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Federal Responsibility for Benefits Payments
The Revitalization Act transferred to the Federal government the responsibility for making eligibility determinations and making benefit payments for eligible District employees for benefits accrued on or before June 30, 1997 (the "Freeze Date"). The Revitalization Act contains provisions however, that require District agencies that are currently responsible for non-investment related administrative functions to continue providing those services until the US Treasury appoints a trustee or otherwise formally assumes those responsibilities.
Because the Revitalization Act does not provide comprehensive methodologies for determining the respective liabilities of the Federal and District governments to individuals eligible to receive benefits under the District retirement programs, the US Treasury has developed "Benefits Regulations" for retroactive application (applicable as of October 1, 1997). These regulations set forth specific procedures for many complex benefits issues including the one (vs. two) check issue. There are also strong indications that the Treasury may opt to provide continuing assistance to the District to enable the relevant District agencies to continue providing those administrative services in a more efficient manner instead of appointing a trustee or otherwise directly assuming the non-investment related administrative responsibilities. |