FROM: Christina Cintron, Chief of Member Services
SUBJECT: Returning Retiree Certification: Angela Walker
RECOMMENDATION:
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Approve the request to extend the employment of Angela Walker from March 7, 2026 through April 7, 2027, in accordance with SBCERA Benefits Policy No. 032, Retirees Returning to Work.
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BACKGROUND:
The California Public Employees’ Pension Reform Act of 2013 (PEPRA) establishes limitations for retirees returning to work in the same retirement system from which they receive a pension. Under SBCERA Benefits Policy No. 032, extensions beyond 18 consecutive months of re-employment must be approved by the Board of Retirement and are permitted only under conditions of Extreme Necessity and for a Limited Duration.
Angela Walker retired from San Bernardino County as a Deputy Sheriff on April 16, 2023, after more than 26.5 years of service. On January 4, 2024, the Board of Retirement granted Ms. Walker a service-connected disability retirement.
Pursuant to SBCERA Benefits Policy No. 032, Section II.A.1(b)(vi), a retiree who has been granted a disability retirement may return to work for an SBCERA-covered employer only if the duties to be performed do not conflict with, or arise from, the medical condition upon which the disability retirement was based. The policy further requires documentation sufficient to demonstrate that the proposed re-employment is consistent with the retiree’s disability status.
In compliance with Policy No. 032, Ms. Walker completed a Returning Disabled Retiree Questionnaire and submitted a physician’s note confirming that her disability does not impose restrictions affecting her upper extremities. Based on the duties described by the employer in both the original certification request and the current extension request, the proposed re-employment does not conflict with the condition underlying her service-connected disability retirement.
Ms. Walker’s original Returning Retiree Certification in a Safety Unit Extra Help classification was approved by staff and was effective September 7, 2024 through March 6, 2026. The present request represents the first extension beyond the initial 18-month certification period.
CURRENT REQUEST:
The San Bernardino County Sheriff’s Department requests an extension of Ms. Walker’s Returning Retiree employment from March 7, 2026 through April 7, 2027, continuing in the classification of Safety Unit Extra Help.
EXTREME NECESSITY:
The employer reports that Ms. Walker is assigned to perform background investigations for public safety dispatcher candidates within the Sheriff’s Department. These duties include conducting pre-employment background investigations and completing required documentation in accordance with standards established by the California Commission on Peace Officer Standards and Training (POST).
POST is the state agency responsible for establishing minimum selection and training standards for law enforcement personnel and public safety dispatchers. Under POST regulations, a thorough background investigation must be completed for each dispatcher candidate prior to appointment, making completion of the investigation a mandatory prerequisite to hiring and onboarding qualified applicants.
The employer represents that Ms. Walker is currently the sole individual assigned to conduct background investigations for public safety dispatcher candidates. As such, completion of dispatcher background investigations is dependent upon her availability to perform these functions.
In addition to conducting background investigations, the employer reports that Ms. Walker assists with annual POST audits, which evaluate compliance with selection standards, including review of moral character assessments and verification of the absence of disqualifying conduct. These audits ensure that dispatcher candidates meet POST suitability requirements and that the Department maintains compliance with state-mandated selection standards.
The employer further reports that timely completion of background investigations directly impacts the Department’s ability to hire and onboard dispatcher candidates. Dispatcher vacancies affect operational staffing levels within emergency communications, where dispatchers are responsible for receiving emergency calls and coordinating law enforcement response. While the absence of Ms. Walker would not result in a complete stoppage of public business, the employer indicates that it would require redistribution of investigative and compliance responsibilities to other personnel who are managing existing workloads and may result in delays in hiring dispatcher candidates until a successful replacement investigator can be recruited.
Based on her more than 26 years of law enforcement experience, including prior service as a Deputy Sheriff, Ms. Walker is able to conduct background investigations efficiently and in compliance with applicable standards. Her experience and familiarity with departmental practices allow her to complete investigations within established timelines and support continuity in the dispatcher hiring process.
Taken together, these factors demonstrate that Ms. Walker’s continued limited assignment is necessary to support timely completion of state-mandated background investigations and to avoid disruption to dispatcher hiring and onboarding efforts.
LIMITED DURATION/COMPLETION OF WORK:
The employer indicates that Ms. Walker’s Returning Retiree appointment remains temporary and is tied to the operational need to conduct background investigations for public safety dispatcher candidates in accordance with POST standards. Ms. Walker serves in an Extra Help capacity supporting the Department’s background investigation workload.
SBCERA Benefits Policy No. 032 provides that re-employment beyond 18 consecutive months may be considered limited in duration where the employer demonstrates ongoing recruitment efforts with an anticipated staffing endpoint. The Sheriff’s Department has represented that it is working with San Bernardino County Human Resources to recruit additional Background Investigators.
The Department indicates that Ms. Walker’s continued assignment is intended to provide interim support during the requested extension period while additional Background Investigators are recruited and onboarded. Her appointment remains classified as Extra Help and is not structured as a permanent appointment within the Department’s authorized staffing structure.
Because the assignment is connected to active recruitment efforts and is intended to supplement staffing capacity during the requested extension period, the employer has identified a temporary operational need consistent with the Limited Duration requirement under Policy No. 032. These factors collectively satisfy the Limited Duration standard.
RECRUITMENT EFFORTS:
The employer reports that it is actively working with San Bernardino County Human Resources to recruit for the Background Investigator classification. The Sheriff’s Department has an open recruitment for a recurrent Sheriff’s Background Investigator position.
The employer represents that recruitment efforts are ongoing in order to increase permanent staffing capacity within the background investigation function and to support continued hiring and onboarding of public safety personnel.
LEGAL AND POLICY CONSIDERATIONS:
Pursuant to SBCERA Benefits Policy No. 032 and applicable PEPRA provisions, Board approval for re-employment beyond 18 consecutive months requires that the request satisfy both of the following conditions:
1. Extreme Necessity: The employer must demonstrate that the re-employment is essential to maintain effective operations due to genuinely unforeseen or unavoidable circumstances; and
2. Limited Duration / Completion of Work: The re-employment must relate to the completion of a specific, time-bound task or project, or meet one of the limited-duration conditions defined in Policy No. 032.
• Hard-to-Recruit Positions: Temporary placement in a classification requiring specialized skills, certifications, or qualifications that are difficult to recruit for in the labor market, supported by documented and ongoing recruitment efforts; or
• Stoppage of Public Business: Re-employment necessary to prevent interruption of essential government functions where such interruption would directly compromise public safety, security, welfare, or the effective administration of justice.
Based on the employer’s statements and the supporting documentation submitted, staff finds that the request satisfies the Extreme Necessity and Limited Duration requirements set forth in SBCERA Benefits Policy No. 032.
CONCLUSION:
Based on the justification provided and the supporting documentation submitted, staff recommends that the Board approve the Returning Retiree extension request for Angela Walker in accordance with SBCERA Benefits Policy No. 032 and applicable PEPRA provisions.
BUDGET IMPACT:
None.
STRATEGIC PLANNING GOAL/OBJECTIVE:
Operational Excellence & Efficiency
STAFF CONTACT:
Christina Cintron
ATTACHMENTS:
Exhibit A: Board Summary Worksheet
Exhibit B: Current Certification Form
Exhibit C: Prior Certification Request