PA 328 required Michigan tax-supported community colleges to submit data to ORS related to their employees who were enrolled as students between July 1, 2014, and June 30, 2018. It required that ORS prepare a legislative report summarizing this data by Jan. 31, 2019.

PA 512 determined that all part-time student employees be reported for the period from July 1, 2014, through June 30, 2018, and gives ORS the authority to administer the reporting adjustment process. It also states that current part-time student employees who were reportable at any time between July 1, 2017, and June 30, 2018, shall be offered a one-time election to continue to be reported as a part-time student or to opt out of being reported effective July 1, 2018.

PA 512 also addresses part-time student employees who worked before July 1, 2014, but were not reported. A person in this group can apply to establish membership in the retirement plan and/or claim unreported prior service by paying the member contributions associated with the prior service. The community college that employed the person will verify eligibility and is responsible for paying employer contributions on the wages for any service claimed by a person who pays member contributions in full.

The laws passed in 2018 treat these groups of students differently and require different remedies for part-time students who were not reported (or were reported during FY 2018).

For non-reported eligible employees, ORS will adjust records dated between July 1, 2014, through June 30, 2018. You're required to make adjustments as needed for records dated July 1, 2018, through the date shown on the file you receive from ORS through the FTS, which will be named 328[Your reporting unit number]. This is called the PA 328 file. 

For employees who worked between July 1, 2017, and June 30, 2018, ORS will send you an email notifying you of a PA 328 file available on the FTS by mid-September. That file will provide the information you need to make reporting changes for students whose forms were returned.

The PA 328 file will show each student employee’s name, social security number, member plan, and the action to take (Continue reporting, Stop reporting, or Begin reporting). It will show the due date for actions as well.

Sample PA 328 file table, illustrating various possible actions:

Consider the example of Jane Doe in the sample file above. Jane worked in FY 2018, but she was not reported. ORS used data from the report you submitted as part of PA 328 to create an account for her and added her service hours from her first day worked through June 30, 2018. She elected the Pension Plus Plan and opted to continue being reported as a part-time student.

You must begin reporting her on your next open detail report. Then you must make adjustments to show her hours earned on or after July 1, 2018, (the period after ORS’ adjustments), in accordance with her choice to opt in. Adjustments must be completed by the date shown in the PA 328 file.

Consider the example of John Jones in the sample file above. John worked in FY 2018 and your reporting unit has been reporting him. He decided not to continue being reported as a part-time student. You'll stop reporting him beginning with your next open detail report. 

You'll also make negative adjustments to reverse all reported wages and service earned after July 1, 2018, (the effective date of his opt-out decision). Adjustments must be completed by the date shown in the PA 328 file. If John continues to work for you but stops being a student (part-time or full-time), he will become an active member again and you would begin reporting him at that time.

Consider the example of Sam Smith in the sample file above. Sam worked in FY 2018 and you have been reporting him. He decided to continue being reported as a part-time student, so no change is needed. The information provided in the PA 328 file confirms that he chose to continue being reporting as a part-time student.

These students were reportable members as well. If they were never reported, ORS created accounts for them (using the default plan at that time, Pension Plus Plan) and entered their service into the retirement system based on the data you provided. ORS will send them a letter to explain that they are Michigan Public School Employees' Retirement System members. You will be (or have been) invoiced for member and employer contributions for these employees.

These students were reportable members as well. If they were never reported, ORS created accounts for them (using the default plan at that time, Pension Plus Plan) and entered their service into the retirement system based on the data you provided. ORS will send them a letter to explain that they are Michigan Public School Employees' Retirement System members. You will be (or have been) invoiced for member and employer contributions for these employees.

If the employee stopped working before July 1, 2018, there is nothing more you need to do. If the employee was reported and stopped working on or after July 1, 2018, you still need to make adjustments to their records for the period between July 1, 2018, and the date they stopped working.

ORS determined eligibility and made adjustments to the employee’s account based on the data you provided, which went through June 30, 2018.

• If a PA 328 file says to begin reporting and you are already reporting the person (as a non-student employee), continue to report.
• If a PA 328 file says to stop reporting, but the employee is no longer a student, make negative adjustments to all records between July 1, 2018, and the date the employee was no longer a student. At that point, the employee became an active member, and reporting should begin with that pay cycle.

ORS determined eligibility and made adjustments to the employee’s account based on the data you provided, which went through June 30, 2018. If the employee’s status changed since that date, please contact ORS at 800-381-5111 and enter your reporting unit number. Full-time students shouldn't be reported.

Adjustments must be made within 20 business days from the date shown on the PA 328 file you receive from ORS. The due date will be included in the PA 328 file.

Each community college will receive one PA 328 file showing all students who had an election and how to report them and/or make adjustments. The file will be sent through FTS by mid-September.

ORS will reach out using a variety of marketing strategies. Those who see or hear our outreach message will be directed to a website where they can find more information.

People who review the website information and believe they are eligible will download an employment verification form and submit it to ORS, along with documentation supporting their claim, such as student transcripts and W-2 forms. ORS will review forms for completeness and minimum qualifications, then contact the community college shown on the form for further verification.

ORS will send you a list of former employees that were granted service along with the retirement plan they were placed in. We will invoice your reporting unit for the employer contributions on the service claimed by these former employees. Since the final deadline for the member contribution payment is June 30, 2020, your college could be invoiced as late as July 2020. As more information becomes available, we will update this answer here and in an email.

Yes. As needed until February 2020, ORS will email you data files with information to be verified, pulled from the forms submitted by former student employees. You'll return the data file with verification data for each employee. For eligible employees you'll provide reportable wages and service by pay period. If you determine a person isn't eligible to be reported, you'll note that fact (with an explanation) in the data file you send back to ORS. Further instructions will be provided with the first file through email.

The PA 512 file will show each person’s name, former name (if applicable), the last four digits of the SSN, as well as the span of dates the person reports that he or she was a part-time student employee. Further detail and instructions will be provided with the first file through email.

We don’t know how frequently we’ll receive forms from people or how many we’ll receive. When ORS receives these forms, we'll return any incomplete forms (including those without documentation) or otherwise unacceptable forms (for example, if the college listed is not a Michigan Public School Employees' Retirement System community college). For people with acceptable forms, ORS will send you an email whenever we have one or more requests for your college. The deadline for submitting a request form is Jan. 31, 2020, so the last PA 512 file could be sent as late as February 2020.

The PA 512 files ORS sends you will have instructions for how to report your findings.

The PA 512 file we send you will have instructions for how to report your findings. In some cases, ORS may make a determination regarding people in this category.

You should provide the data you have, including dates. The employment verification request we send you will have instructions for how to report your findings.

The PA 512 file will include begin dates and end dates provided by the former employee. Work with your registrar and the person’s transcript to confirm the pay periods when the student was enrolled part-time.  

Consistent with the prevailing definition across community colleges, ORS defines part-time students as those enrolled with 11 or fewer credit hours (5 or fewer credit hours for a summer semester or term). A student who is enrolled part-time in the terms on either side of a summer term is considered to still be a part-time student during the summer months.

Initial communications postcard, letters, and forms

Postcard

Making a Retirement Choice (R3747) (PDF, 1 MB) postcard and email with website link targeted to member’s plan sent April 9, 2019.

Letters and forms

Communication varies based on the first day worked. Initial letters and forms were sent April 16, 2019. Reminder letters were sent on May 15, 2019, and June 11, 2019.

Weren't reported and received an opt-in form with plan election:

• Part-Time Student Employee Retirement Plan Election and Participation (R3728C) (PDF, 693 KB) letter and Retirement Plan Election and Participation (R3723C) (PDF, 768 KB) form for Pension Plus Plan or DC Plan. 
• Part-Time Student Employee Retirement Plan Election and Participation (R3727C) (PDF, 707 KB) letter and Retirement Plan Election and Participation (R3724C) (PDF, 795 KB) form for Pension Plus 2 Plan or DC Plan.

Were reported and received an opt-in form with no plan election:

• Part-Time Student Employee Retirement Plan Election (R3768C) (PDF, 675 KB) letter and Part-Time Student Employee Retirement Plan Participation (R3757C) (PDF, 761 KB) form for any plan. 

Confirmation letters

Sent after opt-in form was returned to ORS or after June 28, 2019:

• Reported (no plan election) – Opted in confirmation letter (R3766C) (PDF, 688 KB) for any plan.
• Reported (no plan election) – Opted out confirmation letter (R3758C) (PDF, 703 KB) for Pension Plus and Pension Plus 2 plans.
• Reported (no plan election) – Opted out confirmation letter (R3755C) (PDF, 701 KB) for the DC Plan.

Elected a plan and opted in:

• Pension Plus Plan welcome letter (R3744C) (PDF, 684 KB).
• Pension Plus 2 Plan welcome letter (R3742C) (PDF, 699 KB).
• DC Plan welcome letter (R3741C) (PDF, 688 KB).

Elected a plan and opted out:

• Pension Plus Plan opt-out confirmation letter (R3745C) (PDF, 680 KB).
• Pension Plus 2 Plan opt-out confirmation letter (R3750C) (PDF, 679 KB).
• DC Plan opt-out confirmation letter (R3718C) (PDF, 682 KB).

No form returned, opted out by default:

• Pension Plus Plan opt-out without form letter (R3765C) (PDF, 711KB).
• DC Plan opt-out without form letter (R3769C) (PDF, 667 KB). 

Your public school employees' retirement plan (R5056C) (PDF, 697 KB) letter explaining they are members and welcoming them to the retirement plan.

Initial communications postcard, letters, and forms

Postcard

Remember those college days (R1201C) (PDF, 393 KB) postcard and email with website link targeted to member’s plan.

Letters and forms

Initial request:

• Part-time Community College Student Employment Verification Request (R3800C) (PDF, 119 KB). 

Form received with missing documents:

• Request for Required Documents (R5011C) (PDF, 692 KB).

Form received with missing information:

• More Information Needed to Process Your Employment Verification (R5012C) (PDF, 680 KB).

Eligibility letters:

• Part-Time Student Employee Retirement Plan Eligibility (R5010C) (PDF, 674 KB) – Doesn't meet basic criteria.
• Part-Time Student Employee Retirement Plan Eligibility (R5013C) (PDF, 129 KB) – Ineligible (specific reason to be added by ORS).
• Part-Time Student Employee Service Confirmation (R5036C) (PDF, 667 KB) – Community college employment has already been reported. There's no additional service to be added. 
• Option to Participate in Retirement System No Longer Available (R5015C) (PDF, 688 KB)– Missed the deadline to submit form.
• Option to Participate in Retirement System No Longer Available (R5032C) (PDF, 673 KB) – Missed deadline to submit required documents to prove eligibility.

Estimate letters and forms

Eligible applicants receive an estimate letter and an opt-in form to establish membership or add service and, in some cases, to make a plan selection based on their first day worked. Eligible applicants whose first day worked falls within the election window for the 2012 reform will be offered the reform election. ORS will communicate with these applicants on a case-by-case basis.

Eligible applicants who return the form and opt to establish membership or add prior service will receive a billing statement for member contributions. Those who pay the member contributions in full by June 30, 2020, will receive confirmation letters.

Establishing membership that wasn't previously reported:

• Part-Time Student Employee Retirement Plan Election (R5016C) (PDF, 709 KB) estimate letter for all plans. 
• Your Retirement Plan Election (R5060C) (PDF, 761KB) form for Basic Plan. 
• Your Retirement Plan Election (R5066C) (PDF, 769 KB) form for Member Investment Plan (MIP) Graded. 
• Your Retirement Plan Election (R5069C) (PDF, 761KB) form for MIP Plus. 
• Your Retirement Plan Election (R5072C) (PDF, 773KB) form for Pension Plus Plan with a healthcare election. 
• Your Retirement Plan Election (R5074C) (PDF, 783 KB) form for Pension Plus Plan or DC Plan. 

Adding service for existing members:

• Part-Time Student Employee Service Credit Election (R5022C) (PDF, 700 KB) estimate letter for all plans.
• Your Service Credit Election (R5063C) (PDF, 737 KB) form for all plans. 

Adding service with a plan election:

• Part-Time Student Employee Retirement Plan Election (R5017C) (PDF, 710 KB) estimate letter for all plans. 
• Your Retirement Plan Election (R5061C) (PDF, 761KB) form for Basic Plan. 
• Your Retirement Plan Election (R5064C) (PDF, 763 KB) form for MIP Fixed.
• Your Retirement Plan Election (R5067C) (PDF, 756 KB) form for MIP Graded. 
• Your Retirement Plan Election (R5070C) (PDF, 761KB) form for MIP Plus. 
• Your Retirement Plan Election (R5073C) (PDF, 769 KB) form for Pension Plus Plan with a healthcare election. 
• Your Retirement Plan Election (R5075C) (PDF, 773 KB) form for Pension Plus Plan or DC Plan.