PA 328 FAQs

Do we need to make adjustments to past reporting records for part-time student employees who were not reported?

For non-reported eligible employees, ORS will adjust records dated between July 1, 2014 through June 30, 2018. You are 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 File Transfer Service (FTS) which will be called 328<<reportingunitnumber>> (328 file).

How will you tell us which employees need changes in reporting?

For employees who worked between July 1, 2017 and June 30, 2018, ORS will send you an email notifying you of a 328 file available on the File Transfer Service by mid-September. That file will provide the information you need to make reporting changes for students whose forms were returned. (Updated 8/21/2019)

What information will be included on the 328 file?

The 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 328 file, illustrating various possible actions:

What does “Begin reporting, make adjustments…” mean?

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’s adjustments), in accordance with her choice to opt in. Adjustments must be completed by the date shown in the 328 file.

What does “Stop reporting, make adjustments…” mean?

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 will stop reporting him beginning with your next open detail report. 

You will 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 328 file. If John continues to work for you but stops being a student (part-time or full-time), he would become an active member again and you would begin reporting him at that time.

What does “Continue reporting (no adjustments needed)” mean?

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 328 file confirms that he chose to continue being reporting as a part-time student.

What should we tell a part-time student employee who was not contacted by ORS but believes they should have been contacted?

ORS used the report data the community colleges provided to identify those we contacted. The criteria are:

• Enrolled as a part-time student and employed by the community college where enrolled at some point between July 1, 2017 and June 30, 2018.
• Identified as “primarily a student” by the community college.

If an employee believes they should have been contacted, check the data file you provided us. If they don’t meet the criteria above, explain why. If they do meet the requirements, the address ORS used may be out of date. Ask the person to contact ORS at 800-381-5111 to update their contact information.

Do we need to do anything for part-time students who worked between July 1, 2014 and June 30, 2017, but not after that date?

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) 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 MPSERS members. You will be (or have been) invoiced for member and employer contributions for these employees.

What if a 328 file lists an employee who no longer works here?

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.

What if a 328 file says to stop, begin or continue reporting an employee who works here but is no longer enrolled as a student?

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 328 file says to begin reporting and you are already reporting the person (as a non-student employee), continue to report.
• If a 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.

What if a 328 file says to begin reporting an employee who works here but is now enrolled here as a full-time student?

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 should not be reported.

How long do we have to make adjustments for the period beginning July 1, 2018?

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

How often will we receive 328 files?

Each community college will receive one 328 file showing all students who had an election and how to report them and/or make adjustments. The file will be sent via FTS by mid-September. (Updated 8/21/2019)