Before 2001, federal agencies faced repeated GAO decisions blocking reimbursement of what looked like ordinary employee-development expenses. A 1982 decision said agencies could not pay bar review courses or bar membership fees for their attorneys, calling these "personal expenses related to qualifying for office." A 1976 decision blocked medical licensing fees for Public Health Service physicians. A 1995 decision blocked Certified Government Manager designation costs. The rule was: credentials are a personal investment, not a federal expense. Congress responded with Section 1112(a) of the National Defense Authorization Act for Fiscal Year 2002, which added 5 U.S.C. 5757 to Title 5 effective December 28, 2001. For the first time, agencies had clear statutory authority to pay for professional credentials.
This article explains what 5757 authorizes, the GAO-established scope limits on what counts as a reimbursable credential, how agency implementing policies typically work, the major credential families federal employees pursue (with IT and cybersecurity covered separately in IT & Cybersecurity Certifications in Government), and the practical strategy for getting a credential approved and funded. Everything reflects law and guidance in effect as of April 2026.
Agencies may pay for expenses required to obtain or maintain a license or certification — exam fees, licensing fees, required continuing education, required memberships that condition the license. Agencies generally cannot pay for voluntary professional memberships in organizations of already-credentialed professionals, bar review courses, or credential expenses designed to qualify the employee for a higher-grade position. The statute is discretionary — each agency sets its own implementing policy and priority list. Credentials approved by one agency may be denied by another based solely on policy differences.
Section I The 5 U.S.C. 5757 framework
The statute reads, in relevant part: "An agency may use appropriated funds or funds otherwise available to the agency to pay for (1) expenses for employees to obtain professional credentials, including expenses for professional accreditation, State-imposed and professional licenses, and professional certification; and (2) examinations to obtain such credentials."
Three elements of the statutory text matter:
- "May" — the authority is discretionary. Congress authorized; it did not mandate. Each agency decides whether and to what extent to exercise the authority.
- "Professional credentials" — a specific term with a defined meaning. The GAO has interpreted this narrowly (see Section II below). Not every employee-development expense qualifies.
- Subsection (b) exclusion — "The authority under subsection (a) may not be exercised on behalf of any employee occupying or seeking to qualify for appointment to any position that is excepted from the competitive service because of the confidential, policy-determining, policy-making, or policy-advocating character of the position." Schedule C employees and certain political appointees are excluded.
The reimbursement mechanics
5757 does not set its own procedures — the authority is exercised through each agency's internal training and credential policies. Reimbursement typically flows through the same SF 182 training authorization process that governs other federal training, covered in Training Rights & the Government Employees Training Act. Common mechanics:
- Pre-approval required — you submit a request before incurring the expense, not after
- SF 182 or agency equivalent — the training authorization form documents the credential, cost, and justification
- Agency policy controls — the decision follows the agency's credential list, thresholds, and supervisor approval requirements
- Continued Service Agreement may apply — for higher-cost credentials or those requiring significant training; see CSA mechanics in Topic 01
- Direct pay or reimbursement — agencies may pay the credentialing body directly, or reimburse the employee after the expense is paid
Section II Scope limits — GAO B-302548 and what counts
The defining GAO decision on 5757 scope is B-302548, issued in response to a question from the Department of Agriculture's Risk Management Agency about whether it could use 5757 to pay for California CPA Society (CalCPA) memberships for its accountants. GAO said no, and the reasoning in that decision is the controlling interpretation of 5757 scope.
The core rule from B-302548
GAO held that 5757 authorizes agencies to pay only for expenses required to obtain or maintain the license or official certification needed to practice a particular profession. The analysis turns on one question: is the expense required to hold the license? If yes, 5757 covers it. If no, 5757 does not.
| Expense Category | Covered by 5757? | Why |
|---|---|---|
| Licensing fees (state bar dues, PE license fees, etc.) | Yes | Required to obtain or maintain the license |
| Certification exam fees (PMP exam, CPA exam, CISSP exam) | Yes | Required to obtain the credential |
| Required continuing education to maintain a credential | Yes | Maintenance of the credential requires it |
| State bar membership where required for attorney licensure | Yes | GAO specifically distinguished this as required for license maintenance |
| Bar review courses | No | Personal preparation, not a credential requirement |
| Voluntary association memberships (ABA, AICPA, CalCPA, federal-only professional societies) | No | Not a condition of holding the license |
| Certified Government Manager designation (1995 GAO B-260771) | No | Pre-2001 decision; 5757 itself passed later, but the "voluntary professional title" reasoning still influences interpretation |
| Professional journal subscriptions | Usually no | Not required for the credential itself |
| Conference attendance (as a credential requirement, e.g., mandatory CPE) | Sometimes | Only if the conference provides required CE credits for the credential; otherwise separate training authority applies |
The 5 U.S.C. 5946 parallel prohibition
There is a separate statute that reinforces the scope limit. 5 U.S.C. 5946 prohibits the use of appropriated funds to pay for voluntary memberships in societies or associations by employees already credentialed in their fields. 5757 is an exception to 5946, but only to the extent that 5757 itself reaches — which means only for required memberships conditioning the license or certification. An agency cannot route a voluntary AICPA or ABA membership through 5757 as an end-run around 5946.
The "not to qualify for appointment" limitation
5 U.S.C. 5757 cannot be used to qualify an applicant for a position. The statutory text is directly written into subsection (b), and most agency policies read it more broadly to also exclude credentials sought specifically to meet qualifications for a higher-grade position the employee does not currently hold. For example, an agency generally will not use 5757 to pay for a PMP for a GS-11 project coordinator seeking promotion to a GS-12 project manager position where PMP is a listed qualification. The credential has to fit the employee's current role, not create eligibility for a different role.
Section III How agencies implement 5757
Each agency establishes its own policy for credentialing. There is no government-wide credential list. A credential funded at DHS may not be funded at USDA based solely on policy differences. Typical elements of an agency credentialing policy:
- Approved credential list — specific credentials the agency pre-approves for reimbursement, often organized by occupational series or position type
- Eligibility criteria — who can seek credentialing (typically requires current federal employment, GS-level or equivalent thresholds, performance rating requirements)
- Annual cost caps — agencies may cap annual credential spending per employee
- Approval chain — supervisor, organizational head, HR review, budget approval
- Priority tiers — required credentials (FAC-C, DAWIA, specific licensure) funded first; recommended credentials funded next; voluntary credentials funded last if budget remains
- Recapture provisions — CSA requirements for more expensive credentials
To find your agency's policy, search for terms like "professional credentials" or "certification reimbursement" on your agency's HR SharePoint or intranet. Most agencies also have a training coordinator whose job includes knowing which credentials are on the approved list and which are not.
Some agencies have robust, published credential lists; others have no formal policy beyond supervisor approval. If your agency is in the latter category, the 5757 statute itself and GAO B-302548 are the controlling authorities. A request for a specific credential with a clear written justification tied to your position description and current duties has legal standing to be approved. Denial must typically be based on budget, priority, or fit — not on whether the statute authorizes the expense.
Section IV Mandatory certifications by occupation
Some federal credentials are not optional. The position description requires them, and the agency must fund them. The most significant mandatory credentials by occupational area:
Acquisition workforce — FAC-C (civilian) and DAWIA (defense)
Contracting officers (GS-1102 series) and contracting officer's representatives are subject to certification requirements under the Office of Federal Procurement Policy (OFPP) and the Defense Acquisition Workforce Improvement Act.
- FAC-C (Federal Acquisition Certification in Contracting) — required for civilian agency 1102 positions, with three levels (I, II, III) corresponding to experience and training hours. Maintained through 80 hours of continuous learning every two years.
- DAWIA — required for DoD 1102 positions, aligned to specific functional areas (contracting, engineering, program management, business, life cycle logistics, etc.) with required certifications at each level. Administered through Defense Acquisition University (DAU).
- FAC-COR (Federal Acquisition Certification for Contracting Officer's Representative) — required for CORs, with three levels based on contract complexity.
- FAC-P/PM (Federal Acquisition Certification for Program and Project Managers) — required for designated program and project manager positions.
For these credentials, the agency is obligated to fund the training and certification — they are a condition of holding the position, not discretionary professional development. DAU training for DoD employees is free at the point of delivery. FAC-C training is typically agency-funded through specific appropriations.
Financial management — CGFM and CDFM
The Certified Government Financial Manager (CGFM) is offered by AGA and recognized across civilian agencies. The Certified Defense Financial Manager (CDFM) is the DoD equivalent, offered by ASMC. Neither is universally mandatory, but many agencies require one or the other for senior budget, accounting, and financial management positions (0510, 0505, 0560 series). Both are reimbursable under 5757 when required by the position.
Law — state bar licensure
Attorneys in the 0905 General Attorney series are typically required to maintain active bar admission in at least one state. GAO B-302548 explicitly confirmed that required state bar membership is reimbursable under 5757 as a license requirement. Attorney CLE fees required to maintain bar admission are also reimbursable. Voluntary ABA, Federal Bar Association, or specialty section memberships are not reimbursable.
Medicine and health professions
Physicians in the 0602 series, nurses in 0610, pharmacists in 0660, and other licensed health professionals must maintain active licensure to practice. State licensing fees and required CME to maintain licensure are reimbursable. Board certifications (ABIM, ABFM, ABEM, etc.) are typically reimbursable when they are required for the position — for example, VA physician positions often require board certification, making it reimbursable under 5757. Voluntary specialty society memberships are not.
Section V Finance and audit credentials
Federal employees in financial and audit occupations have a well-developed credential ecosystem, with many credentials reimbursable when required or supported by agency policy.
| Credential | Issuing Body | Typical Federal Use |
|---|---|---|
| CPA (Certified Public Accountant) | State boards of accountancy | Auditors (0511), accountants (0510), some budget analysts. Required state licensure fees reimbursable. |
| CGFM | AGA | Government financial managers across civilian agencies |
| CDFM | ASMC | DoD financial managers — budget, accounting, finance |
| CIA (Certified Internal Auditor) | IIA | Internal audit positions, particularly IG offices |
| CISA (Certified Information Systems Auditor) | ISACA | IT audit positions; see IT & Cybersecurity Certifications |
| CFA (Chartered Financial Analyst) | CFA Institute | Less common in federal; found in SEC, Treasury, Federal Reserve |
| CFE (Certified Fraud Examiner) | ACFE | Fraud investigators, IG staff, financial crimes units |
| EA (Enrolled Agent) | IRS | IRS examiners and tax specialists; can be required for the position |
| CGAP (Certified Government Auditing Professional) | IIA | Government audit specialists, particularly state-federal audit |
Section VI HR and project management credentials
HR credentials
Federal HR specialists (0201 series) and generalists typically pursue one of three credential paths:
- SHRM-CP / SHRM-SCP (Society for Human Resource Management Certified Professional / Senior Certified Professional) — the most common HR credential in the federal space, recognized across civilian and defense agencies
- IPMA-HR (International Public Management Association for Human Resources) — public sector HR focus, often preferred for federal HR positions with policy and labor relations content
- HRCI credentials (PHR, SPHR, GPHR) — widely recognized; some agencies prefer SHRM over HRCI but both are typically reimbursable
These credentials are generally reimbursable under 5757 when the agency's HR policy identifies them as supported. Most larger agencies maintain SHRM site licenses or bulk testing vouchers, making this one of the more accessible credential paths in federal service.
Project management credentials
Federal project and program managers commonly pursue PMI-family credentials:
- PMP (Project Management Professional) — the most widely sought federal project management credential; held by GS-13 and above project managers across IT, acquisition, construction, and program offices
- PgMP (Program Management Professional) — senior program management; fewer holders, typically GS-14+ and above
- PMI-ACP (Agile Certified Practitioner) — Agile/Scrum focus; growing in popularity in federal IT modernization and digital services
- CAPM (Certified Associate in Project Management) — entry-level PMI credential; occasionally funded for GS-11/12 project coordinators
PMP, in particular, is strongly supported by agency policies because PMI credentials align with the FAC-P/PM competency framework. Most agencies that fund FAC-P/PM also fund PMP because the overlap is significant. Maintenance requires 60 Professional Development Units (PDUs) every three years; agencies typically fund the renewal fees but expect employees to earn PDUs through work-related training and activities.
Section VII Engineering, law, and medicine
Engineering — PE license
The Professional Engineer (PE) license is issued by state engineering licensing boards. Federal engineering positions (0801 general engineering, 0810 civil engineering, 0850 electrical engineering, others) do not universally require PE licensure, but specific positions do — particularly those where the engineer signs and seals designs, operates as an engineer of record, or supervises licensed engineers. Where the PE is required by the position, exam fees, licensing fees, and required CE are reimbursable under 5757. Voluntary PE licensure pursued for career development is typically not reimbursable.
Related engineering credentials that may be reimbursable when required:
- LEED AP (Leadership in Energy and Environmental Design Accredited Professional) — for sustainability-related engineering roles
- Certified Quality Engineer (CQE) — ASQ credential for quality engineering positions
- ASME, IEEE, and society-issued specialty certifications — handled on a case-by-case basis; required certifications reimbursable, voluntary ones not
Law — state bar and specialty credentials
For attorneys, state bar membership is the fundamental reimbursable credential. Specialty credentials vary by practice area:
- Mandatory CLE — required by most states for continued bar admission; reimbursable
- Specialty board certifications (e.g., Board Certified in Immigration and Nationality Law, Board Certified in Civil Trial Advocacy) — reimbursable only when required for the position, which is rare in federal service
- Graduate law degrees (LLM) — handled under academic degree training (5 U.S.C. 4107), not 5757; see academic degree training mechanics
Medicine and health professions
Active state medical, nursing, pharmacy, and related licenses are reimbursable when required by the position. Board certifications (internal medicine, family medicine, emergency medicine, pediatrics, etc.) are reimbursable when the position requires them — VA, Indian Health Service, and military treatment facility positions often do. Required CME is reimbursable; conference attendance specifically to earn CME credits is typically reimbursable under training authority. DEA registration fees for prescribing authority are typically reimbursable as a credential required for the position.
Section VIII Getting a certification approved
Credential approval is fundamentally a matching exercise — matching the credential to the position, to agency policy, and to available budget. Employees who consistently get credentials approved do four things well:
What works
- Put it on your IDP first. An Individual Development Plan with the specific credential identified makes the request a follow-through on an agreed plan rather than a new ask. Supervisors find it easier to approve an expense that was already jointly discussed and signed.
- Tie it to position requirements, not personal interest. The statutory framework supports credentials that are required or directly relevant to your current role. A justification that explains how the credential is required, expected, or enables you to perform specific duties is stronger than one that emphasizes career advancement.
- Cite your agency's credential policy. If your agency has a published approved credential list, reference the specific credential on the list. If the credential is not on the list but should be, prepare a short justification that includes the statutory basis (5 U.S.C. 5757), the GAO scope analysis, and the direct connection to your position description.
- Plan around the budget cycle. Most agencies allocate training budget at the start of the fiscal year. Credentials with multiple cost components (exam prep course, exam fee, credential fee, CE) are easier to fund when budget is fresh. A request in Q1-Q2 is more likely to be approved than one in Q4.
Two additional practical points. First, some credentials require prerequisite work experience that you must already have — CISSP requires 5 years, PgMP requires 7,500 hours of program management experience, PE requires passing the FE plus 4 years of qualifying experience. Before seeking funding, confirm you meet eligibility. Second, some credentials have maintenance fee structures that recur over decades — CPA annual license fees, PE CE costs every 1-2 years, PMP PDUs every 3 years. Agency policy may fund the initial credential but defer maintenance to the employee, or vice versa. Read your agency's policy carefully on the maintenance side.
A denial of credential funding is generally not an appealable personnel action — these are budget and priority decisions within agency discretion. However, a denial motivated by discrimination, retaliation for a protected disclosure, or another prohibited personnel practice is actionable. If the denial appears to be based on something other than legitimate agency policy considerations, see Prohibited Personnel Practices & the OSC for the complaint pathway. Also note that 5 U.S.C. 2302(a)(2)(A)(ix) explicitly covers "a decision concerning pay, benefits, or awards, or concerning education or training" in the definition of a personnel action — so a discriminatorily motivated credential denial is a prohibited personnel practice.
Section IX Frequently asked questions
No. 5 U.S.C. 5757 grants agencies discretionary authority to pay for professional credentials — it does not create an employee entitlement. The statute uses "may" rather than "shall." Agencies implement the authority through internal policies that typically specify which credentials are supported, eligibility criteria, and approval procedures.
Whether your specific certification will be paid depends on your agency's policy, your position description, your supervisor's approval, and budget availability. A denial is not appealable unless discrimination or a prohibited personnel practice is involved.
Under 5 U.S.C. 5757 and GAO Decision B-302548, agencies may pay for expenses required to obtain and maintain a professional license or certification. This includes examination fees, licensing fees, and required continuing education to maintain the credential.
Agencies may also pay for required professional association memberships when the membership is a prerequisite to holding the license — such as mandatory state bar membership for attorneys. Agencies generally cannot pay for voluntary professional association memberships (ABA, AICPA, SHRM national dues when not required for licensure), bar review courses, or membership in organizations of already-credentialed professionals.
No. The statute explicitly cannot be used to qualify an applicant for a position. Under 5 U.S.C. 5757(b), the authority cannot be exercised on behalf of any employee occupying or seeking to qualify for appointment to a position that is excepted from the competitive service because of the confidential, policy-determining, policy-making, or policy-advocating character of the position.
More broadly, 5757 is designed to maintain and support credentials within your current role and career path, not to pay for credentials that would make you eligible for a higher-grade position you do not currently qualify for. Some agencies interpret this narrowly; others more broadly.
Often yes, depending on the cost and duration of the credential program. Under 5 U.S.C. 4108 and 5 CFR 410.309, agencies have authority to require Continued Service Agreements for training-related expenses above a defined threshold. Most agencies set the CSA threshold based on cost (often $5,000 or higher) or total training hours (often 80 hours or more).
A single certification exam rarely triggers a CSA; a multi-week training program plus exam often does. The service obligation is at least three times the length of the training. The CSA must be signed before the training begins.
The answer varies dramatically by occupational series. For IT and cybersecurity workforces: CompTIA Security+, CISSP, CISM, AWS/Azure/GCP cloud certifications, and DoD 8140 aligned credentials. For acquisition workforces: FAC-C for civilian agencies and DAWIA for DoD (both agency-funded, required for acquisition positions). For project management: PMP, PgMP, Agile Certified Practitioner.
For financial and audit occupations: CPA, CFA, CIA, CGFM. For human resources: SHRM-CP, SHRM-SCP, IPMA-HR. For engineering: PE license (where required), specific engineering board certifications. For attorneys: state bar membership (required for licensure, reimbursable). For contracting officer's representatives: FAC-COR. Certain credentials (FAC-C, DAWIA) are mandatory for the position; others are voluntary but career-enhancing.