FEDERAL PAID 

ADMINISTRATIVE 

LEAVE

Additional Guidance 

Needed to Improve 

OPM Data

Report to Congressional Requesters

October 2014

GAO-15-79

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-79, a report to 

congressional requesters

October 2014

FEDERAL PAID ADMINISTRATIVE LEAVE

Additional Guidance Needed to Improve OPM Data 

Why GAO Did This Study

Federal agencies have the discretion 

to grant paid administrative leave for a 

variety of reasons, such as weather 

closures and blood donations. While 

paid administrative leave costs 

taxpayers, it has not been reviewed or 

reported on extensively. 

GAO was asked to examine the use of 

paid administrative leave. This report 

(1) describes paid administrative leave

policies at selected federal agencies; 

(2) reviews practices in recording and 

reporting paid administrative leave and 

describes the number of federal 

employees granted such leave, and 

the amount and associated salary 

costs of such leave; and (3) describes

categories for which large amounts of 

paid administrative leave have been 

charged by individual employees at

selected federal agencies. 

To determine the total amount of paid 

administrative leave, GAO analyzed 

fiscal year 2011 through 2013 payroll 

data from OPM’s Enterprise Human 

Resources Integration system. To 

review agency policies and reasons for 

using large amounts of administrative 

leave, GAO selected five agencies

based in part on the percentage of 

employees with higher-than-average 

amounts of such leave.

What GAO Recommends

GAO recommends that OPM develop 

agency and payroll provider guidance 

regarding the recording and reporting 

of paid administrative leave. OPM 

partially concurred agreeing to clarify 

guidance to agencies and payroll 

providers, but said it could not direct 

agencies on how to collect such data. 

GAO continues to believe the 

recommendations are valid.

What GAO Found

Policies. Agencies have the authority to grant paid administrative leave—an 

excused absence without loss of pay or charge to individual leave—and to set 

policies governing its use. Among the five agencies GAO reviewed—the 

Departments of Defense (DOD), the Interior, and Veterans Affairs (VA); the 

General Services Administration; and the U.S. Agency for International 

Development (USAID)—agency policies and guidance contained several 

common activities for granting paid administrative leave (such as voting and

blood donations). However, variations exist, depending on agency mission and 

how leave is categorized in agency policy. For example, USAID and DOD 

officials said that they grant paid administrative leave for rest and recuperation to 

employees serving 6 months or more in Afghanistan, while the other selected 

agencies did not. 

Recording and Reporting Practices. GAO found inaccuracies in Office of 

Personnel Management (OPM) data due to (1) differences between agencies’

leave recording practices and what OPM officials consider paid administrative 

leave; and (2) differences in what payroll providers report to OPM as paid

administrative leave. For example, VA employees record all authorized official 

time for union activities as paid administrative leave in the agency’s time and 

attendance system. In addition, one payroll provider includes federal holidays as 

administrative leave when reporting the data to OPM. OPM officials said that, in 

both instances, they would not expect such absences to be recorded as 

administrative leave. These variations occur because OPM has not provided 

guidance on what agencies should record and has provided limited guidance on 

what payroll providers should report as paid administrative leave. Such guidance 

could help agencies better manage the federal workforce.

Amounts and Costs. After separating federal holidays from the payroll data,

OPM-reported data showed that from fiscal year 2011 through 2013, paid 

administrative leave accounted for less than 1 percent of total paid work days

and estimated salary cost. Over these 3 years, about 97 percent of employees

charged 20 days or less (see figure). For the same time period, 263 employees 

charged between 1 and 3 years of paid administrative leave, with an estimated 

salary cost of $31 million.

Large Amounts. Agency officials stated that the most common reason for which 

selected employees charged amounts relatively higher than the agency average,

was for personnel matters, such as investigations into alleged misconduct.

Employees Charging Paid Administrative Leave Government-wide Fiscal Years 2011-2013

Note: Reflects workdays (5 days per week, about 21 days per month, and 260 days per year).

View GAO-15-79. For more information, 

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

jonesy@gao.gov. 
Page i GAO-15-79 Federal Paid Administrative Leave

Letter 1 

Background 3

Selected Agencies Consistently Categorize Some Activities as 

Acceptable Reasons for Granting Paid Administrative Leave; 

However, Variations Exist 10

Differences in Agency Leave Recording Practices and in Payroll 

Providers’ Interpretation of Guidance Contributed to Large 

Variations in Reporting of Paid Administrative Leave 14

Personnel Matters and Physical Fitness Activities were the Most 

Common Reasons for Charging Large Amounts of Paid 

Administrative Leave 28

Conclusions 31

Recommendations 32

Agency Comments and Our Evaluation 32

Appendix I Objectives, Scope, and Methodology 36

Appendix II Paid Administrative Leave Summary Data by Agency 42

Appendix III Employees with Higher-Than-Average Total Administrative 

Leave by CFO Act Agency 46

Appendix IV Comments from the Office of Personnel Management 49

Appendix V Comments from the Department of Agriculture 51

Appendix VI Comments from the Department of Defense 52

Contents
Page ii GAO-15-79 Federal Paid Administrative Leave

Appendix VII Comments from the Department of Veterans Affairs 54

Appendix VIII GAO Contacts 56

Tables

Table 1: Activities Commonly Categorized as Reasons for 

Granting Paid Administrative Leave by Number of 

Selected Agencies That Cited the Reasons 11

Table 2: Reasons for the Largest Total Amounts of Paid 

Administrative Leave by Number of Times Cited for 

Selected Employees 30

Table 3: FY2011-2013 Paid Administrative Leave Charges by 

Agency 42

Table 4: FY2011-2013 Estimated Salary Cost of Paid 

Administrative Leave by Agency 44

Table 5: Number of Employees at Each CFO Act Agency from 

Fiscal Years 2011 through 2013 with Higher-ThanAverage Total Administrative Leave by Time Range 

(excluding federal holidays) 46

Table 6: Summary of Employees with Higher-Than-Average 

Administrative Leave by Agency from Fiscal Years 2011 

through 2013 (excluding federal holidays) 47

Figures

Figure 1: Example of How Selected Agencies Categorize Activities 

Differently in Leave Policies 13

Figure 2: An Example of Variations in Time and Attendance 

Reporting between Two Agencies and Two Payroll 

Service Providers 18

Figure 3: Paid Administrative Leave Government-wide – 

Estimated Totals and Federal Holidays for Fiscal Years 

2011-2013 21

Figure 4: Impact of Federal Holidays upon Paid Administrative 

Leave for Some Agencies Using National Finance Center 

as Payroll Provider – Average Days per Employee for 

Fiscal Years 2011-2013 22
Page iii GAO-15-79 Federal Paid Administrative Leave

Figure 5: Percentage of Paid Administrative Leave Days to Total 

Paid Days Government-wide – by Percentage of Federal 

Employees for Fiscal Years 2011-2013 24

Figure 6: Reported Paid Administrative Leave Government-wide 

for Fiscal Years 2011-2013 25

Figure 7: Percentage of Estimated Paid Administrative Leave 

Salary to Total Salary Government-wide- by Percentage 

of Estimated Salary for Fiscal Years 2011-2013 27

Abbreviations 

CFO Act Chief Financial Officers Act of 1990

CPDF Central Personnel Data File

DOD Department of Defense

EHRI Enterprise Human Resources Integration

FLRA Federal Labor Relations Authority

FPM Federal Personnel Manual

GSA General Services Administration

HR LOB Human Resources Line of Business

Interior Department of the Interior

MSPB Merit Systems Protection Board

NFC National Finance Center

OPM Office of Personnel Management

State Department of State

USAID U.S. Agency for International Development 

VA Department of Veterans Affairs

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Page 1 GAO-15-79 Federal Paid Administrative Leave

441 G St. N.W.

Washington, DC 20548

October 17, 2014

The Honorable Charles E. Grassley

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Tom A. Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Darrell Issa

Chairman

Committee on Oversight and Government Reform

House of Representatives

The federal government has different types of leave for employees to use 

when they are away from the workplace. These types of leave include 

annual leave, sick leave, leave under the Family and Medical Leave Act, 

donated leave under the voluntary leave transfer program, military leave, 

and paid administrative leave. Federal agencies have the discretion to 

authorize paid administrative leave—an excused absence without loss of 

pay or charge to leave—for a variety of reasons, including closures for 

severe weather and blood donations. Paid administrative leave is a cost 

to taxpayers. If it is used for a large number of government employees 

(such as when major snowstorms and hurricanes force the closure of 

federal government offices) or for extended periods of time (such as when 

an employee is placed on paid administrative leave for several months 

pending a conduct-related investigation), this cost could be substantial.

Furthermore, neither the government-wide cost nor the frequency and 

total amount of paid administrative leave granted to federal employees 

have been reviewed or reported on extensively.

In light of this, you asked us to examine the use of paid administrative 

leave. In this report, we (1) describe policies for paid administrative leave 

at selected federal agencies; (2) review agencies’ and payroll providers’ 

practices in recording and reporting paid administrative leave, and 

describe the number of federal employees granted such leave, the total 

number of days granted, and the associated salary costs; and (3) 

describe categories of reasons for which large amounts of paid 
 

Page 2 GAO-15-79 Federal Paid Administrative Leave

administrative leave have been charged by individual employees at 

selected federal agencies.

To determine the extent and total amount of paid administrative leave, we 

analyzed payroll data between fiscal years 2011 and 2013 from the Office 

of Personnel Management’s (OPM) Enterprise Human Resources 

Integration (EHRI) system.1 EHRI contains payroll data and other 

information for most federal civilian employees in more than 100 federal 

agencies, including employees of the 24 agencies covered by the Chief 

Financial Officers Act, which represent the major departments (such as 

the Department of Defense) and most of the executive branch workforce.2

We estimated the salary cost of these hours using actual employee 

salaries, where available, and average agency salary when employee 

salaries were unavailable. We tested the reliability of the OPM EHRI 

payroll data and concluded that they were sufficiently reliable for our 

purposes. However, the data have limitations. First, the data represent 

charges to several types of leave and other activities that vary across 

agencies, and data were aggregated into a single category of paid 

administrative leave. Since these aggregated charges do not include the 

same activities across all agencies, the data are not comparable across 

agencies. Second, the reasons for the charges to paid administrative 

leave are not specified in the data, so it is not possible to compare the 

amount of paid administrative leave time charged with the reasons for 

which the time was charged. Finally, due to the differences in the types of 

activities and circumstances for which agencies authorize administrative 

leave, the charges may or may not include time when employees were 

participating in activities directly related to their job responsibilities.

To describe the policies for paid administrative leave and categories of 

reasons why selected employees were granted extended amounts of 

such leave, we selected five federal agencies—the Departments of 

Defense, the Interior, and Veterans Affairs; the General Services 

Administration; and the U.S. Agency for International Development. 

 

1

The EHRI system was being implemented prior to fiscal year 2011 and these data were 

not as complete due to fewer agencies reporting their payroll data to OPM. Therefore, we 

did not use data prior to fiscal year 2011. 

2

EHRI is the primary government-wide source for information on federal employees. The 

EHRI data we analyzed cover executive branch civilian employees, with some exclusions, 

and limited legislative branch employees. See appendix I for further detail. 
 

Page 3 GAO-15-79 Federal Paid Administrative Leave

Agency selections were based upon two factors: (1) the percentage of 

employees at each agency with amounts of paid administrative leave that 

were relatively higher than each agency’s average; and (2) the agency’s 

average amount of administrative leave per employee. For these 

agencies, we reviewed leave policies and time and attendance guidance 

for granting and recording paid administrative leave, respectively, and 

interviewed agency officials at the selected agencies, at the four payroll 

service centers used by the selected agencies, and at OPM. Also, at the 

selected agencies, we collected reasons for which selected employees 

charged large amounts of paid administrative leave. To select employees, 

we first identified those employees charging administrative leave in 

amounts relatively higher than the average amount of charges made at 

each agency.3

We conducted this performance audit from November 2013 to October 

2014 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.

From that subset of employees, we selected a 

nongeneralizable sample which included employees with the highest total 

amounts of paid administrative leave, as well as employees randomly 

selected from the remaining employees with large amounts of 

administrative leave. For a more complete description of our 

methodology, see appendix I.

There is no general statutory authority for the use of paid administrative 

leave, which is an excused absence without loss of pay or charge to 

leave; however, we, as well as OPM and others, have provided direction 

in the permissible use of administrative leave.

OPM regulation. In the absence of statutory authority to promulgate 

regulations addressing administrative leave for all executive agency 

employees, OPM has addressed the use of paid administrative leave in 

 

3

We defined “relatively higher” as paid administrative leave charges in excess of three

standard deviations from the agency mean. 

Background

Regulations Addressing 

Administrative Leave
 

Page 4 GAO-15-79 Federal Paid Administrative Leave

limited contexts in regulations, such as those regarding other types of 

leave, excused absences for federal wage employees, and personnel 

matters. Examples include:

• Brief tardiness. In describing minimum charges for sick and annual 

leave, OPM provides that if an employee is unavoidably or necessarily 

absent for less than one hour, or tardy, the agency, for adequate 

reason, may excuse the employee without charge to leave.4

• Federal wage employees. In implementing the statute which 

authorizes employees paid on daily, hourly, or piece-work basis to be 

paid for days they are prevented or excused from working, OPM 

regulations address excused absences for Federal Wage System 

employees, and certain other employees (e.g. those paid on a daily or 

piece-work basis), stating that granting up to 3 consecutive workdays 

of administrative leave may be appropriate when warranted.5

• Adverse actions. OPM addresses the limited use of administrative 

leave in its regulations on the procedural requirements for removing or 

suspending employees.6

 

4

5 C.F.R. § 630.206.

Specifically, in discussing an employee’s 

entitlement to at least 30 days’ advance written notice of a proposed 

action, OPM provides that while it is presumed that an employee will 

remain in a duty status during the advance notice period, in “rare 

circumstances” where the agency determines the employee’s 

presence in the workplace may pose a threat to the employee or 

others, result in loss of or damage to government property, or 

otherwise jeopardize legitimate government interests, the agency may 

elect from one or a combination of alternatives, including placing an 

5

5 C.F.R. part 610, subpart C. Appropriate circumstances include (1) interruption of 

normal operations beyond the control of management or employees, (2) establishment 

closing for a short period for managerial reasons, (3) it being in the public interest for 

employees to participate in civil activities which the government is interested in 

encouraging, or (4) circumstances are such that an agency would excuse the absence of 

employees paid on an annual basis. These regulations implement 5 U.S.C. § 6104, which 

authorizes employees paid on a daily, hourly, or piece-work basis to be paid for days they 

are prevented or excused from working because of a holiday or other authorized reason.

6

5 U.S.C. §§ 7513(a) and 7514. 5 C.F.R. §§ 752.404(b)(3) and 752.604(b)(2) (for Senior 

Executive Service). These regulations apply to a removal, suspension for more than 14 

days, reduction in grade or pay, and a furlough of 30 days or less. 
 

Page 5 GAO-15-79 Federal Paid Administrative Leave

employee on administrative leave for such time as necessary to effect 

the action.7

OPM guidance. While it has not addressed administrative leave in broad 

contexts through regulations, OPM has provided additional guidance to 

agencies on the use of administrative leave via government-wide 

memorandums, handbooks, fact sheets, and frequently asked questions. 

In this guidance to agencies regarding exercising their discretion to use 

administrative leave, OPM provides that the use of administrative leave 

should be limited to those circumstances in which the employee’s 

absence is not specifically prohibited by law and satisfies one or more of 

the following criteria: (1) it is directly related to the agency’s mission, (2) it 

is officially sponsored or sanctioned by the head of the agency, (3) it will 

clearly enhance professional development or skills of the employee in his 

or her current position, or (4) it is brief and determined to be in the interest 

of the agency.8

OPM guidance has acknowledged numerous purposes for which 

administrative leave is appropriate—as recognized by executive order or 

policy, or our decisions. Typically, these purposes are work related or 

civic in nature and include voting9 and registering to vote, civil defense 

activities, blood donations, taking examinations required by the 

employee’s position, and attending conferences or conventions.10

 

7

Other options include assigning the employee to duties where the employee is no longer 

a threat, allowing the employee to take leave (or carrying the employee in an appropriate 

leave status if employee has absented him or herself from the workplace without 

requesting leave), or curtailing the notice period as authorized under 5 U.S.C. § 7513(b) 

when the agency has reasonable cause to believe that the employee has committed a 

crime for which imprisonment may be proposed.

OPM 

has also sanctioned granting excused absence to employees who are 

prevented from reporting to work (or are faced with a personal 

8

See for example, OPM, Fact Sheet: Guidance on Scheduling Work and Granting Time 

Off to Permit Federal Employees to Participate in Volunteer Activities, and Frequently 

Asked Questions Work Life: Can an agency grant time off for fitness activities?

9

See OPM, memorandum Excused Absence for Voting, October 31, 2008.

10OPM’s guidance used to be found in its Federal Personnel Manual (FPM) until FPM was 

abolished in 1993. See Federal Personnel Manual, Chapter 630, Subchapter 11, Excused 

Absence, Sept. 23, 1991. Earlier versions of FPM included representing employee 

organizations as an appropriate purpose for using administrative leave until Congress 

created “official time” under the Civil Service Reform Act of 1978. See, 5 U.S.C. § 7131.

Guidance and Legal 

Decisions
 

Page 6 GAO-15-79 Federal Paid Administrative Leave

emergency) because of severe weather or other emergency situations. 

More recently, OPM has strongly encouraged agencies to permit 

telework-ready employees to telework in such situations, thereby 

maintaining the continuing operations of the federal government.

11

OPM also issued guidance on granting administrative leave in response 

to presidential direction. For example, in response to a 2003 presidential 

directive to provide 5 workdays of excused absences to employees 

returning from active military duty in support of the Overseas Contingency 

Operations, OPM issued guidance to agencies on how to properly 

implement this directive.12

OPM has also incorporated the use of administrative leave into guidance 

on various topics, including workplace violence. In discussing short-term 

administrative options available in removing a potentially dangerous 

employee from the workplace, OPM advises that while conducting further 

investigation and deciding on a course of action, placing an employee on 

excused absence is an immediate, temporary solution to the problem of 

an employee who should be kept away from the worksite.13

OPM is also responsible for settling federal employee leave and 

compensation claims and issuing decisions to agency officials on such 

matters. We had performed this function until it was transferred to OPM in 

1996.14

Our decisions. We have issued numerous decisions on the permissible 

use of administrative leave. Our decisions recognize that in the absence 

of a generally applicable statutory or regulatory framework authorizing 

 

11OPM, Washington, D.C. Area Dismissal and Closure Procedures, December 2013.

12The Overseas Contingency Operations is formerly known as the Global War on 

Terrorism. See OPM, Fact Sheet: 5 Days of Excused Absence for Employees Returning 

from Active Military Duty.

13OPM also suggests detailing the employee to another position if there is another 

position where the employee can work safely and without disturbing other workers.

14Our claims settlement function under 31 U.S.C. § 3702 for federal employee 

compensation and leave claims was transferred to OPM pursuant to section 211 of the 

Legislative Branch Appropriations Act of 1996, effective June 30, 1996. See Pub. L. No. 

104-53. The related authority under 31 U.S.C. § 3529 to render advance decisions to 

agency officials settling these claims was transferred to the head of OPM by the General 

Accounting Office Act of 1996, Pub. L. No. 104-316, effective October 19, 1996. 
 

Page 7 GAO-15-79 Federal Paid Administrative Leave

administrative leave, agencies have the discretion to grant brief periods of 

administrative leave.15 However, our decisions have found granting 

administrative leave for lengthy periods of time is inappropriate unless it is 

in connection with furthering a function of the agency.16

Under a range of situations, our decisions have addressed the 

appropriate usage of administrative leave. In the context of official travel, 

we have recognized several circumstances in which administrative leave 

may be granted, including brief periods of acclimatization rest following 

travel,17 in connection with a transfer,18 and in connection with extended 

temporary duty to attend training.19

A number of our decisions have addressed the use of administrative 

leave during the investigation of an employee or in the context of taking 

an adverse action against an employee. For example, to process an 

employee’s suspension (where it was in the interest of the government to 

have the employee off the job), we approved of placing the employee on 

administrative leave during an investigation for wrongdoing for the short 

time needed (24 hours or so).20

 

1544 Comp. Gen. 333 (1964). 

However, under circumstances when it 

16See 67 Comp. Gen. 126 (1987) which found that granting administrative leave to an

employee for 3 days a month to participate in therapeutic cancer research trial is 

permissible; 63 Comp. Gen. 542 (1984) where, in promulgating agency policy on 

permitting employee support to the federal credit union, we suggest establishing 

appropriate time limits on granting administrative leave for such efforts, such as, not to 

exceed 4 hours in any one day; not to exceed 3 workdays; or not to exceed 40 working 

hours in a calendar year; and 61 Comp. Gen. 652 (1982) deciding that an employee 

involuntarily assigned to represent an indigent defendant may not be placed on 

administrative leave to carry out such responsibility given the indeterminate period in 

question, and that such effort would not be in furtherance of agency function. 

1756 Comp. Gen. 629 (1977) and 55 Comp. Gen. 510 (1975). 

18Administrative leave for one week to manage move of residence was permissible, even 

though transfer was ultimately cancelled. B-180693, May 23, 1974. Administrative leave 

for 40 hours for a house-hunting trip prior to transfer (in lieu of reduction-in-force) was 

permissible even though the reduction-in-force was cancelled and the employee chose to 

remain in his position. B-246646, Apr. 30, 1992. 

19One day of administrative leave may be granted to employees so they may find suitable 

housing while attending training. B-192258, Sept. 25, 1978.

2038 Comp. Gen. 203 (1958). At the time this decision was issued, suspensions for 30 

days or less did not require 30 days advance notice as is the case now for suspensions of 

more than 14 days or indefinite suspensions.
 

Page 8 GAO-15-79 Federal Paid Administrative Leave

would not be feasible to reassign the employee (or when information to 

initiate an adverse action against the employee was insufficient), we

concluded that an agency’s proposed regulations were unauthorized 

where those regulations provided up to 45 days of administrative leave 

while investigating allegations of employee misconduct.21

Administrative tribunal decisions. The Merit Systems Protection Board 

(MSPB) has recognized the authority of agencies to place employees on 

short-term administrative leave while instituting adverse action 

procedures.22 However, the Board has found settlement agreements 

unenforceable where, under its terms, the agency was to place the 

employee on administrative leave for extended periods of time.23

MSPB has also ruled that placing an employee on administrative leave is 

not subject to procedural due process requirements and is not an 

appealable agency action.24 This is in contrast to agency actions, such as 

removals or indefinite suspensions, which require procedural due process 

(such as 30 days advance notice), and are subject to appeal and reversal 

by MSPB where agencies fail to follow such due process procedures.25

 

21B-189773, Nov. 3, 1977.

Similarly, where an agency bars an employee from duty for more than 14 

days, requiring that employee to use his or her own leave (or placing 

22See, Brown v. United States Postal Service, 64 M.S.P.R. 425, 431 (1994). 

23McDavid v. Department of the Army, 46 M.S.P.R. 108 (1990) (employee to be placed on 

administrative leave for a 3-month period) and Miller v. Department of Defense, 45 

M.S.P.R. 263 (1990) (Board concurred with our advice (provided under B-236124, Jan. 2, 

1990) and concluded the settlement agreement was unlawful as it awarded employee 1 

year of administrative leave). 

24Dixon v. United States Postal Service, 69 M.S.P.R. 171 (1995) (placement on 

administrative leave with pay is not an appealable agency action), citing Henry v. 

Department of the Navy, 902 F.2d 949 (Fed. Cir. 1990) (since employee was provided full 

pay while placed on administrative leave during the notice period of her proposed 

removal, there was no adverse action from which the employee could appeal to contest 

her placement on administrative leave).

25See 5 U.S.C. §§ 7513 and 7702(c)(2). 
 

Page 9 GAO-15-79 Federal Paid Administrative Leave

them in a non-pay status), such agency actions are also subject to 

appeal.26

The Federal Labor Relations Authority (FLRA) has also addressed the 

use of administrative leave in some of its decisions. In a recent case, 

FLRA reaffirmed its controlling precedent that agency discretion to grant 

administrative leave is limited to granting brief, occasional, or sporadic 

periods of administrative leave.27

Payroll data. In 2004, OPM began to integrate federal civilian employee 

payroll and personnel data into a single data warehouse—the Enterprise 

Human Resources Integration (EHRI) system—as one of several efforts 

supporting OPM’s Human Resources Line of Business (HR LOB) 

initiative. HR LOB intended to help transform the way human capital 

functions and services are carried out in the federal government. The goal 

of HR LOB was to integrate and streamline human resources systems to 

improve government-wide human capital management by better informing 

policy making and more effectively managing the federal workforce. To 

collect the payroll data, payroll service providers for federal agencies 

report payroll data biweekly to EHRI. According to OPM officials, most 

payroll providers were reporting payroll data to EHRI by 2009.

Time keeping. Federal employees generally use electronic time and 

attendance systems to record their work and leave time. These systems 

allow employees to record time spent on different work and leave 

activities, including paid administrative leave. However, the level of detail 

regarding the exact nature of the work or leave time varies depending on 

the agencies’ systems for recording employee work time.

 

2669 M.S.P.R. at 175 (if employee was forced to use sick leave, annual leave, or leave 

without pay for a period exceeding 14 days, employee was subjected to a constructive 

suspension appealable to MSPB). See also, U.S. Merit Systems Protection Board, 

Information Sheet No. 11, Enforced Leave (Sept. 18, 2008).

27See United States Department of the Air Force and Sport Air Traffic Controllers 

Organization, 65 F.L.R.A. 387 (2010) (granting 59 minutes of administrative leave at the 

end of an employee’s shift where no air traffic operations were required was a permissible 

exercise of agency discretion and supervisory authority could not be unilaterally 

eliminated).

OPM Collects Payroll Data 

on Administrative Leave
 

Page 10 GAO-15-79 Federal Paid Administrative Leave

Payroll service. Federal agencies primarily use four payroll service 

providers to process employee pay and track work and leave hours.28

These payroll providers process employees’ time and attendance 

information and then report payroll data to OPM’s EHRI system. These 

data are then used to populate OPM’s EHRI data warehouse containing 

federal personnel and payroll information. EHRI has a single category for 

all paid administrative leave hours and the payroll service providers may 

aggregate various leave categories when preparing data on paid 

administrative leave to be transmitted to EHRI.

Policy similarities. Among the agencies reviewed, we found activities or 

circumstances which were consistently categorized as eligible for the 

granting of paid administrative leave in each of the agencies’ leave 

policies and guidance. These included donating blood, dismissals due to 

hazardous weather or emergency conditions, physical examinations to 

determine fitness for duty, and voting and registration, among others (see 

table 1 below). In addition to civic activities and weather-related delays or 

closures, all agencies we reviewed also included at least one activity 

directly related to employees’ job responsibilities as reasons for granting 

paid administrative leave. Examples of these activities included attending 

trainings, conferences, conventions, or meetings, and performing tasks 

necessary for change of duty station.

 

28These four payroll service providers are the National Finance Center, General Services 

Administration, Interior Business Center, and Defense Finance and Accounting Services.

Selected Agencies 

Consistently 

Categorize Some 

Activities as 

Acceptable Reasons 

for Granting Paid 

Administrative Leave; 

However, Variations 

Exist

Selected Agency Policies 

and Guidance Commonly 

Categorize Some Activities 

for Granting Paid 

Administrative Leave
 

Page 11 GAO-15-79 Federal Paid Administrative Leave

Table 1: Activities Commonly Categorized as Reasons for Granting Paid Administrative Leave by Number of Selected 

Agencies That Cited the Reasons

Cited in all 5 agencies’ policies and guidance on paid administrative leave

Unavoidable or necessary absence and tardiness for less than 1 hour

Dismissals due to hazardous conditions (weather, civil disturbance, natural disasters)

Blood donation

Voting activities (registration and voting)

Required physical examinations such as those to determine fitness for active military duty 

Veteran participation in funeral ceremonies for members of the U.S. Armed Forces (honor guard, pallbearer)

Cited in 4 of 5 agencies’ policies and guidance on paid administrative leave

Examinations and interviews (civil service, internal promotions)

Personnel matters including investigations for alleged misconduct, security threats, criminal conduct, or adverse actions, 

among others

Change of duty station activities (packing, finding housing, travel)

Civil defense and disaster response activities (state guards, community programs)

Cited in 3 of 5 agencies’ policies and guidance on paid administrative leave

Trainings, conferences, conventions, or meetings

Employee organization (union) activities such as negotiations, grievance and appeals, ongoing labor and management 

committees, or training for union representativesa

Receiving counseling from agency officials or employee assistance program counselors

Rest periods during or following work-related travel 

Parades and ceremonies (incentive award ceremonies, welcoming ceremonies for foreign dignitaries at the White House)

Agency-sponsored volunteer activities

Injury sustained while on duty - initial exam or treatment or for remainder of the day injury occurred

Local holidays (Mardi Gras, holidays observed exclusively overseas)

Bone marrow or organ donation

Returning from active military duty 

Funeral leave (immediate relatives killed in line of duty, to attend funerals of fellow law enforcement or firefighters) 

Source: GAO analysis of agency paid administrative leave policy and guidance. | GAO-15-79

Note: Reasons listed in table above were included in at least three of the five selected agencies’ 

policies on granting paid administrative leave. Like reasons across agency policies were grouped 

together under some of the reasons listed above; examples provided may not be applicable to all 

agencies that grant paid administrative leave for the broader reason listed. For the Department of 
 

Page 12 GAO-15-79 Federal Paid Administrative Leave

Defense (DOD), agency officials provided us with subcomponent policies for review based on 

differences between the subcomponent policies and agency-wide policy. We reviewed policies on 

paid administrative leave for the following DOD subcomponents - Air Force, Defense Contract 

Management Agency, and Washington Headquarters Services-Serviced Components.

a

One of the three agencies that grant paid administrative leave for union activities do so only for 

limited activities, such as training for union representatives.

Agency discretion. Agencies have the discretion to grant paid 

administrative leave for brief periods of time and have exercised this 

discretion through setting policies governing the use of this type of leave.

In some instances, agencies set policies to grant paid administrative 

leave to employees for reasons related to agencies’ missions, or that are 

in the best interest of the agency. For example, U.S. Agency for 

International Development (USAID) and Department of Defense (DOD) 

officials said that they grant paid administrative leave to employees 

serving 6 months or more in Afghanistan for rest and recuperation breaks, 

while other selected agencies did not. In addition, some agencies may 

allow paid administrative leave to be granted for physical fitness activities, 

as an agency employee-wellness initiative or for mission-related reasons. 

For example, the Air Force allows installation commanders (or heads of 

serviced organizations) to excuse civilian employees for physical fitness 

activities—and to charge up to 3 hours of paid administrative leave per 

week—based on mission and workload requirements. Similarly, the 

Department of the Interior (Interior) allows employees to be granted paid 

administrative leave for health and fitness activities, but only under limited 

circumstances and not for regularly recurring periods (such as a set 

amount of time each week).

Categorization differences. While the five selected agencies 

consistently categorize some activities under their paid administrative 

leave policies (as described in table 1), we found that some agencies’ 

policies categorize a specific activity as paid administrative leave while 

others do not. For example, four of the five agencies we reviewed 

categorize time to serve as a juror or witness (commonly referred to as 

court leave)29

 

295 U.S.C. § 6322. 

as separate from paid administrative leave; however, 

Interior policy classifies court leave as a reason for which employees can 

charge paid administrative leave (see figure 1). In another variation, we 

found that an agency subcomponent’s policy categorized activities or 

circumstances as paid administrative leave while agency-wide policy 

categorized the activities or circumstances differently. For example, 

Agencies Can Set Policies 

for Paid Administrative 

Leave; Therefore, Policy 

Differences Exist between 

Agencies
 

Page 13 GAO-15-79 Federal Paid Administrative Leave

according to Air Force policy, legal holidays are categorized as paid 

administrative leave. However, in DOD-wide policy, as well as other DOD 

subcomponents reviewed, legal holidays are not categorized under paid 

administrative leave.

Figure 1: Example of How Selected Agencies Categorize Activities Differently in 

Leave Policies

Congressional authorization. Both court leave and legal holidays are 

examples of circumstances in which Congress has authorized excused 

absences for federal employees. Other instances of congressionally 

authorized excused absences include attending military, law enforcement, 

and firefighter funerals,30 serving as a bone-marrow or organ donor,31

 

305 U.S.C. § 6326 authorizes 3 days of excused absence in connection with the funeral of 

an immediate relative who died while serving in the Armed Forces. 5 U.S.C. § 6328 

authorizes excused absence for a federal law enforcement officer or a federal firefighter to 

attend the funeral of a fellow federal law enforcement officer or Federal firefighter, who 

was killed in the line of duty. Congress has also authorized an excused absence for 

veterans participation in funeral ceremonies for members of the U.S. Armed Forces under 

5 U.S.C. § 6321. 

and 

315 U.S.C. § 6327 provides up to 7 days of leave for bone-marrow donors and 30 days for 

organ donors.
 

Page 14 GAO-15-79 Federal Paid Administrative Leave

recovery for employees injured by hostile action while serving abroad.32

Similarly, Congress has authorized official time to be used when 

engaging in union activities, such as negotiating collective bargaining 

agreements.33 According to OPM officials, these congressionally 

authorized circumstances are not paid administrative leave, but rather 

separate types of leave or authorized absences. OPM officials said that 

they considered paid administrative leave to be an administratively 

authorized absence from duty. However, agencies we reviewed included 

congressionally authorized circumstances in their paid administrative 

leave policies.34 We discuss below our assessment of OPM’s payroll 

guidance and the extent to which it distinguishes between administrative 

leave and congressionally authorized excused absences.

 

32An employee may be absent due to an injury for up to 1 year. 5 U.S.C. § 6325.

335 U.S.C. § 7131. Activities that relate to internal union business may not be charged to 

official time, but rather they must be performed when in a nonduty status.

34Some congressionally authorized excused absences were included in administrative 

leave policies for only one or two agencies that we reviewed, such as for employees 

injured by hostile action while serving abroad and court leave.

Differences in Agency 

Leave Recording 

Practices and in 

Payroll Providers’ 

Interpretation of 

Guidance Contributed 

to Large Variations in 

Reporting of Paid 

Administrative Leave
 

Page 15 GAO-15-79 Federal Paid Administrative Leave

Because agencies’ policies on paid administrative leave differ, OPM data 

on administrative leave is expected to vary across agencies, even when 

controlling for agency size. However, we found large variations in OPM 

data on paid administrative leave as a result of (1) agency recording 

practices, and (2) differences in how payroll providers report time to 

EHRI. Agency practices for recording paid administrative leave included 

time for activities that OPM did not consider to be paid administrative 

leave. Similarly, when payroll providers reported data to EHRI, time for 

activities that OPM did not consider to be paid administrative leave were 

included. Furthermore, in one case, a payroll provider did not report any 

time for activities that OPM officials would expect to be reported as paid 

administrative leave, even though time for these activities was collected 

through the time and attendance system. OPM has not provided guidance 

to agencies on how to record time for paid administrative leave activities, 

and while OPM has provided guidance to payroll providers for reporting 

paid administrative leave hours, this guidance is limited.

Agency recording practices. Agency practices for recording activities as 

paid administrative leave in time and attendance systems vary from what 

OPM officials told us that they expected. In some instances, we found 

that time entered by employees as paid administrative leave may not all 

be considered as paid administrative leave by OPM officials. For 

example, as noted above, employees are to use official time when 

engaging in certain union and labor relations activities (e.g., negotiating 

collective bargaining agreements); however, some agencies record union 

and labor relations activities as paid administrative leave. At the 

Department of Veterans Affairs (VA) for instance, we found that official 

time for engaging in union activities were recorded as paid administrative 

leave because the agency’s time and attendance system does not have a 

job code to capture official time separately.35

 

35See 

In another example, a 

subcomponent of Interior instructs a certain group of employees—those

not paid for specified vacation days but who are paid during this time as 

part of a prorated payment schedule—to record this time as paid 

administrative leave in the time and attendance system. Interior officials 

told us that the subcomponent did not have a separate code for recording 

this vacation time. Thus, the agency established the practice of recording

it as paid administrative leave. OPM has not issued guidance on which 

GAO-15-9 (forthcoming) for more information on VA’s and other agencies’ use of 

official time activities.

A Lack of Detailed 

Guidance Related to 

Recording and Reporting 

Paid Administrative Leave 

Activities Makes Data 

Comparison Challenging
 

Page 16 GAO-15-79 Federal Paid Administrative Leave

activities employees should or should not record as paid administrative 

leave in agencies’ time and attendance systems, which affects the 

accuracy and consistency of the data that OPM collects. Internal control 

standards state that agency management must have relevant, reliable 

information to effectively manage their organization and provide 

accountability for their operations.36 In addition, internal control standards 

state that detailed policies, procedures, and practices are to be developed 

to ensure consistent implementation by responsible parties to achieve 

established objectives.37 Without adequate guidance on what should or 

should not be recorded as paid administrative leave, federal employees 

and agencies cannot provide OPM with relevant and reliable information, 

which could be used to manage the federal workforce and inform human 

capital management policy.38

Additionally, as mentioned previously, OPM officials told us that they do 

not consider any legislatively authorized activities, such as bone marrow

or organ donation, funeral leave, or absence due to injuries sustained 

from hostile actions abroad to be paid administrative leave. However, we 

found that agencies do instruct employees to record these activities as 

paid administrative leave in their time and attendance systems. For 

example, DOD does not have a separate code for employees to record 

time spent for bone marrow or organ donation, but for several agency 

components, including the U.S. Army, Navy, and Air Force, it is included 

as one reason among many for charging paid administrative leave. 

Additionally, Interior instructs its employees to record court time as paid 

administrative leave, which does not align with what OPM officials 

consider to be paid administrative leave. By providing more detailed 

guidance, OPM could assist federal agencies in determining which 

activities should or should not be recorded as paid administrative leave, 

making this government-wide time and attendance data more consistent 

for monitoring the activities of the federal workforce.

Payroll provider reporting. OPM has provided a data codebook to 

payroll service providers to serve as guidance on reporting payroll data to 

 

36GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

37GAO/AIMD-00-21.3.1. 

38Office of Personnel Management, Human Resources Line of Business: Integration 

Support Project, (Washington, D.C., Feb. 20, 2009).
 

Page 17 GAO-15-79 Federal Paid Administrative Leave

EHRI. This codebook includes instructions and technical specifications on 

the data elements that payroll providers should populate every 2 weeks. 

For example, the instructions include specifications for how each 

employee’s data should be formatted in the file along with a listing of all 

data elements to report for each employee such as total salary, annual 

leave hours used, and amounts deducted for health benefits. However, 

this guidance is limited and we found that payroll service providers 

interpret it in different ways. For example, the OPM guidance document 

for reporting payroll data to EHRI does not provide any instructions for 

reporting federal holiday leave hours, and we found that payroll service 

providers report these hours either differently or not at all. One of the four 

primary payroll providers for the federal government—the National 

Finance Center (NFC)—includes federal holidays among the hours 

reported to OPM as paid administrative leave; the other three primary 

providers either report federal holidays as regular duty hours or do not 

report them at all.39 NFC officials said that these charges are reported to 

EHRI as paid administrative leave for lack of another option because, 

according to OPM’s guidance, there is no separate data element for 

federal holidays and regular duty hours should not include any paid leave. 

However, OPM officials told us that they do not consider federal holidays 

to be paid administrative leave. In addition, among the four primary 

payroll providers, three report other legislatively authorized leave 

activities such as court leave, official time, military leave, and bone 

marrow and organ donation as paid administrative leave.40

 

39The four primary payroll service providers are the National Finance Center, General 

Services Administration, Interior Business Center, and Defense Finance and Accounting 

Services. EHRI does not include a separate data element for federal holidays.

These 

reporting differences result in inaccurate data on the total amount of paid 

administrative leave, and since OPM guidance does not define paid 

administrative leave by specifying what should and should not be 

reported in this category, these payroll providers include time for activities 

that OPM does not consider to be paid administrative leave. As illustrated 

below, while employees at USAID (which uses NFC) record federal 

holidays separate from paid administrative leave, when NFC reports 

USAID payroll data to OPM, federal holidays are included in the agency’s 

paid administrative leave totals. In contrast, for the General Services 

Administration (GSA), which uses its own services as one of the four 

40EHRI includes separate data elements for military leave, leave for organ donation, court 

leave, and leave for bone marrow donation, among others. 
 

Page 18 GAO-15-79 Federal Paid Administrative Leave

primary payroll providers, federal holidays are reported as regular duty 

time, not as paid administrative leave (see figure 2 for an illustration of 

how these hours are reported to EHRI).

Figure 2: An Example of Variations in Time and Attendance Reporting between Two Agencies and Two Payroll Service 

Providers

In another example, the Department of State (State) (which acts as its 

own payroll provider for submitting payroll data to OPM for all its 

employees) does not report any hours to OPM as paid administrative 

leave, even though the agency has a policy for granting paid 

administrative leave under several circumstances and records time for 
 

Page 19 GAO-15-79 Federal Paid Administrative Leave

several activities in its time and attendance system as administrative 

leave.41

OPM officials explained that no quality review of the data has occurred 

and that they were not aware of the data discrepancies created by either 

NFC reporting federal holidays as paid administrative leave or by State 

not reporting any time as paid administrative leave. Consequently, the 

agency has not addressed these discrepancies to date. However, OPM 

officials told us that they intended to organize a working group in fiscal 

year 2015 to conduct an initial review of the quality of the EHRI payroll 

data. Similar to our 1998 assessment of the reliability of OPM’s personnel 

data—which facilitated the data’s use in numerous subsequent 

engagements—we have initiated work to review the reliability of OPM’s 

EHRI payroll data.

State officials explained that paid administrative leave is recorded 

as such in the time and attendance system, but recorded as regular duty 

time within the agency’s payroll system. Officials stated that this is due to 

a system limitation that will be corrected with the implementation of a new 

payroll application in late 2015. As a result, all paid administrative leave is 

reported to OPM as regular duty time.

42

As described above, EHRI payroll and personnel data are collected to 

assist OPM and agencies in managing the federal workforce and 

resources more effectively. However, because OPM has not provided 

detailed guidance to ensure the consistency and accuracy of data 

reported to EHRI as stated in federal internal control standards,

The payroll data assessment is expected to be 

completed in fiscal year 2016, and will include following up on the status 

of OPM’s working group.

43

 

41Among the payroll service providers that submit data to OPM for the 24 Chief Financial 

Officers (CFO) Act agencies, the Department of State is the only one that does not report 

any data under the paid administrative leave data element to the EHRI system. 

OPM 

and agency leadership may be unable to use these data to effectively 

manage their workforces and resources.

42EHRI personnel data (formerly Central Personnel Data File (CPDF)) records 

demographic information, job information, the agency of employment and location of 

employees, and other aspects of the on-board Federal workforce. We previously reported 

that government-wide data from CPDF were 96 percent or more accurate. See GAO, 

OPM’s Central Personnel Data File: Data Appear Sufficiently Reliable to Meet Most 

Customer Needs, GAO/GGD-98-199 (Washington, D.C.: Sept. 30, 1998).

43GAO/AIMD-00-21.3.1. 
 

Page 20 GAO-15-79 Federal Paid Administrative Leave

Categorical differences—the reasons for which agencies grant paid 

administrative leave—and reporting differences—such as including official 

time activities or federal holidays—contribute to variations in the total 

amount of paid administrative leave reported to OPM. The reasons for the 

paid administrative leave charges are not reported to OPM and the data 

may include time charged for other reasons that—like federal holidays—

OPM considers as separate and distinct from paid administrative leave.

This includes official time, court leave, leave for injury due to hostile 

action abroad, bone marrow and organ donation, and funeral leave. We 

estimated the extent to which federal holidays impact the total amount of 

paid administrative leave reported and excluded this amount as it is not 

paid administrative leave. However, other reasons—such as weatherrelated events—are relevant to specific employees or geographic areas, 

and unlike federal holidays, cannot be estimated because the hours are 

not charged consistently across all employees and all agencies.44

Federal holidays. When including federal holidays among the charges, 

the total amount of paid administrative leave more than doubles 

government-wide (see figure 3). Over the 3 years we reviewed, federal 

employees charged a total of about 24.6 million days of paid 

administrative leave, or about 12 days per employee, which includes time 

for federal holidays for those agencies using NFC as a payroll service 

provider (see appendix II, table 3).45 Of the total of about 24.6 million days 

of paid administrative leave, an estimated 60 percent were federal 

holidays.46

 

44Weather closures affect federal employees only in the area in which the event occurs. 

Weather-related closures in the Washington, D.C. area would affect a significant number 

of federal employees, but not all because some employees are required to work under 

such circumstances.

Separating federal holidays from the data, the total amount of 

paid administrative leave falls to more than 9.9 million days across the 3 

years reviewed (less than 1 percent of total employee paid days), or 

about 5 days per employee.

45Thirty-four agencies (including 9 CFO Act agencies) in addition to subcomponents of 6 

other agencies use NFC as a payroll service provider and for which NFC reports payroll 

data to EHRI. 

46We estimated the total hours of federal holidays taken by all federal employees in 

agencies that use NFC as their payroll service provider, and for which NFC reports payroll 

data to EHRI, and separated those hours from the totals. 

The Total Amount and 

Estimated Salary Cost of 

Paid Administrative Leave 

is Difficult to Estimate
 

Page 21 GAO-15-79 Federal Paid Administrative Leave

Figure 3: Paid Administrative Leave Government-wide – Estimated Totals and 

Federal Holidays for Fiscal Years 2011-2013

Holiday impact. For those nine CFO Act agencies where federal 

holidays are included among the paid administrative leave time charges,47

 

47These agencies use NFC as their payroll service provider, which includes federal 

holidays among paid administrative leave hours when reporting it to OPM’s EHRI system.

the average number of days of paid administrative leave per employee 

were among the highest government-wide (see appendix II, table 3). For 

example, between fiscal years 2011 and 2013, for these nine agencies, 

the average number of days of paid administrative leave per employee 

ranged from 29 to 49 days. After separating federal holidays, these 

agency averages decreased to between 6 and 20 days (see figure 4). 

Nevertheless, these agencies continue to have an average number of 

days of paid administrative leave per employee that is above the 

government-wide average. USAID continued to have the highest average 

number of days charged per employee among the 24 CFO Act agencies 

after separating federal holidays, dropping from nearly 49 days to 20 

days.
 

Page 22 GAO-15-79 Federal Paid Administrative Leave

Figure 4: Impact of Federal Holidays upon Paid Administrative Leave for Some Agencies Using National Finance Center as 

Payroll Provider – Average Days per Employee for Fiscal Years 2011-2013

Note: Average days are based on the sum of paid administrative leave charges and the on-board 

average number of employees in pay periods containing sufficient data (not missing) across the 3-

year period. Most agency averages were based on data from 77 of the 79 pay periods for the 3-year 

period because two pay periods were missing for most agencies. These missing pay periods differed 

for each agency and generally occurred around the change of fiscal year.
 

Page 23 GAO-15-79 Federal Paid Administrative Leave

Patterns in Paid Administrative Leave Charges

Estimated charges. Between fiscal years 2011 and 2013, most federal 

employees charged from less than 1 day to 20 days of paid administrative 

leave (see figure 5).48

• Nearly 70 percent of federal employees charged 5 days or less of 

paid administrative leave; 

Specifically, over the 3-year period we reviewed: 

• About 90 percent of federal employees charged 10 days or less of 

paid administrative leave; and 

• About 97 percent of federal employees charged 20 days or less of 

paid administrative leave. 

More than 57,000, or 3 percent of federal employees, charged between 1 

month and 3 years of paid administrative leave. Of these, 194 employees 

charged between 1 year and 1.5 years and 69 employees charged 

between 1.5 and 3 years of paid administrative leave.

 

48Unless otherwise noted, all estimates for paid administrative leave time and salary costs 

exclude federal holidays. 
 

Page 24 GAO-15-79 Federal Paid Administrative Leave

Figure 5: Percentage of Paid Administrative Leave Days to Total Paid Days Government-wide – by Percentage of Federal 

Employees for Fiscal Years 2011-2013

Note: Federal holidays are not included in totals. Timeframes reflect workdays, not calendar days, 

with 5 days per week, about 21 days per month, and 260 days per year. For example, 11 to 20 days 

is equivalent to about 2 to 4 weeks, and 1 to 3 months is equivalent to about 21-60 days. Amounts of 

paid administrative leave represent total charges per employee across three fiscal years and are not 

necessarily charged consecutively across days.

Closures/dismissals. Large numbers of federal employees can be 

granted paid administrative leave for short periods of time such as during 

weather-related closures and other hazardous conditions. For example, 

during the 3 years we reviewed, there were approximately 4.9 days of 

OPM closures, delays, and early dismissals in the Washington, D.C., area 

for hazardous conditions, including snow, a hurricane, and an 

earthquake. In addition, according to OPM officials, some federal 

agencies might dismiss employees early on the day prior to a federal 

holiday. These closures and dismissals result in fluctuations in the 

amount of paid administrative leave charges over the course of the 

calendar year (see figure 6).
 

Page 25 GAO-15-79 Federal Paid Administrative Leave

Figure 6: Reported Paid Administrative Leave Government-wide for Fiscal Years 2011-2013

Note: Where noted, total days increased in association with OPM closures, early dismissals, or late 

arrivals for either the Washington, D.C., area or for all federal employees.

Transition and rest. Some agencies, such as USAID and DOD, grant 

paid administrative leave to employees transferring to a new duty location 

to provide time for transition activities, including packing and unpacking, 

reconnecting with family, and attending to other personal matters related 

to the relocation, such as opening bank accounts or obtaining new state 

or local identification. In addition, USAID provides up to 20 days of paid 

administrative leave for rest and recuperation for those stationed in 

Afghanistan. DOD provides up to 20 days of paid administrative leave for 

rest and recuperation per year for employees stationed in Afghanistan or 

Iraq.

Salary Estimates for Paid Administrative Leave

Estimated salary. Total salary estimates for paid administrative leave 

charged from fiscal years 2011 through 2013 totaled nearly $3.1 billion, or 
 

Page 26 GAO-15-79 Federal Paid Administrative Leave

less than 1 percent of total estimated salary for the federal workforce (see 

figure 7).49

While 3 percent of federal employees charged between 1 month and 3 

years of paid administrative leave across three fiscal years, that same 

amount of paid administrative leave accounted for 23 percent of the 

estimated salary cost of paid administrative leave. As discussed 

previously, across the federal government, 263 employees had between 

1 and 3 years of administrative leave between fiscal years 2011 and 

2013. The estimated salary cost for this leave is $31 million, or 1 percent 

of the total salary cost for all paid administrative leave during this period 

(see figure 7).

Over the 3-year time period, the salary cost per employee 

ranged from $1,000 for OPM and the Department of Health and Human 

Services to $7,300 for USAID (see appendix II, table 4). Most of the CFO 

Act agencies used 1 percent or less of their total estimated agency salary 

cost for paid administrative leave. Of the $3.1 billion in estimated salary 

costs, 77 percent of salary cost estimates are associated with federal 

employees who charged 20 days or less of paid administrative leave.

 

49Unless otherwise noted, all salary estimates exclude federal holidays.
 

Page 27 GAO-15-79 Federal Paid Administrative Leave

Figure 7: Percentage of Estimated Paid Administrative Leave Salary to Total Salary Government-wide- by Percentage of 

Estimated Salary for Fiscal Years 2011-2013

Note: Federal holidays are not included in total amount or estimated salary cost of paid administrative 

leave. Timeframes reflect workdays, not calendar days, with 5 days per week, about 21 days per

month, and 260 days per year. For example, 11 to 20 days is equivalent to about 2 to 4 weeks, and 1 

to 3 months is equivalent to about 21-60 days. Leave amounts charged and associated salary cost 

estimates represent totals per employee across 3 fiscal years and leave is not necessarily charged 

consecutively across days.
 

Page 28 GAO-15-79 Federal Paid Administrative Leave

Employees with high charges. At the 24 CFO Act agencies we 

identified more than 26,000 employees charging paid administrative leave 

in amounts relatively higher than the average charges at each agency 

(see appendix III, tables 5 and 6 for summary data on employees with

higher-than-average amounts of paid administrative leave at each of the 

24 CFO Act agencies).50

Summary of reasons. Of the 312 employees selected for further review 

at the five agencies, we found, through analysis of agency responses, 

that the most common reasons for charging higher-than-average amounts 

of paid administrative leave included personnel matters (such as 

investigations into alleged misconduct or criminal actions), physical 

fitness-related activities, and periods of rest and recuperation for 

employees working in overseas locations. Agencies were asked to 

provide reasons for the two largest total amounts of paid administrative 

leave charges per employee. For nearly 70 percent of the employees 

selected, agencies provided one reason for the paid administrative leave, 

but for 79 employees (25 percent) agencies provided two reasons for the 

largest amounts of paid administrative leave. For 5 percent of employees 

selected, agencies were unable to provide any reason for the amount of 

paid administrative leave. Of the reasons provided for paid administrative 

leave charges, 34 percent were for personnel matters, 16 percent were 

for physical fitness-related activities, and 15 percent were for travel to and 

On average, these employees across the 24 

CFO Act agencies charged approximately 51 days of paid administrative 

leave between fiscal years 2011 and 2013. During this 3-year time period, 

total paid administrative leave per employee ranged between 15 and 730 

days. At the five agencies we reviewed, we identified more than 17,000 

employees charging relatively higher amounts of paid administrative 

leave. From among these 17,000 employees, we selected a

nongeneralizable sample of 312 employees based on (1) those 

employees who had charged the highest amounts of paid administrative 

leave, and (2) a random selection from among the remaining employees 

(see appendix I for a detailed description of sample selection process).

We asked agencies to provide reasons for the two largest total amounts 

of paid administrative leave charged per employee in the 3-year period of 

fiscal years 2011 through 2013.

 

50We defined “relatively higher” as charges to paid administrative leave in excess of three

standard deviations from the agency average. See appendix I for further details.

Personnel Matters 

and Physical Fitness 

Activities were the 

Most Common 

Reasons for Charging 

Large Amounts of 

Paid Administrative 

Leave
 

Page 29 GAO-15-79 Federal Paid Administrative Leave

from duty locations, including rest and recuperation periods for 

employees working overseas (see table 2 below).

Predominant reason. Among selected employees, the most commonly 

cited reason for large amounts of paid administrative leave was personnel 

matters, which was cited as a reason for paid administrative leave at all 

five of our selected agencies. Examples of personnel matters include 

investigations into alleged misconduct, criminal matters, or security 

concerns as well as settlement agreements, pending adverse actions due 

to inappropriate behavior, and interim relief.51

As discussed above, personnel matters are cited in four of the five 

selected agencies’ policies as a permissible reason for authorizing paid 

administrative leave. Personnel matters are not explicitly listed as a 

permissible reason in DOD policy although officials confirmed that they do 

authorize paid administrative leave for this reason.

Agency officials told us that 

these personnel matters concluded in a variety of ways including removal, 

retirement, resignation, reinstatement of employee, and settlement 

agreement.

Other reasons. Three of the most frequently cited reasons for higherthan-average amounts of paid administrative leave are specific to the 

policies and practices of one or two of the selected agencies. These 

reasons include

• Physical fitness-related activities. Both GSA and DOD reported that 

selected employees charged paid administrative leave for physical 

fitness-related activities, with GSA having the most selected 

employees granted paid administrative leave for fitness-related 

activities. An agency official at a GSA subcomponent told us that it 

was following a policy allowing employees up to 3 hours per week in 

paid administrative leave for the purposes of physical fitness-related 

activities. GSA reported that this policy was abolished in fiscal year 

2014, outside the time period of the data collected for this analysis 

(fiscal years 2011 through 2013).

 

51If an administrative judge for the Merit Systems Protection Board (MSPB) issues an 

interim order to reinstate an employee pending the outcome of a review by MSPB, but the 

agency determines that the employee’s return would be unduly disruptive to the 

workplace, while the agency is not required to return the employee to work, it must place 

the employee in a pay status to comply with the interim order pending any appeal. See, 5 

U.S.C. § 7701(b)(2) and 5 C.F.R. § 1201.111(c). 
 

Page 30 GAO-15-79 Federal Paid Administrative Leave

• Vacation. A specific group of contract employees at a subcomponent 

of Interior recorded authorized vacation time as paid administrative 

leave. Interior indicated that it plans to explore other options for 

recording authorized vacation time for these employees.

• Professional development. Participating in professional development 

activities, including attending training, was a reason reported for 

employees with higher-than-average amounts of paid administrative 

leave at VA and DOD. Officials from a VA subcomponent told us that 

paid administrative leave is granted to certain employees so that they 

could attend medical training for the purposes of earning or 

maintaining their professional licenses.

Table 2: Reasons for the Largest Total Amounts of Paid Administrative Leave by Number of Times Cited for Selected 

Employeesa

Reason for paid administrative leave charges Number of times reason was citedb

Personnel matters (including investigations into alleged misconduct, criminal matters, and 

security concerns as well as settlement agreements, pending administrative actions, and 

interim relief) 132

Physical fitness-related activitiesc 61

Travel to/from duty locations (including relocation, temporary duty locations, and rest and 

recuperation periods)c 58

Weather-related circumstances 38

Training and professional development (including conferences and agency-sponsored 

attendance to school programs) 28

Official time (union and labor relations activities)c 24

Authorized vacation time reported as paid administrative leavec 21

Agency could not provide a reason for paid administrative leave charges/insufficient 

information/no record of employee 15

Otherd 14

Total 391

Source: GAO analysis of agency responses. | GAO-15-79

N=391, includes one reason for 312 employees and an additional reason for 79 employees. 

a

Employees were selected from population of employees at the five selected agencies who had 

amounts of paid administrative leave that was relatively higher than each agency’s average amount 

of paid administrative leave per employee.

b

Agencies were asked to provide the reasons for the two largest total amounts of paid administrative 

leave taken in fiscal years 2011 through 2013 per selected employee. Of the 312 selected 

employees, agencies provided us more than one reason in 79 (25 percent) of these cases. Agencies 

were not asked if the additional reason accounted for more or less of the paid administrative leave 

than the first reason listed. Weather-related circumstances and birthdays were the only two reasons 

consistently cited alongside another reason.

c

In some instances for these reasons, the agencies noted that this was a timekeeping error and that 

paid administrative leave should not have been charged for this reason.
 

Page 31 GAO-15-79 Federal Paid Administrative Leave

d Reasons aggregated in “other” category were cited fewer than four times and included birthdays,

holidays, blood or organ donations, hazardous conditions, time off awards, as well as military leave 

(recorded as paid administrative leave due to technical limitations of agency time and attendance 

system) and duty time (recorded as paid administrative leave in error).

Federal agencies have the discretion to grant paid administrative leave to 

employees to help manage their workforces when it is in their best 

interest to do so. This discretion is important in ensuring that employees 

are not placed in dangerous circumstances, have access to professional 

development opportunities, and are able to participate in civic activities 

during work hours. Nonetheless, since paid administrative leave is a cost 

to the taxpayer, its use should be managed effectively. While each 

agency has differences in its policies for granting paid administrative 

leave, we found that data collected by OPM on the amount of such leave 

do not accurately reflect the reasons in agency policies for granting—nor 

what OPM considers to be—paid administrative leave. Therefore, OPM 

data on paid administrative leave are inaccurate and inconsistent across 

agencies. Ensuring a more consistent and accurate measure of data 

across agencies could enable both federal agencies and OPM to more 

effectively oversee the use of paid administrative leave. Such data are

important for understanding the extent to which paid administrative leave 

is used across the government and for potentially identifying instances of 

abuse.

OPM’s collection of payroll data from federal agencies, including data on 

paid administrative leave, could provide relevant and reliable information 

to assist OPM and federal agencies in more effectively managing the 

federal workforce. OPM has collected these data for several years, but 

has not ensured that the data are valid. Our work confirms that the data 

OPM has collected on paid administrative leave do not comport with what 

OPM officials intended to collect. For example, the data included time off 

for federal holidays and other legislatively authorized leave that OPM 

does not consider administrative leave. As a result, OPM does not have 

an accurate measure on the use of paid administrative leave across 

federal agencies that can be used to inform decision makers on the use 

of paid administrative leave. Continuing to collect these data without 

ensuring their accuracy is costly to both OPM and federal agencies. In 

addition, using these data to manage the federal workforce could result in 

decisions based upon faulty conclusions that stem from inaccurate data. 

OPM officials told us that, while they had not reviewed the quality of the 

payroll data, they intend to establish a working group in fiscal year 2015 

toward this end. As part of our ongoing work to review the completeness 

Conclusions
 

Page 32 GAO-15-79 Federal Paid Administrative Leave

and accuracy of the payroll data, we will follow up on the status of OPM’s 

working group.

By working with agencies to improve recording practices and by working 

with payroll providers to report the relevant data, OPM has an opportunity 

to help agencies manage their workforce and resources and provide 

decisions makers with reliable information on the use of administrative 

leave. This could assist both agencies and OPM in making informed 

decisions to effectively manage the federal workforce. Improving the data 

is consistent with internal control standards and OPM’s stated goals for 

collecting and warehousing the Enterprise Human Resources Integration 

(EHRI) system data.

To help ensure that agencies report comparable and reliable data to 

EHRI, we recommend that the Director of OPM, in coordination with 

agencies and payroll service providers, take the following actions:

• Develop guidance for agencies on which activities to enter, or not 

enter, as paid administrative leave in agency time and attendance 

systems; and

• Provide updated and specific guidance to payroll service providers on 

which activities to report, or not report, to the paid administrative leave 

data element in EHRI.

We provided the Secretaries of the Departments of Agriculture, Defense, 

the Interior, State, and Veterans Affairs, as well as the Administrator of 

the General Services Administration and the Directors of the U.S. Agency 

for International Development and the Office of Personnel Management 

with a draft of this report for their review and comment.

In its written comments, reproduced in appendix IV, OPM partially agreed 

with our recommendations. OPM also provided technical comments that 

we incorporated, as appropriate. We also received written comments from 

USDA, DOD, and VA, which are reproduced in appendixes V, VI, and VII. 

USDA stated it generally agreed with the findings, and provided technical 

comments that we incorporated, as appropriate. DOD neither agreed nor 

disagreed with the findings and recommendations, and provided technical 

comments that we incorporated, as appropriate. VA stated it agreed with 

the conclusions and concurred with the recommendations. State also 

provided technical comments that we incorporated, as appropriate. In 

Recommendations

Agency Comments

and Our Evaluation
 

Page 33 GAO-15-79 Federal Paid Administrative Leave

emails received on September 29, 2014, October 6, 2014, and October 2, 

2014, respectively, the liaisons for Interior, GSA, and USAID stated that 

the agencies did not have any comments on the report.

OPM agreed in its comments that 

• Some reporting requirements should be clarified, in particular, 

guidance regarding reporting holiday time;

• It will clarify that the paid administrative leave category is a catchall category for paid leave that does not fall into another EHRI 

category; and

• It will collaborate with agencies and payroll providers in 

developing changes in guidance and EHRI payroll data elements.

OPM recommended that our two recommendations be combined into 

one. Regarding our first recommendation that OPM develop guidance for 

agencies on which activities to enter, or not enter, as paid administrative 

leave in agency time and attendance systems, OPM stated that it 

reflected an incorrect understanding of its role. OPM said that its role 

does not include directing guidance to agencies on how to collect time 

and attendance data, but it does include issuing guidance on EHRI data 

requirements that agency systems should support. We do not agree that 

the recommendations should be combined nor that the first 

recommendation is inconsistent with OPM’s role. Our first 

recommendation is directed at the need for OPM to clarify agencies’ 

understanding of how leave should be reported and entered appropriately 

into time and attendance systems. In directing EHRI data requirements to 

all responsible agency officials and payroll providers, OPM can provide 

such guidance to agencies. Our second recommendation is directed at 

what payroll providers report from these agency time and attendance 

systems to EHRI as paid administrative leave. 

Based on our findings, guidance from OPM could directly impact how 

agencies record time for paid administrative leave activities in agency 

time and attendance systems, thereby increasing the likelihood that 

agency data that are ultimately reported to EHRI would be more accurate. 

We believe that this guidance is within the purview of OPM’s role and is 

similar to guidance that OPM has provided in the past. OPM 

acknowledges as much when it states in its comments on this report that 

“[EHRI data requirements] guidance is not just for payroll providers, but 

for all parties involved in collecting and reporting relevant data.” 
 

Page 34 GAO-15-79 Federal Paid Administrative Leave

Moreover, in agency comments to this report, two of the eight agencies 

indicated that they would benefit from such guidance from OPM. For 

example, VA indicated that it is reviewing how the agency approves and 

charges paid administrative leave. In doing so, VA stated that it will 

coordinate with OPM to ensure consistency with OPM’s interpretation of 

when administrative leave is appropriate. USDA noted that additional 

guidance from OPM would greatly benefit how paid administrative leave 

is managed. Based on our findings and agency comments, we feel that if 

agencies had a common understanding of what OPM considers paid 

administrative leave, then the agencies would be more capable of 

meeting OPM’s data reporting requirements.

Concerning the second recommendation for OPM to provide updated and 

specific guidance to payroll service providers on which activities to report, 

or not report, to the paid administrative leave data element in EHRI, we 

continue to believe it is valid because we found that payroll providers 

were reporting time for activities as paid administrative leave that they 

should not, according to OPM. Our assessment of OPM guidance 

demonstrated that it was limited and it was not clear as to what activities 

should be included or excluded from the paid administrative leave data 

element. Therefore, we believe that clarification of the guidance could 

enhance payroll providers’ understanding of the paid administrative leave 

category and minimize future errors. 

OPM also recommended that we include a recommendation to agencies 

and payroll providers to collaborate with OPM as it revises its guidance 

and to modify systems and procedures to comply with OPM data 

reporting requirements. While these are important issues, we did not 

assess agency and payroll provider collaboration with OPM nor did we 

fully assess agency and payroll provider compliance with OPM data 

reporting requirements. Therefore, it would not be appropriate for us to 

include such a recommendation.

In commenting on the draft report, while DOD did not state whether it 

agreed with the findings and recommendations, it stated that it provided 

comments to enhance context, add clarity, and affirm agency discretion in 

granting or placing personnel on paid administrative leave. For example, 

DOD stated that, “in order to add clarity to the scope of administrative 

leave as opposed to other forms of leave, clear coding standards should 

be identified....” Such comments are consistent with the intent of our 

recommendations that OPM work with agencies and payroll providers to 

develop and update guidance clarifying how agencies record, and payroll 

providers report, paid administrative leave.
 

Page 35 GAO-15-79 Federal Paid Administrative Leave

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

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretaries of 

Agriculture, Defense, the Interior, State, and Veterans Affairs, the 

Administrator of the General Services Administration, the Directors of the 

U.S. Agency for International Development and the Office of Personnel 

Management, and interested congressional committees. In addition, the 

report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. 

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 major contributions to this report 

are listed in appendix VIII. 

Yvonne D. Jones

Director

Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-15-79 Federal Paid Administrative Leave

In this report, we had three objectives including (1) describe policies for 

paid administrative leave at selected federal agencies; (2) review 

agencies’ and payroll providers’ practices in recording and reporting paid 

administrative leave, and describe the number of federal employees 

granted such leave, the total number of days granted, and the associated 

salary costs; and (3) describe categories of reasons for which large 

amounts of paid administrative leave have been charged by individual 

employees at selected federal agencies.1

To obtain an understanding of the reasons why agencies authorize paid 

administrative leave for federal employees, we used OPM’s EHRI payroll 

data (described below) to select five federal agencies—the Departments 

of Defense, the Interior, and Veterans Affairs; General Services 

Administration; and the U.S. Agency for International Development

(USAID)—based upon two factors: (1) the percentage of employees with 

amounts of paid administrative leave that was relatively higher than each 

agency’s average, and (2) the agency’s average amount of administrative 

leave per employee. For these five selected agencies, we reviewed leave 

policies and time and attendance guidance for granting and recording 

paid administrative leave, respectively, and interviewed agency officials. 

We compared the administrative leave policies of the five agencies and, 

in the case of DOD, some subcomponent policies, and categorized the 

reasons authorizing such leave to determine those that are similar or 

different across the agencies.

 To better understand the 

reasons why federal agencies authorize paid administrative leave for 

federal employees and the extent to which it is used government-wide, 

we analyzed payroll data from OPM’s Enterprise Human Resources 

Integration (EHRI) system. We selected five agencies at which to review 

administrative leave policies and collect information on the reasons why 

selected employees had large amounts of paid administrative leave.

To determine the extent of use, the total amount, and salary costs of paid 

administrative leave, we analyzed payroll data from OPM’s EHRI system 

for each agency between fiscal years 2011 and 2013. OPM’s EHRI 

payroll data include paid administrative leave data for more than 100 

federal agencies, including 23 of the 24 agencies covered by the Chief 

Financial Officers (CFO) Act of 1990, as amended (the Department of 

 

1

We defined “large amounts,” also referred to as “relatively higher amounts,” as paid 

administrative leave charges in excess of three standard deviations from the agency 

average.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-15-79 Federal Paid Administrative Leave

State (State) does not report paid administrative leave separately from

regular work hours).2 OPM’s goal for the EHRI payroll data is to securely 

acquire pay data for all federal civilian employees by leveraging existing 

data extraction processes. Payroll data are submitted electronically to 

OPM by payroll service providers. Payroll data submissions from 

providers to EHRI represent actual payroll records in a given pay period. 

The EHRI payroll data covers employees in pay and nonpay status. The 

data includes all federal civilian employees of the Executive Branch 

except for employees in the intelligence community, U.S. Postal Service,3

We conducted substantial electronic testing and interviewed cognizant 

officials at OPM to assess the reliability of the EHRI payroll data. Officials 

at OPM explained that they had not tested the data for consistency nor 

validated it against agency data. In our testing, we examined the data 

provided for obvious errors, inconsistencies, and missing data; conducted 

and selected positions, such as nonappropriated fund personnel, 

commissioned officers in the Departments of Commerce, Health and 

Human Services, and Homeland Security, and the Environmental 

Protection Agency, and, as of March 2006, foreign service personnel at

State. The file does not include employees of the Judicial Branch, and 

Legislative Branch coverage is limited to the Government Printing Office, 

the U.S. Tax Court, and several small commissions.

 

2

31 U.S.C. § 901(b). The 24 CFO Act agencies are the Departments of Agriculture, 

Commerce, Defense, Education, Energy, Health and Human Services, Homeland 

Security, Housing and Urban Development, the Interior, Justice, Labor, State, 

Transportation, the Treasury, and Veterans Affairs, as well as the Agency for International 

Development, Environmental Protection Agency, General Services Administration, 

National Aeronautics and Space Administration, National Science Foundation, Nuclear 

Regulatory Commission, Office of Personnel Management, Small Business 

Administration, and Social Security Administration.

3

The data exclude employees from the Central Intelligence Agency, Defense Intelligence 

Agency, Federal Reserve System - Board of Governors, National Geospatial-Intelligence 

Agency, National Security Agency, Office of the Director of National Intelligence, Office of 

the Vice President, Postal Rate Commission, Tennessee Valley Authority, U.S. Postal 

Service, and the White House Office. 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-15-79 Federal Paid Administrative Leave

logic tests; and compared data to EHRI personnel data.4 We also 

interviewed officials at the four payroll service centers5

To summarize EHRI data on paid administrative leave, we totaled the 

number of hours per employee at each agency then converted that to an 

estimated amount of days assuming an 8-hour work day. Total amounts 

used by the five 

selected agencies to better understand what the data on paid 

administrative leave include when the data are reported to OPM’s EHRI 

system. From this assessment, we determined that the data from fiscal 

years 2011 to 2013 are reliable for the purposes of this study. Data prior 

to fiscal year 2011 were not reliable due to missing data and because 

fewer agencies reported the data to OPM during that time. However, the 

data for fiscal years 2011 to 2013 have several limitations. First, the data 

represent charges to specific categories of leave and other activities that 

vary by agency, thus they are not comparable across agencies. For 

example, one agency might instruct employees to record court leave as 

paid administrative leave whereas employees at another agency may 

record it under a separate category. In addition, we found that one payroll 

service provider included federal holidays among the paid administrative 

leave hours, whereas the other three payroll service providers include 

holiday hours in regular duty time or do not report them at all. Finally, the 

reasons for the charges to administrative leave are not specified in the 

data, so it is not possible to determine why employees charged leave, if it 

corresponds to the agency’s policy for administrative leave, or if it 

includes time when employees were participating in activities directly 

related to their job responsibilities. These limitations are described in the 

report and accompany the presentation of data so they can be properly 

understood in the context of the noted limitations.

 

4

EHRI personnel data (formerly Central Personnel Data File (CPDF)) records 

demographic information, job information, the agency of employment and location of 

employees, and other aspects of the on-board Federal workforce. We previously reported 

that government-wide data from CPDF were 96 percent or more accurate. See GAO, 

OPM’s Central Personnel Data File: Data Appear Sufficiently Reliable to Meet Most 

Customer Needs, GAO/GGD-98-199 (Washington, D.C.: Sept. 30, 1998). OPM recently 

repeated that assessment and found similar results. See OPM, An Assessment of the 

Accuracy of Data Elements in the U.S. Office of Personnel Management’s EHRI-Statistical 

Data Mart (Washington, D.C., August 2013).

5

These four payroll service providers are the National Finance Center, General Services 

Administration, Interior Business Center, and Defense Finance and Accounting Services. 

All 24 CFO Act agencies, except the Department of State, use these four payroll service 

providers.
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-15-79 Federal Paid Administrative Leave

of administrative leave are summed across the three fiscal years and are 

not necessarily charged consecutively. We calculated the average 

number of paid administrative leave days charged per person for the 3-

year period at each agency. We calculated this average using the sum of 

paid administrative leave charges and the on-board average number of 

employees in pay periods with sufficient data (not missing) across the 3-

year period. While there were 79 pay periods in the 3-year period, most 

agency averages were based on data from 77 pay periods because 2 pay 

periods were missing for most agencies. While missing pay periods 

differed for each agency, they generally occurred around the change of 

fiscal year. We calculated the per person average to provide an easier 

interpretation of hours of paid administrative leave. We chose a 3-year 

average because paid administrative leave is not uniformly distributed 

across pay periods or years. We calculated the per person average by 

agency because of differences in agency size. We used actual employee

salaries and work schedules, where available, to estimate the salary cost 

of paid administrative leave hours and all other paid hours. Salary cost 

was adjusted for inflation and prorated for work schedule. If salary and 

work schedule information was unavailable, we used the average agency 

salary, adjusted for inflation, to estimate the salary cost of paid 

administrative leave hours and all other paid hours. We then prorated the 

salary estimate based on the proportion of full-time and part-time 

employees in the federal workforce. Unless otherwise noted, all summary 

data and salary estimates for paid administrative leave exclude federal 

holidays. As described in the report, federal holidays are included in paid 

administrative leave data reported to OPM’s EHRI system for those 

agencies that use National Finance Center (NFC) for payroll service. 

Since federal holidays should not be charged to administrative leave, per 

OPM officials’ expectations, and because they occur regularly and are 

generally applicable across all federal employees, we estimated the total 

amount of federal holiday hours used for those agencies using NFC and 

disaggregated the total time from paid administrative leave charges. Not 

all federal employees are eligible for holiday pay. For example, firefighters 

and part-time employees whose work schedules do not fall on a particular 

holiday may not receive holiday pay. Consequently, we only deducted 

holiday hours from a pay period during which a holiday occurred if paid 

administrative leave hours were charged in that pay period.

Finally, to describe categories of reasons why employees had large 

amounts of leave, we selected a nongeneralizable sample of employees 

at each of the five selected agencies and asked officials at each agency 

to provide reasons for the two largest total amounts of paid administrative 

leave per employee. To select the employees, we first identified those 
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-15-79 Federal Paid Administrative Leave

“outlier” employees charging paid administrative leave in amounts 

relatively higher than average (greater than three standard deviations 

from the agency mean) at each of the five selected agencies, finding 

more than 17,000 employees. Among those employees with large 

amounts of charges across the five agencies, we selected 70 for each of 

the five agencies. This included the 35 employees with the highest total 

amount of paid administrative leave and another 35 employees randomly 

selected from the remaining “outlier” employees. For one of the five 

selected agencies, USAID, there were only 32 “outlier” employees, so we 

did not request information for more than those 32 employees.6

We conducted this performance audit from November 2013 to October 

2014 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 

Using a 

standard form for each agency, we provided a listing of each of the 

selected employees and the total amount of administrative leave each 

employee charged between fiscal years 2011 and 2013. For each of 

these employees, we asked the agency to provide all the reasons for 

which the administrative leave was charged and to identify two of those 

reasons that accounted for the majority of the total charges across the 3 

years. We conducted an independent analysis of the responses provided 

by each agency, where one analyst categorized the reasons provided 

independently from a second analyst, and then compared the results. The 

analysts’ initial assessment was in agreement 96 percent of the time. 

Where there was any disagreement, the analysts discussed to come to 

consensus. Results of our analysis of reasons for administrative leave 

charges are not generalizable to the selected agencies or governmentwide because of sample size and selection method.

 

6

During the course of our review, we discovered that federal holidays were included 

among the paid administrative leave charges in OPM’s EHRI data for those federal 

agencies that use NFC as a payroll provider. Our selection of five agencies and outlier 

employees from these selected agencies was based upon data that included federal 

holidays. However, we separated federal holidays for purposes of reporting, including the 

number of outlier employees for all CFO Act agencies. Since USAID uses NFC, the 

number of outliers increases to 52 when separating federal holidays. We did not request 

additional information from USAID on these employees due to the additional burden on 

the agency to collect the information, and because it would not materially impact our 

findings since the information is nongeneralizable and used for illustrative purposes. 
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-15-79 Federal Paid Administrative Leave

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Paid Administrative Leave 

Summary Data by Agency

Page 42 GAO-15-79 Federal Paid Administrative Leave

Table 3: FY2011-2013 Paid Administrative Leave Charges by Agency

Agency

Total paid administrative leave days

FY2011-2013

Average number of administrative leave 

days charged per employee FY2011-2013a

Including Holidays Excluding holidays Including Holidays Excluding Holidays

Chief Financial Officers Act Agencies Using National Finance Center Payroll Service Provider

Agricultureb 3,307,800 833,100 35 9 

Commerceb 1,313,000 279,500 29 6 

Homeland Securityb 5,437,200 1,513,800 29 8 

Housing and Urban Developmentb 349,200 73,900 37 8 

Justiceb 3,649,600 653,200 31 6 

Laborb 583,000 108,600 35 7 

Small Business Administrationb 132,000 27,000 35 7 

Treasuryb 3,571,700 820,700 32 7 

USAIDb 185,900 77,400 49 20

Chief Financial Officers Act Agencies Using Other Payroll Service Providers

Defense

Not Applicable

Holidays are not included in 

total charges to paid 

administrative leave. See 

“Excluding Holidays” 

column for amounts 

included in governmentwide total below

2,365,800

Not Applicable

Holidays are not included in 

total charges to paid 

administrative leave. See 

“Excluding Holidays” 

column for average number 

of days charged per 

employee

3 

Education 22,300 5 

Energy 84,500 5 

Environmental Protection Agency 41,300 2 

General Services Administration 14,900 1 

Health and Human Services 127,200 2 

Interior 345,400 5 

National Aeronautics and Space 

Administration

90,900 5 

Nuclear Regulatory Commission 20,500 5 

National Science Foundation 8,900 6 

Office of Personnel Management 11,300 2 

Social Security Administration 372,600 6 

Statec - - 

Transportation 171,400 3 

Veterans Affairs 1,375,000 4 

Other Agencies Using All Payroll Service Providers

All Other Agenciesd 1,016,200 505,200 20 10

Government-widee 24,597,700f 9,944,400 12 5 

Source: GAO analysis of OPM’s EHRI payroll data. I GAO-15-79

Appendix II: Paid Administrative Leave 

Summary Data by Agency
Appendix II: Paid Administrative Leave 

Summary Data by Agency

Page 43 GAO-15-79 Federal Paid Administrative Leave

Note: Total days of paid administrative leave are calculated by summing all hours charged per pay 

period from fiscal years 2011 through 2013, and assume an 8-hour work day. Total days are rounded 

to the nearest 100, so summing agency amounts may not equal the government-wide total. 

Administrative leave is not necessarily charged in consecutive hours or days. 

a

Average based on the sum of paid administrative leave charges and the on-board average number 

of employees in pay periods containing sufficient data (not missing) across the 3-year period. Most 

agency averages were based on data from 77 of the 79 pay periods for the 3-year period because 2 

pay periods were missing for most agencies. These missing pay periods differed for each agency and 

generally occurred around the change of fiscal year.

b

Agency payroll service provider, the National Finance Center (NFC), reports federal holidays to OPM 

as paid administrative leave.

c

State does not report paid administrative leave separately to OPM/EHRI. Instead, paid administrative 

leave is tracked in the agency’s time and attendance system and is aggregated and reported with 

regular duty hours to OPM’s EHRI system. 

d

These include more than 100 other agencies, some of which use NFC as a payroll service provider, 

which reports federal holidays to OPM as paid administrative leave.

e

Includes all federal agencies reporting to EHRI, some of which use NFC as a payroll service 

provider, which reports federal holidays to OPM as paid administrative leave.

f

This includes the total paid administrative leave days, excluding holidays, for those Chief Financial 

Officer Act agencies that use a payroll service provider other than NFC since federal holidays for 

those agencies are not included in the total charges to paid administrative leave and, therefore, were 

not adjusted.
Appendix II: Paid Administrative Leave 

Summary Data by Agency

Page 44 GAO-15-79 Federal Paid Administrative Leave

Table 4: FY2011-2013 Estimated Salary Cost of Paid Administrative Leave by Agency

Agency

Estimated salary 

cost

FY2011-2013

Estimated salary 

cost FY2011-2013

Estimated average 

salary cost per 

employee FY2011-

2013a

Estimated average 

salary cost per 

employee

FY2011-2013a

Percent of 

estimated total 

agency salary cost

FY2011-2013

Including Holidays Excluding Holidays Including Holidays Excluding Holidays Excluding Holidays

Chief Financial Officers Act Agencies Using National Finance Center Payroll Service Provider

Agricultureb $ 909,889,200 $ 219,433,800 $ 7,200 $ 1,900 1.11%

Commerceb 512,227,900 105,960,500 10,800 2,300 0.84%

Homeland Securityb 1,629,529,700 380,479,700 7,200 1,800 0.93%

Housing and Urban 

Developmentb 136,366,400 28,495,600 12,300 2,700 1.01%

Justiceb 1,272,964,500 219,083,000 9,900 1,800 0.72%

Laborb 203,313,700 36,863,700 10,000 1,900 0.84%

Small Business 

Administrationb 48,971,100 9,755,600 8,000 1,800 0.91%

Treasuryb 1,139,039,900 249,174,400 8,600 1,900 0.92%

USAIDb 78,646,200 32,374,200 16,400 7,300 2.61%

Chief Financial Officers Act Agencies Using Other Payroll Service Providers

Defense

Not Applicable

Holidays are not included 

in total charges to paid 

administrative leave. See 

“Excluding Holidays” 

column for estimated 

salary cost included in 

government-wide total 

below

697,659,300 

Not Applicable

Holidays are not included 

in total charges to paid 

administrative leave. See 

“Excluding Holidays” 

column for average 

salary cost per employee

1,100 0.40%

Education 9,133,400 1,900 0.65%

Energy 34,585,800 1,900 0.67%

Environmental 

Protection Agency

17,550,100 1,200 0.29%

General Services 

Administration

5,313,600 1,200 0.15%

Health and Human 

Services 

47,175,200 1,000 0.20%

Interior 94,787,500 1,200 0.59%

National Aeronautics 

and Space 

Administration

39,845,800 2,100 0.62%

Nuclear Regulatory 

Commission

9,559,100 2,200 0.66%

National Science 

Foundation

3,913,900 2,100 0.75%

Office of Personnel 

Management

3,602,700 1,000 0.21%

Social Security 

Administration

111,012,200 1,500 0.74%

Statec - - - 
Appendix II: Paid Administrative Leave 

Summary Data by Agency

Page 45 GAO-15-79 Federal Paid Administrative Leave

Agency

Estimated salary 

cost

FY2011-2013

Estimated salary 

cost FY2011-2013

Estimated average 

salary cost per 

employee FY2011-

2013a

Estimated average 

salary cost per 

employee

FY2011-2013a

Percent of 

estimated total 

agency salary cost

FY2011-2013

Transportation 72,317,000 1,400 0.38%

Veterans Affairs 451,294,000 1,700 0.64%

Other Agencies Using All Payroll Service Providers

All Other Agenciesd 435,197,500 207,052,700 7,700 3,700 1.27%

Government-widee $ 7,963,895,600f $ 3,086,422,700 $ 4,000 $ 1,600 0.61%

Source: GAO analysis of OPM’s EHRI payroll data. I GAO-15-79

Note: Total salary is rounded to the nearest 100, so summing agency amounts may not equal the 

government-wide total.

 aEstimated average salary cost per employee is based upon all employees with charges to paid 

administrative leave and does not include those employees with no such charges.

b

Agency payroll service provider, the National Finance Center (NFC), reports federal holidays to OPM 

as paid administrative leave.

c

State does not report paid administrative leave separately to OPM/EHRI. Instead, paid administrative 

leave is tracked in the agency’s time and attendance system and is aggregated and reported with 

regular duty hours to OPM’s EHRI system. 

d

These include more than 100 other agencies, some of which use NFC as a payroll service provider, 

which reports federal holidays to OPM as paid administrative leave.

e

Includes all federal agencies reporting to EHRI, some of which use NFC as a payroll service 

provider, which reports federal holidays to OPM as paid administrative leave.

f

This includes the estimated salary cost, excluding holidays, for those Chief Financial Officer Act 

agencies that use a payroll service provider other than NFC since federal holidays for those agencies 

are not included in the total charges to paid administrative leave and, therefore, were not adjusted.
Appendix III: Employees with Higher-ThanAverage Total Administrative Leave by CFO 

Act Agency

Page 46 GAO-15-79 Federal Paid Administrative Leave

Table 5: Number of Employees at Each CFO Act Agency from Fiscal Years 2011 through 2013 with Higher-Than-Average Total 

Administrative Leave by Time Range (excluding federal holidays)a

Total paid administrative leave from FY2011 through FY2013

Agency

11-20 

days

1-3 

months

3-6 

months

6-9 

months

9-12 

months

1-1.5 

years

1.5-2 

years

2-2.5 

years

2.5-3 

years Total

Agriculture 0 2,262 98 36 15 9 3 0 0 2,423 

Commerce 0 253 26 9 5 4 1 1 0 299 

Defense 0 8,617 701 189 65 45 9 4 0 9,630 

Education 14 40 1 1 0 0 0 0 0 56 

Energy 0 35 34 11 7 4 2 0 0 93 

Environmental 

Protection 

Agency

0 50 8 6 3 1 1 0 0 69 

General Services 

Administration

25 122 6 2 1 0 0 0 0 156 

Health and 

Human Services

89 298 59 12 7 3 1 0 0 469 

Homeland 

Security 

0 470 335 118 45 54 11 4 2 1,039 

Housing and 

Urban 

Development

0 136 26 11 1 1 0 0 0 175 

Interior 0 1,489 109 26 15 4 0 0 0 1,643 

Justice 0 1,690 136 22 1 0 0 0 0 1,849 

Labor 0 80 25 7 7 0 0 0 0 119 

National 

Aeronautics and 

Space 

Administration

0 42 11 4 2 2 0 0 0 61 

Nuclear 

Regulatory 

Commission

21 14 1 0 0 0 0 0 0 36 

National Science 

Foundation

6 13 1 0 0 0 0 0 0 20 

Office of 

Personnel 

Management

0 22 4 6 2 3 0 0 0 37 

Small Business 

Administration

0 5 5 3 0 3 1 0 0 17 

Social Security 

Administration

0 268 57 11 5 2 1 0 0 344 

Stateb - - - - - - - - - - 

Transportation 9 340 53 14 4 3 1 0 0 424 

Appendix III: Employees with Higher-ThanAverage Total Administrative Leave by CFO 

Act Agency
Appendix III: Employees with Higher-ThanAverage Total Administrative Leave by CFO 

Act Agency

Page 47 GAO-15-79 Federal Paid Administrative Leave

Total paid administrative leave from FY2011 through FY2013

Agency

11-20 

days

1-3 

months

3-6 

months

6-9 

months

9-12 

months

1-1.5 

years

1.5-2 

years

2-2.5 

years

2.5-3 

years Total

Treasury 0 775 276 65 17 17 2 3 3 1,158 

USAID 0 0 42 6 3 0 0 1 0 52c

Veterans Affairs 0 5,077 814 148 56 31 11 3 1 6,141 

Total for 24 CFO 

Act Agencies

164 22,098 2,828 707 261 186 44 16 6 26,310

Source: GAO analysis of OPM’s EHRI payroll data. I GAO-15-79 

Note: Timeframes reflect workdays, not calendar days, with 5 days per week, about 21 days per 

month, and 260 days per year. For example, 11 to 20 days is equivalent to about 2 to 4 weeks, and 1 

to 3 months is equivalent to about 21-60 days. Amounts of paid administrative leave represent total 

charges per employee across three fiscal years and are not necessarily charged consecutively across 

days.

a

Includes all employees within an agency that have charges to paid administrative leave in excess of 

three standard deviations from the agency average.

b

State does not report paid administrative leave separately to OPM/EHRI. Instead, paid administrative 

leave is tracked in the agency’s time and attendance system and is aggregated and reported with 

regular work hours to OPM’s EHRI system. 

c

During the course of our review, we discovered that federal holidays were included among the paid 

administrative leave charges in OPM’s EHRI data for those federal agencies that use NFC as a 

payroll provider. Our selection of five agencies and outlier employees from these selected agencies 

was based upon data that included federal holidays. However, we disaggregated federal holidays for 

purposes of reporting, including the number of outlier employees for all CFO Act agencies. Since 

USAID uses NFC, the number of outliers increases to 52 when disaggregating federal holidays. We 

did not request additional information from USAID on these employees due to the additional burden 

on the agency to collect the information, and because it would not materially impact our findings since 

the information is nongeneralizable and used for illustrative purposes.

Table 6: Summary of Employees with Higher-Than-Average Administrative Leave by Agency from Fiscal Years 2011 through 

2013 (excluding federal holidays)a

Agency Total days Average Days Minimum Days Maximum Days

Number of 

Employees

Percent of Total 

Agency 

Employees

Agriculture 120,212 50 33 460 2,423 1.72%

Commerce 15,510 52 24 563 299 0.44%

Defense 409,420 43 21 633 9,630 0.99%

Education 1,698 30 18 155 56 1.00%

Energy 10,373 112 35 480 93 0.47%

Environmental Protection 

Agency

4,711 68 21 425 69 0.33%

General Services 

Administration

5,730 37 15 197 156 1.05%

Health and Human 

Services 

22,521 48 15 420 469 0.43%

Homeland Security 107,749 104 38 730 1,039 0.44%
Appendix III: Employees with Higher-ThanAverage Total Administrative Leave by CFO 

Act Agency

Page 48 GAO-15-79 Federal Paid Administrative Leave

Agency Total days Average Days Minimum Days Maximum Days

Number of 

Employees

Percent of Total 

Agency 

Employees

Housing and Urban 

Development

10,920 62 37 333 175 1.54%

Interior 79,916 49 25 299 1,643 1.46%

Justice 70,215 38 23 202 1,849 1.35%

Labor 8,144 68 27 258 119 0.57%

National Aeronautics and 

Space Administration

4,074 67 23 286 61 0.29%

Nuclear Regulatory 

Commission

885 25 15 96 36 0.76%

National Science 

Foundation

601 30 17 102 20 0.94%

Office of Personnel 

Management

3,736 101 28 339 37 0.41%

Small Business 

Administration

2,587 152 37 408 17 0.23%

Social Security 

Administration

17,985 52 22 518 344 0.46%

Stateb - - - - - - 

Transportation 20,210 48 20 409 424 0.63%

Treasury 82,356 71 34 676 1,158 0.78%

USAIDc 6,178 119 78 550 52 1.05%

Veterans Affairs 330,055 54 30 682 6,141 1.44%

Summary for 24 CFO 

Act Agenciesd 1,335,785 51 15 730 26,310 1.00%

Source: GAO analysis of OPM’s EHRI payroll data. I GAO-15-79 

a

Includes all employees within an agency that have charges to paid administrative leave in excess of 

three standard deviations from the agency average.

b

State does not report paid administrative leave separately to OPM/EHRI. Instead, paid administrative 

leave is tracked in the agency’s time and attendance system and is aggregated and reported with 

regular work hours to OPM’s EHRI system. 

c

During the course of our review, we discovered that federal holidays were included among the paid 

administrative leave charges in OPM’s EHRI data for those federal agencies that use NFC as a 

payroll provider. Our selection of five agencies and outlier employees from these selected agencies 

was based upon data that included federal holidays. However, we disaggregated federal holidays for 

purposes of reporting, including the number of outlier employees for all CFO Act agencies. Since 

USAID uses NFC, the number of outliers increases to 52 when disaggregating federal holidays. We 

did not request additional information from USAID on these employees due to the additional burden 

on the agency to collect the information, and because it would not materially impact our findings since 

the information is nongeneralizable and used for illustrative purposes.

d

Summary includes data for those agencies that report paid administrative leave to OPM’s EHRI 

system. 
Appendix IV: Comments from the Office of 

Personnel Management

Page 49 GAO-15-79 Federal Paid Administrative Leave

Appendix IV: Comments from the Office of 

Personnel Management
Appendix IV: Comments from the Office of 

Personnel Management

Page 50 GAO-15-79 Federal Paid Administrative Leave
Appendix V: Comments from the Department 

of Agriculture

Page 51 GAO-15-79 Federal Paid Administrative Leave

Appendix V: Comments from the Department 

of Agriculture 
Appendix VI: Comments from the Department 

of Defense

Page 52 GAO-15-79 Federal Paid Administrative Leave

Appendix VI: Comments from the 

Department of Defense
Appendix VI: Comments from the Department 

of Defense

Page 53 GAO-15-79 Federal Paid Administrative Leave
Appendix VI: Comments from the Department of Agriculture

Page 54 GAO-15-79 Federal Paid Administrative Leave

Appendix VI: Comments from the 

Department of Agriculture

Appendix VII: Comments from the

Department of Veterans Affairs
Appendix VII: Comments from the Department of Veterans 

Affairs

Page 55 GAO-15-79 Federal Paid Administrative Leave
Page 56 GAO-15-79 Federal Paid Administrative Leave

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

In addition to the contact named above, Steven Lozano, Assistant 

Director; Sara Daleski; Karin Fangman; Shelby Kain; Cynthia Saunders; 

Erin Saunders Rath; Rebecca Shea; and Carolyn Taylor made key 

contributions to this report. Jeff DeMarco, Mary Diop, Deirdre Duffy, Ellen 

Grady, Ulyana Panchishin, Robert Robinson, and Jeffrey Schmerling also 

provided assistance.

Appendix VIII: GAO Contacts

GAO Contacts 

Acknowledgments

(451067)
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