State Agencies Bulletin No. 1943

COVID-19 Vaccination Leave Under the 2021 American Rescue Plan Act (ARPA)
Date Issued
September 17, 2021


The purpose of this bulletin is to provide agencies the process for reporting hours of paid leave used by employees to obtain the COVID-19 immunization under the American Rescue Plan Act (ARPA) of 2021. Under ARPA, the paid leave will be reflected on an employee’s annual W-2 (Wage and Tax Statement) for 2021.

Affected Employees

Employees utilizing paid leave to obtain COVID-19 immunization, subject to certain exceptions, between 04/01/2021 and 09/30/2021 are affected.


In March 2020, in response to the COVID-19 global pandemic, Congress passed the Families First Coronavirus Relief Act (FFCRA) that created two new emergency paid leave requirements: the Emergency Paid Sick Leave Act (EPSLA) and the Emergency Family and Medical Leave Expansion Action (EFMLEA). ARPA was enacted in March 2021, effective 04/01/2021. ARPA allows employers a credit against applicable employment taxes equal to 100 percent of the of qualified sick leave wages paid by the employer. Under ARPA, EPSLA was expanded to allow, among other things, employees to use paid sick leave to obtain COVID-19 immunization.

Effective Dates

Effective 04/01/2021 through 09/30/2021.

Agency Actions

Agencies must submit vaccination leave data to OSC by 10/22/2021. This leave is only permitted to be used for a maximum of 4 hours per injection, it is not appropriate to reflect this portion of COVID leave in the payroll system. Agencies must submit an excel spreadsheet (Attachment A) to the Tax and Compliance mailbox that contains a list of employees who charged vaccination leave between 04/01/2021 and 09/30/2021. The spreadsheet should list the DeptID, Employee ID, Employee Record, Leave date, and number of hours. If an employee has more than one leave date, please list them on separate lines of the spreadsheet.

OSC Actions

OSC will compile the COVID vaccination leave information between 04/01/2021 and 09/30/2021 from agency-submitted spreadsheets and update the affected employees’ W-2, Box 14 accordingly.

Tax Information

These monies are taxable income and will be included in the employee’s taxable gross income, subject to all employment and income taxes. In addition, an employee’s COVID-19 leave wages for vaccination leave will be reported in Box 14 on the employee’s 2021 Form W-2 (Wage and Tax Statement).


Questions related to vaccination leave on the annual W-2 (Wage and Tax Statement) issued to employees may be directed to the Tax and Compliance mailbox. All other questions related to reporting COVID leave may be directed to an agency auditor.