Cheryl Rich v. Office of Personnel Management

CourtMerit Systems Protection Board
DecidedApril 16, 2024
DocketPH-0831-21-0067-I-1
StatusUnpublished

This text of Cheryl Rich v. Office of Personnel Management (Cheryl Rich v. Office of Personnel Management) is published on Counsel Stack Legal Research, covering Merit Systems Protection Board primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cheryl Rich v. Office of Personnel Management, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

CHERYL RICH, DOCKET NUMBER Appellant, PH-0831-21-0067-I-1

v.

OFFICE OF PERSONNEL DATE: April 16, 2024 MANAGEMENT, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Cheryl Rich , Blackwood, New Jersey, pro se.

Carla Robinson , Washington, D.C., for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which upheld the reconsideration decision of the Office of Personnel Management (OPM) finding the appellant was overpaid $14,077 in annuity benefits and was ineligible for a waiver of recovery of the overpayment, and adjusting the repayment schedule from 36 monthly installments of $391.02 with a final 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions. In contrast, a precedential decision issued as an Opinion and Order has been identified by the Board as significantly contributing to the Board’s case law. See 5 C.F.R. § 1201.117(c). 2

payment of $0.28, to 93 monthly installments of $150 with a final payment of $127. Generally, we grant petitions such as this one only in the following circumstances: the initial decision contains erroneous findings of material fact; the initial decision is based on an erroneous interpretation of statute or regulation or the erroneous application of the law to the facts of the case; the administrative judge’s rulings during either the course of the appeal or the initial decision were not consistent with required procedures or involved an abuse of discretion, and the resulting error affected the outcome of the case; or new and material evidence or legal argument is available that, despite the petitioner’s due diligence, was not available when the record closed. Title 5 of the Code of Federal Regulations, section 1201.115 (5 C.F.R. § 1201.115). After fully considering the filings in this appeal, we conclude that the petitioner has not established any basis under section 1201.115 for granting the petition for review. Therefore, we DENY the petition for review and AFFIRM the initial decision, which is now the Board’s final decision. 5 C.F.R. § 1201.113(b).

BACKGROUND The appellant retired from Federal service in April 2019 and began receiving an annuity under the Federal Employees’ Retirement System (FERS). Initial Appeal File (IAF), Tab 2 at 1, Tab 16 at 96-99. In May 2020, the appellant became entitled to Social Security Disability Insurance (SSDI) benefits, retroactive to October 1, 2019. IAF, Tab 2 at 1, Tab 16 at 28. Between October 1, 2019, and May 1, 2020, the appellant’s FERS annuity benefit was not reduced by the SSDI benefit as required by 5 U.S.C. § 8452, resulting in an overpayment of $14,077. IAF, Tab 2. The appellant requested reconsideration of OPM’s findings, and OPM issued a reconsideration decision that denied the appellant’s request for a waiver. Id. OPM adjusted the repayment schedule from 36 monthly installments of $391.02 and a final payment of $0.28, to 93 monthly installments of $150 and a final payment of $127. Id. at 4. 3

The appellant filed an appeal with the Board. Petition for Review (PFR) File, Tab 1. The administrative judge issued an initial decision upholding OPM’s reconsideration decision, including the reduced repayment schedule of 93 monthly installments of $150 and a final payment of $127. IAF, Tab 19, Initial Decision (ID). The appellant has filed a petition for review, and the agency has filed a response. PFR File, Tabs 1, 4.

DISCUSSION OF ARGUMENTS ON REVIEW The appellant’s petition for review does not dispute the existence or amount of the overpayment. PFR File, Tab 1. The appellant requests to be “responsible for half” the debt or, in the alternative, an adjustment to the repayment schedule based on financial hardship. Id. We construe the appellant’s request to be “responsible for half” the debt as a request for waiver of one-half of the debt. However, once the Board finds that an overpayment occurred and that the amount of the debt is correct, it lacks any authority in statute or regulation to unilaterally reduce the amount of the debt. Gott v. Office of Personnel Management, 97 M.S.P.R. 538, ¶ 10 (2004). The Board has the statutory authority to order OPM to waive recovery of the entire overpayment if the recipient shows both that she is without fault and that recovery would be against equity and good conscience. 5 U.S.C. § 8470(b); Boone v. Office of Personnel Management, 119 M.S.P.R. 53, ¶ 5 (2012); 5 C.F.R. § 845.301. When the appellant is not without fault in creating the overpayment, she is not entitled to a waiver of the overpayment. Boring v. Office of Personnel Management, 79 M.S.P.R. 600, ¶ 4 (1998). We agree with the administrative judge’s finding that the appellant is not without fault in creating the overpayment, and therefore she is not entitled to a waiver of the debt. ID at 4-6; see id., ¶ 4. We also agree with the administrative judge’s finding that the appellant knew or should have known that she was receiving an overpayment, and therefore the set-aside rule applies, requiring the 4

appellant to have preserved the overpaid funds for repayment to OPM. ID at 4-6; see James v. Office of Personnel Management, 72 M.S.P.R. 211, 217 (1996). Because the set-aside rule applies, financial hardship is not a basis for waiver. See Dorrello v. Office of Personnel Management, 91 M.S.P.R. 535, ¶ 7 (2002). Although the appellant is ineligible for waiver, she may be entitled to an adjustment of the recovery schedule if she demonstrates that it would cause her financial hardship to make payment at the scheduled rate. See id.; 5 C.F.R. § 845.301. The appellant’s request for the monthly repayment schedule to be reduced from $391.02 appears to misunderstand OPM’s reconsideration decision and the initial decision, which adjusted the repayment schedule from 36 monthly installments of $391.02 with a final payment of $0.28, to 93 monthly installments of $150 with a final payment of $127. PFR File, Tab 1 at 3; IAF, Tab 2; ID at 7. The appellant does not assert, and we discern no basis to find, that the repayment of $150 monthly would cause a financial hardship. The appellant submitted a Financial Resource Questionnaire (FRQ) asserting a monthly income of $4,341 and monthly expenses of $3,732.49, resulting in a monthly surplus of $608.51. IAF, Tab 16 at 54-57. The administrative judge accepted these representations and found the appellant’s expenses to be normal and ordinary living expenses. ID at 6-7. The appellant asserts in her petition for review that she recently accrued a monthly expense of $269 for her car in addition to her other bills, that her monthly mortgage payment is $1,311, and that she will have upcoming medical expenses and an increase to her insurance costs. PFR File, Tab 1.

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Cheryl Rich v. Office of Personnel Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cheryl-rich-v-office-of-personnel-management-mspb-2024.