Membership Enrollment for Part-Time Employees

September 4, 2025
Circular Letter: 200-037-25
Topic: Membership

To: All CalPERS Employers

Purpose

The purpose of this Circular Letter is to detail the requirements of monitoring and enrolling employees into California Public Employees’ Retirement System (CalPERS) membership.

Employer Responsibility

A recent employer review by our internal Office of Audit Services found that some employers may not have systems in place to consistently monitor CalPERS membership eligibility for part-time employees. As outlined in the California Public Employees’ Retirement Law (PERL), employers are responsible for ensuring proper enrollment of eligible employees into CalPERS. If your agency doesn’t have a monitoring process, it’s essential to implement a reliable system to identify when employees become eligible.

Membership Requirements

Employees may become eligible for CalPERS membership either upon hire or at a later date, in which case eligibility must be monitored. Eligibility falls into one of the following categories:

Immediate Membership Under Government (Gov.) Code Sections 20280-20281

  • An employee hired in a permanent/full-time position must be enrolled upon hire.
  • An employee who is already a CalPERS member (i.e., employee attained CalPERS membership prior to being hired at your agency) must be enrolled even if they are hired to work on a part-time basis at your agency, unless excluded.
  • An employee who is hired into a part-time position working 20 hours or more for more than 12 months must be enrolled upon hire.

Monitor for Membership

For employees who don’t qualify for immediate membership, employers must keep track of the number of hours/days their employees work in a fiscal year (July 1 through June 30). CalPERS membership is attained when an employee meets one of the following:

  • Works 1,000 hours in a fiscal year (if paid on an hourly basis)
    • Gov. Code section 20305 (a)(3)(B) states the membership date “shall be effective not later than the first day of the first pay period of the month in which 125 days or 1,000 hours of service were completed.”
    • Hours counted towards the 1,000 hours:
      • All compensated hours
      • Regular hours
      • Overtime
      • Paid holidays
      • Used sick leave
      • Used vacation
      • Any hours an employee would have worked had he/she not been subject to furlough
    • Hours not included:
      • Unused leave credits
      • Vacation pay-outs
    • Works 125 days in a fiscal year (if paid on a daily or per diem basis)
      • Gov. Code section 20305(a)(3)(B) defines a ‘day’ as “each eight-hour period of employment worked by an employee paid on a per diem basis…”

Membership Exclusions

Employees hired into excluded positions should not be enrolled in CalPERS, i.e., positions that are:

  • Specifically excluded in the employer’s CalPERS pension contract
  • Specifically excluded in the PERL
  • Covered by another qualifying retirement system (e.g., California State Teachers’ Retirement System, etc.)

Recommendations for Proper Reporting

Employers should consider the following recommendations when enrolling employees hired by their agency.

  • Develop internal systems to monitor the employees’ hours and days worked during every fiscal year. Examples include:
    • Using a spreadsheet to track the employees’ hours and days
    • Reviewing internal payroll reports periodically
    • Developing internal system enhancements to notify when an employee reaches 1,000 hours or 125 days
  • Provide the notice of exclusion when immediate membership is not applicable and inform the employee of the reason.
  • Encourage employees to notify you if they begin or end employment with another CalPERS-covered agency.
  • Periodically check myCalPERS to confirm if the employee has reached CalPERS membership through a position with another CalPERS-covered agency.
  • Submit non-contributory appointments in myCalPERS, so we can alert you if the employee’s appointment status with your agency changes to contributory.

Consequences of Late Reporting

Late enrollment of employees who have attained CalPERS membership into myCalPERS can result in late enrollment fees, contributions, and penalties, as prescribed in Gov. Code section 20283.

Resources

CalPERS offers a series of educational materials to help employers fulfill this responsibility:

Questions

If you have questions, call our CalPERS Customer Contact Center at 888 CalPERS (or 888-225-7377888-225-7377).

Brad Hanson, Chief
Employer Account Management Division