$17.5 Million: The Price of CCSD's Substitute Hour Fix

Clark County School District estimates the annual cost to fix a retirement compliance gap at between $15 million and $17.5 million. The district is restructuring substitute teaching hours to meet a 2023 state law that expanded Public Employees' Retirement System benefits.

A review led by the finance department and Chief Financial Officer Justin Dayhoff found the district failed to enroll substitutes who worked more than 719 hours into the PERS plan. Because of this oversight, the district did not split the required retirement contributions with those employees. Dayhoff stated that roughly 2,600 employees were affected between fiscal years 2024 and 2026.

The district has begun adjusting how these teachers work. Substitutes projected to exceed 719 hours in a year can choose a PERS-eligible position that requires full-year work. They can also continue without enrolling in the system, but their hours will be capped. All other substitutes will also face hour limits.

Lois Glenn Carter, a substitute teacher, spoke during public comment at a school board meeting. She noted that substitutes did not ask for their hours to be restricted. "Nor should they bear the consequence of the district failure to implement the legislation," Carter said. She asked the district to commit to reviewing every eligible long-term substitute. She also requested a determination of the full retroactive financial obligation for those records.

One school board trustee asked why the district would not wait for the next legislative session. The trustee wanted to know if lawmakers might change the law. Dayhoff explained the district could not hedge against legislative action. He said the risk to the district could amount to millions of dollars. "That could instead be in the classroom with kids," Dayhoff said.

The district says it is already working to bring its practices into compliance. The changes apply to the current fiscal year. The goal is to align hiring and scheduling with the 2023 retirement benefits law.