In yesterday's entry "Clampdown", I misrepresented an important piece of the proposed OAR pertaining to the recovery of overpayments. I remarked that PERS used the term "payee" in a very restrictive sense, which I interpreted as being only the retiree. Mea culpa. I should have taken the time to read the "definitions", which form the preamble to the rule. Had I done so, I would have discovered that PERS is defining - for the purpose of this rule - "payee" to mean anyone who could possibly be receiving (or have received) a benefit from PERS that included (includes) the 1999 earnings distribution of 20%. This means, among others, retirees, their beneficiaries, a divorced spouse and, presumably, the humane society. This significantly broadens the scope of recovery efforts and continues to impinge on the question of whether PERS intends to use "joint life expectancy" tables to determine the actuarial recovery period. So far, PERS has not answered that question, which I've now asked multiple times. Hopefully they'll give me an answer soon since it bears on the calculator output. [Note added at 11:30. Just heard back from PERS. While they "think" they know the answer to my question, they're waiting for more direction from the actuary before making their answer public. The actuary has to report on which table(s) to use, whether there are any "holes" in the tables, and what the policy implications are for the actuary's recommendation. So, it may be awhile longer before I can finalize the calculator or answer the question about "joint mortality"].
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