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3201 Provisions of the Act, as amended October 9, 1996

Section 2(c) of the Act provides in part that,

"(A) Generally

With respect to an employee who has ten or more years of service as 

defined in section 1(f) of the Railroad Retirement Act of 1974, who did not 

voluntarily retire and (in a case involving exhaustion of rights to benefits 

for days of unemployment) did not voluntarily leave work without good 

cause, and who had current rights to normal benefits for days of 

unemployment or days of sickness in a benefit year but has exhausted 

such rights, the benefit year in which such rights are exhausted shall be 

deemed not to be ended until the last day of the extended benefit period 

determined under this paragraph, and extended unemployment benefits or 

extended sickness benefits (depending on the type of normal benefit rights 

exhausted) may be paid for not more than 65 days of unemployment or 65 

days of sickness within such extended benefit period. 

(B) Beginning date

An employee's extended benefit period shall begin on the employee's first 

day of unemployment or first day of sickness, as the case may be, 

following the day on which the employee exhausts the employee's then 

current rights to normal benefits for days of unemployment or days of 

sickness and shall continue for 7 consecutive 14-day periods, each of 

which shall constitute a registration period, but no such extended benefit 

period shall extend beyond the beginning of the first registration period in 

a benefit year in which the employee is again qualified for benefits in 

accordance with section 3 on the basis of compensation earned after the 

first of such consecutive 14-day periods has begun."

Note: Prior to the 1996 amendments, extended benefit periods for 

employees with 10, but less than 15 years of service, consisted of 7 

consecutive 14-day registration periods, during which a maximum of 65 

days of benefits were payable. Extended benefit periods for employees 

with 15 or more years of service consisted of 13 consecutive 14-day 

registration periods, during which a maximum of 130 days of benefits were 

payable. The 1996 amendments limited payment of extended benefits to 

a maximum of 65 days during 7 consecutive registration periods for all 

employees. This change was effective with extended periods beginning 

after October 8, 1996.

3202 Provisions of the Regulations

See Railroad Retirement Board Regulations, Section 336.14.
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3203 Elements of Extended Benefit Provisions

3203.01 Exhaustion of Rights

An employee is deemed to have exhausted his or her current rights to normal 

benefits for days of unemployment in a benefit year if:

a. the employee has received unemployment benefits for 130 days of 

unemployment in the benefit year; or

b. the employee has received unemployment benefits in the benefit year 

equal to his or her base year compensation; or

c. at the end of the benefit year, during which the employee was qualified for 

benefits, the employee has received less than the maximum normal 

unemployment benefits for the benefit year and the employee is not 

qualified for benefits in the next succeeding benefit year. (An employee 

who, though qualified for benefits, has not established a right to 

unemployment benefits in a benefit year, may not be regarded as having 

"received less than the maximum normal unemployment benefits for the 

benefit year". A qualified employee establishes a right to benefits by filing 

an application and a compensable claim, or a claim satisfying the waiting 

period requirement.)

3203.02 Years of Service

a. Computing years of service

For purposes of extended benefit periods, "years of service" are years of service 

as defined in section 1(f) of the Railroad Retirement Act. This includes "prior" 

service (railroad service before 1937), as well as service subsequent to 1936; 

service subsequent to the base year; and any military service which is creditable 

under the Railroad Retirement Act (see AIM-19). In accordance with section 1(f) 

of the Railroad Retirement Act, 12 months of service constitute a year of service. 

Thus, an employee who has 120 months of service is considered to have 10 

years of service. 

b. Effective date

Ten years of service is considered to have been acquired by an employee as of 

the first day to which creditable compensation is attributable in his or her 120th 

month of service. Benefits for days of unemployment in an extended benefit 

period are not payable for any day before the date as of which the employee 

acquired the requisite years of service. Generally, an extended benefit period 

will not begin before that date.
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3203.03 Voluntary Leaving

a. In determining for purposes of an extended benefit period whether a 

leaving of work was "voluntary" and "without good cause", principles 

established in connection with determinations under section 4(a-2)(i) of 

the Railroad Unemployment Insurance Act are to be followed (see AIM15).

b. Under some circumstances a voluntary leaving without good cause does 

not prevent establishment of an extended benefit period. Only a voluntary 

leaving creating the need for the extended benefit period and reasonably 

related to the claimant's continued unemployment after the exhaustion of 

his or her normal benefits affects his or her entitlement to such a period. 

When an employee has been paid compensation equal to 2.5 times the 

applicable monthly compensation base for time after a voluntary leaving it 

may generally be assumed that the voluntary leaving did not create the 

need for an extended benefit period.

c. Any voluntary leaving of work which occurred before the base year is to be 

disregarded.

d. A voluntary leaving without good cause occurring after a date with respect 

to which the claimant meets all the conditions precedent to establishment 

of an extended benefit period does not prevent the establishment of an 

extended benefit period beginning on that date and does not terminate the 

period. Under the provisions of section 4(a-2)(i) of the Act, however, no 

day in the period beginning with the date of the voluntary leaving, and 

continuing until the claimant has been paid compensation of not less than 

2.5 times the applicable monthly compensation base with respect to time 

after the date of the voluntary leaving, can be a day of unemployment.

3203.04 Voluntary Retirement

a. In determining for purposes of extended benefit periods whether a 

claimant has voluntarily retired, principles established on that point in 

connection with determination as to availability for work should be followed 

(see AIM-8). In accordance with those principles, application for a 

retirement annuity is not in itself to be considered as conclusive evidence 

of voluntary retirement. Consideration must be given to any action of the 

claimant tending to limit his or her access to the labor market.

b. If a claimant is found to have voluntarily retired, the date of retirement is 

considered to be the date on which he or she took action showing that he 

or she was out of the labor market. In many cases this will be the date on 

which the claimant applied for the annuity or relinquished rights to return 

to service.
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c. Any voluntary retirement which occurred before the base year upon which 

the extended benefit period would be based does not prevent 

establishment of such a period.

d. Voluntary retirement occurring after a date with respect to which the 

claimant meets all the conditions precedent to establishment of an 

extended benefit period does not prevent establishment of an extended 

benefit period beginning on that date and does not terminate the period. 

In such a case, the claimant may receive benefits in the extended benefit 

period for days before the date of retirement, provided that he or she is 

available for work and meets the other requirements of the Act. Benefits 

for days on or after the date of retirement will not ordinarily be payable 

since the claimant ordinarily cannot meet the availability requirement.

3203.05 Beginning of Extended Benefit Period

a. An extended benefit period begins with the first day of unemployment after 

the day on which the claimant exhausts his or her rights to normal 

unemployment benefits. Such first day may fall within a registration period 

established in accordance with section 1(h) of the Act. An extended 

benefit period cannot begin in a benefit year in which the claimant is a 

qualified employee and with respect to which he or she has not exhausted 

his or her rights to normal unemployment benefits.

b. If at the time of establishment of an extended benefit period it is apparent 

that beginning the period with a particular day would clearly be to the 

claimant's disadvantage, no registration is deemed to have been made 

with respect to such day, and, accordingly, the period cannot begin with 

such day.

c. Although an extended benefit period does not have to begin immediately 

after the exhaustion of rights to normal benefits, its beginning cannot, as a 

practical matter, be deferred indefinitely. The following rule has been 

determined to be administratively practical. An extended benefit period 

may not begin later than the first June 30 after the last day of the benefit 

year with respect to which normal rights to benefits were exhausted.

Example A: An employee exhausts normal unemployment benefits for BY 22 on 

January 28, 2023; he is not qualified for BY 23. An extended unemployment 

benefit period may start at any time from January 29, 2023, up to and including 

June 30, 2024. 

Example B: An employee exhausts normal unemployment benefits for BY 22 on 

January 28, 2023; she receives some normal sickness benefits in BY 22 and 

exhausts those benefits on June 30, 2023, by reason of the ending of the general 

benefit year; an extended sickness benefit period is established for April 1 to July 

7, 2024. An extended unemployment benefit period may start at any time from 
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January 29, 2023 up to and including June 30, 2025, which is the first June 30 

after the ending of BY-22 as previously extended.

3203.06 Length of Extended Benefit Period

For an employee with 10 or more years of service, an extended benefit period 

runs for seven consecutive 14-day periods. Benefits are payable for not more 

than 65 days of unemployment in such an extended benefit period. Employees 

with less than 10 years of service are not eligible for extended benefits.

Note: For employees having 10, but less than 15 years of service, extended 

benefit periods with beginning dates prior to October 9, 1996, ran for seven 

consecutive 14-day periods. Benefits were payable for not more than 65 days of 

unemployment in such periods. For employees having 15 or more years of 

service, extended benefit periods with beginning dates prior to October 9, 1996, 

ran for 13 consecutive 14-day periods during which a maximum of 130 days of 

benefits were payable. If an employee acquired 15 years of service during an 

extended benefit period based on 10 years of service, the extended benefit 

period continued until the employee had 13 consecutive 14-day periods.

3203.07 Ending of Benefit Year

A benefit year with respect to which an extended benefit period is established for 

an employee does not end for that employee until the last day of the extended 

benefit period. When both an extended unemployment benefit period and an 

extended sickness benefit period are established, the benefit year does not end 

before the last day of the later of the two periods.

3203.08 Effect On Normal Sickness Benefits

A benefit year which, as a result of establishment of an extended unemployment 

benefit period, does not end until after the end of the general benefit year, is 

continued for sickness benefit purposes as well as for unemployment benefit 

purposes. Such continuation of the benefit year does not affect the limitation on 

amount of normal sickness benefits payable in the benefit year; the limit remains 

at 130 days or an amount equal to base year wages. Sickness benefits based 

on rights to benefits in the next succeeding general benefit year are not payable 

for any day before the day following the end of the extended unemployment 

benefit period.

3203.09 Sequence of Registration Periods

Each of the consecutive 14-day periods in an extended benefit period constitutes 

a registration period. Thus, once the beginning date of an extended benefit 

period has been established, the registration periods for extended benefits are 

fixed; the pattern of days of unemployment and any changes in place of 
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registration do not affect the beginning or ending dates of the registration 

periods. 

3203.10 Relationship of Extended Unemployment to Extended Sickness 

Benefits

An employee's exhaustion of rights to normal unemployment benefits may occur 

during an extended period based on exhaustion of rights to normal sickness 

benefits. In such a case the employee may begin another extended benefit 

period, this one based on his or her exhaustion of normal unemployment benefit 

rights. The establishment of this extended benefit period does not terminate the 

previously established extended sickness benefit period. The two extended 

benefit periods continue to exist independently, each for the period prescribed in 

the Act. Conversely, an employee who exhausted his or her sickness benefit 

rights during an extended unemployment benefit period could then have an 

extended sickness benefit period.

3204 Determining Entitlement to Extended Benefit Period

3204.01 Authority to Make Determinations

In most cases extended benefit periods are established by computer action, 

without examiner determination. In these cases information of record is sufficient 

to indicate entitlement. When information on the record does not warrant 

establishing an extended benefit period automatically, determination by an 

examiner is necessary. The examiners and specialists in the Office of ProgramsOperations are authorized to make such determinations. Some of the points to 

be considered in making determinations are discussed below.

3204.02 Years of Service

The number of years of service shown in the RRB's records is to be accepted as 

correct unless the employee has indicated that he or she has sufficient service to 

qualify for extended benefits, but the record shows insufficient service. If there is 

such an indication that the claimant may have more service than is shown on 

EDMA, the additional service should be developed in accordance with 

instructions in AIM-19.

3204.03 Voluntary Retirement and Voluntary Leaving

In most cases, no special information will be needed on these points because the 

field office would have denied claims for normal benefits if the claimant had 

voluntarily retired or voluntarily left work without good cause. If there is doubt on 

either point, investigation should be made.
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3204.04 Establishing Beginning Date

If the claimant is found to meet the requirements for an extended benefit period, 

the beginning and ending dates of the period are to be determined. If beginning 

the extended benefit period with a particular day would result in there being less 

than five days unemployment in the first 14 days, the extended benefit period 

should not ordinarily be begun with such day since to do so would clearly be to 

the claimant's disadvantage. In such a case, no registration for the day would be 

considered to have been made and consequently it would not be a day of 

unemployment. 

3205 Notice to Claimant

3205.01 Claimant Held Entitled

Form Letter ID-20-5 serves as notice that a claimant is entitled to an extended 

unemployment benefit period. Such notice is usually automatically sent by the 

computer when the claimant exhausts his or her rights to normal unemployment 

benefits and is entitled to an extended benefit period.

3205.02 Claimant Not Entitled

Notice of a determination that an extended unemployment benefit period cannot 

be established is to be sent to the claimant. The notice is to explain why an 

extended benefit period cannot be established, and is to be mailed in each case 

in which benefits are denied on the basis of such a determination.

3206 Determination on Claims in an Extended Benefit Period

Claims for days in an extended unemployment benefit period are to be 

adjudicated in accordance with instructions in the AIM. When a claim ending on 

one of the 14 days before the end of the extended period is processed, the 

claimant is to be advised that his or her extended benefit period is about to end. 

If the extended benefit period ends before the end of the general benefit year, 

Form Letter ID-32c is to be sent; otherwise Form Letter ID-32d should be sent.

3221 Provisions of the Act, as amended October 9, 1996

Section 2(c) of the Act provides in part that,

"(A) Generally

With respect to an employee who has ten or more years of service as 

defined in section 1(f) of the Railroad Retirement Act of 1974, who did not 

voluntarily retire and (in a case involving exhaustion of rights to benefits 

for days of unemployment) did not voluntarily leave work without good 

cause, and who had current rights to normal benefits for days of 
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unemployment or days of sickness in a benefit year but has exhausted 

such rights, the benefit year in which such rights are exhausted shall be 

deemed not to be ended until the last day of the extended benefit period 

determined under this paragraph, and extended unemployment benefits or 

extended sickness benefits (depending on the type or normal benefit 

rights exhausted) may be paid for not more than 65 days of 

unemployment or 65 days of sickness within such extended benefit period.

(B) Beginning date

An employee's extended benefit period shall begin on the employee's first 

day of unemployment or first day of sickness, as the case may be, 

following the day on which the employee exhausts the employee's then 

current rights to normal benefits for days of unemployment or days of 

sickness and shall continue for 7 consecutive 14-day periods, each of 

which shall constitute a registration period, but no such extended benefit 

period shall extend beyond the beginning of the first registration period in 

a benefit year in which the employee is again qualified for benefits in 

accordance with section 3 on the basis of compensation earned after the 

first of such consecutive 14-day periods has begun.

Note: Prior to the 1996 amendments, extended benefit periods for 

employees with 10, but less than 15 years of service, consisted of 7 

consecutive 14-day registration periods, during which a maximum of 65 

days of benefits were payable. Extended benefit periods for employees 

with 15 or more years of service consisted of 13 consecutive 14-day 

registration periods, during which a maximum of 130 days of benefits were 

payable. The 1996 amendments limited payment of extended benefits to 

a maximum of 65 days during 7 registration periods for all employees. 

The change was effective with extended periods beginning after October 

8, 1996.

(C) Termination when employee reaches age 65

Notwithstanding any other provision of this paragraph, an extended benefit 

period for sickness benefits shall terminate on the day next preceding the 

date on which the employee attains age 65, except that it may continue for 

the purpose of paying benefits for days of unemployment."

3222 Provisions of the Regulations

See Railroad Retirement Board Regulations, Section 336.14.
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3223 Elements of Extended Benefit Provision

3223.01 Exhaustion of Rights

An employee is deemed to have exhausted his or her current rights to normal 

benefits for days of sickness in a benefit year if:

a. an employee has received sickness benefits for 130 days of sickness in 

the benefit year; or

b. an employee has received sickness benefits in the benefit year equal to 

his or her base year compensation; or

c. at the end of the benefit year during which the employee was qualified for 

benefits, the employee has received less than the maximum normal 

sickness benefits for the benefit year and the employee is not qualified for 

benefits in the next succeeding benefit year. (An employee who, though 

qualified for benefits, has not established a right to sickness benefits in a 

benefit year, may not be regarded as having "received less than the 

maximum normal sickness benefits for the benefit year". A qualified 

employee establishes a right to benefits by filing a statement of sickness 

and a compensable claim, or a claim satisfying the waiting period 

requirement.)

3223.02 Years of Service

a. Computing years of service

For purposes of extended benefit periods, "years of service" are years of service 

as defined in section 1(f) of the Railroad Retirement Act. Service includes "prior" 

service (railroad service before 1937), as well as service subsequent to 1936; 

service subsequent to the base year; and any military service which is creditable 

under the Railroad Retirement Act (see AIM-19). In accordance with section 1(f) 

of the Railroad Retirement Act, 12 months of service constitute a year of service. 

Thus, an employee who has 120 months of service is considered to have 10 

years of service.

b. Effective date

Ten years of service is considered to have been acquired by an employee as of 

the first day to which creditable compensation is attributable in his or her 120th 

month of service. Benefits for days of sickness in an extended benefit period are 

not payable for any day before the date as of which the employee acquired the 

requisite years of service. Generally, an extended benefit period will not begin 

before that date.
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3223.03 Voluntary Retirement

a. In determining for purposes of an extended benefit period whether a 

claimant has voluntarily retired, principles established on that point in 

connection with determination as to availability for work should be followed 

(see AIM-8). In accordance with those principles, application for a 

retirement annuity is not in itself to be considered as conclusive evidence 

of voluntary retirement. Consideration must be given to any action of the 

claimant tending to limit his or her access to the labor market.

b. If a claimant is found to have voluntarily retired, the date of retirement is 

considered to be the date on which he or she took action showing that he 

or she was out of the labor market. In many cases this will be the date on 

which the claimant applied for the annuity or relinquished rights to return 

to service.

c. Any voluntary retirement which occurred before the base year upon which 

the extended benefit period would be based does not prevent 

establishment of such a period.

d. Voluntary retirement occurring after a date with respect to which the 

claimant meets all the conditions precedent to establishment of an 

extended benefit period does not prevent establishment of an extended 

benefit period beginning on that date and does not terminate the period.

3223.04 Effect of Attaining Age 65

a. Extended sickness benefits are not payable for the day on which an 

employee attains age 65 or for any day thereafter.

b. An extended sickness benefit period terminates for the purpose of paying 

sickness benefits on the day next preceding the date on which the 

employee attains age 65. But it may be continued for the purpose of 

paying unemployment benefits.

c. An extended sickness benefit period continues for the purpose of paying 

unemployment benefits until (1) the end of the seventh (or thirteenth) 

registration period of the extended benefit period or until (2) the employee 

again becomes entitled to normal sickness benefits. That is, if the 

employee is qualified for benefits in a later benefit year and applies for 

sickness benefits in that year and is found entitled to them, the extended 

sickness benefit period then terminates for unemployment benefit 

purposes.

To illustrate this point, assume that an employee with 10 years of service 

exhausts his normal BY-22 sickness benefits on May 14, 2023. He begins 

an extended sickness benefit period of 7 registration periods on May 15, 
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2023. On June 10, 2023 he becomes age 65. Consequently, the 

extended sickness benefit period terminates for the purpose of paying 

sickness benefits on June 9, 2023. But it may continue for the purpose of 

paying unemployment benefits, as illustrated below.

Example 1 The employee recovers from his sickness and becomes able 

to work on July 15, 2023. He claims normal BY-22 unemployment 

benefits from July 15 through August 20, the end of the extended sickness 

benefit period. He is a qualified employee for BY-23, so he receives 

normal BY-23 unemployment benefits beginning August 21, 2023. 

Example 2 As in Example 1, the employee claims normal BY-22

unemployment benefits beginning July 15, 2023. However, he exhausts 

those benefits on August 1, 2023. He therefore begins an extended BY-23

unemployment benefit period on August 2, 2023. That period runs for 7 

registration periods.

Example 3 As in Example 1, the employee claims and receives normal 

unemployment benefits beginning July 15, 2023. However, he becomes 

sick again on August 1, 2023. Since he is qualified for BY-23, he claims 

and receives normal BY-23 sickness benefits beginning August 1, 2023. 

In this instance the extended sickness benefit period which was continued 

for unemployment benefit purposes beyond age 65 ends for 

unemployment benefit purposes on July 31, 2023. 

Example 4 The employee does not become able to work. He claims 

and receives normal BY-23 sickness benefits beginning July 1, 2023. 

Therefore, the extended sickness benefit period was not continued at all 

for the purpose of paying unemployment benefits.

3223.05 Beginning of Extended Benefit Period

a. An extended sickness benefit period begins with the first day of sickness 

after the day on which the claimant exhausts his or her rights to normal 

sickness benefits. Such first day may fall within a registration period 

established in accordance with section 1(h) of the Act. An extended 

sickness benefit period cannot begin in a benefit year in which the 

claimant is a qualified employee and with respect to which he or she has 

not exhausted his or her rights to normal sickness benefits.

b. If at the time of establishment of an extended sickness benefit period it is 

apparent that beginning the period with a particular day would clearly be to 

the claimant's disadvantage, it is considered that there is no statement of 

sickness with respect to such day, and, accordingly, the period cannot 

begin with such day.
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c. Although an extended benefit period does not have to begin immediately 

after the exhaustion of rights to normal benefits, its beginning cannot, as a 

practical matter, be deferred indefinitely. The following rule has been 

determined to be administratively practical. An extended benefit period 

may not begin later than the first June 30 after the last day of the benefit 

year with respect to which normal rights to benefits were exhausted.

Example A: An employee exhausts sickness benefits for BY-22 on 

January 5, 2023; he is not qualified for BY-23. An extended sickness 

benefit period may start at any time from January 6, 2023, up to and 

including June 30, 2024. 

Example B: An employee exhausts BY-22 sickness benefits on January 

5, 2023; she receives some normal unemployment benefits in BY-22 and 

exhausts those benefits on June 30, 2023, by reason of the ending of the 

general benefit year. An extended unemployment benefit period is 

established for April 1 to July 7, 2024. An extended sickness benefit 

period may start as late as June 30, 2025, which is the first June 30 after 

the ending of BY-22 as previously extended.

3223.06 Length of Extended Benefit Period

For an employee with 10 or more years of service, an extended benefit period 

runs for seven consecutive 14-day periods. Benefits are payable for not more 

than 65 days of sickness in such an extended benefit period. Employees with 

less than 10 years of service are not eligible for extended benefits.

Note: For employees having 10, but less than 15 years of service, extended 

benefit periods with beginning dates prior to October 9, 1996, ran for seven 

consecutive 14-day periods. Benefits were payable for not more than 65 days of 

sickness in such periods. For employees having 15 or more years of service, 

extended benefit periods with beginning dates prior to October 9, 1996, ran for 

13 consecutive 14-day periods during which a maximum of 130 days of benefits 

were payable. If an employee acquired 15 years of service during an extended 

benefit period based on 10 years of service, the extended benefit period 

continued until the employee had 13 successive 14-day periods.

3223.07 Ending of Benefit Year

A benefit year with respect to which an extended sickness benefit period is 

established for an employee does not end for that employee until the last day of 

the extended benefit period. When both an extended sickness benefit period and 

an extended unemployment benefit period are established, the benefit year does 

not end before the last day of the later of the two periods.
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3223.08 Effect on Normal Unemployment Benefits

A benefit year which, as a result of establishment of an extended sickness 

benefit period, does not end until after the end of the general benefit year, is 

continued for unemployment benefit purposes as well as for sickness benefit 

purposes. Such continuation of the benefit year does not affect the limitation on 

amount of normal unemployment benefits payable in the benefit year; the limit 

remains at 130 days or an amount equal to base year wages. Unemployment 

benefits based on rights to benefits in the next succeeding general benefit year 

are not payable for any day before the day following the end of the extended 

sickness benefit period.

3223.09 Sequence of Registration Periods

Each of the consecutive 14-day periods in an extended sickness benefit period 

constitutes a registration period. Thus, once the beginning date of an extended 

benefit period has been established, the registration periods for extended 

benefits are fixed; the pattern of days of sickness does not affect the beginning or 

ending dates of the registration periods.

3223.10 Relationship of Extended Sickness to Extended Unemployment 

Benefits

An employee's exhaustion of rights to normal sickness benefits may occur during 

an extended benefit period based on exhaustion of rights to normal 

unemployment benefits. In such a case the employee may begin another 

extended benefit period, this one based on his or her exhaustion of normal 

sickness benefit rights. The establishment of this extended benefit period does 

not terminate the previously established extended unemployment benefit period. 

The two extended benefit periods continue to exist independently, each for the 

period prescribed in the Act. Conversely, an employee who exhausted his or her 

unemployment benefit rights during an extended sickness benefit period could 

then have an extended unemployment benefit period.

3224 Determining Age 65

An employee attains age 65 on the day before his or her sixty-fifth birthday. 

Thus, an employee born on January 15, 1955 attains age 65 on January 14, 

2020. For purposes of determining an employee's rights to benefits in an 

extended sickness benefit period, the adjudicating office may rely on evidence of 

age in the RRB's records and files at the time the determination is made. In the 

absence of fraud, a determination allowing benefits in an extended sickness 

benefit period is not to be disturbed although based on evidence as to age later 

found to be incorrect. But no additional benefits may be paid on the basis of the 

incorrect evidence. In determining whether an employee has attained age 65, 

the adjudicating office is to consider the evidence of age in the Employment Data 

Maintenance system (EDMA) and in the employee's application for benefits.
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3225 Determining Entitlement to Extended Benefit Period

3225.01 Authority to Make Determinations

In most cases extended benefit periods are established by computer action, 

without examiner determination. In these cases information of record is sufficient 

to indicate entitlement. When information on the record does not warrant 

establishing an extended benefit period automatically, determination by an 

examiner is necessary. The examiners and specialists in the Office of ProgramsOperations are authorized to make such determinations. Some of the points to 

be considered in making determinations are discussed below.

3225.02 Years of Service

The number of years of service shown in the RRB's records is to be accepted as 

correct unless the employee has indicated that he or she has sufficient years of 

service to qualify for extended benefits, but the record shows insufficient service. 

If there is such an indication that the claimant may have more service than is 

shown on EDMA, the additional service should be developed in accordance with 

instructions in AIM-19.

3225.03 Voluntary Retirement

In the absence of evidence to the contrary it may be determined that the claimant 

did not voluntarily retire. If the claimant is receiving an annuity under the 

Railroad Retirement Act there is a possibility that he or she voluntarily retired. 

Also, if the claimant is over 60 years of age and there is a gap of a month or 

more between the last day he or she worked and the first day of infirmity, the 

claimant may have retired before the infirmity began. In these types of cases, an 

investigation and a determination are necessary.

3225.04 Action on Evidence of Age

The clearance portion of the RUIA claimant record contains the employee's year 

of birth as shown on EDMA and the year of birth as shown on his or her 

application for benefits. To determine whether an employee has attained age 65, 

both of these years must be checked. Action is to be taken in accordance with 

instructions in the examples below.

Example 1: Both years of birth show that the employee attained age 65 before 

the calendar year in which the extended sickness benefit period would begin. In 

this case an extended sickness benefit period should not be established.

Example 2: Both years of birth show that the employee will not attain age 65 

until after the calendar year in which the extended sickness benefit period would 

end. In this case it may be determined that the employee has not attained age 

65 and will not attain it during the extended benefit period.
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Example 3: Both years of birth agree and show that the employee will attain 

age 65 during the calendar year in which the extended sickness benefit period 

would begin or would end. In this case, the full date of birth as shown on the 

application for benefits is to be accepted as correct.

a. If the date of birth on the application indicates that the employee attained 

age 65 before the date the extended period would begin, an extended 

benefit period should not be established.

b. If the employee will attain age 65 after the end of the extended period, the 

extended period may be established.

c. If the employee will attain age 65 during the extended benefit period, the 

extended period may be established, but a stop is to be entered on the 

record.

Example 4: The years of birth do not agree and the earlier shows that the 

employee will attain age 65 before or during the calendar year in which the 

extended period would begin or end.

a. If the employee is receiving an RRA annuity, check the DATAQ record.

1. If the date of birth is established on the DATAQ record, accept it.

2. If the date of birth is not established on the DATAQ record, proceed 

as in b below.

b. If the employee is not receiving an RRA annuity and 

1. the application year is earlier, accept the date of birth shown on the 

application. If the date of birth is not shown on the application, 

proceed as in 2. below.

2. the application year is later, mail the employee a letter requesting 

that he or she submit proof of date of birth if he or she has not 

attained age 65.

Example 5: One year of birth is missing (either the year is missing from EDMA 

or the year is missing from the application and is not found on an application).

a. If the employee is receiving an RRA annuity, check the DATAQ record.

1. If a date of birth is established on DATAQ, accept it.

2. If a date of birth is not established on DATAQ, proceed as in b. 

below.

b. If the employee is not receiving an RRA annuity and
AIM 32

AIM Art_32 Extended Benefit Periods Revised Dec 1, 2022 Page 16 of 17

1. the year of birth shown indicates that the employee is less than age 

65, mail the claimant a letter requesting a report of his or her date 

of birth and proof, if available.

2. the year of birth shown indicates that the employee is 65, send the 

claimant a letter informing him or her that he or she will have to 

submit proof of date of birth if he or she has not attained age 65.

3225.05 Establishing Beginning Date

If the claimant is found to meet the requirements for an extended benefit period, 

the beginning and ending dates of the period is to be determined. If beginning 

the extended benefit period with a particular day would result in there being less 

than five days of sickness in the first 14 days, the extended benefit period should 

not ordinarily be begun with such day since to do so would clearly be to the 

claimant's disadvantage. In such a case, no registration for the day would be 

considered to have been made and consequently it would not be a day of 

sickness.

3226 Notice to Claimant

3226.01 Claimant Held Entitled

Form Letter ID-20-7 serves as notice that a claimant is entitled to an extended 

sickness benefit period. Such notice is usually automatically sent by the 

computer when the claimant exhausts his or her rights to normal sickness 

benefits and is entitled to an extended benefit period.

3226.02 Claimant Not Entitled

Notice of a determination that an extended sickness benefit period cannot be 

established is to be sent to the claimant. The notice should explain why an 

extended benefit period cannot be established, and is to be mailed in each case 

in which benefits are denied on the basis of such a determination.

3227 Determination on Claims in an Extended Benefit Period

Claims for days in an extended sickness benefit period are to be adjudicated in 

accordance with instructions in the AIM. When a claim ending on one of the 14 

days before the end of the extended period is processed, the claimant is to be 

advised that his or her extended benefit period is about to end. If the extended 

benefit period ends before the end of the general benefit year, Form Letter ID32g is to be sent; otherwise, Form Letter ID-32h should be sent.