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What did the Office of Personnel Management (OPM) instruct agencies about pay during the 2025 shutdown?

Checked on November 25, 2025
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Executive summary

OPM instructed agencies that furloughed employees and excepted employees who worked during the October–November 2025 lapse are to receive retroactive pay “as soon as possible” after the lapse ends, and that initial payments may be imperfect while payrolls are adjusted [1] [2]. OPM’s September 28, 2025 shutdown guidance and follow-up memos told agencies how to treat furlough status, leave, RIF actions and payroll deductions and directed agencies to resume normal pay/benefits processing, with some agency-specific implementation details left to payroll providers and HR offices [3] [4] [5].

1. OPM’s top-line instruction: retroactive pay for furloughed and excepted workers

OPM told agencies that employees furloughed because of the lapse will receive retroactive pay after the appropriation lapse ends, and that excepted employees — those who worked through the lapse — should be paid for time worked, including overtime where applicable [1] [2]. OPM’s guidance emphasized that the agency is “committed to ensuring that retroactive pay is provided as soon as possible,” while acknowledging payroll timing and calculation constraints [1].

2. How pay will be calculated and delivered — expect initial adjustments

OPM warned agencies and payroll providers that “initial retroactive pay” may not fully reflect all guidance on hours, leave and other treatments; payroll systems may need adjustments and subsequent corrections will follow as practicable [1] [2]. DFAS-specific FAQs explained technical steps used to flag furlough days and noted that out-of-cycle payments and deductions may appear differently on statements [6].

3. Leave, benefits and deductions: rules agencies were told to follow

OPM instructed agencies on treatment of leave and benefits: employees could use paid leave during the lapse (excepted employees may elect to use paid leave instead of furlough), FEHB coverage continues during a lapse, FEGLI premiums withheld once retroactive pay is processed, and certain restored annual leave must be used by specified dates [3] [4] [5]. Agencies were advised to follow normal civil service rules for functions funded by non-annual appropriations and consult legal counsel on distinctions [5].

4. RIFs, DRP and special categories — agencies told to protect employment status

OPM’s memos told agencies that reduction-in-force (RIF) activities can be treated as “excepted” work and continue during a shutdown, and that employees within RIF notice windows retain entitlement to retroactive pay for any overlapping shutdown days [7]. Later OPM guidance and related memos instructed agencies to rescind certain RIF notices issued during the shutdown and restore affected employees with back pay where the shutdown-ending measure required it [8].

5. Implementation friction and political dispute over scope of backpay

While OPM’s guidance clearly promised retroactive pay “as soon as possible,” other administration documents and OMB guidance introduced disagreement by removing explicit references to the 2019 Government Employee Fair Treatment Act in some OMB materials, prompting union criticism and public reporting of divergent legal interpretations [9] [10]. OPM did not publicly revise its September guidance as of early October, and OPM spokespeople declined to comment on discrepancies between OPM and some OMB language, leaving room for confusion at agency level [11] [10].

6. What employees were practically told to expect and early payroll timelines

Agency-facing guidance from OPM’s Workforce Policy leadership provided calculation details and warned agencies that speed to payment might produce errors that would then be corrected; the White House and agencies aimed to deliver “super checks” quickly for some departments by mid-November, with the caveat that payroll offices might need more time for full reconciliation [2] [1].

7. Limits of the available reporting and remaining open questions

Available sources do not mention precise national timelines for every pay system, exact algorithms for leave conversion across every personnel system, or the full list of agencies that issued immediate out-of-cycle payments versus those that waited for centralized retro pay (not found in current reporting). They also show disagreement between OPM guidance and later OMB drafts, which creates legal and practical ambiguity until payrolls are reconciled [9] [10].

Concluding takeaway: OPM’s clear operational instruction to agencies was to provide retroactive pay to furloughed employees and to pay excepted employees for hours worked, and to process necessary leave/benefit actions — while acknowledging practical payroll constraints. However, parallel revisions in OMB materials and public disputes about the legal basis for universal backpay introduced implementation uncertainty that agencies and unions publicly debated as payrolls were processed [1] [9] [10].

Want to dive deeper?
What specific pay guidance did OPM issue to federal agencies during the 2025 government shutdown?
Which categories of federal employees were authorized to be paid or unpaid under OPM's 2025 shutdown instructions?
How did OPM's 2025 shutdown guidance differ from prior shutdowns' pay policies?
What legal authorities and funding mechanisms did OPM cite to justify pay decisions in the 2025 shutdown?
How did agencies implement OPM's 2025 pay instructions and what disputes or litigation arose?