SOCIAL SECURITY

Office of the Chief Actuary

September 9, 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 August 31, 2020 letter (enclosed) regarding: 

1) The actuarial opinion included in the 2014 and 2015 Annual Reports of the Board of

Trustees of the Federal Old-Age and Survivors and Federal Disability Insurance Trust

Funds, and

2) My response on August 24, 2020 to a letter from Senators Van Hollen, Sanders, Wyden,

and Schumer.

I appreciate your concerns and thank you for asking me to address them. 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. 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. 

Annual Reports of the Board of Trustees 

The annual report of the Board of Trustees has been produced each year starting in 1941, as 

required by law. My office develops the actuarial models and recommends the assumptions that 

are used to produce the projections of the future actuarial status of the trust funds. Starting in 

1994, the Chief Actuary has been required by law to provide an opinion in the report attesting to 

the reasonableness of the assumptions and methods used. In this time, neither I, nor my 

predecessors, have taken exception to any of the assumptions used for the basic projections and 

determination of the actuarial status of the trust funds under the assumptions that are central to 
Page 2 – The Honorable Chuck Grassley and The Honorable Kevin Brady

this determination. As a result, we have always received a clean opinion on the annual full-scope 

audit of these projections. This audit is completed by our Inspector General, the Government 

Accountability Office, and an independent accounting firm engaged by the Inspector General, 

and is required due to the inclusion of the basic projections in the Social Security 

Administration’s Annual Financial Report.

The issues you refer to in the actuarial opinion for the 2014 Trustees Report 

(https://www.ssa.gov/OACT/TR/2014/tr2014.pdf) did not relate to the basic projections of trust 

fund solvency or the actuarial status of the trust funds. Rather, the comments alerted readers of 

the report that: (1) the range of variation in the stochastic projections was unreasonably small

due to limitations in our stochastic methods, which the Trustees indicated in Appendix E of the 

report stating that “the true range of uncertainty is larger than indicated”; (2) reference to the

implications of trust fund operations on the overall federal budget is not relevant to the actuarial 

status of the trust funds; and (3) the benefit replacement rates that had been included in the 

reports for many years were being removed, but would thereafter be found on the Office of the 

Chief Actuary’s website. The actuarial opinions for the 2015 through 2020 reports have 

continued to include a comment about federal budget implications.

You indicate that my 2014 and 2015 actuarial opinions were subsequently used to promote 

allegations that a single Trustee had undue influence over the Trustees’ process and assumption 

selection. These actuarial opinions did not refer to the Trustees’ process or selection of 

assumptions; they simply disclosed information that was important for readers of the report to 

understand, as is required by actuarial standards of practice. As you mention, I noted in 

testimony in 2016 before the House Ways and Means Subcommittee on Social Security that I 

had never seen one Trustee capable of overwhelming the other five Trustees. In fact, decisions 

by the Trustees are made by consensus, as is indicated by the fact that dissenting opinions, which 

are allowed per the bylaws of the Board of Trustees, have never been included in the report by 

any Trustee. You mention that I did not comment on this point publicly until the hearing in 2016. 

That is only because I was not asked publicly until that time. Had I been asked in a 

Congressional letter or hearing at any earlier point, I assure you I would have provided the same 

answer. 

Response to a Letter from Senators Van Hollen, Sanders, Wyden, and Schumer

Your second concern, regarding answers to questions from Senators Van Hollen, Sanders, 

Wyden, and Schumer in my letter to them on August 24, 2020

(https://www.ssa.gov/oact/solvency/VanHollenSandersWydenSchumer_20200824.pdf), also 

speaks to the basis for public statements made by the Chief Actuary and the Office of the Chief 

Actuary. Our policy has always been to answer questions from members of Congress objectively 

and directly. When the member makes public reference to information that we have provided, we 

post the full letter that we have provided on our website, so that the information is available with

full context and detail, to minimize the possibility of misinterpretation. Per your request, we will 

post this response at the same location as the letter to Senators Van Hollen, Sanders, Wyden, and 

Schumer. I understand that even an entirely objective and factual statement may be interpreted 

and referenced differently, incompletely, or out of context by different parties. My hope and 
Page 3 – The Honorable Chuck Grassley and The Honorable Kevin Brady

intent for any communication is that the answer provided, taken in totality, has provided a 

complete and factual response to the question posed. 

The question the Senators posed related to “hypothetical legislation.” I indicated clearly in 

response that we were not aware that anyone had proposed the changes specified, and that is still 

the case today. I also indicated that our office’s long-standing practice has been to ask the entity 

that has made a proposal if they would like us to prepare an estimate for them directly, rather 

than for the requester. As we were unable to find any party who had proposed the hypothetical 

legislation, I simply provided answers to the specific questions asked by the Senators. While the 

Senators asked only for the implications of setting the payroll tax rates to zero starting on 

January 1, 2021, I did include in our response the fact that the status of the trust funds and ability 

to pay benefits would not be affected if general revenue transfers were specified in amounts 

equal to the reduction in payroll tax.

The response clearly indicated that DI Trust Fund reserves would become depleted in mid-2021 

and OASI Trust Fund reserves would become depleted in mid-2023 only for the hypothetical 

legislation that the Senators posed, and only if there were no alternative revenue source to 

replace the eliminated payroll tax revenue. The letter also clearly stated that we were not aware 

that anyone had proposed such hypothetical legislation. While the appropriateness of asking this 

question may be debatable, we were directly asked, and I can only hope that the clarity of the 

specification of this hypothetical legislation has assisted others in stating clearly that they have 

not proposed this change.

Further Information

It is worth noting that the Office of the Chief Actuary has on other occasions provided requested 

informational analysis and estimates for hypothetical changes that have not been formally 

proposed. One example is an analysis we provided to Senator Tom Cotton on June 1, 2017 

(https://www.ssa.gov/oact/solvency/TCotton_20170601a.pdf), on a proposal he was evaluating 

but that was never introduced. This proposal would have reduced the employee payroll tax rate 

with no provision for revenue to make up the shortfall. On the same date, we provided Senator 

Cotton with estimates for the implications of increasing the rate at which Social Security 

disabled worker beneficiaries have their benefits terminated on the basis of returning to work. 

Senator Cotton felt that an increased disability termination rate might be achieved by 

implementing unspecified proposals he was considering

(https://www.ssa.gov/oact/solvency/TCotton_20170601.pdf). These are examples of 

informational analyses of hypothetical changes we have provided to members of Congress when 

asked. 

As indicated above, when we are asked for analysis of a proposal that has been made by an entity 

other than the entity that made the proposal, we always ask the proposing entity if we may 

provide the answers requested to them. If the proposing entity does not ask that we provide the 

answers to them, and a member of Congress desires that information, then we provide our

objective analysis to the requesting member. One such example is the request made by Senator 

Ron Johnson for estimates of the effects of the President’s Executive Actions for immigration 

announced on November 20, 2014, for which we provided an answer on February 2, 2015 
Page 4 – The Honorable Chuck Grassley and The Honorable Kevin Brady

(https://www.ssa.gov/oact/solvency/BObama_20150202.pdf). Similarly, on February 10, 2016, 

we provided Chairman Sam Johnson with estimates of the effects of a proposal in the President’s 

Budget that would have applied a fee on petroleum products purchased in the United States

(https://www.ssa.gov/oact/solvency/FY2017Budget_20160210a.pdf).

While it is never desirable for the Office of the Chief Actuary to engage in matters with political 

implications, it appears that this is unavoidable to a degree, as long as we are asked to provide 

objective and factual answers to questions posed by members of Congress. Our answers have 

always been as direct and objective as possible, and we regret that even clear answers may be 

taken out of context or used for purposes other than intended. I can only hope that by 

communicating as you have done in this letter, we will be able to continue to provide objective 

and factual information to you and all members of Congress. 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
August 31, 2020

Stephen Goss

Chief Actuary

Social Security Administration

6401 Security Blvd.

Baltimore, MD 21235

Dear Mr. Goss:

We write to express our concern regarding the use of your office for political purposes. The 

American public expects and deserves a fair assessment of the Social Security program’s 

financial status and effects of proposed legislation, however actions over the past several years 

raise concerns about the true independence of the Office of the Chief Actuary. Use of the Office 

of the Chief Actuary to score political points is unacceptable and cannot continue.

On June 7, 2016, Senators Warren, Schumer, and Whitehouse published an essay in HuffPost 

alleging that intellectual and political biases of a Public Trustee led to an overstatement of 

financial challenges facing Social Security’s trust funds.1 They wrote that “...the 2014 trustees 

report curiously incorporated a number of assumptions playing up the potential future insolvency 

of the program — a key talking point in the right-wing war on Social Security. These 

assumptions were so troubling that the independent Chief Actuary for Social Security took the 

unprecedented step of writing a public statement of actuarial opinion disagreeing with the report. 

After similarly questionable elements appeared in the 2015 report, the Chief Actuary repeated 

this extraordinary public rebuke.” 

Those allegations gained national attention, including discussions in at least one hearing in 

Congress, and threatened public confidence in the integrity of the Social Security Trustees’

reports. The allegations were also, as you know, patently false.2 They were used for purely 

political purposes to feed a smear campaign against a nominee for the position of Public Trustee 

1 See, “The Koch Brothers Are Trying to Handpick Government Officials. We Have To Stop Them.,” HuffPost, June 

7, 2016 (available at https://www.huffpost.com/entry/koch-brothers-charles-blahous_b_10325224). 2 https://www.finance.senate.gov/imo/media/doc/2019-06-

21%20CEG%20to%20SSAB%20Technical%20Panel%20(Assessment%20of%20Democrat%20Allegations%20reg

arding%20Trustees%20Report).pdf
for the Social Security and Medicare trust funds, painting him as a “Koch-Funded” individual 

who would undermine retirement security of Americans.3

Because your position was being used to perpetuate falsehoods in the run-up to a Presidential 

election, we would have expected you to have promptly cleared the record. You did not. ThenChairman Hatch of the Senate Finance Committee repeatedly laid bare the lies contained in the 

politically-motivated smear campaign, on the Senate floor,

4 and in the Senate Finance 

Committee.

5 He also identified that the allegations put forward by the Senators had “injected 

needless politics into Social Security trustee reports, and have threatened the integrity of those 

very reports.” Nonetheless, you remained silent.

It was not until you were forced by questioning from then-Chairman Sam Johnson at a House 

Ways and Means Social Security Subcommittee hearing that you weakly disavowed the lies 

fueling political smear campaigns.6 Of course, by that time, skewed political ads were being 

used to mislead voters, and threats to “the perceived nonpartisanship and objectivity of key 

government reports” were noticed even by the liberal Washington Post.

7

We now approach another Presidential election, and your office has once again been asked to 

contribute to a politically motivated effort to mislead voters. On August 19 of this year, Senators 

Van Hollen, Sanders, Wyden, and Schumer wrote to you asking for an analysis of “hypothetical 

legislation” to eliminate FICA and SECA taxes used to fund Social Security programs.8 The 

intention behind the Senators’ inquiry was clear: argue that the President would “terminate” 

payroll taxes that fund Social Security, leaving the trust funds without that important source of 

revenue, and then argue that the President and others want to destroy Social Security.9 

Your response to the Senators’ letter was disappointing, to say the least. The “hypothetical” 

legislation that the authors of the letter identify they would not support has not been proposed by 

anyone and has never, to our knowledge, been proposed or referred to the Senate Finance 

Committee or Committee on Ways and Means, at least in modern history. Nonetheless, your 

analysis of the hypothetical that no one supports appears on your office’s website under “Office 

3 https://www.dscc.org/news/gop-senators-vote-koch-funded-architect-social-security-privatization/ 4 See, for example, https://www.finance.senate.gov/chairmans-news/hatch-calls-out-senate-democratsmanufactured-controversy-on-obama-trustee-nominee. 5 See, for example, https://www.finance.senate.gov/chairmans-news/hatch-statement-at-finance-committeeexecutive-session-on-social-security-and-me-dicare-trustees-nominations. 6 In testimony before Congress, in response to a question from then-Chairman Sam Johnson about whether a single 

Public Trustee “somehow managed to take over the process and changed assumptions in the report to overstate 

Social Security’s troubles” Social Security’s Chief Actuary stated that “I’ve never seen anybody capable of 

overwhelming the five others.” See the recording of the House Ways and Means Subcommittee on Social Security’s 

June 22, 2016 hearing. 7 https://www.washingtonpost.com/opinions/the-showdown-democrats-dont-need-to-have/2016/06/14/0b753d96-

319c-11e6-8ff7-7b6c1998b7a0_story.html 8 https://www.vanhollen.senate.gov/download/van-hollen-letter-to-ssa-actuary-on-payroll-tax 9 https://twitter.com/ChrisVanHollen/status/1296547485272494081
of the Chief Actuary’s Estimates of Proposals to Change Social Security,” 10 and news reports 

have characterized your analysis as a warning of a possible end to Social Security benefits.11 

In your response to the Senators’ letter, you did identify that, aside from the Democrat Senators 

who authored the letter, no one has proposed the legislation to zero-out FICA and SECA taxes 

for which they requested analysis. You also correctly identified that past payroll tax holidays 

enacted by President Obama provided General Fund transfers from Treasury to Social Security’s 

trust funds (breaking the link between worker contributions and their attendant benefits, a 

supposed bedrock foundation of Social Security) to offset effects on trust funds. 

Unfortunately, you did not stop there. While you could have pointed out that effects on trust 

funds of the legislation that the four Democrat Senators were putting forward are readily 

discernible from the most recent trustees report, you did not. Rather, you proceeded to put your 

office’s imprimatur on the hypothetical legislation to display the obvious: absent sources of 

revenue from FICA and SECA payroll taxes, Social Security trust funds would deplete rapidly 

and benefits could not be paid. That, as you know, provided fuel for the ensuing misleading 

political messaging that was the most likely desired outcome of the Senators’ inquiry on their 

“hypothetical.” 12 

In the same spirit of inquiring about a legislative hypothetical that an inquirer does not support, it 

would seem entirely consistent to inquire about “hypotheticals” that Democrats may not have 

proposed, but could be linked to them through innuendo. It would be consistent for someone to 

ask you about “hypothetical” legislation to significantly cut Social Security benefits, arguing that 

while the legislation is not something that they would support, it would be of interest to obtain 

analysis. 

Senator Sanders has identified that former Vice President Biden has a long history of advocating 

cuts in safety net programs, and that Mr. Biden was “talking about the necessity—with pride--

about cutting Social Security, cutting Medicare, cutting veterans programs.”13 It would be 

straightforward for someone to write to you, the Chief Actuary, identifying that “while we would 

not be supportive of this hypothetical legislation,” please analyze “hypothetical” legislation 

involving Social Security benefit cuts of the types that Senator Sanders has alleged Vice 

President Biden has a long history of supporting. The next step, upon receiving your analysis, 

would be to argue that Mr. Biden, with a long history, according to Senator Sanders, of talking 

about cuts to safety net programs, would push to enact such legislation. That, as with the letter 

you received recently from Senators Van Hollen, Sanders, Wyden, and Schumer, would be a 

politically-motivated use of your office. We believe that you are aware of that, and would prefer 

not to have your office used for political reasons, as you understand the important role of 

independent scorekeeping. 

10 https://www.ssa.gov/oact/solvency/index.html 11 See, for example, https://www.nbcnews.com/politics/politics-news/terminating-payroll-tax-could-end-socialsecurity-benefits-2023-chief-n1238021. 12 https://twitter.com/ChrisVanHollen/status/1298046095742963713; 

https://twitter.com/SSWorks/status/1298625721938714624

13 https://www.youtube.com/watch?v=9X3UiSvgle0
Unfortunately, you continue to remain silent, in the face of numerous partisan and distorted 

claims that the President intends to entirely remove, for all time, revenue streams necessary to 

fund Social Security. To preserve the integrity and public trust of your office, please clarify that 

the political claims, facilitated by your response to the Senators’ letter, of some “plan” to 

“destroy Social Security”14 or permanently deplete trust funds15 are false and misleading. Please, 

also, reaffirm that the “hypothetical legislation” that no one supports does not correspond to any 

proposal by the Administration, Member of the House of Representatives, or Senator, including 

those who requested the analysis. We ask that you do so via a written response to this letter and 

that you make your response publicly available in the same location of the website cataloging 

proposals scored by your office. 

Social Security is an important program on which millions of Americans rely, and it is facing 

serious financial challenges to its long term viability. As the Chief Actuary, you have an 

important role helping Congress and the American people understand the implications of 

proposed changes to the program. We take seriously the responsibility to ensure Social Security 

remains strong for generations to come and know the American people expect and deserve real

conversations about how to do just that. It is unfortunate that some seek to use your office for 

election-year partisan scare tactics and we expect that in the future, you will not honor requests 

that serve no purpose beyond political posturing and are not grounded in serious inquiry. We 

look forward to your prompt reply. 

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

14 https://socialsecurityworks.org/2020/08/24/if-donald-trump-is-reelected-he-will-destroy-social-security/; 15 https://twitter.com/ChrisVanHollen/status/1298046095742963713