[Senate Hearing 119-165]
[From the U.S. Government Publishing Office]


                                                        S. Hrg. 119-165

                      PROTECTING OLDER AMERICANS:
                       LEVELING THE PLAYING FIELD
                           FOR OLDER WORKERS

=======================================================================

                                HEARING

                               BEFORE THE

                       SPECIAL COMMITTEE ON AGING

                          UNITED STATES SENATE

                    ONE HUNDRED NINETEENTH CONGRESS


                             FIRST SESSION

                               __________

                             WASHINGTON, DC

                               __________

                           SEPTEMBER 3, 2025

                               __________

                           Serial No. 119-13

         Printed for the use of the Special Committee on Aging
         
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        Available via the World Wide Web: http://www.govinfo.gov
        
                                __________

                   U.S. GOVERNMENT PUBLISHING OFFICE                    
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                       SPECIAL COMMITTEE ON AGING

                     RICK SCOTT, Florida, Chairman

DAVE McCORMICK, Pennsylvania         KIRSTEN E. GILLIBRAND, New York
JIM JUSTICE, West Virginia           ELIZABETH WARREN, Massachusetts
TOMMY TUBERVILLE, Alabama            MARK KELLY, Arizona
RON JOHNSON, Wisconsin               RAPHAEL WARNOCK, Georgia
ASHLEY MOODY, Florida                ANDY KIM, New Jersey
JON HUSTED, Ohio                     ANGELA ALSOBROOKS, Maryland
                              ----------                              
                McKinley Lewis, Majority Staff Director
                Claire Descamps, Minority Staff Director
                        
                        
                        C  O  N  T  E  N  T  S

                              ----------                              

                                                                   Page

Opening Statement of Senator Rick Scott, Chairman................     1
Opening Statement of Senator Kirsten E. Gillibrand, Ranking 
  Member.........................................................     1

                           PANEL OF WITNESSES

Nancy LeaMond, Chief Advocacy and Engagement Officer, AARP, 
  Washington, DC.................................................     4
David Horton, Fair Business Practices and Investor Advocacy, 
  Endowed Chair, Martin Luther King, Jr., Professor of Law, 
  University of California, Davis School of Law, Davis, 
  California.....................................................     5
Gretchen Carlson, Journalist and Co-Founder, Lift our Voices, 
  Greenwich, Connecticut.........................................     7
Rachel Greszler, Senior Research Fellow Workforce and Public 
  Finance, the Heritage Foundation, Washington, DC...............     9

                                APPENDIX
                      Prepared Witness Statements

Nancy LeaMond, Chief Advocacy and Engagement Officer, AARP, 
  Washington, DC.................................................    26
David Horton, Fair Business Practices and Investor Advocacy, 
  Endowed Chair, Martin Luther King, Jr., Professor of Law, 
  University of California, Davis School of Law, Davis, 
  California.....................................................    29
Gretchen Carlson, Journalist and Co-Founder, Lift our Voices, 
  Greenwich, Connecticut.........................................    32
Rachel Greszler, Senior Research Fellow Workforce and Public 
  Finance, the Heritage Foundation, Washington, DC...............    34

                        Questions for the Record

Nancy LeaMond, Chief Advocacy and Engagement Officer, AARP, 
  Washington, DC.................................................    48

                       Statements for the Record

American Association for Justice Statement.......................    57
Defense Credit Union Council Statement...........................    61
Mary Ann (Miki) Herman Statement.................................    65
Ed Henselder Statement...........................................    66

 
                      PROTECTING OLDER AMERICANS:
                       LEVELING THE PLAYING FIELD
                           FOR OLDER WORKERS

                              ----------                              


                      Wednesday, September 3, 2025

                                        U.S. Senate
                                 Special Committee on Aging
                                                    Washington, DC.
    The Committee met, pursuant to notice, at 10:36 a.m., Room 
106, Dirksen Senate Office Building, Hon. Rick Scott, Chairman 
of the Committee, presiding.
    Present: Senator Scott, McCormick, Johnson, Gillibrand, 
Warren, and Kim.

                 OPENING STATEMENT OF SENATOR 
                      RICK SCOTT, CHAIRMAN

    The Chairman. The Senate Special Committee on Aging will 
now come to order. We are proud of the bipartisan history of 
the Special Committee on Aging and to maintain that tradition 
in this Congress, today's hearing will be led by Ranking Member 
Gillibrand. Let me turn it over to the Ranking Member.

                 OPENING STATEMENT OF SENATOR 
             KIRSTEN E. GILLIBRAND, RANKING MEMBER

    Senator Gillibrand. Chairman Scott, thank you so much for 
providing me with the opportunity to discuss this incredibly 
important topic: age discrimination. Thank you to our witnesses 
for being here today, for fighting for the rights of older 
Americans and their families. You all know what it is like to 
spend a lifetime working hard, building your career, and 
contributing to our economy. You can imagine how devastating it 
is to experience discrimination because of how old you are.
    Nobody wants to feel like their contributions don't matter, 
especially not because of some arbitrary characteristic like 
age. Far too often older workers are denied employment, passed 
over for promotions, or even fired because of their age. 
According to research conducted by AARP, 64 percent of workers 
over the age of 50 have seen or experienced some form of age 
discrimination at work, and of that population, 90 percent 
believe that age discrimination against older workers is common 
in the workplace.
    In that same report, more than one in five older Americans 
said that they worried about being pushed out of their job 
because of their age. This comes as Americans have started 
working later in life. With employees over 75 years old, are 
becoming the fastest growing age group in the economy, just ask 
the U.S. Senate.
    The population of older Americans is growing, and many are 
returning to the workforce; We need to ensure that those who 
face age discrimination can have their day in court. Victims of 
age discrimination often can't seek justice or accountability 
in court because of a forced arbitration clause they signed 
when they were hired. Many employees are not even aware that 
their employment contract contained a forced arbitration 
clause.
    It traps those who experience workplace discrimination in a 
system that benefits their employer, preventing them from 
seeking information that could prove their case. Victims are 
left at the hands of an extrajudicial arbitrator who is often 
selected by the employer and not always a trained lawyer. It's 
no surprise that employees are often less likely to win an 
arbitration than they are in court.
    Building on our successful effort to ban forced arbitration 
in cases of sexual harassment and sexual assault, Senator 
Lindsey Graham and I introduced the Protecting Older Americans 
Act, which would invalidate forced arbitration clauses in cases 
of age discrimination as well. It would also allow those who 
have experienced age discrimination the option to file their 
case in court if they choose, even if they previously signed a 
forced arbitration clause. It gives them a voice and a process 
and the ability to seek justice. If employees decide that they 
would like to pursue arbitration when they have faced age 
discrimination, they can. The point is that employees will now 
have this fundamental choice.
    The crux of the issue is that despite how workplace age 
discrimination is categorically illegal, and how Congress has 
already passed laws to protect older Americans from it, forced 
arbitration clauses subvert justice. They take away your 
constitutional right to a jury without you knowing about it. 
They allow employers to hide illegal conduct behind closed 
doors, and they shield those who have committed serious 
misconduct from the public eye.
    Now we have an opportunity for broad bipartisanship at a 
time when many Americans feel Congress is too divided to get 
things done. I look forward to hearing from our witnesses today 
as well as discussing these critical issues. Thank you, Mr. 
Chairman.
    The Chairman. Thank you. Thank you, Ranking Member. First 
off, thanks everybody for being here. We've gathered to discuss 
a very important topic, not just for our aging community, but 
also for generations planning for retirement, and for those who 
won't be retiring for several decades. Today's hearing, we'll 
focus on the value of our older Americans in the workplace, 
what we can do as elected officials to help protect and foster 
a purpose-filled life for our aging constituents.
    I look forward to a discussion today on how we fight 
against age discrimination by highlighting the positive impact 
of older Americans' engagement in their communities, and how 
aging Americans who remain engaged create benefits for 
themselves in our economy. I want to be clear about something. 
Age discrimination is clearly wrong. It's stupid. I built 
businesses. I can tell you that looking at someone's age 
instead of the value they bring to an organization absolutely 
makes zero sense. You can't run a business or government that 
way, and we need to make sure it's not happening to any 
American senior.
    Work provides purpose and fulfillment. These are powerful 
forces that enrich families, strengthen communities, and 
support the health and longevity of our Nation and its people. 
Having a purpose is an essential part of the American dream and 
has long been an indicator of both mental and physical well-
being across all age groups. Research shows that older adults 
who remain engaged experience greater physical health, mental 
resilience, and life satisfaction, and appointing older 
Americans is good for business too because these folks have 
years of wisdom, the ability to mentor the next generation of 
leaders, and a valuable perspective on issues leaders in 
business and government face each and every day.
    To be clear, not every older American wants to stay the 
workforce. Finding purpose will be different for each person. 
For some, it will be taking a class or a course to explore an 
area of interest, volunteering in the community, or dedicating 
time to pursue a new hobby, but for many seniors, purpose will 
be found to continuing to work in some capacity. This could be 
in their previous business as a new part-time employee, at a 
place they enjoy frequently, or even branching out and starting 
something new. We need to make sure Americans of all ages have 
the opportunity to work and pursue their dreams by stopping age 
discrimination and removing the red tape and barriers that 
hamper or discourage older Americans from continuing to work or 
starting a new business or career.
    We did this in Florida when I was Governor. We cut taxes. 
By cutting taxes and costly and unnecessary regulations, we 
managed to turn the economy around making a beacon for 
businesses and those wanting a full and purposeful life. During 
my years as Governor, we cut taxes more than 100 times and 
sliced more than 5,000 burdens from regulations. We cut the 
time it took to get your license or permit from the State of 
Florida from weeks to days. Florida businesses added 1.7 
million jobs. We paid down over $10 billion of debt. We 
increased the efficiency of government to provide additional 
services for our citizens and our state, including for our 
seniors, and as a result, many seniors moved to Florida because 
there's clearly better business opportunities there.
    Because of these policies, Florida is well known as the 
place that thousands of retirees' flock to each and every year, 
escaping less financially hospitable climates, some to retire, 
some to start businesses. In Florida, their dollars go farther, 
and they have communities and opportunities to experience 
connection and fulfillment without the fear of age 
discrimination. I want to thank my colleague, Ranking Member 
Gillibrand for her focus on this important topic and look 
forward to a productive and meaningful conversation. I think 
you're going to go now.
    Senator Gillibrand. Thank you, Chairman Scott. I want to 
introduce our first witness, Nancy LeaMond. Ms. LeaMond serves 
as the chief advocacy and engagement officer for AARP, and she 
has the responsibility of driving the organization's social 
mission on behalf of the Americans 50 plus and their families. 
In this capacity, she leads AARP's legislative campaigns, 
manages public education, volunteerism, multicultural outreach, 
and engagement. Thank you, Ms. LeaMond, you may begin.

          STATEMENT OF NANCY LEAMOND, CHIEF ADVOCACY 
          AND ENGAGEMENT OFFICER, AARP, WASHINGTON, DC

    Ms. LeaMond. Thank you, Chairman Scott, Ranking Member 
Gillibrand, members of the Committee. Thank you for the 
opportunity to testify today. As you said, my name is Nancy 
LeaMond and I serve as AARP's Executive Vice President and 
Chief Advocacy and Engagement Officer.
    On behalf of the 100 million Americans age 50 and over, I 
also want to thank you for working in a bipartisan way to 
highlight so many issues important to older adults. Hearings 
like this as well as others, including Senator Scott's recent 
field hearing on fighting fraud, help move us toward solutions 
that will allow Americans to age with dignity.
    Today's topic of age discrimination is critically 
important. It is an under-discussed and under-recognized issue 
that is real implications for the growing population of older 
Americans who are working longer than ever before, many because 
they need to make ends meet. According to the Federal Reserve 
Survey of Consumer Finances, 54 percent of households have no 
retirement savings. Among those who do the median savings for 
folks, 55 to 64 is $185,000, and it's worth noting that the 
number for older women, particularly those who are divorced, 
widowed, or never married, is significantly lower.
    As we all know, this number is well below what's needed for 
a secure retirement, even factoring in social security and 
likely one reason that folks 75 and older are the fastest 
growing segment of the workforce. At the same time, nearly two 
thirds of workers age 50 plus tell us they've seen or 
experienced age discrimination, and 40 percent of job seekers 
over 45 say they've faced it looking for work.
    Research shows that half of workers in their early 50's 
experience involuntary job loss, and older Americans are more 
likely than their younger peers to be unemployed for six months 
or longer. More than half of older job seekers report being 
asked to provide age related information during the application 
process, and the algorithms used to scan resumes and 
applications can accelerate bias using graduation dates or 
years of experience as proxies for age to screen out otherwise 
qualified candidates.
    Talk to older job seekers and they'll tell you they hear 
things in interviews like, "You're overqualified, we're looking 
for a digital native, or a more energetic candidate." This is 
undermining the financial stability of too many capable 
Americans. It's also economically damaging to our country. AARP 
research shows that age discrimination costs the U.S. economy 
$850 billion every year. Simply put, sidelining experienced 
workers is also a loss we cannot afford, and Congress has the 
power to help fix this problem.
    I want to commend Senator Gillibrand, who along with 
Senator Graham has introduced the Protecting Older Americans 
Act to end mandatory arbitration in age discrimination claims, 
a practice that silences workers and denies them the full 
protection of law. AARP is proud to support this common-sense 
law. Other bipartisan bills that we think should be considered 
by the Congress include the Protecting Older Workers Against 
Discrimination Act and the Protect Older Job Applicants Act.
    AARP is also working at the state level, promoting policies 
to ban age-related inquiries in the initial hiring process and 
to secure funding to help retrain older workers. We're 
partnering with employers to build more age inclusive 
workplaces through initiatives like our Employer Pledge 
Program, which has over 2000 businesses, and we help older 
Americans sharpen their skills to stay competitive.
    It's going to take an all of the above approach to really 
make progress. Again, thank you so much for holding this 
important hearing and for the opportunity to testify on behalf 
of older Americans who ask only for fairness and respect in the 
workplace.
    Senator Gillibrand. Thank you very much, Ms. LeaMond. I 
want to now introduce our next witness, David Horton. Professor 
Horton is the Fair Business Practices and Investor Advocacy 
Professor of Law at the University of California, Davis School 
of Law. Professor Horton's teaching and published works are 
focused on wills and trusts, arbitration, law, and contracts. 
You may begin.

       STATEMENT OF DAVID HORTON, FAIR BUSINESS PRACTICES

          AND INVESTOR ADVOCACY, ENDOWED CHAIR, MARTIN

       LUTHER KING, JR., PROFESSOR OF LAW, UNIVERSITY OF

       CALIFORNIA, DAVIS SCHOOL OF LAW, DAVIS, CALIFORNIA

    Mr. Horton. Thank you, Chairman Scott, Ranking Member 
Gillibrand, distinguished members of the Committee for the 
opportunity to speak today. My name is David Horton. I teach at 
UC Davis, and one of my areas of specialty is forced 
arbitration.
    We just heard from Nancy about how age discrimination harms 
older workers, and I'm going to talk about how forced 
arbitration compounds those harms. At the outset, I should say 
that I believe that arbitration could be socially valuable. For 
example, it would allow two businesses in a particular industry 
to submit a dispute to a specialist in their field rather than 
a generalist judge.
    For two reasons, I oppose the forced arbitration of claims 
that are as pernicious and as pervasive as age discrimination. 
First, although arbitration derives its legitimacy from the 
parties consent to bypass the court system, forced employment 
arbitration is not consensual. Think of some of the ways that 
employers force employees to arbitrate.
    Sometimes they put arbitration provisions in onboarding 
paperwork, but studies confirm what our common sense tells us. 
At that time, workers are bombarded with information, they 
don't read or understand the fine print, and they have no idea 
that they've waived their seventh amendment right to a jury 
trial. Moreover, even if workers did read and understand forced 
arbitration provisions, they would have little choice. Who has 
the luxury to say no to a job because they don't like the fine 
print? And it would make no sense to leave a position for 
another position hoping that it wouldn't be subject to 
arbitration because statistics show that forced arbitration is 
so pervasive that the odds are any other job would also be 
subject to the process.
    Employers often also impose arbitration on people who have 
been on their payroll for years and even decades, so consider 
an example from a recent age discrimination case. There was a 
woman named Joanne Grace. She started as a nurse in 1976. It 
wasn't until 2019 that she took an online training that 
culminated with her clicking a button saying she agreed to 
arbitrate to any dispute with her employer. A year later, a new 
supervisor was assigned to her who made derogatory comments 
about her age and ended up firing her and replacing her with a 
younger worker.
    She sued for age discrimination, but a federal court in 
Ohio compelled arbitration of her claim. It's not true that her 
consent to arbitration in that context is meaningful. Was she 
really going to leave a job that she loved, that she'd been 
working at for 50 years over something like forced arbitration?
    The second reason that employees should not be compelled to 
arbitrate age discrimination claims, is that there are systemic 
differences between litigation and arbitration that make it 
harder for plaintiffs to vindicate their rights. For example, 
employment discrimination often arises out of company-wide 
policies, which calls out for class or collective proceedings, 
but you can't bring class or collective proceedings in 
arbitration.
    Forced employment arbitration also has a repeat player 
problem, so unlike judges, arbitrators are selected by the 
parties and paid by the hour, so they have an economic 
incentive to rule in favor of the only party who's going to be 
in a position to select or veto them again in a future case, 
and this concern about arbitral bias is especially pressing, 
given the rising phenomenon of employers paradoxically 
assigning arbitrators the task of determining whether or not 
the arbitral process is fair.
    For years, courts applied the contract doctrine of 
unconscionability to invalidate arbitration clauses that tried 
to tilt the scales of justice, but in a 2010 decision called 
Rent-A-Center West v. Jackson, the U.S. Supreme Court gave its 
blessing to delegation clauses which allow arbitrators to 
decide that issue. If an arbitrator holds that the arbitral 
process is rigged, they're taking money out of their own 
wallets by denying themselves the power to hear the merits of 
the case.
    There is growing empirical evidence that arbitrations 
differences: it's lack of class and collective proceedings, its 
risk of biased decisionmakers, its limited discovery, are 
deterring plaintiffs from pursuing claims. Scholars estimate 
based on filing levels in federal and state court and the 
percentage of employees who are subject to arbitration clauses, 
that you would expect to see between 323,000 and 727,000 
employment arbitrations every year. How many arbitrations are 
actually filed by employees? In the leading arbitration 
providers, the AAA and JAMS, the number is 2,000 to 3000.
    What we know about the prevalence of age discrimination, 
many of these missing abandoned claims have to be seeking 
redress under the ADEA or its state analogs. For these reasons, 
although we describe arbitration as alternative dispute 
resolution, forced employment arbitration is not alternative 
dispute resolution. It's not an alternative because employees 
have no choice. It's also not an alternative to anything 
because it's increasingly the norm, and it's not dispute 
resolution because its purpose isn't to resolve disputes, it's 
to suppress them.
    One step in the right direction would be for Congress to 
pass the Protecting Older Americans Act. This bill gives 
workers with age discrimination claims, what they've been 
sorely lacking for decades, the freedom to choose a forum in 
which to seek justice. Thank you again for the opportunity to 
testify.
    Senator Gillibrand. Thank you so much, Professor Horton. 
Appreciate it. I want to move now to our next witness, Gretchen 
Carlson. Ms. Carlson is a former Fox News journalist and co-
founder of a not-for-profit, Lift Our Voices, which works to 
end the silencing of harassment victims through forced 
arbitration and non-disclosure agreements.
    A champion for workplace equality, Ms. Carlson was named 
the Time Magazine's 100 most influential people in the world 
after her bold actions against Fox News, which not only helped 
to pave the way for the global Me Too movement, but was the 
leading advocate to change the law, to eliminate forced 
arbitration in the workplace for sexual assault and sexual 
harassment. You may begin.

         STATEMENT OF GRETCHEN CARLSON, JOURNALIST AND 
      CO-FOUNDER, LIFT OUR VOICES, GREENWICH, CONNECTICUT

    Ms. Carlson. I should know how to do that by now. Thank you 
so much, Chairman Scott. I think I have not seen you since we 
were on Fox and Friends together years ago at the Villages and 
we were wrestling a baby alligator together, so it's great to 
see you again.
    Chairman Scott. Both survived.
    Ms. Carlson. We both survived. We did. It was tiny. Ranking 
Member Gillibrand, thank you so much for your support on these 
issues, and to the other members of this Committee, thank you 
for the opportunity to be here. I'm so encouraged to be able to 
talk to you about my advocacy with forced arbitration and the 
work that I've done to make Americans so much safer in the 
workplace.
    In 2016, I somehow found the courage to come forward 
against then chairman and CEO of Fox News, Roger Ailes for 
sexual harassment. It was the toughest decision of my life, but 
after my career that I had killed myself for was taken away 
from me, I thought to myself, "If I don't do this, who will?" 
My story made headlines around the world, but you know, it 
could have easily been swept under the carpet because of a 
forced arbitration clause in my own employment contract.
    No one starts a new job expecting something bad to happen 
to them. I know I didn't. In the face of a new opportunity, few 
people can walk away from a job opportunity because of the fine 
print. I don't care who you are, you don't understand what 
forced arbitration means. In my case, it showed up in my last 
contract with Fox, and while I asked a lot of questions, I was 
told not to worry about it because, "It was becoming the way of 
the world."
    Eerily, I had no idea at the time how true that was. Today, 
more than 60 million American workers are subject to forced 
arbitration. Most have no idea that signing on the dotted line 
means they've accepted forced arbitration as their only remedy 
for justice.
    After my story, I started walking the halls of Congress and 
in 2022, thanks to members of this Committee and other 
champions in Congress from both sides of the aisle, the Ending 
Forced Arbitration of Sexual Assault and Sexual Harassment Act 
was signed into law, one of the proudest moments of my life. 
That meant that Kirsten Tiger, a bartender at a prestigious 
country club facing harassment, she was able to bring lawsuits 
since that law passed against her employer last year, and even 
though her employer still tried to compel the forced 
arbitration clause, the request was denied because of that law.
    A federal judge in Texas also declined to grant Blaze 
Media's motion to dismiss after one of its employees, Sydney 
Watson, she also claimed harassment. Watson's case can now also 
continue in the court of law thanks to the new law, but there's 
still much more work to do.
    Last year in one of the most outrageous stories that you 
probably heard of, a wife and mom died of an allergic reaction 
at a Disney restaurant after staff confirmed to her that the 
food was safe. Disney tried to force her husband into 
arbitration because get this, he had previously signed a Disney 
plus streaming subscription confirmation email, which included 
a forced arbitration clause. Only after enormous public outcry 
did Disney waive the arbitration clause and allowed the case to 
proceed in court.
    How about our kids? Parents of a 14-year-old girl in 
California claimed she was coerced into sharing graphic images 
online with two companies. Both companies tried to force the 
family into arbitration, into secrecy, meaning other families 
of this alleged predator with at least 20 other child victims 
would never be able to know about him.
    Pertinent to why we're here today, Sam Cassel was promoted 
seven times as a top sales rep throughout his 24-year career, 
despite a better sales record than his younger peers, he was 
forced out and terminated, and due to a forced arbitration 
clause, he had no ability to seek justice in the court system. 
These personal stories are why I'm a champion as well of the 
Protecting Older Americans Act.
    Reintroduced today by Ranking Member Gillibrand and Senator 
Graham, also co-sponsored by the Chair and Ranking Member of 
the Senate Judiciary Committee, Senator Grassley and Senator 
Durbin. Too many people are still not getting the simple 
freedom of choice when something bad happens to them at work.
    Now, just for a minute about the naysayers out there, we 
haven't seen what the chamber claimed was going to happen after 
we passed the EFAA that all hell would break loose and if you 
let women file their assault and harassment cases in court, 
there would be a slew of new cases everywhere and companies 
would go out of business, but none of that has happened. 
Instead, we're just cleaning up the workplace and getting rid 
of a few bad apples. I believe the same thing could happen with 
this bill.
    A close friend said to me after my lawsuit at Fox News, 
"Something good is going to happen from this Gretchen." And I 
didn't really see it at the time, but something great has 
happened from this. I thank you for holding this hearing. I 
hope you'll agree this is a bill we can all get behind 
regardless of politics. Maybe we can all start by agreeing that 
all of us here today are part of the age category. Let's take 
this on together, and I thank you for your time.
    The Chairman. First off, thanks. Thanks to all of you for 
your testimony. I now like to introduce Rachel Greszler. Rachel 
is a nationally recognized expert on workforce, retirement, and 
fiscal policy. As a senior research fellow at the Heritage 
Foundation, she has spent over a decade analyzing and advising 
on issues such as fiscal policy, pensions, and labor policy. 
Before joining Heritage in 2013, she served as a senior 
economist for the Joint Economic Committee on of Congress for 
seven years.
    Her research is marked by commitment to promoting economic 
growth, individual freedom, and fiscal responsibility. Her 
expertise and passion for practical people-focused solutions 
make her an invaluable resource for today's discussion on the 
role of purpose, responsibility, and engagement in later life. 
Thank you. Please begin your testimony.

         STATEMENT OF RACHEL GRESZLER, SENIOR RESEARCH

              FELLOW WORKFORCE AND PUBLIC FINANCE,

            THE HERITAGE FOUNDATION, WASHINGTON, DC

    Ms. Greszler. Chairman Scott, Ranking Member Gillibrand, 
and members of the Committee. Good morning and thank you for 
the opportunity to be here today. In my remarks, I would like 
to cover three points.
    First, is that older Americans are an increasingly vital 
contributors to our economy and the fabric of society. Second, 
their continued engagement and productive activities provide 
huge benefits across generations, and third, policymakers can 
and should remove barriers that make it harder for older 
Americans to stay engaged in ways that are meaningful to them 
and beneficial to society.
    Today about one in four Americans are ages 55 and older, 
and this share is steadily rising due to longer life 
expectancies, a declining fertility rate, and the aging of the 
baby boomers. Moreover, almost a quarter of the labor force is 
55 and older, and that has also been rising alongside 
improvements in health and also more flexible work 
opportunities, and this continued work is not just about 
necessity, but because people find purpose and meaning in it.
    While retirement is often considered a one-time event, 
we're seeing more older Americans choose a transitional 
retirement, often giving up their full-time job and pursuing 
part-time employment or independent contracting that provides 
more flexibility. A recent survey found that 26 percent of baby 
boomer professionals and 38 percent of silent generation of 
professionals engaged in independent work, and beyond paid 
employment, older Americans make enormous contributions in 
caregiving and volunteering.
    For example, 20 percent of grandparents care for their 
grandchildren at least once a week, and older Americans have 
the highest volunteer rates in America. Community mentors, 
church volunteers, and hospice companions. These activities 
foster strong families and strong communities, and moreover, 
continued engagement, whether paid or unpaid improves older 
Americans' happiness, their financial well-being, and also 
their health. That includes reducing the risk of chronic 
disease, cognitive decline, and depression.
    I've seen the benefits of aging with purpose firsthand. My 
grandfather, after retiring from a long career in the Marines, 
started a small accounting business in his home. My father 
spent decades practicing medicine and then partly retired and 
spent another decade doing independent medical exams. My mother 
left her full-time job but still serves as a law guardian for 
children and also offers her legal services pro bono, and it 
was because my grandmother cared for me and my older sister 
that my mother was able to attend law school.
    Despite all the benefits of older Americans staying 
engaged, certain public policies impose obstacles instead of 
opportunities. One example is social security's retirement 
earnings test. This great depression era policy was meant to 
push older Americans out of the workforce to free up jobs for 
younger workers. Today we need more workers, not fewer. This 
outdated test functions like an additional 50 percent tax on 
the social security benefits of workers who are under age 67. 
That leads to marginal tax rates as high as 84 percent on 
middle income older workers. Not surprisingly, this prevents 
many of them from working as much as they otherwise would.
    I estimate that eliminating the earnings test could bring 
up to one million older Americans into the workforce that would 
reduce poverty, increase incomes and output, improve health 
outcomes, and boost federal revenues all by simply allowing 
Americans to work as much as they would like without a penalty.
    Other barriers come through regulations that restrict work 
opportunities and they make it harder to start a business. For 
example, the Biden Administration's rule on independent 
contractors limits flexible job options. In California, a 
similar rule was found to reduce self-employment by 10.5 
percent. Two bills the 21st Century Worker Act and the Modern 
Worker Empowerment Act would free up flexible job opportunities 
and enable more Americans to be their own bosses.
    For older Americans who want to start a business, franchise 
ownership offers a proven business model with less risk and 
often lower startup costs, but a Biden Administration rule 
could upend that model. The Save Local Business Act would make 
it easier for Americans to start and grow small businesses, and 
a package of proposals recently introduced in the HELP 
Committee would help make it easier for independent workers to 
access traditional workplace benefits like retirement savings 
plans and health insurance.
    In conclusion, everyone benefits when older Americans have 
equal and ample opportunities to stay engaged in work and in 
society. By removing barriers to work, policymakers can free up 
opportunities for older Americans to contribute to stronger 
families, stronger communities, and a stronger economy. Thank 
you.
    Senator Gillibrand. Thank you all for your testimony. Ms. 
Carlson, you noted in your testimony that the Protecting Older 
Americans Act has bipartisan support. The bipartisan support of 
this bill reflects the coalition that you have been working on 
in building to give workers a choice in how they address their 
discrimination claims. Your organization Lift Our Voices 
includes both Democrats and Republicans as supporters of its 
goal.
    What reasons have your allies in the movement, whether 
Democrat or Republican or independent, given to justify 
opposing forced arbitration? Anecdotally, what have you seen in 
terms of a momentum for why we should pass this bill now?
    Ms. Carlson. Thank you so much, Senator. I think it's a 
variety of different things. I always describe this movement as 
a perfect storm. When I came forward, luckily because my 
lawyers found a way to make my case public, even with my forced 
arbitration clause, or we wouldn't even be having this 
discussion, you know, that happened and then a tidal wave of 
other women came forward, but really what was also essential 
was that the media started covering these stories.
    I can say this as a member of media that had it been 
pitched before 2016 as an idea, it probably would not have been 
covered. The media became interested in covering these stories. 
Social media actually helped because it allowed people to come 
forward either anonymously or with their face on their story in 
droves, and suddenly it became a worldwide issue, but the third 
thing that really helped this perfect storm happen where people 
became more educated on these issues, is that the American 
public got mad, because they thought we had come a lot further 
along in this process of protecting people at work, whether 
it's age discrimination, sexual harassment, or any other kind 
of discrimination.
    Why did they think that? They didn't hear about these 
stories, and why were they not hearing about these stories? 
They were all going to the secrecy of forced arbitration. 
There's been an explosion of the use of forced arbitration. In 
1991, two percent of all employees were under it. This year 
more than 80 percent will be under it. It's been an explosion. 
The American public got mad and they were like, wait a minute. 
I thought we were more equal and fair to all of our workers 
across this country.
    I think that the education behind this has been crucial, 
where more people are starting to understand what forced 
arbitration is, and actually when they find out what it is, 
they don't like it. Last year, Lift Our Voices commissioned to 
study with The Morning Consult, and more than 70 percent of all 
Americans, when they understand what forced arbitration is, and 
it takes away their choice and their seventh amendment right, 
they're against it, and what the study actually found was that 
the percentages are higher in southern states and higher 
amongst the most conservative of those surveyed. When they 
understand what it is, right?
    Senator Gillibrand. Because you're taking away someone's 
constitutional right to a jury trial, a jury of their peers to 
judge an issue and not be shuttered behind closed doors, and as 
you know well, Gretchen, a lot of these forced arbitration 
clauses are paired with non-disclosure agreements, and so, 
you're forced into silence regardless.
    Ms. LeaMond, in your testimony you cite an AARP report that 
found age discrimination is draining $850 billion from the U.S. 
economy every year. This is a shockingly high number. You also 
cited an Urban Institute study that found 50 percent of workers 
in their early 50's are experiencing involuntary job loss. Can 
you please go into more detail on the emotional and economic 
impacts that age discrimination has on the older workforce? 
What is the workforce losing due to age discrimination?
    Ms. LeaMond. Well, Senator, both you and the Chairman spoke 
a little bit about it in your opening remarks. This is 
devastating for individuals and also can be overall for the 
workforce if we lose this valuable resource that I think 
everybody on the panel has spoken about. When you talk about 
individuals and their families, it has tremendous, tremendous 
impact. Rachel mentioned of volunteers, and no organization is 
prouder of their volunteers than the AARP, many of whom are 
here today.
    When I met with them in the cafeteria at the office before 
walking over, one of them said to me, "Thank you for testifying 
to this. I have my own story." That's what I hear everywhere, 
and I'm sure you do as well. The emotional toll of losing your 
job. Much of it is your identity, so much of it is your social 
group, and so much of it obviously is your income, the ability 
to be able to have health insurance and protect your family. 
It's all woven and there are stories everywhere.
    What we hope and are encouraged by sessions like this is 
that we can look at all we can do to help the individual 
workers and also to help businesses in the country.
    Senator Gillibrand. Mr. Chairman, thank you.
    Chairman Scott. Let me defer to Senator Johnson.
    Senator Johnson. Thank you, Mr. Chairman. I'll start by 
saying this is probably a lose proposition from me even asking 
these questions, but I do think somebody has to bring in 
perspective of smaller employers. I mean, nobody wants to see 
people discriminated against. You know, we're talking about 
cases against Disney and against you know, Fox News, big 
corporations. They've got plenty of money to do this. I'm 
talking about the little guy.
    I think we should acknowledge that all people who claim 
discrimination are not equal. There are plenty of situations in 
smaller businesses where somebody claims discrimination 
falsely. You know, I certainly as opposed to--and again, I 
don't know all the laws on arbitration, forced arbitration 
versus voluntary arbitration. What I would not want to see is 
just the Wild Wild West.
    You know, Ms. Carlson, you said, you know, we didn't see an 
explosion in lawsuits, but I'll tell you, as a small employer, 
you fear lawsuits. The only people who win generally are the 
lawyers. Not the claimant, not the company. I guess I'd be 
looking more for a middle ground in terms of can we make 
arbitration work? Can we protect those who have--and again, how 
do you, how do you adjudicate whether it's a valid 
discrimination suit?
    Again, I'm just bringing the perspective of small employers 
who are just screwed by the legal system. I mean, it's awful, 
and again, there are plenty of people that take advantage of 
it. I mean, not all whistleblowers are created equal, not all 
people claiming discrimination.
    I'll start with you, Mr. Horton. Can you comment on that? 
Can you allay some of my concerns about some of these bills 
that are being proposed?
    Mr. Horton. Sure. Thank you, Senator. That's a very 
legitimate concern. One of the things I was most heartened at 
when I looked at how the Ending Forced Arbitration of Sexual 
Assault and Sexual Harassment Act has been playing out in the 
courts over the last three and a half years, is that there 
actually does not seem to have been a deluge of lawsuits and 
certainly not of frivolous lawsuits.
    Although it's not in the text of the statute, courts have 
imposed a common-sense limitation in requiring sexual 
harassment claimants' claim to be plausible, which is the 
general standard for pleading in federal court, and I know that 
sounds like a low standard, but in the case of many 
discrimination claims, it's actually quite a high standard 
where the court is inquiring whether or not these facts would 
actually meet the legal test and entitled the plaintiff to be--
--
    Senator Johnson. Well, but it starts as a lawsuit, correct? 
I mean, is there any middle ground first that it goes to 
arbitration then get kicked up? I mean, what are the steps 
here?
    Mr. Horton. Right, so in the case of the Ending Forced 
Arbitration of Sexual Assault and Sexual Harassment Act, what 
usually happens is, a plaintiff files a complaint in court and 
then the employer moves to compel arbitration, and then there 
is some sort of court hearing in which either the court decides 
whether or not the Ending Forced Arbitration of Sexual Assault 
and Sexual Harassment Act--which I'm just going to call the 
EFAA--applies or not, and that's what happens.
    In these cases, courts are evaluating, are these frivolous 
claims or not? And there are about 200 accessible decisions 
interpreting the EFAA. By my knowledge, a very small number of 
claims have been dismissed as frivolous. Although I completely 
agree that small businesses are a legitimate concern, there 
really is absolutely no evidence that giving workers the right 
to sue in court is producing a flood of claims that are 
unmeritorious or should not be brought in the first place.
    Senator Johnson. Well, again, I'm 70 years old, so I'm one 
of these guys that'd be concerned about being discriminated 
against, but again, employers also have a legitimate concern 
about their own liability. An older worker who's maybe losing 
something in terms of being able to drive. How do you address 
that within this process?
    Mr. Horton. Right. Absolutely. It's a delicate and 
important question. I think what we really need is something 
that we don't have because of forced arbitration, which is a 
sense of how these cases actually play out on the merits. I 
tried to research age discrimination claims in court to prepare 
for this hearing, it was so hard to find any because they're 
all sent to arbitration. I can't tell you whether or not the 
age discrimination laws should be changed or modified. We just 
don't know.
    Senator Johnson. Okay. Fair enough. Thank you, Mr. 
Chairman.
    Senator Kim. Thank you. Thank you all for coming together 
here. Ms. Greszler, something you said that really stuck out to 
me. You were talking about though, labor workforce, and I 
believe you said something to the effect that there are stats 
here that participation rates in the labor workforce of 
individuals aged 55 to 64 increased by 12.8 percent. 
Participation rates for those ages 65 and older increased by 
8.3 percent.
    Is that increasing? Are we going to be seeing that trend 
growing even further as more time passes?
    Ms. Greszler. I think we will continue to see that 
increasing trend there, and a lot of that has to do with both 
the increased health as we've seen improvements in healthcare, 
and also the reduced physical demands of a lot of the jobs that 
we have, and also, deaging the population. Some of it is also 
policy related, but there have been some studies that have 
shown that there is additional work capacity beyond what we've 
already seen. We have seen these positive improvements.
    Senator Kim. Thank you, and Ms. LeaMond, you had something 
in your opening statement that said 54 percent of households 
have no savings, and you know, I think that was of all 
households, but more specifically when it comes to seniors, I 
saw something that AARP put out from a survey last year saying 
that 20 percent of adults aged 50 plus have no retirement 
savings, and more than half, I think it was 61 percent, said 
that they were worried that they don't have enough to be able 
to support them.
    I guess I just want to ask you if there's anything further 
you want to unpack on that, and also is that getting worse as 
well over time?
    Ms. LeaMond. There are additional challenges. People are 
trying to save in many situations, and we find that because of 
caregiving needs in particular, older workers are taking a 
little bit more time out of the workforce. We are concerned 
about that. One reason we're so focused on social security 
obviously is so people have that earned benefit when they 
retire.
    Senator Kim. Yes. I really wanted to just put those two 
stats together because I think it really tells a story of what, 
you know, this Committee and what we here in Congress need to 
focus in on, that we have a rising workforce in terms of an 
aging workforce, but we also have a larger growing level of the 
workforce that feels significant financial insecurity, and, you 
know, my mom and my dad, they retired, but you know, they are 
dependent upon social security for almost all of their income 
right now.
    It causes so much challenge in terms of the decisions that 
are being made, and so that's something that I just really hope 
we hone in on here in this Committee and in Congress to 
address, and Ms. LeaMond, you raised it just in your last 
answer here, about the effects that caregiving can play, you 
know, when it comes to, you know, these issues. I think we're 
seeing this a lot when it comes to combating age discrimination 
challenges when it comes to the growing number of workers who 
are also caregivers need to be able to take some of their time.
    Also recognizing the need for businesses to be able to 
offer benefits and flexibilities that can help with caregiving. 
I guess I wanted to just ask you if you can talk a little bit 
more about the intersection between caregiving and age 
discrimination.
    Ms. LeaMond. Sure. Well, we know there are, based on a 
report we released last week, 63 million family caregivers, and 
60 percent of those are in the workforce. We know this is an 
issue, not just for the caregiver, but for the employer, and we 
hear anecdotally from workers who are caregivers that they're a 
little worried about taking time out of work to say they're 
doing caregiving. They think that that might jeopardize their 
status in the company. We don't have any direct statistics on 
that.
    On the other hand, I mentioned our Employer Pledge Program. 
This is a voluntary program where employers say they are 
committed to leveling the playing field and work with us on 
things they can do, and one of the areas we hear about the most 
from employers right now is, how do I manage the increased 
number of workers I have and not just older workers, workers of 
all ages who are caregivers, part-time family caregivers? How 
do I create a flexible workforce where they can be productive 
at work and also continue to be the backbone of the long-term 
care system in this country?
    I think this is a growing issue, and one we'll continue to 
look at as we encourage more companies to hire older workers, 
and we encourage more older workers to stay in their jobs----
    Senator Kim. Great. Thank you.
    Ms. LeaMond [continuing]. both for their financial support 
and for their good health and for their family.
    Senator Kim. Mr. Chairman, if you don't mind, I'd like to 
ask one more question if that's okay.
    Ms. Carlson, we just heard Mr. Horton talking about sort of 
the economic implications of this, you know, in terms of 
businesses and how, at least from what we've seen so far, we 
haven't seen a deluge of problems that have facing businesses 
when it comes to some of the legislation that we passed 
regarding forced arbitration.
    You got a little bit to this in your opening remarks, but I 
just wanted to offer you another opportunity to delve in a 
little deeper. You know, some of my colleagues have raised 
concerns about whether or not some of these actions that were 
taken of forced arbitration to stopping it would have negative 
impacts on businesses. I, for one, am very compelled by some of 
the responses you've given. I was proud to be able to support 
the efforts to work alongside you to end forced arbitration for 
sexual harassment, sexual assault.
    I wanted to see if there's some further lessons that you've 
learned from that to help us as we're having these discussions 
here on the hill.
    Ms. Carlson. Thank you so much, Senator. I think everything 
we've discussed today with regard to the problems of Americans 
aging longer and be needing to be in the workforce financially, 
the underlying message in all of that is we can improve all of 
those things, everything that's been discussed, but if you keep 
the barrier of forced arbitration, you're still going to have 
the biggest problem, right.
    We talked a lot about removing the barriers today. The 
biggest barrier is the idea that arbitration is being forced on 
these workers. All we're asking for is the choice to make it 
voluntary, and if forced arbitration is so wonderful, why do we 
use the word forced? Right? We're not saying it's voluntary.
    The other thing I would just add is that it ain't fun to 
come forward, and so that's another reason why we haven't seen 
this deluge of cases, and to add to that, what Professor said, 
is that it's very hard to prove these cases at the state level 
or the federal level, and so just offering Americans choice is 
what we're asking for. They may still choose arbitration, but 
they will know that they have the ability to use their seventh 
amendment right.
    Senator Kim. Great. Thank you. Thank you, Ranking Member 
for pushing forward this legislation, and thank you for giving 
us the opportunity to speak here.
    Senator Gillibrand. Thank you. Mr. Horton, I liked that you 
said when you were trying to do your research about this 
hearing, it was very hard to find those cases because they are 
stuck behind the wall of forced arbitration. I think that is a 
huge impact to the legal community, to workers' rights, and 
just to our knowledge base as a committee. I want to ask the 
panel for their examples of what you've seen with age 
discrimination. Sometimes it can be very subtle. Ms. LeaMond 
has noticed, you know, I need a high energy candidate. It's 
just a, you know, cloaked word to say, I don't want somebody 
old. Or you know, in your industry, Ms. Carlson you don't see 
many you know, news anchors that are in their fifties and 
sixties. You see plenty in their twenties and thirties.
    There's a preference for youth in many industries and 
particularly among women, that there's always a joke in 
Hollywood that as soon as you hit 40, you are no longer 
castable because nobody wants to see you. I'd like to hear from 
each of you, what are the examples that you've heard or seen of 
age discrimination? What does it look like?
    When I travel in New York, and I talk to workers, I talk to 
a lot of men who are engineers who say, yes, as soon as they 
hit 50, they were there for a high cost worker. Whereas they 
would try to hire a 25-year-old with the same degree because 
they could pay them half the wage, even though they're 
providing so much value and benefit because of their years of 
experience.
    I really want to hear more about what age discrimination 
looks like and what are the impacts ultimately? Mr. Horton, you 
might have some thoughts on this, on the economy and also on 
the on the jurisprudence. Ms. LeaMond, why don't we start with 
you.
    Ms. LeaMond. Sure. Well, as I mentioned, what we hear the 
most is people are told they're overqualified. Yes, they just 
have too much experience for this job. Even if they are saying, 
"Look, I'm interested in this. I think I can do it. I want to 
be there for it." We also see in the job application process 
some companies that recruit only on college campuses, where the 
likelihood of finding older workers is not as great, obviously.
    Some descriptions talk about no more than five years of 
experience, questions sometimes about different social media 
sites or podcasts in an effort to see how able somebody might 
be with new media. We tend to see all of those kinds of subtle 
comments. Digital native is very common. We hear that all the 
time from folks.
    Then, in preparation for the hearing, I googled cartoons 
ageist discrimination, and it was interesting. There was one 
that said, you know, we really can't say anything too direct, 
but we can put it in really tiny print so an older job 
applicant can't read it, and I think, you know, you kind of get 
a sense of the subtlety jokes about, are you going to retire? 
Are you going to still be able to do this? All of them comprise 
a picture that is discrimination.
    Senator Gillibrand. Yes. Mr. Horton.
    Mr. Horton. Thank you, Senator. As I was preparing for the 
hearing and doing research, I was reminded of the fact that one 
of the most egregious facts in any forced arbitration case that 
I've come across for a long time involved the claim of age 
discrimination, and I would just like to highlight it, if 
that's okay because I think it really shows why forced 
arbitration is a barrier to justice.
    There was a woman who worked, she had a Ph.D. She was a 
doctor, Dr. Anderson, and I believe her employer was called 
Inter Pro. She signed an employment arbitration agreement that 
said that the arbitrator would decide whether or not the case 
should go to arbitration, and she suffered age discrimination 
on the job, and she sued, and so the issue facing the court was 
whether or not to allow the arbitrator to decide whether the 
arbitration should proceed.
    She proved that it would cost $8,000 just to decide the 
issue of whether to arbitrate the merits of her case, and so 
she introduced evidence that showed that she simply could not 
afford access, not to actually try her case, but to try the 
issue of does she have to arbitrate her case, and that really 
made an impression on me because it really highlighted to me 
the fact that there are people with valid age discrimination 
claims who are being blocked by forced arbitration from 
pursuing them.
    Senator Gillibrand. Ms. Carlson.
    Ms. Carlson. I would just dovetail off of the Professor's 
comments that there was a woman in the financial services 
industry in New York City who was telling me about her story. 
Arbitration is supposed to be quicker and cheaper, although the 
company can always outspend the actual individual. She had 
spent $500,000 of her own money and arbitration hadn't even 
started yet.
    Senator Gillibrand. Wow.
    Ms. Carlson. That is another barrier. It's not always true 
that it's cheaper and quicker. The other thing I would just say 
is that of course, age discrimination is rampant in the media 
industry. Men get, you know, salt and pepper hair, and they're 
assessed as being wiser. Women get one wrinkle and they're out, 
but the problem is we're not necessarily hearing about these 
cases, nor are the women getting justice because they're being 
forced into arbitration.
    I think that this once again would bring a fairer system to 
millions of Americans and specifically today about age 
discrimination. I think that one other important note to make 
is that in my unscientific study, of all the women that I've 
spoken to and other workers over the last nine and a half 
years, the vast majority when they're forced into arbitration, 
never work in their chosen profession ever again.
    We can spend all day long talking about the fact that 
people are not hiring older workers. They certainly are not 
hiring them if they've gone through a forced arbitration 
situation because they most likely signed an NDA and then they 
can't explain to their future employer what happened to them at 
their previous job. There's a myriad of problems here, but to 
me, forced arbitration is the evil.
    Senator Gillibrand. Ms. Greszler.
    Ms. Greszler. Thank you. I would just comment that I have 
been fortunate not to experience or to see my peers experience 
age discrimination, but rather the latter, and my employer 
currently has taken a stance to say we really value older 
workers in the workforce because of what they bring, the 
experience and the wisdom that they can share with the younger 
generation has been in increasingly valuable.
    I would love to see more employers actually understand that 
and see what that brings when you can help younger workers in 
sharing things like conscientiousness and just establishing 
good work habits and helping them to build their careers.
    Senator Gillibrand. Thank you. Mr. Chairman.
    Chairman Scott. Thank you. Ms. Greszler, can you go back to 
the comments you made on social security allowing people to, 
you know, not be a cap and still get it? Number one is how 
would that work? Number two, how would it infect the viability 
of social security? We are all worried about, you know, its 
viability in just a few years.
    Ms. Greszler. Yes. The retirement earnings test that I 
described is a misunderstood part of the program. It functions, 
people see it as a 50 percent additional tax on top of their 
federal taxes, their payroll taxes, their state and local 
taxes. As I mentioned, this is like an 84 percent tax on any 
dollar above about $23,000 per year that an older worker earns, 
and this affects people who are between the ages of 62 and 66.
    Actually, the majority of workers do claim benefits early 
in that window of years, and so multiple studies have shown 
that this significantly reduces the willingness to work when 
you have an 84 percent tax on that. People don't realize the 
benefits actually get added back in later on once they reach 
their normal retirement age, but it's perceived as a pure tax, 
and so, it simply reduces work options.
    Just by eliminating that and saying, we're not going to 
take away Social Security benefits, you can continue to claim 
early if you want to and to continue working, and your benefit 
will just stay the same. There won't be that adjustment later 
on, and this would actually improve social security's finances, 
because when people work longer, they're paying more Social 
Security taxes, they're paying all of the additional taxes, 
they're earning income that they get to keep. Across the board, 
this is just a common-sense good policy I see.
    Chairman Scott. Why was this set up this way in the first 
place?
    Ms. Greszler. When Social Security first started in the 
late 1930's depression era program, they wanted older workers 
to get out of the workforce so that they would free up the jobs 
for the younger workers. It wasn't a 50 percent tax, then it 
was 100 percent tax. You could not collect a social security 
check unless you stopped working entirely, and it's been 
modified over the years, but as it stands today, it's like this 
additional 50 percent tax.
    Chairman Scott. Has there ever been a CBO score if you 
changed it?
    Ms. Greszler. I don't know of one, but I estimated an 
additional $18 billion in total tax revenues and an extra eight 
billion in Social Security revenues per year if you were to 
eliminate this.
    Chairman Scott. Ms. Carlson, besides the legislative 
solution, what else do you think employers ought to be doing to 
be respectful of older workers?
    Ms. Carlson. Well, if they want to voluntarily take away 
the word forced from arbitration, then we don't have to pass 
the law, but as I said, there's been an explosion of forced 
arbitration where we now have more than 60 million Americans 
underneath it. In 1991, we had two percent. You know, I believe 
that passing the law is the best way to handle this because it 
simply gives the worker a choice, and just taking out the word 
forced would make all the difference in the world.
    Chairman Scott. Thank you. Mr. Horton, do you think that 
the Protecting Older Americans Act, if it was the law tomorrow, 
does it strike the right balance between the interest of the 
employer and the interest of the employee and making sure that 
everybody's respected?
    Mr. Horton. I do think so, Senator. One of the things that 
I really admire about both the EFAA and the Protecting Older 
Americans Act is the fact that it allows employees to choose. 
They get to choose whether they want to arbitrate, they get to 
choose whether they want to litigate. I think that takes away 
one of the most pernicious parts of forced arbitration, which 
is the fact that it is essentially unilaterally imposed by 
employers on employees.
    Chairman Scott. Right. Thank you.
    Senator Warren. Thank you. Older workers are the fastest 
growing share of the workforce, and one big reason for that is 
because it's gotten a whole lot harder for Americans to retire 
because high costs and low wages squeeze families. Here we are 
in the richest country in the world, where I think workers 
ought to be able to work for fair pay and fair conditions, and 
then retire with security.
    Many workers post-retirement are back in the workforce in 
part-time jobs, and one of the things they encounter there are 
what are called just-in-time scheduling practices. This is when 
employers give workers their schedules at the very last minute, 
sometimes as little as a day or two before their scheduled 
shift, and while that might be just-in-time working for an AI 
algorithm, looking at the latest foot traffic, for example, in 
a grocery store, it is great for the algorithm, but not so 
great for the workers.
    Do you go to the doctor's appointment, you know, or do you 
skip the shift and not get paid? Will you be able to pay your 
electric bill if your shift this week gets canceled? Older 
workers are more likely to be part-time where just-in-time 
scheduling practices are far more common. Ms. LeaMond, you're 
the Chief Advocacy and Engagement Officer at AARP. Why are last 
minute schedule changes particularly difficult for older 
workers?
    Ms. LeaMond. Well, Senator, I think last minute schedule 
changes are difficult for all workers. I will say, I think you 
all know AARP has offices in every state. I oversee a staff of 
700 multi-generational workers, and my experience has been on 
all issues related to flexibility. It is just as much a concern 
of younger workers as it is older workers.
    I would say older workers may be juggling a few more 
caregiving duties and medical appointments. Mothers and fathers 
in their 40's and 50's are the sandwich generation dealing with 
children and those responsibilities along with caregiving, and 
our younger staff, I find are the busiest because many of them 
are in school at night and juggling lots of other duties. I 
think flexibility is something that doesn't just affect older 
workers, but all workers.
    You've raised something important though, which is when 
we've talked a lot about workforce flexibility, it's been 
framed in terms of working at home or working in the office, 
and really what I find most of the discussion to be about is 
not so much that, but work hours. Can it be flexible? Maybe I 
can drop my kids off at school in the morning and then work a 
little later. Can I adjust my hours in some other ways? I think 
employers that are committed to multi-generational workforces 
are beginning to adapt and understand how important flexibility 
is. I think we all benefit from knowing our schedule in 
advance. I was joking with the team that that I think we all 
appreciated being invited last week to testify rather than last 
night, and those are the kinds of things I think we can all 
benefit from.
    Senator Warren. Can you just say a word about what happens 
to workers when last minute work schedule changes, conflict 
with their obligations outside work? I've kind of given my own 
summary, but you're the expert. You're running a staff of 700.
    Ms. LeaMond. Well, when schedules change one of two things 
happen. You will either have to arrange something in your 
personal life often with some cost, or you miss something at 
work, and that depending on your employer, can be a matter for 
discussion or a matter for serious confrontation, and I think 
it really depends, and it's incumbent on all of us, I think, to 
talk much more about what are the labor force needs. We are 
going to have to engage more older workers in jobs across this 
country, and what does that mean also for our multi-
generational workforces?
    Senator Warren. It seems to me that we need some guidance 
around this. As you say, some employers are changing but many 
are not, and so, the question becomes what is the right way? 
What should be the workplace rules? I've got a bill called 
Schedules That Work, and it would give employees just a couple 
of rights. One is the right to request a schedule that works 
for them without getting fired for making the request. I know 
that seems like common sense, but for a lot of people, that's 
not happening for them in the workforce.
    The second thing is to say, if schedules are going to be 
changed at the last minute, then there needs to be some 
compensation for the worker. You can't hold people in effect, 
on call. That is, you are going to come in next Thursday, you 
agree you're coming in next Thursday, you will be there next 
Thursday, and then on Thursday morning you get a call that 
says, don't come in and don't get paid for the day. If you held 
your Thursday open, then there needs to be some compensation in 
return for that.
    I think your point is right, Ms. LeaMond, that it would be 
helpful for workers of all ages, but it is particularly helpful 
for workers who are part-time workers, because they face this 
so much more than full-time workers do, and particularly 
helpful for workers who have obligations outside the workforce.
    I'm going to continue to work on this. I'm going to 
encourage other members of the Aging Committee to take a look 
at it, just to try to get some guidelines in place that will be 
helpful for all of our workers but I think will have a special 
benefit for our older workers. Thank you, Mr. Chairman.
    Chairman Scott. Senator Warren, just as a business person, 
let me just tell you the issue that we're dealing with. I agree 
with you. I mean, we all want to know our schedules, right? I 
mean, but if you think about it from the standpoint of 
employer, here's what goes on. Let's say you take a restaurant. 
Everybody gets their reservations through OpenTable, and you 
find that day that your reservations are down 50 percent, 
right? You say, well, how many people should I have come in? 
You say, well, I don't need as many workers today.
    Is it good for the worker? No, right? If you tell the 
worker to come in, then the employer probably, you know, it 
costs them money, right? Can they keep that restaurant open if 
they did have something?
    I think in almost every industry, what my experience in the 
businesses I was in is, you know, everybody always joked, you 
know, this would be a great job except for the customers. The 
customer dictates all this, and how many people are going to 
show up that day and in so many businesses, not all businesses, 
it's more stable, but there's a lot of them that the revenue 
that you'll get that day is completely dependent on who's going 
to show up.
    Sometimes you, you have a good idea, and sometimes, you 
know, my first business was a donut shop, and I could tell you 
my revenues were 100 percent tied to the weather, but I think 
you got a legitimate point because it's frustrating to somebody 
if they think they're going to get paid and think they're going 
to have not, and they save their time, and then they'd lose 
that income.
    Senator Warren. You know, I would just say in response 
because I appreciate the point you make. The question is not 
the customers. I get it. Customers can come or not come, and 
that's going to change how many workers are needed at any given 
time. The question is, who bears the burden of that risk? And 
the idea that the employer says, "I want you to be available. I 
want you to block out your Thursday no matter what, and don't 
take a class that meets on Thursday, don't agree to take care 
of your grandchildren on Thursday. Pay the caregiver who's 
going to show up and watch your husband who can't be left 
alone." That the employee takes on all of that cost and risk, 
and the employer takes on none of it in many industries.
    I think that's the part we're trying to figure out is who 
is it that should be responsible for that, and I think 
employees need a little more help on their side and some rules 
that give some guidance around that.
    Senator Gillibrand. Thank you all for coming. This was an 
excellent hearing. I think we learned a lot about this issue. I 
really appreciate the time and expertise that you've offered to 
help inform the Senate panel. Thank you so much. Thank you, Mr. 
Chairman.
    Chairman Scott. If any Senators have additional questions 
for the witnesses or statements to be added, the hearing record 
will remain open until next Wednesday at 5:00 p.m. Thanks.
    [Whereupon, at 11:44 a.m., the hearing was adjourned.]  
      
=======================================================================


                                APPENDIX
   
=======================================================================


                      Prepared Witness Statements

=======================================================================
   
                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                      Prepared Witness Statements

                             Nancy LeaMond

    Chair Scott, Ranking Member Gillibrand, and Members of the 
Committee:

    My name is Nancy LeaMond, and I serve as the Executive Vice 
President and Chief Advocacy and Engagement Officer for AARP. I 
am honored to testify on behalf of more than 100 million 
Americans age 50 and older. I have dedicated much of my career 
to ensuring every older American has the opportunity to age 
with dignity and respect. Yet today, far too many hardworking, 
capable, and committed older workers face a barrier that 
undermines both their livelihoods and their families' financial 
well-being: age discrimination.
    I want to begin by saying how much I appreciate Chairman 
Scott, Ranking Member Gillibrand, and the entire committee for 
working in a bipartisan way to put a spotlight on issues 
important to older adults. Hearings like this, as well as 
others you have done, including Senator Scott's recent field 
hearing on fighting fraud, and prior hearings focused on 
fighting isolation, exploitation, disaster preparation, and 
improving the wellness of older Americans, help move us toward 
solutions that will allow all of us to age with dignity. 
Solutions like Senators Gillibrand and Graham's Protecting 
Older Americans Act, which I discuss later in my testimony, 
will give older workers a choice in how they want their age 
discrimination claims resolved. My hope is that today's hearing 
will put us on a path towards ending pernicious age 
discrimination that is holding too many people back from 
fulfilling their dreams and achieving their financial security.
    This hearing is vitally important as the impact of age 
discrimination is not only felt at the personal level - it's 
economically damaging to our country. AARP has found that age 
discrimination drains $850 billion from the U.S. economy every 
year, a figure projected to reach nearly $4 trillion by 2050. 
At a time of labor shortages, sidelining skilled and eager 
workers is a loss we simply cannot afford.
    The effects are profound. An Urban Institute study found 
that about half of workers in their early 50s experience 
involuntary job loss that sharply reduces earnings or forces 
them into long-term unemployment - something older workers face 
at higher rates than younger peers. For example, in July 2025, 
the percentage of jobseekers ages 16 to 54 who were long-term 
unemployed was 23.1 percent, but it was 26.5 percent for 
jobseekers ages 55 and older.
    This comes at a time when many older Americans are working 
later into life than ever before- some by choice, often by 
necessity. According to the Federal Reserve's Survey of 
Consumer Finances, 54 percent of households have no retirement 
savings, and among those who do, the median savings for folks 
age 55 - 64 is $185,000. For those age 65 - 74, it is $200,000. 
That is well below what is needed for a secure retirement - 
even factoring in Social Security - and likely one reason that 
folks 75 and older are the fastest growing segment of the 
workforce.
    Whether for personal fulfilment, financial reasons, or a 
combination of both, older adults deserve a level playing field 
as they compete for, obtain, and retain jobs. Older workers 
are, and will continue to be, the key component to our economic 
success. Unfortunately, it's far too common that age 
discrimination proves to be a pervasive barrier in the 
workplace. That is why holding this hearing is vital.
    According to AARP research, 90 percent of workers age 50-
plus believe that age discrimination is common in the workplace 
today, and 64 percent of older workers have seen or experienced 
age discrimination. These numbers are even higher for Black 
workers (74 percent) and women age 50-plus (67 percent). Age 
discrimination in hiring is also pervasive. Our research tells 
us that 40 percent of job seekers aged 45 and older have 
experienced age discrimination in their job search. In 
addition, 53 percent of workers aged 40 and older were asked by 
an employer to provide their birth date, graduation date(s), or 
other age-related information during the application or 
interview process.
    Sometimes the discrimination is not overt, but cloaked in 
seemingly harmless terms that send a clear signal about who 
employers are really looking for. For example, recruiters might 
use phrases such as "digital native" in their job ads, 
referring to the younger generation of people born into modern 
technological culture, particularly social media. Other 
phrases, such as "high energy level," are used as a euphemism 
for "young," playing off the biased and inaccurate assumption 
that older employees lack energy. An employer also might 
discard applications if the candidates do not have email 
accounts ending in ".edu," which are university accounts 
commonly used by students and recent college grads but are less 
common among older alumni.
    Older workers bring expertise, leadership, perspective, and 
resilience. They have critical skills employers need. Yet 
outdated stereotypes persist, leading to unfair treatment that 
undermines both workers and businesses. Addressing age 
discrimination strengthens not only the financial security of 
individuals but also the health of our communities and economy.

Artificial Intelligence and Older Workers

    Emerging technologies add urgency to the challenges we 
face. Older workers are encountering artificial intelligence 
(AI) in the workplace with both interest and concern. Nearly 
half express a desire to gain AI-related skills, and many 
already use AI tools to improve productivity. According to an 
AARP survey, the top uses of AI include finding information, 
creating content, and analyzing data-functions that can enhance 
productivity and decision-making.
    But it also poses risks. Algorithms can replicate and even 
accelerate bias. Data points such as graduation dates or years 
of experience can serve as proxies for age, leading to older 
applicants being screened out automatically. Policymakers must 
ensure AI is used to expand opportunity, not entrench age 
discrimination, by supporting upskilling programs and enforcing 
protections against algorithmic bias.

Bipartisan Legislative Solutions

    Given the vital role older workers can play in meeting the 
demands of our economy, paired with increasing longevity, it is 
vital that Congress pass policies to ensure every older 
American has the opportunity to obtain and retain employment, 
and this isn't just AARP's view. The vast majority of older 
workers support strengthening age discrimination laws. 
According to a recent AARP survey, 90 percent of workers age 
40-plus support efforts to strengthen the nation's age 
discrimination laws and 89 percent of workers age 40-plus agree 
that older Americans should be protected from age 
discrimination just like they are protected from discrimination 
on the basis of race, sex, national origin, or religion.
    Several bipartisan, commonsense bills would do just that. 
One bill in particular that I noted at the beginning of my 
testimony is the AARP endorsed Protecting Older Americans Act 
(POAA), led by Ranking Member Gillibrand and Senator Graham. 
This bill would prohibit forced arbitration in age 
discrimination claims, ensuring workers can seek justice in 
court with full legal protection. This bill is not only needed, 
but it is just common sense. If we want true change, we must 
not force workers into agreements where their options are 
limited, and their stories are never shared or heard. Instead, 
Congress should pass legislation like the POAA and make sure 
every older American who is sidelined due to age discrimination 
has an opportunity to rectify the situation and have the 
opportunity to work. We applaud Senator Gillibrand, Senator 
Graham and others for their support of these important 
initiatives.
    Other important pieces of legislation that have been 
proposed by leaders of both parties and should be passed by 
this Congress include:
    The Protecting Older Workers Against Discrimination Act 
(POWADA) Led by Senators Baldwin and Grassley, this bill would 
restore long-standing protections weakened by the Supreme 
Court's 2009 Gross decision, ensuring age discrimination is 
treated as seriously as other forms of workplace 
discrimination.

The Protect Older Job Applicants Act (POJA)

     by Representatives Garcia and Salazar, this measure would 
extend ADEA protections to job applicants-closing a gap that 
leaves many vulnerable at the hiring stage.
    AARP also supports efforts to prohibit employers from 
seeking age-related information during hiring, unless required 
by law or directly tied to job performance.

Addressing Age Discrimination in the States

    While AARP is pushing several pieces of federal 
legislation, states across the country are already taking 
action. Recent AARP-backed laws in Oregon, Colorado, 
Connecticut, and other states ban age-related inquiries in 
initial job applications, ensuring older workers are not 
discriminated against early in the hiring process. Other 
efforts include Massachusetts and the U.S. Virgin Islands 
securing funding for older worker retraining programs, and 
Nebraska declaring an Ageism Awareness Month. These efforts 
demonstrate bipartisan recognition that fairness in hiring is 
essential to a strong and thriving economy.

Employers' Role

    Employers also have a critical role to play in combating 
age discrimination. AARP research highlights four key 
priorities:
      Employers can benefit from promoting flexibility in the 
workplace. Many older workers are not settling for stressful 
working conditions or fully in-person jobs. Promoting 
flexibility can help increase productivity as well as job 
satisfaction. According to the National Bureau of Economic 
Research, flexible work arrangements also provide more work 
accessibility for people with disabilities, many of whom are 
older, and have increased their labor force participation rate.
      Employers need to recognize the growing number of 
workers who are also caregivers and embrace ways to mitigate 
burnout. Offering caregiving benefits (e.g., paid leave for 
caregivers) can help workers maintain productivity and help 
employers stay competitive in the marketplace. In addition, 
offering flexible work options can help workers balance work 
and life responsibilities - including caring for themselves and 
their families - ultimately preventing family caregivers from 
leaving the workforce.
      Employers can benefit from placing greater emphasis on 
training to reskill and upskill. Training opportunities can 
help to meet older workers' desires to continue learning, 
helping to enhance their job satisfaction, and given the 
skilled labor shortages, job-related skills training can help 
employers close their skills gap and avoid recruitment costs to 
fill positions.

AARP's Work with Employers

    AARP is working to provide tools and resources that meet 
the needs of the 50-plus wherever they are on their career 
journey, enabling them to embark on new careers, stay 
competitive in their current job, or find work that offers them 
flexibility and fulfillment. This includes resources to help 
older workers searching for a job by providing resume help, 
interview prep, career coaching through our job search toolkit, 
and AARP's Skills Builder for Work resource.
    On the employer side, we are trying to increase economic 
security through expanded access to quality employment 
opportunities. Both the AARP Employer Pledge Program and our 
job search collaboration with Indeed, offer practical resources 
with actionable steps employers can take to build and leverage 
age-inclusive workplaces. Other employers include AARP's Future 
of Skills online resource, Age-Inclusion training for HR 
professionals, our Intergenerational ERG Toolkit, and the Guide 
to Managing Mixed-Age Teams.

Conclusion

    Older workers want a fair shot. They are updating resumes, 
applying for jobs, learning new technologies, and taking 
training to keep their skills sharp. They bring experience, 
commitment, and a growth mindset that employers need - 
especially in today's labor market.
    Every day we hear about job openings going unfilled and the 
impact it has on our economy. At the same time older Americans 
experience age discrimination at alarming rates. This is a 
problem that Congress can and should work to address. Congress 
has an opportunity to act. Passing bipartisan reforms to 
strengthen age discrimination protections, promoting inclusive 
use of AI, and supporting age-diverse workplaces will allow 
older Americans to continue to contribute to, and meet the 
demands of, our economy.
    Thank you for holding this important hearing and for the 
opportunity to testify on behalf of millions of older 
Americans, who play a critical role in helping our economy 
thrive and who ask only for fairness and respect in the 
workplace.

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                      Prepared Witness Statements

                              David Horton

    Thank you Chairman Scott, Ranking Member Gillibrand, and 
Distinguished Members of the Committee for the opportunity to 
speak today.
    My name is David Horton. I hold the Fair Business Practices 
& Investor Advocacy Endowed Chair at UC Davis School of Law. 
One of my areas of focus is forced arbitration. For example, I 
have written papers that analyze outcomes of forced 
arbitrations based on data published by leading arbitration 
providers\1\ and the prevalence and content of forced 
arbitration clauses used by Fortune 500 companies.\2\ Today, we 
heard from Nancy about how age discrimination adversely impacts 
older workers. I will discuss how forced arbitration compounds 
those harms.
---------------------------------------------------------------------------
    \1\ See, e.g., David Horton, Do Arbitrators Follow the Law? 
Evidence From Clause Construction, 126 COLUM. L. REV. FORUM -- 
(forthcoming 2026); Andrea Cann Chandrasekher & David Horton, 
Arbitration Nation: Data from Four Providers, 107 CALIF. L. REV. 1 
(2019); David Horton & Andrea Cann Chandrasekher, Employment 
Arbitration After the Revolution, 65 DEPAUL L. REV. 45 (2016); David 
Horton & Andrea Cann Chandrasekher, After the Revolution: An Empirical 
Study of Consumer Arbitration, 104 GEO. L.J. 57 (2015).
    \2\ See David Horton, Forced Arbitration in the Fortune 500, 109 
MINN. L. REV. 2165 (2025).
---------------------------------------------------------------------------
    At the outset, I should clarify that I believe that 
arbitration can be valuable in certain contexts. For example, 
two businesses in the same industry might prefer to submit a 
dispute to a specialist in their field rather than a generalist 
judge. Similarly, an arbitration provision in a collective 
bargaining agreement between a union and an employer can be a 
fair and efficient way to settle labor grievances.
    However, for two main reasons, I oppose the forced 
arbitration of cases involving pernicious and pervasive 
wrongdoing such as age discrimination. First, although 
arbitration derives its legitimacy from the parties' agreement 
to bypass the court system,\3\ forced arbitration in the 
employment setting is not consensual. Consider the various ways 
in which workers "agree" to arbitrate. Sometimes employers 
place arbitration provisions in their onboarding paperwork. 
Studies confirm what our intuition tells us: workers are 
bombarded with information, their eyes glaze over at the 
legalese, and very few realize that they are surrendering their 
right to access the courts.\4\
---------------------------------------------------------------------------
    \3\ See, e.g., First Options of Chicago, Inc. v. Kaplan, 514 U.S. 
938, 943 (1995) ("arbitration is simply a matter of contract between 
the parties; it is a way to resolve those disputes-but only those 
disputes-that the parties have agreed to submit to arbitration").
    \4\ See, e.g., Zev J. Eigen, The Devil in the Details: The 
Interrelationship Among Citizenship, Rule of Law and Form-Adhesive 
Contracts, 41 CONN. L. REV. 381, 401 (2008) (finding that just 8% of 
sales associates at an electronics dealership understand that they had 
signed a forced arbitration clause when they were hired).
---------------------------------------------------------------------------
    But even workers who read and understand arbitration 
mandates have little meaningful choice. For starters, as one 
court put it: "the arbitration agreement stands between the 
employee and necessary employment, and few employees are in a 
position to refuse a job because of an arbitration 
requirement."\5\ Moreover, declining a position due to forced 
arbitration makes no sense because the odds are that other jobs 
will also be subject to the process. Indeed, forced arbitration 
provisions govern more than half of non-unionized private 
sector workers-a staggering 60,000,000 individuals\6\-and at 
least 53% of the employment contracts used by Fortune 500 
companies.\7\ It would be irrational to say no to an offer 
because of a condition of employment that is becoming 
increasingly unavoidable.
---------------------------------------------------------------------------
    \5\ Armendariz v. Found. Health Psychcare Servs., Inc., 6 P.3d 669, 
690 (Cal. 2000).
    \6\ See Alexander J.S. Colvin, The Growing Use of Mandatory 
Arbitration 1-2, ECON. POL'Y INST. (Sept. 27, 2017).
    \7\ See Horton, supra note 2, at 2208.
---------------------------------------------------------------------------
    Similarly, companies often impose arbitration on people who 
have already been on their payroll for years or even decades. 
Here is an example from a recent age discrimination case: 
Joanne Grace started as a nurse at ValleyCare Health System of 
Ohio in 1976 and worked at a facility that Steward Health Care 
System acquired in 2017.\8\ Steward claims that, in 2019, Grace 
completed an online training that culminated with her 
electronically agreeing to arbitrate (although Grace denies 
this).\9\ A year later, Steward hired a new director of nursing 
who, according to Grace, made inappropriate comments about the 
fact that Grace was in her late sixties, suggested that Grace 
retire, and eventually fired Grace and replaced her with 
someone in their twenties.\10\ In 2023, Grace sued.\11\ A 
federal judge in Ohio enforced the arbitration clause and 
Grace's age discrimination lawsuit, like countless others, 
disappeared into the arbitral forum.\12\ Yet calling Grace's 
acceptance of arbitration "consensual" stretches that word past 
the breaking point. Was she really going to leave her job of 
fifty years over fine print?
---------------------------------------------------------------------------
    \8\ See Grace v. Steward Health Care Sys., LLC, No. 4:23CV2178, 
2024 WL 3992257, at *1 (N.D. Ohio Aug. 29, 2024).
    \9\ See id. at *2.
    \10\ See id.
    \11\ See Complaint for Damages, Grace v. Steward Health Care Sys., 
LLC, No. 4:23CV2178 (N.D. Ohio Nov. 7, 2023).
    \12\ See id. at *3-4.
---------------------------------------------------------------------------
    The second reason employees should not be compelled to 
arbitrate age discrimination claims is that arbitration is less 
hospitable to them than the judicial system. Admittedly, in 
1991, the U.S. Supreme Court held in Gilmer v. Interstate/
Johnson Lane Corp. that workers can effectively prosecute 
alleged violations of the Age Discrimination in Employment Act 
(ADEA) in the arbitral forum.\13\ But arbitration (and what we 
know about the process) has evolved dramatically since then. 
For example, age discrimination often stems from company-wide 
policies which call for class or collective proceedings. When 
the Court decided Gilmer, plaintiffs could pursue aggregate 
relief in arbitration; in fact, the Justices observed that the 
arbitration provider in that case expressly "provide[d] for 
collective proceedings."\14\ Nevertheless, between 2010 and 
2019, the Court decided a rash of cases that held that the mere 
existence of an arbitration agreement functions as a waiver of 
an employee's ability to bring a class or collective 
action.\15\ Today, age discrimination victims can band together 
in the courts but not in arbitration.
---------------------------------------------------------------------------
    \13\ See Gilmer v. Interstate/Johnson Lane Corp., 500 U.S. 20, 30 
(1991).
    \14\ Id. at 32.
    \15\ See, e.g., Lamps Plus, Inc. v. Varela, 587 U.S. 176, 189 
(2019) (interpreting an arbitration clause that does not mention 
whether it allows class actions to bar such procedures).
---------------------------------------------------------------------------
    Forced employment arbitration also suffers from a "repeat 
player" problem. Unlike judges, arbitrators are paid and chosen 
by the parties. This gives them a monetary incentive to rule in 
favor of frequently arbitrating employers that may select or 
veto them in future cases. To be sure, Gilmer "`decline[d] to 
indulge the presumption that the parties and arbitral body 
conducting a proceeding will be unable or unwilling to retain 
competent, conscientious and impartial arbitrators.'"\16\ More 
recently, though, scholars have conducted econometric analyses 
of arbitration results and discovered "strong evidence of a 
repeat player effect."\17\ Some of these studies find that the 
companies that arbitrate the most-"extreme repeat players"-have 
a higher win probability than firms that only arbitrate 
once.\18\ Others determine that there is a "repeat pairing" 
phenomenon in which employers fare better when they arbitrate 
before the same arbitrator more than once.\19\ In 2015, The New 
York Times recounted the story of an arbitrator who "ruled in 
favor of an employee in an age discrimination suit, awarding 
him $1.7 million, and was never hired to hear another 
employment case."\20\
---------------------------------------------------------------------------
    \16\ Id. at 30 (quoting Mitsubishi Motors Corp. v. Soler Chrysler-
Plymouth, Inc., 473 U.S. 614, 634 (1985)).
    \17\ Alexander J. S. Colvin & Mark D. Gough, Individual Employment 
Rights Arbitration in the United States: Actors and Outcomes, 68 INDUS. 
& LAB. REL. REV. 1019, 1026-35 (2015) (reviewing 10,335 cases and 2,802 
awards in AAA employer-promulgated arbitrations between 2003 and 2013).
    \18\ See Chandrasekher & Horton, supra note 1, at 58 (analyzing 
roughly 16,000 forced employment arbitrations from the AAA, JAMS, and 
ADR Services, Inc. and concluding that "arbitration favors repeat-
playing defendants").
    \19\ Colvin & Gough, supra note 17, at 1037; Alexander J.S. Colvin, 
An Empirical Study of Employment Arbitration: Case Outcomes and 
Processes, 8 J. EMPIRICAL LEGAL STUD. 1, 17-17 (2011) (evaluating the 
outcomes of 1,213 AAA forced employment arbitrations between January 1, 
2003 and December 31, 2007 and concluding that the chances of an 
employee win fell by 49% against repeat players and 40% in repeat 
pairings).
    \20\ Jessica Silver-Greenberg & Michael Corkery, In Arbitration, a 
"Privatization of the Justice System", N.Y. TIMES (Nov. 1, 2015), 
https://www.nytimes.com/2015/11/02/business/dealbook/in-arbitration-a-
privatization-of-the-justice-system.html.
---------------------------------------------------------------------------
    Concerns about arbitrator bias are especially pressing 
because of another sea change since Gilmer: the practice of 
arbitrators-not judges-evaluating whether an arbitration clause 
is fair enough to enforce. For decades, courts have used the 
contract doctrine of unconscionability to invalidate 
arbitration provisions that tilt the scales of justice by 
saddling plaintiffs with fees, eliminating certain remedies, 
selecting a distant forum, and shortening the statute of 
limitations.\21\ However, in 2010, the Court decided Rent-A-
Ctr., W., Inc. v. Jackson, which gave its blessing to 
"delegation clauses," which assign questions about whether the 
arbitration should proceed to arbitrators.\22\ More than 80% of 
forced arbitration clauses in the employment contracts of 
Fortune 500 companies contain delegation clauses.\23\ If an 
arbitrator finds that the arbitration clause is unfair, they 
deprive themselves of the ability to preside over the merits of 
the case. As even some arbitrators have admitted, the 
"financial conflict of interest when arbitrators are vested 
with the jurisdiction to determine their own jurisdiction is a 
serious problem."\24\
---------------------------------------------------------------------------
    \21\ See, e.g., David Horton, Unconscionability Wars, 106 NW. U. L. 
REV. 387, 388 (2012).
    \22\ See Rent-A-Ctr., W., Inc. v. Jackson, 561 U.S. 63, 72 (2010).
    \23\ See Horton, supra note 2, at 2241.
    \24\ David Horton, Clause Construction: A Glimpse into Judicial and 
Arbitral Decision-Making, 68 DUKE L.J. 1323, 1374 (2019) Partial Final 
Clause Construction Award at 6 n.1, Schofield v. Delilah's Den. of 
Phila., Inc., Case No. 03-15-0003-4601 (Am. Arb. Ass'n Commercial & 
Class Arbitration Tribunal 2016) (Matthews, Arb.)).
---------------------------------------------------------------------------
    Finally, there is growing evidence that arbitration's 
inherent differences-its lack of class and collective actions, 
risk of biased decision-makers, limited discovery,\25\ and 
privacy and confidentiality\26\-deter plaintiffs from pursuing 
claims. Based on federal and state court filing levels and the 
percentage of employees covered by forced arbitration clauses, 
scholars "expect to see between 320,000 and 727,000 employment 
claims in arbitration" every year.\27\ Yet the American 
Arbitration Association, the leading arbitration provider, 
typically handles a paltry 2,000-3,000 cases stemming from 
forced employment arbitration annually.\28\ Of course, given 
the fact that age discrimination is rampant, many of these 
"missing" lawsuits involve violations of the ADEA or its state 
analogues.\29\
---------------------------------------------------------------------------
    \25\ See, e.g., Martinez v. Master Prot. Corp., 118 Cal. App. 4th 
107, 118, 12 Cal. Rptr. 3d 663, 672 (2004) ("discovery limitations are 
an integral part of the arbitration process").
    \26\ See, e.g., E. Gary Spitko, Arbitration Secrecy, 108 CORNELL L. 
REV. 1729, 1733 (2023).
    \27\ Cynthia Estlund, The Black Hole of Mandatory Arbitration, 96 
N.C.L. Rev. 679, 696 (2018).
    \28\ Id. at 691.
    \29\ See id. at 690; Chandrasekher & Horton, supra note 1, at 32.
---------------------------------------------------------------------------
    For these reasons, the phrase "alternative dispute 
resolution" is a misnomer when applied to the forced 
arbitration of allegations of age discrimination. Arbitration 
is not a true "alternative" because employees have no real 
choice. It is also not "alternative" because it is the norm, 
and it is not "dispute resolution" because it is designed not 
to resolve claims, but to suppress them.
    An elegant way to remedy these issues would be to pass the 
Protecting Older Americans Act.\30\ This bill allows "the 
person alleging conduct constituting an age discrimination 
dispute" the option of invalidating a forced arbitration clause 
or "joint action waiver . . . with respect to a case which is 
filed under Federal, Tribal, or State law and relates to the 
age discrimination dispute."\31\ The Protecting Older Americans 
Act also gives courts, not arbitrators, the exclusive power to 
decide whether its protections apply.\32\ These interventions 
would give workers with age discrimination claims what they 
have been sorely lacking: the freedom to pick a forum in which 
to seek relief.
---------------------------------------------------------------------------
    \30\ See S.1979 - Protecting Older Americans Act of 2023, https://
www.congress.gov/bill/118th-congress/senate-bill/1979.
    \31\ Id.
    \32\ See id.
---------------------------------------------------------------------------
    Thank you again for the opportunity to testify.

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                      Prepared Witness Statements

                            Gretchen Carlson

    Chairman Scott, I don't think I've seen you since I was on 
Fox and Friends and we both tried to wrestle a baby alligator 
at the Villages in Florida. Great to see you. Ranking Member 
Gillibrand, and other distinguished members of the Committee, 
thank you for the opportunity to testify about my experience 
with forced arbitration and the work I've done to make American 
workplaces safer for millions.
    In 2016, I found the courage to sue the most powerful man 
in media, former Fox News Chair and CEO Roger Ailes, for sexual 
harassment. It was the toughest decision of my life, but after 
Fox fired me and tried to take away my career, I said, "If I 
don't do this, who will". My story made headlines around the 
world, but it could have easily been swept under the rug like 
countless others, simply because of a forced arbitration clause 
in my employment contract.
    No one starts a new job expecting something bad to happen 
to them. I know I didn't, and, in the face of a new 
opportunity, few people can walk away from a job because of the 
fine print. I don't care who you are. Most people have no idea 
what forced arbitration means. In my case, it showed up in my 
last contract with Fox, and while I asked questions, I was told 
not to worry because it was quote "becoming the way of the 
world". Eerily, I had no idea at the time how true that was. 
Today, more than 60 million American workers are subject to 
forced arbitration. Most have no idea that signing on the 
dotted line means they've accepted forced arbitration as their 
only remedy for justice.
    So, after my story I started walking the halls of Congress, 
and in 2022, thanks to members of this Committee and other 
champions in Congress from both sides of the aisle - the 
"Ending Forced Arbitration of Sexual Assault and Sexual 
Harassment Act" was signed into law -- one of the proudest 
moments of my life.
    That meant, Kirsten Tiger, a bartender at a prestigious 
country club facing harassment, was able to bring a lawsuit 
against her employer last year, and even though her employer 
tried to silence her by filing a motion to compel arbitration-
the request was denied because of the new law.
    A federal judge in Texas also declined to grant Blaze 
Media's Motion to Dismiss, after one of its employees, Sydney 
Watson, alleged harassment. Watson's case can also continue in 
open court thanks to the new law.
    But there's still more work to do.
    Last year, a wife and mom died of an allergic reaction at a 
Disney restaurant after staff confirmed the food was safe for 
her. Disney tried to force her husband into arbitration because 
he'd previously signed up for a Disney+ account which included 
a forced arbitration clause. Only after enormous public outcry 
did Disney waive the arbitration clause and allow the case to 
proceed in court.
    How about our kids? Parents of a 14-year-old girl in 
California claim she was coerced into sharing graphic images 
with a man she interacted with on Roblox and Discord online. 
Both companies are trying to force the family into secret 
arbitration meaning other families will never know the dangers 
of a predator who had at least 20 other victims.
    Pertinent to why we're here today, Sam Casale was promoted 
seven times as a top sales representative throughout his 24-
year career and despite a better sales record than his younger 
peers, he was suddenly terminated at age 52 for poor sales 
reasons that were false. Due to a forced arbitration clause, he 
had no ability to seek justice in the court system.
    Nurse Joanne Grace rose through the ranks to Director of 
Nursing Services at her company, but when new owners came in, 
older nurses, like herself, started being replaced with younger 
ones and Joanne says she was repeatedly harassed about 
retiring. Joanne says her complaints were dismissed and then 
she was fired and forced into arbitration.
    These personal stories are why I'm a champion of the latest 
bipartisan bill to protect Americans from forced arbitration - 
the Protecting Older Americans Act -introduced today by Ranking 
Member Gillibrand and Senator Graham and also cosponsored by 
the Chair and Ranking Member of the Senate Judiciary Committee, 
Senators Grassley and Durbin.
    Too many peoplee still not getting the freedom of 
choicewhen something bad happens at work.
    If the fine print of forced arbitration severely restricts 
or eliminates any path towards justice and accountability, then 
something must be terribly wrong with our system.[DH1] [GC2]
    For the naysayers out there, we haven't seen what groups 
like the Chamber claimed would happen. They said all hell would 
break loose if you let women file their assault and harassment 
claims in court. There'd be a slew of new cases and companies 
would go out of business, but none of that has happened. 
Instead, we're just cleaning up workplaces and getting rid of a 
few bad apples. I believe the same thing would be true with 
giving workers a choice with forced arbitration and age 
discrimination.
    A close friend said to me after my story at Fox News, 
"Something good is going to come of this Gretchen". At the time 
I couldn't see it, but I'm here today to tell you something 
great has come of this.
    I thank you for holding this hearing and I hope you'll 
agree this is a bill we can all get behind regardless of 
politics. Maybe we can start by agreeing that each of us here 
today are part of the age category we're talking about. Let's 
take this on together. Thank you.

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                      Prepared Witness Statements

                            Rachel Greszler

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]     
       
=======================================================================


                        Questions for the Record

=======================================================================

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                        Questions for the Record

                             Nancy LeaMond

                   Ranking Member Kirsten Gillibrand

    Question:

    In your testimony, you discuss how older workers are 
increasingly affected by emerging technologies, such as AI. On 
the one hand, older workers are interested in learning how to 
use AI. On the other hand, AI algorithms, if implemented 
poorly, can accelerate bias.
    Have any AI developers reached out to AARP about how to 
implement AI in a way that both helps older workers while also 
reducing harm? What are some key points that AARP would like AI 
developers to keep in mind as they work on new AI advances?

    Response:

    AARP has been engaged in high-level, broad conversations 
with AI developers about how to help people understand AI and 
utilize it safely, including at work. However, we have not 
delved into specific implementation details. Several members of 
the AgeTech Collaborative from AARP, which connects startups, 
investors, enterprises, and testbeds to accelerate technology 
solutions that improve people's lives as they age, have been 
building AI products to serve the aging population and 
caregivers supporting them.
    Additionally, we know that older workers are interested in 
learning new skills, including those related to AI. Employers 
have an opportunity to leverage the deep business expertise of 
older employees when integrating AI into existing workflows. We 
have heard from a large IT services firm that what their 
clients tend to need most is the strategic lens on where, when, 
and why to implement AI - rather than the how, which they can 
solve more easily.
    AARP's approach to AI is that policymakers and the private 
sector should harness the potential benefits of AI while 
actively protecting against its potential harms. Some key 
points that AARP would like AI developers to keep in mind as 
they work on new AI advances are:

          AI tools should be fair, reliable, and accurate, 
without disparate impacts on people protected by civil rights 
statutes.
          There should be transparency when an AI tool is 
used, including an explanation about the results.
          A fair and meaningful process should allow 
individuals to challenge adverse outcomes to ensure 
accountability.
          A qualified third party should be required to 
evaluate AI tools used to inform employment decisions for 
reliability, accuracy, and fairness before their deployment and 
routinely thereafter. The results of these evaluations should 
be made public without revealing personal or proprietary 
information.

                        Senator Elizabeth Warren

    Question:

    During his first administration, President Trump proposed 
numerous regulatory changes to the analysis the Social Security 
Administration uses to determine if an individual is eligible 
for disability benefits, including its Medical Vocational 
Guideline "Grids." All of the proposed changes would have made 
it harder for individuals to qualify for disability. Last week, 
President Trump appears to have taken steps to resume these 
efforts to implement these regulatory changes-which advocates 
have dubbed the "mega-reg"-again during his second term.
    On September 4, 2025, the Office of Management and Budget 
announced its plans to publish a rule titled "Improvements to 
the Disability Adjudication Process: Sequential Evaluation 
Process Abstract," which claims to propose "improvements to the 
disability adjudication process to ensure [the] disability 
program remains current and can be more efficiently 
administered." This announcement also states that the rule will 
"include[] proposing policy updates to occupational data 
sources and optimizing their use to serve our customers and 
preserve the trust funds."
    Is AARP concerned with potential regulatory changes to 
Social Security to the disability review process?

    Response:

    The Social Security Disability Insurance (SSDI) and 
Supplemental Security Income (SSI) programs administered by SSA 
provide much-needed lifelines for millions of older Americans 
and those with disabilities who struggle to make ends meet due 
to severe medical impairments and/or a lack of substantial 
resources. In December 2023, nearly 80 percent of SSDI disabled 
workers and 57 percent of SSI recipients were ages 50 and older 
- the ages AARP represents.
    Because these programs are so important to millions of 
older Americans, SSA should therefore take great care and err 
on the side of caution when making significant changes to them. 
We will carefully review any proposed regulation or other 
change when it is released.

    Question:

    If so, are there any specific regulatory changes that you 
are tracking, and which changes are you finding to be most 
concerning?

    Response:

    Given how important Social Security and SSI are to millions 
of older adults, we track all of SSA's regulatory proposals - 
including those listed in the Spring 2025 Unified Agenda\1\ - 
in order to evaluate their potential effects on older adults. 
We would be particularly concerned if any change would have the 
effect of unduly limiting benefit eligibility or customer 
service options available for older adults.
---------------------------------------------------------------------------
    \1\ Social Security Administration, "Spring 2025 Unified Agenda of 
Regulatory and Deregulatory Actions," September 2025. Available at 
https://www.reginfo.gov/public/do/eAgendaMain.

---------------------------------------------------------------------------
    Question:

    Have any of your members, or groups of older Americans that 
you serve, raised concern over the impacts of such regulatory 
changes?

    Response:

    At the moment, our members have contacted us predominantly 
about general customer service issues, and we have not seen any 
outreach about specific regulations.

    Question:

    If so, what changes are these groups most concerned with, 
and are there any changes that these groups would be interested 
in further exploring?

    Response:

    As noted above, we will carefully review any new regulatory 
changes from SSA, and we would be particularly concerned if any 
change would have the effect of limiting benefit eligibility or 
customer service options available for older adults.

    Question:

    Does AARP have any analysis or data on how changes to the 
"Grids" could impact its members?

    Response:

    A recent analysis by the Urban Institute analyzed how SSA's 
forthcoming proposed rule on "Improvements to the Disability 
Adjudication Process: Sequential Evaluation Process" could 
affect older workers, among others.\2\ The Urban paper found 
that changes to the grids, along with switching from the 
Dictionary of Occupational Titles to the Occupational 
Requirements Survey, could have adverse impacts on the number 
of disability beneficiaries - reducing eligibility for new SSDI 
applicants by up to 20 percent, and by up to 30 percent among 
older workers.
---------------------------------------------------------------------------
    \2\ Jack Smalligan, "Updating Social Security Disability Regulatory 
Changes Could Significantly Reduce Eligibility for Benefits, 
Particularly among Older Workers," Urban Institute, September 2025. 
https://www.urban.org/sites/default/files/2025-09/Updating-Social-
Security-Disability.pdf.
---------------------------------------------------------------------------
    Question:

    Many advocates agree that the Grids are due for an update, 
but disagree with the Trump administration's historic approach 
to these updates-which amount to a benefit cut.
    How, if at all, would you recommend the "Grids" be updated 
to more accurately reflect the state of the economy and 
workforce?

    Response:

    We believe that any changes to the disability determination 
process should take into consideration how such changes would 
affect older workers with disabilities. The changes should also 
be based on clear justifications and sound, publicly available 
evidence.

    Question:

    I am also concerned that the Trump Administration will 
attempt to reduce or eliminate thousands of Supplemental 
Security Income (SSI) beneficiaries-which includes over 7.4 
million low-income Americans and dependents who rely on them-by 
limiting the definition of a "public assistance household." 
Currently, an SSI recipient's benefits can be reduced by up to 
one-third if they receive in-kind assistance-such as food or 
housing-from another member of their household-including family 
members or roommates. However, if other members of the 
household also receive public assistance-which historically 
included SSI, Temporary Assistance for Needy Families (TANF), 
and General Assistance (GA)-the household is deemed a "public 
assistance household," and the SSI recipient is exempt from 
these benefit reductions. This exemption was based on the idea 
that such households have "limited means and cannot provide 
significant financial support to SSI beneficiaries." In 2024, 
the Biden Administration expanded the number of households that 
qualify as "public assistance households" by: (1) adding SNAP 
to the list of qualifying programs; and (2) requiring only one 
other household member to receive public assistance. According 
to Center on Budget and Policy Priority estimates, reversing 
the Biden Administration policy would cause 100,000 recipients 
to lose SSI eligibility altogether and 275,000 more to face 
benefit reductions. According to disability advocates, this 
change would "hit low-income, multigenerational households the 
hardest."
    How would this change impact AARP members and the broader 
population of older Americans?

    Response:

    We do not have research on how this change would 
specifically impact AARP members or older Americans. However, 
as noted, one estimate found that "removing SNAP as a 
qualifying form of public assistance would likely result in 
benefit cuts for over 275,000 people and loss of eligibility 
for over 100,000 more."\3\ Given that 57 percent of SSI 
recipients are ages 50 or older, it is likely that many of 
these older adults would be among the recipients affected by 
such a change.
---------------------------------------------------------------------------
    \3\ Kathleen Romig and Devin O'Connor, "Trump Administration Poised 
to Cut SSI Benefits for Nearly 400,000 Low-Income Disabled and Older 
People," Center on Budget and Policy Priorities, August 2025. https://
www.cbpp.org/research/social-security/trump-administration-poised-to-
cut-ssi-benefits-for-nearly-400000-low.

---------------------------------------------------------------------------
    Questions:

    What populations of older Americans' will be most impacted 
by this proposed rule?

    Response:

    We do not have specific analysis of the populations most 
affected by this proposed rule. However, we note that the ISM 
rules can create financial hardship for caregivers. For 
example, SSI benefits may be reduced by one-third if a 
beneficiary lives in another person's household and does not 
pay for their shelter, because such assistance is considered 
in-kind support and maintenance.

    Question:

    How would the elimination of or reduction in an 
individual's SSI impact your members and the broader population 
of older Americans?

    Response:

    SSI payments are a critical safety net for older Americans 
who have limited income and resources. More than half - 57 
percent - of SSI recipients are ages 50 and older, the 
population that AARP represents, including 32 percent who are 
ages 65 and older.
    The maximum and average SSI payments ($967 and $718, 
respectively) are already below the poverty level, and any 
reduction or elimination of SSI payments could pose financial 
hardships for older adults who are affected.

    Question:

    What would this change mean for SSI beneficiaries who 
receive other forms of public assistance benefits, given that 
SSI recipients in some states are automatically enrolled into 
Medicaid?

    Response:

    Access to health care is critically important for all older 
adults, and especially those receiving SSI, many of whom have 
significant disabilities or health conditions. In most cases, 
SSI eligibility automatically confers Medicaid eligibility - 
meaning that any loss of SSI eligibility could mean a loss of 
health care coverage.

    Question:

    How do you anticipate this change to impact an individual's 
ability or willingness to provide support for an SSI recipient 
in their household?

    Response:

    SSI's ISM rules can create a financial burden for 
caregivers. For example, SSI benefits may be reduced by one-
third if a beneficiary lives in another person's household and 
does not pay for their shelter, because such assistance is 
considered in-kind support and maintenance. Any changes that 
apply the ISM rules to more people could serve to 
disincentivize SSI recipients, including older adults, from 
sharing a household with others in order to either provide or 
receive caregiving.

    Question:

    Do you anticipate this change to discourage household 
members from providing care for an SSI beneficiary in their 
household?

    Response:

    As noted above, a change like this could serve to 
disincentivize older SSI recipients from sharing a household 
with others in order to either provide or receive care.

    Question:

    Another concern is whether the Trump Administration will 
abide by the typical formal rule proposal process-including the 
90-day window for public comment-or invoke the "good cause" 
exception under the Administrative Procedure Act (APA) to 
shorten this window, effectively bypassing public comment.
    How do organizations like AARP-as well as the populations 
the organization serves-utilize public comment periods?

    Response:

    AARP, which advocates for the more than 100 million 
Americans aged 50 and over, frequently submits public comments 
on proposed regulations that would affect older Americans. For 
instance, in recent years we have submitted comments on SSA 
regulatory proposals such as a proposed rule on Payroll 
Information Exchange (PIE) data exchange and a proposed rule to 
omit food from SSI's In-Kind Support and Maintenance (ISM) 
calculations. Public comment periods allow us to share the 
unique perspectives, needs, and concerns of older Americans, so 
that policymakers can consider these perspectives as they 
evaluate potential regulatory and other changes. We appreciate 
these opportunities to help inform policies and regulations 
that will better serve Americans aged 50 and older.

    Question:

    Why is preserving the entire 90-day public comment period 
critical for groups like AARP to express their reactions 
towards federal rules and large-scale regulatory changes?

    Response:

    While public comment periods are open, AARP and many other 
organizations have a valuable window of opportunity to directly 
inform regulatory policies. We rely on these comment periods in 
order to effectively advocate for the more than 100 million 
Americans aged 50 and over. These are valuable opportunities 
because they allow us to share the unique perspectives, needs, 
and concerns of older Americans as a direct part of the 
policymaking process. It takes time to assess proposals, listen 
to the concerns of our members, and translate them into 
detailed regulatory comments, so we often use the full comment 
windows that are available.

    Question:

    What would bypassing the typical public comment period for 
this mega-reg mean for groups like AARP and older Americans?

    Response:

    As noted in the prior two answers, public comment periods 
are critical to AARP's ability to help shape policies and 
regulations that will better serve Americans aged 50 and older. 
We appreciate the opportunity during comment periods to share 
the unique perspectives, needs, and concerns of older 
Americans, so that policymakers can consider these perspectives 
as they evaluate potential regulatory and other changes. Our 
ability to comment is particularly important for any potential 
changes that would primarily affect older workers, as the so-
called "mega-reg" is expected to do.

    Question:

    Changes to Social Security regulations could also increase 
the greater administrative burden placed on Social Security 
recipients by requiring additional paperwork and 
authorizations. These leave recipients vulnerable to disrupted 
benefits and improper payments. Increased paperwork and 
administrative costs are also burdensome for Social Security 
Agency (SSA) staff, who are already facing a myriad of issues 
at the agency-including unprecedented staff layoffs. As SSA 
faces an uptick in claims, their staffing and customer service 
crises continue to worsen, which "threatens access to crucial 
benefits," especially for older Americans and people with 
disabilities.
    How is the staffing crisis at SSA-including staff layoffs, 
involuntary reassignments, and increased reliance on automation 
instead of live representatives-and the agency's lack of 
transparency around this crisis impacting older Americans?

    Response:

    Older Americans need to be able to get timely and accurate 
customer service from SSA, whether they are applying for 
benefits for the first time or updating their information in 
order to continue receiving benefits. AARP has consistently 
advocated for increased SSA funding to improve customer 
service. Without additional resources and staffing, SSA's 
customer service is likely to deteriorate further.

    Question:

    Are your members-and the broader population of older 
Americans-concerned that this crisis will disrupt their Social 
Security benefits?

    Response:

    Our members continue to be concerned about customer service 
at SSA, including long wait times by phone or to get an 
appointment, and not always receiving accurate information. 
AARP has worked for years to improve SSA's customer service. 
After a lifetime of hard work and paying into the program, 
older Americans deserve a level of customer service that 
provides them with timely, accurate and accessible information.

    Question:

    Have your members-and the broader population of older 
Americans-experienced delays in their benefits as a result of 
the agency's degrading customer service and staffing levels?

    Response:

    We hear frequently from AARP members who call us for help 
navigating SSA's systems. Largely, we hear about frustrations 
with phone times, delays in getting an appointment, and delays 
in disability decisions. Two examples from recent months 
illustrate the kinds of anecdotes we have heard for several 
years:
          In June, a caller said: "I do not know what is going 
on, I'm calling you [AARP] because I am eligible for a 
retirement benefit, and I got a letter from the Social 
Security, but I have been leaving messages, at least two 
already, and I have not got a call back."
          In August, a client at AARP's Legal Counsel for the 
Elderly (LCE)\4\ had a scheduled phone appointment with an SSA 
field office in Washington, D.C., to get his SSI restored. SSA 
never called during or after the appointment time.
---------------------------------------------------------------------------
    \4\ or more than 40 years, AARP's Legal Counsel for the Elderly 
(LCE) has championed the dignity and rights of Washington, D.C., 
seniors by providing free legal and social work services to empower, 
defend and protect those in need. LCE's staff attorneys and volunteers 
assist more than 6,000 seniors each year, including many who seek help 
navigating the complex processes underlying the SSDI and SSI programs.
---------------------------------------------------------------------------
    SSA's customer service also affects older adults' ability 
to access Medicare, because SSA handles Medicare enrollments on 
behalf of CMS. For example, we have heard that it takes much 
longer to get an appointment with SSA to enroll in Medicare, in 
cases where the person cannot or prefers not to apply online.
    AARP has consistently advocated for increased SSA funding 
to improve customer service. Without additional resources and 
staffing, SSA's customer service is likely to deteriorate 
further.

    Question:

    Why is overreliance on automation instead of live customer 
service representatives especially harmful for older Americans 
and people with disabilities?

    Response:

    Being able to access services and benefits by phone, in a 
way that is not overly burdensome, is critically important for 
the millions of hard-working and retired Americans who have 
earned their Social Security.
    When used responsibly, technology can often be a useful 
tool for improving operational efficiency and innovation. At 
the same time, it is critical that older Americans have the 
ability to reach a human at SSA for assistance if they so 
choose.
    There are many reasons older Americans - including 
retirees, people with disabilities, and others - need to speak 
with a live SSA customer service agent. Often the questions 
that they need answers to are complicated enough and specific 
enough that they require live assistance. Callers also need to 
be able to trust that the information they receive from SSA is 
accurate and complete.

    Question:

    How do staff reassignments and potential further staff cuts 
impact your members'-and the broader population of older 
Americans'-benefits?

    Response:

    Adequate funding and staffing are critical to SSA's ability 
to provide timely and accurate customer service to older 
Americans. As a result, AARP has consistently advocated for 
increased SSA funding to improve customer service. Without 
additional resources and staffing, SSA's customer service is 
likely to deteriorate further.
    After a lifetime of hard work and paying into the program, 
older Americans deserve a level of customer service that 
provides them with prompt access to their earned benefits and 
with timely, accurate and accessible information. That is 
difficult to accomplish without adequate and appropriate 
staffing.

    Question:

    Why are increased administrative burdens-such as more 
paperwork for beneficiaries to complete in order to maintain 
their benefits-especially harmful for older Americans and 
people with disabilities?

    Response:

    It is critical that older adults who rely on SSDI and SSI 
be able to access and maintain their benefits without 
needlessly complex processes. Currently, SSDI and SSI 
beneficiaries face many processes - to apply for and maintain 
their benefits - that are complex, costly and difficult to 
navigate, especially for those with reduced capacities due to 
physical, intellectual or mental health disabilities.

    Question:

    How would the increased paperwork and administrative costs 
brought about by this potential mega-reg impact your members'-
and the broader population of older Americans'-benefits, 
especially given "the continuous degradation" of staffing and 
customer service at SSA?

    Response:

    Because older adults with disabilities already face such 
complex processes to apply for and maintain benefits, we 
believe that SSA should take particular care that any proposed 
changes be evidence-based and carefully evaluated in order to 
avoid placing unnecessary burdens on vulnerable Americans. We 
will carefully review any proposed changes as they are 
released.

                        Senator Raphael Warnock

    Question:

    Georgia's aging workforce is facing rising inflation rates, 
leading these workers to make challenging decisions about 
whether to buy groceries or pay for medical needs.
    How can Congress help ensure our aging population is 
equipped with the necessary tools to succeed in their daily 
lives?

    Response:

    Congress can play a vital role by reauthorizing and 
modernizing the Older Americans Act (OAA). This legislation is 
crucial for expanding access to essential services such as 
nutrition programs, job assistance, transportation, caregiver 
support, and home-based care. By strengthening these 
provisions, Congress ensures that older adults receive the 
assistance they need to maintain their independence and quality 
of life.
    In addition, Congress can assist by expanding Long-Term 
Services and Supports (LTSS). Increasing access to home- and 
community-based services allows older adults to age in place 
rather than being forced into institutional care. To meet the 
growing demand, it is important to fund training programs that 
grow the caregiving workforce and improve the quality of care 
available to older adults. This investment helps address both 
current and future needs, creating a more robust support system 
for aging Americans.
    Another critical area is supporting family caregivers. 
Congress can pass legislation offering caregiver tax credits or 
ensuring paid leave to family members who provide care. These 
measures recognize the invaluable role that family caregivers 
play and help alleviate some of the financial and emotional 
burdens they face.
    Lastly, reauthorizing the Workforce Innovation and 
Opportunity Act (WIOA) is essential. This act supports 
workforce development and job training programs, which can 
include training opportunities for older workers. Reauthorizing 
WIOA will ensure older workers have access to the skills and 
resources needed to stay connected to the workforce.

    Question:

    A report from the U.S. Equal Employment Opportunity 
Commission's on the Age Discrimination in Employment Act of 
1967 describes how courts interpret age discrimination 
differently from other forms of discrimination.
    With rapid advancements in technology and artificial 
intelligence, are there gaps in laws like the Age 
Discrimination in Employment Act, and if so, how can Congress 
bolster these federal protections to protect aging workers?

    Response:

    There are notable gaps in the Age Discrimination in 
Employment Act (ADEA), and Congress has introduced several 
bipartisan bills aimed at addressing these gaps. For instance, 
AARP supports the Protecting Older Workers Against 
Discrimination Act, which seeks to restore the long-standing 
mixed-motives standard of proof that was removed from the ADEA 
by the Supreme Court's 2009 Gross decision. The Gross decision 
made it harder for older workers to establish unlawful 
discrimination under the ADEA. This change would simply make 
the ADEA's proof standard the same as other civil rights laws. 
Additionally, the Protect Older Job Applicants Act would extend 
ADEA protections to job applicants, again like other civil 
rights laws, closing a critical gap that currently leaves many 
vulnerable during the hiring process.
    Algorithms used in hiring can unintentionally replicate-and 
even amplify-bias. Data points like graduation dates or years 
of experience often act as proxies for age, causing older 
applicants to be screened out automatically when AI-driven 
tools are used in hiring and employment decisions. While the 
ADEA prohibits discrimination against workers based on age, it 
does not prevent employers from asking job applicants their 
age. Given the widespread use of online job applications and 
algorithmic screening, it is crucial to eliminate age-related 
questions from these applications.
    Recognizing this, seven states-Connecticut, Colorado, 
Delaware, Oregon, California, Pennsylvania, and Minnesota-have 
enacted laws or regulations banning employers from asking about 
age, birth date, or graduation dates on job applications, 
except where a minimum age is legally required for the job 
(such as serving alcohol). Efforts are underway to introduce 
similar legislation at the federal level, aiming to eradicate 
age discrimination during the hiring process altogether.
=======================================================================


                       Statements for the Record

=======================================================================

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                       Statements for the Record

               American Association for Justice Statement

    Dear Chairman Scot and Ranking Member Gillibrand:

    The American Association for Justice (AAJ) submits these 
comments for the record to the Senate Special Committee on 
Aging on the hearing held on September 3rd, 2025, entitled 
"Protecting Older Americans: Leveling the Playing Field for 
Older Workers". AAJ is grateful to the Chairman and Ranking 
Member for holding this important hearing on the prevalence of 
age discrimination in the workforce and the impact that forced 
arbitration has on American's ability to hold bad actors 
accountable when such discrimination occurs.
    AAJ, the world's largest trial bar with members in the 
U.S., Canada, and abroad, was established to strengthen the 
civil justice system, promote injury prevention, and safeguard 
victims' rights. However, since the early 2000's, corporations, 
banks, and employers have been quietly stripping away 
Constitutional and statutory rights from Americans, including 
workers facing age discrimination, through the use of a 
phenomenon that allows bad actors to break state and federal 
laws and escape all public accountability: forced arbitration. 
In 2022 Congress passed on an overwhelmingly bipartisan basis, 
the Ending Forced Arbitration of Sexual Assault and Sexual 
Harassment Act, which gives survivors of sexual assault or 
harassment the choice to bring their case to court should they 
wish to. Paradoxically, if an older American is sexually 
assaulted or harassed in the workplace, they have the right to 
choose whether to take their case to arbitration or court, but 
if that same person is discriminated against in the workplace 
based on their age, or they suffer from negligent care or abuse 
in a nursing home, they do not have the same rights to decide 
how to pursue justice and accountability. Congress now has an 
opportunity to also protect older Americans from the perils of 
forced arbitration. AAJ submits these comments for the record 
to highlight the role that forced arbitration plays in harming 
older Americans, including by contributing to the prevalence of 
age discrimination.

I. The Perils of Forced Arbitration

    Forced arbitration is a secretive and rigged process 
designed to insulate corporations from accountability for 
wrongdoing, by silencing Americans by taking away their right 
to hold corporations publicly accountable in a court of law. 
Forced arbitration lacks many of the procedural rights that 
would otherwise be available to an individual in court, such as 
the right to seek information through discovery that is 
necessary to prove a case, or the right to appeal a decision. 
Arbitrators are not bound by judicial precedent or any set of 
laws and in fact arbitrators do not even have to be attorneys.
    Forcing Americans into arbitration denies them the ability 
to access America's civil justice system when seeking to 
enforce the rights Congress granted them. The Seventh Amendment 
of the United States Constitution provides that "the right of 
trial by jury shall be preserved."\1\ Forced arbitration 
deprives every American of this Seventh Amendment right and 
forecloses any meaningful opportunity to hold bad actors 
accountable for any violation of the law.
---------------------------------------------------------------------------
    \1\ U.S. Const. amend. VII.
---------------------------------------------------------------------------
    The secretive nature of forced arbitration allows the 
perpetuation of injustice by protecting corporations from 
public scrutiny as arbitrators decide cases behind closed 
doors. The civil justice system has a long history of exposing 
injustices, bringing public awareness, and encouraging 
corporations and entities to follow the law and treat people 
fairly and safely. In contrast, the confidentiality of forced 
arbitration helps keep fraud, abuse, and serious civil rights 
violations secret. It is precisely because of these injustices 
that in 2022 Congress passed on an overwhelmingly bipartisan 
basis, the Ending Forced Arbitration of Sexual Assault and 
Sexual Harassment Act, which gives survivors of sexual assault 
or harassment the choice to bring their claims to the courts 
should they wish to. Congress now has an opportunity to also 
protect older Americans from the perils of forced arbitration.

II. Forced Arbitration Reaches Older Americans in Every Aspect 
of their Lives

    Because of the pervasiveness of forced arbitration clauses 
within employment and consumer contracts, forced arbitration 
impacts older Americans in all areas of their life, by 
stripping them of their ability to access the courts whenever 
their rights are violated. Whether they become a victim of 
financial fraud, age discrimination, or suffer abuse or neglect 
in a nursing home, or otherwise have their rights violated, 
forced arbitration denies older Americans of their ability to 
obtain justice in a court of law.

      a. Forced Arbitration Allows Age Discrimination to 
Perpetuate

    Age discrimination in the workplace is not merely a mater 
of interpersonal bias; it is a systemic failure of corporate 
society. Older American workers are regularly excluded from 
professional opportunities, not because they aren't capable, 
but because of the implicit and explicit bias that exists in 
corporate America in favoring young workers. In fact, age 
discrimination impacts nearly two out of every three American 
workers ages 45 and older.\2\
---------------------------------------------------------------------------
    \2\ Kenneth Terrell, Age Discrimination Common in Workplace, Survey 
Says, AARP, Aug. 2, 2018, https://www.aarp.org/work/agediscrimination/
common-at-work/.
---------------------------------------------------------------------------
    Employers often condition getting or keeping a job on an 
individual's "agreement" to be subject to forced arbitration. 
In fact, over 60 million Americans in the private sector are 
subject to a forced arbitration clause in their employment 
contracts\3\. The result is that American workers experiencing 
age discrimination, or other illegal conduct, are being 
funneled into a secretive, one-sided process where the worker 
holds little chance of achieving justice or bringing an end to 
widespread and systemic age discrimination. Forced arbitration 
denies American workers the right to decide for themselves 
whether and how to hold accountable those who illegally 
discriminate against older Americans. Take, for example, the 
following examples of Americans who experienced age 
discrimination:
---------------------------------------------------------------------------
    \3\ Colvin, Alexander J. S. The Growing Use of Mandatory 
Arbitration: Access to the Courts Is Now Barred for More than 60 
Million American Workers. Economic Policy Institute, 6 Apr. 2018, 
htps://www.epi.org/publica.on/the-growing-use-of-mandatory-arbitra.on-
access-to-the-courts-is-now-barred-for-more-than-60-million-american-
workers/
---------------------------------------------------------------------------
    Joanne Grace, a nurse who testified before the Senate 
Committee on the Judiciary in 2024, worked for ValleyCare 
Health System of Ohio before it was acquired by a private 
equity firm and became the Steward Health Care System. Over the 
course of her nursing career, Joanne rose through the ranks 
from floor nurse to Director of Nursing Services. In 2017, 
after her hospital was acquired by Steward Health System, she 
was met with a hostile work environment. In August of 2020, 
Joanne's newly hired supervisor entered the picture and began 
culling older nurses and replacing them with substantially 
younger ones. Afterwards she was constantly harassed weekly 
about her retirement plans. This peaked in December 2021, when 
Joanne's supervisor insinuated that 2022 would be "a great year 
to retire." When Joanne flagged these age-based comments, her 
complaints were dismissed, and when she needed to take time off 
due to contracting covid, her employer began searching for 
Joanne's replacement while she was out on FMLA leave. She was 
terminated approximately five days after returning from her 
sick leave. Her supervisor continued to push Joanne's case into 
arbitration despite no evidence of a signed arbitration clause, 
leaving Joanne having to spend significant time and resources 
fighting forced arbitration, just for an opportunity to hold 
Steward and her supervisor accountable for illegal age 
discrimination.\4\
---------------------------------------------------------------------------
    \4\ Complaint, Grace v. Steward Health Care System, LCC et al., 
(N.D. Ohio Nov. 7, 2023).
---------------------------------------------------------------------------
    Sam Casale was a top sales representative throughout his 
24-year career, getting promoted seven times, winning multiple 
sales awards, and managing a $60 million+ portfolio. He 
consistently exceeded all performance benchmarks and became the 
only non-executive employee to receive a $100,000 stock award 
for outstanding performance. Despite an excellent track record 
and better sales than similarly situated younger peers, Sam was 
suddenly terminated at age 52 for false pretextual reasons of 
poor sales compared to his peers. Had he been able to stay 
until age 55, Sam would have been considered a "Legacy Nalco" 
employee, entitling him to significantly more retirement 
benefits. Nalco seems to have a history of illegally 
eliminating workers aged 50 and older through "Project Blue 
Wave." This company initiative targets older employees for 
termination, as they have higher salaries and long-term 
incentives starting at age 55. Due to a forced arbitration 
clause, which he does not even remember agreeing to, Sam has no 
ability to seek justice or legal accountability through the 
court system.\5\
---------------------------------------------------------------------------
    \5\ Casale v. Ecolab Inc., No. 2:21-CV-00126-NT, 2022 WL 1910126 
(D. Me. June 3, 2022).
---------------------------------------------------------------------------
    These stories contrast with cases where workers were able 
to seek justice through the courts. For example, in March 2024, 
a federal judge approved a $18 million class action settlement 
that resolved an age discrimination case against HP Inc. 
(formerly Hewlet-Packard Company) where older workers - those 
aged 40 and older - were allegedly systematically discriminated 
against as part of a workforce reduction plan, with the intent 
of firing the older employees and filling those vacancies with 
younger employees. According to the complaint, the company shed 
thousands of older workers, while aggressively recruiting and 
hiring younger employees to replace them, implementing a 
company-wide policy that required 75% of new hires to be recent 
college graduates or `early career' employees. This settlement, 
where each employee received approximately $50,000 due to the 
alleged discriminatory conduct, shows how access to our courts 
can provide meaningful accountability.\6\
---------------------------------------------------------------------------
    \6\ Notice of Age-Discrimination Collective Action Against HP Inc. 
& Hewlett Packard Enterprise Company. Andrus Anderson LLP, 3 Nov 2021, 
htps://andrusanderson.com/judge-approves-18-million-setlement-in-hp-
age-discrimination-case/
---------------------------------------------------------------------------
    Forced arbitration hides the pattern, practices and true 
extent of age discrimination in the workplace from the public. 
Congress passed laws to protect Americans from age 
discrimination, and yet, forced arbitration makes it almost 
impossible to enforce these laws. As American workers continue 
to age, we cannot allow a community of experienced workers to 
be marginalized, discriminated against and then silenced when 
they attempt to vindicate their rights but are instead forced 
into arbitration.

      b. Nursing Home Residents Suffer Immensely from Forced 
Arbitration

    Forced arbitration clauses are widely used by the nursing 
home industry as a form of corporate immunity for injuries and 
deaths related to negligent care of older Americans. Nursing 
home residents and their families unknowingly sign away their 
Seventh Amendment rights when forced arbitration clauses are 
buried inside the facilities' admission papers. Because forced 
arbitration clauses are generally offered on a "take it or 
leave it basis", individuals and families often feel they have 
no choice but to sign the clause and often have little actual 
choice of nursing facilities due to their geographic location, 
specific needs, or the necessity of immediate placement when 
facing imminent hospital discharge. The sheer prevalence of 
forced arbitration clauses in nursing home contracts means 
American families have essentially no choice in giving up their 
right to seek justice when their loved one is hurt or worse, 
killed.
    Take for example, the 2016 case of Bonnie Walker, who was a 
resident in an assisted living facility in Charleston, South 
Carolina. Bonnie had a history of wandering and sleepwalking 
and as a result, required constant monitoring and supervision. 
Yet one evening around 12:15 am, Bonnie managed to wander off 
the Brookdale facility, with no staff realizing she was even 
missing until 7:15 am the following morning. The facility 
informed her granddaughter about Bonnie's disappearance, and in 
fact it was Bonnie's granddaughter who eventually discovered 
her grandmother's remains floating in the pond behind the 
facility - remains, which had been dismembered by an alligator. 
Instead of immediately being able to hold Brookdale accountable 
in court for their negligence in caring for Bonnie, Bonnie's 
family spent the next three years, from 2017 to 2020, fighting 
the facility's attempts to force them into arbitration.

III. The Solution: The Protecting Older Americans Act (S. 2703, 
H.R. 5115)

    Because of a spate of recent Supreme Court decisions6 
interpreting a 1924 law, the Federal Arbitration Act, only 
Congress can end the practice of forcing individuals who have 
experienced age discrimination into forced arbitration, and it 
can do so for older American workers by enacting the Protecting 
Older Americans Act of 2025 (S. 2703, H.R. 5115).
    The bipartisan Protecting Older Americans Act, introduced 
by Senators Gillibrand (D-NY), Grassley (R-IA), Graham (R-SC), 
Durbin (D-IL) and Representative Lawler (R-NY-17), would simply 
make arbitration voluntary for individuals who have experienced 
age discrimination. The bill does not prohibit arbitration; 
rather, it allows individuals who have experienced age 
discrimination the option of filing a case in court. Age 
discrimination disputes would no longer be forced into the 
rigged, secretive process of forced arbitration, which permits 
systemic discrimination and hostile work environments to 
continue in perpetuity. The bill would allow American workers 
facing age discrimination to hold these wrongdoers publicly 
accountable and help end the culture of age discrimination. The 
Protecting Older Americans Act, and the transparency it creates 
will serve as a deterrent to corporations and executives from 
engaging in discriminatory practices against older Americans.

    IV. Conclusion

    Congress has historically been a champion of protecting the 
rights of older Americans and has already taken action to end 
the practice against forced arbitration for cases of sexual 
assault and sexual harassment and now has the opportunity to 
the same for cases of age discrimination. Passing the 
Protecting Older Americans Act would allow age discrimination 
victims to be heard and access our civil justice system to 
enforce the legal protections against age discrimination that 
Congress passed to protect older Americans. AAJ supports 
legislative efforts that will end the use of forced arbitration 
against not only older Americans but all workers, consumers and 
veterans who have had their rights violated. AAJ stands ready 
to work with Congress to protect the rights of all Americans 
and will continue to advocate for fairer and more transparent 
workplaces across the country.

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                       Statements for the Record

                 Defense Credit Union Council Statement

    Dear Chairman Scott and Ranking Member Gillibrand:

    On behalf of America's defense and veteran credit unions 
and our nearly 40 million members, I am writing to provide our 
views and recommendations for the Special Committee on Aging's 
hearing titled "Protecting Older Americans: Leveling the 
Playing Field for Older Workers." The Defense Credit Union 
Council (DCUC) is dedicated to ensuring that our nation's 
seniors - particularly military veterans, retirees, and their 
families - enjoy financial security, fair opportunities in the 
workplace, and protection from exploitation. As older Americans 
become a fast-growing segment of our population - with seniors 
expected to outnumber children by 2035 - it is more critical 
than ever to empower and safeguard these citizens. Notably, a 
rising share of older adults are remaining in or re-entering 
the workforce (about 19% of Americans over 65 are employed 
today, nearly double the rate in the late 1980s). We commend 
the Committee for focusing on "leveling the playing field" for 
these older workers. They face unique challenges - from age 
discrimination and caregiving responsibilities to the ever-
present threat of financial scams - and they merit our 
concerted support. Defense credit unions see these challenges 
firsthand in the communities we serve, and we have developed a 
range of programs to help older members and their families 
thrive. We appreciate the opportunity to share our perspective 
on how credit unions are "serving those who served" and all 
older Americans, and to offer policy ideas to further 
strengthen the financial well-being of seniors.

Financial Education and Fraud Prevention for Seniors

    A cornerstone of credit unions' support for older Americans 
is financial education and fraud prevention. Credit unions 
across the country have instituted robust financial literacy 
programs tailored to seniors and their families, helping inform 
them about modern fraud tactics and how to spot scams. DCUC's 
member credit unions routinely host workshops, provide one-on-
one counseling, and distribute educational materials covering 
topics like retirement planning, budgeting on fixed incomes, 
and fraud awareness. By continuously developing and 
disseminating up-to-date resources, we ensure older members 
(and their caregivers) stay informed about the latest scam 
schemes - from bogus investment "opportunities" to phishing 
attempts - and know how to protect themselves.
    This focus on education is part of the very DNA of credit 
unions. "Consumer protection and financial education are key 
parts of NCUA's mission and part of the credit union model," as 
the NCUA (our federal regulator) has emphasized. We take that 
mission to heart, especially for our senior members who may be 
more vulnerable to fraud. Unfortunately, the threat is growing: 
one in two adults over 50 has been targeted by financial 
exploitation, and elder financial abuse is estimated to cost 
older Americans over $28 billion each year. These crimes can 
devastate seniors' life savings and undermine their retirement 
security. That is why defense credit unions are proactive in 
fraud prevention - from helping members set account alerts and 
monitor transactions, to publishing scam alerts on our websites 
and in branch lobbies. Many credit unions have trained their 
frontline staff to recognize "red flags" of elder financial 
abuse, such as unusual large withdrawals or a senior member 
appearing distressed or coerced. We have embraced training 
programs (for example, AARP's BankSafe initiative) to ensure 
our employees can detect and stop scams before money is lost, 
because over 90% of older adults want their financial 
institutions to be vigilant in protecting them. Moreover, 
credit unions maintain strong fraud reporting systems and work 
closely with law enforcement and Adult Protective Services when 
we suspect a member is being victimized. We believe that 
educating seniors and stopping fraud go hand-in-hand: informed 
members plus alert, well-trained credit union staff make a 
powerful defense against scammers. DCUC member credit unions 
are proud to provide that defense every day, "empowering [older 
members] to monitor their accounts and make informed financial 
decisions to protect themselves from fraud".
    In addition to education and internal safeguards, DCUC 
actively advocates for stronger public policies to combat fraud 
targeting older Americans. We have supported legislation at 
both the state and federal level to toughen penalties for those 
who prey on seniors and to equip regulators with better tools 
to fight fraud. For example, America's credit unions have urged 
Congress to pass the Stop Senior Scams Act and similar 
measures, and to support bipartisan proposals like the TRAPS 
Act. The TRAPS Act would establish a federal task force to 
examine payment scams and include a credit union representative 
- a common-sense step that we believe will improve coordination 
in stopping scams that often target the elderly. We likewise 
caution against any policies that might shift undue fraud 
liability onto credit unions (who are victims of fraud schemes 
themselves) because doing so could drain resources from member 
services and limit our ability to collaborate on innovative 
fraud solutions. Instead, we encourage a focus on going after 
the perpetrators of fraud and bolstering prevention. We are 
encouraged that the Committee's work shines a spotlight on 
protecting older Americans, and we stand ready to work with you 
on measures to thwart scams, punish bad actors, and keep our 
seniors safe from financial harm. Every senior deserves to 
enjoy their golden years without fear that a lifetime of 
savings could be stolen by a con artist. Credit unions are 
committed to making that a reality through both education and 
advocacy.

    Tailored Financial Services and Protections for Older 
Members

    Beyond education, defense credit unions provide a wide 
range of tailored financial services to meet the needs of older 
members and level the playing field for them financially. 
Credit unions are unique, member-owned institutions with a 
community focus - "people helping people" is our guiding 
philosophy - which means we design products not for profit, but 
for the real-life needs of our members. For seniors (including 
many military retirees and veterans in our field of 
membership), this translates into low-cost, age-friendly 
financial products and personalized support. For example, many 
DCUC-affiliated credit unions offer fee-free or discounted 
checking accounts for seniors, often with no minimum balance 
requirements, recognizing that older members on fixed incomes 
shouldn't have to worry about bank fees eroding their funds. In 
fact, defense credit unions helped launch the Veterans
    Benefits Banking Program (VBBP) - a partnership with the VA 
- to provide veterans (especially unbanked or underbanked ones) 
with free, reliable accounts for receiving their VA benefits 
via direct deposit. This initiative ensures that older veterans 
can safely access their earned benefits without paying 
exorbitant check-cashing fees or falling prey to predatory 
lenders. Participating credit unions in VBBP commit to offering 
no-cost checking accounts to any veteran receiving VA payments, 
as well as financial counseling to help those who may not 
initially qualify for an account. We are proud that this 
program not only connects veterans to mainstream financial 
services, but also improves their financial stability by 
reducing fees and encouraging saving. It is one example of how 
credit unions tailor solutions for the military senior 
community, but the same spirit guides our service to all older 
Americans.
    Credit unions also provide affordable credit options that 
can be a lifeline for older adults. Where many for-profit 
lenders might see an older borrower as "high risk" or not 
lucrative, credit unions see a member of our community in need. 
We offer products like small-dollar emergency loans with low 
interest, so that a senior facing an unexpected medical bill or 
home repair can avoid high-cost payday loans or credit card 
debt. We offer auto loans and home equity loans with flexible 
terms that consider an older borrower's circumstances. 
Importantly, credit unions often will work one-on-one with 
senior members to find solutions if they encounter financial 
difficulties - for instance, creating modified payment plans or 
offering skip-a-payment options during hardship. This 
personalized, mission-driven approach helps older members 
maintain good credit and financial dignity.
    We also recognize that as people age, their accessibility 
needs evolve. Credit unions are making banking more accessible 
for seniors through measures big and small: branch layouts 
designed for ease of mobility, readily available staff 
assistance (instead of forcing everyone into self-service 
digital channels), and technologies like large-font, high-
contrast ATMs and websites for those with visual impairments. 
Many defense credit unions have senior call hours or dedicated 
member service representatives who specialize in assisting 
older members patiently with online banking or account 
questions. We know that not all seniors are tech-savvy, so 
while we embrace digital innovation, we also preserve the 
personal touch - ensuring that an older member can always reach 
a helpful human being who knows them by name.
    This dual approach of high-tech and high-touch banking is 
something credit unions excel at, and it's essential for 
building trust with older Americans. A recent AARP survey 
confirmed that age-friendly banking principles are valued by 
consumers - including preventing exploitation, helping those 
with cognitive impairments, empowering caregivers, and making 
the banking experience easier to access. Defense credit unions 
strive to embody these principles. For example, if an elderly 
member is coping with dementia or memory issues, our credit 
unions can offer solutions like placing account alerts, 
requiring a trusted caregiver's co-signature for large 
transactions, or helping set up a legal power of attorney on 
the account so that a family member can manage their finances 
responsibly. We also engage directly with financial caregivers 
- often the adult children or spouses of our senior members - 
to ensure they have the information and support needed to 
manage their loved one's finances. In short, we view the 
member's whole family as part of our community. By empowering 
caregivers and being attentive to signs of cognitive decline, 
credit unions add a crucial layer of protection for seniors, 
beyond what any one regulation or product alone can achieve.
    Another key aspect of leveling the field for older workers 
and retirees is shielding them from predatory practices. DCUC 
and its member credit unions have long focused on fighting 
predatory lending and financial predators that target military 
and senior communities. We actively educate our members about 
the risks of payday lenders, high-fee investment schemes, and 
dubious "pension advance" companies that often zero in on older 
adults. At the same time, we advocate for policies that curb 
these predators. For instance, DCUC has supported strong 
enforcement of the Military Lending Act's 36% interest rate 
cap, which helps many young service members but also protects 
older veterans from payday and auto-title loans charging 
triple-digit rates. We also back efforts to improve disclosures 
and crack down on financial advisors who prey on seniors with 
unsuitable annuities or scams. Financial inclusion is at the 
heart of our mission - we want every senior to have access to 
fair, affordable financial services and to be protected from 
those who would exploit their vulnerabilities. By keeping our 
fees low, our yields competitive, and our underwriting 
compassionate, credit unions are helping older Americans keep 
more of their money and achieve long-term financial stability. 
As Mr. Anthony Hernandez, DCUC's President/CEO, has noted, 
"Veterans have sacrificed so much for our Nation. it is 
critical that we ensure they are best protected from financial 
exploitation". We believe that holds true for all older 
Americans - they have contributed greatly to our society and 
economy, and they deserve financial services that serve them, 
not take advantage of them.

    Supporting Older Workers and Caregivers in the Community

    The theme of this hearing - leveling the playing field for 
older workers - goes beyond banking, and we want to voice our 
strong support for making the labor market fair and accessible 
to older Americans. Many of our credit union members continue 
to work well into their 60s, 70s, or later, whether out of 
financial necessity, a desire to stay active, or both. We know 
that these older workers bring a wealth of experience and 
skills to the table, yet they often face barriers such as age 
discrimination in hiring or retraining. While DCUC's primary 
expertise is in financial services, we join others in urging 
policies that eliminate bias against older workers and that 
encourage employers to tap the talent of experienced employees. 
We support strengthening and enforcing laws like the Age 
Discrimination in Employment Act to ensure no worker is 
unfairly pushed out or passed over simply due to age. 
Additionally, we encourage initiatives for lifelong learning 
and re-skilling - for example, federal or state programs that 
provide training in new technologies to workers over 50, so 
they can continue to advance in their careers. Such efforts 
would directly benefit many credit union members who want to 
remain productive and self-sufficient.
    It is also important to recognize the interplay between 
caregiving and the workforce. Many older Americans find 
themselves in the "sandwich generation," still working while 
also caring for aging parents, an ailing spouse, or helping 
with grandchildren. This dual role can strain their finances 
and time. Credit unions try to help these members by offering 
financial counseling for caregivers - for instance, advising 
them on how to budget for medical expenses or navigate 
insurance and benefits for their loved ones. We often refer 
members to reputable resources (such as the local Aging and 
Disability Resource Centers or the VA Caregiver Support program 
for veteran families) and in some cases partner with community 
organizations to host seminars on caregiving and estate 
planning. Some credit unions have even introduced "caregiver 
accounts" or read-only account access, which allow a designated 
caregiver to monitor an older member's account activity for 
unusual transactions (with the member's consent). These tools 
empower caregivers to help prevent fraud and manage day-to-day 
finances, reducing stress on working seniors who have 
caregiving duties. We applaud Congressional efforts to support 
family caregivers - for example, proposals to provide caregiver 
tax credits or expand respite care programs - because easing 
the burden on caregivers will in turn help many older workers 
remain in their jobs. In the financial sphere, we believe 
credit unions can be valuable partners in any federal 
initiative to educate and assist caregivers in managing an 
elder's finances safely and efficiently.
    Finally, we want to highlight that defense credit unions 
themselves are often large employers, and we benefit greatly 
from the contributions of older employees and volunteers. Many 
credit union boards of directors are composed of retired 
military personnel and civilians, often seniors who volunteer 
their time to govern our institutions. Their wisdom and 
perspective are tremendous assets. We strive to lead by example 
by embracing age diversity in our workforce and governance, and 
we encourage other industries to do the same. When workplaces 
value older workers, provide flexible schedules or phased 
retirement options, and accommodate health needs, it enables 
those workers to continue contributing to their communities 
(and contributing to their retirement savings). That in turn 
strengthens their financial resilience and reduces the 
likelihood they'll face hardship or exploitation. In short, 
treating older workers fairly is not just a moral imperative - 
it's sound economic and social policy that benefits everyone. 
We thank the Committee for recognizing this through today's 
hearing.

    Conclusion: Partnering to Serve and Protect Older Americans

    In conclusion, the Defense Credit Union Council and our 
member credit unions are deeply committed to the financial 
well-being of older Americans. Every day, we see seniors in our 
branches or online - longtime members, veterans, and new 
members alike - who rely on us not just for transactions, but 
for guidance, trust, and a safe harbor for their finances. We 
take that responsibility very seriously. Our defense credit 
unions remain dedicated to helping seniors achieve long-term 
financial stability and stand ready to partner with 
policymakers in advancing this goal. We sincerely thank the 
Committee for highlighting the needs of older workers and 
retirees, and for recognizing the vital role community-based 
financial institutions can play in meeting those needs.
    Moving forward, we encourage Congress to continue 
supporting and working with credit unions as part of the 
solution. Whether it's disseminating fraud alerts, facilitating 
access to affordable financial services, or delivering 
financial education in the community, credit unions are on the 
front lines making a difference for seniors. We can amplify 
these successes through collaboration. We invite members of the 
Committee and your staff to visit a local defense credit union 
to see our senior-focused programs in action - from fraud 
prevention training sessions to veteran benefit counseling - 
and to discuss further how we might expand these efforts with 
federal support.
    Above all, we share a common purpose: to ensure that every 
older American can enjoy their later years with financial 
independence, security, and dignity. Those who spent a lifetime 
defending our country or building our communities should not 
face unfair disadvantages in the workplace or exploitation in 
the marketplace. By leveling the playing field for older 
workers and empowering credit unions and other community 
partners, Congress can uphold that principle. DCUC and our 
member credit unions are eager to work alongside you in this 
mission.
    Thank you for the opportunity to submit this testimony 
letter for the hearing record. We appreciate your leadership in 
protecting older Americans. Should you have any questions or 
require additional information, please do not hesitate to 
contact me at (202) 557-8528 or via email at [email protected]. 
We look forward to continuing to work with you to better serve 
our nation's seniors and their families.
    If you have any questions, please do not hesitate to 
contact me.

    /s/
    Jason Stverak
    Chief Advocacy Officer
    DCUC
    CC: Members of the United States Senate

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                       Statements for the Record

                    Mary Ann (Miki) Herman Statement

    My name is Mary Ann (Miki) Herman, and I am from Portland, 
Oregon. I am 76 years and retired after a 30+ year career 
working in diverse companies. During my career, I lead teams 
and companies across many national and global industries 
holding senior executive positions in $10M to $20B 
organizations. Currently I advocate for equity for older adults 
with local and national organizations in volunteer and Board 
Member roles.
    I'm pleased to strongly support the bipartisan Protecting 
Older Americans Act which allow victims of age discrimination 
to seek justice and accountability. My two very different 
stories show that I've both experienced workplace age 
discrimination but also been on a management team that engaged 
in age discrimination. In both cases, there was little to no 
recourse for an older worker to seek accountability or obtain 
justice.
    In 2008 I was recruited by a well-known Oregon company. I 
had several phone interviews, and my skill set was a perfect 
match for senior management. But when I had the high-level, in-
person interview, most of the questions and comments were 
focused on my current fitness and lifestyle - not my 
qualifications. I was asked probing questions about how my 
athleticism had changed over the years and how I maintain my 
fitness. Several questions were about what type of running I 
still did, the amount of miles that I logged daily compared to 
earlier years - and my stamina for competitive sports now.
    My experience was exactly what they needed, but they said 
my look did not align with their lifestyle, athletic brands or 
their culture. I knew they were talking about my age, and I was 
not surprised when I was not invited back for the final 
interview with the CEO.
    I did think about taking legal action, but I know how hard 
it is to prove, and I needed to focus on finding another job. 
And fortunately, I was successful, and I continued to have a 
very rewarding professional career.
    Jumping forward in time, I want to share my second 
experience. A little more than twelve years ago, I served as a 
high level executive for a major national company at which time 
I found myself part of a management team engaged in blatant age 
discrimination.
    Because of company financial losses, we were told there 
would need to be a restructure of our $6B business unit with a 
focus on a lower salaries to improve profitability, so we would 
be looking at the highest salaries as the basis for this 
restructuring approach.
    I, along with other executive level colleagues met. On a 
whiteboard, we listed everyone's duties and salaries but also 
their age and expected retirement. It didn't matter if you had 
a star performer or their actual salary, the conversation and 
decision-making focused on the employee's age and how long we 
thought they would stay before they would retire. We then 
targeted just the older workers under the guise that they were 
the highest paid employees. In some cases that was true but in 
other cases it was not. It was clear to me that we were using 
the subterfuge of "high salary" as a proxy to engage in age 
discrimination.
    To cover our tracks, we didn't just lay them off because 
that might be too obvious. Instead, these older workers were 
told they could stay but they'd have to re-apply for their job 
in this new structure or they could consider another lesser 
paying job. Except the reality was we restructured the new jobs 
in a way that they would not qualify and if they applied for a 
lesser position, they were not actually considered for those 
positions.
    The reality is workplace age discrimination is far too 
prevalent, and we need to update the laws so that older workers 
are protected.
    Thank you for letting me share my stories.

                 U.S. Senate Special Committee on Aging

   "Protecting Older Americans: Leveling the Playing Field for Older 
                                Workers"

                           September 3, 2025

                       Statements for the Record

                         Ed Henselder Statement

    My name is Ed Henselder. I live in Melville, NY, which is 
part of Huntington Township on Long Island, and I am currently 
63 years old. In my mid-twenties, I developed a condition 
called uveitis, which caused a gradual loss of my vision. At 
age 28, as a married father of two young children, my 
decreasing vision forced me to find a new path to support my 
family. The application process for Social Security Disability 
took 18 months to be approved, causing tremendous financial 
hardship for our family that took many years to overcome.
    I received training with assistance from the New York State 
Commission for the Blind, where I learned how to use a computer 
and adaptive technology. The continuous decline of my vision 
has required me to adapt to new assistive software over the 
years-from using magnification software, combining 
magnification with speech assistance, and relying solely on 
speech technology.
    Securing and maintaining employment has become increasingly 
challenging as my vision deteriorated. Some websites and CRM 
systems became less accessible, with features that were not 
compatible with screen readers or had improperly labeled 
elements, making navigation difficult. Additionally, I have 
encountered hesitancy from employers due to my age or a lack of 
understanding about how a blind individual can use a computer. 
This is often compounded by limited awareness of ADA laws, 
including requirements for accessibility, reasonable 
accommodations, and the ambiguities in these regulations.
    Despite the numerous challenges I have faced over the 
years-whether it be employers' reluctance to hire individuals 
with visual impairments, the need to find workarounds for 
inaccessible websites and computer software, or difficulties 
reaching locations via paratransit-I have managed to secure 
employment on several occasions. Unfortunately, I lost a 
position I held for 13 years due to the COVID-19 pandemic and 
have only been able to work for three months since March 2020. 
During this period, I have continued to expand my knowledge of 
adaptive software and earned certifications in Salesforce but 
have not yet been able to obtain new employment.
    Widespread reductions across various federal departments 
have resulted in many programs for the aged and disabled 
becoming collateral damage, making the prospect of finding 
employment even more difficult. As I persist in my efforts to 
become more employable and actively search for opportunities, I 
often spend hours reflecting on the sacrifices my wife and I 
will need to make to survive. Our goal is to maintain a quality 
of life that allows us to enjoy time with our children and 
grandchildren, even as we navigate increased costs and 
reductions to essential resources such as housing, medical 
needs, and other necessities.
    I simply request the next time you are looking to cut costs 
look to see what exactly does that department do, how will the 
people be effected by the cuts, and what opportunities are 
there for these people to maintain the basics in their lives.

                              [all]