Retirement Savings: Federal Workers’ Portfolios Should Be Evaluated For Possible Financial Risks Related to Climate Change

What GAO Found

Retirement plans’ investments, including those of the Thrift Savings Plan (TSP) for federal employees, could be exposed to financial risks from climate change, according to GAO’s literature review and interviews with stakeholders knowledgeable about climate change and financial markets. Stakeholders said climate-related events, from natural disasters to changes in government policy, are expected to impact much of the economy and thereby investment returns (see figure). Retirement plans can assess their exposure to these risks by analyzing the potential financial performance of holdings in their portfolios under projected climate change scenarios.

How Climate Change Could Impact Retirement Plan Investments

GAO reviewed retirement plans in the United Kingdom, Japan, and Sweden that had taken steps to incorporate climate change risks into their plan management. Officials from these plans described using engagement—such as outreach to corporate boards—to encourage companies in which they invest to address their financial risks from climate change. Officials had taken other steps as well, such as incorporating climate change as a financial risk into their policies and practices. Officials communicate information on climate-related investment risks through public disclosures and reports.

The agency that oversees TSP, the Federal Retirement Thrift Investment Board (FRTIB), has not taken steps to assess the risks to TSP’s investments from climate change as part of its process for evaluating investment options. Officials told us that they use a passive investment strategy and do not focus on risks to a specific industry or company. FRTIB is required by statute to invest TSP’s funds passively, however, it has previously identified and addressed investment risks. For example, in the 1990s, FRTIB reviewed its investment policies and recommended adding an international equities fund and a small- and medium-capitalization stock fund, both passively managed, to incorporate classes of assets that it determined were missing from TSP’s investment mix. Stakeholders in the financial sector, including an advisory panel to a federal financial regulator, have stated that it is important to consider the investment risks from climate change. Evaluating such risks is also consistent with GAO’s Disaster Resilience Framework. Taking action to understand the financial risks that climate change poses to the TSP would enhance FRTIB’s risk management and help it protect the retirement savings of federal workers.

Why GAO Did This Study

Climate change is expected to have widespread economic impacts and pose risks to investments held by retirement plans, including the federal government’s TSP. As of November 2020, TSP had 6 million active and retired federal employee participants and nearly $700 billion in assets. GAO was asked to examine how the agency that oversees TSP has addressed its exposure to such risks.

This report examines (1) what is known about retirement plans’ exposure to climate change-related investment risks, (2) what comparable retirement plans in other countries have done to address risks from climate change and how they communicate this information to the public, and (3) what steps FRTIB has taken to address investment risks from climate change.

GAO reviewed relevant literature and interviewed representatives from investment consulting firms and other stakeholders knowledgeable about climate change and its possible financial impacts. GAO reviewed documents and interviewed officials from selected retirement plans for public- and private-sector employees in the United Kingdom, Japan, and Sweden identified as examples of plans that are addressing climate risks. GAO also reviewed TSP documents, and interviewed FRTIB officials.

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GAO's analysis of SSA disability administrative data and death data found that of the approximately 9 million disability applicants who filed an appeal from fiscal year 2008 through 2019, 109,725 died prior to receiving a final decision on their appeal. This represents about 1.2 percent of the total number of disability applicants who filed an appeal during those years. The annual death rate of applicants awaiting a final disability decision has increased in recent years. From fiscal years 2011 through 2018, the annual death rate for applicants pursuing appeals increased from 0.52 percent to 0.72 percent. Applicants who filed their initial disability claim during years of peak wait times and appealed their initial decision died at a higher rate while awaiting a final decision than applicants who filed their initial claim in years with shorter wait times. Disability applicants awaiting a final decision about their appeal who were male died at higher rates than applicants who were female and those who were older died at higher rates than those who were younger. Death rates were largely similar across reported education levels. Deaths among individuals who were awaiting decisions about disability appeals may have been unrelated to the applicant's claimed disability. The Social Security Administration (SSA) manages two large disability benefit programs–Disability Insurance (DI) and Supplemental Security Income (SSI). As of December 2019, these programs provided benefits to approximately 12.3 million adults living with disabilities and their eligible dependents. A disability applicant who is dissatisfied with SSA's initial disability determination can appeal the decision to multiple escalating levels of review. From fiscal years 2008 through 2019, SSA received approximately 9 million appeals of initial DI or SSI decisions. GAO has previously reported that applicants who appeal a benefits denial can potentially wait years to receive a final decision, during which time an applicant's health or financial situation could deteriorate. Given the heightened risk of worsening medical and financial conditions for disability applicants, GAO was asked to examine the incidence of such events while applicants await a final decision on their disability claim. This report examines the status of disability applicants while they awaited a final benefits decision including 1) their total wait times across all levels of disability appeals within SSA, 2) their incidence of bankruptcy, and 3) their incidence of death. For wait times, bankruptcies, and deaths, GAO also examined variations across certain demographic characteristics of applicants. GAO obtained administrative data from SSA for all adult disability applicants from fiscal years 2008 through 2019 who filed an appeal to their initial disability determination. GAO used these data to calculate wait times across appeals levels, rates of approvals and denials, and appeals caseloads, and examined changes in these three areas over time. To describe the incidence of bankruptcy among individuals awaiting a disability appeals decision, GAO matched SSA disability data to AOUSC bankruptcy data for fiscal years 2014 through 2019. To describe the incidence of death among individuals awaiting a disability appeals decision, GAO matched the disability data to SSA's Death Master File. For all of these analyses, GAO also examined variations across demographic characteristics of applicants, including age, sex, and reported education level. GAO also reviewed relevant policies, federal laws and regulations, and agency publications, and interviewed agency officials. For more information, contact Elizabeth Curda at (202) 512-7215 or CurdaE@gao.gov.
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