U.S. Postal Service
The Program for Reassessing Work Provided to Injured Employees Is Under Way, but Actions Are Needed to Improve Program Management Gao ID: GAO-10-78 December 14, 2009Between 50,000 and 60,000 United States Postal Service (Service) employees, or 7 to 8 percent of the Service's workforce, occupied a modified work assignment during fiscal year 2008. The Service must provide these assignments to employees with workplace injuries if work is available to perform within their medical restrictions. Historically, the Service has returned employees to work as soon as possible, partly to reduce its costs for workers' compensation. In 2006, the Service initiated a program, the National Reassessment Process (NRP), to ensure that modified work assignments are medically suitable and necessary to carry out the Service's mission. This requested report addresses (1) the goal of the program, (2) how it is being implemented, and (3) the program's status and outcomes. To perform its work, the Government Accountability Office (GAO) analyzed data and documentation, visited four districts selected to illustrate a range of conditions, and interviewed Service officials.
The goal of the National Reassessment Process is to ensure that all employees in modified work assignments are performing work that is both suitable to their medical restrictions and necessary to the Service's mission. Among other things, the program aims to eliminate what Service officials call "make-work" assignments which, over time, occurred when factors such as increasing automation and declining mail volumes reduced the amount of manual, sedentary, and useful work available for these employees to perform. The number of employees reassessed under the program is not readily available nationwide because the Service does not aggregate district data. However, on September 30, 2008, there were 31,044 employees in modified work assignments, all of whom may have been reassessed under the program. The program is being implemented in three phases in the Service's 74 districts. In Phase 1, the Service ensures that all employee medical records are current, and categorizes the employees based on their medical status. In Phases 2 and 3, the Service attempts to find each employee medically suitable and necessary work. If successful, the Service provides these employees with modified work assignments. However, when suitable work is not available, employees become eligible for wage loss compensation (workers' compensation). Specifically, because employees in Phase 2 have reached their maximum medical improvement, they are not expected to return to work for the Service and, thus, may receive workers' compensation indefinitely, whereas Phase 3 employees are eligible for workers' compensation for only the number of hours they cannot work for the Service. Initially, the Service implemented each phase of the program sequentially; however, in July 2009, it began allowing some districts to conduct Phases 2 and 3 concurrently to expedite the program's completion. The Service has not established milestones for completing the program, but, according to Service officials, they expect the program to be fully implemented by September 30, 2010. After 3 years, none of the Service's districts had completely implemented the program, and implementation in most is far from complete. Available data on employee outcomes are limited and preliminary because implementation is ongoing, and the Service does not track employees who receive medically suitable and necessary work--the goal of the program. The Service achieves program cost savings when, for example, employees return to full duty, retire, resign, or perform modified work assignments. However, when suitable work is not available, some employee outcomes could increase the Service's short- and long-term costs for workers' compensation. For the year ending June 30, 2009, workers' compensation costs totaled about $1.1 billion and, in 2008, the Service estimated that its future liability for these costs totaled about $8 billion. The Service reported to the Congress that the program saved $146 million in fiscal year 2008. However, the Service did not disclose that these reported savings reflect neither the Service's total gross savings nor its net savings, nor any other limitations in its cost estimation methodology.
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Director: Team: Phone:GAO-10-78, U.S. Postal Service: The Program for Reassessing Work Provided to Injured Employees Is Under Way, but Actions Are Needed to Improve Program Management
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
December 2009:
U.S. Postal Service:
The Program for Reassessing Work Provided to Injured Employees Is Under
Way, but Actions Are Needed to Improve Program Management:
GAO-10-78:
GAO Highlights:
Highlights of GAO-10-78, a report to congressional requesters.
Why GAO Did This Study:
Between 50,000 and 60,000 United States Postal Service (Service)
employees, or 7 to 8 percent of the Service‘s workforce, occupied a
modified work assignment during fiscal year 2008. The Service must
provide these assignments to employees with workplace injuries if work
is available to perform within their medical restrictions.
Historically, the Service has returned employees to work as soon as
possible, partly to reduce its costs for workers‘ compensation. In
2006, the Service initiated a program, the National Reassessment
Process, to ensure that modified work assignments are medically
suitable and necessary to carry out the Service‘s mission. This
requested report addresses (1) the goal of the program, (2) how it is
being implemented, and (3) the program‘s status and outcomes. To
perform its work, GAO analyzed data and documentation, visited four
districts selected to illustrate a range of conditions, and interviewed
Service officials.
What GAO Found:
The goal of the National Reassessment Process is to ensure that all
employees in modified work assignments are performing work that is both
suitable to their medical restrictions and necessary to the Service‘s
mission. Among other things, the program aims to eliminate what Service
officials call ’make–work“ assignments which, over time, occurred when
factors such as increasing automation and declining mail volumes
reduced the amount of manual, sedentary, and useful work available for
these employees to perform. The number of employees reassessed under
the program is not readily available nationwide because the Service
does not aggregate district data. However, on September 30, 2008, there
were 31,044 employees in modified work assignments, all of whom may
have been reassessed under the program.
The program is being implemented in three phases in the Service‘s 74
districts. In Phase 1, the Service ensures that all employee medical
records are current, and categorizes the employees based on their
medical status. In Phases 2 and 3, the Service attempts to find each
employee medically suitable and necessary work. If successful, the
Service provides these employees with modified work assignments.
However, when suitable work is not available, employees become eligible
for wage loss compensation (workers‘ compensation). Specifically,
because employees in Phase 2 have reached their maximum medical
improvement, they are not expected to return to work for the Service
and, thus, may receive workers‘ compensation indefinitely, whereas
Phase 3 employees are eligible for workers‘ compensation for only the
number of hours they cannot work for the Service. Initially, the
Service implemented each phase of the program sequentially; however, in
July 2009, it began allowing some districts to conduct Phases 2 and 3
concurrently to expedite the program‘s completion. The Service has not
established milestones for completing the program, but, according to
Service officials, they expect the program to be fully implemented by
September 30, 2010.
After 3 years, none of the Service‘s districts had completely
implemented the program, and implementation in most is far from
complete. Available data on employee outcomes are limited and
preliminary because implementation is ongoing, and the Service does not
track employees who receive medically suitable and necessary work”the
goal of the program. The Service achieves program cost savings when,
for example, employees return to full duty, retire, resign, or perform
modified work assignments. However, when suitable work is not
available, some employee outcomes could increase the Service‘s short-
and long-term costs for workers‘ compensation. For the year ending June
30, 2009, workers‘ compensation costs totaled about $1.1 billion and,
in 2008, the Service estimated that its future liability for these
costs totaled about $8 billion. The Service reported to the Congress
that the program saved $146 million in fiscal year 2008. However, the
Service did not disclose that these reported savings reflect neither
the Service‘s total gross savings nor its net savings, nor any other
limitations in its cost estimation methodology.
What GAO Recommends:
GAO recommends that the Service establish program completion timelines,
track and measure outcomes, and disclose limitations of its reported
cost savings. The Service agreed with GAO‘s third recommendation and
disagreed with the other two. While GAO modified one recommendation in
response to the Service‘s comments, GAO retained all three to encourage
program completion, accountability, and transparency.
View GAO-10-78 or key components. For more information, contact Phillip
Herr, (202) 512-2834, or Herrp@gao.gov.
[End of section]
Contents:
Letter:
Background:
The Goal of the NRP Is to Ensure That All Employees in Modified Work
Assignments Are Performing Medically Suitable, Necessary Work:
The Service Is Implementing the NRP in Three Phases, Which Take Many
Months to Complete:
Despite Incomplete NRP Implementation, the Service Estimated $146
Million in Savings during Fiscal Year 2008:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Methodology for Determining Number of Service Employees
Who Occupied (or Could Have) a Modified Work Assignment:
Appendix III: Number, Percentage, and Distribution of Modified Work
Assignments Nationwide during Fiscal Year 2008:
Appendix IV: Description of NRP Activities, by Phase and Step:
Appendix V: Comments from the United States Postal Service:
Appendix VI: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: The Four Largest Postal Unions and the Primary Crafts Each
Union Represents:
Table 2: Number, Percentage, and Distribution of Service Employees in
Modified Work Assignments Nationwide during Fiscal Year 2008:
Figures:
Figure 1: How a Physician's Determination about a Service Employee's
MMI Status Affects the Type of Modified Work Assigned to the Employee:
Figure 2: Key NRP Activities, Stages, and Possible Employee Outcomes,
by Phase:
Figure 3: NRP Outcomes Experienced by Service Employees in Modified
Work Assignments:
Figure 4: Overall Status of NRP Implementation, by Phase, as of August
31, 2009:
Figure 5: Status of NRP Implementation for Phases 1 and 2, by Step, as
of August 31, 2009A:
Figure 6: Description of NRP Activities in Phase 1:
Figure 7: Description of NRP Activities in Phase 2:
Figure 8: Description of NRP Activities in Phase 3:
Abbreviations:
DOL: Department of Labor:
GAO: Government Accountability Office:
MMI: maximum medical improvement:
NRP: National Reassessment Process:
NWA: no work available:
OWCP: Office of Workers Compensation Programs:
Service: United States Postal Service:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
December 14, 2009:
The Honorable Stephen F. Lynch:
Chairman:
Subcommittee on Federal Workforce, Postal Service, and the District of
Columbia:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Danny K. Davis:
House of Representatives:
In fiscal year 2008, the United States Postal Service (Service) had
about 748,000 employees, representing about 25 percent of all federal
employees. These employees also accounted for about 42 percent of all
federal traumatic workplace injuries and occupational illnesses
(injuries).[Footnote 1] According to Service officials, the high rate
of employee injuries arises largely from the often physically
demanding, industrial, and highly repetitive nature of their work. Some
injured employees recover from their injuries quickly and return to
work without medically prescribed physical restrictions (medical
restrictions), while others require long-term, modified work
assignments to accommodate their medical restrictions. Based on our
analysis, there were between 50,000 and 60,000 postal employees, or
about 7 to 8 percent of the Service's workforce, in these assignments
at some point during fiscal year 2008, the most recent year for which
complete data were available. Not included in this number are employees
with workplace injuries who have medical restrictions that preclude
them from returning to work for the Service in any capacity.[Footnote
2]
When employees are able to return to work after a compensable workplace
injury, federal agencies, including the Service, are required to employ
them if work is available that they can accomplish within their medical
restrictions.[Footnote 3] In the 1990s, the Service aggressively
pursued the return of employees to work as soon as possible as a means
to (1) help employees recover more quickly and stay up to date with
workplace changes and (2) reduce the Service's costs for workers'
compensation.[Footnote 4] According to senior headquarters officials,
the Service's previous practice often resulted in bringing employees
back to work in "make-work" assignments without regard to productivity.
In addition, they said that the practice created a workplace culture in
which employees believed they were entitled to modified work
assignments, regardless of whether the assignment was needed for the
Service's mission.
In 2006, the Service introduced a new, agencywide initiative--the
National Reassessment Process (NRP)--to revise its practices for
assigning modified work to injured employees. The Service's Office of
Health and Resource Management is responsible for implementing the NRP.
Numerous other postal officials are also involved through a phased
implementation approach. The NRP is being carried out in the Service's
74 districts,[Footnote 5] with supervision from headquarters and area
officials, and focuses on reassessing employees in modified work
assignments to determine whether the assignments are (1) within the
employees' medical restrictions (medically suitable work) and (2)
necessary to carry out the Service's mission.
Because of congressional interest in the large number of postal
employees in modified work assignments and whether these employees are
being productively employed, we were asked to review the NRP. This
report addresses the following objectives: (1) What is the goal of the
NRP? (2) How is the program being implemented? (3) What is the status
of the NRP, and what outcomes have been achieved?
To address these objectives, we reviewed and analyzed, among other
documentation, (1) applicable laws, regulations, and postal policies
and procedures for protecting federal employees who sustain compensable
workplace injuries, including their rights with respect to job
restoration; (2) documentation describing the NRP's goal and the
process for implementing the initiative, as well as available data on
its status and outcomes; and (3) documentation and views on the NRP
from the four largest postal unions. We also interviewed a wide range
of Service officials, and officials within the Department of Labor's
(DOL) Office of Workers' Compensation Programs (OWCP), which makes wage
loss and other payments to federal employees with compensable workplace
injuries. To determine the number of employees in modified work
assignments during fiscal year 2008, we analyzed data from each of the
Service's districts and headquarters and determined that the Service's
data were sufficiently reliable for our reporting purposes. To obtain
views on the NRP, we also visited four postal districts--San Francisco,
Westchester, the Dakotas, and Dallas--and contacted officials in four
other districts--Sierra Coastal, Southeast New England, Los Angeles,
and Santa Ana.[Footnote 6] Finally, we reviewed prior reports and
literature on the value of returning injured employees to work as soon
as possible; reports on the Service's declining financial
circumstances, including our high-risk report and the Service's recent
annual financial reports and comprehensive statements for fiscal years
2007 and 2008,[Footnote 7] which included data on the NRP's cost
savings; and guidance on key principles for managing agency initiatives
and reporting program outcomes. Additional information on our (1) scope
and methodology, including information on how we selected the eight
postal districts we contacted and (2) methodology for determining the
number of employees with workplace injuries who occupied (or could have
occupied) a modified work assignment during 2008 are provided in
appendixes I and II, respectively.
We conducted this performance audit from October 2008 to December 2009,
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Background:
The Service's mission is to provide universal mail service 6 days a
week to, as nearly as practicable, the entire U.S. population. The
Service delivered mail to over 149 million addresses in 2008 and is
broadly organized into nine large, geographic areas. Each of these
areas comprises many postal districts, which collectively accomplish
the Service's mission. To carry out its mission, the Service maintains
a network of facilities, including over 36,700 retail and delivery
facilities, such as local post offices and approximately 400 major mail-
processing facilities. In addition, the Service operates one of the
largest vehicle fleets in the United States. The Service also employs
career and noncareer employees to carry out its mission.[Footnote 8]
Most of the Service's employees are in occupations (crafts) represented
by one of the four largest postal unions. Table 1 identifies the four
largest unions and the primary crafts each represents.
Table 1: The Four Largest Postal Unions and the Primary Crafts Each
Union Represents:
Union: American Postal Workers Union;
Primary crafts represented:
Clerks: Provide customer services at retail and delivery facilities
including selling postage, accepting packages for shipment, and
dispensing Certified Mail or Registered Mail. They also operate
machinery for sorting mail in facilities like processing and
distribution plants;
Technicians and mechanics: Diagnose and repair equipment and vehicles.
Union: National Association of Letter Carriers;
Primary crafts represented:
City carriers: Organize mail into delivery sequence at postal
facilities and deliver the mail along established routes, either by
foot, or in a vehicle.
Union: National Postal Mail Handlers Union;
Primary crafts represented:
Mail handlers: Load, unload, and move bulk mail, including sacks and
trays at processing facilities;
Equipment operators: Move mail throughout a facility using equipment
such as a forklift or pallet truck.
Union: National Rural Letter Carriers' Association;
Primary crafts represented:
Rural carriers: Organize mail into delivery sequence and deliver it by
vehicle along established rural routes that vary in length. They also
collect mail and sell stamps, money orders, and other products to
customers along their routes.
Source: GAO analysis of Service documentation.
[End of table]
Postal employees generally sustain two types of employment-related
injuries--traumatic injuries and occupational illnesses. Traumatic
injuries are linked to a specific event, such as when a letter carrier
trips and falls while delivering mail, or when an employee is injured
operating automated machinery in a processing plant. In contrast,
occupational illnesses can develop from prolonged workplace exposure
and repetitive motion activities, such as when a rural letter carrier
develops a back, shoulder, or rotator cuff injury by repeatedly
twisting and stretching to reach mail in the back of his or her
vehicle.
When federal employees suffer a compensable workplace injury, they are
entitled to available work within their medical restrictions, in
accordance with the Rehabilitation Act of 1973.[Footnote 9] The right
to available work and the obligation to provide it (restoration rights)
are contained in statute and regulations promulgated by the Office of
Personnel Management, which has delineated different job restoration
rights for employees, depending on their recovery status.[Footnote 10]
These rights are also specified in various Service manuals, including
the Employee and Labor Relations Manual. According to this manual, the
Service will provide the following:
* "rehabilitation" assignments to an employee "when the effects of the
injury are considered permanent and/or the employee has reached his/her
maximum medical improvement" (MMI), which means that, according to the
employee's treating physician, the employee is unlikely to recover
further; and:
* "limited duty" assignments to an employee who has not reached his or
her MMI and is expected to fully recover.
Service employees remain in limited duty assignments until either they
fully recover and return to work (i.e., return to full duty) or their
physician determines that they have reached their MMI. Once a physician
determines that an employee has reached his or her MMI and is able to
work for the Service, the Service may provide the individual with a
rehabilitation work assignment. If an employee is unable to work for
the Service, the Service refers the employee to OWCP for wage loss
compensation.
Under the Federal Employees' Compensation Act and implementing
regulations, injured employees must be examined by a medical officer or
approved physician, the results of which are to be provided to the
employer--in this case the Service. If a physician specifies medical
work restrictions for the employee, the Service must consider these
restrictions in providing a modified work assignment. For example, if
after a compensable on-the-job injury, a physician determines that a
city carrier can walk only 2 hours a day, the Service may try to find
the employee a driving mail route that will allow the employee to
remain seated most of the day. Similarly, if a clerk's medical
restrictions specify that the clerk can neither stand nor extend his or
her arms above shoulder height, the Service could physically lower the
workstation the clerk uses to organize mail into delivery route
sequence so that the task can be done while seated.
The Service's Employee and Labor Relations Manual specifies different
job restoration rights, depending on the length of time between (1)
OWCP's approval of the employee's injury claim for compensation and (2)
the date that the employee's physician specified that the employee
reached his or her MMI.[Footnote 11] Figure 1 illustrates how a
physician's determination about whether an employee has (or has not)
reached his or her MMI affects the type of modified work assignment
provided.
Figure 1: How a Physician's Determination about a Service Employee's
MMI Status Affects the Type of Modified Work Assigned to the Employee:
[Refer to PDF for image: illustration]
Injured employees:
Employees injured off the job[A];
Employees injured on the job:
* Employees who have not yet reached their MMI;
* Employees in limited duty assignments.
Employees injured on the job:
* Employees who have reached their MMI;
* Employees in rehabilitation assignments:
- Employees who reached MMI in less than one year;
- Employees who reached MMI in more than one year.
Source: GAO analysis of Service data.
[A] In some cases, the Service also provides modified work assignments
to employees injured off-the-job. These assignments, however, are
beyond the scope of our review.
[End of figure]
OWCP handles employees who suffer a compensable on-the-job injury by
placing the employees on either its (1) "periodic rolls" (for employees
with long-term or permanent injuries that are expected to keep them out
of work for more than 90 days) or (2) "daily rolls" (i.e., employees
who are expected to return to work within 90 days). In general,
employees are entitled to receive 66 and two-thirds percent of their
basic compensation during the period of their disability.[Footnote 12]
As discussed in appendix II, our analysis of Service data indicates
that 50,031 employees with workplace injuries occupied a modified work
assignment during fiscal year 2008. Up to 9,740 other employees could
have been in such an assignment during the same period.[Footnote 13]
Collectively, these employees represent about 7 to 8 percent of the
Service's workforce in fiscal year 2008. In addition, our analysis
found wide variability in the number, percentage, and distribution of
employees in these assignments among districts. For example, in Dallas,
over 12 percent of all employees in the district at the end of fiscal
year 2008 were in a modified work assignment; while in the Metro
Caribbean district, fewer than 2 percent occupied one of these
assignments at the end of that fiscal year. Additional information on
the nationwide distribution of employees in modified work assignments
during fiscal year 2008, by district, is available in appendix III.
According to senior postal officials, in the past, the Service
aggressively returned employees to work as soon as possible. This
practice occurred when the Service (1) had many manual, sedentary jobs
that were useful for its injured employees to perform (e.g., filling
out customers' change of address forms manually) and (2) enjoyed steady
growth in mail volume and revenues. Neither of these circumstances
exists today. In addition, as we previously reported[Footnote 14],
since 2007, the Service has been experiencing its steepest decline in
mail volume since the Great Depression. In fiscal year 2009, the
Service incurred an unprecedented net loss of $3.8 billion and
experienced a decline in mail volume of over 25 billion pieces--its
steepest decline ever.
To respond to its deteriorating financial circumstances, the Service
has, among other actions, downsized its workforce through "early out"
retirement offers, closed some facilities, removed underutilized mail
collection boxes, realigned its delivery routes to enhance efficiency
(route realignments), and eliminated one of three work shifts (tours)
in many mail processing and distribution facilities and about 114
million work hours from its 2009 operations.
Given the Service's deteriorating financial condition, in July 2009, we
placed the Service on our list of high-risk areas needing attention by
the Congress and the executive branch to achieve broad-based
transformation.[Footnote 15] At that time, we reported that a key
action for reducing the Service's costs was to reduce its employee
costs for compensation and benefits and suggested that the Service
align costs and revenues, including its costs for compensation and
benefits. These costs account for about 80 percent of the Service's
costs.
When implementing major initiatives, agencies--such as the Service--
need to ensure that these initiatives will be accomplished effectively
and efficiently. Fundamentally, the success of any initiative, such as
the NRP, begins at the top--with clear management support for the
purpose, goals, and time frames established for completing the
initiative. Clear upper-level support and direction help managers
throughout the organization properly prioritize the initiative relative
to others. Such support and direction also help ensure that managers
devote sufficient time and resources to complete the initiative
successfully and in a timely manner. In addition, to help ensure the
success of key initiatives, an agency should establish measures for
determining whether program goals are being met, such as measures of
expected outcomes. Furthermore, when an agency reports data on these
outcomes to the Congress and others, the agency needs to ensure that
the data are reliable and understandable, and that any limitations
applicable to the data are clearly disclosed.[Footnote 16]
The Goal of the NRP Is to Ensure That All Employees in Modified Work
Assignments Are Performing Medically Suitable, Necessary Work:
The Service began implementing the NRP in November 2006 to help ensure
that all postal employees placed in modified work assignments because
of a workplace injury are performing work that is medically suitable
and necessary to the execution of the Service's mission. Although the
number of employees being reassessed under the NRP is available at a
district level, this number is not readily available nationwide because
the Service does not aggregate these data. However, according to senior
headquarters officials responsible for implementing the NRP, there were
31,044 employees in modified work assignments on September 30, 2008,
all of whom were potentially subject to review under the NRP, depending
on their work status when the Service began implementing the NRP in
their district. In addition, according to these officials, employees
injured after the NRP's initiation were "rolled into" the NRP process
at each applicable district.[Footnote 17]
According to Service and DOL officials, the Service began accumulating
large numbers of employees in modified work assignments when it was
financially healthy and before the introduction of widespread
automation, which decreased the availability of manual and sedentary
jobs that, nevertheless, were useful to the execution of the Service's
mission. Many of these jobs have disappeared over time and, thus,
managers began assigning make-work, such as answering phones or serving
as a lobby greeter, to accommodate employees with workplace injuries--
even when these assignments were not required at a particular facility.
Thus, according to senior headquarters officials, they will consider
the NRP a success when every employee with a workplace injury is
working in a modified work assignment that accommodates both the
employee's medical restrictions and the Service's needs.
While the Service specifically precluded make-work assignments, senior
headquarters officials purposely did not specify which of the Service's
work assignments nationwide involve necessary work or, alternatively,
identify those assignments that do not. According to these officials,
they did not do so because the Service's needs vary by location and, as
a consequence, they wanted to provide facility supervisors and district
managers with flexibility to identify necessary work in their
facilities and districts. Thus, under the NRP, work assignments that
might be considered unnecessary in one facility may be considered
necessary in another, depending on the facility's needs. While the
Service purposely did not specify a list of necessary work assignments,
it precluded local managers from assigning work to an injured employee
when the work is part of another employee's duties. According to
officials at the four districts we visited, prior to the NRP, they
routinely assigned portions of one or more employees' duties to other
employees to create modified work assignments for injured workers.
The Service Is Implementing the NRP in Three Phases, Which Take Many
Months to Complete:
The Service is implementing the NRP in three phases, involving a total
of 56 steps and the participation of a wide variety of officials at all
levels of the organization and, in some cases, affected employees and
their union representatives. Some employee outcomes arising from the
NRP vary by phase, while others do not. For example, during any phase
of the NRP, employees may return to full duty, retire, or resign from
the Service. In addition, assuming that necessary and medically
suitable work exists, employees may continue working in either a new
assignment or their prior modified assignment. Employee outcomes vary
between Phases 2 and 3, however, when sufficient necessary and
medically suitable work is not available for the employees to perform.
Until recently, the Service has been implementing the NRP in a
staggered manner, with each phase performed sequentially. However,
instead of waiting for each of the districts to complete Phase 2 before
initiating Phase 3, in July 2009, the Service began implementing these
phases concurrently. According to senior headquarters officials, the
Service took this approach to stimulate progress and expedite the NRP's
overall implementation. While the NRP takes many months to fully
implement in each district, in part, because large numbers of employees
are being reassessed, senior Service officials told us in August 2009
that they expected the entire NRP process will be completed by
September 30, 2010. However, given that none of the districts has
completed all of the phases of the NRP since its initiation more than 3
years ago, and absent established milestones and clear program
priorities for completing the NRP nationwide, it is unclear when the
NRP will be completed.
The NRP Has Three Phases and Involves 56 Prescribed Steps:
The NRP has three phases,[Footnote 18] involving 56 prescribed steps.
Phase 1 principally involves identifying all employees with compensable
on-the-job injuries; ensuring that information about all employees,
such as their medical restrictions, is up to date; and categorizing the
employees into one of two groups, according to their medical status
(i.e., whether they have, or have not, reached their MMI). The Service
uses the employees' updated information for Phases 2 and 3, during
which the Service attempts to find medically suitable and necessary
work for each employee; however, the focus of these phases varies--
depending on whether an employee has reached his or her MMI (Phase 2)
or has not reached his or her MMI (Phase 3). Figure 2 describes the key
NRP activities, stages, and possible employee outcomes in each of the
three phases. See appendix IV for a complete list of all NRP steps, by
phase.
Figure 2: Key NRP Activities, Stages, and Possible Employee Outcomes,
by Phase:
[Refer to PDF for image: table]
Phase 1 – All employees with workplace injuries;
Stages in phase: None;
13 steps;
Key activities:
* Identify all employees with workplace injuries who are in (or capable
of working in) modified work assignments;
* Ensure that employee information, including medical documentation of
the employee‘s work restrictions, is up to date and, where necessary,
request updated documentation;
* Ensure that all employees are properly classified according to
whether they have, or have not, reached their MMI;
* Validate that all records have been updated and that employees have
been properly sorted according to their physician‘s determination of
each employee‘s MMI status (done by headquarters officials);
Possible employee outcomes: Employee may:
* Return to full duty if the employee‘s medical documentation
indicates, for example, that he or she has fully recovered from his or
her injury.
Phase 2 – Employees who have reached their MMI;
Stages in phase:
* Job search (9 steps);
* Job offer (6 steps);
* No work available (NWA) (15 steps);
30 steps;
Key activities:
* Identify all necessary work available within the district.[A, B];
* Assess whether the available work can be accomplished within an
employee‘s medical restrictions;
* Where medically suitable work is available, prepare a job offer for
each employee. (This may be either a new job offer, or a job reflecting
the employee‘s prior modified assignment);
* When no medically suitable work is available, develop a preliminary
list of employees with NWA determinations for review and approval by
district management, and double check each of these employees‘ files
for accuracy to ensure, for example, that job searches for each
employee were performed correctly;
* Approve preliminary NWA list and meet with unions to discuss the
list;
* Notify affected employees of the Service‘s NWA determination;
* Meet with employee and, when requested, the employee‘s union
representative to discuss the job offer and provide the employee with
an opportunity to update his or her medical records[C];
Possible employee outcomes: Employee may:
* Be placed in a modified work assignment (i.e., either the same
medically suitable and necessary work assignment that he or she
performed before the NRP or a new medically suitable and necessary work
assignment);
* Return to full duty;
* Retire or resign from the Service; or;
* Receive an NWA determination”(i.e., the Service was unable to find a
necessary and medically suitable work assignment for the employee).
Phase 3 – Employees who have not reached their MMI;
Stages in phase:
* Implementation (6 steps);
* Job offer (4 steps)[E];
* New medical documentation/new injury (3 steps);
13 steps;
Key activities:
* Identify all available necessary work (from work conducted during
Phase 2)[A];
* Update records to ensure that all employees who have not reached
their MMI are listed and that all employees‘ files are complete and
still up to date;
* Conduct job searches within the Service for employees and hold work
status meetings with employees to discuss possible work assignments[D];
* Assess employees with new medical documentation or a new injury to
determine whether medically suitable and necessary work is available
for these employees;
Possible employee outcomes: Employee may:
* Return to full duty, or;
* Retire or resign from the Service;
The remaining employees receive one of three possible work
determinations:
* a ’full day work“ determination”-(i.e., the number of hours of
medically suitable and necessary work identified by the Service matches
the number of hours the employee is allowed to work by his or her
physician);
* a ’partial day work“ determination-”(i.e., the number of hours of
medically suitable and necessary work identified by the Service is less
than the number of hours the employee is permitted to work;[E] or;
* a ’complete day no work“ determination”(i.e., the Service could not
identify any necessary work within the employee‘s craft, tour, and
facility, and within his or her medical restrictions).[E]
Source: GAO analysis of Service data.
[A] The lists of necessary work are developed by each district's
Service operations managers and are subject to change, based on
agencywide or local changes in job availability resulting from, among
other matters, reductions in staffing due to, among other actions,
route realignment activities, and fluctuations in mail volume.
[B] Beginning in July 2009, the Service began allowing certain
districts implementing Phase 2--those that had already developed their
list of necessary work (Phase 2, step 5)--to begin simultaneously
implementing Phase 3. This matter is discussed in more detail later in
this report.
[C] These meetings include a review and discussion of the proposed
employee job offer and are designed to elicit feedback from the
employee on (1) his or her ability to perform the duties identified and
(2) other necessary work that might be available and medically suitable
for the employee to perform. The Service is expected to consider the
employee's feedback and, consequently, can make changes to the job
offer on that basis.
[D] "Work status" refers to the stage in which facility supervisors
determine what, if any, necessary work is available for each employee.
[E] Before the Service provides a "partial day work" or a "complete day
no work" determination to an employee, it must first search for
necessary work in the employee's facility. If suitable work is not
found, the Service must expand the search to other postal facilities
within the district's boundaries.
[End of figure]
Each of the NRP phases is highly participative, involving a wide
variety of postal employees representing headquarters, areas, and
districts, including senior operations managers, injury compensation
specialists, and medical staff in the Service's districts. Officials
from health and resource management, injury compensation, and labor
relations offices, and the Office of General Counsel in headquarters
also participate in the NRP. In Dallas, Texas, for example, we met with
more than 25 postal employees who, in addition to their normal duties,
also were involved in carrying out some portion of the NRP. Many of
these individuals also served as members of the district's assessment
team that implements many of the NRP-related tasks. According to senior
headquarters officials, the average size of the district assessment
teams ranges from six to eight officials. In addition, because the NRP
requires discussions between managers and affected employees when, for
example, they receive an NWA determination, the employees and, when
required, their union representatives, also participate in the NRP.
Currently, the Service is using the NRP process principally to reassess
the 31,044 employees who were in modified assignments on September 30,
2008 (i.e., the "backlog" of these employees).[Footnote 19] However, in
the future, the focus of the process will be to determine whether
medically suitable and necessary work assignments are available for (1)
newly injured employees and (2) employees who have reached their MMI
and, thus, require reevaluation. The future process will be referred to
as the "National Assessment Process," according to senior headquarters
officials.
Some Employee Outcomes Vary, Depending on Phase:
According to Service officials, during any phase of the NRP, employees
may return to full duty (i.e., return to their preinjury job), retire,
or resign from the Service. In addition, assuming that necessary and
medically suitable work exists, the outcomes for employees in Phases 2
and 3 are the same--employees may continue working in either a new,
medically suitable assignment, or in their prior modified assignment.
[Footnote 20] Employee outcomes vary between these phases, however,
when sufficient necessary and medically suitable work is not available
for the employees to perform. For example, when work is not available,
the Service provides employees in Phase 2 (those who have reached their
MMI) with an NWA determination and sends them home, along with the
necessary forms for filing a wage loss claim to receive compensation
from DOL's OWCP for the number of hours they could not work for the
Service.[Footnote 21] In contrast, in Phase 3, when sufficient
necessary and medically suitable work is not available, the Service
provides employees who have not reached their MMI with either a (1)
"partial day work" determination or a (2) "complete day no work"
determination. These employees also are referred to DOL's OWCP for wage
loss compensation.[Footnote 22] Figure 3 illustrates the various NRP
outcomes experienced by employees in modified work assignments,
depending on the employees' MMI status.
Figure 3: NRP Outcomes Experienced by Service Employees in Modified
Work Assignments:
[Refer to PDF for image: illustration]
Employees in modified work assignments: NRP:
* Return to full duty;
* Retire or resign;
* NWA for employees who have reached their MMI (referred to OWCP):
OWCP:
- Return to full duty (upon successful appeal)[A];
- Retire or resign (decline OWCP);
- Vocational rehabilitation;
- New occupation/employer;
- Daily or periodic rolls;
* Necessary work assignments for employees who have reached their MMI;
* Daily work determinations for employees who have not reached their
MMI:
- Full daywork;
- Partial daywork
- Complete day no work;
- Daily or periodic rolls;
NRP: Administered by the Service, except for OWCP, which is administers
by DOL.
Source: GAO analysis of Service data.
[A] Employees may appeal, file suit, or grieve, if applicable, work
determinations arising from the NRP.
[End of figure]
Another distinction between Phases 2 and 3 relates to the frequency of
employee outcome determinations. Phase 2 NWA determinations, for
example, occur once[Footnote 23] and, as discussed previously, result
in the employee's referral to OWCP for wage loss compensation. Because
these individuals have reached their MMI, according to senior
headquarters officials, they likely would be placed on OWCP's "periodic
rolls." Thus, the senior headquarters officials said, they do not
expect these employees will ever return to work for the Service. In
contrast, Phase 3 "full day work," "partial day work," and "complete
day no work" determinations are dynamic and subject to frequent change,
sometimes on a daily basis, because of fluctuations in factors such as
staff availability and mail volume that affect the availability of
necessary and medically suitable work. Thus, depending on the
availability of work, postal managers may be required to make daily
determinations about whether suitable work is available for these
employees.
Each of these three Phase 3 employee outcomes has somewhat different
consequences for an employee, including the frequency with which the
employee is expected to report to the Service for possible work and the
length of his or her anticipated duration on OWCP's compensation rolls.
For example, when a facility supervisor determines that there is no
necessary and medically suitable work available for an employee to
perform (i.e., a "complete day no work" determination), the employee is
sent home and instructed to return to work only if the employee's (1)
medical restrictions change or (2) supervisor informs him or her that
necessary work has become available for the employee to perform. In
contrast, employees with "full day work" [Footnote 24] and "partial day
work" determinations are required to report to work every day to see if
necessary work is available for them to perform. These employees are
eligible to receive wage loss compensation from OWCP, depending on the
number of hours the employees could not work for the Service. However,
whether OWCP places them on its "periodic rolls" or "daily rolls," is
likely to depend on how long the Service estimates the employee will be
out of work.[Footnote 25]
The Service Staggered the NRP's Implementation and, Until Recently,
Required Each Phase to Be Implemented Sequentially:
After spending about 3 years developing the NRP, the Service began
implementing the NRP nationwide in November 2006. The Service initiated
the NRP in a staggered manner, varying the dates when districts within
an area could begin Phase 1. According to senior headquarters
officials, this approach was needed to train, assist, and oversee the
NRP's initiation in each of the districts. In addition, once
implementation began, the Service required each district to carry out
the three NRP phases sequentially. Specifically, each district had to
complete each step in a phase before it could proceed to the next step
in the phase and, similarly, it had to complete each phase before
proceeding to the next one. According to senior headquarters officials
responsible for implementing the NRP, the sequential approach was
needed to ensure that each of the Service's districts implemented the
NRP correctly and consistently. Furthermore, to help ensure this
objective would be realized, according to these officials, they
purposefully did not provide a district with guidance for implementing
the next NRP step until they had (1) determined that the district had
implemented the prior step correctly and (2) approved the district to
start the next step, or phase.[Footnote 26]
Until recently, the Service's implementation of the NRP was confined to
Phases 1 and 2. However, instead of waiting for each of the districts
to complete these phases before initiating Phase 3, in July 2009, the
Service began implementing Phases 2 and 3 concurrently for some
districts. Senior headquarters officials told us that they did this to
stimulate progress within the districts and, consequently, to expedite
the NRP's overall implementation. According to these officials, this
decision was necessary, in part, because area and district managers'
commitment to the NRP's timely implementation varied greatly between
the Service's areas and districts. They explained that, in addition to
the daily effort required to "move the mail," managers must
simultaneously implement a host of other operational initiatives.
According to senior headquarters officials, districts are now
"eligible" to begin simultaneously implementing Phases 2 and 3 when
they have identified all of their necessary work assignments (Phase 2,
step 5). However, the Service is staggering the introduction of Phase 3
in the districts, much as it did the earlier phases of the NRP.
Specifically, at the conclusion of our review, senior headquarters
officials were precluding managers in each of the Service's nine large,
geographic areas from initiating Phase 3 in more than one district at a
time.[Footnote 27]
Absent Time Frames and Clear Program Priorities It Is Unclear When the
NRP Will Be Completed Agencywide:
The Service initiated the NRP without establishing milestones or clear
program priorities for its completion. According to senior headquarters
officials, they intentionally did this because they do not have the
authority to require area and district managers to prioritize the NRP's
completion over competing operational initiatives. In addition, the
officials were unable to identify or provide any Service documentation:
* describing, among other matters, upper level management's support for
the purpose of the initiative and time frames for completing it, or:
* specifying the NRP's strategic importance relative to the Service's
other initiatives.
Despite the absence of an overall implementation time frame, progress
has been made. Of the 62 districts implementing Phase 2 as of August
31, 2009, almost one-half (30) had been doing so for more than 1 year.
Of these, 5 districts had been implementing Phase 2 for longer than 2
years, and 9 others had been implementing this phase for more than 18
months. Senior headquarters officials acknowledge that, after 3 years,
none of its districts have fully implemented the NRP, largely because
of (1) the large number of employees being reassessed, (2) competing
demands on the managers' time resulting from the ongoing implementation
of various Service initiatives, and (3) the rigorous nature of the NRP.
In addition, these managers explained that certain NRP steps, such as
the job search process for each employee, are particularly time-
consuming. Specifically, the Service's Employee and Labor Relations
Manual requires postal managers to "make every effort" to identify
potential positions for employees who have reached their MMI. In
addition, the manual specifies that the Service's job offers "should
minimize any adverse or disruptive impact on the employee." Thus, in
conducting job searches for these employees, postal managers must first
look for necessary and medically suitable work in each employee's
craft, tour, and facility. If this search does not identify a necessary
and medically suitable assignment, postal managers must conduct
additional searches to try to find work for the employee within his or
her current facility (i.e., work in a different craft or tour).
[Footnote 28] If work cannot be identified for an employee at his or
her current facility--for employees who reached their MMI in 1 year or
less--managers must search for necessary and medically suitable work
within each employee's commuting area. If still unsuccessful, the
Service must (for these employees) expand its job search to other
facilities beyond the boundary of each employee's current district.
[Footnote 29]
According to senior headquarters officials, the time and resources
required to correctly and consistently implement the NRP are necessary
to ensure that each employee's job restoration rights are fully
protected. These officials also noted that the rigorous process is
needed because the NRP can affect whether an employee retains a postal
job. They further explained that the methodical nature of the NRP
process:
* helps ensure that the Service complies with all applicable laws,
regulations, and contractual obligations related to employees with
workplace injuries, and:
* decreases the likelihood of successful grievances, appeals, and other
actions against the Service.[Footnote 30]
Senior headquarters officials told us that in 2006 they initially
expected that all phases of the NRP would be completed by January 2010.
The NRP's implementation, however, has taken longer than anticipated.
Thus, as of August 2009, these officials estimated that the entire
process would be completed by September 30, 2010. However, without
specific milestones and clear upper management support across the
Service's areas and districts, it is unclear when the NRP will be
completed.
Despite Incomplete NRP Implementation, the Service Estimated $146
Million in Savings during Fiscal Year 2008:
While the implementation of the NRP is incomplete, the initiative has
begun to produce cost savings. These savings resulted from the
placement of injured employees in medically suitable and necessary work
assignments that contribute to the Service's bottom line, as well as
from retirements and resignations. Data on these outcomes, however, are
both limited and preliminary, partly because the Service does not track
or aggregate information on all employee outcomes. Moreover, although
some outcomes, such as retirements, result in cost savings, others,
such as NWA determinations, result in short-and, possibly, long-term
cost increases. The Service reported in its most recent comprehensive
report to the Congress that it saved $146 million in fiscal year 2008
as a result of the NRP, but it reported these savings without
disclosing the limitations that applied. Specifically, the estimate
accounted for neither (1) all potential savings (total gross savings)
nor (2) additional costs resulting from some employee outcomes and the
cost of implementing the NRP and thus was not an estimate of total net
savings after costs.
NRP Implementation Is Incomplete:
As discussed, the Service did not set specific time frames for
completing the NRP or establish program priorities for its completion
nationwide, and implementation, thus far, has taken longer than senior
headquarters officials expected. While the NRP began in 2006, according
to data provided by the Service, none of the districts had completed
all phases of the NRP as of August 31, 2009.[Footnote 31] Specifically:
* 69 of the Service's 75 districts (92 percent) had completed Phase 1
of the NRP as of August 31, 2009,[Footnote 32] and the remaining 6
districts had nearly completed this phase;
* 7 of 75 districts (9 percent) had completed Phase 2, 62 districts (83
percent) were in the process of implementing this phase, and 6
districts had not yet begun this phase; and:
* 17 of 75 districts (23 percent) had begun implementing Phase 3 as of
August 31, 2009, while 58 had not begun. However, 14 of the remaining
58 districts were scheduled to begin implementing Phase 3 by the end of
October 2009.
Figure 4 illustrates the overall status of NRP implementation among the
Service's 75 districts, as of August 31, 2009.
Figure 4: Overall Status of NRP Implementation, by Phase, as of August
31, 2009:
[Refer to PDF for image: horizontal bar graph]
Phase: Phase 1:
Complete implementation: 69;
Incomplete implementation: 6;
Have not begun implementation: 0.
Phase: Phase 2;
Complete implementation: 7;
Incomplete implementation: 62;
Have not begun implementation: 6.
Phase: Phase 3:
Complete implementation: 0;
Incomplete implementation: 17;
Have not begun implementation: 58.
Source: GAO analysis of Service data.
[End of figure]
Although 6 districts had not completed Phase 1 as of August 31, 2009,
each of these districts was concluding this phase and awaiting final
validation of results by headquarters. In contrast, according to data
provided by the Service, of the 69 districts that had completed or were
implementing Phase 2, the majority were in the first stage.
Specifically,
* 40 were in the job search stage (about 58 percent),
* 12 were in the job offer stage (about 17 percent),
* 10 were in the NWA stage (about 14 percent), and:
* 7 had completed Phase 2 (about 10 percent).
Figure 5 illustrates the status of the NRP for phases 1 and 2, by step,
as of August 31, 2009.
Figure 5: Status of NRP Implementation for Phases 1 and 2, by Step, as
of August 31, 2009[A]:
[Refer to PDF for image: vertical bar graph]
Phase 1:
Step: 1: 0;
Step: 2: 0;
Step: 3: 0;
Step: 4: 0;
Step: 5: 0;
Step: 6: 0;
Step: 7: 0;
Step: 8: 0;
Step: 9: 0;
Step: 10: 0;
Step: 11: 0;
Step: 12: 0;
Step: 13: 6 districts.
Search Phase 2:
Step: 1: 2 districts;
Step: 2: 0;
Step: 3: 0;
Step: 4: 0;
Step: 5: 13 districts;
Step: 6: 9 districts;
Step: 7: 12 districts;
Step: 8: 3 districts;
Step: 9: 1 districts.
Other:
Step: 1: 0;
Step: 2: 1 districts;
Step: 3: 0;
Step: 4: 4 districts;
Step: 5: 0;
Step: 6: 7 districts.
NWA:
Step: 1: 0;
Step: 2: 0;
Step: 3: 0;
Step: 4: 2 districts;
Step: 5: 2 districts;
Step: 6: 1 districts;
Step: 7: 0;
Step: 8: 0;
Step: 9: 0;
Step: 10: 0;
Step: 11: 0;
Step: 12: 3 districts;
Step: 13: 0;
Step: 14: 0;
Step: 15: 2 districts.
Composite:
Step: 7.
Source: GAO analysis of Service data.
[A] Data on 17 of the 75 districts that had begun implementing Phase 3
as of August 31, 2009, are not presented because similar data, by step,
were not available.
[End of figure]
Employee Outcomes Are Beginning to Be Realized, but Available Data Are
Limited and Preliminary:
Although implementation of the NRP is incomplete, the initiative is
beginning to realize outcomes for Service employees. However, partly
because of incomplete implementation of the NRP and tracking of all NRP
employee outcomes, agencywide data on NRP outcomes are both limited and
preliminary. As previously shown in table 2, the potential employee
outcomes of Phase 2 for employees (employees who have reached their
MMI) are as follows:
* return to full duty,
* retirement,
* resignation,
* continuation in the employee's prior modified work assignment,
* reassignment to a new medically suitable and necessary work
assignment, or an:
* NWA determination (i.e., the Service could not find necessary and
medically suitable work for employees to perform).
Although the Service tracks and aggregates data on some NRP employee
outcomes, it does not track or aggregate data on others. According to
senior headquarters officials, they do not track or aggregate data on
all employee outcomes because the data are employee-specific and
recorded and stored at each of its districts. They explained that
aggregating data for the thousands of employees nationwide is
challenging, given limited staff resources, the scope of effort
required, and the absence of an automated system for tracking and
reporting information on the status of employees in modified work
assignments. While senior headquarters officials were able to provide
data on employee outcomes for 616 of 1,738 (about 35 percent) employees
that were reviewed in the eight districts that had completed, or nearly
completed, Phase 2 as of June 30, 2009,[Footnote 33] they were unable
to provide similar data for the remaining 1,122 employees (about 65
percent). Senior headquarters officials told us that data on these
employee outcomes were unavailable principally because the Service does
not track or aggregate the number of employees who:
* remained in their prior work assignment because the Service
determined through the employees' NRP review that the work assignment
was medically suitable and necessary work, or:
* received a new modified work assignment because their prior
assignment was determined to be either medically unsuitable or
unnecessary to the Service's mission.[Footnote 34]
According to senior headquarters officials, the Service does not need
to track or aggregate these outcomes because both outcomes indicate
that the goal of the NRP has been achieved. In its comments on a draft
of this report, the Service said that it intends to deploy a new
national claims management program in February 2010 that will enhance
its ability to track and measure NRP progress and enable cost efficient
aggregation of NRP data. However, the Service did not indicate that it
planned to use the new program to track and measure NRP employee
outcomes.
For the remaining 616 employees (of 1,738) whose specific outcomes
headquarters tracked data indicate that:
* 103 employees returned to full duty,
* 223 employees retired,
* 257 employees received NWA determinations, and:
* 33 employees had "other" outcomes.[Footnote 35]
Senior headquarters officials also provided us with preliminary data on
some employee outcomes for the districts implementing Phase 3 as of
August 31, 2009. Most of these data were very limited because the
majority of the districts were in the early stages of implementing
Phase 3 and, thus, had very few employee outcomes to report. Available
data were most complete for the four districts that piloted Phase 3
and, consequently, had been implementing Phase 3 the longest. Outcomes
for the 2,301 employees reviewed in these four districts indicated
that:
* 1,039 employees received a "full day work" determination (about 45
percent),
* 589 employees received a "partial day work" determination (about 26
percent), and:
* 673 employees received a "complete day no work" determination (about
29 percent).
While these data provide some useful insights into the districts' early
experience with implementing Phase 3, outcomes in this phase are
dynamic and subject to frequent change because, as discussed, district
managers are required to perform daily work determinations for many of
these employees.
Some Employee Outcomes Result in Cost Savings, while Others Increase
the Service's Short-and Long-term Costs:
While some employee outcomes result in cost savings for the Service,
others increase the Service's costs. Savings accrue when, for example,
an employee returns to full duty, and the Service no longer has to pay
for overtime or temporary employees to perform the work the injured
employee could not perform. Savings also may accrue when an employee
retires or resigns because the Service's obligation to this employee is
either greatly reduced or eliminated.[Footnote 36] Furthermore,
according to senior headquarters officials, if an employee receives an
NWA determination as a result of Phase 2, savings can result over the
long term if (1) the employee is retrained and reemployed through
OWCP's vocational rehabilitation training program; (2) OWCP reduces the
employee's compensation for an administrative reason, such as the
employee's refusal to fully participate in OWCP's vocational
rehabilitation training program; or (3) the employee finds another job
on his or her own. Each of these cases would result in a reduction in
the Service's overall OWCP costs.[Footnote 37] While only about one-
third of all employees enrolled in OWCP's vocational rehabilitation
training program eventually receive employment elsewhere, according to
DOL officials, senior headquarters officials at the Service told us
that, for every employee who is successfully placed by OWCP with a new
employer, more than three employees either retire or have their
compensation reduced for an administrative reason.
However, in addition to creating savings, the NRP creates short-and
long-term costs. These costs arise in part from the increased numbers
of employees on OWCP's periodic or daily rolls and increased
operational costs for the NRP's implementation. Specifically, each NWA
determination in Phase 2 and each "complete day no work" or "partial
day" determination in Phase 3 increases the number of Service employees
eligible to receive OWCP wage loss compensation.[Footnote 38] Increases
in the number of employees receiving these determinations also will
increase the Service's annual OWCP costs, at least in the short term.
OWCP's most recent bill totaled about $1.1 billion for the period
between July 1, 2008, and June 30, 2009. Thus, to the extent that
employees remain on OWCP's rolls, increasing the number of Service
employees receiving OWCP compensation will also increase the Service's
long-term costs.[Footnote 39] For example, about $18 million of the
Service's most recent OWCP bill was for the approximately 500 employees
injured before 1971 who still remain on OWCP's periodic rolls about 40
years later. Finally, increases in the number of Service employees
receiving OWCP wage loss compensation as a result of their NRP
reassessment could accelerate, given the Service's efforts to reduce
its employee work hours and the continuing decline in mail volume.
Increases in the number of employees receiving workers' compensation
are problematic because, at the end of 2008, the Service estimated that
its total liability for workers' compensation costs was about $8
billion--an increase of about $197 million, or 2.5 percent, from 2007.
The NRP also has increased the Service's operational costs for
developing, implementing, and integrating the NRP into the Service's
management practices.[Footnote 40] These include, for example, the
costs for headquarters staff to travel to each of its districts to
implement the NRP over the past 3 years. In addition, based on our
interviews of district officials implementing Phases 2 and 3, the
rigors of the NRP process have placed additional demands on available
staff, such as the requirement to perform daily work determinations for
many Phase 3 employees. Senior headquarters officials responsible for
implementing the NRP, however, view these additional costs as "up-
front" costs associated with reassessing the large number of employees
in modified work assignments (i.e., the backlog)--costs that no longer
will be incurred after the NRP reassessment process has been fully
implemented. As discussed previously, the Service intends to use the
NRP process moving forward for newly injured employees and employees
who reach their MMI (and require reevaluation). According to senior
headquarters officials, once the NRP reassessment is complete, future
costs for NRP activities will be part of the routine cost of managing
these assignments.
While the NRP's up-front costs will no doubt decline as implementation
is completed, to the extent that the NRP process creates permanent
managerial requirements where none previously existed or were carried
out, the process may create additional operational costs moving
forward. As in the case of the Service's OWCP costs, the increase in
the Service's operational costs likely will vary, depending on, among
other factors,
* the number of employees in these assignments;
* the duration of their assignments;[Footnote 41]
* the number of hours the employees are able to work, as well as their
productivity; and:
* the extent to which the employees' absence or diminished productivity
requires the Service to use overtime or hire temporary employees to
accomplish the injured employees' duties.
The Service Reported That NRP Saved $146 Million in Fiscal Year 2008
but Did Not Disclose the Limitations That Applied:
The Service attributed $146 million in cost savings to the NRP in its
comprehensive report to the Congress for fiscal year 2008 without
disclosing how it derived these savings or disclosing that this figure
was based on estimates.[Footnote 42] In addition, the Service did not
disclose that its protocols for estimating cost savings have several
limitations and, as a consequence, its estimate reflects neither the
Service's total gross savings nor its total net savings. For example,
the protocols used to estimate the Service's savings from Phases 1 and
2:
* do not account for savings accruing from all of the possible NRP
employee outcomes. For example, although the protocols account for
savings accruing for three of the Phase 2 employee outcomes--return to
full duty, retirement, and resignation--the Service does not account
for savings that, in some cases, might accrue from NWA determinations.
[Footnote 43]
* use "benchmark" cost savings, such as the Service's "lowest fully
loaded work hour" for employees--regardless of their actual salaries--
to quantify savings associated with the employee outcomes.[Footnote 44]
* do not account for savings from employee outcomes that accrue beyond
12 months after the outcome occurred. For example, when an employee
retires as a result of the NRP, the Service only counts the savings
that accrue for the first 12 months after the date of retirement.
* do not offset costs, such as the additional OWCP expenses that accrue
from Phase 2 NWA determinations, and do not offset increases in the
Service's operational costs resulting from the NRP's implementation.
Because the goal of the NRP is to ensure that all employees with
workplace injuries in modified work assignments are performing
medically suitable and necessary work--not to produce cost savings--
senior headquarters officials told us that they intentionally designed
the protocols to arrive at rough estimates that understate the NRP's
savings. In addition, they told us that it was not feasible to
precisely estimate savings resulting from the NRP because the savings
are specific to each employee's circumstances. Furthermore, they said
that implementing a more rigorous process for more precisely estimating
NRP savings would place unreasonable and unnecessary demands on
available staff. Thus, in their view, their current estimating approach
is adequate for the Service's needs.
Conclusions:
By implementing the NRP, the Service has taken an important step to
balance its obligation to provide work to employees with compensable
workplace injuries (when necessary work is available for them to
perform within their medical restrictions) with its obligation to the
Congress, its employees, and the public to operate as effectively and
efficiently as possible. In addition, because the NRP has the potential
to cut some of the Service's costs, the NRP may represent a step toward
addressing the Service's future financial viability. However, thus far,
the NRP has been carried out without a strong management framework for
ensuring timely implementation. For example, absent upper management's
clearly articulated support for the initiative, specified time frames
for its completion, and information about the NRP's relative priority
compared to competing Service initiatives, area and district managers'
commitment to the NRP's timely implementation has varied. Thus, after
more than 3 years, none of the districts has completed all NRP phases.
Furthermore, although Service officials estimate that the NRP will be
completed by September 30, 2010, without milestones for its completion,
it is uncertain when the NRP will be completed. In addition, because
the Service has not tracked and aggregated data on NRP employee
outcomes, it is difficult to measure the success of the program or
accurately report on employee outcomes. Finally, while the Service
believes its process for estimating savings is adequate for its needs,
when an agency reports data on its program outcomes to the Congress and
others, to help ensure that the data are not used inappropriately, it
is important to fully disclose any limitations that apply.
Recommendations for Executive Action:
To enhance the NRP's implementation, we recommend that the Postmaster
General take the following three actions to improve program management
and enhance accountability and transparency:
* Articulate senior management's commitment to the NRP by setting
program milestones, including a timeline for all districts to complete
the NRP;
* When deployed, use the Service's new claims management process to
track and measure whether the NRP's goals are being met, including
tracking the number of employees placed in necessary and medically
suitable modified work assignments; and:
* Fully disclose any limitations that apply to NRP-related cost savings
reported to the Congress and others.
Agency Comments and Our Evaluation:
The Service provided its written comments on a draft of this report by
letter dated December 1, 2009. These comments are summarized below and
are included, in their entirety, as appendix V of this report.
The Service agreed with our third recommendation, indicating that, in
the future, it will fully disclose any limitations that apply to NRP-
related cost savings it reports to the Congress and others; however,
the Service disagreed with our first and second recommendations. In
commenting on our first recommendation, the Service stated that it does
not believe that setting an "arbitrary deadline" for the NRP's
completion is in the best interests of its employees. We agree that
establishing an arbitrary deadline is inappropriate because it could
result in unacceptable and unintended employee outcomes. Thus, we
clarified our draft to exclude any unintended suggestion that the NRP
should be completed by September 30, 2010, which, according to senior
headquarters officials, is the current estimated date for completing
the NRP. The Service also stated that the NRP received "complete senior
management support as evidenced by the commitment of resources by each
area." While we believe that many senior managers fully committed to
the NRP's timely implementation, according to senior headquarters
officials and, as discussed in our report, the level of commitment at
the local level has varied greatly. Consequently, we continue to
believe that the Service should, after careful consideration of the
time required to reasonably complete the remaining portion of the NRP,
establish timelines for its completion nationwide and, where
practicable, track progress against those timelines. This would help
ensure that local managers properly prioritize the NRP, which is
especially important given that more than 3 years have passed since
implementation of the NRP began.
The Service disagreed with our second recommendation that it establish
methods for tracking and measuring whether the NRP's goals are being
met. The Service stated that the reports it uses to monitor the program
are sufficient for its purposes and that in February 2010 it intends to
deploy a new national claims management program that will enhance its
ability to aggregate NRP-related data. While the Service's current
reports may be sufficient for its senior management officials, given
the importance of this program and its potential impact on thousands of
employees, we believe it is important to fully track whether the NRP's
goals are being met. Thus, we have revised our recommendation to
clarify that we believe the Service should use its new program, when
available, to track and measure all NRP employee outcomes, including
the number of employees placed in necessary and medically suitable
modified work assignments. This will enhance transparency in reporting
program outcomes to employees, unions, congressional stakeholders, and
others.
In its comments, the Service also stated that it did not agree that its
"tracking data for the NRP is unknown." While our draft report
indicated that "the number of employees reassessed under the program is
unknown," we revised the report to clarify that the Service does not
aggregate NRP data, and therefore, that it could not specify the number
of employees being reviewed under the NRP nationwide.
Service officials, including the Manager of the Service's Office of
Health and Resource Management, also provided oral technical comments,
which we incorporated as appropriate.
We are sending copies of this report to appropriate congressional
committees and the U.S. Postal Service. The report also is available at
no charge on the GAO Web site at [hyperlink, http://www.gao.gov].
If you have any questions about this report, please contact me at
Herrp@gao.gov or (202) 512-2834. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. Key contributors to this report are listed in
appendix VI.
Signed by:
Phillip Herr:
Director, Physical Infrastructure Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Because of congressional interest in whether the large number of United
States Postal Service (Service) employees in modified work assignments
are being productively employed, we were asked to review the Service's
National Reassessment Process (NRP). Our work focused on three
objectives: (1) What is the goal of the NRP? (2) How is the initiative
being implemented? (3) What is the status of the NRP, and what outcomes
have been achieved?
To address these objectives, we reviewed and analyzed, among other
documentation, (1) applicable laws, regulations, and postal policies
and procedures for protecting federal employees who sustain a
compensable workplace injury, including their rights with respect to
job restoration; (2) Service documentation describing the goals of the
NRP and the process for implementing the initiative, as well as
available Service data on the status and outcomes of the NRP;[Footnote
45] (3) documentation from the four largest postal unions,[Footnote 46]
including information about the unions' views on the NRP; and (4)
information about the Department of Labor's (DOL) Office of Workers'
Compensation Programs (OWCP), which makes wage loss and other payments
to employees with compensable workplace injuries. We also interviewed a
wide range of postal officials, including senior headquarters health
and resource management officials who are responsible for the NRP's
implementation, injury compensation, and labor relations, and the
Service's Office of General Counsel. In addition, we interviewed
national-level representatives from each of the Service's four largest
unions, DOL officials, some postal employees affected by the NRP, and
other postal personnel, as applicable. To accomplish our objectives, we
also visited four districts--San Francisco, Westchester, the Dakotas,
and Dallas--and conducted in-depth, semistructured interviews with a
broad range of individuals, including members of each district's
District Assessment Team, district and facility managers, and local
union representatives, and contacted officials in four other districts-
-Sierra Coastal, Southeast New England, Los Angeles, and Santa
Ana.[Footnote 47] The results of our discussions with officials in
these districts are not generalizable to all of the Service's
districts. Finally, we reviewed prior reports and literature on, for
example, the value of returning injured employees to work as soon as
possible; reports on the Service's declining financial circumstances,
including GAO's high-risk reports and the Service's recent annual
financial reports and comprehensive statements for fiscal years 2007
and 2008; and guidance on key principles for managing agency
initiatives and reporting program outcomes. Because the Service did not
begin Phase 3 of the NRP until July 2009, our work primarily focuses on
Phases 1 and 2 of the NRP. Using data supplied by the Service, we also
determined the number of employees who either occupied (or could have
occupied) a modified assignment during fiscal year 2008. Our
methodology for this analysis is contained in appendix II.
While the Service has ergonomics and other safety-related programs to
reduce workplace injuries, we did not evaluate their effectiveness in
controlling the numbers of employees with workplace injuries in
modified work assignments. In addition, we excluded from our review
postal employees who sustained off-the-job injuries. Similarly, we
excluded postal employees who had sustained compensable workplace
injuries but have medical restrictions that preclude them from
continuing to work for the Service because they are not in modified
work assignments.[Footnote 48] Related to this, because of the time and
complexity involved in cross-matching individuals in modified work
assignments with DOL's OWCP payment records, we did not determine the
portion of the Service's costs for workers' compensation that is
attributable to individuals in modified work assignments. Finally,
while we evaluated the Service's methods for estimating cost savings
arising from the NRP, we did not attempt to arrive at an independent
assessment of the overall savings attributable to the NRP initiative
because it was not feasible to analyze thousands of individual employee
records at each of the Service's districts to determine, among many
other matters, the (1) number of hours worked (or not worked) by each
employee in a modified work assignment, (2) each employee's hourly wage
rate with benefits, or (3) possible differences in productivity between
each employee's pre-and post-NRP work assignments. In addition, data
needed to offset these savings against additional costs incurred (i.e.,
determine the Service's net savings), such as the cost of implementing
the NRP and increased OWCP costs associated with some employee
outcomes, were either not available or not feasible to determine.
[Footnote 49]
We conducted this performance audit from October 2008 to December 2009,
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
[End of section]
Appendix II: Methodology for Determining Number of Service Employees
Who Occupied (or Could Have) a Modified Work Assignment:
According to senior headquarters officials responsible for implementing
the NRP, there were 31,044 Service employees in modified work
assignments on September 30, 2008--the last day of fiscal year 2008.
Because this number understates the total number of employees in these
assignments throughout the year, we analyzed Service data to determine
the total number of employees in these assignments at any time during
fiscal year 2008.[Footnote 50] Our analysis found that over 50,031
employees with workplace injuries occupied a modified work assignment
during fiscal year 2008. In addition, another 9,740 employees with
workplace injuries could have occupied such an assignment, for a total
of 59,771 employees who either occupied (or, could have occupied) a
modified work assignment in fiscal year 2008.[Footnote 51] We
determined that the Service's data were sufficiently reliable for our
reporting purposes.
The following information describes our methodology for conducting this
analysis. We obtained Service data on employees in modified assignments
during fiscal year 2008--the period from October 1, 2007 through
September 30, 2008. These data are contained in one or more Excel
workbooks from headquarters and each of the 80 districts that existed
when we began our review.[Footnote 52] The workbooks contain various
information about the employees, including their name; work location;
work status;[Footnote 53] and a unique identifier, such as their Social
Security numbers.
Because data in these workbooks were not presented uniformly, we
standardized the data before beginning our analysis. In addition, we
performed other data cleaning activities to address other anomalies.
For example, because certain employee records had obvious errors, such
as Social Security numbers with fewer than nine digits, or beginning
with "000," we eliminated these data from further analysis. Finally, we
eliminated data fields that were not relevant to our review, such as
information about the employees' pay locations.
We then analyzed the data to determine the number of unique employees
contained in the Service's workbooks.[Footnote 54] In total, there were
59,824 unique employees at the start of our analysis. The majority of
these employees (51,516 of 59,824 or, about 86 percent) had only one
line of data, or "record," in the workbooks. However, the remaining
8,308 employees had more than one record during fiscal 2008.[Footnote
55] To ascertain the correct employee record to use in these cases, we
devised a protocol for deleting all but the most recent of the
employees' records.[Footnote 56] Thus, at the completion of this
activity, we had one record for each of these 8,308 employees.
To determine which of the 59,824 employees occupied a modified work
assignment during fiscal year 2008, we ran a frequency analysis on the
employees' work status data. In total 50,031 of the 59,824 employees
were coded "1," meaning that they were in a modified assignment at some
point during fiscal year 2008. The remaining 9,793 employees, however,
had a variety of other work status codes, including 53 that we
eliminated because data irregularities precluded us from determining
anything about the employees' work status. This left us with 9,740
employees with data indicating that the employees had occupied a
modified work assignment at some point in the past, but, for example,
subsequently had retired or otherwise separated from the Service. Thus,
sufficient data were not available for us to determine whether these
employees actually occupied a modified work assignment during fiscal
year 2008. However, based on our knowledge of the Service's data, and
our discussions with senior headquarters officials, we determined that
each of these 9,740 employees could have occupied a modified work
assignment during fiscal year 2008. We shared our findings with senior
headquarters officials who indicated that the results of our analysis
were reasonable.
[End of section]
Appendix III: Number, Percentage, and Distribution of Modified Work
Assignments Nationwide during Fiscal Year 2008:
[End of section]
As discussed in the body of this report, our analysis of Service data
found wide variability among Service districts nationwide in the
number, percentage, and distribution of employees in limited duty and
rehabilitation assignments (modified work assignments) during fiscal
year 2008. For example, in Dallas, over 12 percent of all employees in
the district (1,719 of 14,150) were in a modified work assignment;
while in the Metro Caribbean district, fewer than 2 percent occupied
one of these assignments during fiscal year 2008.[Footnote 57] In
addition, about 50 percent of the 50,031 employees in modified work
assignments during fiscal year 2008 worked in 30 percent of the
Service's organizations (24 of 81 organizations, including
headquarters).[Footnote 58] Table 2 shows the number and percentage of
employees in modified work assignments nationwide and the distribution
of these assignments, by organization, during fiscal year 2008.
Table 2: Number, Percentage, and Distribution of Service Employees in
Modified Work Assignments Nationwide during Fiscal Year 2008:
Rank: 1;
Service organization (district or headquarters): Dallas;
Number of employees in limited duty assignments: 792;
Number of employees in rehabilitation assignments: 927;
Total number of employees in modified assignments: 1,719;
Total number, all employees: 14,150;
Percentage of workforce in modified assignments: 12.15%.
Rank: 2;
Service organization (district or headquarters): San Francisco;
Number of employees in limited duty assignments: 479;
Number of employees in rehabilitation assignments: 684;
Total number of employees in modified assignments: 1,163;
Total number, all employees: 9,651;
Percentage of workforce in modified assignments: 12.05%.
Rank: 3;
Service organization (district or headquarters): Bay Valley;
Number of employees in limited duty assignments: 1,255;
Number of employees in rehabilitation assignments: 189;
Total number of employees in modified assignments: 1,444;
Total number, all employees: 12,276;
Percentage of workforce in modified assignments: 11.76%.
Rank: 4;
Service organization (district or headquarters): Detroit;
Number of employees in limited duty assignments: 698;
Number of employees in rehabilitation assignments: 253;
Total number of employees in modified assignments: 951;
Total number, all employees: 8,412;
Percentage of workforce in modified assignments: 11.31%.
Rank: 5;
Service organization (district or headquarters): Los Angeles;
Number of employees in limited duty assignments: 1,131;
Number of employees in rehabilitation assignments: 181;
Total number of employees in modified assignments: 1,312;
Total number, all employees: 11,932;
Percentage of workforce in modified assignments: 11%.
Rank: 6;
Service organization (district or headquarters): Northern Ohio;
Number of employees in limited duty assignments: 1,096;
Number of employees in rehabilitation assignments: 186;
Total number of employees in modified assignments: 1,282;
Total number, all employees: 12,019;
Percentage of workforce in modified assignments: 10.67%.
Rank: 7;
Service organization (district or headquarters): Santa Ana;
Number of employees in limited duty assignments: 720;
Number of employees in rehabilitation assignments: 753;
Total number of employees in modified assignments: 1,473;
Total number, all employees: 14,059;
Percentage of workforce in modified assignments: 10.48%.
Rank: 8;
Service organization (district or headquarters): Colorado Wyoming;
Number of employees in limited duty assignments: 671;
Number of employees in rehabilitation assignments: 704;
Total number of employees in modified assignments: 1,375;
Total number, all employees: 13,708;
Percentage of workforce in modified assignments: 10.03%.
Rank: 9;
Service organization (district or headquarters): Seattle;
Number of employees in limited duty assignments: 954;
Number of employees in rehabilitation assignments: 174;
Total number of employees in modified assignments: 1,128;
Total number, all employees: 11,282;
Percentage of workforce in modified assignments: 10%.
Rank: 10;
Service organization (district or headquarters): Louisiana;
Number of employees in limited duty assignments: 794;
Number of employees in rehabilitation assignments: 132;
Total number of employees in modified assignments: 926;
Total number, all employees: 9,413;
Percentage of workforce in modified assignments: 9.84%.
Rank: 11;
Service organization (district or headquarters): Atlanta;
Number of employees in limited duty assignments: 1,245;
Number of employees in rehabilitation assignments: 166;
Total number of employees in modified assignments: 1,411;
Total number, all employees: 14,502;
Percentage of workforce in modified assignments: 9.73%.
Rank: 12;
Service organization (district or headquarters): Pittsburgh;
Number of employees in limited duty assignments: 508;
Number of employees in rehabilitation assignments: 127;
Total number of employees in modified assignments: 635;
Total number, all employees: 6,737;
Percentage of workforce in modified assignments: 9.43%.
Rank: 13;
Service organization (district or headquarters): Cincinnati;
Number of employees in limited duty assignments: 740;
Number of employees in rehabilitation assignments: 289;
Total number of employees in modified assignments: 1,029;
Total number, all employees: 10,953;
Percentage of workforce in modified assignments: 9.39%.
Rank: 14;
Service organization (district or headquarters): Sacramento;
Number of employees in limited duty assignments: 549;
Number of employees in rehabilitation assignments: 430;
Total number of employees in modified assignments: 979;
Total number, all employees: 10,863;
Percentage of workforce in modified assignments: 9.01%.
Rank: 15;
Service organization (district or headquarters): Southeast Michigan;
Number of employees in limited duty assignments: 567;
Number of employees in rehabilitation assignments: 79;
Total number of employees in modified assignments: 646;
Total number, all employees: 7,271;
Percentage of workforce in modified assignments: 8.88%.
Rank: 16;
Service organization (district or headquarters): San Diego;
Number of employees in limited duty assignments: 496;
Number of employees in rehabilitation assignments: 495;
Total number of employees in modified assignments: 991;
Total number, all employees: 11,262;
Percentage of workforce in modified assignments: 8.8%.
Rank: 17;
Service organization (district or headquarters): South Florida;
Number of employees in limited duty assignments: 534;
Number of employees in rehabilitation assignments: 319;
Total number of employees in modified assignments: 853;
Total number, all employees: 9,832;
Percentage of workforce in modified assignments: 8.68%.
Rank: 18;
Service organization (district or headquarters): Sierra Coastal;
Number of employees in limited duty assignments: 365;
Number of employees in rehabilitation assignments: 531;
Total number of employees in modified assignments: 896;
Total number, all employees: 10,332;
Percentage of workforce in modified assignments: 8.67%.
Rank: 19;
Service organization (district or headquarters): Ft. Worth;
Number of employees in limited duty assignments: 363;
Number of employees in rehabilitation assignments: 371;
Total number of employees in modified assignments: 734;
Total number, all employees: 8,540;
Percentage of workforce in modified assignments: 8.59%.
Rank: 20;
Service organization (district or headquarters): Chicago;
Number of employees in limited duty assignments: 571;
Number of employees in rehabilitation assignments: 178;
Total number of employees in modified assignments: 749;
Total number, all employees: 9,315;
Percentage of workforce in modified assignments: 8.04%.
Rank: 21;
Service organization (district or headquarters): Columbus;
Number of employees in limited duty assignments: 440;
Number of employees in rehabilitation assignments: 87;
Total number of employees in modified assignments: 527;
Total number, all employees: 6,719;
Percentage of workforce in modified assignments: 7.84%.
Rank: 22;
Service organization (district or headquarters): Houston;
Number of employees in limited duty assignments: 840;
Number of employees in rehabilitation assignments: 170;
Total number of employees in modified assignments: 1,010;
Total number, all employees: 13,010;
Percentage of workforce in modified assignments: 7.76%.
Rank: 23;
Service organization (district or headquarters): Alaska;
Number of employees in limited duty assignments: 118;
Number of employees in rehabilitation assignments: 25;
Total number of employees in modified assignments: 143;
Total number, all employees: 1,867;
Percentage of workforce in modified assignments: 7.66%.
Rank: 24;
Service organization (district or headquarters): Suncoast;
Number of employees in limited duty assignments: 585;
Number of employees in rehabilitation assignments: 324;
Total number of employees in modified assignments: 909;
Total number, all employees: 11,914;
Percentage of workforce in modified assignments: 7.63%.
Rank: 25;
Service organization (district or headquarters): Oklahoma;
Number of employees in limited duty assignments: 275;
Number of employees in rehabilitation assignments: 328;
Total number of employees in modified assignments: 603;
Total number, all employees: 8,053;
Percentage of workforce in modified assignments: 7.49%.
Rank: 26;
Service organization (district or headquarters): Lakeland;
Number of employees in limited duty assignments: 702;
Number of employees in rehabilitation assignments: 253;
Total number of employees in modified assignments: 955;
Total number, all employees: 12,923;
Percentage of workforce in modified assignments: 7.39%.
Rank: 27;
Service organization (district or headquarters): Northern Illinois;
Number of employees in limited duty assignments: 387;
Number of employees in rehabilitation assignments: 392;
Total number of employees in modified assignments: 779;
Total number, all employees: 10,729;
Percentage of workforce in modified assignments: 7.26%.
Rank: 28;
Service organization (district or headquarters): Philadelphia;
Number of employees in limited duty assignments: 722;
Number of employees in rehabilitation assignments: 140;
Total number of employees in modified assignments: 862;
Total number, all employees: 11,926;
Percentage of workforce in modified assignments: 7.23%.
Rank: 29;
Service organization (district or headquarters): Northern Virginia;
Number of employees in limited duty assignments: 302;
Number of employees in rehabilitation assignments: 157;
Total number of employees in modified assignments: 459;
Total number, all employees: 6,457;
Percentage of workforce in modified assignments: 7.11%.
Rank: 30;
Service organization (district or headquarters): Portland;
Number of employees in limited duty assignments: 578;
Number of employees in rehabilitation assignments: 40;
Total number of employees in modified assignments: 618;
Total number, all employees: 8,803;
Percentage of workforce in modified assignments: 7.02%.
Rank: 31;
Service organization (district or headquarters): S.E. New England;
Number of employees in limited duty assignments: 337;
Number of employees in rehabilitation assignments: 139;
Total number of employees in modified assignments: 476;
Total number, all employees: 6,896;
Percentage of workforce in modified assignments: 6.9%.
Rank: 32;
Service organization (district or headquarters): North Florida;
Number of employees in limited duty assignments: 351;
Number of employees in rehabilitation assignments: 295;
Total number of employees in modified assignments: 646;
Total number, all employees: 9,531;
Percentage of workforce in modified assignments: 6.78%.
Rank: 33;
Service organization (district or headquarters): Capital District;
Number of employees in limited duty assignments: 423;
Number of employees in rehabilitation assignments: 188;
Total number of employees in modified assignments: 611;
Total number, all employees: 9,347;
Percentage of workforce in modified assignments: 6.54%.
Rank: 34;
Service organization (district or headquarters): N. New Jersey;
Number of employees in limited duty assignments: 580;
Number of employees in rehabilitation assignments: 213;
Total number of employees in modified assignments: 793;
Total number, all employees: 12,132;
Percentage of workforce in modified assignments: 6.54%.
Rank: 35;
Service organization (district or headquarters): Greater Indiana;
Number of employees in limited duty assignments: 557;
Number of employees in rehabilitation assignments: 286;
Total number of employees in modified assignments: 843;
Total number, all employees: 13,161;
Percentage of workforce in modified assignments: 6.41%.
Rank: 36;
Service organization (district or headquarters): Salt Lake City;
Number of employees in limited duty assignments: 185;
Number of employees in rehabilitation assignments: 92;
Total number of employees in modified assignments: 277;
Total number, all employees: 4,332;
Percentage of workforce in modified assignments: 6.39%.
Rank: 37;
Service organization (district or headquarters): Central Illinois;
Number of employees in limited duty assignments: 719;
Number of employees in rehabilitation assignments: 50;
Total number of employees in modified assignments: 769;
Total number, all employees: 12,444;
Percentage of workforce in modified assignments: 6.18%.
Rank: 38;
Service organization (district or headquarters): Big Sky;
Number of employees in limited duty assignments: 106;
Number of employees in rehabilitation assignments: 55;
Total number of employees in modified assignments: 161;
Total number, all employees: 2,614;
Percentage of workforce in modified assignments: 6.16%.
Rank: 39;
Service organization (district or headquarters): Triboro;
Number of employees in limited duty assignments: 476;
Number of employees in rehabilitation assignments: 150;
Total number of employees in modified assignments: 626;
Total number, all employees: 10,217;
Percentage of workforce in modified assignments: 6.13%.
Rank: 40;
Service organization (district or headquarters): Central Pennsylvania;
Number of employees in limited duty assignments: 651;
Number of employees in rehabilitation assignments: 51;
Total number of employees in modified assignments: 702;
Total number, all employees: 11,536;
Percentage of workforce in modified assignments: 6.09%.
Rank: 41;
Service organization (district or headquarters): Connecticut;
Number of employees in limited duty assignments: 433;
Number of employees in rehabilitation assignments: 180;
Total number of employees in modified assignments: 613;
Total number, all employees: 10,082;
Percentage of workforce in modified assignments: 6.08%.
Rank: 42;
Service organization (district or headquarters): Erie;
Number of employees in limited duty assignments: 241;
Number of employees in rehabilitation assignments: 23;
Total number of employees in modified assignments: 264;
Total number, all employees: 4,353;
Percentage of workforce in modified assignments: 6.06%.
Rank: 43;
Service organization (district or headquarters): Arizona;
Number of employees in limited duty assignments: 500;
Number of employees in rehabilitation assignments: 176;
Total number of employees in modified assignments: 676;
Total number, all employees: 11,265;
Percentage of workforce in modified assignments: 6%.
Rank: 44;
Service organization (district or headquarters): Long Island;
Number of employees in limited duty assignments: 450;
Number of employees in rehabilitation assignments: 44;
Total number of employees in modified assignments: 494;
Total number, all employees: 8,333;
Percentage of workforce in modified assignments: 5.93%.
Rank: 45;
Service organization (district or headquarters): Massachusetts;
Number of employees in limited duty assignments: 339;
Number of employees in rehabilitation assignments: 249;
Total number of employees in modified assignments: 588;
Total number, all employees: 9,989;
Percentage of workforce in modified assignments: 5.89%.
Rank: 46;
Service organization (district or headquarters): Gateway;
Number of employees in limited duty assignments: 504;
Number of employees in rehabilitation assignments: 239;
Total number of employees in modified assignments: 743;
Total number, all employees: 12,679;
Percentage of workforce in modified assignments: 5.86%.
Rank: 47;
Service organization (district or headquarters): Nevada Sierra;
Number of employees in limited duty assignments: 275;
Number of employees in rehabilitation assignments: 30;
Total number of employees in modified assignments: 305;
Total number, all employees: 5,216;
Percentage of workforce in modified assignments: 5.85%.
Rank: 48;
Service organization (district or headquarters): Rio Grande;
Number of employees in limited duty assignments: 677;
Number of employees in rehabilitation assignments: 85;
Total number of employees in modified assignments: 762;
Total number, all employees: 13,084;
Percentage of workforce in modified assignments: 5.82%.
Rank: 49;
Service organization (district or headquarters): Greensboro;
Number of employees in limited duty assignments: 559;
Number of employees in rehabilitation assignments: 69;
Total number of employees in modified assignments: 628;
Total number, all employees: 10,880;
Percentage of workforce in modified assignments: 5.77%.
Rank: 50;
Service organization (district or headquarters): South Jersey;
Number of employees in limited duty assignments: 253;
Number of employees in rehabilitation assignments: 143;
Total number of employees in modified assignments: 396;
Total number, all employees: 7,027;
Percentage of workforce in modified assignments: 5.64%.
Rank: 51;
Service organization (district or headquarters): Central New Jersey;
Number of employees in limited duty assignments: 288;
Number of employees in rehabilitation assignments: 125;
Total number of employees in modified assignments: 413;
Total number, all employees: 7,494;
Percentage of workforce in modified assignments: 5.51%.
Rank: 52;
Service organization (district or headquarters): Honolulu;
Number of employees in limited duty assignments: 101;
Number of employees in rehabilitation assignments: 55;
Total number of employees in modified assignments: 156;
Total number, all employees: 2,836;
Percentage of workforce in modified assignments: 5.5%.
Rank: 53;
Service organization (district or headquarters): Boston;
Number of employees in limited duty assignments: 176;
Number of employees in rehabilitation assignments: 169;
Total number of employees in modified assignments: 345;
Total number, all employees: 6,506;
Percentage of workforce in modified assignments: 5.3%.
Rank: 54;
Service organization (district or headquarters): New Hampshire -
Vermont;
Number of employees in limited duty assignments: 224;
Number of employees in rehabilitation assignments: 91;
Total number of employees in modified assignments: 315;
Total number, all employees: 6,024;
Percentage of workforce in modified assignments: 5.23%.
Rank: 55;
Service organization (district or headquarters): Baltimore;
Number of employees in limited duty assignments: 274;
Number of employees in rehabilitation assignments: 182;
Total number of employees in modified assignments: 456;
Total number, all employees: 9,044;
Percentage of workforce in modified assignments: 5.04%.
Rank: 56;
Service organization (district or headquarters): Greater Michigan;
Number of employees in limited duty assignments: 375;
Number of employees in rehabilitation assignments: 113;
Total number of employees in modified assignments: 488;
Total number, all employees: 9,727;
Percentage of workforce in modified assignments: 5.02%.
Rank: 57;
Service organization (district or headquarters): Mid-Carolinas;
Number of employees in limited duty assignments: 427;
Number of employees in rehabilitation assignments: 60;
Total number of employees in modified assignments: 487;
Total number, all employees: 9,796;
Percentage of workforce in modified assignments: 4.97%.
Rank: 58;
Service organization (district or headquarters): Appalachian;
Number of employees in limited duty assignments: 315;
Number of employees in rehabilitation assignments: 47;
Total number of employees in modified assignments: 362;
Total number, all employees: 7,400;
Percentage of workforce in modified assignments: 4.89%.
Rank: 59;
Service organization (district or headquarters): Richmond;
Number of employees in limited duty assignments: 238;
Number of employees in rehabilitation assignments: 204;
Total number of employees in modified assignments: 442;
Total number, all employees: 9,064;
Percentage of workforce in modified assignments: 4.88%.
Rank: 60;
Service organization (district or headquarters): Tennessee;
Number of employees in limited duty assignments: 571;
Number of employees in rehabilitation assignments: 124;
Total number of employees in modified assignments: 695;
Total number, all employees: 14,578;
Percentage of workforce in modified assignments: 4.77%.
Rank: 61;
Service organization (district or headquarters): Albuquerque;
Number of employees in limited duty assignments: 74;
Number of employees in rehabilitation assignments: 111;
Total number of employees in modified assignments: 185;
Total number, all employees: 3,884;
Percentage of workforce in modified assignments: 4.76%.
Rank: 62;
Service organization (district or headquarters): Western New York;
Number of employees in limited duty assignments: 291;
Number of employees in rehabilitation assignments: 69;
Total number of employees in modified assignments: 360;
Total number, all employees: 7,747;
Percentage of workforce in modified assignments: 4.65%.
Rank: 63;
Service organization (district or headquarters): Central Florida;
Number of employees in limited duty assignments: 342;
Number of employees in rehabilitation assignments: 121;
Total number of employees in modified assignments: 463;
Total number, all employees: 9,974;
Percentage of workforce in modified assignments: 4.64%.
Rank: 64;
Service organization (district or headquarters): Hawkeye;
Number of employees in limited duty assignments: 249;
Number of employees in rehabilitation assignments: 166;
Total number of employees in modified assignments: 415;
Total number, all employees: 9,120;
Percentage of workforce in modified assignments: 4.55%.
Rank: 65;
Service organization (district or headquarters): South Georgia;
Number of employees in limited duty assignments: 179;
Number of employees in rehabilitation assignments: 104;
Total number of employees in modified assignments: 283;
Total number, all employees: 6,365;
Percentage of workforce in modified assignments: 4.45%.
Rank: 66;
Service organization (district or headquarters): Maine;
Number of employees in limited duty assignments: 93;
Number of employees in rehabilitation assignments: 84;
Total number of employees in modified assignments: 177;
Total number, all employees: 4,067;
Percentage of workforce in modified assignments: 4.35%.
Rank: 67;
Service organization (district or headquarters): Greater S.Carolina;
Number of employees in limited duty assignments: 212;
Number of employees in rehabilitation assignments: 83;
Total number of employees in modified assignments: 295;
Total number, all employees: 7,283;
Percentage of workforce in modified assignments: 4.05%.
Rank: 68;
Service organization (district or headquarters): Arkansas;
Number of employees in limited duty assignments: 222;
Number of employees in rehabilitation assignments: 38;
Total number of employees in modified assignments: 260;
Total number, all employees: 6,427;
Percentage of workforce in modified assignments: 4.05%.
Rank: 69;
Service organization (district or headquarters): Mid-America;
Number of employees in limited duty assignments: 259;
Number of employees in rehabilitation assignments: 173;
Total number of employees in modified assignments: 432;
Total number, all employees: 11,044;
Percentage of workforce in modified assignments: 3.91%.
Rank: 70;
Service organization (district or headquarters): Alabama;
Number of employees in limited duty assignments: 212;
Number of employees in rehabilitation assignments: 171;
Total number of employees in modified assignments: 383;
Total number, all employees: 9,857;
Percentage of workforce in modified assignments: 3.89%.
Rank: 71;
Service organization (district or headquarters): Albany;
Number of employees in limited duty assignments: 151;
Number of employees in rehabilitation assignments: 150;
Total number of employees in modified assignments: 301;
Total number, all employees: 7,813;
Percentage of workforce in modified assignments: 3.85%.
Rank: 72;
Service organization (district or headquarters): Spokane;
Number of employees in limited duty assignments: 139;
Number of employees in rehabilitation assignments: 45;
Total number of employees in modified assignments: 184;
Total number, all employees: 5,022;
Percentage of workforce in modified assignments: 3.66%.
Rank: 73;
Service organization (district or headquarters): Central Plains;
Number of employees in limited duty assignments: 211;
Number of employees in rehabilitation assignments: 156;
Total number of employees in modified assignments: 367;
Total number, all employees: 10,338;
Percentage of workforce in modified assignments: 3.55%.
Rank: 74;
Service organization (district or headquarters): Dakotas;
Number of employees in limited duty assignments: 112;
Number of employees in rehabilitation assignments: 52;
Total number of employees in modified assignments: 164;
Total number, all employees: 5,134;
Percentage of workforce in modified assignments: 3.19%.
Rank: 75;
Service organization (district or headquarters): New York;
Number of employees in limited duty assignments: 407;
Number of employees in rehabilitation assignments: 67;
Total number of employees in modified assignments: 474;
Total number, all employees: 15,146;
Percentage of workforce in modified assignments: 3.13%.
Rank: 76;
Service organization (district or headquarters): Northland;
Number of employees in limited duty assignments: 451;
Number of employees in rehabilitation assignments: 31;
Total number of employees in modified assignments: 482;
Total number, all employees: 15,781;
Percentage of workforce in modified assignments: 3.05%.
Rank: 77;
Service organization (district or headquarters): Kentuckiana;
Number of employees in limited duty assignments: 159;
Number of employees in rehabilitation assignments: 139;
Total number of employees in modified assignments: 298;
Total number, all employees: 10,034;
Percentage of workforce in modified assignments: 2.97%.
Rank: 78;
Service organization (district or headquarters): Mississippi;
Number of employees in limited duty assignments: 103;
Number of employees in rehabilitation assignments: 53;
Total number of employees in modified assignments: 156;
Total number, all employees: 5,576;
Percentage of workforce in modified assignments: 2.8%.
Rank: 79;
Service organization (district or headquarters): Westchester;
Number of employees in limited duty assignments: 73;
Number of employees in rehabilitation assignments: 54;
Total number of employees in modified assignments: 127;
Total number, all employees: 6,424;
Percentage of workforce in modified assignments: 1.98%.
Rank: 80;
Service organization (district or headquarters): Metro Caribbean;
Number of employees in limited duty assignments: 27;
Number of employees in rehabilitation assignments: 35;
Total number of employees in modified assignments: 62;
Total number, all employees: 3,404;
Percentage of workforce in modified assignments: 1.82%.
Rank: 81;
Service organization (district or headquarters): Headquarters;
Number of employees in limited duty assignments: 34;
Number of employees in rehabilitation assignments: 36;
Total number of employees in modified assignments: 70;
Total number, all employees: 11,370;
Percentage of workforce in modified assignments: 0.62%.
Rank: Total;
Number of employees in limited duty assignments: 35,082;
Number of employees in rehabilitation assignments: 14,949;
Total number of employees in modified assignments: 50,031;
Total number, all employees: 748,307.
Source: GAO analysis of Service data.
[End of table]
[End of section]
Appendix IV: Description of NRP Activities, by Phase and Step:
Figures 6, 7, and 8 provide additional information about the NRP,
including a description of activities, by phase and step.
Figure 6: Description of NRP Activities in Phase 1:
[Refer to PDF for image: table]
Phase 1:
Step: 1;
Responsible team member:
* District Injury Compensation Specialist;
Activity description: Identify all employees in modified work
assignments.
Step: 2;
Responsible team member:
* Area National Assessment Process Injury Compensation Specialist;
Activity description: Transfer information about these employees to the
NRP workbook;
Step: 3;
Responsible team member:
* Area Injury Compensation Manager;
* Area Medical Function Representative;
* Area Operations Team Leader;
Activity description: Brief senior district management on NRP Phase 1.
Step: 4;
Responsible team member:
* District injury compensation staff;
Activity description: Identify employees in modified work assignments
who require medical review.
Step: 5;
Responsible team member:
* District medical staff;
* District injury compensation staff;
Activity description: Review all employees identified in step 4;
determine if medical updates are required.
Step: 6;
Responsible team member:
* District medical staff;
* District injury compensation staff;
* District labor relations staff;
Activity description: Follow up on employee medical update requests.
Step: 7;
Responsible team member:
* District Assessment Team (DAT) including operations, injury
compensation and medical staffs;
Activity description: DAT verifies current job offer matches tasks
performed.
Step: 8;
Responsible team member:
* District medical staff;
* District labor relations staff;
Activity description: Ensure procedures for light duty assignments are
in effect, enabling identification and tracking of these employees[A].
Step: 9;
Responsible team member:
* District medical staff;
Activity description: Identify veterans-preference eligible employees
in light duty assignments.
Step: 10;
Responsible team member:
* District Injury Compensation Specialist or staff;
Activity description: Update NRP workbook to ensure all veterans in
modified work assignments are properly recorded.
Step: 11;
Responsible team member:
* District Injury Compensation Specialist or staff;
Activity description: Create NRP file for all employees in modified
work assignments to ensure that all necessary documents are on file.
Step: 12;
Responsible team member:
* Area injury compensation team;
Activity description: Review injury compensation file and NRP file for
employees in all modified work assignments to verify that the NRP file
is complete and accurate in preparation for reassessing employees.
Step: 13;
Responsible team member:
* Area Injury Compensation Manager;
Activity description: Area injury compensation staff review NRP Phase 1
actions – all aspects must be verified as accurately completed.
Source: GAO analysis of Service data.
[A] In some cases, the Service also provides modified work assignments
to employees injured off-the-job. These assignments are called "light
duty" assignments. However, they are beyond the scope of our review.
[End of figure]
Figure 7: Description of NRP Activities in Phase 2:
[Refer to PDF for image: table]
Phase 2[A], Stage 1: Search:
Step: 1;
Responsible team member:
* Headquarters Injury Compensation Team Leader;
Activity description: Train area and district NRP teams on Phase 2
search process.
Step: 2;
Responsible team member:
* Area NRP team;
Introduce and initiate NRP Phase 2 with district senior staff.
Step: 3;
Responsible team member:
* District senior management;
* Area and district injury compensation team leaders;
* Area and district operations team leaders;
* Area and district labor relations managers;
Activity description: Hold meeting with all applicable union
representatives.
Step: 4;
Responsible team member:
* Area injury compensation team;
* District injury compensation staff;
Activity description: Update NRP workbooks to include all employees who
have reached their maximum medical improvement (MMI), i.e., employees
in rehabilitation assignments, and employees who have not reached their
MMI, i.e., employees in limited duty assignments.
Step: 5;
Responsible team member:
* Area NRP team;
Activity description: Meet with district NRP team to discuss ’necessary
work“ assignments.
Step: 6;
Responsible team member:
* Area and district NRP teams;
* Area NRP team;
Activity description: Prepare local commuting area documentation for
employees who have reached their MMI.
Step: 7;
Responsible team member:
* Area NRP team;
Activity description: Perform job searches for all employees who
reached their MMI in less than a year to identify potential
rehabilitation assignments within their local commuting area.
Step: 7;
Responsible team member:
* Area and district NRP teams;
Activity description: Perform job searches for all employees who
reached their MMI in more than a year to identify potential
rehabilitation assignments within their local commuting area.
Step: 8;
Responsible team member:
* Area and district NRP teams;
Activity description: Meet to discuss the status of all employees who
have reached their MMI.
Stage 2: Job offer:
Step: 1;
Responsible team member:
* District Injury Compensation Manager;
* District operations team;
Activity description: District operations team submits the DAT-approved
proposed job offers (i.e., rehabilitation duties worksheets) to the
senior manager for approval, thus demonstrating that the position had
been identified and approved by senior management.
Step: 2;
Responsible team member:
* District injury compensation staff;
* District operations team leaders;
Activity description: Prepare and complete formal job offers.
Step: 3;
Responsible team member:
* District NRP team (operations and injury compensation);
* District labor relations team;
Activity description: Schedule employee interviews to discuss and
present job offers; notify employees and union representatives.
Step: 4;
Responsible team member:
* District NRP team;
Activity description: Conduct interviews for the approved job offers
with employees.
Step: 5;
Responsible team member:
* District NRP team;
* District Injury Compensation Manager;
* District NRP Labor Relations Representative;
Activity description: Two weeks after each interview, follow up to
ensure that each employee has responded to their job offer.
Step: 6;
Responsible team member:
* District Injury Compensation Manager;
Activity description: When the job offer is accepted, the Injury
Compensation Manager must coordinate with the manager of the new
facility to prepare for the employee to start work there.
Stage 3: NWA (no work available):
Step: 1;
Responsible team member:
* Area Injury Compensation Manager;
* Area Injury Compensation Team Leader;
Activity description: Meet with DOL…s OWCP District Director to discuss
the NRP and the Service‘s preliminary NWA list.
Step: 2;
Responsible team member:
* Area and district NRP teams;
Activity description: Area and district teams review all NWA employee
files and review them for accuracy.
Step: 3;
Responsible team member:
* Area and district NRP team leaders;
Activity description: Meet with district managers on the status of the
NRP and discuss the job searches that senior managers will have to
approve.
Step: 4;
Responsible team member:
* Area NRP team leaders;
Activity description: Brief surrounding district managers in the local
commuting area on the NRP, and discuss the district's responsibility in
completing the job searches.
Step: 5;
Responsible team member:
* District injury compensation staff;
* District NRP operations team;
Activity description: Track and file job search results.
Step: 6;
Responsible team member:
* District NRP team;
Activity description: Schedule interviews with employees receiving NWA
determinations.
Step: 7;
Responsible team member:
* Area NRP team;
Activity description: Brief the Service‘s Inspection Service and its
Office of Inspector General on NRP and NWA interviews[B].
Step: 8;
Responsible team member:
* Area NRP team;
* District labor relations team;
* District Operations Team Leader;
Activity description: Brief local unions about ongoing and preliminary
NWA employee results.
Step: 9;
Responsible team member:
* District NRP team;
Activity description: Prepare employee resource guide and meet with
applicable Service staff to discuss the final steps of the NWA process.
Step: 10;
Responsible team member:
* District NRP team;
Activity description: Notify employees by letter at least 14 days in
advance of employee interviews.
Step: 11;
Responsible team member:
* Area NRP team;
Activity description: Brief district NRP teams on the prescribed script
for the interviews and select interview team leaders.
Step: 12;
Responsible team member:
* District NRP team;
* Area Operations Team Leader;
* Area Injury Compensation Team Leader;
Activity description: Conduct first interviews with all affected
employees.
Step: 13;
Responsible team member:
* District NRP Operations Team Leader or member;
Activity description: Notify facility managers of upcoming second
interview with employees receiving NWA determinations.
Step: 14;
Responsible team member:
* District NRP team;
* Area Operations Team Leader;
* Area Injury Compensation Team Leader;
Activity description: Conduct second interviews with employees
receiving NWA determinations.
Step: 15;
Responsible team member:
* District injury compensation staff;
* District NRP operations team;
Activity description: Track and identify activities related to
employees placed on OWCP‘s rolls due to NWA determinations.
Source: GAO analysis of Service data.
[A] The Service calls this phase, "Phase 2: Rehabilitation." To enhance
the clarity of this report, we refer to this phase as "Phase 2."
[B] The Service notifies representatives within its Postal Inspection
Service and its Office of Inspector General in anticipation of problems
that may be encountered during interviews with employees receiving an
NWA determination.
[End of figure]
Figure 14: Description of NRP Activities in Phase 3:
[Refer to PDF for image: table]
Phase 3[A]:
Stage 1: Implementation:
Step: 1;
Responsible team member:
* Headquarters Health and Resource Management Team Leader;
Activity description: Meet with area and selected district NRP team
members and train them on this phase.
Step: 2;
Responsible team member:
* Headquarters NRP team;
* Area NRP team;
Activity description: Meet with district senior managers to initiate
this phase and confirm their support.
Step: 3;
Responsible team member:
* District senior management;
* DAT members;
Activity description: Meet with union representatives and Service
management organizations to inform them about this phase.
Step: 4;
Responsible team member:
* Area Health and Resource Management Team Leader;
* District health and resource management staff;
Activity description: Review NRP workbook files to ensure that all
employees who have not yet reached their MMI are listed.
Step: 5;
Responsible team member:
* Area NRP team;
* District NRP team;
Activity description: Train district managers on their role in Phase 3.
Step: 6;
Responsible team member:
* Area NRP team;
* District NRP team;
Activity description: DAT conducts initial modified work assignment
determinations and area team commences its review of these
determinations.
Stage 2: Work status:
Step: 1;
Responsible team member:
* Headquarters/area/district NRP teams;
Activity description: Review all proposed modified work assignment
determinations for accuracy.
Step: 2;
Responsible team member:
* Headquarters/area/district NRP teams;
Activity description: Train facility managers or supervisors on work
status meetings and explain all possible work status determinations;
Step: 3;
Responsible team member:
* DAT;
Activity description: Review documentation for all modified work
assignments for compliance.
Step: 4;
Responsible team member:
* Facility Manager/Supervisor;
Activity description: On a daily basis, review available necessary
tasks and make assignment determinations, and conduct daily work status
meetings with injured employees who have not yet reached their MMI.
Stage 3: New medical/new injury:
Step: 1;
Responsible team member:
* Facility Manager/Supervisor;
Activity description: Employee presents updated medical documentation
for an existing injury or new documentation for a recent injury.
Step: 2;
Responsible team member:
* Facility Manager/Supervisor;
Activity description: Managers/supervisors assess each employee based
on recently presented medical documentation to determine the
availability of necessary work.
Step: 3;
Responsible team member:
* Facility Manager/Supervisor;
Activity description: Managers/supervisors present work status
determination to each employee, elicit employee feedback regarding the
proposed assignment, and make adjustments if necessary.
Source: GAO analysis of Service data.
[A] The Service calls this phase, "Phase 2: Limited Duty." We refer to
this phase as "Phase 3."
[End of figure]
[End of section]
Appendix V: Comments from the United States Postal Service:
United States Postal Service:
Anthony J. Vegliante:
Executive Vice President and Chief Human Resources Officer:
475 L'Enfant Plaza, SW:
Washington, DC 20280-4000:
[hyperlink: http://www.usps.com]
December 1, 2009:
Mr. Phillip R. Herr:
Director, Physical Infrastructure Issues:
United States Government Accountability Office:
Washington, DC 20548-0001:
Dear Mr. Herr:
Thank you for providing the U.S. Postal Service with the opportunity to
review and comment on the draft report titled U.S. Postal Service: The
Program for Reassessing Work Provided to Injured Employees Is Underway,
but Actions Are Needed to Improve Program Management (GAO-10-78).
We appreciate your understanding of the complex issues facing the
Postal Service in our efforts to ensure that injured employees
requiring modified work assignments within their medical restrictions
perform necessary work. This has been a particularly difficult
challenge in light of recent economic conditions, improved
technological and engineering work processes, and complex federal
regulations. As your report indicates, "By implementing the NRP, the
Service has taken an important step to balance its obligation to
provide work to employees with compensable workplace injuries (when
necessary work is available for them to perform within their medical
restrictions) with its obligation to Congress, its employees and the
public to operate as effectively and efficiently as possible."
The goal of the National Reassessment Process (NRP) is to place every
injured employee requiring modified work within current medical
restrictions in only necessary work assignments. This goal ensures that
financial savings are not placed as a higher priority than the injured
employee.
In your report, you suggest that the NRP is hampered by a lack of
senior management support and the lack of identified milestones toward
the completion date. The NRP was given complete senior management
support as evidenced by the commitment of resources by each area. We
implemented the NRP with an end goal in sight; however, we fully
understood that the
stakeholders in our process were many and varied and that we would have
to constantly address new issues as they surfaced even at the expense
of an on time completion. We do not believe that setting an arbitrary
deadline for district completion of this process is in the best
interests of our employees. Establishing a timeline could negatively
impact our ability to ensure that each injured employee is given an
individualized review that insures each resolution is specific to the
individual and their medical restrictions.
The Postal Service does not agree that the tracking data for the NRP is
unknown. The Postal Service tracks and monitors each injured employee
on a 51-field Excel spreadsheet report at each of the 74 district
offices. We certainly recognize that because the data are not
aggregated at the national level this provides audit challenges,
however, the program was implemented to be reviewed and monitored at
the district level, not nationally. The NRP summary reports monitored
at the national level are sufficient for the experienced senior
management officials responsible for this program. In February 2010 the
new national claims management program will be deployed. This will
enhance our abilities to track and measure NRP progress and enable cost
efficient aggregation of data.
We agree to fully disclose any limitations that apply to the NRP-
related cost savings reported to Congress and others as appropriate. As
noted in the GAO report, often times the actual savings were
consciously conservative. This conservative approach led to under
reporting actual savings taking into account all new associated program
costs such as increased travel.
The goal of the NRP remains the same, ensuring that employees requiring
medically restricted work are offered only necessary work assignments.
We also recognize that as the Postal Service completes the NRP and
moves into the next phase, which is the ongoing National Assessment
Process, a growing number of postal employees who may require the
services of the Vocational Rehabilitation Program will impact the
Office of Workers' Compensation Programs.
If you or your staff would like to discuss any of these comments
further, Ron Henderson is available at your convenience at (202) 268-
3587.
Sincerely,
Signed by:
Anthony Vegliante:
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
Phillip Herr, (202) 512-2834, or Herrp@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Kathleen Turner, Assistant
Director; Shirley Abel; Teresa Anderson; Lindsay Bach; Lauren Calhoun;
Jay Cherlow; Tonnye Conner-White; Elizabeth Eisenstadt; Colin Fallon;
Lauren Gilbertson; Brandon Haller; Elizabeth A. Marchak; Josh Ormond;
Patricia Owens; Jerome Sandau; and Laura Shumway made key contributions
to this report.
[End of section]
Footnotes:
[1] For purposes of this report, we generally refer to both traumatic
injuries, such as injuries arising from vehicular crashes, and
occupational illnesses, such as carpal tunnel syndrome, as "injuries."
[2] Because these employees are not in modified work assignments, they
are not included in the scope of this review.
[3] Under the Americans with Disabilities Act of 1990, codified as
amended at 42 U.S.C. § 12101 et seq., employers are required to make
"reasonable accommodations" for qualified individuals with
disabilities, unless to do so would require undue hardship (e.g.,
creating a new position.) See 42 U.S.C. §§ 12112(b)(5), 12111(10). The
Rehabilitation Act of 1973, Pub. L. No. 93-112, 87 Stat. 355, applies
these standards to federal agencies, including the Postal Service. See
29 U.S.C. § 791, 39 C.F.R. § 255.5, 29 C.F.R. § 1614.203.
[4] Payments to federal employees for compensable work-related injuries
and illnesses are authorized by the Federal Employees' Compensation
Act, 39 Stat. 743 (1916), codified as amended at 5 U.S.C. chapter 81,
and administered by the Office of Workers' Compensation Programs within
the Department of Labor. The Department of Labor provides benefits to
workers injured on the job, including wage loss compensation, payments
for medical care and, where necessary, vocational rehabilitation
training and assistance in returning to work. The department charges
these expenses back to the federal agencies in order to be reimbursed
for making payments to their employees.
[5] When we began our review in October 2008, there were 80 postal
districts. The Service subsequently eliminated 6 districts, and their
activities were absorbed by other districts. While there are currently
74 districts, we report available information on the status and
outcomes of 75 districts because 1 of these had not fully distributed
its employee files, including those related to the NRP, to other postal
districts.
[6] The results of our discussions with officials in these eight
districts are not generalizable to all of the Service's districts.
[7] GAO, High Risk Series: Restructuring the U.S. Postal Service to
Achieve Sustainable Financial Viability, [hyperlink,
http://www.gao.gov/products/GAO-09-937SP] (Washington, D.C.: July 28,
2009).
[8] Noncareer employees include "casual" and "transitional" staff with
limited-term appointments. The Service hires these employees when it
needs to temporarily augment the size of its workforce, such as during
the Christmas season.
[9] Pub. L. No. 93-112, 87 Stat. 355. See also fn. 3.
[10] See 5 C.F.R. part 353. These regulations implement 5 U.S.C. §
8151, part of the Federal Employees Compensation Act, as amended, Pub.
L. No. 64-267, 39 Stat. 742 (1916), codified as amended at 5 U.S.C.
chapter 81. Other legislative and regulatory protections also apply to
injured federal employees, including protections afforded to employees
in the Rehabilitation Act, and the Family Medical Leave Act of 1993,
Pub. L. No. 103-3, 107 Stat. 6, as applicable.
[11] Specifically, employees who reached their MMI within a year from
the date they became eligible for compensation have the right to resume
employment in their former job, or an equivalent position, agencywide.
In contrast, employees who reach their MMI in more than a year from the
date they became eligible for compensation are entitled to rights
accorded to individuals who fully or partially recover, as applicable.
49 C.F.R. § 353.301(c).
[12] 5 U.S.C. §§ 8105, 8106. The calculation of basic compensation
differs depending on whether the disability is total or partial. An
employee may also be entitled to additional compensation depending on
the nature of their injury and whether the employee has dependents. 5
U.S.C. §§ 8107, 8110. Other considerations may also warrant more or
less compensation. See 5 U.S.C. §§ 8111, 8112, 8113. Senior
headquarters officials noted that Service employees receiving
compensation from OWCP typically receive more than 66 and two-thirds
percent of their prior salary.
[13] Service data indicate that these employees had occupied a modified
work assignment at some point, but, for example, subsequently had
retired or otherwise separated from the Service. Thus, sufficient data
were not available for us to determine whether these employees actually
occupied a modified work assignment during fiscal year 2008.
[14] GAO, U.S. Postal Service: Broad Restructuring Needed to Address
Deteriorating Finances, [hyperlink,
http://www.gao.gov/products/GAO-09-790T] (Washington, D.C.: July 30,
2009).
[15] [hyperlink, http://www.gao.gov/products/GAO-09-937SP].
[16] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]; Government
Auditing Standards, [hyperlink,
http://www.gao.gov/products/GAO-07-731G] (Washington, D.C.: July 2007
Revision); Results Oriented Government: GPRA Has Established a Solid
Foundation for Achieving Greater Results, [hyperlink,
http://www.gao.gov/products/GAO-04-38] (Washington, D.C.: Mar. 10,
2004); Tax Administration: IRS Needs to Further Refine Its Tax Filing
Season Performance Measures, [hyperlink,
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22,
2002); Managing for Results: Enhancing Agency Use of Performance
Information for Management Decision Making, [hyperlink,
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: Sept. 9,
2005); Statement of Federal Financial Accounting Standard Number 4,
"Managerial Cost Accounting Concepts and Standards for the Federal
Government," 2008 update.
[17] Data on the number of these employees is also available at a
district level, but is not aggregated by the Service agencywide.
[18] The Service is implementing the NRP in two phases--Phase 1 and
Phase 2--which includes "Phase 2 Rehabilitation" for employees who have
reached their MMI and "Phase 2 Limited Duty" for those who have not yet
reached their MMI. However, to enhance the clarity of this report, we
refer to "Phase 2 Rehabilitation" as "Phase 2" and "Phase 2 Limited
Duty" as "Phase 3."
[19] Employees injured after the NRP's initiation also were included in
the NRP process at each district.
[20] In Phase 3, such an employee outcome is referred to as a "full day
work" determination.
[21] In certain cases, DOL may decide that an individual is eligible
not only to receive wage loss compensation but also to participate in
its vocational rehabilitation training program.
[22] Wage loss compensation for these employees includes compensation
for (1) the number of hours the employees could not work for the
Service because of their medical restrictions and (2) the additional
work hours for which the Service did not have medically suitable and
necessary work for the employees to perform.
[23] This assumes that the employee did not, for example, successfully
appeal or grieve his or her initial NWA determination.
[24] A "full day work" determination does not necessarily equal a
typical 8-hour workday. For example, if an employee is capable of
working only 4 hours a day, and the Service provides the employee with
an assignment of that duration, such an assignment would constitute
"full day work" for that employee. If, however, the Service provides
only a 2-hour work assignment, the employee would be eligible to
receive OWCP compensation for the 2 additional hours that he or she
could have worked for the Service, as well as the remaining 4 hours
that he or she could not have worked because of his or her medical
restrictions.
[25] Depending on the employee's expected date of recovery and the
likelihood of future work at the Service, employees who receive a
"complete day no work" determination may be placed on OWCP's "periodic
rolls." In contrast, employees who receive a "partial day work"
determination likely would be placed on OWCP's "daily rolls."
[26] Senior headquarters officials acknowledged that mistakes were
sometimes made, particularly early in the NRP's implementation. For
example, in San Francisco, officials responsible for implementing the
NRP told us that they moved forward with the NRP's implementation
(using information provided by another district) without receiving
necessary guidance from headquarters. As a consequence, headquarters
required the district to repeat prior steps because the district had
not implemented them correctly.
[27] Like the other NRP phases, the order of Phase 3's implementation
among the districts is determined by area managers in each of the
Service's nine areas.
[28] The additional searches are required to proceed in the following
manner: (1) different craft, same tour and facility; (2) same craft,
different tour, and same facility; and (3) different craft and tour,
same facility.
[29] The majority of the job search process is the same for employees
who have reached their MMI regardless of when (i.e., more than 1 year,
or less than 1 year, after their date of eligibility for compensation).
However, for employees who reached their MMI in more than 1 year,
postal managers do not need to expand their search for jobs beyond the
district's boundaries.
[30] As of July 2009, three of the four largest postal unions had filed
a total of six national-level grievances related to the NRP process.
The grievances cover a broad scope of issues, ranging from the
consideration of seniority when making job offers under the NRP to a
challenge of an entire phase of the NRP process. As of July 2009, one
grievance had been settled, while the others were either pending a
decision by the Service or pending arbitration. On the local level,
employees have filed a number of grievances under their union contracts
related to their NRP work determinations. In addition to filing
grievances, employees have other avenues of redress, including filing
actions before the Merit Systems Protection Board and before the Equal
Employment Opportunity Commission. Generally, the board adjudicates
individual federal employee appeals when an employee believes he or she
has suffered an adverse personnel action. The commission adjudicates
matters in which the federal employee believes he or she has suffered
an action in violation of workplace discrimination laws.
[31] See appendix IV for a complete list of NRP steps, by phase.
[32] As previously noted, while the Service currently has 74 districts,
we report available information on the status and outcomes of 75
districts because 1 of these had not fully distributed its employee
files, including those related to the NRP, to other postal districts.
[33] The Service provided us with data on Phase 2 employee outcomes for
eight districts as of June 30, 2009. Six of these districts--Western
New York, Dakotas, New Hampshire-Vermont, Westchester, Metro Caribbean,
and Honolulu--had completed Phase 2, while the 2 others--San Diego and
Boston--had essentially completed this phase at that time. The Service
was unable to provide us with data for these districts as of August 31,
2009.
[34] In addition, senior headquarters officials do not track or
aggregate data on employees with outcomes that have not been resolved
because of grievances or appeals.
[35] According to senior headquarter officials, "other" outcomes
include, but are not limited to, employees who had (1) either been
terminated or transferred, (2) their MMI status rescinded by their
treating physician, or (3) received a new medical assessment from their
physician stating that they were now totally disabled and unable to
work for the Service.
[36] According to Service officials, to date, the Service has prefunded
retirement costs for its employees. Thus, except for the Service's
continued payments for retired employees' health benefits, its
obligation to retired employees is eliminated. In addition, the Service
bears no future financial obligation to employees who resign.
[37] In addition to cost savings, senior headquarters officials,
officials in the four districts we visited, and some union officials
noted several additional benefits arising from the NRP, such as (1) the
creation of a systematic approach to managing the medical records of
employees with workplace injuries, (2) better job offers that match
injured employees' medical restrictions with necessary work
assignments, and (3) increased morale among Service employees who, for
example, had to perform mission critical tasks that could not be
performed by injured employees.
[38] As discussed, employees also are entitled to receive compensation
for the hours they could not work for the Service because of their
medical restrictions.
[39] Over time, some of the additional costs may decline. For example,
when former Service employees on OWCP's periodic rolls find work as a
result of their enrollment in OWCP's vocational rehabilitation training
program or on their own, their compensation is reduced to account for
their additional income. According to OWCP officials, the vocational
rehabilitation training program normally takes more than 2 years to
complete.
[40] While we requested data on the costs associated with developing,
implementing, and integrating the NRP into the Service's management
practices, the Service did not provide us with this information.
[41] We were unable to ascertain from Service data the typical length
of time in which employees were in a modified assignment. However,
according to senior headquarters officials, some employees are in
modified work assignments for many years, while others require only a
short-term modified work assignment.
[42] United States Postal Service Comprehensive Statement on Postal
Operations, 2008, 29. The Service is required to provide this report to
Congress in conjunction with its annual budget. 39 U.S.C. § 2401(e).
According to the Service, this report summarizes customer, employee,
and operations-focused developments during fiscal year 2008.
[43] For example, as discussed, if an employee receives an NWA
determination and is successful in obtaining a new job with a salary
that is equal to or greater than the salary he or she received from the
Service, the Service no longer incurs any OWCP costs for this employee.
[44] The "lowest fully-loaded work hour" represents the salary and
benefits, such as annual leave and retirement, that the Service pays to
employees in its lowest clerk position. According to senior
headquarters officials responsible for implementing the NRP, this
position is a "Clerk 4."
[45] Available data on employee outcomes arising from Phase 2 are as of
June 30, 2009, while data on the outcomes of Phase 3 are as of August
31, 2009. We determined these data were sufficiently reliable for our
reporting purposes.
[46] The four largest postal unions are the American Postal Workers
Union, the National Association of Letter Carriers, the National Postal
Mail Handlers Union, and the National Rural Letter Carriers'
Association. The four unions represent about 85 percent of all postal
employees.
[47] We selected the four districts we visited to include districts
that (1) had either relatively high or low percentages of employees in
modified work assignments as of December 2008 and (2) were implementing
various phases of the NRP (Phase 1 or 2) when we began our review. In
addition, the four selected districts are geographically diverse and
represent a mix of urban, suburban, and rural locations. Finally, we
selected the four other districts we contacted because they had been
implementing Phase 3 of the NRP the longest.
[48] Unlike employees in modified work assignments, these individuals
presumably receive the entirety of their work-related compensation from
DOL's OWCP program.
[49] While we requested data on the cost of implementing the NRP, the
Service did not provide us with this information. Furthermore, although
OWCP costs associated with employee outcomes resulting from the NRP can
be determined, it was not feasible for us to do so for a wide variety
of reasons, including the time and effort required to cross-match
employees with specific NRP outcomes, such as "no work available"
determinations (Phase 2) and "complete day no work" and "part-day no
work" determinations (Phase 3), to DOL's OWCP payment records.
[50] The number of employees in modified work assignments fluctuates
both between years and within each year as employees, for example, (1)
incur injuries and, possibly, begin working in modified assignments and
(2) return to full duty, retire, or otherwise separate from the Service
(i.e., leave their modified work assignments).
[51] Collectively, these employees represent about 7 to 8 percent of
the Service's workforce during fiscal year 2008.
[52] While the Service has eliminated 6 of its districts, it had 80
districts in fiscal year 2008.
[53] Data on the employee's work status provides, for example,
information on whether the employee was in a modified assignment during
fiscal year 2008 and whether he or she retired, separated, or returned
to full duty during that fiscal year.
[54] To ensure that employees in these assignments were counted only
once in our analysis, we generally used the employees' Social Security
numbers as their unique identifier. However, five of the districts'
workbooks did not provide the employees' Social Security numbers, so we
created other, unique identifiers for these employees.
[55] Multiple records occur when, for example, an employee reaches his
or her maximum medical improvement and is moved from a limited duty
assignment to a rehabilitation assignment. The 8,308 employees had from
2 to 10 records. Determining why these employees had up to 10 records
was beyond the scope of this review.
[56] This protocol was approved by senior Service headquarters
officials with overall responsibility for the workbooks and for
implementing the NRP.
[57] The Service's headquarters organization had the lowest percentage
(70 of 11,370 employees or, fewer than 1 percent) of employees in
modified work assignments during fiscal year 2008.
[58] As discussed in appendix II, our analysis of Service data
indicates that 50,031 employees with workplace injuries occupied a
modified work assignment during fiscal year 2008. Up to 9,740 other
employees could have been in such an assignment during the same time
period. However, for the purpose of this analysis, we limited our
analysis to the 50,031 employees who, based on the Service's data,
definitely occupied a modified work assignment during this period.
[End of section]
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