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505.5 General 

This chapter includes the current procedure for full-time student (FTS) benefits. Refer 

to Appendix E for a description of the provisions in effect prior to August 1982. 

505.5.1 Definition of Employee's Student Child 

The term "child" means the employee's natural child, adopted child, dependent stepchild 

or, under certain conditions, grandchild whose parents are deceased or disabled. This 

definition is the same as the definition of "child" under the Social Security Act (SS Act). 

Children age 18-19 qualify as students if they are in full-time attendance at elementary 

or secondary schools, as explained inFOM-I-505.5.3. 

505.5.2 Student Must Be Unmarried 

To qualify as an FTS, the child must be unmarried. See FOM-I-420.10.2 if the child has 

ever been married. 

505.5.3 Full-Time Student Defined 

Under the Railroad Retirement Act (RRA), children qualify as full-time students if they 

are age 18 through age 19 and in full-time attendance at an elementary or secondary 

school. For RRA purposes, students are generally considered to be in full-time 

attendance if the program is at least 13 weeks duration and is in accordance with the 

law of the State or other jurisdiction in which they reside. This includes: 

A. Enrollment in a public, private or religious elementary or secondary school 

course at least 13 weeks duration with minimum attendance of 20 hours per 

week; or, 

B. Enrollment in an independent study elementary or secondary education program 

administered by the school district in which the student resides; or, 

C. Home school elementary or secondary education in accordance with the 

standards and practices for home schooling in the State or other jurisdiction in 

which the student resides. This should be at least 20 hours a week in a course 

of study lasting at least 13 weeks. 

D. On-Line study that is in accordance with the standards in the State in which the 

student lives. The on-line study must be at least 13 week duration with a 

minimum of 20 hour per week study. 

A child cannot be entitled as a student if the child's employer asks or requires the child 

to attend school and pays the child for doing so. 

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A child can meet the definition of an FTS for some months in and after age 19 is 

attained. See FOM-I-535.10.3 for details. 

505.5.4 What is required for payment of student benefits 

An eligible child of the employee can be included as a student in the Retirement O/M 

computation when the Retirement O/M rate applies (see FOM-I-325.40 and FOM-I325.45) and the employee completes the required forms and submits any evidence 

requested by the RRB. 

An eligible child of the deceased employee is entitled to a survivor student annuity upon 

applying therefore, and submitting any evidence requested by the RRB, as explained in 

FOM-I-510.5. 

The RRB field office should assist the applicant/annuitant to the extent possible. 

However, the burden of proof is on the applicant/annuitant. 

505.5.5 One Application Concept 

An application for a child’s annuity filed by, or on behalf of, a minor child protects the 

child's rights to an RRB annuity as a disabled or student child when they attain age 18, 

provided there is no break in entitlement between the minor child annuity and the fulltime student or disabled child annuity. 

A. If a child is disabled before age 18, they to need only submit an informational 

supplement (Form AA-19a) and furnish the RRB with evidence of disability in 

order to receive their child disability benefits at age 18. 

B. If a child is in an elementary or high school students at an educational institution 

in the month they attain age 18, need only submit a Form G-315 and furnish the 

RRB with verification of their full-time attendance in order to receive student 

benefits at age 18. 

C. Children who are elementary or high school students in home schooling in the 

month they attain age 18, need only submit a Form G-315 and furnish the RRB 

with documentation of the home schooling described in FOM-I-525.10.2 in order 

to receive their student benefits at age 18. 

505.5.6 Special Retroactivity Provisions For Students 

Payments to the child will end with the month before the month that the children 

attained age 18 if the RRB does not receive evidence that they are full-time students. 

Provided the required proofs are submitted within 12 months of the month the child 

attained age 18, annuity payments may be reinstated from the month the child attained 

age 18. 

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EXAMPLE: Roger attained age 18 in 9-2008 and his child's annuity payments ended as 

of 8-31-2008. Roger was attending Central Catholic High School full-time but he failed 

to submit proof to the RRB of his status. He continued attending school full-time and 

filed a G-315 on 3-29-2009. Since he was in verified full-time attendance in 9-2008, the 

month he attained age 18, a new AA-19 application was not required to continue his 

entitlement. His annuity can be reinstated retroactive to 9-1-2008. 

505.5.7 Payee for Student 

Students are normally considered legally competent adults. All development will be with 

the students and payments will be made directly to them. 

505.15 Paid Students 

505.15.1 Part-Time Jobs 

Students who work part-time in a business while going to school and receiving pay for 

actual work done (e.g., working part-time in a business establishment and being paid by 

the hour) are considered Full-Time Student. This is true even though the employer 

hires only students of a particular school, or students taking a particular type of course, 

for a particular job. However, the usual work deductions are applicable. 

505.15.2 Work-study programs 

A student registered in a work-study program is a FTS as long as the Educational 

Institution (EI) considers the student to be in FTA. A student in such a program is 

considered to be in FTA while he is working at a job assigned to or obtained for him by 

the school, as an integral part of his instruction. In these cases, work deductions are 

applicable. 

505.15.3 Work Incentive Program (WIN) 

AFDC (Aid to Families with Dependent Children) recipients who enroll in the Work 

Incentive Program may receive a monthly incentive payment. They are not employees 

of the Federal government. They may meet the definition of an FTS if their training for 

employment requires full-time attendance at an EI. 

505.15.4 High School ROTC programs 

No allowances are made under a high school ROTC program. The participant is not on 

active duty and is not an employee of the Armed Forces while attending school. 

Therefore, the participant is included in the definition of an FTS. 505.15.5 Job Corps 

Persons enrolled in the Job Corps are excluded from the definition of a FTS. This is true 

even if they are attending school under this program. They are deemed to be 

employees of the Federal government. 

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505.15.5 Job Corps 

Persons enrolled in the Job Corps are excluded from the definition of a FTS. This is 

true even if they are attending school under this program. They are deemed to be 

employees of the Federal government. 

505.15.6 Other Economic and Human Development Programs 

The most recent major piece of job training legislation enacted by Congress was the 

Workforce Investment Act (WIA), which was enacted in 1998. WIA consolidated a 

number of Labor Department job training programs and created one-stop-centers in 

every state to help job seekers negotiate their way through the system of federal job 

training programs. 

Students attending an EI under these programs are excluded from the definition of a 

FTS if an employee-employer relationship exists and the student is paid by his employer 

for attending school. 

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