COVID-19 Closure Q & A
During these unprecedented times of school closures across the state, each of you are facing new challenges daily. Some of those challenges are currently or in the future will be in the area of retirement reporting. Please know that employer services analysts are available to assist you.
We have created a COVID-19 Closure Q&A for your reference. Our hope is that this will answer some of the more common questions you may have.
| Hours | Salary | |
|---|---|---|
| Active Members - Working | Nothing to Report | Actual Salary |
| Active Members - Not Working | Nothing to Report | Actual Salary if being paid |
| Retirees/Non-Members - Working | Actual Hours Worked | Actual Salary Earned |
| Retirees/Non-Members - Not Working | 0.01 | Actual Salary Earned if being paid |
- Q: Because of COVID-19 and social distancing requirements, my school district is considering holding graduation services (or other similar traditional school events) in July. This is the month that July 1st retirees must remain separated from covered service. If graduation services (or other similar traditional school events) are held in July, may retiring employees participate in these graduation services/events?
- A: PSRS/PEERS believes that these retiring employees may participate in these graduation services (or other similar traditional school events) and still satisfy the bona fide separation of service requirement as long as:
- they are not required to participate, and
- they receive no compensation for participating.
- cash
- gift cards
- gift certificates
- any other cash equivalent item
- anything of value not offered to all other attendees of the graduation
A plaque or other similar item presented to a retiring employee is not considered compensation, if its receipt is not dependent upon his or her participation in the ceremony.
All the normal rules of termination of employment still apply. Returning to covered employment or agreeing to post-retirement employment (whether such agreement is in writing or is verbal) within one month of the retirement date means employment has not been properly terminated. Additionally, accepting a retirement incentive that includes post-retirement work in exchange for compensation (including health insurance benefits) means that employment has not been properly terminated.
If you have any questions or concerns about July school district events or your employee's participation in them, please contact PSRS/PEERS.
- Q: Because of COVID-19 and the current school closures, my school district plans to hold summer school in the month of July. This is the month that July 1st retirees must remain separated from covered service. If summer school is held in July, can PSRS/PEERS waive this prohibition and allow retiring employees to teach or otherwise work during summer school?
- A: No. Proper termination of service is an IRS requirement that PSRS/PEERS cannot waive. A retiree may not be employed by a covered school district within one month of the date of his or her retirement. July 1 retirees may not be employed to work summer school during this month. If a July retiree does so, he or she will not have properly terminated employment and will lose at least one month's worth of retirement benefits.
- Q: Will annual bases need to be adjusted on employees that didn't get paid during the closure?
- A: No. You should not correct an annual base salary for members that did not get paid during the closure. In this situation, the member will not earn a full year of service.
- Q: Will we add extended contract pay to annual base salaries?
- A: The annual base salary should include extended contracts but should not include extra duties.
- Q: Is FFCRA leave retirement eligible?
- A: Emergency leave or expanded FMLA leave paid by a covered employer in accordance to the FFCRA is retirement eligible.
- Q: Can employees purchase service if they choose to go on "leave without pay" during this time?
- A: The employee will not be able to remit contributions on their missed salary through an Unpaid Sick Leave Remittance, but they could possibly qualify for one of the Systems' other purchase types offered through Member Services. The employee should call our Information Center to discuss their options.
- Q: Can I still report monthly payrolls and pay contributions to PSRS/PEERS?
- A: Yes. OASIS is functional. You can report as you normally would even if working remotely. PSRS/PEERS Employer Service Analysts are available to assist from 7:30 am - 5 pm.
- Q: If a retiree is getting paid, but is not physically working, do their salary and hourly limitations still apply?
- A: Because they are getting paid, their salary limit still applies. Since they are not working, no hours would be applied towards their limit. You should report .01 in the hours box to have a valid file.
- Q: If a retiree is working remotely, do the hours still count?
- A: Yes. Their hours and salary (PSRS) continue to count towards their working after retirement limitation.
- Q: If a retiree is working under Critical Shortage Employment; is still receiving pay, but not physically working, will the time away from work still count towards their 24-month limit?
- A: Yes. The time away from work will still count toward their limit because they are still getting paid, therefore still considered employed.
- Q: If our district decides to extend school into July, will we report hours and salary in the 2019-2020 school year or the 2020-2021 school year?
- A: Hours and salary should be reported in the school year they were earned. Hours worked and salary earned in July 2020, would need to be reported in the 2020-2021 school year.
- Q: Is there a waiver on the 550-hour limit for retirees working after retirement?
- A: No there is not a waiver on the 550 hours limit. If a retiree exceeds their limit, they will lose their benefit for the month the limit is exceeded, and future benefits will be put on hold until the termination of their employment.
- Q: If we are not paying employees while school is closed, will they still earn a year of service?
- A: Currently the answer is no. If employers are putting staff on unpaid leave, they will likely not get a full year of service. PSRS/PEERS will continue to monitor the situation and evaluate the impact closures will have on service.
- Q: If non-members receive a stipend while school is closed, but aren't physically working, do we still report hours?
- A: No. You will not report hours since the non-member isn't physically working. You will report .01 in the hours box to have a valid file.
- Q: Will members still earn a full year of service if school does not re-open?
- A: If members are being paid therefore "employed" while school is closed, they will continue to earn service. Members not being paid while school is closed will not continue to be eligible for service.
- Q: If the member is working remotely, will they continue to earn a full year of service?
- A: Yes, assuming there are no other gaps in employment such as late start, maternity/paternity leave, etc.). that would impact service.
- Q: If the district extends the school year into July, will there be an impact on July 1 retirements?
- A: Regardless of the extended school year, the member will need to meet retirement eligibility requirements. The member would also need to follow all termination guidelines and end all employment by June 30. If the member needs the full year of service to be eligible for a July 1 retirement, the extended school year may have an impact. The member should contact PSRS/PEERS.
- Q: Do unemployment checks count toward working after retirement salary limitations?
- A: Unemployment pay should not be submitted to PSRS/PEERS and it does not count toward working after retirement salary limitations.