1 

United States

Office of 

Personnel Management 

The Federal Government’s Human Resources Agency

Benefits Administration Letter

Number: 20 - 103 Date: 02/01/2020

Subject: Additional Problems Encountered in Documentation for Disability Retirements 

The Office of Personnel Management (OPM) previously published guidance through 

BAL 99-101, Common Problems Encountered in Documentation for Retirements Under the 

Federal Employees Retirement System (FERS), and BAL 15-102, Additional Items to Report on 

Individual Retirement Records (IRRs) in Cases of Separation, Removal, or Resignation, on 

various issues OPM has encountered with applications for retirements and reporting submissions. 

The purpose of this Benefits Administration Letter (BAL) is to identify the challenges

encountered with documentation submitted for Disability Retirements and to outline additional 

reporting requirements necessary to expedite the processing of Disability Retirements after an 

individual separates from a former Agency. 

Agencies are encouraged to implement the procedures as described in this BAL. These actions 

will allow OPM to improve the retirement submission process and adjudication of Disability 

claims. 

Kenneth J. Zawodny, Jr. 

Associate Director

Retirement Services
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TRANSFERRING RECORDS TO THE NATIONAL PERSONNEL RECORDS 

CENTER AFTER SEPARATION

Problem: Agencies have been sending or electronically transferring separated employees’ 

official personal folders (OPFs), including performance records and the

employees’ medical folder (EMF) to the National Personnel Records Center

(NPRC) within 90 to 120 days after employees separate from Federal Service. In 

situations when a separated employee applies for retirement under the Disability 

provisions within 1 year after separation and OPM subsequently requests the 

individual’s OPF and any necessary information from the former Agency, the 

former Agency has already transferred that individual’s OPF to the NPRC. 

Because the former Agency is unable to provide the individual’s OPF, the 

applicant’s adjudication of disability benefits is significantly delayed. 

Rules:

• Separated employees may file an application for disability retirement within one 

year after their separation from employment (5 C.F.R. § 831.1204). 

• The time limit for submitting an application for retirement can be waived only in 

the case of an employee who is mentally incompetent upon leaving Federal 

Service or who becomes incompetent within 1 year thereafter. 

• In such a situation, the application will be accepted by OPM if filed within 1 year 

from the date the employee is restored to competency or a guardian is appointed, 

whichever is earlier. 

• OPM will accept only one disability retirement application from an employee 

based upon the same circumstances. Thus, once there has been a final denial of a 

disability retirement application, another new application may not be filed absent 

a material change in the employee’s situation. In the case of a separated employee, 

only one disability application may be submitted. 

• Agencies may not submit a disability application for a separated employee. The 

separated employee must file the application directly with OPM. 

• When a separated employee files an application directly with OPM, it will request 

any necessary information from the Agency that has not already been submitted. 

• Agencies may need to retain personnel folders for more than 90 days under certain 

circumstances, as outlined in the Guide to Personnel Record Keeping. 

• Disability retirement applications cannot be adjudicated if OPM is missing 

required information from an applicant’s OPF. 

Action Requested:

Agencies should retain complete personnel folders for at least 1 year after 

the effective date of an employee’s separation when the Agency expects the 
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former employee to apply for Disability retirement benefits within 1 year 

after separation. Being able to obtain a separated employee’s complete OPF 

directly from the Agency, or the eOPF, will help OPM expedite Disability 

retirements more efficiently and quickly authorize the individual’s interim 

pay. 

REPORTING THE LAST DAY OF PAY ON INDIVIDUAL RETIREMENT 

RECORDS 

Problem: OPM typically uses the last day of pay (LDOP) as the commencing date of 

a Disability retirement annuity (e.g. the annuity will be paid retroactively 

from the annuitant’s LDOP). OPM often receives incorrect or missing 

LDOP information on the Individual Retirement Records (IRR’s) of 

employees initially separating under a non-retirement nature of action. In

situations where the employee resigns, is terminated or removed and 

subsequently applies and is approved for disability retirement, OPM 

requires the last day on which employees were in a pay status in order to 

authorize interim annuity payments. 

In many circumstances, the LDOP as certified by Agencies after they 

receive OPM’s Notice of Approval of Disability Retirement Application, 

does not match or concur with other payroll information provided in the 

Disability application. Incomplete or unclear information on the LDOP 

requires OPM to contact the Agency to resolve the discrepancy before 

Disability benefits can be authorized, extending the final adjudication 

process even longer. 

Rules:

• An IRR is used by OPM as the basic record for determining the retirement

benefits payable to a separated employee. It is important that each IRR be

correct, complete, clear in every detail, and properly certified so that when

the record is received by OPM, claims may be processed expeditiously.

• A disability annuity can begin as early as the day after the individual’s pay

stops. Annuity payments can be retroactive to the last day the employee was

in a pay status.
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• If an employee is on leave without pay (LWOP), the final day of separation 

should be no later than the end of the pay period in which the approval 

notice is received. 

• If an applicant has periods of donated leave that interrupt periods of LWOP, 

annuity payments will be retroactive only to the last day of continuous pay. 

Agencies can credit any donated leave retroactively to any periods of 

LWOP (5 C.F.R. § 630.1009(d)). 

Action Requested: 

 

• Employees should be consistently counseled on the impact of their disability 

annuity commencing date when accepting donated leave and informed that their

interim annuity payments cannot start until after their last day of pay. 

• In instances when an employee has not been separated from the Agency and 

OPM’s Notice of Approval of Disability Retirement Application is received, 

Agencies should separate the employee as soon as practical, but usually not later 

than the end of the pay period in which the notice of approval is received. 

Employees cannot exhaust their annual leave or donated leave for any purpose 

past the end of the pay period during which the notice of approval is received (5 

C.F.R. § 630.910(4)).

• Agencies, Shared Service Centers and Payroll Offices must report the LDOP on 

IRRs with the following Nature of Action (NOA) codes:

• 3112 – Resignation ILIA (In lieu of Involuntary Action) 

• 317 – Resignation 

• 310 – Removal

• 351 – Termination Sponsor Relocating 

• 352 – Termination Appointment in (Agency) 

• 353 – Separation US 

• 355 – Termination Expiration of Appointment 

• 356 – Separation RIF (Reduction in Force)

• 357 – Separation RIF (Reduction in Force)

• 357 – Termination

• 385 – Termination during probation/trial period 

• Payroll offices must certify the correct LDOP on all separation IRRs, including 

those related to resignations, removals and terminations, in order for OPM to 

commence benefits on the earliest possible date (CSRS/FERS Handbook, Chapter 

81, Part A2, Section 2-2 and 3-2). 

• All periods of LWOP for each year must be recorded on the IRRs. Only LWOP 

that occurred prior to the LDOP should be posted for the year in which pay stops. 
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COMMENCING DATE OF DISABILITY ANNUITY

Problem: Disability retirement annuitants are often confused or unaware of the rules 

regarding the commencement date of their disability retirement annuity.

Rules:

• A disability annuity commences on the day after separation from service or 

on the day after the LDOP if the employee meets all the conditions to be 

eligible for a disability retirement (5 C.F.R. § 844.301). See CSRS/FERS 

Handbook, Chapter 60, Sections 60A1.1-3 and 60B1.1-2 for eligibility 

requirements. 

• If, after reviewing the medical evidence, OPM determines the date the

disability began (DDB) was on or before the LDOP, the day after the LDOP 

will be used as the commencing date of annuity. If the DDB is found to have 

occurred after the LDOP, the day after the DDB will be used as the 

commencing date of annuity. 

• In situations where the employee resigns, is terminated or removed and 

subsequently applies and is approved for disability retirement, OPM will 

typically use the day after the LDOP as the commencing date of annuity 

unless the applicant specifically requests that the day after separation be 

used. 

NOTE: To determine the most advantageous commencing annuity date, 

OPM will contact the annuitant and provide the opportunity to choose 

which date would be most beneficial for him/her. For example, assume an 

annuitant would not be eligible for health benefits and/or life insurance if 

the LDOP is used as the commencing date. The annuitant may request that 

the separation date be used as the commencing date of annuity. This would 

ensure that he/she does not lose eligibility for health/life insurance 

coverage. This option, however, may result in loss of income since the 

annuity benefit would commence on a later date. 

Action Requested: 

• It is imperative that employees be counseled properly on the effect of using 

LWOP before separating from service. A disability annuity will begin as 

early as the day after the individual’s pay stops. An individual’s LDOP date 

or dates of continuous pay may change if records indicate that the individual 
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received any pay (such as donated leave or other paid leave) before 

separating from service. 

• Employees should also be reminded that OPM will typically use the day

after the LDOP as the commencing date of annuity unless it is otherwise

requested. Each disability case is different, and, in most situations, it is more

advantageous for the annuitant to request to commence the annuity as soon

as possible.

RECORDING HEALTH INSURANCE INFORMATION ON INDIVIDUAL 

RETIREMENT RECORDS

Problem: Currently, payroll offices and shared service centers do not routinely 

include the Federal Employees Health Benefits (FEHB) plan code on the 

IRRs of employees initially separating under a non-retirement nature of 

action. When OPM receives Disability retirement applications from 

separated employees who have up to one year after separating from their 

Agencies to apply for Disability benefits, it must try to obtain this 

information from Agencies, adding additional time to process their 

disability retirements. 

Rules:

• In cases where an applicant’s complete OPF is not readily available and

records of Federal Employee Health Benefits (FEHB) enrollments

documentation are not provided, a final IRR should include health benefit

enrollment information current as of the time of separation. (See Chapter

81 of the CSRS and FERS Handbook on preparing and closing out final

IRRs for Disability Retirement, and additional guidance on items to report

on final IRRs in BAL 15-102).

• A separated employee is eligible to continue health benefits coverage upon

approval of a Disability retirement, if he/she meets all of the following

requirements:

• Is entitled to an immediate retirement annuity under a retirement

system for civilian employees; and

• Has been continuously enrolled (or covered as a family member) in

any FEHB plan(s) for the 5 years of service immediately before the

date their annuity starts, or for the full period(s) of service since their

first opportunity to enroll (if less than 5 years).
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• Breaks in service are not counted as interruptions when the 5 years

of service requirement is determined, as long as they reenroll in

FEHB within 60 days following any such break in service.

• OPM makes the final determination as to whether a separated employee is

eligible to continue health insurance coverage as a Disability annuitant.

• When an individual is eligible for an immediate annuity, but doesn’t apply

for retirement upon separation, agencies will terminate their enrollment on

the Notice of Change in Health Benefits Enrollment (SF 2810) upon their

separation. The individual’s FEHB enrollment will terminate when they are

separated.

• In situations where an employee resigns, is terminated or removed and

subsequently applies and is approved for disability retirement, OPM will

reinstate the FEHB enrollment, retroactive to the starting date of their

Disability annuity (as long as they meet the requirements to continue

enrollment).

Action Requested: 

• To ensure proper health insurance coverage to retiring employees and to

adjust interim annuity payments for necessary insurance withholdings,

Agencies, Shared Services Centers and Payroll Offices must include FEHB

plan codes on all final separation IRRs (including non-retirement

separations).

• Agencies must report an individual’s health insurance enrollment in the

“Remarks” section of the separation IRR as follows:

• H.B. Enrollment Code: ### (See Example 14 for final SF 3100 and

Example 13 for final SF 2806 of Chapter 81 of the CSRS and FERS

Handbook).

• Agencies should counsel employees on their eligibility to enroll for health

care coverage under the Temporary Continuation of Coverage (TCC)

provisions even when employees plan to apply for retirement after

separation or have a disability retirement pending at the time of separation

from the Agency. If their retirement application is approved after the

separation occurs, OPM will contact the individual to offer FEHB

retroactive reinstatement options, if they meet the requirements to continue

their health insurance enrollment. OPM will also confirm coverage under

TCC and request a refund to the retiree of premiums paid for overlapping

periods of coverage.

• Agencies should also notify employees of the consequences of losing FEHB

or FEGLI coverage after being in a nonpay status for longer than 365 days
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(or when FEHB enrollment under TCC ends or conversion to an individual 

health or life insurance policy does not occur). For example, if an employee 

dies in service before being separated from the Agency and after FEHB or 

FEGLI coverage stops, surviving dependents may not be eligible to 

continue their health benefits enrollment and entitlement to FEGLI benefits 

may cease (See Chapter 70 and Chapter 73 of the CSRS and FERS 

Handbook for additional information on continuing health benefits 

enrollment and eligibility for surviving dependents). 

RECORDING LIFE INSURANCE INFORMATION ON INDIVIDUAL 

RETIREMENT RECORDS

Problem: Currently, payroll offices and shared service centers do not routinely 

include Federal Employees Group Life Insurance (FEGLI) enrollment 

codes on the IRRs of employees initially separating under a non-retirement 

nature of action. When OPM receives Disability retirement applications 

from separated employees who have up to one year after separating from 

their Agencies to apply for Disability benefits, it must try to obtain this 

information from Agencies, adding additional time to process their 

disability retirements. 

Rules:

• In cases where an individual’s complete OPF is not readily available and

records of Federal Employee Group Life Insurance (FEGLI) coverage

documentation is not provided, a final IRR should include life insurance

coverage information current as of the time of separation. (See Chapter 81

of the CSRS and FERS Handbook on preparing and closing out final IRRs

for Disability Retirement, and additional guidance on items to report on

final IRRs in BAL 15-102).

• A separated employee is eligible to continue Basic Life insurance – or have

it reinstated - upon approval of a Disability retirement, if he/she meets all

of the following requirements:

• Is entitled to an immediate retirement annuity under a retirement

system for civilian employees;

• Has been insured for the 5 years of service immediately before the

date their annuity starts, or for the full period(s) of service during

which they were eligible to be insured if less than 5 years (called the

“all opportunity” requirement);

• Was enrolled in FEGLI on the date of separation.
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• Has not converted their life insurance coverage to an individual

policy.

• Breaks in service are not counted when determining the 5 years of service

requirement (because the individual was not eligible to be enrolled in

FEGLI during the break in service)

• If the individual is eligible to continue (or have reinstated) Basic insurance,

they are also eligible to continue (or have reinstated) Optional insurance if

they meet the same coverage requirements for Optional insurance as those

for Basic insurance. For the purpose of continuing insurance as an annuitant,

they are not considered to have been eligible for Option C during any period

when they had no eligible family members.

• OPM makes the final determination as to whether a separated employee is

eligible to continue life insurance coverage as a Disability annuitant.

Action Requested:

• To ensure proper life insurance coverage to retiring employees and to adjust

interim annuity payments for necessary insurance withholdings, Agencies,

Shared Services Centers and Payroll Offices must include FEGLI

enrollment codes on all final separation IRRs (including non-retirement

separations).

• Agencies must report an individual’s life insurance status in the “Remarks”

section of the separation IRR as follows:

• Basic Life: Elected [75 Percent Reduction/50 Percent Reduction/No

Reduction]

• Option A: [Waived/Eligible to continue: coverage began (date)/Not

eligible to continue]

• Option B: [Waived/Eligible to continue: coverage began (date) –

number of multiples held during entire last 5 years/Not eligible to

continue]

• Option C: [Waived/Eligible to continue: coverage began (date) –

number of multiples held during entire last 5 years/Not eligible to

continue] (See Example 14 for Final SF 3100 and Example 13 for

final SF 2806 of Chapter 81 of the CSRS and FERS Handbook).
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SUMMITTING COMPLETE DISABILITY RETIREMENT APPLICATION 

PACKAGES

Problem: OPM is receiving disability application packages without all required 

accommodation and/or reassignment documentation. Missing 

documentation further delays the applicant’s adjudication of disability 

benefits. 

Rules: In cases when an individual submits a disability retirement application 

directly to OPM after having been separated from Federal service for a 

period of 31 days or more, the same documentation requirements apply. The 

agency must certify to OPM that all reasonable steps were taken to retain

the employee in the Federal Service. 

• The following required forms should be submitted to OPM for all disability

retirement applications:

For CSRS covered employees: 

• Application for Immediate Retirement - SF 2801

• Spouse’s Consent to Survivor Election – SF 2801-2 (if applicable)

• Employee's Statement of Disability - SF 2824A

• Supervisor's Statement - SF 2824B, including the following

documents when applicable:

• Employee’s Performance Standards

• Employee’s Position Description

• Supporting Documentation regarding employee’s

performance

• Supporting Documentation regarding employee’s leave use

• Supporting documentation regarding employee’s conduct

• Physician's Statement (or equivalent) - SF 2824C

• Agency Certification of Reassignment and Accommodation Efforts -

SF 2824D, including the following documents when applicable:

• Supporting documentation of Agency’s accommodation

efforts

• Supporting documentation of employee’s non-reassignment

or non-selection

• Disability Retirement Application Checklist - SF 2924E

For FERS covered employees:
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• Application for Immediate Retirement - SF 3107

• Spouse’s Consent to Survivor Election – SF 3107-2 (if applicable)

• Employee's Statement of Disability - SF 3112A

• Supervisor's Statement - SF 3112B, including the following

documents when applicable:

• Employee’s Performance Standards

• Employee’s Position Description

• Supporting Documentation regarding employee’s

performance

• Supporting Documentation regarding employee’s leave use

• Supporting documentation regarding employee’s conduct

• Physician's Statement (or equivalent) - SF 23112C

• Agency Certification of Reassignment and Accommodation Efforts -

SF 3112D, including the following documents when applicable:

• Supporting documentation of Agency’s accommodation

efforts

• Supporting documentation of employee’s non-reassignment

or non-selection

• Disability Retirement Application Checklist - SF 3112E

Actions Required: 

• Agencies must document whether the employee's service was deficient and

whether accommodation and or reassignment were possible at the time of

separation when the Agency expects the former employee to apply for

Disability retirement benefits within 1 year after separation.

• Disability retirement applicants that have been separated from Federal

Service for more than 31 days must contact their former supervisor and

employing agency to complete the Supervisor’s Statement, Agency

Certification and Reassignment and Accommodations Efforts form and

Disability Retirement Application Checklist. These forms must be

completed in their entirety and sent back to the applicant before the

disability application package is submitted to OPM within 1 year after the

date of separation.