Bangs was tasked with evaluating the case after Sandusky appealed the loss of his pension. A final decision by the retirement system board is not expected until fall, an agency spokeswoman said.
Though released on the same day, Bangs' opinion is unrelated to the long-awaited report on the state's handling of the Sandusky investigation.
Sandusky, 70, retired as a Pennsylvania State University assistant football coach in 1999, but the agency concluded he was "an actual or de facto employee" through 2008, a span during which he sexually abused boys.
An attorney representing the agency said that Sandusky was an "ambassador" for Penn State in his post-coaching years, and that he received perks such as tickets to games and an on-campus office.
Sandusky's attorney, Charles Benjamin, argued that the state used an unprecedented interpretation of the law to deny Sandusky his pension, and that Sandusky's retirement benefits were vested before 2004, when the state amended a law to include some sexual-assault crimes among those that could lead to pension revocation.
Sandusky has been fighting since 2012 to have his pension restored. He is serving a 30-to-60-year prison sentence.