The GAO found 17 countries with aging populations and national pension systems similar to Social Security. It focused on four of them—Canada, Germany, Sweden and the U.K.— that offer various strategies nationally to encourage phased retirement. But the specific programs differed on design and sources of supplemental income for participants.

In the beginning, some countries adopted such policies to encourage older people to begin to leave the workforce, thus making room for younger workers.

That reason has now changed due to demographics, so countries are aiming to do the opposite—encourage older people to remain so that knowledge and skills can be passed along to the next generation of workers as well as increasing older workers’ participation in the labor force.

While in the U.S. employers deal with employee-directed retirement plans and many employees are not covered by collective bargaining, some phased retirement plans in use in other countries allow access to employer-sponsored or national pension benefits while working part time. For example, in the U.K.,  workers are allowed part of their pension money without it being taxed. And one U.K. employer also reported allowing concurrent contributions to those plans.

The GAO was told by U.S. employers that offering phased retirement to specific groups of workers could run afoul of employment discrimination laws.

The report notes that a union representative in Germany told of an agreement in which employers can restrict or cap participation, such as at 3 percent of the workforce, to manage the number of workers in the program.

Another German strategy involves national policies that make it easier for workers to cut their hours and get a portion of their pension benefits while still being able to contribute to that plan since they’re still working. One national program uses tax preferences.

Then there’s Sweden, which launched a policy in 2010 that allows partial retirement and access to partial pension benefits to encourage workers to stay in the labor force longer.

The GAO report notes that their investigation found it can be costly to design and implement phased retirement programs. Complicating matters for a U.S. program would be the fact that health insurance is provided through the employer, not nationally as in other countries. Additionally phased retirement programs could run afoul of U.S. employment regulations regarding discrimination, and those issues would also have to be addressed.

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