NPERS workshops clarify 'substitute' vs 'regular' service, 20‑hour formula and 180‑day separation limits

NPERS auditors spent the bulk of the workshop on membership classification and post‑separation rules, telling reporting agents that statutory definitions determine whether service counts for pension eligibility.

Vanessa Holand, internal auditing manager, framed the rule as three exclusive buckets: "temporary," "substitute," and "regular." She said all substitutes are temporary employees hired to fill in for a regular employee who is temporarily absent, and that common on‑call or vacant-position work may not meet the substitute definition. "You have to know, are your members taking a distribution?" she said, urging employers to document assignments to support classification.

NPERS reiterated the 20‑hour averaging formula used to evaluate monthly qualifying months: add hours for the month, divide by days in the month, multiply by seven to get a weekly average. Three qualifying months in the retirement fiscal year (July–June) trigger mandatory enrollment the next payroll period.

The agency also emphasized rules for employees who terminate and take a distribution: retirees who take a distribution are subject to a 180‑day separation period and may perform only up to eight days of substitute or voluntary service across all school employers in a calendar month during that 180‑day window. Vanessa noted a statutory timing change effective March 19, 2024; for terminations after that date the 180‑day clock begins at the later of the termination date or NPERS' receipt of a valid distribution application.

NPERS provided an eligibility checklist, an Excel eligibility calculator tool, and an extra‑duty reporting template to help districts track hours and decide whether to enroll workers.