Expert's View

My, how time flies. Back on October 28, 2009, a provision in the National Defense Authorization Act for the first time allowed rehired employees who had taken a refund of their FERS retirement contributions to redeposit that money, plus accrued interest, and get credit for that time in determining their eligibility to retire and in their annuity computation. It also provided that the survivors of employees who die in service may make that redeposit.

In January, OPM sent a Benefits Administration Letter to agencies informing them about the change in law and noting that it was preparing regulations and revising forms. That was a subtle way of saying don’t do anything now. Not surprisingly, that didn’t sit well with those affected by the change.

As a result, OPM has now told agencies that effective immediately, it will accept the current Standard Form 3108, Application to Make a Deposit or Redeposit, from anyone eligible to make a FERS redeposit.

Because the form hasn’t been revised, if you are applying to make a redeposit, you will have to indicate on the form that the period of service was refunded. At the same time OPM is cautioning anyone submitting an application not to include a payment. Once OPM receives an application, it will calculate the redeposit amount and establish an account. Only after you hear back from OPM should you arrange to make payment. Whether that payment will go directly to OPM or be made through your agency, as is true of CSRS redeposits, remains to be seen.

P.S. You can get a copy of the SF 3108 from your personnel office or download a copy at http://opm.gov/form/pdf_fill/SF3108.pdf. Anyone wanting to see the January Benefits Administration Letter will find it at www.opm.gov/retire/pubs/2010/10-101.pdf.