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HR-222 Payroll FICA Exemption Q&As

  1. Is FICA exemption limited to those working and enrolled at the University of Missouri?
    Yes. The exemption from FICA for students is specifically limited to those students working at the institution where they are enrolled in University classes, generally at least half-time basis. However, University of Missouri medical and veterinary residents are considered career employees and thus are not eligible for FICA exemption.

    Students enrolled at an institution other than the University of Missouri (including high school students) but working for the University of Missouri are not eligible for FICA exemption.

  2. What constitutes half-time status?

    Undergraduate Students: Department of Education mandates that half-time status for an undergraduate student meet or exceed minimum requirements. At the University of Missouri, six (6) hours per standard semester equates to half-time status. The Registrar maintains the certified enrollment indicators for each currently enrolled student. The Department of Education does not address the summer semester. The Registrar has determined that 3 hours equates to half-time status during the summer. If the break between sessions is more than 5 weeks (35 calendar days), the student loses eligibility for FICA exemption if the student does not meet the enrollment criteria.

    Graduate and Professional Students: Regular, full-time status is established by Department of Education regulations. The law allows each school to determine what constitutes half-time status for graduate and professional students. The Registrar maintains the certified enrollment indicator for each currently enrolled student.

  3. Is there any situation where a student who is enrolled less than half-time can continue to be exempt from FICA withholding?
    Yes. If the student is enrolled for their last semester and taking the hours needed to complete their degree, the student is still eligible for FICA exemption.

  4. Must an employee be in a student employee title to qualify for the FICA exemption?
    No. FICA exemption does not depend on the student working in a student employee title.
  5. Does a student, who is otherwise FICA exempt, lose the exemption during winter or summer breaks?
    It depends. If the break is 5 weeks (35 calendar days) or less, the student remains in FICA exempt status. If the break is greater than 5 weeks (35 calendar days), the FICA exemption is lost during the break if the student fails to meet the enrollment criteria. The length of the break is counted from the campus’ published date for semester closing.
  6. Does a student lose the exemption if they work 40 hours or more a week over breaks of less than 35 days?
    No. Hours worked during academic breaks of less than 35 days are not considered when determining whether the employee is regularly working 40 or more hours per week.
  7. If students earn over a specific dollar amount, do they lose the FICA exemption?
    No. The FICA exemption is not dependent on amount of earnings. There is no limitation on the amount of earnings.
  8. Is a student considered to be regularly attending classes if they are taking independent study or correspondence courses?
    A student may satisfy the requirement of “regularly attending classes” if any of their coursework is independent study or correspondence.
  9. How often is the University required to assess whether a student continues to be enrolled at least half-time?
    The criteria will be checked no less than once each semester as of the end of that semester’s drop/add period.
  10. If the student is no longer enrolled at least half-time as of the end of the drop/add period, should FICA be retroactively charged?
    No. The regulations permit the University to determine “student status” as of the end of the drop/add period. If, at that time, the student is no longer eligible for exemption, FICA should be withheld from the first pay period begin date after the edit report is run.
  11. Should students be informed before a change in FICA eligibility is processed?
    There is no regulatory requirement to do so, but communication is always desirable. Each campus HR/Payroll office will monitor eligibility and may communicate to students about their status change.
  12. Under what circumstances is a student entitled to a FICA refund?
    If FICA was erroneously withheld due to an administrative error on the part of the University (e.g., a department did not process FICA exemption even though the student met the criteria), the student is eligible for a refund. The University will file a claim for the refund on behalf of the student, provided the student returns a signed FICA Refund Request form. There is a 3-year period to file for a FICA refund.
  13. Can a student opt to have FICA withheld even though the student meets the criteria for exemption?
    No. An individual cannot voluntarily opt to have FICA withheld.


Date Created: 01/01/2001
Updated: 04/01/2011; 07/01/2020; 04/20/2023

Reviewed 2023-04-21