4-2-2021 Draft – Subject to Change – Close-Hold Distribution Only

ATTACHMENT C

# **ACCOUNTING SCENARIOS FOR THE EMERGENCY FEDERAL EMPLOYEE LEAVE FUND**

**BACKGROUND**

Section 4001 of the American Rescue Plan Act of 2021 (Public Law 117-2), enacted on March 11, 2021, established a new category of paid leave for selected Federal employees.  Eligibility for the leave is based on certain COVID-19-related qualifying circumstances. This emergency paid leave will be funded by a $570 million Emergency Federal Employee Leave Fund (Fund) and administered by the Director of the Office of Personnel Management (OPM).  Amounts in the Fund shall be available for reimbursement to an agency for the use of paid leave under this section by any covered employee of the agency who is unable to work because of certain COVID-19-related qualifying circumstances.

Each agency with covered employees using emergency paid leave must submit to OPM a request for reimbursement from the Fund.  Agencies must inform employees that the granting of emergency paid leave to employees who meet the eligibility conditions is tentative and conditional upon monies being available in the Fund.  When submitting a reimbursement claim to OPM, an authorized agency official must attest that, to the official’s knowledge, the agency’s established policies and procedures for implementing emergency paid leave are in compliance with section 4001 and OPM’s supporting guidance.  

OMB/Treasury has established a unique Treasury Account Fund Symbol (TAFS) under OPM agency identification code (024-2021/2022-0806).  Agencies should reference this TAFS with the reimbursements received from this Fund.  OPM has received a definite mandatory appropriation of $570 million.  OMB has apportioned the budgetary resources into two category B projects - Emergency Federal Employee Leave Fund ($565 million) and Administration EFELF ($5 million).

**PURPOSE**

To outline guidance on the accounting for the emergency paid leave reimbursement activity by OPM and the agencies seeking reimbursements from the Fund.

**ACCOUNTING SCENARIOS FOR THE REIMBURSEMENT TRANSACTIONS**

Agency’s request for reimbursement should be based on disbursements to eligible employees.  The two scenarios below relate to the timing of the reimbursements affecting TAFSs.  Scenario 1 addresses emergency leave paid (i.e., disbursement) by a requesting agency and reimbursed by OPM (from budgetary resources in TAFS 024-2021/2022-0806) to a requesting agency in FY 2021.  Scenario 2 addresses emergency paid leave paid (i.e., disbursement) by a requesting agency in FY 2021 but reimbursed by OPM (from budgetary resources in TAFS 024-2021/2022-0806) to a requesting agency in FY 2022.  All disbursements must be incurred during the allowable period specified in OPM’s supporting guidance.  

**SCENARIO 1** – Current year (FY 2021) activity, including agencies’ reimbursement requests submitted, approved, and paid for emergency paid leave disbursed in FY 2021.  Eligible period covered by section 4001 is March 11, 2021 – September 30, 2021.

**Note 1:**  In this presentation, additional entries related to Budgetary Resources (e.g., appropriation, spending authority from offsetting collections, etc.) of the requesting agency, and the Status for Budgetary Resources (e.g., apportionments, allotments) of OPM and the requesting agency are not shown.  

**Note 2:** Reimbursement from the Fund is contingent on budgetary resources being available in the Fund.  As a result, when the requesting agency prepares and submits a request for reimbursement, there is no receivable to set up by the requesting agency and no payable to be set up by OPM.  After OPM approves the request and processes an Intra-Governmental Payment and Collection (IPAC) to reimburse the requesting agency, transaction 3 shows the recording of OPM’s disbursement, and the requesting agency’s receipt of the reimbursement.

**Note 3:** Reimbursements to agencies are conditional upon budgetary resources being available in the Fund.  Accounting entries for situations where the Fund is depleted are not presented in this document.  Agencies should refer to OPM’s supporting guidance.

1. *To record the enactment of FY 2021 appropriation and warrant received for OPM Emergency Federal Employee Leave Fund (024-2021/2022-0806.)*

2. *To record the payroll payment (Paid Leave) by the requesting agency against its own budgetary resources before any reimbursement by OPM.*

3. *To record a disbursement out of the Fund to reimburse agency XXX, as directed by**section 4001.  OPM reimburses the agency via IPAC.  The requesting agency must have submitted a request for reimbursement to OPM and records the reimbursement entry as refunds collected to a current fiscal year paid obligation (i.e., disbursement).*

4. *To record appropriations used this fiscal year.*

**SCENARIO 2** – Subsequent year (FY 2022) activity, including agencies’ reimbursement requests submitted and/or approved in FY 2021 or FY 2022 but paid to the requesting agency for emergency paid leave disbursed in FY 2022.  Eligible period covered by the Statute is March 11, 2021 – September 30, 2021.  For example, an employee may use conditionally granted emergency paid leave through September 30, 2021, in the biweekly pay period covering September 18, 2021, through October 1, 2021, and the employee’s paycheck for that period (including leave disbursements) would be issued in October 2021.  Also, an agency may be retroactively applying conditional emergency paid leave to an earlier biweekly pay period in FY 2021 as a retroactive correction processed (disbursed) in FY 2022. 

1. *To record a disbursement out of the Fund in FY 2022 to reimburse agency XXX, as directed by section 4001.  OPM reimburses the agency via IPAC.  The requesting agency must have incurred the disbursements during the allowable period and submitted a request for reimbursement to OPM.  The requesting agency records the reimbursement as a downward adjustment to a prior fiscal year paid obligation (i.e., disbursement).*

2. *To record appropriations used this fiscal year.*

*Specific TAFS will depend on the agency requesting reimbursement from the Fund.  The accounting for the disbursement and the reimbursement depends on the type of fund used.  For budgetary resources derived from the General Fund of the US Treasury, the agency will also record the entry for appropriations used (e.g. Transaction Code B234 for disbursement) when it records the disbursement and the reimbursement as a downward adjustment to a prior fiscal year paid obligation (i.e., disbursement).