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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?
  2. When do I have to submit my Record of Activities (ROA) to the clerk of the governing board?
  3. My term of office began before August 12, 2009. What does this regulation mean to me? How do I comply with it?
  4. I was appointed to my position prior to August 12, 2009 and have served continuously. Does Regulation 315.4 apply to me?
  5. What should I do if I take a two-week vacation during the three-month time period when I'm keeping record of my work activities?
  6. I already submit time sheets. Do I also need to keep a Record of Activities (ROA)?
  7. Could you give me examples of activities that are, and are not, considered work-related?
  8. 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?
  9. What should I do if, after preparing a Record of Activities (ROA) for three consecutive months, I decide that the ROA isn’t a good representation of time I actually work?
  10. Do I need to keep a Record of Activities (ROA) each time I begin a new term?
  11. Who can I contact if I have questions about following the regulation?
 
  1. I’ve never been asked to keep a Record of Activities (ROA) before. Was I supposed to?

    Yes. Since 1975, the Regulation requires every elected or appointed official, who is a member of the Retirement System, 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. (An acceptable time-keeping system keeps track of accruals used and attests that, other than time charged to accruals, full hours were worked.)

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

    Beginning January 1, 2016, you must complete your ROA within 150 days of the start of a new term or appointment, sign it attesting to its accuracy, and you have to submit it to the clerk no later than 30 days after completion. 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?

    All elected or appointed officials whose terms began before August 12, 2009 were required to complete and submit a one-month Record of Activities (ROA). A three-month ROA is required to be completed and submitted for any re-election/appointment after August 12, 2009.

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

    Yes. The Regulation applies to all Elected and Appointed officials who are members of the Retirement System. Since your term began prior to August 12, 2009, you were only required to keep a Record of Activities (ROA) for one month. Upon re-appointment, any time after 2009, you are required to complete/submit a three-month ROA. We encourage everyone to keep a three-month ROA, but the regulation doesn’t require it until the start of the term after 2009.

  5. 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.

  6. I already submit time sheets. Do I also need to keep an Record of Activities (ROA)?

    Not if your time sheets track the actual hours you’ve worked and accruals charged for time not worked. Regulation 315.4 does not require officials who participate in their employer’s time keeping system to keep an ROA.

  7. 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 Record of Activities (ROA) are hours spent attending electoral and campaign events, attending a candidate’s forum, on-call time and time spent socializing after board meetings.

  8. 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.

  9. What should I do if, after preparing a Record of Activities (ROA) 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.

  10. Do I need to keep a Record of Activities (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 Recertification of the Record of Activities (RS2419) Adobe pdf to the governing board no later than 180 days of taking office. An ROA can be valid for up to eight years.

  11. 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. 6/16)

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