CSAC Bulletin Article

CSAC Submits Comments on CalPERS’ Regulations Seeking to Define Retired Annuitant Limitations

January 5, 2023

As reported previously, the California Public Employees Retirement System (CalPERS) proposed a rulemaking action on June 17, 2022, seeking to define “limited duration” employment and provide clarity and uniformity for CalPERS-covered employers. The proposed rulemaking action limits an appointment of a retired annuitant to an initial period of two years, which could be extended by an additional year up to two times, for a total of four years, if certain requirements are met. For current retired annuitants, the two years would be counted from when the regulations go into effect.

On December 1, 2022, CalPERS submitted revisions to the initial text, which included wording changes, renumbering, and restructuring. As part of the process mandated under the Administrative Procedure Act, these changes had to be published for 15 days in order to give the public and stakeholders an opportunity to comment on the respective changes. CSAC submitted written comments within the 15-day public comment period, that ended on December 16, requesting CalPERS seek less administratively burdensome options to reduce the reporting requirements, clarify the extension period timelines, improve the definition of limited duration employment, and revise the certification process.

Under the rulemaking process, public agencies are required to summarize and respond to any public comments received as part of the final rulemaking package. It is expected that CSAC’s comments will be presented to CalPERS’ Board of Administration for consideration prior to being forwarded to the Office of Administrative Law as part of the final rulemaking action.

From CalPERS:

Notice of Modifications to Text (PDF)

Revised Text of Proposed Regulation (PDF)

Addendum to the Initial Statement of Reasons (PDF)

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