Payment Management System payment request justifications

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 Financial Reporting
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OGM
             Washington, D.C. 20210                       DATE
                                                          December 29, 2025

ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 06-25

TO:             STATE WORKFORCE AGENCIES
                STATE WORKFORCE ADMINISTRATORS
                STATE WORKFORCE LIASIONS
                STATE AND LOCAL WORKFORCE INVESTMENT BOARDS
                ALL DIRECT AWARD RECIPIENTS

FROM:           LORI FRAZIER BEARDEN
                Acting Assistant Secretary

SUBJECT:        Payment Management System Mandatory Payment Request Justification

1. Purpose. To provide Employment and Training Administration (ETA) grant and
   cooperative agreement recipients (recipients) with information regarding the Payment
   Management System’s (PMS) mandatory payment request justification, ETA’s review and
   approval of payment request justifications, as well as to provide examples of acceptable
   payment request justifications.

2. Action Requested. Please disseminate this guidance to all recipient staff responsible for
   submitting payment requests through PMS.

3. Summary and Background.

   a. Summary – This guidance outlines the requirement in PMS for recipients to complete a
      mandatory payment request justification field and provides examples of acceptable
      payment request justifications. It also covers ETA’s review and approval of the payment
      request justifications.

   b. Background – The U.S. Department of Labor uses the U.S. Department of Health and
      Human Services’ (HHS) PMS to disburse funds to its recipients. A recipient submits a
      payment request to PMS, which is approved or rejected by PMS staff based on the
      recipient’s payment drawdown history, authorized award amount, and remaining award
      balances.

       As of March 17, 2025, all recipients are now required to submit a justification with each
       payment request submitted to PMS. HHS has created a new mandatory field on the PMS
       payment request screen that requires recipients to provide a brief justification for each
       payment request submitted for approval. This new field is part of the implementation of
       section 3 of Executive Order (E.O.) 14222, Implementing the President's "Department of

   RESCISSIONS                                             EXPIRATION DATE
   None                                                    Continuing

       Government Efficiency" Cost Efficiency Initiative, which requires that each agency
       “record every payment issued by the agency,” along with “a brief, written justification
       for each payment submitted by the agency employee who approves the payment.” The
       recipient justification provided in PMS will help inform ETA’s own justification and
       approval or denial of the payment.
4. PMS Mandatory Payment Request Justification and ETA Review and Approval.

   a. PMS Mandatory Payment Request Justification

   On March 17, 2025, HHS introduced a mandatory field in the PMS payment request screen
   to capture a justification from the recipient explaining the purpose of the payment request.

     i.   Payment Request Justification Content and Length

          The payment request justification must be detailed enough to allow ETA to be able to
          make an approval decision (as discussed further in section 4.b below). At a
          minimum, the recipient payment request justification must provide:

              •   The ETA program for which the payment is being requested;
              •   A list of budget item(s) or expense category(ies), along with an amount for
                  each that sums up to the total payment request; and
              •   A date range associated with the costs included in the payment request.

          If requesting payment for contractual services and operations costs, recipients must
          provide a breakdown as part of the payment request justification. In preparing their
          payment request justification, recipients should be mindful that the field to capture
          the payment request justification in PMS is limited to 1,000 characters. Please see
          Attachment I for examples of payment request justifications.

    ii.   Payment Request Justifications Should Not Contain Personally Identifiable
          Information (PII)

          Recipients must refrain from including PII or other sensitive information in their PMS
          payment request justifications. Additional information regarding PII and other
          sensitive information can be found in Training and Employment Guidance Letter No.
          39-11, Guidance on the Handling and Protection of Personally Identifiable
          Information (PII). ETA staff will ensure that no PII or protected information is
          included in payment approvals. The Defend the Spend (DTS) system, discussed in
          more detail below, contains functionality that will allow ETA staff to remove any PII
          from the recipient payment request. Both the payment request justification provided
          by the recipient as well as the approval comment provided by ETA staff are posted at
          www.doge.gov/payments.

 iii.   Payment Requests Covering Multiple PMS Subaccounts

        If a payment request covers multiple PMS subaccounts, a justification is required for
        each of the PMS subaccounts, as shown below.

                      Payment Request - $25,000 (two sub-accounts)

        If a justification is needed or is insufficient for one subaccount, the entire payment
        request will be on hold until adequate justification is received for the subaccount in
        question. Therefore, recipients are strongly encouraged to submit separate payment
        requests and justifications for each individual PMS subaccount to avoid potential
        payment delays.

If a recipient leaves the required payment request justification field blank, PMS will not
allow the request to move forward, and the following error message will display:

Once the payment request justification is inputted and submitted, the payment request
justification is then transferred to the DTS system for ETA staff review.

b. ETA Review and Approval – Defend the Spend

In support of E.O. 14222, the Department of Government Efficiency launched an initiative
called DTS that requires each agency to provide written justification and approval for each
recipient payment request. The DTS system captures the recipient’s payment request
justification (recipient justification) submitted in PMS and provides functionality for ETA

staff to: (1) review and approve the recipient’s payment request and provide the agency’s
written justification for approval (Agency approval justification), (2) request additional
clarification from the recipient for the payment request justification, if needed, or (3) reject
the payment request.

The DTS system interface with PMS pulls payment requests every 60 seconds into DTS for
review by ETA staff. ETA staff must review and act on payment requests within three
business days of receipt.
  i.   Payment Request Justification Clarification

       When clarification is required on a payment request justification (e.g., the
       justification does not contain the minimum required elements, the justification is
       unclear, etc.), a DTS system generated email notification will be sent to the recipient
       with specifics on what clarification and updates are needed.

       Once the recipient responds to the clarification request via an updated payment
       request justification, it will re-enter the review and approval cycle. Recipients should
       respond to requests for clarification on payment request justifications as soon as
       possible and ensure that all the elements in the clarification request are addressed in
       the updated payment request justification, as the payment request will be in a hold
       status until the clarification request is responded to and accepted by ETA.

       Recipients should save DTS in their email contacts to ensure DTS emails are not
       identified as spam and can be acted upon quickly. Recipients should work with their
       ETA representative if issues arise.

 ii.   Payment Requests Covering Multiple PMS Subaccounts

       As noted above, if a payment request covers multiple PMS subaccounts, a
       justification is required for each PMS subaccount. If a recipient submits a payment
       request with multiple PMS subaccounts and ETA staff request additional clarification
       for one of the subaccount’s justifications, the entire payment request will be in a hold
       status until the clarification request is completed and accepted by ETA.

       Thus, as mentioned above, recipients are strongly encouraged to submit separate
       payment requests and justifications for each individual PMS subaccount to avoid the
       potential of payment delays when the justification for one or more of the PMS
       subaccount(s) is sufficient while clarification is needed on the justification for another
       of the PMS subaccounts.

    iii.   Payment Release

           Once reviewed and approved by ETA staff, the DTS system releases the payment.
           Typically, DTS has a daily 4:00 pm EST cut-off to send approved requests to the U.S.
           Department of the Treasury to release payments.

     iv.   Payment Request Rejections

           In certain circumstances, it may be necessary for ETA staff to reject a recipient
           payment request outright (e.g., a recipient submits a duplicate payment request or a
           request for unallowable costs). When a payment request is rejected, the recipient will
           receive a DTS system generated email notification of the payment request rejection.

5. Inquiries. Please direct any inquiries as follows:

   a. Questions on this Guidance – please contact your assigned Federal Project Officer (FPO)
       or the appropriate regional or national program office.

   b. PMS Technical Assistance – please contact the PMS Helpdesk at:
      [email protected] and copy your assigned FPO. Submit an online ticket at:
      https://gditshared.servicenowservices.com/hhs_pms.

6. References.
   • Executive Order 14222, Implementing the President's "Department of Government
      Efficiency" Cost Efficiency Initiative, https://www.whitehouse.gov/presidential-
      actions/2025/02/implementing-the-presidents-department-of-government-efficiency-cost-
      efficiency-initiative/; and
   • Training and Employment Guidance Letter No. 39-11, Guidance on the Handling and
      Protection of Personally Identifiable Information (PII),
      https://www.dol.gov/agencies/eta/advisories/training-and-employment-guidance-letter-
      no-39-11.

7. Attachments.

   Attachment I – Payment Management System Mandatory Payment Request Justification
                   Examples
   Attachment II – Frequently Asked Questions

                                                                                    Attachment I

    Payment Management System Mandatory Payment Request Justification Examples

A. FORMULA PROGRAMS

Example 1

These funds reimburse Dislocated Worker program expenditures for assisting dislocated workers
in finding employment and support on-the-job and incumbent worker training. This covers
personnel salary ($100,000), associated fringe benefit costs ($10,000), utilities ($500), indirect
costs ($16,000), performance tracking and subrecipient costs for job search ($50,000), career
planning and training ($500,000) for January 6 through January 31, 2025.

Example 2

These funds reimburse expenditures under the Work Opportunity Tax Credit program which is a
federal tax credit available to employers who invest in American job seekers who consistently
face barriers to employment. This request covers staff salary ($43,000), associated fringe benefit
costs ($12,000), related operational expenditures ($2,300), and system supports ($1,200) for the
review and approval of tax credit applications for employers hiring eligible individuals for the
month of February 2025.
Example 3

These funds reimburse expenditures under the Reemployment Services and Eligibility
Assessment program that assists individuals in finding employment quickly after dislocation by
engaging unemployment compensation claimants. This covers personnel salaries ($450,000),
associated fringe benefit costs ($125,000), related operational expenditures ($53,250), case
management ($16,000), program evaluation ($300,000), individualized job planning, provision
of labor market information, and referrals of individuals to additional resources (covered under
personnel) for the week of April 7, 2025.

Example 4

These funds reimburse expenditures under the Unemployment State Administration program that
provides funding to states for administering their unemployment insurance (UI) programs,
including processing claims to provide UI benefits to eligible workers, to ensure that the UI
system is functioning efficiently. This covers personnel salaries ($675,000), associated fringe
benefit costs ($250,000), and related operational expenditures ($325,000), for the week of April
14, 2025.

                                                                                     Attachment I

B. DISCRETIONARY PROGRAMS

Example 1

These funds reimburse expenditures to expand and strengthen the Registered Apprenticeship
system through support of public/private partnerships designed to serve a range of industries and
individuals. This includes grant staff salaries ($87,650), associated fringe benefits ($13,246),
program-related travel ($1,400), equipment acquisition ($23,000), supplies ($54), contractors and
subrecipients ($56,500), and indirect costs ($16,000) from December 31, 2024 through
January 10, 2025.

Example 2

These funds reimburse expenditures for the program’s provision of pre-apprentice and
educational services, occupational training, and other employment services for youth ages 16 to
24 while performing meaningful work and service to their communities. This includes staff
salary ($135,000), associated fringe benefits ($45,000), program-related travel ($32), equipment
acquisition ($32,000), supplies ($125), contractors and subrecipients ($32,250), other program-
related expenses ($1,200), and indirect costs ($567) for the month of February 2025.

Example 3

These funds reimburse project expenditures for the period of December 15 to 31, 2024, as
outlined in the grant agreement. This request covers reimbursements for project salaries
($18,790), associated fringe benefits ($5,400), project-related travel ($356), supplies ($69),
contractors ($140,000), and indirect costs ($1,560).

C. FUNDING ADJUSTMENTS/REFUNDS (All Programs)

Example

The $68,543 being returned to the U.S. Department of Labor is due to (see example explanations
below that could complete this justification)

•   Disallowed costs from June 23, 2024 to July 15, 2024, due to audit/monitoring findings.
•   The final negotiated indirect cost rate coming in lower than the provisional rate and all the
    budgeted funds were previously drawn down.
•   Excess funds returned by a subrecipient.
•   Adjustment to expenditures to a previous Program Year grant following first-in, first-out
    practice for full utilization of grant funds.

                                                                                    Attachment II

                             Frequently Asked Questions
Payment Request Justification
Is the justification simply restating the purpose of the grant?

No, the payment request justification must describe the exact reason for the payment request and
must include the name of the Employment and Training Administration (ETA) program, the
main budget item(s) or expense category(ies), along with an amount for each that sums up to the
total payment request, and the date range associated with the costs included in the payment
request.

If we use a blanket statement that is repetitious will that set off alarms? Or cause further
investigation due to the justification not being unique?

The payment request justification must be specific to the payment amount. ETA would not
expect the justification to be the same for all payment requests.

What format should be used to submit the justification?

The Payment Management System (PMS) payment request screen provides a mandatory field for
the payment request justification. The payment request justification maximum length is 1,000
characters. Please see Attachment I of the Training and Employment Guidance Letter (TEGL)
for payment request justification examples.

Is ETA requiring supporting documentation as an attachment to the payment request?

ETA currently does not require any supporting documents/attachments for payment request
justifications.

Can we submit multiple requests in one day per sub-account?

Yes, a recipient can send multiple payment requests/justifications in one day per sub-account.

If we have a payment request with multiple sub-accounts, will questions on the payment
justification for one sub-account delay the entire payment request?

Yes, if a recipient submits one payment request for multiple sub-accounts and clarification is
needed on the justification for one of the sub-accounts, the entire payment request will be on
hold until the clarification is submitted and approved. ETA strongly recommends sending
separate payment requests per PMS sub-account to avoid potential delays.

Do the amounts in the justification for each category need to align with the amount being
requested for drawdown?

Yes, the justification for each category in the payment request justification should add up to the
total payment request.

                                                                                     Attachment II

What if we are submitting payment requests for many different expenses (such as payroll,
supplies, consultants, etc.); how detailed do we have to be?

Recipients should be as detailed as possible when submitting payment request justifications to
inform why the funds are being requested and to facilitate ETA’s approval. Please see
Attachment I of the TEGL for payment request justification examples.

Should the payment justification dates be based on actual expenditure dates or dates we paid
our subrecipients?

Payment requests must be based on the actual expenditure dates. Please include the dates in the
payment request justification.

Is there a limit on the time difference allowed between incurring the expenses and submitting
a payment request?

No, but recipients must ensure the period for the expenses incurred is included in the
justification. For example, “to pay a subrecipient invoice for the period April 1, 2025 to May 30,
2025.”

Approvals and Timing
Who is reviewing the payment justifications?

ETA staff are reviewing and approving the payment request justifications in the Defend the
Spend (DTS) system.

Is the DTS system set up to send auto-replies for clarification or are messages sent after
someone reviews the payment request?

If additional information is needed regarding the payment request justification, the ETA reviewer
will issue a clarification request through the DTS system. A notification link will be sent to the
recipient (payment requester) through the DTS system to respond to the clarification. Recipients
should save DTS in their email contacts to ensure DTS emails are not identified as spam and can
be acted upon quickly.

Once the recipient responds to the clarification request via an updated payment request
justification, it will re-enter the review and approval cycle. Recipients should respond to
requests for clarification on payment request justifications as soon as possible and ensure that all
the elements in the clarification request are addressed in the updated payment request
justification, as the payment request will be in a hold status until the clarification request is
responded to and accepted by ETA.

                                                                                  Attachment II

What is the expected turnaround for ETA review and approval?

ETA staff have three business days to review and act on payment request justifications. Funds
for payments approved by 4:00 pm EST will generally be available for drawdown that same day.

What happens if the DTS system displays “error 404, not found”?

Please reach out to your ETA contact or your Federal Project Officer.

Will the name of the organization, payment request and payment justification be posted online
for the public to review?

Yes, the name of the organization, the payment amount, and the justifications from both the
recipient and ETA will appear on the Department of Government Efficiency’s (DOGE) official
website, www.doge.gov/payments. Recipients must not include protected or non-sensitive
personally identifiable information in payment request justifications.

Payment Management System
In PMS, you can only see about 50 characters in the input fields on the payment screen. Are
there any planned development changes to expand the input fields on the payment request
screen to see the full details of what you can type in?

PMS does not have any plans to expand the justification comment box at this time.

Is it possible to get a list of payments previously submitted and processed for the entire Payee
Account Number?

To see payment history, recipients can access the Apex Reports – Grantee Inquiry – Financial
Transactions.

       Attachment II

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