United States 

Office of 

Personnel Management 

The Federal Government’s Human Resources Agency

Benefits Administration Letter 

Number: 05-103 Date: March 17, 2005 

Subject: Retirement Coverage Error Correction: Correction of Errors that Provide an 

Election

Introduction 

This Benefits Administration Letter (BAL) provides instructions for correcting retirement coverage 

errors when the individual has an election. It applies to correction of errors that have not been 

corrected and provides instructions to agencies for the actions they must take after an election is 

made under the Federal Erroneous Retirement Coverage Corrections Act (FERCCA). 

Categories of errors that agencies should currently be correcting 

Agency Personnel/Human Resource offices should correct the following types of retirement 

coverage errors: 

• Administrative corrections. Administrative corrections are corrections of errors that lasted 

less than 6 months (e.g., tentative placement in FERS until a coverage determination can be 

made) and corrections of errors where there is no error in the coverage determination but the 

person must be moved from one type of coverage to another. An example of the latter type is 

to and from law enforcement officer/firefighter coverage within a retirement system 

(correcting retirement code 1 to 6, or 6 to 1). 

• Erroneous FERS coverage that lasted for less than 3 years of service. BAL 02-103 provided 

detailed instructions for making these corrections. 

• Errors that do not provide an election. BAL 03-104 provided detailed instructions for making 

these corrections. 

• Required agency actions for retirement coverage error corrections. BAL 04-107 reviews the 

types of actions that agencies should now be taking on all retirement coverage errors and the 

time limits for processing error corrections. 

• Corrections for individuals who are currently in the wrong retirement system and who have 

been provided with an election opportunity. This BAL provides the detailed instructions for 

making these corrections. 

Civil Service 

Retirement 

System 

Federal Employees’ 

Group Life 

Insurance Program 

Federal Employees 

Health Benefits 

Program 

Federal Employees 

Retirement 

System 

Long Term 

Care Insurance 

Program 
Using this BAL 

The procedures in this BAL apply to corrections for individuals that have not previously been 

corrected and have made a coverage election or the six month time limit for making an election has 

passed and they are being placed in the default retirement coverage. 

This BAL is organized by type of error and the coverage election. Each section contains all the steps 

needed for making a specific type of correction. For example, a person who was erroneously in 

FERS and should have been CSRS-Offset elected CSRS-Offset. That section of the BAL specifies 

the actions needed to correct the HR records, payroll records, retirement contributions, social 

security taxes, and the thrift savings plan contributions. Each section ends with a summary of the 

actions that need to be taken. 

Definitions of Acronyms Used in this BAL 

BAL means Benefits Administration Letter. 

CSRS means the Civil Service Retirement System. 

CSRS Offset means the Civil Service Retirement System Offset plan. 

FERCCA means the Federal Erroneous Retirement Coverage Corrections Act. 

FERS means the Federal Employees Retirement System. 

Social Security Only means coverage under Social Security without concurrent coverage under 

CSRS, CSRS Offset, or FERS. 

Retirement Fund means the Civil Service Retirement and Disability Fund. 

TSP means the Federal Retirement Thrift Savings Plan. 

EDR means Employee Data Record 

Errors that provide an election 

The Federal Erroneous Retirement Coverage Correction Act (FERCCA) legislation and OPM 

regulations give some individuals who had a retirement coverage error an election about which 

retirement system to be under. There are seven types of retirement coverage errors that have an 

election. The following chart summarizes the types of errors that trigger an election: 

2
Employee is In: But Belongs In: May Elect Between: Correction 

Instructions 

CSRS FERS CSRS Offset or FERS If elects CSRS Offset – 

See Section I 

If elects FERS – See 

Section II 

CSRS Offset FERS CSRS Offset or FERS If elects CSRS Offset – 

See Section III 

If elects FERS – See 

Section IV 

CSRS Social Security 

Only 

CSRS Offset or Social 

Security Only 

If elects CSRS Offset – 

See Section V 

If elects Social Security 

Only – See Section VI 

CSRS Offset Social Security 

Only 

CSRS Offset or Social 

Security Only 

If elects CSRS Offset – 

See Section VII 

If elects Social Security 

Only – See Section 

VIII 

FERS CSRS FERS or CSRS If elects FERS – See 

Section IX 

If elects CSRS – See 

Section X 

FERS CSRS Offset FERS or CSRS Offset If elects FERS – See 

Section XI 

If elects CSRS Offset – 

See Section XII 

FERS Social Security 

Only 

FERS or Social Security 

Only 

If elects FERS – See 

Section XIII 

If elects Social Security 

Only – See Section 

XIV 

DEFAULT ELECTIONS

If the employee fails to make an election within 6 months from the date of the notice to the 

employee, the default retirement coverage is shown in the table below. Notify the employee that 

the time limit has expired and that the default retirement coverage is effective on (give default 

retirement coverage and effective date). The employee needs to be notified that he/she can be 

granted a waiver of the time limit to make an election. In order for the agency to grant a waiver 

of the time limit, the employee must submit, in writing, a request for waiver. It is up to you, as 

the employer, to determine that the employee exercised due diligence, but could not make an 

election within the time limit because of circumstances beyond his/her control. If you do not 

grant the employee’s request for waiver, you must provide written notice of the decision to the 

employee and notify the employee of his/her rights to request that OPM reconsider the decision. 

 A copy of the waiver decision needs to be documented in the employee’s OPF. Attachment 6 is 

a 

3
sample letter for notifying the employee of the time limit waiver. Attachment 7 is a sample time 

limit waiver denial letter. 

Make the adjustments in accordance with the sections shown in the table. The Human Resource and 

Payroll Offices must document the employee’s records to show that the employee failed to make an 

election. 

Employee is In: But Belongs In: Default Election: Correction 

Instructions 

CSRS FERS CSRS Offset Section I 

CSRS Offset FERS CSRS Offset Section III 

CSRS Social Security 

Only 

CSRS Offset Section V 

CSRS Offset Social Security 

Only 

CSRS Offset Section VII 

FERS CSRS FERS Section IX 

FERS CSRS Offset FERS Section XI 

FERS Social Security 

Only 

FERS Section XIII 

SOCIAL SECURITY TAXES AND EARNINGS 

Employees who are subject to the Social Security Act must pay Old-Age, Survivors, and 

Disability Insurance (OASDI) taxes. OASDI taxes are sent to the Internal Revenue Service 

(IRS) while an employee’s report of earnings is sent to the Social Security Administration. In 

order for an employee to receive service credit for Social Security purposes his/her earnings 

must be reported directly to the Social Security Administration by using forms W-2C and W-3C. 

 

Below is an explanation of barred and non-barred years that affect OASDI taxes that are paid to 

the IRS. There are no barred years for Social Security service credit purposes. That means that 

there is no statute of limitations on reporting Social Security earnings to the Social Security 

Administration. 

BARRED VS. NON-BARRED YEARS 

The Internal Revenue Service retroactive tax adjustment statute of limitations limits corrections 

of Social Security tax payments (OASDI) to three years after the filing deadline in which the 

wages were paid. These years in which adjustments can be made are known as the non-barred 

years. Years beyond this limit are known as the barred years. One of the major issues that 

complicated corrections of retirement coverage errors was the absence of a way to correct the 

retirement contributions that involved Social Security and extended into the barred years. 

FERCCA provides a method for making corrections during the barred years. Agencies transfer 

excess CSRS deductions to OPM for transfer to the General Fund of the Treasury for use by the 

Social Security Trust Fund. Employees receive full credit for the service under Social Security 

during the barred years. 

Below is a schedule for IRS Retroactive Tax Adjustments Statute of Limitations. 

4
For Tax Year With Tax Return Due Date 

of: 

Adjustments Can Be Made 

Until: 

2001 April 15, 2002 April 15, 2005 

2002 April 15, 2003 April 15, 2006 

2003 April 15, 2004 April 16, 2007 

2004 April 15, 2005 April 15, 2008 

For Errors Corrected Between: Corrections Can Be Made for Tax Years: 

April 16, 2004 – April 15, 2005 2001, 2002, 2003, 2004 

April 15, 2005 – April 15, 2006 2002, 2003, 2004, 2005 

When making corrections, the employee contributions (both Social Security and the Civil 

Service Retirement System (CSRS) or the Federal Employees Retirement System (FERS)) 

during the barred years and the non-barred years must be treated separately. Calculate the 

amount of agency and employee contributions previously made for the barred and non-barred 

years. The two “pots of money” (one for barred years and the other for non-barred years) must 

be dealt with independently and not commingled. Previous contributions that are available for 

correcting Social Security taxes and retirement contributions must be kept within the same 

category, i.e. barred year contributions and non-barred year contributions. 

5
I. ERRONEOUS CSRS COVERAGE, EMPLOYEE BELONGS IN FERS: 

ELECTION BETWEEN CSRS OFFSET AND FERS, 

EMPLOYEE ELECTS CSRS OFFSET 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from CSRS to CSRS 

Offset, retroactive to the effective date of the error. Attachment 1 is a chart of “Common Retirement 

Plans and Corresponding Codes” for your use in determining the correct codes to include on the 

personnel action. Include in remarks, “Erroneous CSRS, should have been FERS – Employee elected 

CSRS Offset on _______ (insert date of election), Correction due to Public Law 106-265 

(FERCCA)”. Refer to the Guide to Processing Personnel Actions at 

www.opm.gov/feddata/persdoc.htm for additional assistance in preparing personnel actions. Provide 

the employee with a copy of the SF 50 or equivalent showing the action taken. Working with your 

Payroll Office and using the example in Attachment 2 as a guide, explain to the employee the 

distribution of money from the Retirement Fund and Social Security. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the retirement deductions and Social Security. 

Non-Barred Years - Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

2. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. 

3. Calculate the Social Security’s Old-Age, Survivors, and Disability Insurance (OASDI) taxes 

due for the non-barred years. You can determine the taxes due for a given year up to 3 years 

after that year’s filing deadline. For example, if the coverage error occurred in year 2001, 

the filing deadline for tax year 2001 was April 15, 2002. You can determine the OASDI 

taxes due in calendar year 2001 up to April 15, 2005. This would constitute the Non-Barred 

Years. Use the balance of any remaining (excess) retirement deductions for the non-barred 

years to cover in whole or in part the employee’s cost of the OASDI taxes. If the individual 

owes additional taxes due to awards and bonuses, etc, above his or her base pay, this is 

treated as a salary overpayment subject to due process. Bill the employee for the additional 

OASDI taxes but suspend collection for 45 days while the employee submits a claim for 

reimbursement of out-of-pocket expenses to OPM. If OPM approves the claim for out-ofpocket expense, a waiver of the overpayment would be inappropriate. OPM will provide a 

copy of our out-of-pocket decision letter to the billing office. After 45 days, continue with 

the due process procedures. 

4. Submit both employer and employee social security taxes to the Internal Revenue Service 

(IRS), following current procedures. 

6
Barred Years - Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

2. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. 

3. Calculate the employee OASDI taxes that would have been payable for the barred years. 

4. Return any excess retirement deductions to OPM for posting to account 24X8135 via IPAC 

with these remarks: “Amount submitted for NAME, SSN, AGENCY, ALC, on DATE is 

being done in accordance with FERCCA”, in the appropriate field to identify the payment as 

a FERCCA payment. Submissions should be on a periodic basis (monthly, quarterly, or 

other to be established by the agency). If the excess retirement deductions do not cover the 

full amount of the OASDI taxes that the employee would have owed for the barred years, no 

additional OASDI tax is owed. Return only the excess retirement deductions to OPM, who 

will in turn send that money to the General Fund for payment of Social Security taxes. 

Return only what is needed to pay the OASDI tax for the barred years. If there is any 

money remaining, refund it to the employee. The refund should be treated as an 

underpayment of salary. No interest is payable on this refund. Submit copies of worksheets 

in Attachment 3 to the U.S. Office of Personnel Management, Financial Reporting & Policy 

Group, Division for Management & Chief Financial Officer, 1900 E Street, NW, Room 

3H28, Washington, DC 20415. 

C. Record Corrections by Payroll Office 

1. Correct the employee’s Social Security earnings record for all years (barred and nonbarred), using current procedures (W-2C/W-3C). 

2. Correct the employee’s Individual Retirement Record (IRR) for all years to reflect the 

correct retirement deduction amount. Annotate the record to show that, “Erroneous CSRS, 

should have been FERS – employee elected CSRS Offset on ________ (insert date of 

election), Correction due to Public Law 106-265 (FERCCA)”. 

D. The employee worked at more than one agency during the period of the coverage error. 

The current agency (or last employer) must correct the personnel records for the entire period. 

The current payroll office will adjust the retirement deductions, OASDI taxes and Social 

Security earnings records for the period of time the employee was at the current agency. If the 

period of service in the other agencies was during the barred years, the current agency must 

notify and provide the following information: name, social security number and complete 

information about the person and their election to the former employing agencies (through the 

agencies’ benefits counselors), and advise them that the FERCCA error has been corrected and 

that they must adjust the employee’s Social Security earnings record. The list of agency benefits 

counselors can be found at http://apps.opm.gov/abo/. (See Attachment 5 for a 

sample letter to send to the former agency.) The current agency must notify OPM’s Retirement 

Services & Management Group, Boyers, PA 16017 of the dates to be corrected. OPM will 

7
correct the 2806 on file and transfer the funds for the payment of OASDI taxes. 

E. The employee worked at another agency during the non-barred years. 

The current agency (or last employer) must notify the prior agency (through that agency’s 

benefits counselor) so the prior agency can ensure that the corrections are made. The prior 

agency’s payroll office must take the same steps outlined above in B and C. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS FERS CSRS-Offset 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. 

• Provide employee worksheet on distribution of 

contributions to the Retirement Fund and Social 

Security. 

Payroll Office 

• Retirement contributions • Calculate and submit appropriate retirement 

deductions separately for barred and non-barred 

years. 

• Correct Individual Retirement Record 

• Social security taxes • Non-barred years: Calculate OASDI taxes. 

Submit both employer and employee taxes to 

IRS. Bill employee for any additional employee 

taxes due. 

• Barred years: Calculate OASDI taxes. Return 

excess retirement contributions to OPM. You 

may not bill employee for any additional 

employee taxes due. 

All years: Correct employee’s Social Security 

earnings record. 

• Thrift Savings Plan • No actions required. 

8
II. ERRONEOUS CSRS COVERAGE, EMPLOYEE BELONGS IN FERS: 

ELECTION BETWEEN CSRS OFFSET AND FERS, 

EMPLOYEE ELECTS FERS 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from CSRS to FERS, 

retroactive to the effective date of the error. However, if the erroneous CSRS coverage occurred 

between 1984 and 1987, the FERS coverage can not be corrected retroactive to the date the error 

occurred. An additional correction is needed to show CSRS Interim coverage before the FERS 

coverage is effective. Attachment 1 is a chart of “Common Retirement Plans and Corresponding 

Codes” for your use in determining the correct codes to include on the personnel action. Include in 

remarks, “Erroneous CSRS, should have been FERS – Employee elected FERS on _______ (insert 

date of election), Correction due to Public Law 106-265 (FERCCA)”. Refer to the Guide to 

Processing Personnel Actions at www.opm.gov/feddata/persdoc.htm for additional assistance in 

preparing personnel actions. Provide the employee with a copy of the SF 50 or equivalent showing 

the action taken. Working with the Payroll Office and using the example in Attachment 2 as a guide, 

explain to the employee the distribution of money from the Retirement Fund and Social Security 

taxes. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the retirement deductions and Social Security taxes. 

Non-Barred Years - Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

2. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. The agency must pay any 

additional agency contributions to the Retirement Fund that are due. You may not collect 

any additional retirement contributions (either agency or employee) from the employee. 

3. Calculate the Social Security’s Old-Age, Survivors, and Disability Insurance (OASDI) taxes 

due for the non-barred years. You can determine the taxes due for a given year up to 3 years 

after that year’s filing deadline. For example, the error occurred in year 2001, the filing 

deadline for tax year 2001 was April 15, 2002. You can determine the OASDI taxes due in 

calendar year 2001 up to April 15, 2005. This would constitute the Non-Barred Years. Use 

the balance of any remaining (excess) deductions for the non-barred years to cover in whole 

or in part the employee’s cost of the OASDI taxes. If the individual owes additional taxes 

due to awards and bonuses, etc, above his or her base pay, this is treated as a salary 

overpayment subject to due process. Bill the employee for the additional OASDI taxes but 

suspend collection for 45 days while the employee submits a claim for reimbursement of 

out-of-pocket expenses to OPM. If OPM approves the claim for out-of-pocket expense, a 

waiver of the overpayment would be inappropriate. OPM will provide a copy of our out-ofpocket decision letter to the billing office. After 45 days, continue with the due process 

procedures. 

9
4. The agency should submit both employer and employee social security taxes to the Internal 

Revenue Service (IRS), following current procedures. 

Barred Years – Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

2. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. The agency must pay any 

additional agency contributions to the Retirement Fund that are due. You may not collect 

any additional retirement contributions (either agency or employee) from the employee. 

3. Calculate the employee OASDI taxes that would have been payable for the barred years. 

4. Return any excess retirement deductions for the barred years to OPM for posting to account 

24X8135 via IPAC with these remarks: “Amount submitted for NAME, SSN, AGENCY,

ALC, on DATE is being done in accordance with FERCCA”, in the appropriate field to 

identify the payment as a FERCCA payment. Submissions should be on a periodic basis 

(monthly, quarterly, or other to be established by the agency). If the excess retirement 

deductions do not cover the full amount of the OASDI taxes that the employee would have 

owed for the barred years, no additional OASDI tax is owed. Return only the excess 

retirement deductions to OPM, who will in turn send that money to the General Fund for 

payment of the Social Security taxes. Return only what is needed to pay the OASDI tax for 

the barred years. If there is any money remaining, refund it to the employee. The refund 

should be treated as an underpayment of salary. No interest is payable on this refund. 

Submit copies of worksheets in Attachment 3 to the U.S. Office of Personnel Management, 

Financial Reporting & Policy Group, Division for Management & Chief Financial Officer, 

1900 E Street, NW, Room 3H28, Washington, DC 20415. 

C. Record Corrections by Payroll Office 

1. Correct the employee’s Social Security earnings record for all years (barred and nonbarred), using current procedures (W-2C/W-3C). 

2. Correct the employee’s Individual Retirement Record (IRR). When the employee separates 

(or the IRR is otherwise created), an SF 3100, not an SF 2806, must be created. If a hard 

copy SF 2806 has already been created and has not been submitted to OPM, it must be 

voided. Document the SF 3100 with the following statement: “Erroneous CSRS should have 

been FERS – Employee elected FERS on _______ (insert date of election), Correction due 

to Public Law 106-265 (FERCCA)”. 

D. The employee worked at more than one agency during the period of the coverage error. 

The current agency (or last employer) must correct the personnel records for the entire period. 

The current payroll office will adjust the retirement deductions, OASDI taxes and Social 

Security earnings records for the period of time the employee was at the current agency. If the 

period of service in the other agencies was during the barred years, the current agency must 

10
notify and provide the following information: name, social security number and complete 

information about the person and their election to the former employing agencies (through the 

agencies’ benefits counselors), and advise them that the FERCCA error has been corrected and 

that they must adjust the employee’s Social Security earnings record. The list of agency benefits 

counselors can be found at http://apps.opm.gov/abo/ . (See Attachment 5 for a 

sample letter to send to the former agency.) The current agency must notify OPM’s Retirement 

Services & Management Group, Boyers, PA 16017 of the dates to be corrected. OPM will 

correct the 2806 on file and transfer the funds for the payment of OASDI taxes.

 

E. The employee worked at another agency during the non-barred years. 

The current agency (or last employer) must notify the prior agency (through that agency’s 

benefits counselor) so the prior agency can ensure that the corrections are made. The prior 

agency’s payroll office must take the same steps outlined above in B and C. 

F. TSP Contributions 

Follow the rules in the Federal Retirement Thrift Investment Board (FRTIB) regulations at 5 CFR 

1605. The agency must notify the employee that he/she is eligible for makeup contributions to 

replace the missed employee contributions due to the retirement coverage error. The agency must 

make the agency automatic (1%) contributions and agency matching contributions on the employee 

contributions that were made while the employee was misclassified. The agency is also responsible 

for lost earnings (breakage) on the agency automatic (1%) contributions and agency matching 

contributions, and on any employee make-up contributions. If the employee elects to make make-up 

contributions, the agency is also responsible for lost earnings (breakage) on the employee’s make-up 

contributions, agency matching contributions, and lost earnings (breakage) on the agency matching 

contributions. 

Ensure that the employee’s make-up contributions, when combined with any previous employee 

contributions, do not exceed the statutory employee contribution limit or the elective deferral limit 

for the year that the contributions should have been made. The elective deferral limit for 2004 is 

$13,000 and will increase each year by $1,000, until it reaches $15,000 in 2006. See Attachment 8 

for the annual elective deferral limits (1987 through 2005). Make-up employee contributions are 

subject to the IRS elective deferral limit for the year in which the contributions should have been 

made. Consequently, if the employee’s make-up contributions should have been made in an earlier 

year, they do not count against the current year’s elective deferral limit. For purposes of determining 

the amount of make-up contributions for an earlier year, that earlier year’s elective deferral limit 

must be applied. 

To report the make-up contributions, the agency must submit late payment records to the TSP 

record keeper. As explained in TSP Bulletin 02-19, Processing Agency Submissions in the New 

Record Keeping System, dated June 27, 2002, breakage (or lost earnings) will be calculated and 

posted to a participant's account for all three sources of makeup contributions reported on late 

payment records, and separate lost earnings records cannot be submitted. If, however, the 

makeup contributions had been reported to the TSP before June 1, 2003, the agency must submit 

separate lost earnings records to authorize the TSP to calculate and post lost earnings to a 

11
participant's account.

 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS FERS FERS 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. If erroneous coverage 

occurred between 1984 and 1987, correct 

coverage to CSRS Interim and then to FERS. 

• Provide employee worksheet on distribution of 

contributions to the Retirement Fund and Social 

Security. 

Payroll Office 

• Retirement contributions • Calculate and submit appropriate retirement 

deductions separately for barred and non-barred 

years. 

• Submit any additional agency contributions that 

are due. 

• Correct the Individual Retirement Record 

• Social security taxes • Non-barred years: Calculate OASDI taxes. 

Submit both employer and employee taxes to 

IRS. Bill employee for any additional employee 

taxes due. 

• Barred years: Calculate OASDI taxes. Return 

excess retirement contributions to OPM. You 

may not bill employee for any additional 

employee taxes due. 

All years: Correct employee’s Social Security 

earnings record. 

• Thrift Savings Plan Agency owes: 

• Agency automatic (1%) contributions for period 

of erroneous CSRS coverage plus lost earnings 

(breakage) on those contributions. 

• Agency matching contributions on any 

employee contributions made while erroneously 

covered by CSRS plus lost earnings (breakage) 

on those contributions. 

And if employee elects to make make-up 

contributions, the agency also owes: 

• Lost earnings (breakage) on the employee’s 

make-up contributions 

• Agency matching contributions plus lost 

earnings (breakage) on those contributions. 

12
III. ERRONEOUS CSRS OFFSET COVERAGE, EMPLOYEE BELONGS IN FERS: 

ELECTION BETWEEN CSRS OFFSET AND FERS, 

EMPLOYEE ELECTS CSRS OFFSET 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must document in Remarks on a Standard Form 50 or 

equivalent that “Erroneous CSRS Offset, should have been FERS – Employee elected to remain 

in CSRS Offset on _______, (insert date of election), Correction due to Public Law 106-265 

(FERCCA)”. Provide the employee with a copy of the SF 50 or equivalent showing the action 

taken. 

B. Actions by Payroll Office 

Servicing Payroll Office must document the SF 2806 to reflect the employee’s election to remain 

in CSRS Offset. Annotate the record to show that, “Erroneous CSRS Offset, should have been 

FERS – Employee elected to remain in CSRS Offset on _______ (insert date of election), 

Correction due to Public Law 106-265 (FERCCA)”. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS Offset FERS CSRS-Offset 

 Actions Required 

HR Office • Document Standard Form 50 showing employee 

chose to remain in CSRS Offset 

Payroll Office 

• Retirement contributions • Document SF 2806 to reflect employee’s 

election to remain in CSRS Offset. 

• Social Security taxes • No action required. 

• Thrift Savings Plan • No action required. 

13
IV. ERRONEOUS CSRS OFFSET COVERAGE, EMPLOYEE BELONGS IN FERS: 

 ELECTION BETWEEN CSRS OFFSET AND FERS, 

EMPLOYEE ELECTS FERS 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from CSRS Offset to FERS, 

retroactive to the effective date of the error. However, the effective date can be no earlier than 

January 1987. Attachment I is a chart of “Common Retirement Plans and Corresponding Codes” for 

your use in determining the correct codes to include on the personnel action. Include in remarks, 

“Erroneous CSRS Offset, should have been FERS – Employee elected FERS on ________ (insert 

date of election), Correction due to Public Law 106-265 (FERCCA)”. Refer to the Guide to 

Processing Personnel Actions at www.opm.gov/feddata/persdoc.htm for additional assistance in 

preparing personnel actions. Provide the employee with a copy of the SF 50 or equivalent showing 

the action taken. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the Individual Retirement Record (IRR). When the 

employee separates (or the IRR is otherwise created), an SF 3100, not an SF 2806, must be 

created. If a hard copy SF 2806 has already been created and has not been submitted to OPM, it 

must be voided. Document the SF 3100 with the following statement: “Erroneous CSRS Offset, 

should have been FERS – Employee elected FERS on _______ (insert date of election),

Correction due to Public Law 106-265 (FERCCA)”. Calculate and submit the appropriate 

retirement deductions based on the new retirement coverage via the RITS/2812 system, 

following current procedures. The agency must pay any additional agency contributions to the 

Retirement Fund that are due. You may not collect any additional retirement contributions 

(either agency or employee) from the employee. 

For employees earning over the Social Security maximum wage base, there will be excess 

retirement deductions to refund to the employee as well as any amounts subject to premium 

conversion (see BAL 02-304, dated February 6, 2002). 

No adjustments are necessary to the Social Security records. 

C. TSP Contributions 

Follow the rules in the Federal Retirement Thrift Investment Board (FRTIB) regulations at 5 CFR 

1605. The agency must notify the employee that he/she is eligible for makeup contributions to 

replace the missed employee contributions due to the retirement coverage error. The agency must 

make the agency automatic (1%) contributions and agency matching contributions on the employee 

contributions that were made while the employee was misclassified. The agency is also responsible 

for lost earnings on the agency automatic (1%) contribution and agency matching contributions, and 

on any employee make-up contributions. 

Ensure that the employee’s make-up contributions, when combined with any previous employee 

contributions, do not exceed the statutory employee contribution limit or the elective deferral limit 

14
for the year the contributions should have been made. The elective deferral limit for 2004 is $13,000 

and will increase each year by $1,000, until it reaches $15,000 in 2006. See Attachment 8 for the 

annual elective deferral limits (1987 through 2005). Make-up employee contributions are subject to 

the IRS elective deferral limit for the year in which the contributions should have been made. 

Consequently, if the employee’s make-up contributions should have been made in an earlier year, 

they do not count against the current year’s elective deferral limit. For purposes of determining the 

amount of make-up contributions for an earlier year, that earlier year’s elective deferral limit must be 

applied. 

To report the make-up contributions, the agency must submit late payment records to the TSP 

record keeper. As explained in TSP Bulletin 02-19, Processing Agency Submissions in the New 

Record Keeping System, dated June 27, 2002, breakage (or lost earnings) will be calculated and 

posted to a participant's account for all three sources of makeup contributions reported on late 

payment records, and separate lost earnings records cannot be submitted. If, however, the 

makeup contributions had been reported to the TSP before June 1, 2003, the agency must submit 

separate lost earnings records to authorize the TSP to calculate and post lost earnings to a 

participant's account. See Attachment 4 for examples of what agencies must pay for TSP. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS Offset FERS FERS 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. 

• Notify employee of correction taken. 

Payroll Office 

• Retirement contributions • Correct the Individual Retirement Record 

• Create a SF 3100 and void any SF 2806 

showing incorrect retirement coverage. 

• Submit any additional agency contributions that 

are due. 

• Refund any excess retirement deductions due 

the employee. 

• Social Security taxes • No action required. 

• Thrift Savings Plan Agency owes: 

• Agency automatic (1%) contributions for period 

of erroneous CSRS coverage plus lost earnings 

(breakage) on those contributions. 

• Agency matching contributions on any 

employee contributions made while erroneously 

covered by CSRS plus lost earnings (breakage) 

on those contributions. 

And if employee elects to make make-up 

contributions, the agency also owes: 

• Lost earnings (breakage) on the employee’s 

15
make-up contributions 

• Agency matching contributions plus lost 

earnings (breakage) on those contributions. 

16
V. ERRONEOUS CSRS COVERAGE, EMPLOYEE BELONGS IN SOCIAL 

 SECURITY ONLY: 

 ELECTION BETWEEN CSRS OFFSET AND SOCIAL SECURITY ONLY, 

 EMPLOYEE ELECTS CSRS OFFSET 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from CSRS to CSRS 

Offset, retroactive to the effective date of the error. Attachment 1 is a chart of “Common Retirement 

Plans and Corresponding Codes” for your use in determining the correct codes to include on the 

personnel action. Include in remarks, “Erroneous CSRS, should have been Social Security Only – 

Employee elected CSRS Offset on _______ (insert date of election), Correction due to Public Law 

106-265 (FERCCA)”. Refer to the Guide to Processing Personnel Actions at 

www.opm.gov/feddata/persdoc.htm for additional assistance in preparing personnel actions. Provide 

the employee with a copy of the SF 50 or equivalent showing the action taken. Working with the 

Payroll Office and using the example in Attachment 2 as a guide, explain to the employee the 

distribution of money from the Retirement Fund and Social Security taxes. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the retirement deductions and Social Security taxes. 

Non-Barred Years - Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following 

current procedures. 

2. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. 

3. Calculate the Social Security’s Old-Age, Survivors, and Disability Insurance (OASDI) 

taxes due for the non-barred years. You can determine the taxes due for a given year up 

to 3 years after that year’s filing deadline. For example, if the error occurred in year 

2001, the filing deadline for tax year 2001 was April 15, 2002. You can determine the 

OASDI taxes due in calendar year 2001 up to April 15, 2005. This would constitute the 

Non-Barred Years. Use the balance of any remaining (excess) deductions for the nonbarred years to cover in whole or in part the employee’s cost of the OASDI taxes. If the 

individual owes additional taxes due to awards and bonuses, etc, above his or her base 

pay, this is treated as a salary overpayment subject to due process. Bill the employee for 

the additional OASDI taxes but suspend collection for 45 days while the employee 

submits a claim for reimbursement of out-of-pocket expenses to OPM. If OPM approves 

the claim for out-of-pocket expense, a waiver of the overpayment would be 

inappropriate. OPM will provide a copy of our out-of-pocket decision letter to the billing 

office. After 45 days, continue with the due process procedures. 

4. Submit both employer and employee social security taxes to the Internal Revenue Service 

(IRS), following current procedures. 

Barred Years – Adjustments to Retirement Deductions and Social Security taxes 

17
1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

2. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. 

3. Calculate the employee OASDI taxes that would have been payable for the barred years. 

4. Return any excess retirement deductions for the barred years to OPM for posting to account 

24X8135 via IPAC with these remarks: “Amount submitted for NAME, SSN, AGENCY,

ALC, on DATE is being done in accordance with FERCCA”, in the appropriate field to 

identify the payment as a FERCCA payment. Submissions would be on a periodic basis 

(monthly, quarterly, or other to be established by the agency). If the excess retirement 

deductions do not cover the full amount of the OASDI taxes that the employee would have 

owed for the barred years, no additional OASDI tax is owed. Return only the excess 

retirement deductions to OPM, who will in turn send that money to the General Fund for 

payment of Social Security taxes. Return only what is needed to pay the OASDI tax for the 

barred years. If there is any money remaining, refund it to the employee. The refund should 

be treated as an underpayment of salary. No interest is payable on this refund. Submit copies 

of worksheets in Attachment 3 to the U.S. Office of Personnel Management, Financial 

Reporting & Policy Group, Division for Management & Chief Financial Officer, 1900 E 

Street, NW, Room 3H28, Washington, DC 20415. 

C. Record Corrections by Payroll Office 

1. Correct the employee’s Social Security earnings record for all years (barred and nonbarred), using current procedures (W-2C/W-3C). 

2. Correct the employee’s Individual Retirement Record (IRR) for all years to reflect the 

correct retirement deduction amount. Annotate the record to show that, “Erroneous CSRS, 

should have been Social Security Only – Employee elected CSRS Offset on ______ (insert 

date of election), Correction due to Public Law 106-265 (FERCCA)”. 

D. The employee worked at more than one agency during the period of the coverage error. 

The current agency (or last employer) must correct the personnel records for the entire period. 

The current payroll office will adjust the retirement deductions, OASDI taxes and Social 

Security earnings records for the period of time the employee was at the current agency. If the 

period of service in the other agencies was during the barred years, the current agency must 

notify and provide the following information: name, social security number and complete 

information about the person and their election to the former employing agencies (through the 

agencies’ benefits counselors), and advise them that the FERCCA error has been corrected and 

that they must adjust the employee’s Social Security earnings record. The list of agency benefits 

counselors can be found at http://apps.opm.gov/abo/. (See Attachment 5 for a 

sample letter to send to the former agency.) The current agency must notify OPM’s Retirement 

Services & Management Group, Boyers, PA 16017 of the dates to be corrected. OPM will 

correct the 2806 on file and transfer the funds for the payment of OASDI taxes 

18
E. The employee worked at another agency during the non-barred years. 

The current agency (or last employer) must notify the prior agency (through that agency’s 

benefits counselor) so the prior agency can ensure that the corrections are made. The prior 

agency’s payroll office must take the same steps outlined above in B and C. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS Social Security Only CSRS-Offset 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. 

• Provide employee worksheet on distribution of 

contributions to the Retirement Fund and Social 

Security. 

Payroll Office 

• Retirement contributions • Calculate and submit appropriate retirement 

deductions separately for barred and non-barred 

years. 

• Correct the Individual Retirement Record 

• Social security taxes • Non-barred years: Calculate OASDI taxes. 

Submit both employer and employee taxes to 

IRS. Bill employee for any additional employee 

taxes due. 

• Barred years: Calculate OASDI taxes. Return 

excess retirement contributions to OPM. You 

may not bill employee for any additional 

employee taxes due. 

All years: Correct employee’s Social Security 

earnings record. 

• Thrift Savings Plan • No actions required. 

19
VI. ERRONEOUS CSRS COVERAGE, EMPLOYEE BELONGS IN SOCIAL 

 SECURITY ONLY: 

 ELECTION BETWEEN CSRS OFFSET AND SOCIAL SECURITY ONLY, 

 EMPLOYEE ELECTS SOCIAL SECURITY ONLY 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from CSRS to Social 

Security Only, retroactive to the effective date of the error. Attachment 1 is a chart of “Common 

Retirement Plans and Corresponding Codes” for your use in determining the correct codes to include 

on the personnel action. Include in remarks, “Erroneous CSRS, should have been Social Security 

Only – Employee elected Social Security Only on ______ (insert date of election), Correction due to 

Public Law 106-265 (FERCCA)”. Refer to the Guide to Processing Personnel Actions at 

www.opm.gov/feddata/persdoc.htm for additional assistance in preparing personnel actions. Provide 

the employee with a copy of the SF 50 or equivalent showing the action taken. Working with the 

Payroll Office and using the example in Attachment 2 as a guide, explain to the employee the 

distribution of money from the Retirement Fund and Social Security taxes. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the retirement deductions and Social Security taxes. 

Non-Barred Years - Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

2. Calculate the Social Security’s Old-Age, Survivors, and Disability Insurance (OASDI) taxes 

due for the non-barred years. You can determine the taxes due for a given year up to 3 years 

after that year’s filing deadline. For example, the coverage error occurred in year 2001, the 

filing deadline for tax year 2001 was April 15, 2002. You can determine the OASDI taxes 

due in calendar year 2001 up to April 15, 2005. This would constitute the Non-Barred Years. 

Use the retirement deductions for the non-barred years to cover in whole or in part the 

employee’s cost of the OASDI taxes. If the individual owes additional taxes due to awards 

and bonuses, etc, above his or her base pay, this is treated as a salary overpayment subject to 

due process. Bill the employee for the additional OASDI taxes but suspend collection for 45 

days while the employee submits a claim for reimbursement of out-of-pocket expenses to 

OPM. If OPM approves the claim for out-of-pocket expense, a waiver of the overpayment 

would be inappropriate. OPM will provide a copy of our out-of-pocket decision letter to the 

billing office. After 45 days, continue with the due process procedures. 

3. Submit both employer and employee social security taxes to the Internal Revenue Service 

(IRS), following current procedures. 

Barred Years – Adjustments to Retirement Deductions and Social Security taxes 

1. Back out the full 7% employee contributions via the RITS/2812 system, following current 

procedures. 

20
2. Calculate the employee OASDI taxes that would have been payable for the barred years. 

3. Return the retirement deductions for the barred years to OPM for posting to account 

24X8135 via IPAC with these remarks: “Amount submitted for NAME, SSN, AGENCY,

ALC, on DATE is being done in accordance with FERCCA”, in the appropriate field to 

identify the payment as a FERCCA payment. Submissions would be on a periodic basis 

(monthly, quarterly, or other to be established by the agency). If the retirement deductions 

do not cover the full amount of the OASDI taxes that the employee would have owed for the 

barred years, no additional OASDI tax is owed. Return the retirement deductions to OPM, 

who will in turn send that money to the General Fund for payment of Social Security taxes. 

Return only what is needed to pay the OASDI tax for the barred years. If there is any 

money remaining, refund it to the employee. The refund should be treated as a refund of 

retirement contributions. Submit copies of worksheets in Attachment 3 to the U.S. Office of 

Personnel Management, Financial Reporting & Policy Group, Division for Management & 

Chief Financial Officer, 1900 E Street, NW, Room 3H28, Washington, DC 20415. 

C. Record Corrections by Payroll Office 

1. Correct the employee’s Social Security earnings record for all years (barred and nonbarred), using current procedures (W-2C/W-3C). 

2. Void the employee’s Individual Retirement Record (IRR) for all years and annotate the 

record to show that, “Erroneous CSRS, should have been Social Security Only – Employee 

elected Social Security Only on _______ (insert date of election), Correction due to Public 

Law 106-265 (FERCCA)”.

D. The employee worked at more than one agency during the period of the coverage error. 

The current agency (or last employer) must correct the personnel records for the entire period. 

The current payroll office will adjust the retirement deductions, OASDI taxes and Social 

Security earnings records for the period of time the employee was at the current agency. If the 

period of service in the other agencies was during the barred years, the current agency must 

notify and provide the following information: name, social security number and complete 

information about the person and their election to the former employing agencies (through the 

agencies’ benefits counselors), and advise them that the FERCCA error has been corrected and 

that they must adjust the employee’s Social Security earnings record. The list of agency benefits 

counselors can be found at http://apps.opm.gov/abo/. (See Attachment 5 for a 

sample letter to send to the former agency.) The current agency must notify OPM’s Retirement 

Services & Management Group, Boyers, PA 16017 of the dates to be corrected. OPM will 

correct the 2806 on file and transfer the funds for the payment of OASDI taxes. 

E. The employee worked at another agency during the non-barred years. 

The current agency (or last employer) must notify the prior agency (through that agency’s 

benefits counselor) so they can ensure that the corrections are made. That agency’s payroll office 

must take the same steps outlined above in B and C. 

21
F. TSP Contributions 

Personnel/Human Resource Office must correct TSP eligibility prospectively to reflect employee 

is ineligible to contribute. 

Individual is treated as a separated employee. Payroll Office must submit an Employee Data 

Record (EDR) to reflect a separation from service and a correct retirement code. 

Employee is deemed separated for all TSP purposes. Outstanding loans will be declared taxable 

distributions; employee is eligible for post-service withdrawal options and is eligible to leave 

employee contributions and earnings made while coded CSRS in the TSP account. 

An employee may choose to have all employee contributions that he or she made to the TSP 

after December 31, 1999, removed from the account and refunded to him or her. If the 

employee elects this option, the payroll office must submit negative adjustment records to the 

TSP record keeper, as explained in TSP Bulletin 02-19, and refund the contributions to the 

employee. Refunded employee contributions must be reported as income for the year they are 

paid to the employee. Employee contributions made before January 1, 2000, and earnings on all 

employee contributions will remain in the TSP account (and will be paid to the employee when 

the account is ultimately withdrawn). 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS Social Security Social Security 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. 

• Provide employee worksheet on distribution of 

contributions to the Retirement Fund and Social 

Security. 

Payroll Office 

• Retirement contributions • Void the Individual Retirement Record 

• Social security taxes • Non-barred years: Calculate OASDI taxes. 

Submit both employer and employee taxes to 

IRS. Bill employee for any additional employee 

taxes due. 

• Barred years: Calculate OASDI taxes. Return 

excess retirement contributions to OPM. You 

may not bill employee for any additional 

employee taxes due. 

All years: Correct employee’s Social Security

earnings record. 

• Thrift Savings Plan • Employee contributions and earnings may 

remain in the TSP account. 

• Submit an EDR to reflect the employee’s 

22
ineligible status, the employee’s separation, and 

the employee’s correct retirement code. 

• Submit negative adjustment records to TSP if 

employee elects to receive employee 

contributions. 

23
VII. ERRONEOUS CSRS OFFSET COVERAGE, EMPLOYEE BELONGS IN SOCIAL 

 SECURITY ONLY, ELECTION BETWEEN CSRS OFFSET AND SOCIAL 

 SECURITY, 

 EMPLOYEE ELECTS CSRS OFFSET 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must document in Remarks on a Standard Form 50 or 

equivalent that “Erroneous CSRS Offset, should have been Social Security Only – Employee 

elected to remain in CSRS Offset on ______ (insert date of election), Correction due to Public 

Law 106-265 (FERCCA)”. Provide the employee with a copy of the SF 50 or equivalent showing 

the action taken. 

B. Actions by Payroll Office 

Servicing Payroll Office must document the SF 2806 to reflect the employee’s ELECTION to 

remain in CSRS Offset. Annotate the record to show that, “Erroneous CSRS Offset, should have 

been Social Security Only – Employee elected to remain in CSRS Offset on _______ (insert date 

of election), Correction due to Public Law 106-265 (FERCCA)”. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS Offset Social Security CSRS-Offset 

 Actions Required 

HR Office • Document Standard Form 50 showing employee 

chose to remain in CSRS Offset 

Payroll Office 

• Retirement contributions • Document SF 2806 to reflect employee’s 

election to remain in CSRS Offset. 

• Social Security taxes • No action required. 

• Thrift Savings Plan • No action required 

24
VIII.ERRONEOUS CSRS OFFSET COVERAGE, EMPLOYEE BELONGS IN 

 SOCIAL SECURITY ONLY: 

 ELECTION BETWEEN CSRS OFFSET AND SOCIAL SECURITY ONLY, 

 EMPLOYEE ELECTS SOCIAL SECURITY ONLY 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from CSRS Offset to Social 

Security Only, retroactive to the effective date of the error. Attachment 1 is a chart of “Common 

Retirement Plans and Corresponding Codes” for your use in determining the correct codes to include 

on the personnel action. Include in remarks, “Erroneous CSRS Offset, should have been Social 

Security Only – Employee elected Social Security Only on ______ (insert date of election), 

Correction due to Public Law 106-265 (FERCCA)”. Refer to the Guide to Processing Personnel 

Actions at www.opm.gov/feddata/persdoc.htm for additional assistance in preparing personnel 

actions. Provide the employee with a copy of the SF 50 or equivalent showing the action taken. 

Working with the Payroll Office and using the example in Attachment 2 as a guide, explain to the 

employee the distribution of money from the Retirement Fund and Social Security taxes. 

B. Actions by Payroll Office 

Servicing Payroll Office must void the employee’s Individual Retirement Record (IRR) (for all 

years) and annotate the record to show that, “Erroneous CSRS Offset, should have been Social 

Security Only – Employee elected Social Security Only on _______ (insert date of election), 

Correction due to Public Law 106-265 (FERCCA)”. Submit the voided IRR to OPM to 

document the record for possible future use, following current procedures. Refund to the 

employee the employee contributions in the retirement account. 

No adjustments are necessary to the Social Security records. 

C. TSP Contributions 

Personnel/Human Resource Office must correct TSP eligibility prospectively to reflect employee 

is ineligible to contribute. 

Individual is treated as a separated employee. Payroll Office must submit an Employee Data 

Record (EDR) to reflect a separation from service and a correct retirement code. 

Employee is deemed separated for all TSP purposes. Outstanding loans will be declared taxable 

distributions; employee is eligible for post-service withdrawal options and is eligible to leave 

Employee Contributions and earnings made while coded CSRS Offset in the TSP account. 

An employee may choose to have all employee contributions that he or she made to the TSP 

after December 31, 1999, removed from the account and refunded to him or her. If the 

employee elects this option, the payroll office must submit negative adjustment records to the 

TSP record keeper, as explained in TSP Bulletin 02-19, and refund the contributions to the 

employee. Refunded employee contributions must be reported as income for the year they are 

paid to the employee. Employee contributions made before January 1, 2000, and earnings on all 

25
employee contributions will remain in the TSP account (and will be paid to the employee when 

the account is ultimately withdrawn). 

 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

CSRS Offset Social Security Social Security 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. 

• Provide employee worksheet on distribution of 

contributions to the Retirement Fund and Social 

Security. 

Payroll Office 

• Retirement contributions • Calculate retirement deductions and refund to 

employee. 

• Void Individual Retirement Record 

• Social security taxes • No adjustments are necessary. 

• Thrift Savings Plan • Employee contributions and earnings may 

remain in the TSP account. 

• Submit an EDR to reflect the employee’s 

ineligible status, the employee’s separation, and 

the employee’s correct retirement code. 

• Submit negative adjustment records to TSP if 

employee elects to receive employee 

contributions. 

26
IX. ERRONEOUS FERS COVERAGE, EMPLOYEE BELONGS IN CSRS: 

 ELECTION BETWEEN FERS AND CSRS, 

 EMPLOYEE ELECTS FERS 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must document in Remarks on a Standard Form 50 or 

equivalent that “Erroneous FERS, should have been CSRS – Employee elected to remain in 

FERS on ______ (insert date of election), Correction due to Public Law 106-265 (FERCCA)”. 

Provide the employee with a copy of the SF 50 or equivalent showing the action taken. 

B. Actions by Payroll Office 

Servicing Payroll Office must document the SF 3100 to reflect the employee’s election to remain 

in FERS. Annotate the record to show that, “Erroneous FERS, should have been CSRS – 

Employee elected to remain in FERS on __________ (insert date of election), Correction due to 

Public Law 106-265 (FERCCA)”. 

C. TSP Contributions 

Follow the rules in the Federal Retirement Thrift Investment Board (FRTIB) regulations at 5 CFR 

1605. The agency must notify the employee that he/she is eligible for make-up contributions to 

replace the missed employee contributions that he/she could have made during the waiting period

required for new or rehired FERS employees. The agency must make the agency automatic (1%) 

contributions for the waiting period during erroneous automatic FERS coverage and is also 

responsible for lost earnings on these contributions. If the employee elects to make make-up 

contributions for the waiting period during erroneous automatic FERS coverage, the agency also 

owes agency matching contributions plus lost earnings on those contributions. 

Note: Lost earnings on the employee’s make-up contributions ARE NOT PAYABLE in this type 

of coverage error. 

Ensure that the employee’s make-up contributions, when combined with any previous employee 

contributions, do not exceed the statutory employee contribution limit or the elective deferral limit 

for the year that the contributions should have been made. The elective deferral limit for 2004 is 

$13,000 and will increase each year by $1,000, until it reaches $15,000 in 2006. See Attachment 8 

for the annual elective deferral limits (1987 through 2005). Make-up employee contributions are 

subject to the IRS elective deferral limit for the year in which the contributions should have been 

made. Consequently, if the employee’s make-up contributions should have been made in an earlier 

year, they do not count against the current year’s elective deferral limit. For purposes of determining 

the amount of make-up contributions for an earlier year, that earlier year’s elective deferral limit 

must be applied. 

To report the make-up contributions, the agency must submit current payment records to the TSP 

record keeper. As explained in TSP Bulletin 02-19, breakage (or lost earnings) will be calculated 

and posted to a participant’s account for only the agency sources of makeup contributions reported 

on current payment records, and separate lost earnings records cannot be submitted. If, however, the 

27
agency makeup contributions had been reported to the TSP before June 1, 2003, the agency must 

submit separate lost earnings records to authorize the TSP to calculate and post lost earnings to a 

participant’s account. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

FERS CSRS FERS 

 Actions Required 

HR Office • Document Standard Form 50 showing employee 

chose to remain in FERS 

Payroll Office 

• Retirement contributions • Document SF 3100 to reflect employee’s 

election to remain in FERS. 

• Social Security taxes • No action required. 

• Thrift Savings Plan Agency owes: 

• Agency automatic (1%) contributions for

waiting period during erroneous automatic 

FERS coverage plus lost earnings on those 

contributions. 

And if employee elects to make make-up 

contributions for waiting period during erroneous 

automatic FERS coverage, the agency also owes: 

• Lost earnings on the employee’s make-up 

contributions ARE NOT PAYABLE in this 

type of coverage error 

• Agency matching contributions plus lost 

earnings on those contributions. 

28
X. ERRONEOUS FERS COVERAGE, EMPLOYEE BELONGS IN CSRS: 

 ELECTION BETWEEN FERS AND CSRS, 

 EMPLOYEE ELECTS CSRS

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from FERS to CSRS 

retroactive to the effective date of the error. Attachment 1 is a chart of “Common Retirement Plans 

and Corresponding Codes” for your use in determining the correct codes to include on the personnel 

action. Include in remarks, “Erroneous FERS, should have been CSRS – Employee elected CSRS on 

________ (insert date of election), Correction due to Public Law 106-265 (FERCCA)”. Refer to the 

Guide to Processing Personnel Actions at www.opm.gov/feddata/persdoc.htm for additional 

assistance in preparing personnel actions. Provide the employee with a copy of the SF 50 or 

equivalent showing the action taken. Working with the Payroll Office and using the example in 

Attachment 2 as a guide, explain to the employee the distribution of money from the Retirement 

Fund and Social Security taxes. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the retirement deductions and Social Security taxes. 

Non-Barred Years – Adjustments to Retirement Deductions and Social Security taxes 

1. The employee owes additional retirement deductions for CSRS coverage and has overpaid 

Old-Age, Survivors, and Disability Insurance (OASDI) taxes. Determine whether you can 

recover some or all of the OASDI taxes withheld from the employee. You can recover 

OASDI taxes erroneously paid for a given year up to 3 years after that year’s filing deadline. 

For example, the coverage error occurred in year 2001, the filing deadline for tax year 2001 

was April 15, 2002. This would constitute the Non-Barred Years. You can recover OASDI 

taxes that were erroneously paid in calendar year 2001 up to April 15, 2005. The agency is 

responsible for any difference between the employee retirement contributions withheld and 

the full CSRS contribution. The employee does not get social security credit for these years. 

2. Recover the OASDI taxes erroneously paid for each year that you are permitted to recover 

by completing IRS form 941c. See www.irs.gov/pub/irs-pdf/f941c.pdf for instructions on 

completing form 941c. Recover both the employee and employer OASDI taxes. You should 

refund to the employee any recovered OASDI taxes that are not needed to pay the 

employee’s CSRS retirement withholdings. 

3. For each calendar year that you are permitted to recover erroneous 

OASDI taxes, complete and submit form W-2c, Corrected Wage and Tax Statement, 

showing the employee’s Social Security wages to be $0.00. Note that although the Medicare 

wages are not being changed, you must indicate what was previously reported for Medicare 

and indicate that same amount as being the correct information. See www.irs.gov/pub/irspdf/fw2c.pdf for instructions on completing form W-2c. 

4. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. The agency is 

29
responsible for the full amount of the employee retirement contributions, even if the full 

amount is not recovered from OASDI taxes. Do not bill the employee for any retirement 

contributions. In addition the agency cannot collect any excess agency contributions paid to 

OPM while the employee was under FERS. 

Barred Years – Adjustments to Retirement Deductions and Social Security taxes 

1. Calculate and submit the appropriate retirement deductions based on the new retirement 

coverage via the RITS/2812 system, following current procedures. The agency is 

responsible for any difference between the employee retirement contributions withheld and 

the full CSRS contribution. Do not bill the employee for any retirement contributions. 

2. Servicing Payroll Office must correct the Individual Retirement Record (IRR). When the 

employee separates (or the IRR is otherwise created), an SF 2806, not an SF 3100, must be 

created. If a hard copy SF 3100 has already been created and has not been submitted to 

OPM, it must be voided. Document the SF 2806 with the following statement: “Erroneous 

FERS, should have been CSRS – Employee elected CSRS on ______ (insert date of 

election), Correction due to Public Law 106-265 (FERCCA)”.

3. The agency may not recover the Social Security taxes paid during the barred years. Notify 

the employee that the Social Security taxes for the barred years remain credited to Social 

Security. The employee receives credit for the service for Social Security benefits and Civil 

Service Retirement benefits. 

C. The employee worked at more than one agency during the period of the coverage error. 

The current agency (or last employer) must correct the personnel records for the entire period. 

The current payroll office will adjust the retirement deductions, OASDI taxes and Social 

Security earnings records for the period of time the employee was at the current agency. If the 

period of service in the other agencies was during the barred years, the current agency must 

notify and provide the following information: name, social security number and complete 

information about the person and their election to the former employing agencies (through the 

agencies’ benefits counselor), and advise them that the FERCCA error has been corrected and 

that they must adjust the employee’s Social Security earnings record. The list of agency benefits 

counselors can be found at http://apps.opm.gov/abo/ . (See Attachment 5 for a 

sample letter to send to the former agency.) 

D. The employee worked at another agency during the non-barred years. 

The current agency (or last employer) must notify the prior agency (through that agency’s 

benefits counselor) so they can ensure that the corrections are made. That agency’s payroll office 

must take the same steps outlined above. 

E. TSP Contributions 

Pursuant to 5 CFR 1605, all employee contributions made to the TSP while the employee was 

erroneously covered by FERS may remain in the TSP account. However, the employee may 

choose to have those employee contributions that exceeded the CSRS limit (excess 

30
contributions) and that were made to the TSP after December 31, 1999, removed from the 

account and refunded to him or her. If the employee elects this option, the payroll office must 

submit negative adjustment records to the TSP record keeper, as explained in TSP Bulletin 02-

19, and refund the contributions to the employee. Refunded employee contributions must be 

reported as income earned for the year they are paid to the employee. Excess employee 

contributions made before January 1, 2000, and earnings on all employee contributions will 

remain in the TSP account. 

 

The employee is not entitled to any of the agency contributions and attributable earnings in his or 

her account and the TSP will ultimately remove these contributions from the account. If the 

agency wants to receive those erroneous agency contributions that it had reported within the last 

year, it must submit negative adjustment records to the TSP, as explained in TSP Bulletin 02-

19. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

FERS CSRS CSRS 

 Actions Required 

HR Office • Correct retirement coverage retroactive to the 

effective date of the error. 

• Provide the employee worksheet on distribution 

of contributions to the Retirement Fund and 

Social Security. 

Payroll Office 

• Retirement contributions • Calculate and submit appropriate retirement 

deductions separately for barred and non-barred 

years. Agency contributions made while the 

employee was covered under FERS remains in 

the Retirement Fund. 

• Create an SF 2806 Individual Retirement 

Record, void any SF 3100 

• Social security taxes • Non-barred years: Recover both the employee 

and employer OASDI taxes by completing IRS 

form 941c. Refund any excess taxes not needed 

to pay the employee’s CSRS retirement 

deductions. 

• Barred years: May not recover taxes. Notify 

employee that the taxes for barred years remain 

credited to Social Security and employee 

receives credit for the service for both Social 

Security benefits and CSRS. 

All years: Correct employee’s Social Security 

earnings record. 

• Thrift Savings Plan • Notify the employee that employee 

contributions and earnings on those 

31
contributions may remain in TSP. 

• Notify the employee that agency contributions 

and earnings will be removed from the account. 

• Submit negative adjustment records to TSP if 

the employee elects to receive excess employee 

contributions over the applicable contribution 

percentage or if the agency wants to receive 

agency contributions made within last year. 

32
XI. ERRONEOUS FERS COVERAGE, EMPLOYEE BELONGS IN CSRS OFFSET: 

 ELECTION BETWEEN FERS AND CSRS OFFSET, 

 EMPLOYEE ELECTS FERS 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must document in Remarks on a Standard Form 50 or 

equivalent that “Erroneous FERS, should have been CSRS Offset – Employee elected to remain 

in FERS on _______ (insert date of election), Correction due to Public Law 106-265 

(FERCCA)”. Provide the employee with a copy of the SF 50 or equivalent showing the action 

taken. 

B. Actions by Payroll Office 

Servicing Payroll Office must document the SF 3100 to reflect the employee’s election to remain 

in FERS. Annotate the record to show that, “Erroneous FERS, should have been CSRS Offset – 

Employee elected to remain in FERS on _______ (insert date of election), Correction due to 

Public Law 106-265 (FERCCA)”. Also document the SF 3100 to show that, “Employee will be 

eligible for an actuarial reduction for any money he owes for any prior service that is credited 

under CSRS rules.” 

C. TSP Contributions 

Follow the rules in the Federal Retirement Thrift Investment Board (FRTIB) regulation at 5 CFR 

1605. The agency must notify the employee that he/she is eligible for make-up contributions to 

replace the missed employee contributions that he/she could have made during the waiting period

required for new or rehired FERS employees. The agency must make the agency automatic (1%) 

contributions for the waiting period during erroneous automatic FERS coverage and is also 

responsible for lost earnings on these contributions. If the employee elects to make make-up 

contributions for the waiting period during erroneous automatic FERS coverage, the agency also 

owes agency matching contributions plus lost earnings on those contributions. 

Note: Lost earnings on the employee’s make-up contributions ARE NOT PAYABLE in this type 

of coverage error. 

Ensure that the employee’s make-up contributions, when combined with any previous employee 

contributions, do not exceed the statutory employee contribution limit or the elective deferral limit 

for the year that the contributions should have been made. The elective deferral limit for 2004 is 

$13,000 and will increase each year by $1,000, until it reaches $15,000 in 2006. See Attachment 8 

for the annual elective deferral limits (1987 through 2005). Make-up employee contributions are 

subject to the IRS elective deferral limit for the year in which the contributions should have been 

made. Consequently, if the employee’s make-up contributions should have been made in an earlier 

year, they do not count against the current year’s elective deferral limit. For purposes of determining 

the amount of make-up contributions for an earlier year, that earlier year’s elective deferral limit 

must be applied. 

To report the make-up contributions, the agency must submit current payment records to the TSP 

33
record keeper. As explained in TSP Bulletin 02-19, breakage (or lost earnings) will be 

calculated and posted to a participant’s account for only the agency sources of makeup 

contributions reported on current payment records, and separate lost earnings records cannot be 

submitted. If, however, the agency makeup contributions had been reported to TSP before June 

1, 2003, the agency must submit separate lost earnings records to authorize TSP to calculate and 

post lost earnings to a participant’s account. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

FERS CSRS Offset FERS 

 Actions Required 

HR Office • Document Standard Form 50 showing employee 

chose to remain in FERS 

Payroll Office 

• Retirement contributions • Document SF 3100 to reflect employee’s 

election to remain in FERS. 

• Social Security taxes • No action required. 

• Thrift Savings Plan Agency owes: 

• Agency automatic (1%) contributions for 

waiting period during erroneous automatic 

FERS coverage plus lost earnings on those 

contributions. 

And if the employee elects to make make-up 

contributions for waiting period during erroneous 

automatic FERS coverage, the agency also owes: 

• Lost earnings on the employee’s make-up 

contributions ARE NOT PAYABLE in this 

type of coverage error 

• Agency matching contributions plus lost earning 

on those contributions. 

34
XII. ERRONEOUS FERS COVERAGE, EMPLOYEE BELONGS IN CSRS OFFSET: 

 ELECTION BETWEEN FERS AND CSRS OFFSET, 

 EMPLOYEE ELECTS CSRS OFFSET 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from FERS to CSRS Offset, 

retroactive to the effective date of the error. Attachment 1 is a chart of “Common Retirement Plans 

and Corresponding Codes” for your use in determining the correct codes to include on the personnel 

action. Include in remarks, “Erroneous FERS, should have been CSRS Offset – Employee elected 

CSRS Offset on _______ (insert date of election), Correction due to Public Law 106-265 

(FERCCA)”. Refer to the Guide to Processing Personnel Actions at 

www.opm.gov/feddata/persdoc.htm for additional assistance in preparing personnel actions. Provide 

the employee with a copy of the SF 50 or equivalent showing the action taken. Working with the 

Payroll Office and using the example in Attachment 2 as a guide, explain to the employee the 

distribution of money from the Retirement Fund and Social Security taxes. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the Individual Retirement Record (IRR). When the 

employee separates (or the IRR is otherwise created), an SF 2806, not an SF 3100, must be 

created. If a hard copy SF 3100 has already been created and has not been submitted to OPM, it 

must be voided. Document the SF 2806 with the following statement: “Erroneous FERS, should 

have been CSRS Offset – Employee elected CSRS Offset on _______ (insert date of election), 

Correction due to Public Law 106-265 (FERCCA)”. Also document the SF 3100 to show that, 

“Employee will be eligible for an actuarial reduction for any money he owes for any prior 

service that is credited under CSRS rules.” 

If in any year of erroneous coverage, the employee’s total basic pay reached the Social Security 

maximum taxable wage base, the retirement deduction rate must be corrected to reflect the “full” 

CSRS employee withholding rate for the position. The Payroll Office must take the full 

deductions on the first dollar of basic salary over the Social Security wage base and that 

the reversion to full withholdings is reflected during the pay period in which it occurs. See BAL 

02-304 for detailed instructions for determining the correct retirement deduction rate. The IRR 

must reflect these retirement deductions. Calculate and submit the appropriate retirement 

deductions via the RITS/2812 system, following current procedures. The agency may not collect 

additional retirement contributions from the employee. In addition the agency cannot collect any 

excess agency contributions paid to OPM while the employee was under FERS. 

No corrections to the Social Security records are required. 

C. TSP Contributions 

Pursuant to 5 CFR 1605, all employee contributions made to TSP while the employee was 

erroneously covered by FERS may remain in the SP account. However, the employee may 

choose to have those employee contributions that exceeded the CSRS limit (excess 

contributions) and that were made to the TSP after December 31, 1999, removed from the 

35
account and refunded to him or her. If the employee elects this option, the payroll office must 

submit negative adjustment records to the TSP record keeper, as explained in TSP Bulletin 02-

19, and refund the contributions to the employee. Refunded employee contributions must be 

reported as income earned for the year they are paid to the employee. Excess employee 

contributions made before January 1, 2000, and earnings on all employee contributions will 

remain in the TSP account. 

The employee is not entitled to any of the agency contributions and attributable earnings in his or 

her account and TSP will ultimately remove these contributions from the account. If the agency 

wants to receive those erroneous agency contributions that it had reported within the last year, it 

must submit negative adjustment records to the TSP, as explained in TSP Bulletin 02-19. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

FERS CSRS Offset CSRS Offset 

 Actions Required 

HR Office • Correct retirement coverage retroactive to 

effective date of error. 

• Notify employee of correction taken. 

Payroll Office 

• Retirement contributions • Correct the Individual Retirement Record 

• Create a SF 2806 

• Void any SF 3100 showing incorrect retirement 

coverage. 

• Send OPM any additional retirement 

contributions. 

• Agency contributions made while the employee 

was covered under FERS remains in the 

Retirement Fund. 

• Social Security taxes • No adjustment necessary. 

• Thrift Savings Plan • Notify the employee that employee 

contributions and earnings on those 

contributions may remain in TSP. 

• Notify the employee that agency contributions 

and earnings will be removed from the account 

• Submit negative adjustment records to TSP if 

the employee elects to receive the excess 

employee contributions over the applicable 

contribution percentage or if agency wants to 

receive agency contributions made within the 

last year. 

36
XIII.ERRONEOUS FERS COVERAGE, EMPLOYEE BELONGS IN SOCIAL SECURITY 

 ONLY: 

 ELECTION BETWEEN FERS AND SOCIAL SECURITY ONLY, 

 EMPLOYEE ELECTS FERS

A. Actions by Human Resource Office 

Personnel/Human Resource Office must document in Remarks on a Standard Form 50 or 

equivalent that “Erroneous FERS, should have been Social Security Only – Employee elected to 

remain in FERS on________ (insert date of election), Correction due to Public Law 106-265 

(FERCCA)”. Provide the employee with a copy of the SF 50 or equivalent showing the action 

taken. 

B. Actions by Payroll Office 

Servicing Payroll Office must document the SF 3100 to reflect the employee’s election to remain 

in FERS. Annotate the record to show that, “Erroneous FERS, should have been Social Security 

Only – Employee elected to remain in FERS on________ (insert date of election), Correction 

due to Public Law 106-265 (FERCCA)”. Also document the SF 3100 to show that, “Employee 

will be eligible for an actuarial reduction for any money he owes for any prior service that is 

credited under CSRS rules.” 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

FERS Social Security FERS 

 Actions Required 

HR Office • Document Standard Form 50 showing the 

employee chose to remain in FERS 

Payroll Office 

• Retirement contributions • Document SF 3100 to reflect the employee’s 

election to remain in FERS. 

• Thrift Savings Plan • No action required 

37
XIV.ERRONEOUS FERS COVERAGE, EMPLOYEE BELONGS IN SOCIAL SECURITY 

 ONLY: 

 ELECTION BETWEEN FERS AND SOCIAL SECURITY ONLY, 

 EMPLOYEE ELECTS SOCIAL SECURITY ONLY 

A. Actions by Human Resource Office 

Personnel/Human Resource Office must correct the retirement coverage from FERS to Social 

Security Only, retroactive to the effective date of the error. Attachment 1 is a chart of “Common 

Retirement Plans and Corresponding Codes” for your use in determining the correct codes to include 

on the personnel action. Include in remarks, “Erroneous FERS, should have been Social Security 

Only – Employee elected Social Security Only on _______ (insert date of election), Correction due 

to Public Law 106-265 (FERCCA)”. Refer to the Guide to Processing Personnel Actions at 

www.opm.gov/feddata/persdoc.htm for additional assistance in preparing personnel actions. Provide 

the employee with a copy of the SF 50 or equivalent showing the action taken. Using the example in 

Attachment 2 as a guide, explain to the employee the distribution of money from the Retirement 

Fund and Social Security. 

B. Actions by Payroll Office 

Servicing Payroll Office must correct the retirement deductions. Void the employee’s Individual 

Retirement Record (IRR) for all years and annotate the record to show that, “Erroneous FERS, 

should have been Social Security Only – Employee elected Social Security Only on _______ 

(insert date of election), Correction due to Public Law 106-265 (FERCCA)”. Recover employee 

retirement contributions via the RITS/2812 system. Refund to the employee the employee 

contributions in the retirement account. 

If the employee worked at another agency during the period of the error, notify OPM of the 

employee’s election. OPM will need to correct any Individual Retirement Records on file for 

that service and refund any retirement deductions to the employee. The agency cannot collect 

any excess agency contributions paid to OPM while the employee was under FERS. 

No adjustments are necessary to the Social Security records. 

C. TSP Contributions 

Personnel/Human Resource Office must correct TSP eligibility prospectively to reflect employee 

is ineligible to contribute. 

Individual is treated as a separated employee. Payroll Office must submit an Employee Data 

Record (EDR) to reflect a separation from service and a correct retirement code. 

The employee is deemed separated for all TSP purposes. Outstanding loans will be declared 

taxable distributions; employee is eligible for post-service withdrawal options and is eligible to 

leave employee contributions and earnings made while coded FERS in the TSP account. 

38
Pursuant to 5 CFR 1605, all employee contributions made to the TSP while the employee was 

erroneously covered by FERS may remain in the TSP account. However, the employee may choose 

to have those employee contributions that were made to the TSP after December 31, 1999, 

removed from the account and refunded to him or her. If the employee elects this option, the payroll 

office must submit negative adjustment records to the TSP record keeper, as explained in TSP 

Bulletin 02-19, and refund the contributions to the employee. Refunded employee contributions 

must be reported as income for the year they are paid to the employee. Employee contributions 

made before January 1, 2000, and earnings on all employee contributions will remain in the TSP 

account. 

The employee is not entitled to any of the agency contributions and attributable earnings in his or her 

account and TSP will ultimately remove these contributions from the account. If the agency wants 

to receive those erroneous agency contributions that it had reported within the last year, it must 

submit negative adjustment records to TSP, as explained in TSP Bulletin 02-19. 

Summary of Actions Required 

Currently in: Belongs in: Correct to: 

FERS Social Security Social Security 

 Actions Required 

HR Office • Correct retirement coverage retroactive to the 

effective date of the error. 

• Provide employee worksheet on distribution of 

contributions to the Retirement Fund and Social 

Security. 

Payroll Office 

• Retirement contributions • Calculate retirement deductions and refund to 

employee. 

• Void the Individual Retirement Record 

• Agency contributions made while the employee 

was covered under FERS remains in the 

Retirement Fund. 

• Social security taxes • No action required. 

• Thrift Savings Plan • Submit an EDR to reflect the employee’s 

ineligible status, the employee’s separation, and 

the employee’s correct retirement code. 

• Submit negative adjustment records to TSP if 

the employee elects to receive employee 

contributions or if agency wants to receive 

agency contributions made within the last year. 

Raymond J. Kirk, Manager 

Benefits Officers Training & Development Group 

Human Capital Leadership & Merit Systems Accountability 

39