* Short version…
The Tier 2 fix is what convinced the Associated Fire Fighters of Illinois to sign on to the plan. So, any changes to that could imperil the whole thing.
* Excerpt from long version…
As indicated by the discussion above, determining when or if Tier 2 benefits will violate IRS rules is not simple. The analysis must consider the pension multiplier as well as the growth in the pensionable salary cap. Supporters of Senate Bill 616 have not as yet shown whether the proposed changes are needed to satisfy legal requirements and, if they are needed, whether they must be implemented immediately.
To the extent that growth in the pensionable salary cap is an issue, it remains to be seen whether Senate Bill 616 solves the problem. The legislation proposes that the salary cap grow by 3% or the inflation rate, whichever is less. This is clearly a faster rate than the current formula of the lesser of 3% of one-half of the inflation rate, but it does not match the national average wage index used to calculate growth in the Social Security wage base. The difference might be accounted for by the proposed change in the calculation of final average salary, which lowers the required multiplier under IRS rules.
Up to now, neither the Governor’s task force nor supporters of Senate Bill 616 have publicly provided actuarial reviews showing the cost of the Tier 2 changes for the affected police and fire funds. In the task force report, the cost is estimated at $70 million to $95 million over five years, or $14 million to $19 million per year, but there is no supporting documentation for the estimate.
The task force also noted that these estimated costs are minor compared to increases in investment returns projected to be earned by the consolidated funds compared with the 649 existing police and fire funds. The task force estimated that the consolidated funds could generate an additional $820 million to $2.5 billion in investment returns over five years, or $164 million to $500 million per year.
However, it should be noted that these increased returns are not guaranteed. Any increase in actual returns will be partly due to the consolidated funds’ ability to invest in riskier investments. State law restricts the securities that the existing police and fire funds are allowed to hold. In addition, because the assumed rate of return is used as the discount rate for pension liabilities, an increase in the expected return rate by the consolidated funds would also reduce statutorily required annual pension contributions. Senate Bill 616 requires that contribution changes due to changes in actuarial assumptions be phased in over three years.
Since Tier 2 applies to nearly all pension funds across the State, there could be a move to simply apply the same changes to all funds statewide, also without first determining whether the changes are the minimum necessary so as not to impose additional fiscal hardship on already struggling governments.
In recent years, the State has frequently rushed to enact pension changes without actuarial evaluation and public disclosure of their financial impact. The latest example involved pension buyouts, which were budgeted to reduce General Funds contributions by more than $400 million in FY2019 but ended up saving about $13 million that year. The original savings estimate was based largely on a different buyout plan; the enacted plan surfaced in the last days of the spring 2018 legislative session and was not vetted by pension actuaries before being approved by lawmakers.
The Civic Federation urges the Governor’s Office and sponsors of Senate Bill 616 to demonstrate the need for the specific Tier 2 enhancements in the legislation. In addition, they must ensure that the financial impact of any proposed Tier 2 changes is fully evaluated by pension actuaries and publicly disclosed before any action is taken by the General Assembly.
I’m hearing there could be an announcement this afternoon about the consolidation bill. Stay tuned.