U.S. Postal Service Actions to Improve Its Financial Reporting

Gao ID: GAO-03-26R November 13, 2002

Over the past 2 years, we have been raising concerns and have made recommendations regarding the lack of sufficient and timely periodic information on the U.S. Postal Service's financial condition and outlook available to the public between publications of its audited year-end financial statements. This report responds to a request that we provide periodic updates on several key areas related to the Service's financial outlook, including improvements in financial and performance reporting. Specifically, this report discusses actions taken by the Service to address our past recommendations to provide sufficient, more timely, and accessible financial reports as well as our assessment of the Service's responses.

Transparency is particularly important because the Service is the hub of a $900 billion mailing industry and is a vital part of the nation's communications network. Its recent financial difficulties have accentuated the need for stakeholders--including the Congress, Postal Rate Commission, and mailers--to be well apprised of the Service's financial situation and understand how future operating results may be affected by impending events. Although the service has traditionally provided a range of detailed financial and operating data to stakeholders throughout the fiscal year, its periodic financial reports have not clearly explained changes in its financial condition, results of operations, and outlook and have not always been readily available to the public. The Securities and Exchange Commission requires that quarterly reports submitted by publicly traded companies include a discussion of material changes in a company's financial condition and results of operations. This type of discussion is consistent with the intent of our recommendations.



GAO-03-26R, U.S. Postal Service Actions to Improve Its Financial Reporting This is the accessible text file for GAO report number GAO-03-26R entitled 'U.S. Postal Service Actions to Improve Its Financial Reporting' which was released on November 13, 2002. This text file was formatted by the U.S. General Accounting Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products‘ accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. United States General Accounting Office: November 13, 2002: The Honorable Daniel K. Akaka: Chairman: The Honorable Thad Cochran: Ranking Minority Member: Subcommittee on International Security, Proliferation, and Federal Services: Committee on Governmental Affairs: United States Senate: Subject: U.S. Postal Service Actions to Improve Its Financial Reporting: Given the vital role of the nation‘s postal system and the importance of its financial viability, it is imperative that the U.S. Postal Service (the Service), the Congress, stakeholders, and the public have adequate information available to them to understand the Service‘s financial situation and assess its progress towards meeting its performance goals and planning for its future. During the first part of fiscal year 2001, the Service made numerous revisions to its estimated net income with little or no public explanation. The Service‘s financial outlook changed from a $480 million deficit in its fiscal year 2001 budget approved in November of 2000, to a $2 billion to $3 billion deficit projected 3 months later in February 2001. Likewise, at the beginning of fiscal year 2002, the Service estimated that it would end the year with a $1.35 billion deficit and then stated, in May 2002, that its net loss for the year could have reached $4.5 billion. Despite the fact that the Service publicly released periodic financial information, these significant changes in financial outlook were not evident from publicly available information and came as a surprise to many stakeholders. More recently, the Service announced the results of a new financial analysis that could significantly reduce its Civil Service Retirement System (CSRS) pension liability if Congress takes related legislative action, which would significantly impact the Service‘s financial outlook.[Footnote 1] It will be important for the Service to keep stakeholders well informed about this issue. Over the past 2 years, we have been raising concerns and have made recommendations regarding the lack of sufficient and timely periodic information on the Service‘s financial condition and outlook available to the public between publications of its audited year-end financial statements. This report responds to your July 31, 2002, request that we provide periodic updates on several key areas related to the Service‘s financial outlook, including improvements in financial and performance reporting. Specifically, this report discusses the actions taken by the Service to address our past recommendations to provide sufficient, more timely, and accessible financial reports as well as our assessment of the Service‘s responses. Our specific recommendations and the Service‘s initial responses were as follows: In April 2001, we recommended that the Service provide summary financial reports to Congress and the public on a quarterly basis. These quarterly reports were to present sufficiently detailed information for stakeholders to understand the Service‘s current and projected financial condition, how its outlook may have changed since the previous quarter, and its progress towards achieving its desired results.[Footnote 2] In a letter dated June 2001 to congressional oversight and appropriation committees and subcommittees, the Service agreed to provide additional transparency related to its financial condition and said that it would create, and post to its Web site, financial statements ’similar to what publicly traded enterprises provide“ and continue this practice quarterly. In February 2002, we recommended that the Service provide its monthly and quarterly financial reports on its Web site in a user-friendly format and in a timelier manner.[Footnote 3] In its February 2002 comments on a draft of our report, the Service agreed with our recommendation and said it was providing financial reports on its Web site in a more timely and user-friendly manner. In September 2002, we reported that the Service should carefully reassess its overall accounting treatment for pension and postretirement health obligations and reaffirmed a recommendation that we previously made to the Service to enhance disclosure of its postretirement health benefit obligations in its financial statements. In its September 10 letter commenting on the report, the Service stated that it planned to address its pension and postretirement health obligations in the Management Discussion and Analysis (MD&A) section of its annual report.[Footnote 4] This report on the Service‘s financial reporting is based on our previous work, review of the Service‘s monthly and quarterly financial reports from the third quarter of fiscal year 2001 through the third quarter of fiscal year 2002, the Service‘s written responses to our recommendations, and discussions with Service officials about their responses to our recommendations. We compared the Service‘s quarterly financial report for the third quarter ending in May 2002, with those of a similar period completed by two of its major publicly traded competitors--FedEx and United Parcel Service (UPS). Publicly traded companies are subject to Securities and Exchange Commission (SEC) quarterly financial reporting requirements.[Footnote 5] These quarterly reports include three major components: (1) financial statements, which consist of an income statement, balance sheet, cash flow statement, and related footnotes; (2) management‘s discussion and analysis (MD&A) of financial condition and results of operations; and (3) quantitative and qualitative disclosures about market risk.[Footnote 6] The SEC requires that information in quarterly reports from publicly traded entities provide investors and others with an accurate understanding of the company‘s current and prospective financial position and operating results. Although the Service is not subject to SEC reporting requirements, the purpose of these requirements is similar to the intent of our recommendations for improved transparency to enable stakeholders to better understand the Service‘s financial condition and outlook. We conducted our review between July 2002 and September 2002 in accordance with generally accepted government auditing standards. We requested comments on a draft of this report from the Postal Service, and its comments are discussed near the end of this letter and are reproduced in enclosure IV. Results In Brief: Transparency is particularly important because the Service is the hub of a $900 billion mailing industry and is a vital part of the nation‘s communications network. Its recent financial difficulties have accentuated the need for stakeholders--including the Congress, Postal Rate Commission (PRC), and mailers--to be well apprised of the Service‘s financial situation and understand how future operating results may be affected by impending events. Further, we recently reported that the Service‘s financial situation is significantly impacted by its pension and postretirement health obligations and that the Service should reassess its accounting treatment and reporting of these obligations. We also reaffirmed our previous recommendation that the Service disclose the full amount of the accrued postretirement health benefits earned by its employees and retirees in notes to its financial statements. The importance of these obligations was recently highlighted when the Service announced the results of a new analysis that could significantly reduce its CSRS pension liabilities if Congress takes related legislative action. This change would improve its overall financial condition and provide opportunities to address other key financial issues, such as its postretirement health benefit obligations and outstanding debt. Although the Service has traditionally provided a range of detailed financial and operating data to stakeholders throughout the fiscal year, its periodic financial reports have not clearly explained changes in its financial condition, results of operations, and outlook and have not always been readily available to the public. In response to our recommendations, the Service committed to provide quarterly financial statements ’similar to what publicly traded enterprises provide.“ The Service also has begun posting its quarterly reports on mail volumes and revenues, along with its monthly operating statements, to its Web site. However, we do not believe that the quarterly financial reports provided to date meet the intent of our recommendations, because the Service provided only limited analysis and explanations to help stakeholders understand what had changed, why it had changed, and how these changes affected the Service‘s current financial situation and expected outlook. The SEC requires that quarterly reports submitted by publicly traded companies include a discussion of material changes in a company‘s financial condition and results of operations.[Footnote 7] This type of discussion is consistent with the intent of our recommendations. When we compared the Service‘s most recent quarterly report with those of two of its publicly traded competitors--FedEx and UPS--we found that the Service‘s quarterly report generally provided the same basic financial statements as did its competitors. However, unlike the Service, FedEx and UPS also provided very detailed ’Management‘s Discussion and Analysis“ sections in their reports that discussed events during the period that may have had a significant impact on the financial condition of the company and the outlook for the future, and compared the results of operations with the prior year‘s results. FedEx and UPS‘s reports also included explanatory footnotes to the financial statements that provided details about significant changes that have occurred and material contingencies that were not included in the Service‘s reports. Further, the Service‘s quarterly reports were not consistent in format and content, or as available to the public as the FedEx and UPS quarterly reports. These changes in subsequent quarterly reports and their limited availability made it difficult to make comparisons and analyze trends. In commenting on our draft report, the Service said that it would provide additional information in its periodic financial reports to improve stakeholder understanding of its business and that it would retain the data placed on its Web site for 3 years. The Service also cautioned that public discussion of retirement obligations must be undertaken with great care, and that it would ensure greater public understanding in this area. Due to the magnitude of these costs, the potential effects on current and future ratepayers, and the complexity of the issues involved in reporting retirement-related obligations, we agree that greater public understanding of these obligations is important and that the Service can help accomplish this through enhanced disclosure in its financial and related statements. The Service also said that it makes more financial and operating information available than we reflected in our report. We discuss this issue near the end of this letter. Background: Traditionally, between the annual issuance of its audited year-end financial statements, the Service has provided several types of periodic financial reports, including its monthly Financial and Operating Statements; quarterly Revenue, Piece, and Weight (RPW) Reports; and most recently, quarterly financial reports.[Footnote 8] The information provided in its periodic monthly operating statements and quarterly RPW reports is as follows: Monthly Financial and Operating Statements: Cover a 4-week period and include data that provide an overview of financial results for that period, compare results with the budget, compare results with the same period in the previous year, and provide year-to-date information. These statements also include detailed information on revenues, expenses, volumes, and work hours; a balance sheet; a cash flow statement; and capital commitments and outlays. Traditionally, these reports were sent to stakeholders by request or posted on the PRC‘s Web site. The Service began posting the most recently completed financial and operating statement to its Web site in early 2002. Quarterly Revenue, Piece, and Weight Reports: Contain information relating to the Service‘s mail classes and special services. RPW reports document the total revenue, pieces, and weights for each mail class, subclass, and service for that quarter; in addition, the reports provide data on the amount and percentage change from the same period in the previous year and year-to-date information. Quarterly RPW reports dating back to fiscal year 1999 are currently available on the Service‘s Web site. During the fall of 2001, when the Service experienced sharp declines in its mail volumes and revenues, and it requested additional appropriations from Congress, readily available and detailed information on the Service‘s changing financial situation was scarce. Our February 2002 report noted that from October 2001 to mid-January 2002, the Service did not publicly release its monthly statements for the last accounting period of fiscal year 2001 and for the first three accounting periods of fiscal year 2002.[Footnote 9] Although the Service issued its annual report for fiscal year 2001 in December 2001, it did not publicly release financial results for the fourth quarter of fiscal year 2001.[Footnote 10] We reported that more timely availability of monthly and quarterly reports, even if they contain preliminary data subject to revision, would be useful to improve transparency for congressional oversight, the stakeholder community, and the public.[Footnote 11] The Service‘s Quarterly Financial Reports Lacked Explanatory Information, Consistency, and Public Availability: Much attention has recently been focused on efforts to improve accountability and the usefulness of financial information, in both the public and private sectors. One of the key components of the President‘s Management Agenda is to improve accountability to the American people by enhancing the timeliness, usefulness, and reliability of financial information provided by federal agencies. Likewise, recently enacted legislation--the Sarbanes-Oxley Act of 2002 (Public Law 107-204, enacted into law on July 30, 2002)--seeks to protect investors by improving the accuracy and reliability of corporate disclosures made pursuant to the securities laws. Given the importance of the Service‘s financial condition and outlook, timely, accurate, and complete financial information is needed for oversight purposes and for stakeholders to better understand the Service‘s changing financial situation and its potential effect on stakeholders‘ future plans. The key limitations of the Service‘s quarterly financial reports were that they have lacked sufficient analysis and explanation of what has changed and why in its financial condition, operating results, and outlook. This type of explanatory information is typically provided in quarterly financial reports of publicly traded companies and is consistent with the intent of our previous recommendations. Further, the Service‘s quarterly reports have not been consistent in format and content or readily available to the public. Sufficient, consistent, and accessible financial information helps provide the necessary transparency and accountability that are fundamental principles in ensuring public confidence in an organization and proper oversight. The Service‘s Quarterly Financial Reports Lacked Sufficient Analysis and Explanations: When we compared the most recent quarterly reports of the Service with those of its publicly traded competitors--FedEx and UPS--we found that the greatest differences were in the level of analysis and explanation provided for changes in financial condition, operating results, and outlook.[Footnote 12] This information is generally included in the sections titled MD&A in the publicly traded quarterly reports and in the notes to the financial statements. Management‘s Discussion and Analysis (MD&A): The SEC requires publicly traded enterprises to provide a management‘s discussion and analysis of the entities‘ financial condition and results of operations, both in quarterly and annual reports. The SEC guidance for interim financial reports states: ’the MD&A requirements are intended to provide in one section of a filing, material historical and prospective textual disclosure enabling investors and other users to assess the financial condition and results of operations of the registrant, with particular emphasis on the registrant‘s prospects for the future . . .. Disclosure is mandatory where there is a known trend or uncertainty that is reasonably likely to have a material effect on the registrant‘s financial condition or results of operations. Accordingly, the development of an MD&A should begin with management‘s identification and evaluation of what information, including the potential effects of known trends, commitments, events, and uncertainties, is important to providing investors and others an accurate understanding of the company‘s current and prospective financial position and operating results.“[Footnote 13] In comparing the most recent quarterly reports of the Service, FedEx, and UPS, we found that the most notable differences were in the level of detail provided in the MD&A sections of the reports.[Footnote 14] For example, FedEx and UPS provided explanations in their MD&A sections of how they planned to meet their working capital needs for the future; causes of changes in revenues and volume, by business line, compared with prior periods; and their outlook for the future, including the effect of significant events, such as the terrorist-related events of the fall of 2001. In contrast, the Service provided minimal explanations in these areas. Given the potential impact of these and other key factors, such as the timing and amount of proposed rate increases, it would be helpful to know how these factors affect the Service‘s changing year-end outlook. Specific examples of the differences between the MD&A section of the Service‘s quarterly report and those in FedEx‘s and UPS‘s quarterly reports are provided below. The full text of the quarterly reports we compared can be found in enclosure I for the Service, enclosure II for FedEx, and enclosure III for UPS. Postal Service discussion of outlook: ’Volume trends of the past three quarters are expected to continue through the fiscal year end in September. Taking the June 30, 2002 rate increase into account, volume losses in the 3 to 4 percent range are anticipated for the quarter, compared to the same quarter last year. With expense reductions in excess of $2.5 billion and the rate increase on June 30, the estimated net loss for the year will be in the range $1.0 billion to $1.5 billion.“ FedEx discussion of outlook: ’While we believe there is evidence that a modest economic recovery is underway, a significant portion of our U.S. domestic express business comes from the manufacturing and wholesale sectors, especially in the high technology area. Recovery in these sectors is still lagging the rest of the economy on a year-over-year basis. Until these key sectors experience sustained growth, volumes at FedEx Express are expected to remain soft. ’Our fourth quarter volume outlook for FedEx Express is for U.S. domestic average daily package volume to be approximately 2% below last year‘s fourth quarter and for IP shipments to be down about 1%. In addition, our dynamic fuel surcharge at FedEx Express effectively has a six-week lag before the surcharge is adjusted for increased fuel prices. Therefore, our operating income may be negatively affected should the spot price of jet fuel increase significantly in the fourth quarter. At FedEx Ground, fourth quarter volume is expected to grow about 16% year-over-year. ’We believe our diverse portfolio of services is the key factor to our long-term growth. The expansion of our Home Delivery network and continued development and cross selling of the diverse FedEx portfolio of services, particularly to small-and medium-sized businesses, is central to our strategy. Our website, fedex.com, is heavily utilized and has helped us reduce costs and improve customer satisfaction. We believe that our substantially fixed cost express network infrastructure will allow us to realize incremental profits when the economy recovers. ’Maintenance costs during the fourth quarter of 2002 are expected to be higher due to scheduled maintenance activities. Also, we accrued increased variable compensation in the third quarter of 2002 and expect to continue to do so in the fourth quarter. Our 2002 incentive compensation costs will be sharply reduced for most employees (including senior management). However, fourth quarter incentive compensation provisions will be higher year-over-year since the prior year‘s fourth quarter included reversals of incentive compensation that had been previously accrued. ’We expect pension and health care costs to continue to increase over the near term. Our net pension cost for 2002 will increase by approximately $90 million due to lower interest rates and a reduction in the value of plan assets. We expect next year‘s pension cost to increase by $90-100 million based on a continued decline in interest rates and a decrease in the expected return on pension plan assets. While employee retirement costs continue to rise, our retirement programs are well funded, with assets more than sufficient to meet our current obligations.“: UPS excerpts of significant events and outlook: ’— Due to the events of September 11, 2001, increased security requirements for air carriers may be forthcoming; however, we do not anticipate that such measures will have a material adverse effect on our financial condition, results of operations or liquidity. In addition, our insurance premiums have risen and we have taken several actions, including self-insuring certain risks, to mitigate the expense increase. ’As of December 31, 2001, we had approximately 232,500 employees (64% of total employees) employed under a national master agreement and various supplemental agreements with local unions affiliated with the International Brotherhood of Teamsters (’Teamsters“). These agreements run through July 31, 2002. The majority of our pilots are employed under a collective bargaining agreement with the Independent Pilots Association, which becomes amendable January 1, 2004. Our airline mechanics are covered by a collective bargaining agreement with Teamsters Local 2727, which became amendable on August 1, 2001. Members of Teamsters 2727 recently voted down a proposed new contract, and negotiations resumed in April 2002 with the assistance of the National Mediation Board. In addition, the majority of our ground mechanics who are not employed under agreements with the Teamsters are employed under collective bargaining agreements with the International Association of Machinists and Aerospace Workers. These agreements have various expiration dates between July 31, 2002 and May 31, 2003. ’We entered into negotiations with the Teamsters in January 2002 for a new national master agreement. It is our desire through these discussions to reach an agreement on a new contract prior to the end of our current five-year agreement on July 31, 2002. Any strike, work stoppage or slowdown that results from our failure to reach a timely agreement with the Teamsters, and any change in shipping behavior by our customers or potential customers due to perceptions that we will not reach a timely agreement with the Teamsters, could have a material adverse effect on our financial condition and results of operations. We do not, however, anticipate that this will occur. ’We believe that funds from operations and borrowing programs will provide adequate sources of liquidity and capital resources to meet our expected long-term needs for the operation of our business, including anticipated capital expenditures such as commitments for aircraft purchases, through 2009.“: * Postal Service discussion of changes in revenue: ’U.S. domestic package revenue decreased 1.2% compared to last year. This decline was driven by a 1.5% reduction in average daily package volume which was primarily a result of the continued weakness in the U.S. economy. Revenue for our Next Day Air products was also adversely affected by a decline in revenue per piece. The decline results in part from lower package weights combined with a mix shift favoring letters to packages. This reflected what we believe to be continued slowness in the manufacturing sector. Conversely, revenue for our Ground products increased slightly due to a 3.5 % increase in average revenue per piece. This improvement resulted in part from having a rate increase that occurred four weeks earlier than compared to the pr“Revenue: Revenue of $15.3 billion was 4.9 percent ($796 million) below plan and 2.0 percent ($322 million) below Quarter III of last year. Planned revenue growth for Quarter III was 3.1 percent. ’Volume in Quarter III was 2.5 percent below last year. We processed and delivered 47.1 billion pieces as compared to 48.3 billion pieces last year. Revenue loss from the volume decline of 1.2 billion pieces was offset through expense reductions.“ * UPS excerpts of changes in revenue: UPS reports its operations in three segments: U.S. domestic package operations, international package operations, and nonpackage operations, as well as on a consolidated basis. Although the entire revenue discussion is included in enclosure III, for brevity purposes, only the U.S. domestic package revenue discussion is presented here, as follows: ’U.S. domestic package revenue decreased 1.2% compared to last year. This decline was driven by a 1.5% reduction in average daily package volume which was primarily a result of the continued weakness in the U.S. economy. Revenue for our Next Day Air products was also adversely affected by a decline in revenue per piece. The decline results in part from lower package weights combined with a mix shift favoring letters to packages. This reflected what we believe to be continued slowness in the manufacturing sector. Conversely, revenue for our Ground products increased slightly due to a 3.5% increase in average revenue per piece. This improvement resulted in part from having a rate increase that occurred four weeks earlier than compared to the prior year. ’On January 7, 2002, we increased rates for standard ground shipments an average of 3.5% for commercial deliveries. The ground residential charge increased $0.05 to $1.10 over the commercial ground rate, and this charge will also be applied to express deliveries in 2002. The additional delivery area surcharge, which is added to ground deliveries in certain less accessible areas, remained at $1.50. In addition, in 2002, this charge will also be applied to express deliveries to these addresses. Rates for UPS Hundredweight increased 5.9%. ’We also increased rates for UPS Next Day Air, UPS Next Day Air Saver, UPS 2nd Day Air, and 3 Day Select an average of 4.0%. The surcharge for UPS Next Day Air Early A.M. increased from $27.50 to $28.50. Rates for international shipments originating in the United States (Worldwide Express, Worldwide Express Plus, UPS Worldwide Expedited and UPS International Standard service) increased an average of 3.9%. Rate changes for shipments originating outside the U.S. were made throughout the past year and varied by geographic market. ’An index-based fuel surcharge, which became effective December 10, 2001, continued and resets on a monthly basis beginning in February 2002. The index-based surcharge is based on the National U.S. Average On-Highway Diesel Fuel Prices as reported by the U.S. Department of Energy.“: * FedEx discussion of changes in revenue: FedEx also reports its operations on a consolidated basis and for its major business segments: FedEx Express, FedEx Ground, FedEx Freight, and other Operations. See enclosure II for the complete tables and discussion in each of these areas. As these examples indicate, the level of explanations in the FedEx and UPS quarterly MD&A sections is significantly greater than that provided by the Service and helps provide the reader with a better understanding not only of what has changed, but why. In comparing the quarterly reports, we developed the following questions that we believe would provide meaningful information for the Service to include in its quarterly report in order to make it a more useful document to its stakeholders: Information regarding the current reporting period: What were the major changes in revenue, expense, and volume and the causes of these changes? How do these results compare with the prior period‘s? What major challenges or risks did the Service face during the period, and what was done to respond to them? What were the financial consequences of these occurrences? Information regarding the upcoming reporting period: What challenges are expected, by business line? How will they be overcome? What are the financial expectations of the Service as a whole and on a business line basis? What impact will competitors have in the upcoming period? What significant trends, events, commitments, or uncertainties may affect the Service‘s expectations? What are the expected cash requirements and year-end cash position? What are the expected capital commitments and outlays? What is the expected net income, and what actions may be taken to address specific situations or conditions? Specifically, focus on the causes of any losses and specific plans to correct them, if known. By major business line, what are the major challenges faced, accomplishments, and plans to generate revenue, reduce costs, and pay down the debt with the U.S. Treasury? Information regarding long-term outlook: What are the capital expansion plans, projects, time periods, amounts, and return on investment? What are current projects, their status, and planned projects? How will these projects be funded and implemented? How will changing economic factors affect these plans? What risk analysis and contingency plans have been developed? What are the changes to the previously reported plans? What are the plans to remain within the present debt limit and plans to pay off long-term debt? How is the Service prepared to meet its long-term obligations, such as funding postretirement health care costs? While not all of these issues would necessarily be included in every report, they do represent items that should be considered for disclosure each quarter, giving special consideration to changes that have occurred since the annual report was issued. In addition, some of these disclosures would most appropriately be made in the footnotes accompanying the quarterly financial statements, as are discussed in more detail below. Financial Statement Footnotes: The Service‘s most recent quarterly report provided financial statements that were generally comparable to those provided by FedEx and UPS in that they included the basic statements of income, balance sheet, and cash flow. However, unlike the Service, FedEx and UPS provided notes to the quarterly financial statements that included explanations on a variety of issues, including changes in accounting policies, business segment information, major new commitments and contingencies, and supplemental cash flow information. The SEC guidance for the content of interim financial statements states, in part, that: ’— disclosure shall be provided where events subsequent to the end of the most recent fiscal year have occurred which have a material impact on the registrant. Disclosures should encompass, for example, significant changes since the end of the most recently completed fiscal year in such items as: accounting principles and practices; estimates inherent in the preparation of financial statements; status of long- term contracts; capitalization including significant new borrowings or modification of existing financing arrangements; and the reporting entity resulting from business combinations or dispositions. Notwithstanding the above, where material contingencies exist, disclosure of such matters shall be provided even though a significant change since year end may not have occurred...“[Footnote 15] These footnote explanations can greatly enhance the reader‘s understanding of the quarterly financial statements. For example, in their quarterly reports, FedEx and UPS each discuss in detail contingent losses due to pending lawsuits, whereas the Service does not present similar information on contingent losses, even though such contingencies exist.[Footnote 16] Another area where footnote disclosures would be helpful to the understanding of the Service‘s quarterly reports is a more detailed breakdown of certain key line items in the financial statements. For example, the Service includes in its income statement a single line item for ’revenues,“ with no further breakdown provided. UPS also reports a single line item for revenue in its income statement, but then provides breakdowns of revenue for each of its reporting segments, including comparative numbers for the prior quarter. Similarly, details of financial statement line items for ’other expenses“ and ’other assets“ are provided in UPS footnotes, which would also be helpful for the Service. ’Other liabilities“ is also a significant line item on the Service‘s balance sheet at $41.8 billion, out of $63 billion in total liabilities. Within this number is approximately $30 billion related to deferred pension liabilities that warrant explanation in the footnotes, as well as other liabilities related to employee benefits that are included in this line item. Further, we have recommended that the Service disclose the amount of postretirement health benefits earned by postal employees and retirees in notes to its financial statements to provide more complete information about these significant obligations.[Footnote 17] In our September 2002 report, we stated that the Service should reassess its accounting treatment for both its pension and postretirement health obligations and reiterated our previous recommendation that the Service should fully disclose its postretirement health obligations because they represent a very material commitment that affects the future viability of the Service. An additional useful footnote disclosure for the recent quarterly report would have been a discussion of the $675 million in supplemental funds appropriated to the Service during fiscal year 2002 to deal with expenses relating to the terrorist attacks of September 11 and subsequent anthrax attacks.[Footnote 18] These funds are significant because the Service, as an entity that is substantially self-financing, generally receives only a small annual appropriation. For example, in fiscal year 2002, the Service was appropriated only about $77 million in its general fiscal year appropriation.[Footnote 19] Further, disclosure of the approximately $4 billion projected to be needed over the next 5 years for improving the Service‘s mail processing systems to protect postal employees and the general public from future attacks through the mail would have informed the reader of the potentially material effect these expenses may have on the Service‘s financial results in the future.[Footnote 20] Consideration of the level of detail included in FedEx‘s and UPS‘s quarterly reports, as well as that of other organizations‘ reports, may be helpful to the Service as it makes enhancements to future quarterly reports. We recognize that judgments must be made about the level of detail that should be provided in quarterly financial reports and that not all quarterly reports will be the same. However, it is clear from recently publicized problems in financial reporting that more detailed information and transparency are called for by both Congress and the public. Such transparency is critical for the Service because of the importance of its financial situation and the implications for stakeholders in making their own financial plans. These factors help support stakeholders‘ need for timely, accurate, and complete financial information that is provided on a consistent basis. The Service‘s Quarterly Financial Reports Lacked Consistent Format and Adequate Availability to the Public: The first quarterly report that the Service posted to its Web site for the third quarter of fiscal year 2001 was a good starting point for providing information to Congress and the public. However, changes in subsequent quarterly reports and their limited availability made it difficult to make comparisons and analyze trends. Table 1 shows quarterly financial information provided since our recommendation. Table 1: The Service‘s Quarterly Financial Reports from Third Quarter Fiscal Year 2001 through Third Quarter Fiscal Year 2002: (Continued From Previous Page) Fiscal quarter; The Service‘s actions. Third quarter, FY 2001; Posted quarterly report to its Web site. Fourth quarter, FY 2001; Annual report, no quarterly report available. First quarter, FY 2002; Posted slide presentation to its Web site. Second quarter, FY 2002; Posted slide presentation to its Web site. Third quarter, FY 2002; Posted quarterly report to its Web site. [End of table] Source: U.S. Postal Service. The Service stated that its audited fiscal year 2001 annual report would serve as its fourth quarter report, which is a common reporting practice for publicly traded companies under SEC‘s rules. Although neither FedEx nor UPS are required to submit fourth quarter reports to the SEC, they do issue press releases on their Web sites that include detailed fourth quarter financial information, such as income statement and balance sheet information, and a discussion of quarterly results. The Service occasionally releases financial information via press releases; however, no press release was provided that included financial results for the fourth quarter of fiscal year 2001. Utilizing press releases to discuss fourth quarter results would compensate for the time lapses between the release of its third quarter report and its annual report, thus providing stakeholders with more timely financial information. Another concern we raised was that the format for quarterly reports was not consistent, so that it was difficult to compare results and analyze trends over time. For the first quarter of fiscal year 2002, the Service changed its reporting format from what was provided in its first publicly available quarterly report for the third quarter of fiscal year 2001. The Service used the Chief Financial Officer‘s (CFO) first quarter slide presentation to the Board of Governors as its quarterly financial report and stated that it was posted on its Web site. In spring of 2001, the Service stated that for future quarterly reports these slide presentations would be used. The Service then posted the CFO‘s slide presentation for the second quarter of fiscal year 2002 to its Web site. We testified in May of 2002 that the CFO‘s slide presentations contained less information than the fiscal year 2001 third quarter report.[Footnote 21] The slide presentations included summary information on total revenues, expenses, and work-hour information, but did not include any discussion of the Service‘s current position and outlook. For the third quarter of fiscal year 2002, the Service posted to its Web site a quarterly report that was similar to its third quarter report for fiscal year 2001. Finally, we raised a concern that the Service‘s financial reports were not readily available to the public. Although the Service has begun to post both its monthly and quarterly reports to its Web site, it only posted the two most recent monthly reports and the latest quarterly report. In comparison, FedEx and UPS make available not only their most recent report, but also past quarterly reports. For example, FedEx‘s quarterly reports dating back to April 1998 and UPS‘s quarterly reports dating back to May 2000 are currently available on their Web sites. Posting past monthly and quarterly reports to the Service‘s Web site would improve accessibility to past financial information and would assist stakeholders in understanding the Service‘s changing financial condition and allow for trend analysis and comparisons. Agency Comments and Our Evaluation: The Service provided comments on a draft of this report in a letter from the Chief Financial Officer dated October 17, 2002. These comments are summarized below and reproduced in enclosure IV. In commenting on our draft report, the CFO stated that the Service would provide additional information in its periodic financial reports to improve stakeholder understanding of its business and that it would retain the data placed on its Web site for 3 years. Specifically, the Service agreed to provide explanations about variances from budgeted amounts, financial expectations, and the projected financial and operational impact of material events or transactions. The CFO pointed out that while the Service received many suggestions for fine-tuning certain disclosures, the financial community expressed overall satisfaction with the quantity and quality of data the Service provides. The CFO commented that the Service publicly discloses information to the PRC during rate case filings that exceeds the amount of information required by SEC-regulated companies and most other government agencies. We acknowledge that the Service provides a significant amount of information in its rate case filings; however, this information is provided only for rate-setting purposes, and rate cases are not filed on a regular cycle. Thus, rate case information does not provide stakeholders timely information about the Service‘s current financial condition and changes to its expected outlook. As we have reported, stakeholders have been surprised by the significant changes that have occurred during the fiscal year to the Service‘s net income estimates and financial outlook. The CFO also stated that our report did not adequately or completely reflect the Service‘s ongoing financial reporting, including its detailed revenue, volume, and weight information; annual billing determinants data; and 4-week Financial and Operating Statements. Our report does provide descriptions of the Service‘s periodic financial information, including its quarterly Revenue, Piece, and Weight reports and its monthly Financial and Operating Statements. As we noted, however, these periodic financial reports do not clearly explain changes in its financial condition, outlook, and results of operations, and have not always been readily available to the public. The Service also provides annual information, such as its Annual Auditor‘s Report and annual billing determinants data, but this information is not available throughout the year for use in periodic analysis. Moreover, the billing determinants data for fiscal year 2001, which ended in September 30, 2001, was not released until October of 2002. With regard to the CFO‘s point about the Service‘s retirement obligations, he cautioned that public discussion of retirement obligations must be undertaken with great care and that the Service would ensure greater public understanding in this area. Due to the magnitude of these costs, the potential effects on current and future ratepayers, and the complexity of the issues involved in reporting retirement-related obligations, we agree that greater public understanding of these obligations is important. The Service‘s announcement regarding its CSRS pension liability at its November 2002 Board of Governors meeting further emphasizes the importance of enhanced disclosure and discussion of the implications of all of its retirement-related obligations. Further, the reduction in future pension obligations would increase the Service‘s options for dealing with its postretirement health obligations and other financial challenges. For these: reasons, we believe that the Service needs to enhance its disclosure of its postretirement health obligations in its financial reports. Importantly, a number of major employers have provided disclosures relating to these types of obligations for several years. In addition, the consolidated financial statements of the U.S. government include extensive disclosures of these obligations on a government-wide basis. Without sufficient disclosure of these obligations in the Service‘s financial statements or the related footnotes, neither Congress nor stakeholders can have adequate information needed to make appropriate decisions related to these issues. We continue to believe that, at a minimum, these obligations should be discussed in the notes to the financial statements. - - - --: We are sending copies of this report to the Chairman and Ranking Minority Member of the Senate Committee on Governmental Affairs, Chairman and Ranking Minority Member of the House Committee on Government Reform, the Service‘s Postmaster General/Chief Executive Officer, the Service‘s Chief Financial Officer, the Chairman of the Postal Rate Commission, and other interested parties. We will also make copies available to others on request. In addition, the report will be available at no charge on the GAO Web site at http://www.gao.gov. If you have any questions about this report or the enclosures, please contact Bernard Ungar at (202) 512-2834, ungarb@gao.gov, or Linda Calbom at (202) 512-8341, calboml@gao.gov. Key contributors to this assignment were Teresa Anderson, Tida Barakat, Joshua Bartzen, Heather Dunahoo, and Michael Fischetti. Bernard L. Ungar: Director, Physical Infrastructure Issues: Signed by Bernard L. Ungar: Linda Calbom: Director, Financial Management and Assurance: Signed by Linda Calbom [End of Section] Enclosure 1: Postal Service Fiscal Year 2002 Third Quarter Financial Report: [See PDF for image] [End of enclosure] FedEx Fiscal Year 2002 Third Quarter Financial Report: [See PDF for image] [End of enclosure] United Parcel Service Quarterly Report: [See PDF for image] [End of enclosure] Comments from the U.S. Postal Service: [See PDF for image] [End of enclosure] (543036): FOOTNOTES [1] In May 2002, we asked the Office of Personnel Management (OPM) to, among other things, estimate how much of the underfunded CSRS pension liability is attributable to the Service. OPM‘s projections indicate that the Service‘s future payments required under current legislation would overfund the CSRS liability by $71 billion over the remaining benefit period. Legislation would be required to modify the existing funding method so as to prevent overfunding of benefits in the future. [2] U.S. General Accounting Office, U.S. Postal Service: Transformation Challenges Present Significant Risks, GAO-01-598T (Washington, D.C.: Apr. 4, 2001). [3] U.S. General Accounting Office, U.S. Postal Service: Deteriorating Financial Outlook Increases Need for Transformation, GAO-02-355 (Washington, D.C.: Feb. 28, 2002). [4] U.S. General Accounting Office, U.S. Postal Service: Accounting for Postretirement Benefits, GAO-02-916R (Washington, D.C.: Sept. 12, 2002). [5] See 17 C.F.R. §240.13a-13. [6] Such risks are typically associated with derivative instruments utilized to hedge changing market conditions and may not be applicable to activities of the Service. [7] See 17 C.F.R. §229.303 (b)(2002). [8] The Service uses a 52-week ’postal fiscal year“ for management purposes that contains 364 days and thus starts and ends on a different day each postal fiscal year. The Service divides each postal fiscal year into 13 accounting periods of 4 weeks each. The first postal quarter corresponds to the first three accounting periods, and the last postal quarter includes the last four accounting periods of the postal fiscal year. [9] GAO-02-355. [10] The Service has a long-standing practice of withholding detailed financial information on the fourth quarter of a fiscal year and the first accounting periods of the following fiscal year until its annual financial statements have been audited and approved by the Board of Governors. The board approved the Service‘s audited financial statements for fiscal year 2001 in December 2001. [11] GAO-02-355, pp. 44-45. [12] Our comparisons were based on the most recent publicly available quarterly reports by the Postal Service, FedEx, and UPS, which covered different periods. The Postal Service‘s third quarter report for fiscal year 2002 covered the period February 23-May 17, 2002, and was made publicly available in July 2002. FedEx‘s third quarter report for fiscal year 2002 covered the period December 1, 2000-February 28, 2002, and was filed with the SEC in April 2002. UPS‘s first quarter report for fiscal year 2002 covered the period January 1, 2002-March 31, 2002, and was filed with the SEC in May 2002. [13] See SEC Rel. Nos. 33-8056; 34-45321; FR-61 (Jan. 22, 2002). [14] The Service did not have a section titled Management‘s Discussion and Analysis in its quarterly report, but it did have similar sections titled ’Operating Results“ and ’Message from the Chief Financial Officer.“ In our analysis, we compared these sections with the MD&A sections of FedEx and UPS quarterly reports. [15] See 17 C.F.R. §210.10-01(a)(5)(2002). [16] A general discussion in the footnotes to the U.S. Postal Service Annual Report 2001 discloses contingent liabilities. [17] In May 1992, we recommended that the Service provide additional information on its postretirement health benefits as part of its annual financial statement (U.S. General Accounting Office, Financial Reporting: Accounting for the Postal Service‘s Postretirement Health Care Costs, GAO/AFMD-92-32, Washington, D.C.: May 20, 1992). The Service did not agree with and did not implement this recommendation. We reiterated this recommendation and also discussed the accounting treatment of these obligations in our recent report, U.S. General Accounting Office, U.S. Postal Service: Accounting for Postretirement Benefits, GAO-02-916R (Washington, D.C.: Sept. 12, 2002). [18] On November 20, 2001, the President released $175 million to the Postal Service from the Emergency Response Fund for expenses relating to the terrorist attacks. In January 2002, the Service was appropriated an additional $500 million for emergency expenses. [19] Public Law 107-67. [20] Public Law 107-117 appropriated $500 million to the Service for emergency expenses and required the Service to develop an Emergency Preparedness Plan with its planned expenditures to support this Plan. [21] GAO-02-694T. GAO‘s Mission: The General Accounting Office, the investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. GAO examines the use of public funds; evaluates federal programs and policies; and provides analyses, recommendations, and other assistance to help Congress make informed oversight, policy, and funding decisions. 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