Rail Employer Reporting Instructions

Part VII – Additional Communications About Service and Compensation Reports

Chapter 3: Form Letter GL-99, Employer's Deemed Service Month Questionnaire

1

Deemed Service Months

In order to complete Form Letter GL-99, Employer's Deemed Service Month Questionnaire, an 

understanding of deemed service months is necessary.

Effective January 1, 1985, additional service months may be deemed in some cases where an 

employee does not actually work in every month of the year. An employee may never be 

credited with more than 12 service months in any calendar year and the employee must be in an 

employment relation with a covered railroad employer in order for that month to be deemed.

Deemed Service Month Calculation

To determine the maximum number of deemed months for an employee for a year:

Step Action

1 Multiply the number of reported service months by 1/12 the annual Tier II maximum 

compensation for the year.

2

Subtract this product from the reported Tier II compensation. If the result is zero or 

negative, no deemed months are possible. If the result is a positive amount, go to Step 

3.

3 Divide by 1/12 the Tier II maximum compensation.

4 Round up to a whole number.

This is the maximum, or potential number of deemed service months. The actual number of 

deemed months will depend on whether the employee has an employment relation in the months 

not worked.

Form GL-99, Employer's Deemed Service Month Questionnaire

Employers do not report deemed service months and the deeming of service months has no effect 

on the employer's report of service and compensation or tax liability. Deemed service months are 

determined and recorded by the RRB. Where the employee's Tier II compensation would yield 

additional service but an employment relationship is not apparent, the employer must provide 

that information by responding to Form GL-99, Employer's Deemed Service Month 

Questionnaire.

Note: Employers can however report employment relation information on their annual report by 

using two new service month codes. The RRB has added service month codes for employers to 

report employment relation information for non-worked months. (8 = employment relationship; 9

= no employment relationship). The new codes would be used in place of code 0. See Part V, 

Chapter 3 for information on using these codes on Form BA-3.

Form GL-99 is designed to obtain information as to whether an employment relation exists in 

certain months. The person completing the form need only answer "Yes" or "No" to question 8. 

The “remarks” section is for supplementary information you may wish to provide; it should not 
Rail Employer Reporting Instructions

Part VII – Additional Communications About Service and Compensation Reports

Chapter 3: Form Letter GL-99, Employer's Deemed Service Month Questionnaire

2

be used instead of answering question 8 directly. A prompt reply will eliminate the need for the 

RRB to trace for GL-99 replies. 

Note: Form GL-99 also requires a Form BA-4, "Report of Creditable Compensation 

Adjustments", in addition to a response if you advise that the service and compensation 

previously reported was incorrect.