FROM: Christina Cintron, Chief of Member Services
SUBJECT: Returning Retiree Certification: Ellen Hargrove
RECOMMENDATION:
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Approve the request to extend the employment of Ellen Hargrove from January 3, 2026, through June 30, 2027, in accordance with SBCERA Benefits Policy No. 032, Retirees Returning to Work. The request meets the policy criteria for extensions beyond the 18-month employment limit, based on the employer’s demonstration of extreme necessity and the time-limited scope of the assignment
(limited duration).
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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.
Ellen Hargrove retired from San Bernardino County, Department of Public Works - Special Districts on March 9, 2024, after over 39 years of service with the County. At the time of her retirement, she was serving as a Special Districts Project Manager. Her original returning retiree certification covered the period from October 7, 2024, through January 2, 2026, during which she resumed duties in the same classification.
CURRENT REQUEST:
The employer requests an extension of Ms. Hargrove’s returning retiree employment from January 3, 2026, through June 30, 2027, continuing in the classification of Special Districts Project Manager for the Department of Public Works.
Extreme Necessity:
The employer reports that Ms. Hargrove is responsible for overseeing a major design contract tied to the California State Water Resources Control Board’s October 2027 compliance deadline for addressing the presence of chromium-6 in five Hesperia wells. Chromium-6 is a toxic heavy metal that can pose serious long-term health risks, including increased cancer risk, when present in drinking water. Because of these well-documented risks, the State has established strict treatment and compliance standards, making timely progress on this project essential to protecting public health.
Failure to meet these regulatory deadlines could jeopardize both current and future funding opportunities for critical water and wastewater infrastructure improvements. While Ms. Hargrove’s absence would not result in a complete stoppage of public business, the department reports that it would significantly increase the risk of non-compliance with State requirements, expose the County to potential fines, and delay progress on essential public health-related work.
The employer further explains that the remaining project managers are operating at full capacity. Redistributing Ms. Hargrove’s responsibilities would likely overextend existing staff, increasing the probability that key milestones will be missed and undermining the County’s ability to meet State-mandated deadlines.
Taken together, these factors demonstrate that Ms. Hargrove’s continued involvement is essential to meeting the State’s water quality requirements and preventing avoidable risks to public health and regulatory compliance. For these reasons, the request satisfies the Extreme Necessity requirement under Policy No. 032.
Limited Duration / Completion of Work:
The employer indicates that Ms. Hargrove’s returning retiree appointment remains temporary and is tied directly to a clearly defined, time-limited body of work. Her primary responsibility is managing the chromium-6 mitigation project, which must comply with the State Water Resources Control Board’s October 2027 deadline. This project has a finite scope and a foreseeable conclusion dictated by external regulatory requirements.
In addition to her project management duties, Ms. Hargrove is assisting in the development of newer project managers who have not yet acquired the specialized experience required to carry the project through to completion. Her continued involvement will help ensure continuity and prevent disruption as newer staff gain the necessary skills.
Because the work is driven by specific milestones and tied to a firm regulatory deadline, the employer has identified a discrete and time-limited scope of work that aligns with the requested extension period. These factors collectively satisfy the Limited Duration / Completion of Work requirement under Policy No. 032.
Recruitment Efforts:
The employer reports that recruitment for Project Manager positions has been ongoing for approximately three years and has included multiple attempts to fill vacancies. Several offers have been extended; however, some candidates did not complete the hiring process, some did not pass Human Resources screening, and others declined the position. During this same period, the division has also experienced employee turnover, which has offset hiring progress and contributed to continued staffing challenges.
Given these ongoing recruitment difficulties, the employer has continued active efforts to attract and onboard qualified candidates while managing operational needs with the staff currently available. Newer project managers are still developing the technical skill sets required for complex regulatory and infrastructure projects, and the department notes that Ms. Hargrove’s continued involvement supports both project continuity and staff development.
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, which may include:
• 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, staff finds that both the Extreme Necessity and Limited Duration conditions are satisfied in this case.
CONCLUSION:
Based on the justification provided, staff recommends that the Board approve the returning retiree extension request for Ellen Hargrove in accordance with SBCERA Benefits Policy No. 032 and PEPRA.
BUDGET IMPACT:
None.
STRATEGIC PLANNING GOAL/OBJECTIVE:
Operational Excellence & Efficiency
STAFF CONTACT:
Christina Cintron
ATTACHMENTS:
Exhibit A: Board Summary Worksheet
Exhibit B: Certification Extension Request
Exhibit C: Prior Certification Forms