APS #5054

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Hiring Retirees to Work in Staff or Faculty Positions

Brief Description

This policy will assist departments when hiring retirees to work in staff or faculty positions at CU.

Reason for Policy

Allows CU to demonstrate employee and employer responsibility and provide clarity and consistency to departments when hiring CU retirees or non-CU retirees to work in staff or faculty positions.

Policy Profile

APS Policy Title: 
Hiring Retirees to Work in Staff or Faculty Positions
APS Number: 
5054
Effective Date: 
January 1, 2026
Approved By: 
President Todd Saliman
Responsible University Officer: 
Vice President and Chief Human Resources Officer
Responsible Office: 
Office of Vice President and Chief Human Resources Officer
Policy Contact: 
Office of Vice President and Chief Human Resources Officer
Supersedes: 
Hiring Retirees to Work in Staff Positions, March 1, 2023
Last Reviewed/Updated date: 
January 1, 2026
Applies to: 
Departments that hire retirees to work in staff or faculty positions and retirees working in staff or faculty positions.

I. Policy Statement

  1. The hiring of CU retirees (employees who have officially retired from the university) includes both Colorado Public Employee Retirement Association (PERA) and University of Colorado 401(a) retirees, needs to be coordinated for retiree health/dental/life benefit purposes, and must be tracked appropriately.
    1. PERA Retiree: employees who have officially retired from PERA.
    2. University of Colorado 401(a) Retiree:  employees who participated in the University of Colorado 401(a) Retirement Plan and have officially retired from the university.
       
  2. The use of working CU retirees should not be a long-term replacement for regular, full-time positions.  There is no limit on how many years a CU retiree can perform in temporary, part-time positions.
     
  3. CU retirees may be hired into temporary university staff, temporary research faculty, or temporary faculty positions (see table in section I.I - Appointment Options for CU Retirees).
     
  4. Non-PERA Retirees from other institutions or companies can be hired with no restrictions and are not subject to this policy.
     
  5. PERA retirees from other PERA employers are restricted to the 110 day/720 hour per calendar year rule and are subject to this policy.
     
  6. Appointments may be used to:
    1. train, cross-train, transfer knowledge, or act in a short-term mentoring role for a new incumbent;
    2. fill a position that is defined as part time and does not supervise full-time employees;
      • While retirees are generally not appointed to supervisory positions for full-time staff, there may be situations where a retiree is asked to assume supervisory responsibilities for full-time employees for a limited period.
    3. fill a position on a unique and non-recurring project;
    4. provide specialized knowledge or fill a specialized role; or
    5. fill an interim vacancy. 
       
  7. Hiring any retiree (CU retiree or non-CU retiree) who is also a PERA retiree as an employee or contract worker results in certain complexities based on C.R.S. § 24-51-1101:
    1. It is the employee/contract worker’s responsibility to confer with Employee Services and PERA to understand calculating time worked.
      1. See Reference Guide: Hiring Working PERA Retirees for information on calculating daily and hourly time worked for PERA retirees working for the university.
    2. Contributions[1]
      1. The working PERA retiree is required to pay a working retiree contribution equal to the member contribution rate, which will be deducted from the working retiree’s pay as a pre-tax contribution.
      2. A PERA Retiree working as an Independent Contractor will have PERA contributions deducted from the member’s PERA monthly retirement benefit that is received from PERA.  It is the Independent Contractor’s obligation to notify PERA of their compensation. The Independent Contractor must also provide a PERA Disclosure of Compensation form to Employee Services every time they are compensated so the appropriate employer contributions can be remitted to PERA.
      3. The department is required to pay employer contributions.
      4. The working retiree contribution does not accrue an additional benefit.  The working retiree is not eligible for a refund of these contributions.
      5. Upon termination of such retiree's employment, there shall be no benefit calculation reflecting additional service credit or any increase in the highest average salary of such person.

        [1] The contributions to PERA are paid into a general PERA fund.
    3. Days worked
      1. The working PERA retiree can work a maximum of 110 days or 720 hours per calendar year.  If that retiree works more than 110 days or 720 hours, PERA will reduce the retiree’s monthly pension by a formula-set percentage.  Independent contractors are not subject to the work limits; however, they are subject to contributions.  Refer to PERA’s publication https://content.copera.org/wp-content/uploads/2024/07/working-after-retirement-for-independent-contractor.pdf.
      2. Each campus and system administration can designate 10 PERA retirees to work for a maximum of 140 days or 916 hours per calendar year, following the campus’ established approval process.
        • A PERA retiree may be added to the 140-day list at any point during the calendar year if their retirement occurs after the submission deadline.
        • This is an annual process.  Campus HR offices are responsible for submitting their designated retiree list to Employee Services each year.  The submission deadline is communicated by Employee Services.
      3. It is the retiree’s responsibility to track days worked under PERA rules.

        NOTE:  If you fail to submit any of the forms as required by PERA or provide PERA with false information, PERA may suspend your retirement and take legal action to recover unearned benefit payments and interest.
    4. Departments cannot hire PERA retirees through a temporary agency to circumvent the PERA restrictions—the PERA rules on working retirees apply to any employment, including employment as an independent contractor.
    5. If the working PERA retiree chooses to suspend retirement and work at CU in a regular position, the suspension must occur for both PERA and CU retirement (if the PERA retiree also retired from CU).
       
  8. Hiring University of Colorado 401(a) Retirees may result in certain complexities and constraints.  It is the retiree’s responsibility to understand these constraints:
    1. Working after retirement may affect:
      1. distributions from CU retirement funds.  It is the retiree’s responsibility to confer with Employee Services and TIAA;
      2. distributions from other non-CU retirement plans; and
      3. Social Security benefits.
    2. University of Colorado 401(a) Retirees may be subject to additional constraints and should check their Agreement prior to working after retirement.  University of Colorado 401(a) Retirees subject to the tax deferred Early Retirement Incentive Agreement (ERIP) option are prohibited to work for the university in any capacity while the ERIP agreement is active.
    Appointment options for CU retirees.  

    If a CU retiree is hired into an erroneous job code, Employee Services will work with the appropriate campus HR office to correct the appointment.
     

    Job Code

    Title

    Job Category

    Utilization

    Position Type

    Rate of Pay
    1610 Working PERA Retiree – Staff University Staff Required for all CU Retirees with PERA retirement

    Optimal for all PERA Retirees from a different PERA employer    		 Temporary Hourly Rate
    1611 Working 401(a) Retiree – Staff University Staff Required for all CU Retirees with CU ORP retirement Temporary Hourly Rate
    1620 Working PERA Retiree - Faculty Faculty Required for all CU Retirees with PERA retirement

    Optimal for all PERA Retirees from a different PERA employer    		 Temporary Hourly Rate
    1621 Working 401(a) Retiree - Faculty Faculty Required for all CU Retirees with CU ORP retirement Temporary Hourly Rate/ Contract/ Monthly
    1630 Working PERA Retiree – Faculty Research Research Faculty Required for all CU Retirees with PERA retirement 

    Optimal for all PERA Retirees from a different PERA employer    		 Temporary Hourly Rate/ Contract/ Monthly
    1631 Working 401(a) Retiree  – Faculty Research Research Faculty Required for all CU Retirees with CU ORP retirement Temporary Hourly Rate/ Contract/ Monthly
  9. Appointment options for retirees from other Non-PERA institutions or companies. 
    1. Specific requirements are based on university policies and state personnel rules, dependent on job code.
    2. There are no restrictions as to which job code retirees from other Non-PERA institutions or companies can be hired.
    3. Retirees from different PERA employers (see section I.G) have limitations on how much they may work in a calendar year.
  10. Benefits and HR processes for CU Retirees working in temporary staff, temporary research, or temporary faculty positions.
    1. If a CU Retiree is enrolled in retiree CU medical, dental or life plans, retiree benefits will continue.
      • Temporary employees may become eligible for employee medical benefits if they meet the Affordable Care Act (ACA) requirements.
    2. CU Retirees are eligible to contribute to the voluntary retirement plans (403(b), 457, or 401(k)).
    3. CU Retirees may have working titles that are reflective of the duties being performed (job code reflects formal title of Working Retiree).
    4. CU Retirees are not eligible to accrue vacation leave.
    5. CU Retirees are eligible for sick leave provided to temporary employees.
    6. CU Retirees are not eligible for annual merit increases.
      • Pay adjustments are allowed upon review of appointment and should be evaluated by Human Resources to ensure alignment under the Equal Pay for Equal Work Act (EPEWA).
    7.  Performance plans and evaluations are not required but recommended.
    8. CU Retirees are not eligible for the tuition benefit.
    9. CU Retirees are not allowed to volunteer time performing same duties as employment.
    10. All hourly CU Retirees are required to track time in the timekeeping system used by the department, and the department must process the biweekly payroll through time collection.

II. Related Policies, Procedures, Forms, Guidelines and Other Resources

III. History

  • Adopted:  January 1, 2014.
  • Revised:  August 1, 2017; August 30, 2021, non-substantive changes were made to this APS; March 1, 2023; June 26, 2023, Job Codes 1630 and 1631 added to Appointment Options table; January 1, 2026.
  • Last Reviewed:  January 1, 2026.