If the wages of an employee of a state or local government are exempt from the Social Security portion of OASDI, 414(h)(2) contributions will indeed be exempt from Social Security, also (although, as you correctly note, they will be subject to Medicare taxes). However, there are two major limitations on the application of the exemption in section 3121(B)(7):[list=1]
[*]Section 3121(B)(7)(E) excludes from that exemption
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service included under an agreement entered into pursuant to section 218 of the Social Security Act
Most states (although not Pennsylvania) have entered into such agreements with respect to all of their employees. For a list of those which have not, see
Section 1014 of the Social Security Handbook. Even those states may have entered into Section 128 agreements with respect to some of their political subdivisions.
[*]Section 3121(B)(7)(F) further excludes from that exemption
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service in the employ of a State (other than the District of Columbia, Guam, or American Samoa), of any political subdivision thereof, or of any instrumentality of any one or more of the foregoing which is wholly owned thereby, by an individual who is not a member of a retirement system of such State, political subdivision, or instrumentality
Treas. Reg. § 31.3121(B)(7)-2 interprets this rule to impose a requirement that employees must be covered by a retirement system that meets various minimum requirements before they can be exempt from Social Security coverage.[/list=1]Thus, the only employees of state and local government to whom section 3121(B)(7) applies are those (a) whose employment is not covered by a Section 218 agreement, and (B) who are personally covered by a retirement system meeting minimum requirements. If the employee is either (a) subject to a Section 218 agreement, or (B) covered by a retirement plan that requires section 414(h)(2) contributions, but does not meet minimum requirements under the regulation, the 414(h)(2) contributions are subject to Social Security taxes to the extent they reduce the employee's salary.
For more information on OASDI coverage of state and local government employees, see
http://www.ssa.gov/slge/overview.htm.