SOCIAL SECURITY

Office of the Chief Actuary

October 23, 2020 

The Honorable Chuck Grassley 

Senate Finance Committee

United States Senate

Washington, DC 20510 

The Honorable Kevin Brady

Committee on Ways and Means

United States House of Representatives

Washington, DC 20515 

Dear Chairman Grassley and Ranking Member Brady: 

This letter is in response to your October 9, 2020 letter (enclosed) regarding practices of the Office 

of the Chief Actuary for information, analysis, and/or technical assistance requested by nongovernment individuals and organizations. 

Thank you for asking me to address your concerns. I have enjoyed working with both of you and 

your staffs from my position in the Office of the Chief Actuary at the Social Security 

Administration, where I have served as Chief Actuary since 2001, and prior to that as Deputy Chief 

Actuary. Our office’s mission has always been to provide objective information and analysis to 

assist lawmakers, the Social Security Board of Trustees, the Commissioner of Social Security, and 

the Administration in maintaining and evolving the Social Security and Supplemental Security 

Income programs to best serve the American people. 

We are intensely aware of the finite resources available to the Social Security Administration. The 

Office of the Chief Actuary is the smallest component in the agency reporting to the Commissioner, 

with less than fifty full-time-equivalent staff and no paid overtime allocation. In addition, our office 

does all of our work directly with no use of external contractors. We therefore carefully manage and 

prioritize our many demands. Our primary work has always been the development of the baseline 

projections of the future operations and actuarial status of the OASI and DI Trust Funds for the 

Annual Report of the Trustees, as required in the Social Security Act. 

In addition, we develop estimates for changes in regulations and law under consideration by the 

Administration and Congress. As you point out, we maintain a web page showing letters and 

memoranda where we have provided information on potential changes in the law that would affect 

taxpayers, beneficiaries, and the actuarial status of the trust funds 

(https://www.ssa.gov/OACT/solvency/). This web page, as well as the web page providing the 
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estimated effects of individual provisions included in proposals for which we have estimates

(https://www.ssa.gov/OACT/solvency/provisions/), have been used by members of Congress and 

others for years in their development of legislation addressing the financing and benefits specified 

in the law. We do prioritize the work done for these estimates. The Administration has always come 

first; Congress second (the House Ways and Means Committee and the Senate Finance Committee 

primarily, but in addition all committees and members of Congress); and finally, entities external to 

the federal government, as time permits, when they raise possibilities that are known to be of 

interest to the Administration or Congress. As pointed out below, possibilities raised by outside 

organizations have largely been followed with inclusion in a bill introduced by one or more member 

of Congress. I note that requests from external entities have been few, and we have received and 

responded to no external requests for over four years now. The most recent is the response on 

October 11, 2016 to Kent Conrad (former member of Congress) and James B. Lockhart, III (former 

Deputy Commissioner of the Social Security Administration), Co-Chairs of the Bipartisan Policy 

Center’s Commission on Retirement Security and Personal Savings. 

Critical to the value of the work we do in the Office of the Chief Actuary is that we are apolitical 

and only make estimates for proposals developed by others. We do not ever indicate a preference 

for any proposal, but rather assess what the implications of implementing the proposal would be on

an objective basis. By taking this approach, we hope to provide a basis for understanding and 

considering the effects of proposals on Social Security that will be useful for all.

Below, please see answers to the seven specific questions you have raised. 

1. When a request is received from a non-government source, how does your office determine if the 

requested information, analysis, and/or technical assistance will be provided?

Answer: Requests come to our office in many forms. For requests related to operational statistics 

and policy considerations, we refer to or consult with the Office of the Commissioner or other 

agency components on what might be provided other than publicly available material. Most 

requests for assistance from non-government sources related to potential changes in the law are 

already addressed by estimates we have provided on our proposals and provisions web pages. When 

we receive an occasional request from an outside (non-governmental) organization for estimates on 

a proposal that has not been previously evaluated, we recommend working with a member of 

Congress to gain higher priority. Beyond that, we consider the involvement of the requester, current 

and past, in Congress and Administration, and in groups that have influence with Congress and 

Administration through their work. Of the more than 150 letters and memoranda included on our 

proposals web page going pack to 1993, 17 were provided to non-governmental individuals or 

organizations. Specifically:

a) Letters to Kent Conrad and James B. Lockhart III, Co-Chairs of the Bipartisan Policy 

Center’s 2016 Commission on Retirement Security and Personal Savings, on October 

11, 2016 and June 19, 2016.

b) Letter to Jim McCrery and Earl Pomeroy (both former members of Congress) Co-Chairs 

of the SSDI Solutions Initiative organized by the Committee for a Responsible Budget, 

on April 4, 2016.
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c) Letter to Pete Domenici (former member of Congress) and Alice Rivlin (former Director 

of CBO), Co-Chairs of the Bipartisan Policy Center’s 2010 Debt Reduction Task Force,

on February 2, 2011, and memorandum to their staff on November 17, 2010. 

d) Memorandum to Kenneth Apfel (former Commissioner of Social Security), Chair, John 

L. Palmer (former Public Trustee of the Social Security and Medicare Boards of 

Trustees), Co-Chair, and Rudolph G. Penner, Co-Chair, for their committee report of the 

National Research Council and the National Academy of Public Administration on 

“Choosing the Nation’s Fiscal Future”.

e) Memorandum to Virginia Reno, Vice President for Income Security at the National 

Academy of Social Insurance (former staff at Social Security Administration and 

subsequent Deputy Commissioner for Retirement and Disability Policy at the Social 

Security Administration) on October 30, 2009.

f) Memorandum to Mark Warshawsky (former Assistant Secretary for Economic Policy at 

Treasury and subsequent Deputy Commissioner for Retirement and Disability Policy at 

Social Security Administration), on September 17, 2008.

g) Memorandum to John Gist and Sara Rix, staff for the AARP Public Policy Institute, on 

June 19, 2008.

h) Memorandum to Jeffrey Liebman (former staff at the White House National Economic 

Council), Maya MacGuineas, and Andrew Samwick, on November 17, 2005.

i) Memoranda to Robert M. Ball (former Commissioner of Social Security 

Administration), on April 14, 2005 and October 10, 2003.

j) Memoranda to Bob Pozen (former member of the President’s Commission to Strengthen 

Social Security), on February 10, 2005 and November 4, 2002.

k) Memoranda to Peter Ferrara on December 1, 2003 and April 6, 2004.

l) Memorandum to Peter Diamond (member of numerous Advisory Council and Advisory 

Board Technical Panels and Congressional Commissions) and Peter Orszag (former staff 

of the White House National Economic Council and subsequent CBO Director), on 

October 8, 2003.

m) Letter to Paul Simon (former Senator), along with former Senators Simpson, Pryor, and 

Danforth, on June 9, 1997

Regarding the subsequent use of the specific proposals analyzed for non-governmental entities, 

many were later incorporated as provisions in bills introduced by members of Congress. Our 

provisions web page provides a listing of provisions for which we have provided estimates,

including a cross-reference of letters and memoranda where the precise provision appeared. The 

following is a partial list of such provisions that were included in bills after development by a nongovernmental entity:

• Provisions A3, A8, and B3.12 developed by the Bipartisan Policy Center 

• Provision A4 developed by the NRC and NAPA

• Provisions B5.2, B6.1, D1, and E1.4 by the National Academy of Social Insurance
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2. When a request is received from a non-government source, does the Commissioner (or Acting 

Commissioner) of the Social Security Administration approve whether or not to provide the 

requested information, analysis, and/or technical assistance?

Answer: We inform the Commissioner or acting Commissioner when we receive a request from a 

non-governmental entity that would require any new development of estimates that are not already 

publicly available. In addition, when we receive a request from a member of Congress (or staff) to 

explore an option confidentially, we honor that and only disclose the request and our estimates if the 

member decides to make anything we have provided public. 

3. Does an Executive (e.g., the Office of Management and Budget) or Legislative (e.g. office of a 

Representative or a Senator) branch government entity have to make the request on behalf of a nongovernment individual or organization for the information, analysis, and/or technical assistance to 

be conducted? If so, is the requesting government office listed in the published memo?

Answer: We do not require that requests related to proposals developed by non-governmental 

entitles be made specifically by OMB or a member of Congress. As is apparent in the list provided 

in response to the first question, virtually all non-governmental entities who have made requests 

have previously been members of Congress or other government officials. In some cases, requests 

have been made by a non-governmental entity that has been working with a member of Congress 

who has asked not to be identified. 

4. Did any of the non-government individuals or organizations who received information, analysis, 

and/or technical assistance published on your website pay a fee to cover the cost of taxpayer 

resources used to produce the analysis?

Answer: No. 

5. Does your office provide information (including responding to oral or written questions) or 

analysis to non-government individuals or organizations that is not published on the agency’s 

website?

Answer: We are frequently asked informal questions that are handled simply by referring the 

requestor to publicly available information. New information that we develop and provide to nongovernment entities is disclosed. 

6. Has your office received any requests for information or analysis from non-government 

individuals or organizations since January 1, 2010 that have not resulted in a memo published on 

your office’s website?

Answer: We have not developed or provided new information (information not already available 

to the public) that has not been disclosed since January 1, 2010.

7. Please detail, and provide documentary evidence of, the technical assistance provided by the 

Office of the Chief Actuary of the SSA for production of the book “Social Security Works!,” by 

Nancy J. Altman and Eric R. Kingston (2014, The New Press, New York and London).
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Answer: We did not develop or provide any new information or estimates to the authors of this 

book. We pointed them to our web pages with existing provisions and our estimates, which are 

updated annually. My understanding is that the authors made their own calculations for the total 

effects of any combination of provisions, including interactions.

We are occasionally asked for publicly available information related to data and assumptions used 

for baseline projections, as for the Trustees Report, from non-government entities who are doing 

their own analysis. Examples include:

a) We provided demographic files from the 2006 Trustees Report to Jagadeesh Gokhale for 

his book “Social Security: A Fresh Look at Policy Alternatives” published in 2010, with 

acknowledgement.

b) We provided information to Sylvester J. Schieber and John B. Shoven for their book 

“The Real Deal: The History and Future of Social Security” published in 1999, with 

acknowledgement.

c) We provided assistance to Peter G. Peterson and Neil Howe for their book “On 

Borrowed Time: How the Growth in Entitlement Spending Threatens America’s 

Future”, published in 1988, with acknowledgment.

We also receive frequent requests from within the Social Security Administration for requests 

received from the Press and other entities. 

We look forward to continuing work with you and your staff, providing objective and factual 

information to you and all members of Congress, the Administration, and others, that will assist you 

in finding the best approaches for improving all aspects of the Social Security program. We take 

seriously our obligation to help assure that your decisions on behalf of the American people will 

always be well informed.

Sincerely,

Stephen C. Goss, ASA, MAAA

Chief Actuary

Enclosure

cc: 

The Honorable Andrew Saul, Commissioner of Social Security and Trustee of the Old Age and 

Survivors Insurance and Disability Insurance Trust Funds 

The Honorable Steven Mnuchin, Secretary of the Treasury and Managing Trustee of the Old Age 

and Survivors Insurance and Disability Insurance Trust Funds
October 9, 2020

Stephen Goss

Chief Actuary

Social Security Administration

6401 Security Blvd.

Baltimore, MD 21235

Dear Mr. Goss:

We write to better understand your office’s practices involving non-government requests for

information or analysis. The Office of the Chief Actuary, as part of the Social Security 

Administration (SSA), is funded by hard-earned taxpayer dollars as part of the agency’s annual 

appropriation. Some advocates and stakeholders regularly raise concerns about the amount of 

appropriations the SSA has received and argue to increase the agency’s budget to improve 

service delivery.1 Given the finite resources available and the important services the SSA 

provides to Americans, it is essential that the agency’s budget is used wisely. For that reason, we 

are seeking additional information regarding practices of the Office of the Chief Actuary for 

information, analysis, and/or technical assistance requested by non-government individuals and 

organizations. 

Since 2001, the Office of the Chief Actuary has analyzed proposals from non-government2

individuals and organizations on at least 14 occasions.

3

 In order to better understand your 

office’s practices responding to non-government requests, please provide the following 

information:

1. When a request is received from a non-government source, how does your office 

determine if the requested information, analysis, and/or technical assistance will be 

provided?

1 See, for example, https://www.cbpp.org/blog/ssa-needs-more-funding-to-support-essential-services 2 For the purposes of this letter, a non-government individual is any individual who is not elected, appointed and

Senate-confirmed (or otherwise appointed), or employed by the Executive or Legislative branch. In the case of an 

individual appointed to a part time role (such as the Social Security Advisory Board or Public Trustee), we 

differentiate between those requests that were asked as part of official capacity versus other professional or personal 

interest. In the case of a Commission established by Executive Order (such as the National Commission on Fiscal

Responsibility and Reform), we consider the Commission Members and staff as government requestors during the 

duration of the Commission. A non-government organization is any group that is not a part of the Executive or 

Legislative branch, such as a non-profit organization or a commission not created by the Executive or Legislative 

branch. 

3 See list of published proposals available at https://www.ssa.gov/oact/solvency/index.html
2. When a request is received from a non-government source, does the Commissioner (or 

Acting Commissioner) of the Social Security Administration approve whether or not to 

provide the requested information, analysis, and/or technical assistance? 

3. Does an Executive (e.g., the Office of Management and Budget) or Legislative (e.g., 

office of a Representative or a Senator) branch government entity have to make the 

request on behalf of a non-government individual or organization for the information, 

analysis, and/or technical assistance to be conducted? If so, is the requesting government 

office listed in the published memo? 

4. Did any of the non-government individuals or organizations who received information, 

analysis, and/or technical assistance published on your website pay a fee to cover the cost 

of taxpayer resources used to produce the analysis? 

5. Does your office provide information (including responding to oral or written questions)

or analysis to non-government individuals or organizations that is not published on the 

agency’s website?

6. Has your office received any requests for information or analysis from non-government 

individuals or organizations since January 1, 2010 that have not resulted in a memo 

published on your office’s website? 

7. Please detail, and provide documentary evidence of, the technical assistance provided by 

the Office of the Chief Actuary of the SSA for production of the book “Social Security 

Works!,” by Nancy J. Altman and Eric R. Kingston (2014, The New Press, New York 

and London).

We take seriously our oversight responsibility to ensure the SSA is a good steward of taxpayer 

dollars throughout the agency. We look forward to your prompt reply, and request that you 

respond by October 23, 2020. 

Sincerely, 

________________________ _________________________

Chuck Grassley Kevin Brady

Chairman Ranking Member

Senate Finance Committee Committee on Ways and Means

cc: The Honorable Andrew Saul, Commissioner of Social Security and Trustee of the Old 

Age, Survivors, and Disability Insurance Trust Funds

The Honorable Steven Mnuchin, Secretary of the Treasury and Managing Trustee of the 

Old Age, Survivors, and Disability Insurance Trust Funds