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Office of the New York State Comptroller’s Seal

NYS Comptroller

Thomas P. DiNapoli

Understanding Your Responsibilities

Changes to Reporting Requirements

Since 1975, elected and appointed officials have been required to keep a record of their work-related activities (ROA) and submit it to their employers if:

  • They are members of the New York State and Local Retirement System (NYSLRS); and
  • They are not part of a time-keeping system that 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.)

The August 19, 2015 revisions help ensure that elected and appointed officials receive appropriate service credit. The chart below summarizes the changes to the Regulation.

Comparison of Previous to Current Requirements for Regulation 315.4

Previous Regulation Amended Regulation
Elected and Appointed Officials
Official did not need to attest to the accuracy of their Record of Activities (ROA). Official must sign their Record of Activities (ROA) to attest to its accuracy.
Regulation did not clearly address how frequently an official must/can submit an ROA.
  1. Official must submit a new ROA following a new or subsequent appointment or election.
  2. Official may attest that a previous ROA is still valid for up to eight years.
  3. Official may submit a new ROA if the previous ROA is not representative of their work hours.
Governing Body
Regulation did not address whether the governing body had the authority to determine whether activities are official duties of the position. Regulation now states that the employer determines whether activities listed on the ROA are official duties of the position and, if they are not, excludes the activity and time from the calculation of average number of days worked per month.
Clerk or Secretary
Employer had to include officials who participate in the employer’s time-keeping system on the Standard Workday and Reporting Resolution and indicate their participation by checking the box that says “Participates in the Employer’s Time-Keeping System.” Employer is no longer required to include officials who participate in the employer’s time-keeping system on the Standard Workday and Reporting Resolution.
Employer may omit NYSLRS registration numbers and social security numbers from the publically posted Standard Workday and Reporting Resolutions. Employer must omit NYSLRS registration numbers and Social Security numbers from the publically posted Standard Workday and Reporting Resolutions.
Employer had to submit the Standard Workday and Reporting Resolution to the State Comptroller within 45 days of the adoption of the resolution. Employer must submit the Standard Workday and Reporting Resolution to the State Comptroller within 15 days after the 30-day public posting period ends.
Employer had to keep copies of the officials’ Records of Activities for 10 years. Employer must keep copies of the officials’ Records of Activities for 30 years.
Regulation did not address whether the Secretary or Clerk had to provide the average number of days worked per month listed on the standard work day and reporting resolution to the individual(s) responsible for reporting days worked to the Retirement System on the employer’s behalf. Once a standard work day and reporting resolution is passed, the Secretary or Clerk must provide the average number of days worked per month listed on the standard work day and reporting resolution to the individual(s) responsible for reporting days worked to the Retirement System on the employer’s behalf.

(Rev. 6/16)