How to Complete the FRS Employment Certification Form: Rule, Routing, and Penalties

The FRS Employment Certification Form, labeled “CERT” and tied to administrative rule 19-11.009 F.A.C., is the document a Florida Retirement System employer uses at the point of hire to verify whether a new employee is already a retiree of the FRS or another state-administered retirement system.¹ You download it from the MyFRS website, the new employee completes their section, an authorized representative of the hiring agency completes and signs the employer section, and the form goes to the Division of Retirement. It should be filled out before or on the first day of employment.

What the Form Does

The CERT form is how a Florida Retirement System employer documents that it has checked a new hire’s retirement status against the mandatory six-month termination requirement. Hiring an FRS retiree who has not been separated from all FRS employment for six full calendar months voids the retirement and makes the retiree and the employer jointly and severally liable for repaying every benefit dollar already paid out.² The form gives the employer a written record that it asked the question and the employee answered it, before onboarding goes any further.

Information the Employee Fills In

The employee section captures identifying details and the facts the Division needs to check the six-month window:

Full legal name, Social Security number, and contact information.
Retirement effective date, or DROP termination date if the employee participated in the Deferred Retirement Option Program.
The start date of the new position.
A certification stating whether the employee is currently retired from any state-administered retirement system. This is the central question the form exists to answer.

Have the retirement effective date (or DROP termination date) in hand before you start the form. Mismatches between what the employee writes here and what the Division has on file are one of the most common reasons the paperwork comes back for correction.

Information the Employer Fills In

The employer section is completed and signed by an authorized representative of the hiring agency. It requires:

The agency’s name.
The agency’s five-digit identification number.
The position title the employee is being hired into.
The effective date of hire.
The signature, printed name, title, and date of the authorized representative.

Signatures should be legible and the printed name should match the signature exactly. The employer signature is the agency’s attestation that it is aware of the employee’s retirement status and has evaluated the hire against the termination requirement.

Where to Send the Completed Form

The completed CERT form goes to the Division of Retirement. You can mail it to:

Division of Retirement
P.O. Box 9000
Tallahassee, FL 32315-9000³

Or fax it to 850-410-2010.³ Faxing is faster and gives you a transmission confirmation worth keeping as proof of filing. Whichever method you use, keep a signed copy for the employee’s personnel file and for the retiree’s own records. The blank form is downloadable from the Forms section of the MyFRS website.⁴

The Rule the Form Is Checking

Florida Statute 121.021(39) defines “termination” for retirements effective on or after July 1, 2010 as ceasing all employment with every FRS employer for six calendar months. If the retiree is employed by any FRS employer during that window, termination is deemed never to have occurred.⁵ There are no exceptions for part-time work, unpaid arrangements, or positions that happen to fall outside FRS coverage. The one carve-out, effective July 1, 2023, is for volunteer services performed in compliance with Section 121.091(15) of the Florida Statutes, which do not count as employment.²

For retirees whose effective date fell before July 1, 2010, the break period was one calendar month under the older rules, which still apply to those retirees.⁶

If the new hire participated in DROP, the six-month clock runs from the DROP termination date, not the original retirement effective date. The consequences of a violation are heavier for DROP participants: FRS membership gets reinstated retroactively to the date DROP began, and the agency must pay the difference between DROP contributions and the regular FRS contributions that would have been owed during the DROP period, plus 6.5 percent interest compounded annually.²

One boundary worth stating plainly: none of this applies to employment with an employer that does not participate in a state-administered retirement system. A retiree can take a private-sector job, work for the federal government, or freelance the day after retirement, and the CERT form is not needed.⁶

What a Missed or Wrong Certification Costs

If the form is skipped, filled in incorrectly, or signed in a situation where the employee hasn’t completed the six-month break, the fallout hits both sides:

The retirement is voided and the retiree is treated as though they never retired. Benefits already paid, including any DROP accumulation, must be returned to the FRS Trust Fund.²
The retiree and the employer are jointly and severally liable for the full repayment, meaning the Division can pursue either party for the entire balance.⁶
The retiree must submit a new retirement application with a later effective date to establish a new retirement.²

The voiding applies even when the specific position the retiree holds is not itself FRS-covered. What matters is whether the hiring agency participates in the system, not whether the particular job carries FRS membership.⁷ An hourly, non-benefited position at an FRS-participating school district still triggers the rule.

Other Forms That May Follow

The CERT form confirms status at hire. Depending on the situation, other forms may come into play afterward:

Form FR-23, Notification of Reemployment for Suspension of Retirement Benefits, applies to retirees whose reemployment falls under older rules that required benefit suspension during a limitation period.⁴
Form FR-23A, Application to Reactivate Retirement Benefits, is used to restart suspended pension payments once the retiree leaves the position or the limitation period ends.⁴
A new beneficiary designation (Form BEN-001 for the Pension Plan or IPBEN-1 for the Investment Plan) should be filed by a reemployed retiree who earns renewed membership, so the designation covers any benefits earned during the second period of employment.²

1
MyFRS. FRS Employment Certification Form
2
Florida Retirement System. Division of Retirement Employer Handbook – Chapter 13 Reemployment After Retirement
3
Florida Department of Management Services. Contact Us
4
MyFRS. FRS Resources Forms
5
Florida Statutes. Florida Code 121.021 – Definitions
6
Florida Statutes. Florida Code 121.091 – Benefits Payable Under the System
7
MyFRS. FRS Programs Comparing the Plans Reemployment After Retirement