POLICY UPDATE: Rehiring RCUH Retirees – Addendum to RCUH 3.210 Employing People Through the RCUH Policy

 

Former RCUH employees who have separated from service with the RCUH AND who have elected a distribution from their RCUH Group Retirement Annuity (GRA) plan (e.g., monthly retirement income, a lump sum withdrawal, etc.) MUST have experienced a “bona fide retirement” from the RCUH before they may considered for rehire with the RCUH, as required by the Internal Revenue Code [26 Code of Federal Regulations Sec. 1.401(a)-1(b)(1)(i), Sec. 1.401(a)(36)].

 

 

 

To assist programs (and former employees) in determining whether a “bona fide retirement” exists, we have established the following guidelines (see addendum to the RCUH 3.210 Employing People Through the RCUH policy for additional details and future reference).

 

 

 

Age Prior to Separation from Service or During Retirement

Bona Fide Retirement Presumption / Break in Service Requirement

Age 65 and older

May be rehired at any time

Ages 62-64

Must have a separation of Service of at least two (2) months

Ages 59 ½ – 61

Must have a separation of Service of at least four (4) months with NO evidence of intention to rehire the employee at the time of separation

Under Age 59 ½

Must have a separation of Service of at least six (6) months with NO evidence of intention to rehire the employee at the time of separation

 

 

 

NOTE:  Former employees who did not elect for a distribution from their GRA retirement plan benefits may be rehired at any time.

 

 

 

This policy addendum is effective May 1, 2012 but, in general, represents the pre-existing, informal policy of the RCUH.   If you have any questions regarding this policy/addendum, please contact Jill Niitani at [email protected].