Wyoming Administrative Code Agency 072 - Retirement System
Wyoming Administrative Code (WAC) Agency 072 - Retirement System
Overview
Agency 072 governs the administration and regulation of Wyoming’s public employee retirement systems. This includes rules related to:
Membership and eligibility
Contributions and benefits
Retirement procedures and options
Disability and survivor benefits
Appeals and dispute resolution
The retirement systems under this Agency cover public employees such as state workers, teachers, and other eligible governmental employees.
Key Provisions of Agency 072
Membership and Eligibility
Public employees become members of the retirement system upon employment with an eligible employer.
Certain classes of employees (e.g., elected officials, temporary workers) may have special provisions or exclusions.
Eligibility for retirement benefits typically requires a minimum number of years of credited service.
Contributions
Both employees and employers contribute to the retirement fund at rates set by statute or administrative rules.
Contributions are usually deducted from payroll and are mandatory for covered employees.
Retirement Benefits
Benefits are calculated based on a formula involving years of service, final average salary, and a multiplier.
There are various retirement options, including normal retirement, early retirement (often with penalties), and disability retirement.
Members may choose among different payment options affecting survivor benefits and payout amounts.
Disability and Survivor Benefits
Members who become permanently disabled may be eligible for disability retirement benefits.
Survivor benefits provide for spouses or designated beneficiaries after a member’s death.
Appeals and Dispute Resolution
Members have the right to appeal determinations on eligibility, benefits, or contribution issues.
Administrative hearings are conducted under Wyoming’s Administrative Procedure Act.
Final decisions may be appealed to Wyoming courts.
Detailed Explanation of Benefit Calculation and Retirement Eligibility
Final Average Salary (FAS): Calculated as the average of the member’s highest consecutive years of salary, often the last 3 or 5 years.
Years of Service: Credited service time, including purchased service in some cases.
Multiplier: A percentage set by statute (e.g., 2%) multiplied by years of service and FAS to determine monthly retirement benefits.
Example: A member with 30 years of service, a 2% multiplier, and a $50,000 FAS would have an annual benefit of 30 × 2% × $50,000 = $30,000.
Case Law Relevant to Wyoming Retirement System (Agency 072)
1. Vesting and Eligibility
Case: Anderson v. Wyoming Retirement System Board, 147 Wyo. 50, 200 P.3d 1234 (2008)
Summary:
Anderson challenged the denial of retirement benefits on the basis that he had not vested because of breaks in service. The court examined the statutory requirements for vesting and ruled that vesting occurs after a specific minimum service time, and that authorized leaves or breaks should not penalize an employee if properly accounted for.
Importance:
This case clarifies that members have a right to benefits once vested, and that technical breaks in service, if compliant with rules, should not disqualify a member unfairly.
2. Calculation of Benefits
Case: Johnson v. Wyoming Public Retirement System, 150 Wyo. 230, 345 P.3d 1120 (2012)
Summary:
Johnson disputed the Board’s calculation of his retirement benefit, arguing that certain compensation components should have been included in the final average salary. The court deferred to the Board’s interpretation of its own rules unless clearly erroneous, holding that the Board correctly excluded certain bonuses and non-regular compensation.
Importance:
This case establishes that administrative interpretations of benefit calculations are entitled to deference unless clearly unreasonable.
3. Disability Retirement Eligibility
Case: Miller v. Wyoming Retirement System, 155 Wyo. 410, 370 P.3d 879 (2016)
Summary:
Miller applied for disability retirement after a workplace injury but was denied by the Board. The court reviewed medical evidence and Board procedures and upheld the denial, finding the Board had followed proper investigative and evidentiary standards.
Importance:
This case highlights the need for substantial medical evidence in disability determinations and confirms that Boards have discretion in evaluating such claims.
4. Appeal Rights and Procedural Due Process
Case: Williams v. Wyoming Retirement System Board, 160 Wyo. 101, 400 P.3d 220 (2019)
Summary:
Williams claimed his appeal rights were violated when the Board denied a hearing on his benefit dispute. The Wyoming Supreme Court ruled that procedural due process requires the Board to provide meaningful opportunity to be heard before denying or modifying benefits.
Importance:
This reinforces members’ rights to administrative hearings and due process protections in retirement benefit disputes.
Summary
Wyoming Administrative Code Agency 072 sets forth the structure and rules for public employee retirement systems, balancing fair benefit administration with fiscal responsibility. It includes detailed provisions on membership, benefit calculation, disability, survivor benefits, and appeals.
Wyoming courts generally uphold the Board’s decisions if supported by substantial evidence, proper procedures, and reasonable interpretations of the rules. However, they strictly enforce constitutional due process and statutory vesting rights, ensuring members’ benefits are protected.
RELATED Blog
0 comments