"California laws governing retired annuitants prohibit employers from offering retired annuitants health or other benefits without incurring serious consequences. The result is a potential Catch 22 -- employers are prohibited from offering retired annuitant health benefits, but the ACA will penalize employers that fail to offer health benefits to full-time employees.... CalPERS has recommended that certain public employers develop policies prohibiting retired annuitants from working full-time to ensure that the employer will not be in jeopardy of federal penalties and will not inadvertently offer health benefits in violation of provisions in the California Government Code. In order for an employer to determine what kind of policy to adopt, the employer must know how it will identify full-time employees under the ACA."