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Can retirees be rehired as independent contractors/consultants since they’re not UM employees?

If the retiree meets all of the IRS and UM criteria required to be an independent contractor or consultant, the retiree may be hired as such since contractors are not considered UM employees. However, this mechanism must not be utilized in order to circumvent the policy of reemploying retirees. Contractor and consultant appointments must be approved in advance by campus business services.