Working After You Retire

This section explains how you can lose benefits or earn additional benefits if you go back to work after retirement. You should review this information even before you retire.

Important Topics

Reemployment Reporting Requirements
Reemployment Checklist
Suspension of Benefits Rules
Suspendible Employment
Applicable Hours Limits
Suspension of Benefit Payments
Re-Starting Your Suspended Benefits
Annual Retiree Certification
Increasing Your Benefit After Retirement

How Returning to Work Affects Your Benefits

This section explains how you can lose benefits if you go back to work in covered or non-covered suspendible employment after retirement. If you are considering a return to work after retirement—in covered or non-covered employment—you need to know about your Plan’s suspension of benefits rules before you accept a job. These rules are explained starting on this page.

The Plan also has rules that allow you to increase your retirement benefits if you return to work in covered employment after retirement and work a certain number of hours. Click here for the rules about Increasing Your Benefit After Retirement.

Important Reminder: The suspension of benefits rules are distinct from the retirement from employment rules for early (pre-age 65) retirees. Under those rules explained under Applying for Retirement Benefits, you must intend to retire permanently from employment with your most recent covered employer (which includes an affiliated company). If after your early retirement you return to work within six months for your last covered employer (or even longer if you intended to return when you retired), you may forfeit your right to receive retirement benefits (and must repay benefits that you already received) until you stop working again.

If you are considering going back to work for your last covered employer, you should review the retirement from employment rules. Even if the job being offered is different from your previous job, the fact that you are returning to work for the same employer may result in your retirement being canceled. Contact your Administrative Office if you have additional questions.

Reemployment Reporting Requirements

If you decide to go back to any kind of work (covered or non-covered) after you retire and you are under age 65, Plan rules require that you notify your Administrative Office before you start your job. You must do so even if you think your work is not suspendible employment. That way you can find out beforehand if your work may cause you to lose any benefits. The financial consequences of failing to follow this reporting requirement could be severe. Once you are age 65 or older, there are no reporting requirements.

If the Pension Trust finds out that you are working before age 65, and you have not already reported it, your benefit payments may be suspended while your Administrative Office gathers more information to determine whether your work is suspendible employment.

Contact your Administrative Office as soon as possible if you are considering returning to work. Do not wait until after you have already begun working. Your Administrative Office will provide you with a Request for Evaluation of Reemployment form to complete. You can also download the form here.

On the Request for Evaluation of Reemployment form, you must provide enough information about your work, including the location and the number of hours you expect to work. If you do not know your work schedule, provide your best estimate of the hours you will work. This information helps the Plan determine whether your work is suspendible employment and whether your hours each month exceed your hours limit.

If your employment is performed through a temporary or staffing agency that dispatches you to work with more than one employer, you must provide the required information for each employer.

If you are considering more than one job, you must complete a separate Request for Evaluation of Reemployment form for each.

Determinations cannot be made on hypothetical jobs. The Pension Trust will only make a determination on actual jobs you are considering for a specific employer. If you have a job description from your employer, include it with your request form.

Important: The Annual Retiree Certification sent to retirees under age 65 is not a substitute for the Request for Evaluation of Reemployment form. You are required to complete a Request for Evaluation of Reemployment form if you are considering returning to work.

The Reemployment Checklist above, helps you through the steps you should follow to obtain an official determination of whether your proposed reemployment will result in a suspension of your retirement benefits.

You should allow your Administrative Office approximately 30 days to review your request and send you a determination. If the reemployment you have asked your Administrative Office to review is determined to be suspendible employment, your Administrative Office will provide you with information about the Plan’s suspension of benefits rules and how you can appeal the determination if you wish.

Suspension of Benefits Rules

Under the Plan’s suspension of benefits rules, you forfeit the right to receive some or all of your age retirement benefit for any month in a calendar year if:

• You work in suspendible employment during that month, and
• The hours you work exceed your hours limit for that month; and
• You already exceeded your hours limit in three calendar months in that calendar year.

The chart below gives a brief explanation of suspendible employment. A more detailed explanation follows.

The suspension of benefits rules require that you notify your Administrative Office in writing whenever you return to work in any type of employment. Also, each year you must complete an Annual Retiree Certification form. These reporting requirements are explained below.

The Plan’s suspension of benefits rules apply to you through the end of the month in which you turn age 65. After that, you can work as much as you want in any kind of job, without worrying about forfeiting your monthly benefit under these rules.

If you are thinking about returning to work in any job, ask your Administrative Office in advance to give you a written evaluation that tells whether that job qualifies as suspendible employment. That's the only way you will know whether you will lose retirement benefits if you work in that job at or above the applicable hours limits.

Note: Only the Administrative Office can make a determination as to whether your work qualifies as suspendible employment.

Note: If you retire on a disability retirement benefit and return to work, the Plan’s suspension of benefits rules do not apply to you. But you may lose your entitlement to Social Security disability benefits by working and, as a result, lose your right to receive disability retirement benefits from the Plan. If your disability retirement benefit is converted to or you apply for an early retirement benefit, then your benefit would be subject to the suspension of benefits rules.

Suspendible Employment

The Plan applies three separate tests to determine whether your post-retirement work is subject to the Plan’s suspension of benefits rules. They are:

• The trade or craft test.
• The industry test.
• The geographic area test.

For your reemployment to qualify as suspendible employment, the Plan must determine that your employment meets all three of these tests. In other words, if the Plan determines that your employment fails to meet any one of the three tests, that specific work will not qualify as suspendible employment.

The industry test is different depending on whether your work is in covered or non-covered employment. The chart above explains the difference between suspendible covered employment and suspendible non-covered employment.

The charts below explain the three tests in more detail. They are intended to serve only as an informational guide.

If you are considering returning to work after retirement (or are already working as a retiree), you should not attempt to apply these tests on your own or rely on anything other than a written determination from your Administrative Office.

If you make a mistake in interpreting or applying any of these tests, you can suffer serious financial consequences as a result. Instead, any time you are considering reemployment, always ask your Administrative Office for a written determination regarding your proposed work. That is the only way you can find out if your work will be suspendible employment.

Applicable Hours Limits

Subject to the Plan’s three-month rule, under your Plan’s suspension of benefits rules, you lose the right to receive your retirement benefit payment for any calendar month if the hours of suspendible employment you work (or are paid for) exceed your applicable hours limit for that month. The hours limit that applies depends on your age at the beginning of the month. The chart below shows the rules for determining your hours limit and describes the three-month rule (which is discussed further in the next section).

Your Plan counts hours that you worked as well as all hours for which you are compensated (such as vacation, jury duty, sick leave or other compensable hours). Compensated hours also include hours for which pension contributions are made on your behalf in excess of your paid hours under the terms of an acceptable pension agreement.

If you are paid on a basis other than hours worked, such as mileage, your hours of suspendible employment are determined using the same formula that determines the number of hours for which your employer is required to make contributions to the Pension Trust. Contact your Administrative Office if you have questions regarding how the mileage rules apply.

A special rule applies if the Plan cannot determine how many hours of suspendible employment you actually worked in a month. Under that rule, the Plan considers that you worked in suspendible employment in excess of your hours limit for that month if:

• You receive pay for eight or more days (or separate work shifts) in that month, or
• You receive pay for eight or more days (or separate work shifts) in any four-week or five-week payroll period ending within that month.

Suspension of Benefit Payments

If your work after retirement qualifies as suspendible employment, your retirement benefits are subject to either full or partial suspension in the fourth and any subsequent calendar month in each calendar year in which you work above the applicable hours limits. This means that, each calendar year, you may work more than the permissible number of hours in three calendar months before your benefits will be subject to suspension. During the remainder of that year, for each month you work above the hours limit, you lose (forfeit) the right to receive all or the portion of your monthly benefit that is subject to suspension. Click here for examples on how this three-month rule works.

Once the Pension Trust determines that you are working in suspendible employment above your hours limit for a fourth or subsequent month in a calendar year, your benefit payments will be suspended.

If you receive benefit payments for any months when your retirement benefits were subject to suspension, you must repay these amounts to the Pension Trust. If you do not repay by check, the Plan will deduct what you owe from future benefit payments.

Your benefits will continue to be subject to suspension until you provide satisfactory evidence that you worked less than your applicable hours limit each month or that your work is not suspendible employment.

Full or Partial Suspension

The percentage of your current retirement benefit that is subject to suspension depends on whether your work is in covered or non-covered employment.

Full Suspension. If your work is in covered suspendible employment, 100% of your monthly retirement benefit is subject to suspension.

Partial Suspension. If your work is in non-covered suspendible employment, only the portion of your retirement benefit that you earn after 1994 is subject to suspension. The portion earned before 1995 is protected from suspension and is called your protected percentage. If all your retirement benefit is earned after 1994, your protected percentage will be zero and 100% of your benefit will be subject to suspension.

Restarting Your Suspended Benefits

If your retirement benefits are suspended because you return to employment, your benefits will continue to be subject to suspension until you complete and file a Benefit Resumption Notice with your Administrative Office.

This notice must be filed once you stop working in suspendible employment, reach age 65 or your hours of suspendible employment fall below your applicable hours limit. You can request this notice from your Administrative Office.

If you still owe any amounts when your benefits restart, they will be deducted from your first reinstated monthly benefit payment. If your first benefit payment is not enough to recover what you owe the Pension Trust, 25% of your future benefit payments will be withheld until the entire amount is repaid.

Special Rule

Additional Protection

A special suspension of benefits rule may apply if you return to work in non-covered employment and in an industry different from any industry you worked in before retirement. Under this rule, if the unit you are working in later becomes covered by the Plan, your retirement benefits will not be suspended when your work for that employer changes from non-covered to covered employment.

This special rule no longer applies if you go to work for another employer. Your Administrative Office can give you more information about this special rule and whether it applies to you.

Annual Retiree Certification

Each year the Plan sends an Annual Retiree Certification form to all age retirees under age 65. On this form, you must list all work performed in the previous calendar year (this includes both covered and non-covered employment). You may also be asked to authorize the Pension Trust to obtain verification of your earnings for the year from Social Security.

Plan rules require that you complete and return the Annual Retiree Certification form within 30 days. (The annual certification requirement is waived for calendar years after your 65th birthday.)

If you are under age 65 and do not return the completed Annual Retiree Certification form to your Administrative Office by the deadline, your monthly benefits are subject to suspension until you provide the required documentation.

Benefits are also suspended if your completed Annual Retiree Certification form shows that you worked in the previous calendar year but does not provide enough information for the Plan to determine if your work is suspendible employment or if your hours exceeded the applicable hours limit in any month.

As long as you are under age 65, your benefits will continue to be suspended until you provide satisfactory evidence that you either worked less than your hours limit per month or that your work is not suspendible employment.

If you have properly followed the Plan’s rules for notification of any reemployment, the Annual Retiree Certification form will likely serve to simply confirm the information you have already provided to the Plan.

Increasing Your Benefit After Retirement

If you return to covered employment after retirement, you may qualify for increased benefits. There are two ways you can increase the benefit you are receiving:

• Pension increase
• Total benefit recomputation

Reemployment Pension Increase

A pension increase is separate from your original retirement benefit and is payable in addition to your original amount. The increase is based only on the basic contributions paid on your behalf during your period of reemployment. In some cases, your increase may also include a noncontributory service benefit based on past employment or intermediate employment. Your Administrative Office can provide you with additional information if you think you may be eligible.

If you take normal or early retirement, there are two ways you qualify for a pension increase:

• You complete at least 750 covered hours after your original pension effective date, or
• You complete at least 750 covered hours after the date your last pension increase takes effect.

If you take disability retirement, the Plan only looks at your covered hours after age 65 to see if you qualify for a pension increase.

The earliest date you can receive your pension increase is January 1 following the year when you qualify.

Applying for a Reemployment Pension Increase

If you are under age 65, you just turned 65, or this is your first pension increase after age 65, you must complete the following steps before you can receive your pension increase:

1. You must again retire from employment if you are under age 65, and
2. You must apply for benefits with your Administrative Office

If you stop work, or are about to stop work in covered employment as a retiree, you should contact your Administrative Office as soon as possible to find out if you qualify for a pension increase. They will give you an application to complete on which you can choose your desired pension effective date.

Under the Plan’s retro payment rule, your reemployment pension increase effective date can be no more than 23 calendar months from the date your Administrative Office receives your application (24 calendar months if your application is received on the first day of the month). It is best to get your application on file as soon as you decide to stop working. For additional information, see Retro Payment Rule.

Eligibility to Elect Form of Pension Increase

You can choose a benefit payment option for your pension increase that is different than the option you chose for your original retirement benefit, as long as it is your first pension increase after you reached age 65 or the increase takes effect by January 1 of the year after you reach age 65. If you are married, your spouse is required to consent to your pension increase election (see Spouse Consent Requirements).

Once your Administrative Office verifies your eligibility for the increase, you are sent an information packet containing your personalized Benefit Election Form that explains the payment options available for your pension increase. The amounts shown are based only on the basic contributions paid for your covered hours during your period of reemployment. They are paid in addition to your original benefit. For details about making your pension choices, see Your Benefit Payment Choices.

Your Plan’s suspension of benefits rules also apply to your pension increase. If you are under age 65 and go back to suspendible employment after your pension increase starts, both your original benefit and your pension increase are subject to the Plan’s benefit suspension rules described earlier in this section.

Automatic Pension Increases

If you have previously qualified for a pension increase after the year in which you turn age 65, you do not need to apply for any later pension increases for which you may qualify. Your pension increase starts automatically. Once the amount of your automatic pension increase is calculated, payment begins retroactive to the beginning of the calendar year after the year in which you qualify. If you have questions about the status of your reemployment pension increase, the Administrative Office recommends that you contact them in June, following the year in which you meet the eligibility requirements.

Total Benefit Recomputation

With a total benefit recomputation, your original retirement benefit is canceled and replaced with a completely new benefit. Your new benefit is based on your covered hours and basic contributions earned before your original retirement plus the covered hours and basic contributions you earn after your original retirement. Your new recomputed benefit is based on your age on your new pension effective date and is adjusted to reflect the value of all benefit payments you already received.

There are two ways you qualify for a total benefit recomputation:

• You complete 1,500 covered hours within a 12-month period and do so within 36 months of your original pension effective date and before age 70, or
• You complete 6,000 covered hours over a 60-month period after your pension effective date and do so before age 70.

An age retiree can elect a total benefit recomputation only once. If you take disability retirement, you cannot qualify for a total benefit recomputation (unless your disability retirement is converted to an age retirement).

Applying for a Total Benefit Recomputation

Before you can receive your total benefit recomputation you must complete the following steps:

1. You must again retire from employment if you are under age 65, and
2. You must apply for benefits with your Admininstrative Office

If you apply for a total benefit recomputation, your application is processed using the rules and procedures explained in the Applying for Retirement Benefits section.

If you are under age 65, your Plan’s suspension of benefits rules also apply to your new recomputed benefit. The rules apply beginning with your new pension effective date.

Click here for questions and answers about Working After You Retire.