Current through Register Vol. 49, No. 9, September, 2024
RULE13-1
ADMINISTRATION ADJUDICATIONS: STAFF DETERMINATIONS AND APPEALS
A.C.A. §§
25-15-201 to 219
I.
Scope and Purpose
A. The purpose of this rule is to govern
practice and procedure before ATRS and the Board of Trustees ("Board")
involving any issue or claim ("claim(s)") arising as a result of any
administrative decision or staff determination of ATRS relating to any
retirement plan or program administered by ATRS. ATRS staff is responsible for
administering ATRS members' accounts. Sometimes, the staff will make a
determination based on ATRS rules and the rule of law that may be adverse to a
member's claim. This rule outlines the procedure for a member to appeal a
decision of ATRS.
B. This rule
applies to any claim of a member. For purposes of this rule, "member" includes
any member of ATRS as defined in A.C.A. §
24-7-702, as well as any
beneficiary of a member; any retiree of ATRS; any guardian, administrator, or
executor of a member, retiree, or beneficiary; or any public school (all such
categories of persons shall be referred to within this rule as the
"member").
C. This rule should be
read in conjunction with the Arkansas Administrative Procedures Act.
See A.C.A. §§
25-15-201 -219 (the "APA"). To the
extent any term or provision of this rule conflicts with any term or provision
of the APA, the terms and provisions of the APA shall supersede this rule and
control. This rule does not apply to claims or causes of action that ATRS or
the Board may have against a member or any other person or entity, regardless
of the origin or nature of the claim.
D. The Board and the ATRS Executive Director
have the power to extend any deadline applicable to a member's appeal upon a
showing of good cause, except when a Hearing Officer has been assigned, in
which case such power shall rest with the Hearing Officer until the completion
of the hearing.
E. When compliance
with this Rule is based on "delivery", delivery is the earlier of either the
date of the postmark, if posted with the United States Postal Service, or the
date of actual delivery by one of the following methods:
i. Hand delivery;
ii. Electronic transmission; or
iii. Delivery service other than USPS.
II.
Informal Resolution Encouraged
Claims by a member are usually settled by mutual agreement
through correspondence or informal conference between the member and the staff
of ATRS. The staff and the member are strongly encouraged to engage in a good
faith attempt to mutually resolve claims based upon proper application of the
laws, statutes, and rules which govern the operation and administration of ATRS
plans and programs to the specific facts of the member's claim.
III.
Staff
Determinations
A. If the staff makes a
determination that is adverse to a member's claim, ATRS shall issue a Staff
Determination Letter to the member. The letter shall detail the reasons for the
decision. The member may disagree with the staff determination based upon a
factual dispute or a dispute regarding the application of the rules and law.
All reasonable efforts will be made to informally resolve the issue with the
member. For claims that are not resolved informally, a member may appeal the
staff determination to the Executive Director.
B. The decision stated in the Staff
Determination Letter issued in accordance with this rule will become a final
administrative decision and final agency action on the thirty-first
(31st) day following the date of the Staff
Determination Letter unless the member requests a timely Executive Director
review.
IV.
Executive Director ReviewA. The
member may request a review of the staff determination by the Executive
Director no later than close of business thirty (30) calendar days after the
date of the Staff Determination Letter. If the last day to file the request
falls on an official state holiday or weekend, then the request must be
delivered to the Executive Director no later than close of business on the next
business day. The Executive Director will promptly acknowledge the member's
request for review.
B. The member
shall not be required to resubmit any documents or information with the written
request for Executive Director review. If the member believes that the
Executive Director should review any relevant documents or information not
previously submitted to ATRS, the member may submit such information to the
Executive Director. Any additional information must be delivered to the
Executive Director within thirty-five (35) calendar days of the date of
Executive Director's acknowledgment letter.
C. The Executive Director will conduct an
independent review of the facts and the law, taking into consideration the
staff determination as well as any relevant information provided by the member.
After the review period, which may vary in length according to the facts of the
member's claim, the Executive Director will issue an Executive Director Review
Determination Letter to the member on the claim.
D. The Executive Director may affirm,
reverse, or modify the staff determination at any time prior to the final
determination of the Board. The Executive Director shall provide to the member
the applicable statutes and rules used in reaching the decision and a summary
of the factual basis and legal conclusions for the Executive Director's
decision. Unless the member initiates a timely appeal of the Executive
Director's decision in accordance with this rule, the decision of the Executive
Director will become a final administrative decision and final agency action on
the 31st day following the date of the Executive Director Review Determination
Letter.
V.
Appeals
to the Board
A. Any decision of the
Executive Director regarding a staff determination may be appealed to the
Board. In order to initiate an appeal, the member must deliver to the address
below a signed written Notice of Appeal to the Board within thirty (30)
calendar days of the date of the Executive Director Review Determination
Letter. The Notice of Appeal may be in the form of a letter addressed to:
AIRS Board of Trustees
Member Appeals
ATTN: Legal Department
1400 West Third Street
Little Rock, Arkansas 72201
B. All appeals from an Executive Director
decision to the Board will be assigned to a Hearing Officer, who will conduct
an administrative hearing, recommend factual and legal determinations, and
prepare a proposed order to the Board that includes findings of fact and
conclusions of law. The Executive Director or his designee shall appoint the
Hearing Officer from a list of qualified individuals approved by the Executive
Director.
C. Following appointment,
the Hearing Officer shall issue a written scheduling order to the member, the
Executive Director of ATRS, and the legal counsel of ATRS. The scheduling order
shall contain all information required under the Arkansas Administrative
Procedures Act. (See A.C.A. §
25-15-208.) The Hearing Officer, at his or
her discretion, may include in the scheduling order reasonable deadlines for
the submission and exchange of exhibits, witness lists, and related materials
prior to the hearing, including but not limited to, any requested proposed
findings of fact and conclusions of law. Unless otherwise ordered, hearings
shall be held at the offices of ATRS, 1400 West Third Street, Little Rock,
Arkansas 72201.
D. The Hearing
Officer may continue any scheduled matter at his or her discretion for good
cause shown by any party or counsel of record.
VI.
Filing of Documents
A. Following the appointment of a Hearing
Officer, all correspondence, documents, requests, submissions, or filings of
any type relating to an appeal shall be mailed or hand delivered to:
Arkansas Teacher Retirement System
Legal Department
1400 West Third Street
Little Rock, Arkansas 72201
B. Any party submitting or filing a document
relating to an appeal shall simultaneously deliver a copy of the filing or
document to the opposing party (or opposing counsel, if applicable). It shall
be the responsibility of AIRS to ensure:
(a)
that copies of all correspondence, documents, requests, submissions, and
filings relating to an appeal are provided in a timely manner to the Hearing
Officer; and
(b) that a complete
record of each appellate proceeding before a Hearing Officer and the Board is
prepared and maintained in a single, centralized location.
VII.
Hearings
A. The hearing is an administrative hearing
before the Hearing Officer, and is not a hearing before the Board. Hearings
will be conducted according to this rule and the corresponding procedural
provisions of the Arkansas Administrative Procedures Act (See A.C.A. §
25-15-213). The member shall at all times have the right to counsel, provided
that such counsel:
(a) is duly licensed to
practice law in the State of Arkansas; or
(b) has been granted permission to appear
pro hac vice by the Hearing Officer. All hearings shall be
conducted in an orderly manner. The Hearing Officer shall have the authority to
maintain the decorum of the hearing and may clear the hearing room of witnesses
not under examination.
B. If the member fails to appear at the
hearing, the member waives his or her right to present evidence and argument to
the Hearing Officer, and the Hearing Officer may proceed with the hearing and
prepare a proposed order to the Board based on the evidence
presented.
C. The Hearing Officer
shall have the authority to administer oaths and affirmations. Each party shall
be entitled to examine and cross-examine witnesses, present evidence, make
arguments, and generally participate in the conduct of the proceeding. The
Hearing Officer may question a witness during any portion of the direct or
cross-examination of such witness. Ail testimony to be considered by the
Hearing Officer, except matters officially noticed or entered by stipulation,
shall be sworn testimony. Before giving testimony, each person shall swear or
affirm that the testimony about to be given shall be the truth, the whole truth
and nothing but the truth.
D. The
hearing shall be informal and formal rules of evidence shall not apply. In
conducting a hearing, the Hearing Officer shall not be bound by the formal
rules of evidence, and no informality in any proceedings or in the manner of
taking of testimony shall invalidate any order or decision of the Board. The
Hearing Officer may admit into the record any evidence that in the judgment of
the Hearing Officer:
i. Has a reasonable
degree of probative value and trustworthiness; or
ii. Is of a type or nature commonly relied
upon by reasonably prudent people in the conduct of their affairs. The Hearing
Officer may exclude evidence that is irrelevant, immaterial, or unduly
repetitious. Objections to evidentiary offers may be made and shall be noted of
record.
iii. Following the close of
evidentiary submissions and witness testimony, the Hearing Officer may in his
or her discretion allow summations and closing arguments by the
parties.
E. ATRS shall
arrange for a court reporter to attend and record all hearings. Documents
received into evidence by the Hearing Officer shall be marked and filed as part
of the record. ATRS shall be responsible for payment of the cost of the
preparation of the transcript. Upon receipt of the transcript of the hearing,
ATRS shall promptly forward a copy of the transcript to the Hearing Officer and
the member (or counsel for the member, if applicable).
VIII.
Post-hearing Briefs
A. Upon the completion of the hearing, the
Hearing Officer may allow the parties to submit post-hearing briefs to be
included as part of the record on appeal. The decision whether to allow the
submission of post-hearing briefs is committed to the sole discretion of the
Hearing Officer. A decision by the Hearing Officer to not allow post-hearing
briefs shall have no effect on the validity of any order or decision issued by
the Board.
B. If the Hearing
Officer grants the member or ATRS an opportunity to submit a post-hearing
brief, the Hearing Officer shall provide the opposing party an opportunity to
submit a response. The Hearing Officer shall have discretion to set reasonable
deadlines for the parties to submit post-hearing briefs and responses, provided
that the parties shall be allowed a minimum of fourteen (14) calendar days from
the date of receipt of the transcript of the hearing before any initial
post-hearing brief shall be due for filing.
IX.
Proposed Orders
Once the Hearing Officer receives all evidence, arguments, and
post-hearing briefs (if any), the record before the Hearing Officer shall be
officially closed. Once the record is closed and after considering all of the
evidence, the Hearing Officer shall, as soon as practical, prepare a proposed
order to be delivered to the Board of Trustees. The proposed order shall
include findings of fact based exclusively on the evidence and testimony in the
record of the hearing, conclusions of law, and a recommendation to the Board of
Trustees. The Hearing Officer shall provide the proposed order to the Board at
ATRS via facsimile and United States mail at the address listed in Section VI
of this rule. Upon receipt of the proposed order, ATRS shall mail a copy of the
proposed order to the member (and his or her counsel, if applicable) via
Certified, First Class, United States mail, with a copy to the Executive
Director.
X.
Written
Objections to Proposed Order
The member shall have the right to file a written statement of
objections outlining any objections, exceptions, and/or arguments that the
member desires the Board to consider in its evaluation of the Hearing Officer's
proposed order. Any statement of objections by the member must be delivered to
ATRS within twenty-one (21) calendar days of receipt of the Hearing Officer's
proposed order. The member may not introduce additional evidence or testimony
in the statement of objections. Counsel for ATRS may prepare a written response
to any statement of objections filed by the member. A copy of any response by
ATRS shall be provided to the member and the Board prior to the Board meeting
at which the Hearing Officer's proposed order on the member's appeal is
scheduled to be considered by the Board.
XI.
Board Consideration of Proposed
OrderA. The Board will make a final
determination on the Hearing Officer's proposed order. The Board's
consideration of the Hearing Officer's proposed order will be scheduled within
a reasonable time to be heard, at a regular Board meeting after the issuance of
the proposed order. The Board may call an emergency meeting to consider the
Hearing Officer's proposed order if the situation warrants. ATRS shall notify
the member or the member's counsel in writing of the date, time, and location
of the Board Meeting.
B. Before
rendering a decision on the Hearing Officer's proposed order, the Board may
request that the member (and his or her attorney, if applicable) make a brief
statement to the Board concerning the facts and any arguments the member wishes
to present and respond to any questions from the Board. The Board's
consideration of the matter will not require the Board to conduct another
hearing, and will be based on the hearing previously conducted before the
Hearing Officer. The Chairman of the Board will have final authority to set the
amount of tinne any party may have to make a statement to the Board.
C. Failure of the member to appear at the
meeting of the Board without prior notification will result in the member
waiving his or her right to be heard by the Board. The member may petition the
Board for another opportunity to address the Board, and,jf the Board determines
that the member's absence was for good cause, it may grant the
petition.
D. After consideration by
the Board of the Hearing Officer's proposed order, the Board has the final
authority to accept or reject all or part of the Hearing Officer's proposed
order. The Board may:
i. Accept the Proposed
Order;
ii. Reject the proposed
order; or
iii. Accept the Proposed
Order as modified by the Board.
E. If the Board elects to reject the Proposed
Order or accept the Proposed Order as modified, the Board may:
i. Make its own Findings of Fact and
Conclusions of Law and issue its own Order based upon those findings and
conclusions and may consider manifest injustice as a basis for any remedy;
or
ii. Remand the matter in whole
or in part to the Hearing Officer for reconsideration or for additional
findings of fact and/or additional conclusions of law.
F. As in all matters before the Board, a
quorum of votes is_necessary to approve any motion, resolution, or order under
consideration.
G. Following a
decision of the Board with respect to the Hearing Officer's proposed order, the
Board shall cause to be prepared a written final order on the member's appeal.
The Board's final order shall include separate findings of fact and conclusions
of law relied upon by the Board in formulating the final order. A copy of the
Board's final order (including the Board's findings of fact and conclusions of
law) will be delivered via Certified, First Class, United States mail to the
member (and any counsel) by the Executive Director.
XII.
Authority to Settle
At any time prior to the issuance by the Board of a final order,
the Executive Director is authorized to settle any claim in a manner mutually
agreeable to ATRS and the member. In settling any claim, the Executive Director
shall not exceed the authority previously granted to him or her by the Board.
The Executive Director shall report to the Board any settlement that occurs
after the Hearing Officer issues a proposed order.
XIII.
Appeals Under the APA
Any member receiving an adverse ruling from the Board retains
certain rights under the Arkansas Administrative Procedures Act (See A.C.A.
§§
25-15-201 to -219.) The member may file a petition for judicial
review. Any petition for judicial review of a final Board administrative
decision shall be filed in Pulaski County Circuit Court. See
A.C.A. §
25-15-212 and §
24-7-211. Such action must be filed
within thirty (30) days after service upon the member of the Board's final
order. See id.
XIV.
Communications With the Hearing
Officer and Board of Trustees
A. The
Arkansas Administrative Procedures Act prohibits direct or indirect
communications by the members and employees of ATRS with a Hearing Officer or
the Board in connection with any issue of fact or law regarding an appeal,
except upon notice that provides an opportunity for all parties to participate.
Hearing Officers and the members of the Board will not consider any "ex-parte"
or "off-the-record" evidence or statements made to them by the member or any
employee of ATRS in connection with a pending appeal.
B. This Section does not preclude
communications by and between the Hearing Officer, ATRS Staff, and/or the Board
concerning minor scheduling and procedural matters necessary to the timely and
efficient processing and handling of appeals under these rules.
Approved: February 1, 2010 (Emergency)
June 7, 2010 Permanent
Approved by Board: July 26, 2013
Amended: October 9, 2013
Effective: Novembers 8, 2013
FINAL Approval by Board: February 5, 2018
Effective: