BAL Document

United States

Office of
Personnel Management

The Federal Government’s Human Resources Agency

Benefits Administration Letter (BAL)
Number: 20-102 REVISED

Date: July 28, 2020

Subject: Temporary Changes to Retirement Application Processing While
Operating Under Coronavirus Disease (COVID-19) Telework Policies.
The purpose of this updated BAL is to outline additional temporary changes and requirements for
submitting valid retirement packages during COVID 19 operations. The updated guidance is shown in
red/italicized text. These changes are effective the date of publication of this updated BAL.

Contents

Preface: Temporary Changes to Retirement Application Processing While Operating Under
Coronavirus Disease (COVID-19) Telework Policies .............................................................................. 2
Contacting OPM Regarding Operations During COVID-19: ................................................................ 2
Requirements for Submitting a Valid Retirement Package Electronically: .......................................... 2
Agency Chain of Custody Process ............................................................................................................ 2
Signature Requirements ............................................................................................................................ 3
Evidence of Chain of Custody: ................................................................................................................. 3
Secure Drop Box for Retirement Applications: ....................................................................................... 4
Accessing OPM’s Secure Drop Box ......................................................................................................... 4
Types of Retirement Applications Accepted Through OPM’s Drop Box ................................................ 4
Retirement Package Requirements ........................................................................................................... 4
Supporting Customers if a Payroll Office is Closed but can Still Submit Data Exchange Gateway
(DEG) Files .................................................................................................................................................. 5
The Federal Employees’ Group Life Insurance (FEGLI) Forms ........................................................... 5
Forms with Special Requirements ............................................................................................................. 6

Preface: Temporary Changes to Retirement Application Processing
While Operating Under Coronavirus Disease (COVID-19) Telework
Policies
In response to COVID-19, many Federal agencies are operating under varying levels of
telework. If possible, agencies should continue to submit retirement applications as they
normally would. However, in order to support increasing levels of telework and to give Human
Resource and Payroll Offices the flexibility to submit retirement applications, the Office of
Personnel Management (OPM) is allowing certain flexibilities.
Effective May 26, 2020, OPM is temporarily suspending requirements to submit paper
documents with wet signatures for agency-submitted immediate retirement applications and
death in service cases. Agencies and Payroll offices may prepare and submit retirement
applications as described below. During this temporary situation, applications submitted in
accordance with this BAL will be accepted as valid and no additional documentation will be
required. Retirement applications are not valid if they are not submitted in accordance with this
BAL, contain incorrect information, or are otherwise incomplete. If a retirement application is
not valid, agencies will be required to resubmit documentation. Once OPM lifts these temporary
measures, agencies will be expected to begin submitting retirement packages as normal.
Agencies can submit applications using their normal procedures even while these temporary
guidelines are in place.
Many of the electronic submission requirements described in this BAL originate from BAL 12102. This BAL does not supersede BAL 12-102.

OPM will continue to monitor the COVID-19 situation. This BAL will be rescinded once
OPM determines normal operations can resume.

Contacting OPM Regarding Operations during COVID-19:
Questions regarding retirement application submission during COVID-19 operations should be
directed to your agency’s Benefits Officer (https://apps.opm.gov/abo/). Agency Benefits Officers
should contact their OPM liaison at [email protected] or 202-606-0788.

Requirements for Submitting a Valid Retirement Package
Electronically:
Retirement applications submitted pursuant to the below policies will be considered valid and
require no additional paper submission.

Agency Chain of Custody Process

Under this temporary measure, OPM will accept scanned retirement application packages in a
PDF format. For a retirement package to be valid, it must be maintained and submitted in
accordance with applicable Federal law on records management, including the Business Records

Act (BRA). The BRA requires agencies to use written procedures that establish a chain of
custody for submitted documents. The agency’s procedures should include:
1. a record of the origin of each document submitted, who sent the document, how the
document was sent, and which documents were sent together;
2. if scanning an original paper document, a process by which an agency official compares
the original document to the scanned or electronic document; and
3. a certification from the document custodian (for these purposes only, OPM considers the
agency submitting the retirement application to be 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, and the BRA.
Note – If a document is completed fully by electronic means and submitted to OPM through the
drop box, the above chain of custody process is not required for that document. For example, an
SF-3107 (FERS application for immediate retirement) would be considered original if an agency,
Payroll Office, and applicant completed their sections by entering data directly into the PDF
form, PDF signing the appropriate section, and then passing the form along to other appropriate
parties via email, or shared drive.

Signature Requirements

Applicants must sign the appropriate form: SF-3107, SF-2801, SF-3104, or SF-2800 for
retirement or SF-2803 or SF-3108 for civilian deposit/redeposits or military deposits. OPM will
not accept applications without one of the signature types below (e.g. signature blocks with
“national emergency, “signature not available,” digitized signatures using a mouse, stylist, or
touchscreen to type text using a cursive font, or copied/pasted signatures are not acceptable).
Under this temporary measure OPM will accept applicant and agency signatures only in the
following formats:
1. Original ink signatures.
2. Scanned ink signatures – Documents may be signed in ink and then scanned by the
submitting agency.
3. “Printed” PDF signatures using PIV or CAC – PDF documents may be signed using
PIV/CAC method and then printed. Once printed, the form may be scanned by the agency
and uploaded to the drop box or sent via mail.
4. PDF signatures using PIV or CAC – PDF documents may be signed using PIV/CAC
method and then included in a retirement package submission.

Evidence of Chain of Custody:

Agencies must ensure the retirement application package chain of custody stays intact by
adhering to the following:
1. The document is directly submitted to OPM by a Payroll Office through Government
email (e.g., .gov, .mil).
2. In accordance with BAL 12-102, documents contained within a retirement or death in
service application package must include an agency checklist that clearly shows that the
application package includes the document/s in question. For example, the agency
checklist (Schedule D) indicates the following forms (for which OPM would normally
require an original signature) are included in the package: SF 3107, SF 2801, SF 2801-2,

SF 3107-2, SF 3106, SF 2803, SF 3112, SF 2823, SF 3104, SF 3104B, SF 2800 and SF
2800A. The agency checklist must be signed by the agency personnel official handling
the documents and there must be a telephone contact and email address for this agency
official.

Secure Drop Box for Retirement Applications:
Payroll Offices may use OPM’s secure electronic drop box to upload scanned retirement
packages. Access to OPM’s drop box will only be granted to Payroll Offices. Retirement
applications may also be prepared using the electronic means outlined in this BAL and then
printed and mailed to OPM by payroll offices.

Accessing OPM’s Secure Drop Box

Payroll Office leadership should contact OPM’s Benefits Officer Liaison and Development
group at [email protected] or 202-606-0788 to establish access to OPM’s portal.
• Each Payroll Office will be permitted to select a limited number of representatives that
will officially submit retirement applications via the portal. Access to the OPM portal
will be restricted to those designated by leadership at each Payroll Office.
• Only Payroll Offices can submit retirement packages through OPM’s portal.

Types of Retirement Applications Accepted through OPM’s Drop Box

OPM will accept the following types of retirement applications along with the application’s
required supporting documentation:
• Immediate retirement packages (SF-2801/SF-3107 and supporting documentation)
• Disability retirement packages (SF-2801/SF-3107/SF-3112 and supporting
documentation)
• Death in service packages (SF-2800/SF-3104 and supporting documentation)
• Application to Make Service Credit Payment under FERS (SF-3108 along with
supporting documentation to verify service)
• Application to Make Deposit or Redeposit under CSRS (SF-2803 along with supporting
documentation to verify service)

Retirement Package Requirements

All applications submitted to OPM’s secure drop box must be prepared in accordance with the
following requirements:
•
•
•

The Data Exchange Gateway (DEG) file remains unchanged and must be submitted in
the normal method.
Each scanned submission must be named with the register number and source – for
instance: OPM 202001 – NFC.
Each submission must include the scanned register and the retirement documents listed
on the register.

•

•
•
•

Each scanned document must mimic the physical register/records that OPM currently
receives.
o The first page must be the completed SF-3103/2807 (Register of Separations and
Transfers) identifying the retirement packages contained in the scanned
document.
o Retirement packages should follow the SF-3103/2807 in the order they appear on
the SF-3103/2807.
Each retirement package must be separated by a blank sheet
Scanned packages must be in PDF format.
Retirement applications must be sent using the existing method, in groups associated with
the corresponding register.

Supporting Customers when a Payroll Office is Closed and only
Submitting DEG Files
OPM cannot finalize retirement payments if a Payroll Office is unable to submit retirement
packages by mail or through OPM’s drop box. However, if a Payroll Office still has the
capability to send a DEG file, OPM will process the DEG file and initiate interim payments, if
possible. It is important that payroll centers submit accurate and complete DEG files to limit
potential interim pay overpayments. OPM will finalize adjudication of the retirement claim upon
receipt of a valid retirement package. That is, a retirement package submitted using normal
methods or one submitted in accordance with this BAL.

The Federal Employees’ Group Life Insurance (FEGLI) Forms
FEGLI forms must be processed in accordance with BAL 20-201:
Agencies should continue to accept, and process forms related to FEGLI. Agencies may accept
documents by fax or email, with the original to follow as soon as practicable. This includes, but
is not limited to, the SF 2821 (Agency Certification of Insurance Status) and SF 2823
(Designation of Beneficiary). Although the SF 2821 indicates in signature blocks 15a and 16a
that a facsimile of the certifying official’s signature is not acceptable, OPM is temporarily
suspending this requirement when necessary for an agency to complete timely processing of this
form. FEGLI regulations at 5 C.F.R. § 870.802 (b) allow agencies to determine the appropriate
methods for receipt of the FEGLI Designation of Beneficiary form.

Forms with Special Requirements
Certain forms submitted with retirement packages have special requirements. Below is a table of those and a description of how each form must be
submitted.
Form Number/Name

Special Requirements

Submission During COVID-19

Spouse’s Consent to Survivor
Annuity (SF 3107-2 & SF 28012)

This form must be completed in front of a notary (notarized).

Applicants may use remote/electronic notaries. Visit
https://www.nationalnotary.org/notary-bulletin/blog/2018/06/remote-notarizationwhat-you-need-to-know for guidance on remote and electronic notaries. If the
applicant’s state of residence does not support remote notary, the applicant may
submit a notarized spousal consent up to 30 days after OPM rescinds this BAL.

FERS/CSRS Designation of
Beneficiary (SF 3102 & SF
2808)

This form must be completed in front of two witnesses.

Human Resources staff may witness the execution of this form.

This form must be completed in front of two witnesses.

Human Resources staff may witness the execution of this form.

Court Orders – wage
garnishments

Scanned copies are acceptable.

N/A

Court Orders – division of CSRS
and FERS annuity and survivor
benefits

Court orders must be submitted as original court certified
documents. (OPM will accept copies to award benefits, but
payment based on the order will not occur until the original
certified order is received).

Death Certificates

Copies are acceptable.

Marriage Certificates

Copies are acceptable.

SF 2823

Applicants may visit https://www.cdc.gov/nchs/w2w/index.htm for guidance on
obtaining Death/Marriage/Birth Certificates and Divorce Decrees.