Retiree Employment Restrictions


There are certain statutory restrictions on retiree employment. These restrictions are a matter of law and although all retirees are notified at the time of their retirement, a number of retirees are consistently discovered through government audits to be violating these restrictions. These retirees are then forced to reimburse the Article II Pension Fund for all pension benefits received while in violation of the law.

In 1998, a City Comptroller's audit caught 81 retired City employees illegally collecting pension benefits while receiving paychecks from either City or State agencies for whom they had gone back to work. These "double-dipping" retirees had collected nearly $600,000 in illicit benefits, and now, several of them, including NYPD retirees, are reimbursing the Fund over $200,000 each! Don't let this happen to you!

The New York City Comptroller's office has turned over the results of their audit to the New York City Department of Investigation for possible criminal prosecution, in addition to recovery of all pension monies received.

Retirees – make sure that you are in compliance with the following guidelines on employment. You should review the statutes cited to avoid jeopardizing your pension benefit. Questions regarding these statutory restrictions should be submitted to the Pension Section in writing. A copy of your correspondence will be made a part of your pension records.

Remember that you are responsible for ensuring that you are not violating these important restrictions. Violations will result in substantial financial reparations as well as possible criminal repercussions.

Employment Limitations for All Article II Retired Persons
Your retirement benefit consists chiefly of a pension portion, and to a lesser degree, an annuity portion. The following is concerned with the pension portion only. (The annuity portion of your retirement benefit was purchased by your contributions and is not affected. Also, continuation of your annuity portion maintains your eligibility for medical benefits.)

An active member of the pension system is one who is in the active service of a governmental agency. He or she may or may not be making contributions to the pension system, but is earning future pension benefit credits. A passive member is one who is receiving benefits.

Service and Vested Interest Retirees
According to Section 1117 of the New York City Charter, the pension portion of the retirement benefit is to be suspended or forfeited for all retired persons who are employed by New York State or any of its political subdivisions, unless the sum of the pension portion and the compensation or salary is less than $1,800 per year.

Section 211 of the New York State Retirement and Social Security Law allows a person retired for other than a physical disability to be employed by New York State or one of its political subdivisions if the agency wishing to employ the person obtains approval from the New York State Civil Service Commission or others in power to grant such approval.

Disability Retiree Prior to 20th Anniversary
Disability retirees may be employed, with an earnings limitation, by New York City, State or any political subdivision prior to the 20th anniversary of their appointment to the Police Department. The earnings are limited to the difference between the pension portion and the current salary, plus overtime, night shift differential, and vacation work for the next higher rank than that of the retired person at the time of retirement. Uniform allowance shall be included at the rate for the rank of the retired person at the time of retirement. Earnings in excess of this difference are to be subtracted from subsequent pension portion payments.

Disability Retirees after the 20th Anniversary
After the 20th anniversary of their appointment to the Police Department, all accident or ordinary disabilities are subject to Section 1117 of the New York City Charter, which states that you may not be employed by New York City, State or any political subdivision without first suspending the pension portion of your retirement allowance. As disability retirees, you are excluded from the exmption provisions of Section 211 or 212 of the New York State Retirement and Social Security Law, because you would have had to retire for other than a physical disability in order to be eligible. This means that after the 20th anniversary, disability retirees cannot work for any municipal employer in New York State (other than a public benefit corporation) without suspending their pension benefit with the Pension Section.

Section 40-C-9 RSSL
Any retired person (disability, service or vested interest) may not join another New York State Retirement System as an active member while receiving a pension benefit from the Article II Pension System. If a retired person elects to do so, the pension portion must be suspended. When the active membership ceases, pension portion payments will be reinstated.

Section 212 of the New York State Retirement and Social Security Law permits employement by New York State or one of its political subdivisions without approval for non-disability retired persons if the salary or compensation is less than an amount set by the Legislature each year (check the amount with the NYPD Pension Section). Under Section 212, you must notify the Article II Pension System if you elect to exercise this right.

Please note that it is the responsibility of the service or vested interest retiree to verify that the prospective employer has obtained a waiver under Section 211 and that waiver is continued in force throughout the duration of employment.

Public Benefit Corporation
The Office of the Corporation Counsel has interpreted Section 1117 of the New York City Charter as not applying to the "Public Benefit Corporations," so that retired City employees can work for such corporations without suspension of benefits. The Corporation Counsel has determined the following Authorities to be Public Benefit Corporations:

New York City Housing Authority
New York City Transit Authority
New York City Dormitory Authority
Off-Track Betting Corporation
New York City Health and Hospitals Corporation
Metropolitan Transportation Authority
Urban Development Corporation
Port Authority
Waterfront Commission
New York City School Construction Authority
New York City Convention Operating Corporation