatory time off for religious observances in five different categories: (1) 

caps on the number of pay periods to earn and use compensatory time off for 

religious observances, (2) repaying compensatory time off for religious 

observances that was taken in advance, (3) the forms or other documentation 

required to make the request and providing a reason for request, (4) other types 

of schedule adjustments referenced in the policy, and (5) disposition of unused 

compensatory time off for religious observances. For example, IRS has a 120-

day cap and ICE has a six pay period cap for earning and using compensatory 

time off for religious observances. 

Some of the differences are within the discretion of the agency and may reflect 

individual needs of the agency, but in one area the differences in policy may 

reflect a lack of clarity in Office of Personnel Management (OPM) regulations. 

For example, CBP policy states that unused compensatory time off for religious 

observances will be converted to regular compensatory time, which according to 

an OPM official, is not authorized under statute or OPM’s implementing 

regulations. In OPM’s view, compensatory time off for religious observances and 

regular compensatory time are different forms of compensatory time off that are 

separately authorized; serve different purposes; and are subject to differing 

conditions for earning, using, and retaining, as well as liquidating. OPM officials 

stated they are updating regulations that they believe will address the disposition 

of unused compensatory time off for religious observances, but have not set a 

timetable for completing the proposed revised regulations. Without such 

clarification on the disposition of unused compensatory time off for religious 

observances in OPM’s regulations, agencies may have policies that are not 

consistent with OPM’s views on the proper disposition of unused compensatory 

time off for religious observances. 

View GAO-13-96. For more information, 

contact Yvonne D. Jones at (202) 512-2717 or 

jonesy@gao.gov.
Page i GAO-13-96 Religious Accommodations

Letter 1 

Background 3

Some Agency Policies on Compensatory Time off for Religious 

Observances May Not Be Subject to or Consistent with OPM 

Regulations or Guidance; Rationales for Policies Vary 8

Conclusion 18

Recommendations for Executive Action 18

Agency Comments 19

Appendix I Objectives, Scope, and Methodology 21

Appendix II Comments from the Office of Personnel Management 23

Appendix III Comments from the Department of Homeland Security 26

Appendix IV GAO Contact and Staff Acknowledgment 27

Tables

Table 1: Law Enforcement Officers and Air Transportation Safety 

and Security Personnel in Selected Agencies 7

Table 2: Agency Policies Display Differences in Several Categories 12

Contents
Page ii GAO-13-96 Religious Accommodations

Abbreviations

ATSS air transportation safety and security

BOP Federal Bureau of Prisons

CBA collective bargaining agreement

CBP U.S. Customs and Border Protection

DHS Department of Homeland Security

DOJ Department of Justice

EEO equal employment opportunity

EEOC U.S. Equal Employment Opportunity Commission

FAA Federal Aviation Administration

FBI Federal Bureau of Investigation

FLRA Federal Labor Relations Authority

FLSA Fair Labor Standards Act

ICE U.S. Immigration and Customs Enforcement

IRS Internal Revenue Service

LEO law enforcement officer

LWOP leave-without-pay

NTEU National Treasury Employees Union

OPM U.S. Office of Personnel Management

TIGTA Treasury Inspector General for Tax Administration

Treasury Department of Treasury

TSA Transportation Security Administration

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Page 1 GAO-13-96 Religious Accommodations

United States Government Accountability Office

Washington, DC 20548

October 12, 2012

The Honorable Joseph I. Lieberman

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Mr. Chairman:

Since 1978, federal statute has required agencies to allow employees the 

option to engage in overtime work and receive equal compensatory time 

off to make up for lost time due to religious observances. The statute 

provides that agencies may make exceptions when necessary to 

efficiently carry out the mission of the agency. Further, federal 

antidiscrimination laws promote a federal workplace that is fair, equitable, 

and free from discrimination and retaliation, including as it relates to 

religious beliefs, practices, and observance.

In response to your interest in federal agencies’ religious accommodation 

leave policies for federal law enforcement officers (LEO) and air 

transportation safety and security (ATSS) personnel, you asked us to 

identify the similarities and differences in policies of selected agencies 

concerning compensatory time off for religious observances for these 

groups of personnel and determine the agencies’ rationale for adopting 

their policies.1

We selected seven federal agencies with significant numbers of LEO and 

ATSS personnel based on their U.S. Office of Personnel Management 

(OPM) occupational group and description, including personnel in the 

investigation and transportation groups and the correctional officer series. 

Six selected agencies each had over 10,000 employees in these 

 

1 For purposes of this report, we are defining “law enforcement officer” as an individual 

authorized to perform any of four specific functions: (1) conduct criminal investigations, (2) 

execute search warrants, (3) make arrests, or (4) carry firearms. In addition, some of 

these law enforcement officers are responsible for care and custody of convicted 

offenders. We defined ATSS personnel to include Transportation Security Administration’s 

federal air marshals and passenger and baggage screeners/handlers, or transportation 

security officers, and Federal Aviation Administration’s air traffic controllers, based on the 

U.S. Office of Personnel Management’s occupational groups and descriptions as well as 

agency job descriptions and other information from agency websites. 

 
 

Page 2 GAO-13-96 Religious Accommodations

occupational groups based on recent data from OPM’s Central Personnel 

Data File. These included three components in the Department of 

Homeland Security (DHS)—U.S. Customs and Border Protection (CBP), 

U.S. Immigration and Customs Enforcement (ICE), and Transportation 

Security Administration (TSA); two components in the Department of 

Justice (DOJ)—Federal Bureau of Investigation (FBI) and Federal Bureau 

of Prisons (BOP); and one agency in the Department of Transportation—

Federal Aviation Administration (FAA).2

In evaluating agency policies, we reviewed agency documentation, such 

as guidance, and collective bargaining agreements to identify similarities 

and differences in the policies. We reviewed applicable federal statutes 

and regulations, as well as proposed regulations, and executive branch 

policies and guidance. Since OPM is responsible for administering the 

statute on compensatory time off for religious observances and the U.S. 

Equal Employment Opportunity Commission (EEOC) is responsible for 

enforcing the federal antidiscrimination statute requiring religious 

accommodations, we interviewed officials from each on their duties and 

responsibilities concerning compensatory time off for religious 

observances for federal employees and reviewed applicable EEOC 

cases. We developed a structured interview instrument to discuss agency 

policies on schedule adjustment for religious accommodation, and the 

rationale for such policies, with human resource or human capital officials, 

field supervisors, and civil rights or diversity officials, from the selected 

agencies and their “parent” departments. We also interviewed LEO 

association representatives as well as union representatives about 

whether, from their viewpoint and the viewpoint of those they 

represented, there were any problems or concerns with schedule 

accommodation or compensatory time for religious observance at the 

selected agencies.

We selected the seventh agency, 

the Internal Revenue Service (IRS) in the Department of Treasury 

(Treasury), because of their unique role as criminal investigations of tax 

matters.

We conducted this performance audit from December 2011 through 

October 2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

 

2

For purposes of this report, we are referring to both agencies and components as 

“agencies”. 
 

Page 3 GAO-13-96 Religious Accommodations

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Federal law has prohibited religious discrimination in employment since 

the enactment of the Civil Rights Act of 1964.3 Title VII of the act, as 

amended, provides that discrimination against any employee or applicant 

for employment based upon his or her religion is prohibited, and that 

employers must accommodate religious beliefs, practices, and 

observances, unless doing so would pose an undue hardship on the 

employer. 4 In addition, Congress enacted Title IV of the Federal 

Employees Flexible and Compressed Work Schedules Act of 1978, which 

provided the authority for federal employees to work overtime and receive 

equal compensatory time off in order to meet requirements for religious 

observance, which is the focus of this report. 5

 

3

Pub. L. No. 88-352, 78 Stat. 241 (July 2, 1964).

This statute, which was 

codified in 5 U.S.C. § 5550a (hereinafter “section 5550a”), directed OPM 

to “prescribe regulations providing for work schedules under which an 

employee whose personal religious beliefs require the abstention from 

work during certain periods of time, may elect to engage in overtime work 

for time lost for meeting those religious requirements.” Enactment of the 

statute permits federal employees covered under section 5550a to 

exercise the tenets of their faiths without being forced to lose a portion of 

4

See 42 U.S.C. § 2000e-2 and § 2000e-16 which prohibit discrimination in nonfederal and 

federal employment, respectively, on the basis of religion. See also, 42 U.S.C. § 2000e(j), 

which defines “religion” to include the requirement to reasonably accommodate.

5

Pub. L. No. 95-390, § 401, 92 Stat. 755 (Sept. 29, 1978).

Background 
 

Page 4 GAO-13-96 Religious Accommodations

their pay or annual leave. FAA and TSA are not subject to 5 U.S.C. § 

5550a nor OPM’s regulations implementing section 5550a.6

Issued in 1978, OPM regulations provide that:7

• employees may elect to work overtime for time lost for meeting 

religious requirements;

• to the extent that such modifications in work schedules do not 

interfere with the efficient accomplishment of an agency’s mission, the 

agency shall in each instance afford the employee the opportunity to 

work compensatory overtime and grant the requested compensatory 

time off for religious observances;

• employees may work compensatory overtime either before or after the 

grant of compensatory time off for religious observance;

• if compensatory time off was granted in advance, the time should be 

repaid by compensatory overtime work within a “reasonable amount 

of time”; and

• premium pay provisions for overtime work do not apply to 

compensatory overtime work performed under this authority.8

In addition, OPM issued guidance to federal agencies to supplement the 

regulations providing that:

• agencies should require employees to submit a written request for an 

adjusted work schedule in advance;

 

6

Under 49 U.S.C. § 40122(g), FAA was authorized to develop a personnel management 

system under which only specified provisions of Title 5 of the U.S. Code would apply in 

order to provide for greater flexibility in, among other things, the hiring and compensation 

of personnel. Therefore FAA is excluded from many provisions of Title 5 including section 

5550a. The Aviation and Transportation Security Act applied the personnel management 

system of the FAA to TSA employees, and further authorized TSA to make any 

modifications to the system it considered necessary. See 49 U.S.C. § 114(n). TSA was 

provided further flexibility under the Aviation and Transportation Security Act for the 

employment of its screener personnel. See section 111(d) of Pub. L. No. 107-71, 115 Stat. 

597, 620 (Nov. 19, 2001). 49 U.S.C. § 44935 note.

7

OPM issued interim rules in 1978. See 43 Fed. Reg. 46288, October 6, 1978. In 1986, 

OPM adopted these interim rules as final. See 51 Fed. Reg. 23036, June 25, 1986. OPM 

regulations are found at 5 C.F.R. part 550, subpart J.

8

Premium pay provisions for overtime work in subpart A of Part 550 of Title 5, Code of 

Federal Regulations, and section 7 of the Fair Labor Standards Act of 1938 (FLSA), as 

amended, codified at 29 U.S.C. §§ 201-219. The FLSA establishes standards for 

minimum wage and overtime pay.
 

Page 5 GAO-13-96 Religious Accommodations

• when deciding whether an employee’s request for an adjusted work 

schedule should be approved, a supervisor should not make any 

judgment about the employee’s religious beliefs or his or her affiliation 

with a religious organization;

• a supervisor may deny an employee’s request if modifications of an 

employee’s work schedule would interfere with the efficient 

accomplishment of the agency’s mission;

• an employee should specifically state that his or her request for an 

adjusted work schedule is for religious purposes and should provide 

acceptable documentation of the need to abstain from work;

• if an employee’s request is approved, a supervisor may determine 

whether the alternative work hours will be scheduled before or after 

the religious observance;

• an employee should be allowed to accumulate only the number of 

hours of work needed to make up for previous or anticipated 

absences from work for religious observances; and

• if an employee is separated or transferred before using the time set 

aside for religious observances, any hours not used must be paid at 

the employees rate of basic pay in effect when the extra hours of work 

were performed.

In 2005, OPM proposed revisions to the regulations that would have 

standardized procedures and definitions concerning compensatory time 

for religious accommodation.9 OPM proposed that agencies must require 

employees to perform the compensatory overtime within three pay 

periods after taking advanced compensatory time off for religious 

observance, and that agencies may require employees seeking time off to 

provide documentation to ensure the legitimacy of their request.10

 

9

See 70 Fed. Reg. 1068, January 5, 2005.

The 

10According to OPM officials, the proposed revisions were part of a larger package and no 

specific event prompted revisions to regulations on compensatory time for religious 

accommodation. 
 

Page 6 GAO-13-96 Religious Accommodations

proposed regulations were published and OPM received comments but 

took no further action.11

EEOC is responsible for, among other things, providing guidance to 

employers concerning religious discrimination and for adjudicating 

discrimination complaints and hearing appeals brought by complainants 

from federal agencies. EEOC has issued regulations requiring that 

agencies “[m]ake reasonable accommodations to the religious needs of 

applicants and employees when those accommodations can be made 

without undue hardship on the business of the agency.”12

Table 1 provides information on occupation types and staffing levels 

within each of these agencies, including the department in which each is 

located and the number of LEO and ATSS personnel in each agency.

EEOC also has 

issued guidance suggesting that employers adopt flexible leave and 

scheduling policies and facilitate voluntary substitutions and shift swaps 

to enable employees to practice their religion.

 

11According to OPM officials, OPM decided not to complete and issue the regulations after 

commenters expressed concern about the proposal to require documentation for requests 

for compensatory time off for religious observances (that the requirement was not clear or 

that it might require agencies to make judgments about the legitimacy of religious 

observance) and about the proposal to allow three pay periods to earn compensatory time 

after taking time off for religious observance (some commenters thought this was too 

restrictive). 

1229 C.F.R. § 1614.102(a)(7).
 

Page 7 GAO-13-96 Religious Accommodations

Table 1: Law Enforcement Officers and Air Transportation Safety and Security Personnel in Selected Agencies

Department Agency OPM group

Number of law 

enforcement 

officers 

Number of air 

transportation 

safety and 

security 

personnel

Percentage of total 

population of law 

enforcement officers 

and air transportation 

safety and security 

personnel 

represented

Department of 

Homeland Security

U.S. Customs and Border Protection

Customs and Border 

Protection Officer GS-1895

21,362 7.8%

Border Patrol Agent Series 

GS-1896

21,302 7.8

U.S. Immigration and Customs Enforcement

General Inspection, 

Investigation, and 

Compliance Series GS-1801

6,148 2.2

Criminal Investigating Series 

GS-1811

6,976 2.5

Transportation Security Administration

Transportation 

security officers

Compliance Inspection and 

Support Series SV-1802 

51,804 18.9

Federal Air Marshal SV-180a

Department of 

Justice

Bureau of Prisons

Correctional officers Correctional Officer Series 

GS-0007

17,826 6.5

Other correctional law 

enforcement officers

18,260 6.7

Federal Bureau of 

Investigation 

Criminal Investigating Series 

GS-1811

13,816 5.0

Department of 

Transportation

Federal Aviation 

Administration

Air Traffic Control Series 

GS-2152

20,387 7.4

Department of 

Treasury 

Internal Revenue 

Service 

Criminal Investigating Series 

GS-1811

2,665 1.0

Total law enforcement officer and air transportation safety and 

security personnel represented

108,355 72,191 66.0%b

Source: GAO analysis of most recently available data in OPM’s Central Personnel Data File as of March 2012.

Note: For purposes of this report, we are defining “law enforcement officer” as an individual 

authorized to perform any of four specific functions: (1) conduct criminal investigations, (2) execute 

search warrants, (3) make arrests, or (4) carry firearms. In addition, some of these law enforcement 

officers are responsible for care and custody of convicted offenders. We defined ATSS personnel to 

include TSA federal air marshals and passenger and baggage screeners/handlers, or transportation 

security officers, and FAA’s air traffic controllers based on the OPM’s occupational groups and 

descriptions as well as agency job descriptions and other information from agency websites.

a

The total number of federal air marshals is sensitive security information.
 

Page 8 GAO-13-96 Religious Accommodations

b

Total number of LEOs and ATSS combined as identified in OPM’s Central Personnel Data File is 

approximately 273,667. Total does not include TSA’s federal air marshals.

All seven of the agencies in our review, including the two agencies not 

subject to section 5550a, have written policies supporting an employee’s 

ability to earn and use compensatory time off for religious observances.13

The agency policies are similar in several ways including: (1) employee 

eligibility, (2) applicability across geographic locations, (3) schedule 

planning, and (4) implementation. First, all of the agencies have policies 

that cover all occupational groups and none include language in their 

policies that make a distinction between the eligibility of LEOs and nonLEOs or ATSS and non-ATSS personnel. However, while FAA’s policy 

applies to all employees, the policy is superseded by a collective 

The agency policies include varied amounts of detail, but in most cases 

they outline who may earn and use compensatory time off for religious 

observances and how and when such compensatory time may be sought. 

Two of the agencies—BOP and FBI—are covered by DOJ’s policy. The 

remaining five agencies—CBP, ICE, TSA, FAA, and IRS—have their own 

agency policies and are not covered by department-wide policies.

 

13As noted, FAA and TSA are not subject to 5 U.S.C. § 5550a and are therefore not 

required to make compensatory time off for religious observances available to their 

employees; however, both agencies have policies that do make compensatory time off for 

religious observances available.

Some Agency Policies 

on Compensatory 

Time off for Religious 

Observances May Not 

Be Subject to or 

Consistent with OPM 

Regulations or 

Guidance; Rationales 

for Policies Vary

Agency Policies Share 

Similarities That Support 

Compensatory Time off for 

Religious Observances
 

Page 9 GAO-13-96 Religious Accommodations

bargaining agreement that allows the air traffic controller bargaining unit 

employees to use only annual leave for religious observances, according 

to FAA officials.

14 As a result, the bargaining unit employees are unable to 

earn and use compensatory time off for religious observances, although 

all other FAA employees may do so.15

Second, all agency policies apply to all of the agencies’ geographical 

locations and all facilities, regardless of a facility’s size or the number of 

employees who work there. All of the agencies in our review have 

numerous locations, facilities, and installations, such as airports and 

federal prisons, of varying size and purpose with thousands of employees 

spread across the country. Despite the geographic diversity, all agency 

employees at every facility and installation have the same ability to seek 

compensatory time off for religious observances, with the aforementioned 

exception of air traffic controller bargaining unit employees at FAA.

Third, all of the agency policies provide employees with flexibility to plan 

their schedules. Typically an employee earns compensatory time off for 

religious observances by performing work outside of his or her normal 

duty hours. All of the agency policies allow their employees the flexibility 

to earn this compensatory time both before and after the religious 

accommodation has been made. In addition, none of the policies include 

caps or other numerical limits on the amount of compensatory time that 

can be earned and used.

 

14Although the FAA has approximately 22,347 air traffic controllers, as shown in table 1, 

not all are subject to the negotiated restriction on using compensatory time off for religious 

observances. Approximately 15,000 air traffic controllers are subject to the restriction in 

the collective bargaining agreement and other approximately 7,000 either are in a different 

bargaining unit with an agreement that permits the use of compensatory time off for 

religious observances or not in a bargaining unit and thus fall under FAA management 

policy, which also permits the use of compensatory time off for religious observances.

15According to FAA officials, the bargaining union negotiated with the FAA to offer only 

annual leave for religious observance. A 2008 Federal Claims Court decision held that 

FAA did not have the authority to provide its employees with regular compensatory time 

for overtime worked instead of paying employees at the overtime rate required by FLSA. 

The court found that the statute providing FAA with flexibility in establishing a new 

personnel management system (49 U.S.C. § 40122(g)) removed FAA’s authority (under 5 

U.S.C. §§ 5543 and 6123) to grant regular compensatory time in lieu of overtime pay 

under FLSA. See Abbey v. United States, 82 Fed. Cl. 722 (2008). In light of the Abbey v. 

United States decision, the FAA and the union negotiated that employees also could not 

earn compensatory time off for religious observances for overtime worked, but could use 

annual leave for religious observance.
 

Page 10 GAO-13-96 Religious Accommodations

Lastly, through interviews with agency officials, we also identified 

similarities in the ways agencies implement their policies, which further 

support employees’ ability to seek compensatory time off for religious 

observances. First, all agencies we reviewed notify their employees of 

their right by law to file a complaint of discrimination. ICE provides this 

information in its religious accommodation policy, which states that any 

employee who believes he or she has been discriminated against based 

on religious practices may file an equal employment opportunity (EEO) 

complaint. Other agency officials stated that employees have the right to 

file an EEO complaint of discrimination if their request for compensatory 

time off for religious observances was denied. For example, officials at 

CBP stated that whenever a supervisor or other decision maker denies an 

employee’s religious accommodation request, the supervisor issues a 

written decision to the employee specifying why the request was denied 

and notifies the employee of his or her right to file an informal EEO 

complaint within 45-calendar days from the date of receiving the 

response. However, with the exception of ICE, information on how to file 

EEO complaints is not included in agencies’ policies.16

Each agency we reviewed also provides managers and supervisors with 

diversity training that includes some information on religious 

accommodations in general, although agencies vary in whether they 

specifically cover issues on religious compensatory time off. As we have 

previously reported, diversity training can help an organization’s 

management and staff increase their awareness and understanding of 

diversity as well as develop concrete skills to assist them in 

communicating with a diverse workforce.

In addition, 

employees covered by collective bargaining agreements (CBA) may also 

file grievances with the agencies or through their unions and may be 

informed of such a process by their union representative.

17

 

16Such guidance may be found in other agency documents; however, we did not include 

them in the scope of our review.

Such training can provide 

employees with an awareness of their differences—including cultural, 

work style, and personal presentation—and an understanding of how 

diverse perspectives can improve organizational performance. In our 

review, some agencies provide training on sensitivity and awareness of 

religious accommodations, such as accommodations for dress and 

17GAO, Diversity Management: Expert-Identified Leading Practices and Agency 

Examples, GAO-05-90 (Washington, D.C.: Jan. 14, 2005).
 

Page 11 GAO-13-96 Religious Accommodations

personal grooming, while others provide additional information on 

schedule adjustments for religious observances. ICE provides its 

managers and supervisors with information on EEOC’s definition of 

religion, governing laws, and the duty of the agency to provide reasonable 

accommodations. CBP’s awareness training for supervisors provides 

examples of different methods for providing schedule adjustments for 

religious accommodations other than compensatory time off for religious 

observances, such as voluntarily swapping shifts with other employees. 

For some agencies, the additional EEO training and information 

complements language included in policy outlining management’s 

responsibility regarding approval of religious accommodation requests. 

For example, TSA’s policy states that management should not make any 

judgment about the employee’s religious beliefs when deciding whether 

an employee’s request for an adjusted work schedule should be 

approved.

Finally, all of the agencies use automated time and attendance systems 

to record data on earned and used compensatory time off for religious 

observances, as stated in OPM’s regulations. Supervisors can use data in 

time and attendance systems to monitor the number of hours employees 

are accumulating or using and to determine whether employees are 

within the cap for the number of pay periods outlined in the agency policy 

guidance. Some systems enable the employee to submit automated 

requests directly to their supervisor. For example, ICE states in its policy 

that employees are to make official requests for compensatory time 

through the agency’s time and attendance system. IRS states in its policy 

that first-level supervisors are to use the agency time and attendance 

system to maintain records of compensatory time off for religious 

observances earned and used. None of the agencies in our review told us 

that management routinely reviews the level of compensatory time off for 

religious observances requested, accrued, or used, and the agencies 

have no requirement to report out on such data.

Several differences exist in the way agencies administer their policies on 

compensatory time off for religious observances. These differences fall 

into different categories: (1) caps on the number of pay periods to earn 

and use compensatory time off for religious observances, (2) repaying 

compensatory time off for religious observances that was taken in 

advance, (3) the forms or other documentation required to make the 

request and the reason for request, (4) other types of schedule 

adjustments referenced in the policy, and (5) disposition of unused 

Policy Differences Exist 

and OPM Regulations Do 

Not Specify Proper 

Administration of Unused 

Compensatory Time off for 

Religious Observances
 

Page 12 GAO-13-96 Religious Accommodations

compensatory time off for religious observances. See table 2 for 

additional information.

Table 2: Agency Policies Display Differences in Several Categories 

Agencies Pay period cap

Consequences of 

not earning 

compensatory time 

off for religious 

observances taken 

in advance 

Forms or 

documentation required 

and reason for request 

Other types of 

schedule adjustments 

referenced

Disposition of 

unused 

compensatory time 

off for religious 

observances

CBP Earn and use in 

five pay periods; 

three pay periods 

to repay advanced 

use compensatory 

time 

Annual leave taken 

to eliminate negative 

balance

• Oral request 

currently, but drafting 

a policy to use 

request form in the 

future, according to 

agency officials

• Policy does not 

address whether 

employees need to 

provide a reason for 

the request

• Annual leave

• Leave-without-pay 

(LWOP) 

• Requests to make 

other reasonable 

arrangements if 

such arrangements 

do not cause undue 

hardship on the 

business of CBP

Employee time is 

converted to regular 

compensatory time, 

although CBP officials 

state that any 

subsequent 

liquidation of such 

time is at the basic 

pay rate

ICE Earn and use in 

six pay periods; six 

pay periods to 

repay 

compensatory time 

taken in advance 

based on 

collective 

bargaining 

agreement (CBA)

Annual leave or 

leave without pay 

taken, as 

appropriate (based 

on CBA)

• Request through time 

and attendance 

system (based on 

CBA) 

• No reason required 

as a general rule 

(based on CBA)

• Flexible scheduling

• Time and place to 

pray

• Other workplace 

practices, policies, 

and/or practices

Employee forfeits 

unused time (based 

on CBA)

TSA Earn and use in 

two pay periods; 

employees not 

allowed to “bank” 

excess 

compensatory time 

off for an unknown 

future use 

Required to liquidate 

the indebtedness—

required to make a 

payment at the nonovertime rate

• Written request to 

supervisor in 

advance of date

• Request should 

specifically states 

that it is for religious 

purposes

• Available 

compensatory time 

off in lieu of 

overtime pay

• Available 

compensatory time 

off for travel

• LWOP

• Accrued and 

accumulated, 

advance annual 

leave

• Adjusted work 

schedules

• Shift swaps for 

transportation 

security officers

Employee receives 

payment at the 

nonovertime rate at 

time of separation 

from TSA
 

Page 13 GAO-13-96 Religious Accommodations

BOP and the 

FBIa Earn and use in six periods 

Annual leave or 

LWOP taken (as 

requested by the 

employee) 

• OPM’s Standard 

Form 71, Application 

for Leave, or other 

form prescribed by 

the department, 

agency, or approving 

official

• OPM’s Standard 

Form 71 does not 

provide specifically 

for compensatory 

time off for religious 

observances

• Policy does not 

address whether 

employees need to 

provide a reason for 

the requestb

• No additional 

adjustments 

detailed

Employee forfeits 

unused time

FAA No cap detailed in 

policyc Annual leave, use of credit hours, or 

LWOP taken

• Written request for an 

adjusted work 

schedule in advance

• Request must 

specifically state that 

the request for an 

adjusted work 

schedule is for 

religious purposes

• Annual leave

• Use of credit hours

• LWOP

Employee paid at the 

rate of basic pay in 

effect when the extra 

hours were worked, 

should he or she 

separate or transfer 

before using the 

compensatory time 

set aside for religious 

observances

IRS Earn and use in 

120 days 

Annual leave or 

LWOP taken as 

appropriate

• Written request to 

take compensatory 

time off for a specific 

religious observance 

that identifies the 

need to abstain from 

work

• Request should 

identify the need to 

abstain from work

• Annual leave

• LWOP

• Previously earned 

compensatory time 

in lieu of overtime

• Change to their 

regularly scheduled 

tour of duty to 

accommodate their 

personal religious 

beliefs 

Employee paid at the 

rate of basic pay at 

the time the work was 

performed when 

separating 

Source: GAO analysis of agency policies and CBAs.

a

DOJ’s policy covers all of its agencies.

b

DOJ’s Leave Administration Policy allows other “forms” than the Standard Form 71, and allows its 

agencies to make the determination as to how employees must request leave. The FBI has decided 

that employees should present and document these requests through their time and attendance 

system. In addition, an employee may make a request of their supervisor in writing or orally, and then 

follow up in their time and attendance system to document the transaction.

c

CBA for air traffic controllers does not allow for these personnel to earn compensatory time off for 

religious observances. They may only use annual leave.

Since each agency has a different mission and different requirements of 

its employees, agencies developed and administered policies on 
 

Page 14 GAO-13-96 Religious Accommodations

compensatory time off for religious observances to fit their individual 

needs. Most of the differences are consistent with OPM regulations and 

guidance or otherwise within the discretion of the agency in administering 

compensatory time off for religious observances. In fact, OPM officials we 

spoke with stated that policies on compensatory time off for religious 

observances should not be “one-size-fits-all” and OPM recognizes 

agencies may have different requirements.

Moreover, all of the agencies reported few or no issues and cases within 

their respective agencies on administering compensatory time off for 

religious observances, including denying requests or granting schedule 

adjustments. OPM commented that a few issues had been raised at one 

agency concerning certain aspects of compensatory time off for religious 

observances over the last 5 years and have been resolved. Otherwise, 

according to OPM officials, they have not observed any practical 

problems with agencies administering the regulations nor have they 

received any questions or comments from EEOC concerning 

administration of the regulations. EEOC commented that employees have 

filed few cases of discrimination related to requests for a schedule 

change or adjustment for religious observances. We interviewed union 

officials from the Council of Prison Locals in the American Federation of 

Government Employees, National Air Traffic Controllers Association, and 

National Treasury Employees Union that represent bargaining units at 

agencies with union representation and none of them reported problems 

within their constituencies concerning requesting compensatory time off 

for religious observances or denials of compensatory time off for religious 

observances requests. Finally, we interviewed representatives of LEO 

associations and they also reported no problems within their groups 

concerning requesting compensatory time off for religious observances or 

denials of compensatory time off for religious observances requests.

Even so, while some differences in policy reflect the individual needs of 

agencies in our review, in one area the differences in policy may reflect a 

lack of clarity in OPM regulations. Specifically, regarding the disposition of 

unused compensatory time off for religious observances, CBP’s policy 

provides for conversion of unused compensatory time off for religious 

observances to regular compensatory time, which is not clearly 

authorized under section 5550a and OPM regulations, based on our 

discussions with OPM. The ICE and DOJ policies provide for the 

forfeiture of unused compensatory time off for religious observances 

which is contrary to OPM guidance providing that unused compensatory 

time off for religious observances is to be paid off at the rate of basic pay 

in effect when earned upon an employee’s separation or transfer.
 

Page 15 GAO-13-96 Religious Accommodations

CBP’s policy states that unused compensatory time off for religious 

observances will be converted to regular compensatory time at the end of 

five pay periods and will be subject to the regulations which govern 

regular compensatory time.18 Under OPM regulations addressing the 

liquidation of regular compensatory time, payment is generally at the 

overtime rate.19 Yet, CBP officials told us that they do not intend for 

employees to receive the overtime rate of pay upon liquidation of 

compensatory time off for religious observances which has been 

converted to regular compensatory time and state that controls in their 

time and attendance system ensure that unused compensatory time off 

for religious observances is paid at the rate of basic pay. Moreover, CBP 

officials said they recognize that the language in their policy could be 

misconstrued as permitting liquidation of the converted compensatory 

time at the overtime rate of pay and will take it into consideration when 

renegotiating policies in upcoming discussions with the union. According 

to CBP officials, the policy provision providing for the conversion of 

compensatory time off for religious observances to regular compensatory 

time was at the request of the union. The negotiability of this provision 

was challenged by the agency as inconsistent with OPM regulations on 

compensatory time off for religious observances but a decision by the 

Federal Labor Relations Authority (FLRA) concluded that converting 

unused compensatory time off for religious observances into regular 

compensatory time was not prohibited by OPM regulations and was 

therefore subject to collective bargaining.20

Noting a lack of analysis supporting the FLRA’s conclusion, a Senior 

Counsel in OPM’s Office of the General Counsel, stated that the 

conversion of unused compensatory time off for religious observances to 

regular compensatory time is contrary to section 5550a and OPM’s 

implementing regulations, even assuming that liquidation of such 

The decision did not address 

the liquidation of such compensatory time.

 

18CBP’s parent department, DHS, does not have a department-wide policy on 

compensatory time off for religious observances.

195 C.F.R. § 550.114 and § 551.531. 

2046 F.L.R.A. 696 (Nov. 27, 1992).
 

Page 16 GAO-13-96 Religious Accommodations

converted leave is at the rate of basic pay in effect when earned.21 In 

OPM’s view, compensatory time off for religious observances and regular 

compensatory time are different forms of compensatory time off that are 

separately authorized, serve different purposes, and are subject to 

differing conditions for earning, using, retaining, as well as liquidating.22

We have previously affirmed OPM’s view that these two forms of 

compensatory time off are to be regarded as separate and distinct kinds 

of entitlements.23

OPM’s regulations on compensatory time off for religious observances do 

not specifically address the proper treatment of unused compensatory 

time off for religious observances. Further, ICE and DOJ’s policies require 

their employees to forfeit earned compensatory time off for religious 

observances if it has not been used within a certain number of pay 

periods, which may result in employees not being paid for time that they 

have earned. OPM officials said they have concerns about such 

forfeitures since employees did earn the time. One OPM official stated 

that earned compensatory time off for religious observances should 

remain to the credit of the employee until separation or transfer, and, as

specified in OPM guidance, then liquidated at the regular rate of pay in 

effect when earned. However, these OPM officials recognize that section 

5550a and OPM’s regulations do not prohibit forfeiture and that OPM’s 

guidance providing for the proper disposition of unused compensatory 

time off for religious observances is not binding on agencies, but serves 

as meaningful advisement for agencies in applying the law and 

regulations for compensatory time off for religious observances off. OPM 

 

21In this regard, we note that when FLRA decisions are subject to judicial review by 

federal courts of appeal, those courts do not accord deference to an FLRA interpretation 

of a statute or regulation that it does not administer, such as would be the case here 

where OPM has been charged with the responsibility to administer both regular overtime 

and compensatory time off for religious observances provisions. United States Dept. of the 

Air Force v. FLRA, 952 F.2d. 446 (D.C. Cir. 1991) and IRS v. FLRA, 521 F.3d 1148 (Ninth 

Cir. 2008).

22For rules addressing regular compensatory time for those exempt or non-exempt from 

the minimum wage and overtime provisions of FLSA, see 5 U.S.C. § 5543 and 5 C.F.R. § 

550.114 (covering FLSA exempt employees) and 5 C.F.R. § 551.531 (covering FLSA 

nonexempt employees).

23See 62 Comp. Gen. 589 (1983) wherein we concluded that compensatory time off for 

religious observances is not subject to the aggregate salary limitation under 5 U.S.C. § 

5547 which serves to limit the amount of regular compensatory time earned in lieu of 

monetary compensation for overtime work performed.
 

Page 17 GAO-13-96 Religious Accommodations

officials also said they are drafting updated regulations that they believe 

will address the disposition of unused compensatory time off for religious 

observances among other things, but have not established a timetable for 

completing their internal review of the proposed regulations. OPM officials 

plan to complete their process for drafting the proposed regulations 

sometime next year. Without such clarification on the disposition of 

unused compensatory time off for religious observances in OPM’s 

regulations, agencies may have policies that are not consistent with 

OPM’s views on the proper disposition of unused compensatory time off 

for religious observances.

We discussed with department and agency officials the reasons why their 

agencies adopted specific policy provisions, such as time limitations. In 

most cases, officials said the agencies followed existing federal rules 

when developing policies and that they wanted to provide their employees 

with additional scheduling flexibility. However, two agencies—IRS and 

CBP—made or are making changes to their compensatory time off for 

religious observances policies based on findings by their department’s 

Inspector General or EEOC.

• IRS developed its current policy following an August 2009 report by 

the Treasury Inspector General for Tax Administration (TIGTA). In 

March 2006, IRS had identified 42 employees as having balances 

from 101 to 305 hours of compensatory time off for religious 

observances. By February 2008, 18 of these employees still had 

balances of 80 hours or more, an amount equivalent to 2 weeks, or 

one pay period, and that TIGTA considered being an excessive 

balance. TIGTA identified that IRS needed additional controls to 

address such potential abuse as excess accumulation of 

compensatory time off for religious observances, and according to 

agency officials, IRS’s current policy was designed to comply with this 

recommendation.

• CBP officials stated the agency is modifying its policy based on a 

2009 EEOC administrative judge decision that included a finding that 

CBP failed to facilitate voluntary swaps of work schedules.24

 

24The administrative judge’s 2009 decision was affirmed on appeal and a request for 

reconsideration was denied in 2011. 

As a 

result, CBP established a formal process for employees requesting 

Agencies Have Various 

Rationales for Developing 

Their Policies on 

Compensatory Time off for 

Religious Observances
 

Page 18 GAO-13-96 Religious Accommodations

religious accommodations. The directive was forwarded to the 

agency’s commissioner of June 11, 2012, where it is awaiting final 

agency approval.

Overall, the seven agencies we reviewed have policies in place for 

employees to adjust their work schedules to engage in religious 

observances. While most of the agencies reviewed have policies that 

permit employees to earn and use compensatory time to meet religious 

obligations, many of FAA’s air traffic controllers may only take annual 

leave for religious observances due to their collective bargaining 

agreement. Many agency policies showed similarities but varied in areas 

such as caps for the number of pay periods employees can earn and use 

compensatory time and on the disposition of unused compensatory time. 

OPM prescribed regulations for the administration of compensatory time 

off for religious observances as required but these regulations do not 

address all aspects of implementing such a policy and some confusion 

exists. Specifically, agencies may be instituting practices in areas such as 

disposition of unused compensatory time off for religious observances in 

a way that OPM views as unauthorized or inconsistent with the proper 

administration of this authority. OPM has an opportunity to provide 

agencies with clarification on the administration of compensatory time off 

for religious observances but does not have a firm timetable for 

completing its internal review of proposed revised regulations. Unless 

OPM clarifies its regulations and works with agencies such as CBP to 

revise its policy, there is a continued risk agencies’ religious 

accommodation leave policies will not be in accordance with the proper 

administration of this authority.

To ensure agency compensatory time off for religious observances 

policies are in accordance with the proper administration of OPM’s 

regulations on compensatory time off for religious observances, we 

recommend the Director of OPM take the following actions:

• Establish time frames for the internal process of finalizing proposed 

revised regulations for compensatory time off for religious 

observances. Such revised regulations should provide clarification in 

areas such as the disposition of unused compensatory time off for 

religious observances.

• Work with CBP to ensure its policies and practices regarding its 

disposition of unused compensatory time off for religious observances 

Conclusion 

Recommendations for 

Executive Action
 

Page 19 GAO-13-96 Religious Accommodations

are in compliance with section 5550a and OPM’s implementing 

regulations.

We provided a draft of this report to OPM, DOJ, DOT, DHS, and Treasury 

for review and comment.25 In commenting on a draft of this report, OPM 

agreed with our recommendations. OPM said compensatory time off for 

religious observances off is an important human resource tool to support 

the needs of federal employees. Regarding our first recommendation, 

OPM agreed to issue proposed regulations in 2013 but did not commit to 

an exact time frame due to the numerous steps needed to review, 

consider public comments, and finalize draft regulations, including 

submission to the Office of Management and Budget for interagency 

clearance. OPM agreed with our second recommendation and will assist 

CBP in complying with the law and OPM’s regulations for both 

compensatory time off for religious observances off and regular 

compensatory time off. OPM believes that although its guidance for 

providing for the proper disposition of unused religious compensatory 

time off is not binding on agencies. CBP should comply with this guidance 

until OPM issues explicit regulations to cover this matter. DHS also 

agreed with our recommendation and stated it will work to ensure its 

policies and practices comply with OPM’s regulations. OPM, DOJ, DOT, 

DHS, and Treasury provided technical comments, which we incorporated 

where appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until seven days from the 

report date. At that time, we will send copies to other interested 

congressional committees; the Secretaries of Homeland Security, 

Transportation, and Treasury; the Attorney General and the Directors of 

the U.S. Office of Personnel Management, U.S. Customs and Border 

Protection, Federal Aviation Administration, Federal Bureau of 

Investigation, Federal Bureau of Prisons, U.S. Immigration and Customs 

Enforcement, Internal Revenue Service, and Transportation Security 

Administration. In addition, the report will be available at no charge on the 

GAO website at http://www.gao.gov.

 

25This report number changed to GAO-13-96 after we provided agencies with the draft 

report GAO-12-921 for comment. 

Agency Comments
 

Page 20 GAO-13-96 Religious Accommodations

If you or your staff have any questions about this report, please contact 

me at (202) 512-2717 or jonesy@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix IV.

Sincerely yours,

Yvonne D. Jones

Director, Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 21 GAO-13-96 Religious Accommodations

In response to your request we identified the similarities and differences 

in policies of selected agencies concerning compensatory time off for 

religious observances for law enforcement officers (LEO) and air 

transportation safety and security (ATSS) personnel and described their 

rationale for adopting the policies.

We selected seven federal agencies for our review. These agencies had 

a substantial concentration of LEO and ATSS personnel. Based on our 

previous work, we defined a LEO as an individual authorized to perform 

any of four specific functions: (1) conduct criminal investigations, (2) 

execute search warrants, (3) make arrests, or (4) carry firearms.1

Using data from OPM’s Central Personnel Data File, we selected six 

agencies with over 10,000 LEOs and ATSS employees based on their 

OPM occupational group and description, including personnel in the 

correctional officer series and the investigation and transportation groups. 

These included three components in the Department of Homeland 

Security—U.S. Customs and Border Protection, U.S. Immigration and 

Customs Enforcement, and TSA; two components in the Department of 

Justice—Federal Bureau of Investigation and Federal Bureau of Prisons; 

and one agency in the Department of Transportation—FAA. We selected 

the seventh agency, the Internal Revenue Service, because of their 

unique role in criminal investigations of tax matters. We believe the 

Central Personnel Data File data are sufficiently reliable for our purposes.

In 

addition, some of these law enforcement officers are responsible for care 

and custody of convicted offenders. We defined ATSS personnel to 

include Transportation Security Administration’s (TSA) federal air 

marshals and passenger and baggage screeners/handlers, or 

transportation security officers, and Federal Aviation Administration’s 

(FAA) air traffic controllers based on the U.S. Office of Personnel 

Management’s (OPM) occupational groups and descriptions as well as 

agency job descriptions and other information from agency websites. We 

consulted with you and with our Applied Research and Methodology team 

on the engagement scope.

To accomplish our objectives, we evaluated agency policies and other 

documentation and identified similarities and differences in compensatory 

 

1

GAO, Federal Law Enforcement; Survey of Civilian Law Enforcement Functions and 

Authorities, GAO-07-121 (Washington, D.C.: Dec. 19, 2006). 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 22 GAO-13-96 Religious Accommodations

time off for religious observances. We also reviewed applicable federal 

statutes and regulations, as well as proposed regulations, and executive 

branch policies and guidance. Since OPM is responsible for administering 

the statute on compensatory time off for religious observances and the 

U.S. Equal Employment Opportunity Commission (EEOC) is responsible 

for enforcing the federal antidiscrimination statute requiring religious 

accommodation, we interviewed officials from each on their duties and 

responsibilities concerning accommodations for federal employees and 

reviewed applicable EEOC cases. We developed a structured interview 

instrument to discuss agency policies on schedule adjustment for 

religious accommodation, and the rationale for such policies, with human 

resource/human capital officials, field supervisors, and civil rights/diversity 

officials, from selected agencies and their ‘parent’ departments. We also 

interviewed LEO association representatives as well as union 

representatives from the Council of Prison Locals in the American 

Federation of Government Employees, National Air Traffic Controllers 

Association, and National Treasury Employees Union about whether, 

from their viewpoint and the viewpoint of those they represented, there 

were any problems or concerns with schedule accommodation or 

compensatory time for religious observance at the selected agencies.

For purposes of this report, we defined schedule adjustments as anything 

that would require an employee to make modifications to his or her 

assigned schedule for religious purposes. This could include requesting 

compensatory time off for religious observances, using annual leave or 

leave without pay, or requesting schedule changes or shift swaps

We conducted this performance audit from December 2011 through 

October 2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Comments from the Office of 

Personnel Management

Page 23 GAO-13-96 Religious Accommodations

Appendix II: Comments from the Office of 

Personnel Management
Appendix II: Comments from the Office of 

Personnel Management

Page 24 GAO-13-96 Religious Accommodations
Appendix II: Comments from the Office of 

Personnel Management

Page 25 GAO-13-96 Religious Accommodations
Appendix III: Comments from the Department 

of Homeland Security

Page 26 GAO-13-96 Religious Accommodations

Appendix III: Comments from the 

Department of Homeland Security
Appendix IV: GAO Contact and Staff 

Acknowledgment

Page 27 GAO-13-96 Religious Accommodations

Yvonne D. Jones, (202) 512-2717 or jonesy@gao.gov

In addition to the contact named above Signora May, Assistant Director; 

Steven J. Berke; Dewi Djunaidy; Karin Fangman; Robert Gebhart; and 

Greg Wilmoth made key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgment 

GAO Contact

Staff 

Acknowledgments 

(450953)
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