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Change in Social Security Offset Is Not Prohibited Cutback, 11th Circuit Rules
Deloitte via BenefitsLink 
June 24, 2012
"The 11th Circuit Court of Appeals ruled that an amendment changing the formula for calculating the social security offset in a defined benefit plan did not violate the anti-cutback rule under ERISA section 204(g) -- which prohibits plan amendments that reduce a participant's accrued benefit. The affected participants were not yet eligible for a retirement benefit under the plan, so the more favorable preamendment social security offset formula was not part of their accrued benefit, the court found."
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