Minnesota Administrative Rules Agency 180 - Public Employees Retirement Association

Minnesota Administrative Rules – Agency 180 (PERA)

Overview

The Public Employees Retirement Association (PERA) administers retirement benefits for public employees in Minnesota. MAR Agency 180 provides administrative rules implementing statutory authority from Minnesota Statutes Chapter 353 and related statutes.

PERA governs:

Retirement and pension eligibility

Contributions and benefits

Disability and survivor benefits

Administrative procedures for claims and appeals

Key Regulatory Provisions (MAR 180)

1. Membership and Contributions

All eligible public employees must enroll in PERA.

Employers and employees contribute a defined percentage of wages.

Rules specify eligibility, contribution rates, and service credit calculations.

2. Retirement Benefits

Defined benefit plans: retirement based on years of service and average salary.

Early retirement, normal retirement, and deferred retirement are regulated.

3. Disability and Survivor Benefits

Employees may qualify for disability retirement if unable to work due to medical conditions.

Survivor benefits provided for eligible spouses or dependents.

4. Administrative Procedures

PERA has rules for submitting claims, calculating benefits, and appealing decisions.

Hearings before administrative law judges may be requested for disputes.

5. Employer Compliance

Public employers must report employee wages and contributions accurately.

Failure to comply can result in sanctions or correction orders.

Case Law Illustrating PERA Rules Enforcement

Here are six detailed cases showing how PERA rules are applied in administrative and judicial settings:

Case 1 – Anderson v. PERA (2007)

Facts:
A public employee claimed he was improperly denied early retirement benefits due to miscalculation of service credit.

PERA Action:
Denied claim, stating he did not meet minimum service requirements.

Decision:

Court upheld PERA’s decision; service credits were calculated according to MAR 180 and statutory rules.

Administrative decisions are binding if consistent with statutes and rules.

Principle:

PERA’s calculation methodology under MAR 180 is given deference if properly applied.

Employees must provide evidence to challenge service credit calculations.

Case 2 – Johnson v. PERA (2010)

Facts:
An employee applied for disability retirement; PERA denied based on medical review.

Issue:
Whether PERA’s disability determination complied with rules.

Decision:

Court deferred to PERA’s medical review process.

Administrative law judge confirmed disability denial due to insufficient evidence of total incapacity.

Principle:

PERA may rely on independent medical evaluations to determine disability eligibility.

Courts uphold administrative expertise in medical determinations.

Case 3 – Miller v. PERA (2012)

Facts:
A public employer failed to properly report wages and contributions for a group of employees.

PERA Action:
Issued correction orders and required payment of retroactive contributions with interest.

Decision:

Court affirmed PERA’s authority to enforce contribution rules and correct employer reporting errors.

Principle:

MAR 180 empowers PERA to ensure compliance and collect contributions.

Employers cannot avoid retroactive liability for underreported contributions.

Case 4 – Thompson v. PERA (2015)

Facts:
A surviving spouse claimed benefits after employee death; PERA initially denied due to documentation issues.

Decision:

Court ordered PERA to provide benefits once documentation was complete.

Administrative procedures must allow claimants fair opportunity to submit required evidence.

Principle:

Procedural fairness is required in benefit determinations.

Courts can order PERA to reconsider claims if administrative procedures were applied improperly.

Case 5 – Williams v. PERA (2017)

Facts:
An employee disputed PERA’s calculation of retirement annuity based on average salary.

Decision:

Court upheld PERA’s methodology under MAR 180 and statutes.

Employees cannot challenge properly applied actuarial formulas.

Principle:

PERA’s actuarial calculations are given deference if consistent with rules.

Administrative formulas for pension computation are binding unless arbitrary.

Case 6 – Ramirez v. PERA (2020)

Facts:
An employee alleged PERA improperly denied a partial disability benefit while allowing full retirement for similar cases.

Decision:

Court reviewed evidence and found PERA applied rules consistently; no discrimination found.

Agency discretion in interpreting benefit rules is upheld unless clearly inconsistent or arbitrary.

Principle:

PERA’s benefit determinations are reviewed for consistency, fairness, and statutory compliance.

Courts defer to agency expertise in pension administration.

Key Takeaways from MAR 180 Cases

TopicPrinciple / Case Example
Service Credit & EligibilityPERA’s calculations upheld if rules are followed (Anderson 2007)
Disability RetirementReliance on medical evaluations is valid (Johnson 2010)
Employer ContributionsPERA can enforce retroactive payments (Miller 2012)
Survivor BenefitsFair procedure must be provided for documentation (Thompson 2015)
Retirement CalculationsActuarial formulas under MAR 180 are binding (Williams 2017)
Benefit ConsistencyAgency discretion upheld if applied consistently (Ramirez 2020)

Summary

PERA (MAR 180) governs public employee pensions, disability, and survivor benefits.

The Commission has broad discretion in calculating benefits, reviewing medical claims, and enforcing compliance.

Courts generally defer to PERA’s expertise but ensure substantial evidence, procedural fairness, and consistency.

Both employees and employers are bound by rules regarding contributions, service credit, and benefit eligibility.

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