Every year, ERSGA staff receives questions about rehired retirees
and the 1,040 hours return-to-work provisions. One of the most
frequent rehired retiree questions is in regard to independent
contractors not on the payroll. Employers should know that few
rehired retirees working as independent contractors are exempt
from 1,040 hour reporting. The exemption to the 1,040 hour
reporting requirement only applies to independent contractors who
meet all of the following exceptions: