United States

Office of 

Personnel Management

The Federal Government’s Human Resources Agency

Benefits Administration Letter

Number: 21-303 Date: April 2021 

Subject: COVID-19 Emergency Paid Leave Reimbursement 

Section 4001 of the American Rescue Plan Act of 2021 (Public Law 117-2), enacted on March 

11, 2021, established a new category of paid leave for selected Federal employees. Eligibility for 

the leave is based on certain COVID-19-related qualifying circumstances. The Office of 

Personnel Management (OPM)’s “COVID-19 Emergency Paid Leave”, Memorandum for Heads 

of Executive Departments and Agencies (Compensation Policy Memorandum (CPM) 2021-15) 

that provides necessary guidance, including a high-level summary of key features, detailed 

guidance, and templates is available at https://www.chcoc.gov/content/covid-19-emergencypaid-leave. This emergency paid leave (EPL) will be funded by a $570 million Emergency 

Federal Employee Leave Fund, which will be administered by the Director of OPM. This letter 

informs agencies how they may seek reimbursements for emergency paid leave payments as 

described in section 4001. 

Agencies with covered employees using emergency paid leave must submit requests for 

qualifying reimbursements to OPM, using the request form in Attachment A. Agencies must 

submit said requests via email to: OPMARPAServices@opm.gov. An agency may not submit a 

request for reimbursement unless the leave covered by the request has been used by the 

employee. Additionally, an agency request must be associated with completed pay periods. 

Requesting Reimbursement Procedures:

Reimbursement is available for agency leave payments to covered employees in qualifying 

circumstances for leave used during the qualifying period from March 11 through September 30, 

2021. Reimbursement is based on the gross value of the paid leave. It does not consider any 

benefit costs associated with basic pay generated by EPL. 

• Complete the Request for COVID-19 Emergency Paid Leave Reimbursement Form 

in Attachment A after the completion of the biweekly pay period in which leave covered 

by the request was used. To assist OPM in monitoring the Fund, we recommend that 

agencies submit requests each biweekly pay period, rather than hold and consolidate 

requests that cover multiple biweekly pay periods. The request should specify the 

biweekly pay period, total number of leave hours covered, total number of employees 

using the covered leave, and total dollar value of the covered leave. The agency will 

maintain all related supporting documentation for audit purposes.

• OPM will remit the reimbursement payment to the agency via the Treasury Department’s 

Intra-Governmental Payment and Collection (IPAC) mechanism. The reimbursement 

request should include one Treasury Account Symbol for the IPAC payment.
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• When submitting a reimbursement claim to OPM, an authorized agency official must 

attest that, to the official’s knowledge, the agency’s established policies and procedures 

for implementing emergency paid leave are in compliance with section 4001 and OPM’s 

supporting guidance. The request for reimbursement must be certified by an Authorizing 

Officer (i.e. the Chief Financial Officer or his/her Designee).

• The request must be submitted to OPM Office of the Chief Financial Officer via email at

OPMARPAServices@opm.gov.

• All IPAC payments will be initiated by OPM.

• Agency reimbursement requests will be processed on a first-come, first-served basis, 

based on the date and time OPM receives each agency reimbursement request via email 

to OPM’s Office of the Chief Financial Officer, as instructed above. If the Fund 

approaches the point where it will be exhausted, agency reimbursement requests will be 

processed on a first-come, first-served basis, based on the date and time OPM receives 

each agency reimbursement request, subject to the rules in the following paragraphs. 

a. For the purposes of applying the first-come/first-served protocol, OPM will not 

consider any agency reimbursement request in connection with a given biweekly 

pay period to be received prior to 12:00 noon on the second Friday following the 

end of that pay period—regardless of the actual day and time of receipt. OPM 

will not process agency reimbursement requests until after this earliest-allowedreceipt point in time. (This rule considers the fact that agencies have different 

payroll processing timeframes.) 

b. An agency reimbursement request (or set of agency requests with the same receipt 

date/time) that exhausts the Fund will result in a partial reimbursement to the 

agency (or agencies). The partial reimbursement will be determined applying a 

proration percentage derived by dividing the remaining funds available by the 

total dollar value of the affected agency (or agencies’) reimbursement requests. 

In this partial reimbursement scenario, OPM will organize agency claims by 

biweekly pay period. OPM will apply available funds to reimbursement claims 

for the earliest biweekly pay period, seeking to provide full reimbursement, until 

it identifies the earliest biweekly pay period for which there are insufficient funds 

to fully cover the reimbursement claims associated with that period. OPM will 

provide partial reimbursement for claims associated with that biweekly pay period 

and will provide no reimbursement to claims associated with any later biweekly 

pay period. When an agency receives a partial reimbursement, it will need to 

determine how to allocate available funds to cover (i.e., give final approval of) 

individual employee EPL claims that were conditionally granted.

• Agencies must inform employees that the granting of emergency paid leave to employees 

who meet the eligibility conditions is tentative and conditional upon monies being 

available in the Fund. 

• If an agency’s reimbursement request cannot be granted due to exhaustion of the Fund, 

the emergency paid leave conditionally granted to an employee by the agency must be 

cancelled. The affected period of time will be converted to a period of leave without pay 

(resulting in an overpayment) unless the employee elects, in accordance with the signed 

Employee Agreement (see Paragraph F.4 in Attachment 2, and Attachment 4 to the 

OPM’s supporting guidance cited above), to apply other paid leave or paid time off 

available to the employee (including advanced annual leave or advanced sick leave, as 
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appropriate). 

• Correction of errors – When an agency discovers an error in a request for reimbursement 

that it has previously certified and submitted to OPM, the agency has to report the 

correction on a separate line on a subsequent reimbursement request. For example, if the 

agency granted an employee too many EPL hours but the agency had already received 

reimbursement from the Fund, the agency would report the overpayments in a separate 

line for each pay period on a subsequent reimbursement request as a negative amount 

(reduction) whether or not the agency is requesting new reimbursement. When OPM 

processes the reimbursement, the lines will show up as separate lines of IPAC.

• OPM will provide agencies with regular updates on the balance remaining in the Fund on 

OPM web site at https://www.opm.gov/policy-data-oversight/pay-leave/ARPA.

For questions about the new reimbursement request collection process, please contact the

OPMARPAServices@opm.gov.

Dennis D. Coleman

Chief Financial Officer

Attachments:

A.Request for COVID-19 Emergency Paid Leave Reimbursement Form

B.Accounting Scenarios for the EPL Reimbursement