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Office of the New York State Comptroller’s Seal

NYS Comptroller

Thomas P. DiNapoli

Understanding Your Responsibilities

Frequently Asked Questions

  1. I’ve never been asked to keep a record of activities (ROA) before. Was I supposed to?

    Since 1976, every elected or appointed official who is a member of the Retirement System has been required to keep an ROA and submit it to his/her governing board if you do not participate in your employer’s time keeping system which shows hours worked. (This includes systems that keep track of accruals used and attest that, other than time charged to accruals, full hours were worked.)

  2. When do I have to submit my ROA to the clerk of the governing board?

    Effective August 12, 2009, you have to prepare your ROA within 150 days of the start of a new term or appointment, and you have to submit it to the clerk no later than 180 days of taking office. See our schedule of due dates for the ROA for help determining what to do and when to do it.

  3. My term of office began before August 12, 2009. What does this regulation mean to me? How do I comply with it?

    For elected or appointed officials whose terms began before August 12, 2009, the expanded requirements of Regulation 315.4 apply at the start of the term after their next election/appointment to office.

  4. Do I have to submit an ROA if my term of office began before August 12, 2009?

    You still have to keep an ROA and submit to your governing board. Since your term began prior to August 12, 2009, you are only required to keep an ROA for one month. We encourage everyone to keep a three-month ROA, but the regulation doesn’t require this until the start of the term after your next election/appointment to office.

  5. I was appointed to my position prior to August 12, 2009 and serve continuously. Does Regulation 315.4 apply to me?

    Yes. Your term is considered to be coterminous with your appointer’s term of office. You will need to comply with the requirements of Regulation 315.4 at the beginning of your appointer’s term after his or her next election or appointment to office.

  6. What should I do if I take a two week vacation during the three-month time period when I’m keeping a record of my work activities?

    You should extend your record by two weeks.

  7. I already submit time sheets. Do I also need to keep an ROA?

    Not if your time sheets track the actual hours you’ve worked. Regulation 315.4 does not require officials who already submit records of the time they’ve worked to keep an ROA.

  8. Could you give me examples of activities that are, and are not, considered work-related?

    Work-related activities can include attending an employer-sponsored event, addressing constituent matters and responding to an emergency. Activities that should be excluded from your ROA are hours spent attending electoral and campaign events, attending a candidates forum, on call time and time spent socializing after board meetings.

  9. I know that I cannot receive service credit for electoral fundraisers, but how about other events like attending testimonial dinners or fundraising events for not-for-profit organizations?

    An event can be included on your record of activities (ROA) Adobe pdf, if you attended in your capacity as an elected or appointed official — not as a private citizen. For example, a testimonial dinner at which you presented a formal proclamation would be considered work-related and could be included in your ROA. However, a fundraising dinner for a not-for-profit organization on whose board you sit as a private citizen cannot be included.

  10. What should I do if, after preparing a record of work activities for three consecutive months, I decide that the ROA isn’t a good representation of the time I actually work?

    You can submit a new ROA for a different three-month period.

  11. Do I need to keep an ROA each time I begin a new term?

    If you feel a previously submitted three-month ROA is still representative of the time you actually work, you can certify in writing that your duties, responsibilities and hours have not changed substantially. You would submit your written certification to the governing board no later than 180 days of taking office. A record of work activities can be valid for up to eight years.

  12. Who can I contact if I have questions about following the regulation?

    You can always email our Member & Employer Services Bureau if you are unsure about how to correctly comply with this regulation.

(Rev. 4/13)

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