United States General Accounting Office GAO Briefing Report to Congressional Requesters February 1990 AGE DISCRIMINATION Use of Age-Specific Provisions in Company Exit Incentive Programs GAO/HRIWO-87BR GAO United States General Accounting Office Washington, D.C. 20548 Human Resources Division B-234436 February 27, 1990 Congressional Requesters:’ On December 11,1989, you requested information on the use of age- specific provisions in company exit incentive programs. These provi- sions either bar a certain group of older workers from program participation or exclude these workers from enhanced benefits available to younger eligible workers. Whether older workers can be either excluded from benefits under exit incentive programs or offered lower benefits than eligible younger workers has concerned many. Your request indicated that this information would be important to delibera- tions on proposed legislation to amend the Age Discrimination in Employment Act of 1967 (ADEA) in the wake of a 1989 Supreme Court ruling2 affecting exit incentive programs with age-specific provisions. Companies sometimes use short-term exit. incentive programs to reduce their work forces when downsizing their operations. Under these pro- grams, eligible workers are offered enhanced benefits, often through the company pension plan, as inducement for early departure. In this way, younger workers eligible for the program are given improved status in the company pension plan so that they may receive benefits comparable to those received by older workers who are already at or near the pen- sion plan’s normal retirement age.” Exit incentive programs can offer various kinds of enhanced benefits. These include (1) additional credits that improve early retirement bene- fits under the company pension plan; (2) some other specially designed incentives, such as a one-time severance allowance, not connected with the pension plan; (3) continued or improved health or life insurance cov- erage; or (4) a combination of these enhancements. ADEAforbids employers from arbitrarily discriminating against workers on the basis of age. However, under the act, company exit incentive pro- grams may have age-specific provisions that offer benefits that either decrease with age or cut off at a certain age provided that a program is ‘See appendix I for a list of the requesters. “Public Employees Retirement System of Ohio v. e, 109 S. Ct. 2854. “Older workers who are eligible for retirement under the company pension plan get an unreduced pension benefit. In addition, workers 62 and over are entitled to receive social security benefits, and workers 65 and over are entitled to Medicare benefits. Page 1 GAO/HRLWO-S7RR Age Discrimina tion in Company Ehit Incentive Programs 5234436 not a scheme to evade the general purpose of ADEA. For example, a pro- gram could offer eligible workers a retirement supplement until they reach age 62. To determine whether exit incentive programs with age-specific provi- sions conform to ADEA, employers were formerly required to satisfy a cost-justification test. Under this provision, a plan that provided lower benefits for older employees was prohibited unless the employer could show that this was due to greater costs or other economic considerations. Congressional concern about the use of age-specific provisions height- ened following the 1989 Supreme Court ruling. Under the ruling, an employer is not required to meet a cost-justification test when providing lesser benefits to older workers. Among other things, the proposed legis- lation seeks to prohibit age discrimination against older workers in all employee benefit plans except when age-based reductions are justified by significant cost considerations. As agreed with your offices, this briefing report provides information on the use of age-specific provisions for eligibility and enhanced benefits in exit incentive programs. We compiled information on the provisions of these programs from three data sources: (1) programs sponsored by For- tune 100 companies between 1979 and 1988; (2) data obtained from Charles D. Spencer and Associates,4 a private-sector publishing firm; and (3) the Bureau of Labor Statistics.” Our work focused on determin- ing the prevalence of programs that (1) excluded a particular group of older workers by applying an age cap or age bracket on program eligibil- ity and (2) offered certain enhanced benefits only to workers in a spe- cific age group because an age cap or bracket was applied. We interviewed selected officials from Fortune 100 companies who were familiar with their companies’ programs to gain perspective on employ- ers’ motivations for using or not using exit incentive programs with age- specific provisions. Although very few of the exit incentive programs we identified had age- Results in Brief specific provisions for eligibility, most used age-specific provisions for enhanced benefits. Specifically, we found that: “See Charles D. Spencer and Associates, “Early Retirement Incentives Offered by 24 Percent of Com- panies in 1986,” Spencer’s Research Reports on Employee Benefits (1987). “Department of Labor, Bureau of Labor Statistics, Employee Benefits Survey (1988) Page 2 GAO/HRD~7RR Age Disc rimination in Company Ihit Incentive Programs B-234436 l Only 5 percent (3 of 62) of Fortune 100 company exit incentive pro- grams used age-specific eligibility provisions (see fig. 1, p. 12). These programs used age brackets or set a cap on the age of workers to which the incentive offer was extended. Two programs set age brackets and one had an age cap. The age brackets used were 55 to 65 years and 55 to 62 years. Age 62 was the cap applied in the one program that used it. For each program, the bracket’s upper boundary or the applied cap was the normal retirement age under the company pension plan. None of Spencer’s exit incentive programs had age-specific provisions for eligibility.” l A majority of exit incentive programs offered workers age-specific enhanced benefits, according to results from the three surveys (see fig. 2, p. 14). In these programs, certain enhanced benefits were provided to younger eligible workers so that they could receive benefits comparable to those received by older workers already at or approaching normal retirement age. Officials of some companies that used age-specific exit incentives indi- cated that cost considerations played a role in their companies’ decisions (see p. 16). Some others commented that before deciding to target the program to younger workers, the company considered the number of older workers approaching the pension plan’s normal retirement age. They believed that the company could not have met its work-force- reduction goal by relying on attrition. Officials of companies not using age-specific provisions in exit incentive programs generally told us that they believed such provisions were unfair. Some also mentioned the desire to avoid an ADEX age- discrimination lawsuit as a significant factor. Several company officials emphasized that the purpose of exit incentive programs had been to reduce staff in general, not to retire older workers. We are sending copies of this report to other interested congressional committees, and we will make copies available to others who request them. If you have any questions concerning this report, please call me “The Bureau of Labor Statistics’ Employee Benefit Survey did not report information on program eligibility provisions in a manner that allowed us to determine the incidence of age-specific provisions. . Page 3 GAO/HRD90-87BR Age Discrimina tion in Company Exit Incentive Programs R-234436 on (202) 275-6193. Other major contributors to this report are listed in appendix II. Joseph F. Delfico Director, Income Security Issues Page 4 GAO/HR.D96+37BR Age Discrimination in Company Exit Incentive programs Page 6 GAO/HRD90#7FlR Age Discrimina tion in Company Exit Incentive Programs Contents Letter Age Discrimination: 8 Use of Age-Specific Background Age-Discrimination Issues in Exit Incentive Programs 8 9 Provisions in Objective, Scope, and Methodology 10 Company Exit Age-Specific Eligibility Provisions Rarely Used 12 Age-Specific Enhanced Benefits Used in Most Programs 13 Incentive Programs Additional Details on Age-Specific Exit Incentives 15 Comments of Company Representatives 16 Appendixes Appendix I: Congressional Requesters 18 Appendix II: Major Contributors to This Report 19 Figures Figure 1: Eligibility Provisions for Fortune 100 Exit 12 Incentive Programs Figure 2: Exit Incentive Programs With Age-Specific 14 Enhanced Benefits Figure 3: Use of Various Age-Specific Enhanced Benefits 15 Abbreviations ADEA Age Discrimination in Employment Act of 1967 BIAS Bureau of Labor Statistics EEOC Equal Employment Opportunity Commission Page 6 GAO/HRDM-J37BR Age Discrimination in Company Exit Incentive Programs Page 7 GAO/HRD9OMRR Age Discrimination in Company Exit Incentive Programs Age Discrimination: Use of Age-Specific Provisions in Company Exit Incentive Programs In recent years, mergers, competition from abroad, or a general decline Background in sales have caused many companies to cut back their work forces. To reduce employment, companies sometimes use exit incentive programs, which offer employees financial incentives for early departure. These programs are generally instituted for a fixed period of time (e.g., 2 months) during which each eligible employee can accept or decline the exit incentive offer. Companies view these programs as alternatives to layoffs, and consider them as one way to cut labor costs in the long run. Exit incentive programs are frequently offered through company pen- sion plans. To encourage departure, younger workers who are eligible for the program are given improved status in the company pension plan so that they may receive benefits comparable to those received by older workers already at or near the pension plan’s normal retirement age.’ In this way, employers enhance the provisions of the company pension plan so that younger eligible workers will get higher pension benefits than normally would be available to them. The following are examples of enhanced benefits. 1. Liberalized early retirement benefits-Monthly benefits are increased by diminishing or eliminating the actuarial factor that is normally used to reduce benefits of workers who have not yet reached the pension plan’s normal retirement age. 2. Retirement supplements-A fixed cash amount is added to monthly pension benefits and may be discontinued after workers become eligible for social security benefits at age 62. 3. Age and service credits-Workers receive additional credits to their age and years of service. This permits younger workers to meet the pen- sion provisions for eligibility and increases the amount of benefits they would have otherwise received. Exit incentive programs can provide workers accepting the offer with other forms of enhanced benefits. These include one-time severance allowances-which are usually based on years of service-and contin- ued or improved medical and life insurance coverage. ‘Older workers who are eligible for retirement under the company pension plan get an unreduced pension benefit. In addition, workers 62 and over are entitled to receive social security benefits, and workers 65 and over are entitled to Medicare benefits. . Page 8 GAO/HRD9O-87RR Age Discrimina tion in Company Rxit Incentive Programs Age Mscriminstion: Use of Ag&pecific Provisions in Company Exit Incentive Program8 Exit incentive programs have become widespread in recent years. We estimate that 80 percent of the Fortune 100 companies sponsored an exit incentive program at least once during 1979 through 1988.2 A study conducted by Hewitt Associates shows that about 55 percent of a sam- ple of large companies (25,000 or more employees) offered such pro- grams at least once between 1981 and 1985.3 The Hewitt study also reports that companies with 50,000 or more employees were most likely to use exit incentive programs. Protecting the rights of elderly Americans has been a policy goal of the Age-Discrimination Congress for many years. In 1967, the Congress passed the Age Discrim- Issues in Exit ination in Employment Act (ADF.A),which protects the employment Incentive Programs rights of workers age 40 and over. ADEAgenerally precludes an employer from discriminating against workers on the basis of age with respect to compensation, terms, conditions, or privileges of employment. AJXA does not forbid an employer from having an employee benefit plan that differentiates on the basis of age, so long as the plan is not a scheme to evade the general purpose of ADEA.Under the act, employee benefit plans may have benefits that either decrease with age or cut off at a certain age. Similarly, exit incentive programs may use certain so-called age-specific provisions. For example, a program with age-specific eligibility provi- sions could extend the exit incentive offer only to workers within a specified age bracket or below a certain age. A program with age- specific enhanced benefits could extend the exit incentive program to all workers but offer certain enhanced benefits only to workers in a speci- fied age group. The Congress permitted age-specific provisions in part to avoid making older workers more expensive to employers than younger workers because of age-related costs. The Equal Employment Opportunity Commission (EEOC), the agency charged with implementing ADEA,issued regulations pertaining to age- specific provisions in employee benefit plans. Under EEOCregulations, a plan which provided lower benefits for older employees was prohibited 3SeeHewitt Associates “Plan Design and Experience in Early Retirement Windows and in Other Voluntary Separation Ibns” (1986). Page 9 GA0/HRIb9047RR Age Discrimination in Company &it Incentive Programs Age Diadmhatiom use of Agespecific Provisions in Company Ed Incentive Progmms unless the employer could justify the difference by showing increased costs or other economic considerations. In 1989, the Supreme Court invalidated the EEOC cost-justification test and established a new test.4 Under the Supreme Court ruling, an employer is not required to meet a cost-justification test when providing lesser benefits to older workers. Instead, a worker must show that an employee benefit plan was intended to discriminate against the employee in hiring and firing, wages and salaries or, in the words of the Supreme Court, in some other “nonfringe-benefit aspects of the employ- ment relationship.” Concern about the use of age-specific provisions heightened following the Supreme Court decision. In response, some congressional members have proposed the Older Workers Benefit Protection Act (S. 1511 and H.R. 3200) to amend ADEA.If passed, the legislation will, among other things, prohibit age discrimination against older workers in all employee benefit plans except when age-based reductions are justified by signifi- cant cost considerations. On December 11,1989, the Chairman of the Senate Subcommittee on Objective, Scope,and Labor and others requested that GAO review the use of age-specific pro- Methodology visions in company exit incentive programs. We agreed to provide infor- mation on age-specific provisions for eligibility and enhanced benefits offered to workers under these programs. To respond to the congressional request, we compiled information on the provisions of exit incentive programs. We relied primarily on informa- tion for programs sponsored by Fortune 100 companies between 1979 and 1988, which we obtained for a previous GAO study. These companies were the largest 100 companies in Fortune magazine’s listing of the top 500 industrial corporations for 1987. The number of Fortune 100 exit incentive programs varies throughout this report because programs were omitted when information was not available.5 To observe the use of age-specific provisions across different data sources, we compared the information for Fortune 100 companies with 4F’ublic Employees Retirment System of Ohio v. e, 109 S. Ct. 2864 (1989). 5We reviewed eligibility provisions for 62 Fortune 100 exit incentive programs and enhanced benefit provisions for 42 programs. Page 10 GAO/HRD9O-87BR Age Disdmhation in Company Exit Incentive m AgeM ” tionz use of Ag&3pecific Provisions in Company Exit Incentive Pmgrams that gathered from (1) Charles D. Spencer and Associates, a private sector publishing firm, on 45 exit incentive programs offered in 1986fi and (2) our analysis of information collected by the Department of Labor’s Bureau of Labor Statistics (BEi) on 100 exit incentive programs sponsored by medium and large employers from 1983 through 1988.’ Because of time constraints associated with this request, we did not ver- ify the accuracy of the Spencer and BE3 information. We identified the prevalence and characteristics of age-specific provi- sions for eligibility under exit incentive programs. To do this, we (1) cat- egorized eligibility provisions and (2) looked for evidence of age bracketing (for example, exit incentive programs offered only to employees ages 50 to 55) or age capping (for example, programs extending eligibility only to employees under a certain age). For pur- poses of this report, we did not consider eligibility provisions with an age floor and no upper limit to be age-specific. We also focused on identifying programs offering enhanced benefits only to workers within specific age groups or under a certain age. We identified the use of bracketing and age caps that limited the availability of liberalized retirement benefits, supplemental retirement payments, and other forms of employee benefits provided as part of the exit incen- tive program. For our analysis, we did not attempt to compare the cost to the employer of providing benefits under exit incentive programs to older and younger workers. Nor did we ascertain whether some of the benefits offered as part of an exit incentive program were also included as part of a company’s routine employee benefit package. To gain perspective on employers’ motivations for using or not using age-specific provisions for eligibility and enhanced benefits under com- pany exit incentive programs, we interviewed officials from several For- tune 100 companies who were cognizant of their company’s program features. %ee Charles D. Spencer and Associates, “Early Retirement Incentives Offered by 24 Percent of Com- panies in 1986,” Spencer’s Research Reports on Employee Benefits (1987). 7Department of Labor, &reau of Labor statistics, Employee Benefits Survey (1988). Page 11 GAO/HRB9M7RE Age Dhrhination in Company Exit Incentive Programs Age Dhrhination: Use of AgeSpecific Provisions in Company Exit Incentive Programa Figure 1: Eligibility Provisions for Fortune S 100 Exit Incentive Programs 11 No Age Provision Point System Minimum Age Provision N = 62 programs We found very few instances where exit incentive programs used age- Age-Specific Eligibility specific provisions for eligibility. Only 3 of 62 Fortune 100 programs Provisions Rarely used these provisions (see fig. 1). Two programs set age brackets and Used one had an age cap on the age of workers to which the incentive offer was extended. The age brackets used were 55 to 65 years and 55 to 62 years. Age 62 was the cap applied in the one program that used it. For each of the three programs with age-specific provisions for eligibility, the age bracket’s upper boundary or the applied cap was the normal retirement age under the company pension plan. One of the programs with an age bracket was offered repeatedly during the lo-year period from 1979 through 1988. None of the exit incentive programs in the Spencer study had age-specific provisions for eligibility.8 “BE% Employee Benefits Survey did not report information on program eligibility provisions in a manner that allowed us to determine the incidence of age-specific provisions. Page 12 GAO/Hl?S9O-87BB Age Discrimination in Company Exit Incentive Programs Age Diacrhination: Use of AgeSpecific Provisions in Company Exit Incentive Programs Additional Information on Our alsoanalysis showed of eligibility provisions that for Fortune 100 company programs Eligibility Provisions for Exit Incentive Programs . Two-thirds of programs offered exit incentives to employees over a cer- tain age, normally to those at least age 55, with some specified years of service; l just under 20 percent of programs had no age provision; and . 13 percent of programs used a point system that coordinated workers’ ages and service to determine eligibility. For example, a program could require that workers have combined age and service totalling 75 points. Similarly, most of Spencer’s programs (84 percent) offered exit incen- tives to employees over a certain age, 55 on average, with some speci- fied years of service. Seven percent of the programs had only a service provision for eligibility, while the remaining 9 percent used other crite- ria (for example, a point system based on a combination of workers’ age and years of service). A majority of exit incentive programs offered age-specific enhanced Age-Specific Enhanced benefits to eligible workers (see fig. 2). In these programs, certain Benefits Used in Most enhanced benefits were provided exclusively to younger eligible work- Programs ers so that they could receive benefits comparable to those received by older workers who were already at or near the pension plan’s normal retirement age. Programs with age-specific enhanced benefits generally offered workers at certain ages at least one of the following provisions. l Liberalized early retirement benefits. This provision lessens or elimi- nates the actuarial reduction factor usually applied to early retirement benefits. It does not apply to workers who have reached normal retire- ment age. l Age credits. This provision credits additional years to workers’ actual age to make them eligible for retirement benefits, or to liberalize early retirement benefits, or both. Of course, workers above the pension plan’s normal retirement age are not helped by this provision. . Retirement supplements until a specified age. This provision gives work- ers below the specified age a benefit not available to older workers. Health or life insurance coverage until a specified age. This provision l provides benefit coverage for workers below the age limit but not above it. Page 13 GAO/IDUMO-87BR Age Dbdmination in Company Exit Incentive Programs Age Discrimination: Use of Age-Specific Provision in Company Exit Incentive Programs Figure 2: Exit incentive Programs With Age-Specific Enhanced Benefits 60 Percent of Programs 60 60 40 30 20 10 Fortune Spencer BLS 100 Dais Sources Similarities exist among the various sources regarding the use of age- specific enhanced benefits. As shown in figure 3, most programs with age-specific enhanced benefits, about 60 percent, liberalized the pension plan’s early retirement provisions. A substantial portion of programs, from 28 to 57 percent, placed an age cap on retirement supplements, usually 62 or 65. Less than 40 percent gave age credits. Also, a minority of programs imposed an age cap on health or life insurance coverage, normally age 65. A few exit incentive programs in BIAS Employee Benefits Survey gave workers age credits and offered retirement supplements that capped at a certain age. Our analysis shows that only 8 percent of these programs offered the two enhancements concurrently. None of the programs among the Fortune 100 or those reported on by Spencer did this. Page 14 GAO/HRD-90-87FSR Age Disc rimination in Company Exit Incentive Programs Age Discrimination: Use of Age-Specific provisions in Company Exit Incentive Programs Enhanced Benefits Percent of Programs 70 60 60 40 30 20 10 0 1 Fotlutw 100 Data Souroee ] Age Cap on Retirement Supplement ’ I Added Years to Workers’ Ages Liberalized Eariy Retirement I I Age Cap on Health or Life Insurance BLS did not inquire about age caps on health and life insurance coverage. We found several programs that used age-specific enhanced benefit pro- Additional Details on visions in unique ways when compared with other programs. A brief Age-Specific Exit description follows. Incentives In two programs, enhanced benefits were graduated by discrete age brackets. One such program, which provided a retirement supplement and liberalized early retirement benefits, allowed workers ages 55 to 59 to receive a supplement totalling up to 18 months of their base salary. Workers in the under-55 and those in the 60-and-over age groups, how- ever, were allowed supplements of only up to 15 months of their base salary. The other program provided workers in lower age brackets a greater number of enhanced benefits than older workers. Although this program offered all eligible workers a basic cash supplement, workers ages 55 to 60 could receive two additional enhanced benefits-a retire- ment supplement and cash allowance. Those ages 60 and 61 could Page 15 GAO/HRDSO-87BR Age Discrimination in Company Exit Incentive Programs Age Discrimination: Use of AgeSpecific Provisions in Company Exit Incentive Programs receive the retirement supplement but not the cash allowance. Those ages 62 and over were offered only the basic cash supplement. One Fortune 100 company program based the enhanced benefit on an age and service point system. Under this system, if workers had below the requisite points, the pension plan’s actuarial reduction factor nor- mally associated with early retirement was not applied. For purposes of calculating pension benefits, another program provided employees with service credit equal to one-half the difference between their actual ages and age 65. In operation, this program would give fewer service credits to older workers. Comments of using age-specific exit incentives. Officials of some companies that used Company age-specific exit incentives indicated that cost considerations played a Representatives role in company decisions. Others commented that before deciding to target the programs to younger workers, the company had considered the number of older workers approaching normal retirement age. They believed that the company could not have met its work force reduction goal by relying on attrition. Typical comments were: . “Workers at or above normal retirement age did not need an incentive to leave since they were entitled to full benefits under the pension plan.” . “The program was intended to encourage employees below the plan’s normal retirement age to leave.” Officials of companies that applied age caps on retirement supplements or insurance coverage stated that the caps were instituted at the point when workers were eligible for government sponsored programs. Offi- cials of companies with an age cap on retirement supplements com- mented that the payments were programmed to stop approximat,ely when workers became eligible for social security benefits. Officials of companies with a cap on health coverage said that they wanted to extend company benefits until workers reached age 65 and were eligible for Medicare benefits. Other comments were: . “The retirement supplement would allow retirees to receive approxi- mately the same retirement income before social security payments began as they would afterwards.” Page 16 GAO/HRD!3O-8WR Age Disc rimination in Company Exit Incentive Program, Age Discrimination: Use of Age-Specific Provisions in Company Exit Incentive Programs . “It was not considered a cap, but the age that coordinated with the Social Security Administration’s age for starting social security payments.” . “The idea was to make younger workers whole until normal retirement.” . “We capped health benefit coverage at age 65 because we didn’t want to give early retirees an advantage over those who normally retired at 65, since we didn’t extend coverage for them.” . “The age bracketing in the exit incentive program was identical to that in the regular pension plan. We wanted to show employees what more they could gain from the exit incentive program.” Officials for companies not using age-specific provisions generally told us that they believed such provisions were unfair to older workers. Some also mentioned the desire to avoid an ADEA age-discrimination law- suit as a significant factor. Several company officials emphasized that the purpose of exit incentive programs had been to reduce staff in gen- eral, not to retire older workers. Other statements follow. . “It isn’t fair to tell someone age 65 they can participate, but someone age 67 cannot.” . “Morally, so to speak, you owe more to people who have been with the company longer.” . “It would get us into more hot water in that it sounds like a pretty good basis for an ADEA age discrimination case.” . “If misconstrued, establishing age brackets or age caps might have adversely impacted on the program objective of reducing the total head count.” . “A program that discriminated against older workers would not be cost effective because, generally, the older the employee, the more they earn.” Page 17 GAO/HRD904i7BR Age Discrimha tion in Company Exit Incentive Programs Appendix I CongressionalRequesters The Honorable Howard M. Metzenbaum Chairman, Subcommittee on Labor Committee on Labor and Human Resources United States Senate The Honorable James M. Jeffords Ranking Minority Member, Subcommittee on Labor Committee on Labor and Human Resources United States Senate The Honorable David H. Pryor Chairman, Special Committee on Aging United States Senate The Honorable John Heinz Ranking Minority Member Special Committee on Aging United States Senate The Honorable William Clay, Chairman Subcommittee on Labor-Management Relations Committee on Education and Labor House of Representatives The Honorable Augustus F. Hawkins, Chairman Committee on Education and Labor House of Representatives The Honorable Edward R. Roybal, Chairman Select Committee on Aging House of Representatives The Honorable Matthew G. Martinez, Chairman Subcommittee on Employment Opportunities Committee on Education and Labor House of Representatives . Page 18 GAO/HRIXKM7BR Age Discdhation in Company Exit Incentive Program5 Appendix II Major Contributors to This Report Donald C. Snyder, Assistant Director, (202) 535-8358 Human Resources Glenn G. Davis, Project Manager Division, Sheila R. Nicholson, Evaluator Washington, D.C. Dayna K. Shah, Assistant General Counsel Office of the General Counsel, Washington, D.C. (105629) Page 19 GAO/HRD90-97RR Age Dhrimhation in Company Exit Incentive Programs . United States General Accounting Washington, Office D.C. 20548 $ Official Business Penalty for Private Use $300 Requests for copies of GAO reports should be sent to: U.S. General Accounting Office Post Office Box 6015 Gaithersburg, Maryland 20877 Telephone 202-275-6241 The first five copies of each report are free. Additional copies are $2.00 each. There is a 25”‘) discount on orders for 100 or more copies mailed to a single address. Orders must be prepaid by cash or by check or money order made out to the Superintendent of Documents.
Age Discrimination: Use of Age-Specific Provisions in Company Exit Incentive Programs
Published by the Government Accountability Office on 1990-02-27.
Below is a raw (and likely hideous) rendition of the original report. (PDF)