Retirement Services 

Quality Benefits for the Federal Family 

United States 

Office of 

Personnel Management 

The Federal Government’s Human Resources Agency

Benefits Administration Letter 

Number: 12-102 Date: May 25, 2012

Subject: Acceptance of Photocopies of Signed Documents in 

Retirement Application Packages and other Agency 

Submissions

Purpose: This Benefits Administration Letter (BAL) describes our revised policy on the 

acceptance of photocopies of signed documents that are submitted to the Office of Personnel 

Management (OPM) directly from an official system of records in the custody of the agency. 

Previously, OPM required the transmission of originals containing a “wet” signature for 

applications, SF 2818’s (Continuation of Life Insurance Coverage as an Annuitant or 

Compensationer), SF 2821’s(Agency Certification of Life Insurance), and other documents for 

which a signature is required. Under the new policy, OPM will accept photocopies of such 

signed documents from agencies that have established procedures, as set forth below, to ensure 

the documents we receive are a photocopy of the actual original. 

For purposes of this policy, a photocopy means an image of an original document printed on 

paper. Consistent with procedures established by the agency, any process may be used to create 

the image. For example, an agency may establish a procedure where original documents are 

scanned in a remote location and the scanned images are emailed or faxed to the centralized 

benefits office and then forwarded to OPM by fax, email or mail. 

Background: Historically, guidelines for maintaining records by Federal agencies were 

promulgated in title 5, Code of Federal Regulations, Section 293.102, which established 

definitions for “information” (...documentary materials regardless of physical form or 

characteristics) and “system of records” (...group of records under the control of any agency 

from which information is retrieved...) and Section 293.103, which established standards for 

recordkeeping. Guidance was also contained in the Guide to Personnel Recordkeeping. 
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Retirement Services

Quality Benefits for the Federal Family

Beginning in the 1990s, Federal authorities and standards for maintaining records electronically 

started to evolve.

 

 In 1998, the Government Paperwork Elimination Act (GPEA) (Public Law 105-277) 

“required agencies to provide individuals or entities the option to submit information or 

transact with the agency electronically and to maintain records electronically when 

practicable.” 

 In 1999, the National Archives and Records Administration (NARA) issued standards, 

published in 36 C.F.R. § 1234, for the creation, use, preservation, and disposition of 

electronic records, which specifically address the minimum requirements for electronic 

recordkeeping systems that maintain the official file copy of documents on electronic 

media. 

 In 2000, the Business Records Act, 28 U.S.C. § 1732, promulgated rules for according 

scanned documents “the same status as original.” The Act listed three conditions that 

must be met in order to consider a scanned document the same as the original:

1) The documents consist of “writing[s]” that a “department or agency of government in 

the regular course of business or activity has kept or recorded.”

2) The agency causes those writings to be scanned and converted to electronic format 

“in the regular course of business.”

3) The records are “satisfactorily identified” (a requirement that is met by showing that 

the reproduction was made and kept in the “ordinary course of business”). 

Discussion: Under our new policy, OPM will accept photocopies of documents where the

requirements of the Business Records Act are met, through an agency’s use of written 

procedures that establish a chain of custody for the documents. The agency’s procedures should

include:

 a record of where the document came from, who sent the document, how the document

was sent (i.e., mail, fax, or email) and which documents were sent together; 

 a process in which an agency official compares the original document(s) to the 

photocopied, scanned, or faxed document(s); and

 a certification from the document custodian attesting that the documents were produced 

within the context of the written records management procedures as prescribed in 5 

C.F.R. § 293.103, 36 C.F.R. § 1234, the Business Records Act and other guidance 

defining chain of custody. 

All signed applications, documents, and forms OPM receives from an agency that maintains such 

written procedures will be accepted in the form of a photocopy (which includes a scan or fax) 

under the following conditions:

1) The document is directly submitted to OPM by an agency through mail, fax, or email.

2) If the document is contained within a retirement or death in service package, there must be 

an agency checklist that clearly shows the submission includes this document. For 

example, the agency checklist (Schedule D) indicates the following forms (for which we 

would normally require an original signature) are included in the package: SF 3107, SF 
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Retirement Services

Quality Benefits for the Federal Family

2801, SF 2801-2, SF 3107-2, SF 3106, SF 2803, SF 3112, SF 2821, SF 2818, SF 2823.

The agency checklist must be signed by the agency personnel official handling the 

documents and there must be a telephone contact and/or email address for this official. 

3) In situations where individual documents are sent to OPM via fax or email as opposed to 

through the mail, retirement staff will look for the following to determine agency origin: 

a. EMAIL: Email addresses must identify an agency source and agency contact. 

b. FAX: A fax must show the document was faxed from an identifiable agency 

location.

4) SCANS: OPM already accepts scans of documents maintained in the eOPF. These scans 

should have a watermark to indicate they are from the eOPF. OPM will accept scans from 

agencies using other electronic storage systems as long as there is an identifiable 

watermark that indicates the document was maintained in a system of records used in the 

routine course of business.

As long as OPM can verify through these steps that photocopies, scans and faxes of signed 

retirement applications, documents, and forms came directly from a Federal agency (via mail, 

fax, or email), OPM will consider them as authentic representations of the original and will fully 

process the benefit based on these agency submissions. 

Please note that this new policy is for agency submissions only. OPM will continue to require 

“wet” signatures when they originate from a non-agency source (such as from an employee or 

annuitant). 

Kenneth J. Zawodny, Jr.

Associate Director 

Retirement Services