POSTAL REGULATORY COMMISSION

Analysis of the Postal 

Service’s FY 2022 Annual

Performance Report and 

FY 2023 Performance Plan

June 28, 2023

Postal Regulatory Commission

Submitted 06/28/2023 04:02 PM

Filing ID: 125527

Accepted 6/28/2023
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TABLE OF CONTENTS

Page

CHAPTER I: INTRODUCTION............................................................................................................................1

A. Background.................................................................................................................................1

B. FY 2023 Plan and FY 2022 Report.....................................................................................5

1. Evaluation of Performance Goals.........................................................................5

2. Observations and Recommendations ................................................................6

C. Procedural History................................................................................................................ 10

CHAPTER II: COMPLIANCE WITH LEGAL REQUIREMENTS............................................................. 13

A. Legal Requirements.............................................................................................................. 13

B. Commission Analysis ........................................................................................................... 14

1. FY 2023 Plan ............................................................................................................. 15

2. FY 2022 Report........................................................................................................ 17

3. Non-Public Performance Indicators ................................................................ 22

4. Performance Indicator Changes ........................................................................ 23

CHAPTER III: EVALUATION OF PERFORMANCE GOALS.................................................................... 25

A. High-Quality Service............................................................................................................. 25

1. Background ............................................................................................................... 25

2. Comments .................................................................................................................. 27

3. Commission Analysis............................................................................................. 29

B. Excellent Customer Experience ....................................................................................... 50

1. Background ............................................................................................................... 50

2. Comments .................................................................................................................. 55

3. Commission Analysis............................................................................................. 56

C. Safe Workplace and Engaged Workforce..................................................................... 80

1. Background ............................................................................................................... 80

2. Comments .................................................................................................................. 84

3. Commission Analysis............................................................................................. 85

D. Financial Health ..................................................................................................................... 98

1. Background ............................................................................................................... 98

2. Comments ................................................................................................................100

3. Commission Analysis...........................................................................................100

CHAPTER IV: STRATEGIC INITIATIVES..................................................................................................112

A. Background............................................................................................................................112

B. Commission Analysis .........................................................................................................114

Appendix A—Commission Findings and Recommendations

Appendix B—Checklists for Compliance with Major Legal Requirements
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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CHAPTER I: INTRODUCTION

A. Background

The Postal Service is required by Title 39 of the United States Code to submit to the 

Commission an annual performance report for the previous fiscal year and an annual 

performance plan for the current fiscal year.1 On December 29, 2022, the Postal Service 

filed its fiscal year (FY) 2022 Annual Report to Congress in Docket No. ACR2022.2 The 

FY 2022 Annual Report contains the Postal Service’s FY 2022 annual performance report 

(FY 2022 Report) and FY 2023 annual performance plan (FY 2023 Plan).3

The FY 2022 Report and FY 2023 Plan discuss the Postal Service’s performance goals,4

which are:

• High-Quality Service—deliver mail and packages on-time

• Excellent Customer Experience—improve Postal Service customer satisfaction with 

services provided through every primary touchpoint or interaction

• Safe Workplace and Engaged Workforce—promote employee safety in the 

workplace and increase employee satisfaction and engagement

• Financial Health—achieve financial stability and improve the Postal Service’s 

financial position by generating revenue, controlling expenses, and improving 

efficiency5

A performance goal is “a target level of performance expressed as a tangible, measurable 

objective, against which actual achievement shall be compared, including a goal expressed 

as a quantitative standard, value, or rate[.]” 39 U.S.C. § 2801(3). The FY 2022 Report

discusses the Postal Service’s progress in meeting its performance goals during FY 2022. 

The FY 2023 Plan describes the Postal Service’s plans for meeting its performance goals in 

FY 2023.

1 39 U.S.C. §§ 2803, 2804, 3652(g); 39 C.F.R. § 3050.43.

2 See United States Postal Service Annual Report to Congress; see also Library Reference USPS-FY22-17, December 29, 2022, folder “USPS-FY22-

17,” folder “FY22.17.Annual.Report,” file “FY 2022 Annual Report to Congress.pdf”(FY 2022 Annual Report).

3 FY 2022 Annual Report at 32-53. This Analysis cites to pages from the FY 2022 Annual Report when referring to the FY 2022 Report and 

FY 2023 Plan.

4 The Postal Service refers to the performance goals as “corporate performance outcomes.” See id. at 32-33.

5 See Docket No. ACR2020, Responses of the United States Postal Service to Questions 2-3 of Chairman’s Information Request No. 27, April 9, 

2021, question 2.b.ii. (Docket No. ACR2020, Response to CHIR No. 27); Docket No. ACR2020, Motion of the United States Postal Service for Late 

Acceptance of Responses to Questions 2 and 3 of Chairman’s Information Request No. 27, April 9, 2021.
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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Each performance goal has one or more performance indicators, which are metrics the 

Postal Service uses to measure outcomes and assess whether it has achieved the 

performance goals. See 39 U.S.C. § 2801(4). For example, the performance indicators for the 

High-Quality Service performance goal measure the percentage of various categories of 

mail delivered on-time. Figure I-1 lists the four performance goals and their corresponding 

performance indicators in FY 2022:

Figure I-1

FY 2022 Performance Goals and Performance Indicators

Source: FY 2022 Annual Report at 33.

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Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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For each performance indicator, the Postal Service sets a target in the annual performance 

plan and provides the result in the annual performance report for that fiscal year. See FY 

2022 Annual Report at 33. Table I-1 lists the four performance goals, their corresponding 

performance indicators, results from FY 2019 through FY 2022, and targets for FY 2022 

and FY 2023.
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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Table I-1

Performance Goals and Associated Performance Indicators, Targets, and Results

Performance 

Goal Performance Indicator

Targets Results

FY 2023 FY 2022 FY 2022 FY 2021 FY 2020 FY 2019

High-Quality 

Servicea

Single-Piece

First-Class Mail

2-Day 93.00% 90.25% 91.34% 86.44% 91.47% 92.05%

3-5-Day 90.28% 90.00% 83.62% 63.20% 78.83% 80.88%

Presorted

First-Class Mail

Overnight 95.00% 94.75% 94.92% 93.38% 94.72% 95.46%

2-Day 95.00% 93.00% 93.36% 88.29% 92.77% 94.10%

3-5-Day 92.20% 90.50% 91.49% 80.87% 89.89% 91.95%

First-Class Mail Letter and Flat Compositeb 92.50 91.00 91.00 82.69 89.73 91.36

USPS Marketing Mail and Periodicals 

Compositeb

93.37 91.50 92.86 87.12 88.38 88.73

Market Dominant Compositebc 93.00 91.25 92.14 85.30 89.00 89.86

Excellent 

Customer 

Experience

Customer Experience Composite Indexbd 74.39 72.99 72.72 68.49 72.40 69.04

Business Service Network 98.00% 97.33% 98.20% 97.89% 97.33% 96.68%

Point of Sale 87.46% 87.46% 86.34% 84.39% 87.46% 87.77%

Deliveryb 80.94 80.94 73.91 70.41 80.94 80.40

Customer Care Centerbd 69.88 63.02 70.75 61.85 60.03 46.94

Customer 360e 40.05% 40.05% 38.44% 33.34% 40.05% 37.45%

Business Mail Entry Unit 96.29% 96.72% 96.48% 95.66% 96.72% 96.00%

usps.com 73.41% 73.41% 73.62% 67.13% 73.41% 72.94%

Safe 

Workplace

and Engaged

Workforce

Total Accident Rate 13.25 13.45 12.39 13.48 13.09 14.19

Engagement Survey Response Ratee N/A 25% 25% 33% 38%

Grand Mean Engagement Scoree 3.33 3.38 3.31 3.36 3.29 3.36

Financial 

Health

Deliveries per Total Workhours % Change N/A N/A 0.90% (0.60)%

Controllable Income (Loss) $ in billions $0.50 ($4.10) ($0.47) ($2.39) ($3.75) ($3.42)

Note: Red text indicates target was not met. Green text indicates target was met.

N/A – Not used as a performance indicator for that fiscal year.

a Table I-1 lists targets and results for public performance indicators measuring High-Quality Service for Market Dominant products. The Postal Service 

filed under seal information for non-public performance indicators measuring High-Quality Service for certain Competitive products. FY 2022 Annual 

Report at 33 n.1; see Chapter II, Section B.3., infra.

b Targets and results for these performance indicators are not presented as percentages because they are calculated by weighting and aggregating 

various survey results.

c TheMarket Dominant Composite is an additional performance indicator the Postal Service began using in FY 2021 to measure High-Quality Service. See

FY 2022 Annual Report at 33 n.4. Results from FY 2019 and FY 2020 are shown for comparison purposes.

d Results of the Customer Experience Composite Index and Customer Care Center performance indicators are not comparable from FY 2019 through 

FY 2022. See Chapter II, Section B.2.b., infra.

e

In FY 2022, the Postal Service changed the performance indicator for measuring an engaged workforce from the Engagement Survey Response Rate to 

the Grand Mean Engagement Score. See Chapter III, Section C.1.b., infra.

Source: FY 2022 Annual Report at 33; Docket No. ACR2021, Postal Regulatory Commission, Analy i f the P tal Servi e’ FY 2021 Ann al Perf r an e 

Report and FY 2022 Performance Plan, June 30, 2022, at 3 (FY 2021 Analysis).
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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B. FY 2023 Plan and FY 2022 Report

Each year, the Commission must evaluate whether the Postal Service met its performance 

goals established in the annual performance plan and annual performance report. 39 U.S.C. 

§ 3653(d). The Commission may also “provide recommendations to the Postal Service 

related to the protection or promotion of public policy objectives set out in [Title 39].” Id.

1. Evaluation of Performance Goals

The Commission evaluates whether the Postal Service met each performance goal by 

comparing targets and results for each performance indicator measuring progress toward 

that goal. It considers the Postal Service to have met a performance goal if the result of each 

performance indicator for that performance goal meets or exceeds the target established in 

the applicable performance plan. FY 2021 Analysis at 4. The Commission considers the 

Postal Service to have partially met a performance goal if the Postal Service meets or 

exceeds some but not all targets for each performance indicator measuring progress 

toward that goal. The Commission considers the Postal Service to have not met a 

performance goal if it missed targets for each performance indicator measuring progress 

toward that goal.

For each performance goal, the Commission compared FY 2022 targets and results for each 

performance indicator. Table I-1 and Figure I-2 show which performance indicators met or 

exceeded targets for each performance goal and which ones failed to meet targets. Based 

on this comparison, the Commission finds that in FY 2022:

• The Postal Service partially met the High-Quality Service performance goal because 

it met seven of the eight targets for the High-Quality Service performance indicators.

• The Postal Service partially met the Excellent Customer Experience performance 

goal because it exceeded targets for three performance indicators but missed 

targets for the other five performance indicators.

• The Postal Service partially met the Safe Workplace and Engaged Workforce 

performance goal because it exceeded the FY 2022 Total Accident Rate target but 

missed the FY 2022 Grand Mean Engagement Score target.

• The Postal Service met the Financial Health performance goal because the FY 2022 

Controllable Income (Loss) result was better than the target.
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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Figure I-2

FY 2022 Performance Indicators That

Met, Exceeded, or Failed to Meet Targets

Source: FY 2022 Annual Report at 34, 38, 42-43, 46.

Chapter III discusses the Postal Service’s explanations for why it partially met or met the 

High-Quality Service, Excellent Customer Experience, Safe Workplace and Engaged 

Workforce, and Financial Health performance goals, as well as its plans and timelines for 

achieving each performance goal in FY 2023.

2. Observations and Recommendations

When evaluating whether the Postal Service met its performance goals, the Commission 

may provide recommendations related to protecting or promoting public policy objectives 

in Title 39. 39 U.S.C. § 3653(d). In this Analysis, the Commission provides observations and 

recommendations for each performance goal. These observations and recommendations 

are discussed in detail in Chapter III and include the following:

 e ee e e 

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 Single Piece First Class ail 

 2 a 

 Presorted First Class ail

 vernight 2 a 3 a 

 First Class ail e er and Flat Composite

 SPS ar e ng ail and Periodicals 

Composite

 ar et ominant Composite

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 Total Accident Rate

 e en u e e en e

 usiness Service Net or 

 Customer Care Center

 

 n n e 

 Controlla le Income oss 

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 Single Piece First Class ail 

 3 a 

 e e n n e e

 rand ean ngagement Score

 e en u e e en e

 Customer perience 

Composite Inde 

 Point of Sale

 eliver 

 Customer 3 

 usiness ail ntr nit
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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High-Quality Service:

• The Commission commends the Postal Service for its efforts to deliver COVID-19 

test kits. These efforts demonstrate the Postal Service’s vital role in the COVID-19 

pandemic response.

• The Commission finds that the High-Quality Service performance goal was partially 

met in FY 2022, with the Postal Service failing to meet one performance indicator 

related to Market Dominant products.

• The Commission continues to recommend that the Postal Service develop more 

granular composite indicators for service performance based on significant class, 

shape, and product-level differences between mailpieces. If the Postal Service 

continues using highly aggregated composites as performance indicators, then the 

Commission recommends that the Postal Service also develop more granular 

performance indicators, such as it currently uses for First-Class Mail, to supplement 

the highly aggregated composites. Finally, the Commission expects the Postal 

Service to include with each Annual Report supporting workpapers containing the 

inputs for, and a detailed calculation of, the High-Quality Service performance 

indicator results, to the extent that they are not included elsewhere in the Annual 

Compliance Report (ACR) filing.

• In the FY 2023 Annual Performance Report (FY 2023 Report), the Postal Service 

should address whether any service standard changes implemented in FY 2023

affected the comparability of performance indicator results. If comparability has 

been affected, the Postal Service should propose a way for the Commission to 

compare FY 2023 High-Quality Service performance indicator results to results from 

prior fiscal years. If the Postal Service asserts that comparability is unaffected, the 

Postal Service should fully explain the rationale and supporting basis for this 

assertion. The Postal Service should also consider methodologies to study the effect 

of service standard changes on Operating Plan Precision (OPP) at affected facilities.

• The Commission encourages the Postal Service to continue reviewing routings and 

streamlining its network to reduce complexity, improve reliability, and improve 

service performance for the Single-Piece First-Class Mail 3-5-Day performance 

indicator.

• The Commission commends the Postal Service for its efforts devoted to delivering 

Election Mail and Political Mail during the CY 2022 election cycle. These efforts were 

undertaken notwithstanding the adverse effects of the COVID-19 pandemic, in 

furtherance of the vital role the Postal Service plays in the American democratic 

process.

• The Commission recommends that the Postal Service:

o Consider the additional processing requirements for single-piece volumes when 

devising targets in the future. As these requirements and associated challenges 

can be anticipated based on experience, they should be accounted for in 

developing applicable targets. If the Postal Service experiences higher-thanexpected failure in certain processes relating to the processing of single-piece 
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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volumes and does not achieve any of its single-piece performance targets in 

FY 2023, it should explain the reason that failures in processing single-piece 

volumes exceed expectations and identify the operational processes 

experiencing the failures.

o Continue monitoring and optimizing peak season performance.

o Continue to monitor fluctuations in employee availability and its impact on 

service performance.

o Continue initiatives to reduce supplier failure, improve supplier capacity, and 

increase its efforts to address Critically Late Trips (CLTs) whose causes are 

within its direct control.

o Report on its progress in developing, and any results from, the Unexpected 

Events Initiative in the FY 2023 Report, including any effect on reducing CLTs.

o Report how the Delivering for America Plan (10-Year Strategic Plan) (as a whole 

and for applicable distinct initiatives) affected the High-Quality Service 

performance indicator result.6

o Explore ways to better balance service performance scores across the nation and 

study the reasons for service performance issues in the lowest performing 

Areas/Districts.

Excellent Customer Experience:

• The Commission recommends that the Postal Service consider asking questions on 

the Customer 360 (C360) survey about mail theft to collect more data and evaluate 

its impact on C360 performance indicator results. The Commission also 

recommends that the Postal Service consider adding questions to the Delivery 

survey about missed mail or non-delivery of mail to gather more data on this issue.

• The Commission finds that the FY 2023 targets for the Excellent Customer 

Experience performance indicators are reasonable. It reiterates its recommendation 

that the Postal Service consider the prior year’s result when setting the subsequent 

year’s target. To improve transparency, the FY 2024 annual performance plan (FY 

2024 Plan) should discuss the rationale for setting the FY 2024 targets.

• The Commission recommends that the Postal Service continue to use the Net 

Promoter Score to measure and assess customer experience (CX) in FY 2023. The 

Commission also recommends the Postal Service focus its efforts on improving the 

C360 Net Promoter Score to have a higher percentage of Promoters than Detractors.

• The Commission finds that the Postal Service is effectively using social listening to 

determine what people are saying about its brand and services on social media. The 

social media heat map is an effective tool for visualizing customer comments and

categorizing them by concern and geographic area. The Commission recommends 

6 United States Postal Service, Delivering for America: Our Vision and Ten-Year Plan to Achieve Financial Sustainability and Service Excellence, 

March 23, 2021, available at https://about.usps.com/what/strategic-plans/delivering-for-america/assets/USPS_Delivering-For-America.pdf

(10-Year Strategic Plan).
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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that the Postal Service continue to use social listening and the social media heat map 

to improve CX in FY 2023.

• The Commission commends the Postal Service for continuing to expand its efforts to 

respond to customer inquiries via social media. The Commission encourages the 

Postal Service to continue using the Facebook ChatBOT, Artificial Intelligence Virtual 

Agent, and other artificial intelligence tools to continue helping customers and to 

improve the response time for customer inquiries.

Safe Workplace and Engaged Workforce:

• The Commission commends the Postal Service for meeting the Total Accident Rate 

target for the fourth year in a row and achieving the best result since the Postal 

Service began using the Total Accident Rate as a performance indicator in FY 2017. 

The Commission finds that the FY 2023 Total Accident Rate target is reasonable 

considering the changes in FY 2023 that could increase the potential for safety 

incidents.

• The Commission recommends that the Postal Service continue to recognize 

employees that promote a safe workplace and motor vehicle safety in quarterly 

newsletters and other publications. Also, the Commission recommends that the 

Postal Service continue to monitor the safety and performance of contractoroperated motor vehicles (including vehicles operated by subcontractors of freight 

brokers) and address safety incidents shortly after they occur to help prevent future 

incidents and unsafe practices.

• The Commission is concerned that mean scores for almost every question on the 

Postal Pulse survey decreased in FY 2022 but acknowledges that none of the scores 

declined by more than 0.08 points on the survey scale. The decline in employee 

engagement is consistent with employee engagement levels across the country in 

recent years. The FY 2023 Grand Mean Engagement Score target is reasonable 

considering the range of results during the past few years.

• The Commission recommends that the Postal Service implement the programs 

described in the FY 2023 Plan to improve the Engagement Survey Response Rate in 

FY 2023. If the rate does not improve in FY 2023, the Commission recommends that 

the Postal Service investigate and address the root causes and describe its efforts to 

do so in the FY 2023 Report.

Financial Health:

• The Commission finds that the Postal Service met the Financial Health performance 

goal in FY 2022.

• The Commission recommends that the Postal Service continue to include 

information on Controllable Income (Loss) and non-controllable expenses in future 

annual performance plans and annual performance reports.

• In all future Annual Reports through the first year following completion of the 

10-Year Strategic Plan, the Postal Service should report on the effects of the 10-Year 
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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Strategic Plan on: (1) the Postal Service’s Financial Health performance indicator 

results; and (2) labor productivity.

• The Commission encourages the Postal Service to communicate with its 

stakeholders to gather their views of the effects of rate increases on volume.

• The Commission recommends that the Postal Service consider whether a Generally 

Accepted Accounting Principle (GAAP) measure such as Net Income (Loss) or Net 

Operating Income (Loss) offers a more useful indication of the Postal Service’s 

financial health and whether such a metric should be used as a performance 

indicator in lieu of, or in addition to, Controllable Income (Loss). If the Postal Service 

makes changes to, or supplements, the Controllable Income (Loss) performance 

indicator in its FY 2023 Report, the Postal Service should also provide comparable 

performance indicator results for FY 2020 through FY 2023 to help ensure 

compliance with 39 U.S.C. § 2804(c).

• The Commission recommends that the Postal Service continue monitoring and 

reporting Total Factor Productivity (TFP) and labor productivity trends. The 

Commission recommends that future annual performance reports continue to 

include information on TFP, labor productivity, and other productivity measures. In 

addition, the Postal Service should explain the reason for any changes in TFP and/or 

labor productivity in FY 2023.

• The Commission continues to recommend that the Postal Service consider adopting 

one or more additional performance indicators for measuring progress towards the 

Financial Health performance goal. Specifically, the Commission recommends that 

the Postal Service consider incorporating the operating ratio, or another measure 

associated with operational efficiency, as a performance indicator.

The Commission’s findings, observations, and recommendations contained in this Analysis 

are listed in Appendix A.

C. Procedural History

Since Docket No. ACR2013, the Commission has evaluated whether the Postal Service met 

its performance goals in reports separate from the Annual Compliance Determination

(ACD).7 By issuing separate reports, the Commission provides a more in-depth analysis of 

the Postal Service’s progress toward meeting its performance goals and plans to improve 

7 See Docket No. ACR2013, Postal Regulatory Commission, Review of Postal Service FY 2013 Performance Report and FY 2014 Performance Plan, 

July 7, 2014; Docket No. ACR2014, Postal Regulatory Commission, Analy i f the P tal Servi e’ FY 2014 Program Performance Report and 

FY 2015 Performance Plan, July 7, 2015; Docket No. ACR2015, Postal Regulatory Commission, Analy i f the P tal Servi e’ FY 2015 Ann al 

Performance Report and FY 2016 Performance Plan, May 4, 2016 (FY 2015 Analysis); Docket No. ACR2016, Postal Regulatory Commission, 

Analy i f the P tal Servi e’ FY 2016 Ann al Performance Report and FY 2017 Performance Plan, April 27, 2017 (FY 2016 Analysis); Docket 

No. ACR2017, Postal Regulatory Commission, Analy i f the P tal Servi e’ FY 2017 Ann al Perf r an e Re rt and FY 2018 Performance 

Plan, April 26, 2018 (FY 2017 Analysis); Docket No. ACR2018, Postal Regulatory Commission, Analysis f the P tal Servi e’ FY 2018 Annual 

Performance Report and FY 2019 Performance Plan, May 13, 2019 (FY 2018 Analysis); Docket No. ACR2019, Postal Regulatory Commission, 

Analysis of the P tal Servi e’ FY 2019 Annual Performance Report and FY 2022 Performance Plan, June 1, 2022 (FY 2019 Analysis); Docket No. 

ACR2020, Postal Regulatory Commission, Analy i f the P tal Servi e’ FY 2020 Ann al Perf r an e Re rt and FY 2021 Perf r an e Plan, 

June 2, 2021 (FY 2020 Analysis); FY 2021 Analysis.
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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performance in future years. The Commission continues this current practice by issuing its 

analysis of the FY 2023 Plan and FY 2022 Report separately from the FY 2022 ACD.8

In conducting this review, the Commission designated a Public Representative and invited 

comments on whether the Postal Service met its performance goals and satisfied applicable 

statutory and regulatory requirements.9 It also sought input on public policy 

recommendations, strategic initiatives, and other relevant matters. Order No. 6047 at 3.

Several CHIRs were issued seeking clarification of the FY 2023 Plan and FY 2022 Report.

10

The Postal Service filed responses to all information requests.11 The Public Representative 

and the National Association of Presort Mailers (NAPM) filed comments,12 which the Postal 

Service addressed in reply comments.13

The Commission analyzes the FY 2023 Plan and FY 2022 Report in the following chapters:

• Chapter II analyzes the FY 2023 Plan and FY 2022 Report for compliance with the 

legal requirements of 39 U.S.C. §§ 2803 and 2804.

8 See Annual Compliance Determination Report, Fiscal Year 2022, March 29, 2023 (FY 2022 ACD).

9 Notice Requesting Comments on the Postal Service FY 2022 Annual Performance Report and FY 2023 Annual Performance Plan, January 11, 

2023, at 3 (Order No. 6407).

10 Chairman's Information Request No. 13, February 10, 2023 (CHIR No. 13); Chairman's Information Request No. 14, February 24, 2023 (CHIR 

No. 14); Chairman's Information Request No. 15, February 28, 2023 (CHIR No. 15); Chairman's Information Request No. 17, March 3, 2023 (CHIR 

No. 17); Chairman's Information Request No. 18, March 14, 2023 (CHIR No. 18); Chairman's Information Request No. 19, March 20, 2023 (CHIR 

No. 19); Chairman's Information Request No. 20, March 21, 2023 (CHIR No. 20); Chairman's Information Request No. 23, March 29, 2023 (CHIR 

No. 23); Chairman's Information Request No. 24, March 31, 2023 (CHIR No. 24); Chairman's Information Request No. 25, April 13, 2023 (CHIR 

No. 25); Chairman's Information Request No. 26, April 17, 2023 (CHIR No. 26); Chairman's Information Request No. 27, April 26, 2023 (CHIR No. 

27); Chairman's Information Request No. 29, May 3, 2023 (CHIR No. 29); Chairman's Information Request No. 30, May 8, 2023 (CHIR No. 30).

The Postal Service filed a motion for reconsideration of questions 1-10 and 16 of CHIR No. 13. Motion for Reconsideration of Questions 1-10 

and 16 of Chairman's Information Request No. 13, February 16, 2023 (Motion for Reconsideration). Because questions 1-10 and 16 of CHIR No. 

13 were subsequently withdrawn, the Commission denies the Motion for Reconsideration as moot. See Notice Concerning Chairman's 

Information Request No. 13, Questions 1 through 10 and 16, February 28, 2023.

11 Responses of the United States Postal Service to Questions 11-15 of Chairman’s Information Request No. 13, February 24, 2023 (Response to 

CHIR No. 13); Responses of the United States Postal Service to Questions 1-8 of Chairman's Information Request No. 14, March 3, 2023

(Response to CHIR No. 14); Responses of the United States Postal Service to Questions 1-5 of Chairman's Information Request No. 15, March 7,

2023 (Response to CHIR No. 15); Responses of the United States Postal Service to Questions 1-11 of Chairman's Information Request No. 17, 

March 10, 2023 (Response to CHIR No. 17); Responses of the United States Postal Service to Questions 1-6 of Chairman’s Information Request 

No. 18, March 21, 2023 (Response to CHIR No. 18); Responses of the United States Postal Service to Questions 1-7 of Chairman's Information 

Request No. 19, March 27, 2023 (Response to CHIR No. 19); Responses of the United States Postal Service to Questions 1-4 of Chairman's

Information Request No. 20, March 28, 2023 (Response to CHIR No. 20); Responses of the United States Postal Service to Questions 1-12 of 

Chairman's Information Request No. 23, April 5, 2023 (Response to CHIR No. 23); Responses of the United States Postal Service to Questions 1-3 

of Chairman's Information Request No. 24, April 7, 2023 (Response to CHIR No. 24); Responses of the United States Postal Service to Questions 

1-7 of Chairman's Information Request No. 25, April 20, 2023 (Response to CHIR No. 25); Responses of the United States Postal Service to 

Questions 1-12 of Chairman's Information Request No. 26, April 24, 2023 (Response to CHIR No. 26); Responses of the United States Postal 

Service to Questions 1-3 of Chairman's Information Request No. 27, May 3, 2023 (Response to CHIR No. 27); Responses of the United States 

Postal Service to Questions 1-10 of Chairman's Information Request No. 29, May 10, 2023 (Response to CHIR No. 29); Responses of the United 

States Postal Service to Questions 1-5 of Chairman's Information Request No. 30, May 15, 2023 (Response to CHIR No. 30).

12 Public Representative Comments on the FY 2022 Performance Report and FY 2023 Performance Plan, March 14, 2023 (PR Comments); 

Comments of the National Association of Presort Mailers, March 13, 2023 (NAPM Comments).

13 Reply Comments of the United States Postal Service, March 29, 2023 (Postal Service Reply Comments).
Analysis of FY 2022 Performance Report Introduction

and FY 2023 Performance Plan

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• Chapter III evaluates whether the Postal Service met its four performance goals in 

FY 2022 and contains related observations and recommendations for each 

performance goal.

• Chapter IV discusses the Postal Service’s strategic initiatives and its 10-Year 

Strategic Plan.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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CHAPTER II: COMPLIANCE WITH LEGAL 

REQUIREMENTS

A. Legal Requirements

The FY 2023 Plan and FY 2022 Report must meet the requirements of 39 U.S.C. §§ 2803 and 

2804.14 Section 2803 establishes requirements for the Postal Service’s annual performance 

plan, which must cover “each program activity set forth in the Postal Service budget,”15 and 

must:

• Establish performance goals that define the performance level to be achieved by a 

program activity

• Express the performance goals in an objective, quantifiable, and measurable form 

unless an alternative form is used16

• Briefly describe the operational processes, skills and technology, and the human, 

capital, information, or other resources needed to meet the performance goals

• Establish performance indicators to measure or assess each program activity’s 

relevant outputs, service levels, and outcomes

• Provide a basis for comparing actual program results with established performance 

goals

• Describe the means to be used to verify and validate measured values

39 U.S.C. § 2803(a). The annual performance plan may aggregate, disaggregate, or 

consolidate program activities, provided that doing so does not omit or minimize the 

14 Chapter 28 of Title 39, which includes sections 2803 and 2804, was added by the Government Performance and Results Act (GPRA) of 1993, 

Pub. L. 103-62, 107 Stat. 285 (1993). Sections 2803 and 2804 were not affected by the GPRA Modernization Act of 2010, which does not apply 

to the Postal Service. See Pub. L. 111-352, 124 Stat. 3866 (2011).

15 A “program activit ” is “a specific activit related to the mission of the Postal Service[.]” 39 .S.C. § 28 1 . The Commission discusses 

program activities below. See Section B.1., infra.

16 See 39 U.S.C. § 2803(b). The Postal Service may use an alternative form if it determines that it is not feasible to express the performance goals 

for a particular program activity in an objective, quantifiable, and measurable form. Id. The alternative form must either: (1) include separate 

descriptive statements of a minimally effective program and a successful program, with sufficient precision and in such terms to allow for an 

accurate, independent determination of hether the program activit ’s performance meets the criteria of either descriptive statement; or (2)

“state h it is infeasi le or impractical to e press a performance goal in an form for the program activit .” Id. §§ 2803(b)(1), (b)(2).
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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significance of any program activity constituting a major function or operation. Id.

§ 2803(c).

39 U.S.C. § 2804 sets forth requirements for the Postal Service’s annual performance 

report, which must:

• Evaluate whether the Postal Service has met the performance goals previously 

established by the annual performance plan for that fiscal year

• “[S]et forth the performance indicators established in the Postal Service 

performance plan, along with the actual program performance achieved compared 

with the performance goals expressed in the plan for that fiscal year”17

• Include “actual results for the three preceding fiscal years”

• Evaluate the annual performance plan for the current fiscal year (in this case, the 

FY 2023 Plan) relative to the performance achieved toward those goals in the year 

covered by the annual performance report (in this case, the FY 2022 Report)

• If the Postal Service does not meet a performance goal, explain why the goal was not 

met and describe plans and schedules for achieving the performance goal18

• Include summary findings of program evaluations completed during the fiscal year 

covered by the report

39 U.S.C. § 2804(b)(1), (c), (d).

CHIR Nos. 17 and 23 were issued to help evaluate compliance with 39 U.S.C. §§ 2803 

and 2804. The Public Representative asserts that the FY 2023 Plan and FY 2022

Report complies with sections 2803 and 2804. PR Comments at 4. He states that the 

Postal Service “has included all of the information necessary to evaluate its 

performance in FY 2022 and has included the information required on the program

activities set forth in the Postal Service budget for FY 2023.” Id.

B. Commission Analysis

This section evaluates whether the FY 2023 Plan and FY 2022 Report complied with 

39 U.S.C. §§ 2803 and 2804, respectively. 39 U.S.C. §§ 2803 and 2804. The Commission 

17 Id. § 2804(b)(1). If performance goals are specified in an alternative form by descriptive statements of a minimally effective program activity 

and a successful program activity, the annual performance report must describe results of these program activities in relation to these 

categories, including whether the performance failed to meet the criteria of either category. Id. § 2804(b)(2); see id. § 2803(b).

18 Id. § 2804(d)(3)(A) and (B). If the performance goal is impractical or infeasible, the annual performance report must explain why and 

recommend further action. Id. § 2804(d)(3)(C).
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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finds that the FY 2023 Plan complies with section 2803. The FY 2022 Report complies with 

section 2804 except for the Excellent Customer Experience performance goal, which does 

not comply with section 2804(c). See Section B.2.b., infra.

Appendix B includes guidance for compliance with the major requirements of 39 U.S.C. 

§§ 2803 and 2804 for the FY 2024 Plan and FY 2023 Report.

1. FY 2023 Plan

The FY 2023 Plan must meet the requirements of 39 U.S.C. § 2803. The Commission 

evaluates legal compliance based on the following seven elements.

First, the FY 2023 Plan must “cover[] each program activity set forth in the Postal Service 

budget . . . .” See 39 U.S.C. § 2803(a). The Commission previously found that “Postal Service 

budget” in section 2803(a) means the Postal Service’s operating budget that is part of the 

Integrated Financial Plan (IFP). See FY 2016 Analysis at 13. In the FY 2021 Analysis, the 

Commission stated that to comply with 39 U.S.C. § 2803(a), the FY 2023 Plan must identify 

all program activities in the FY 2023 IFP and link each program activity to at least one 

performance goal or indicator. FY 2021 Analysis, Appendix B at 1.

In the FY 2023 Plan, the Postal Service explains that FY 2023 targets for each performance 

indicator are aligned with the FY 2023 IFP, which includes the Postal Service’s planned 

revenue and expenses for FY 2023. FY 2022 Annual Report at 32. It notes that each fiscal 

year, it develops a plan and budget intended to be sufficient to meet targeted financial and 

nonfinancial performance outcomes. Id. It states that it sets all performance indicator 

targets “to be achievable given the planned expenses in the IFP.” Id. The Postal Service 

complied with the Commission’s directive by identifying the program activities in the 

FY 2023 IFP (planned revenue and expenses) and linking them to the targets set for each 

performance indicator.

Second, the FY 2023 Plan must “establish performance goals to define the level of 

performance to be achieved by a program activity[.]” 39 U.S.C. § 2803(a)(1). Section 

2803(a)(1) requires the FY 2023 Plan to establish performance goals and set targets for 

each performance indicator the Postal Service will use to evaluate performance during 

FY 2023. See FY 2016 Analysis at 10. If no target is set, the Postal Service should explain 

why. FY 2021 Analysis at 13.

In the FY 2023 Plan, the Postal Service establishes four performance goals and sets targets 

for each public performance indicator the Postal Service will use to evaluate performance 
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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during FY 2023.

19 The Postal Service did not set a FY 2023 target for the Engagement 

Survey Response Rate because it stopped using that metric in FY 2022 and replaced it with 

the Grand Mean Engagement Score as the performance indicator for measuring progress 

toward the Safe Workplace and Engaged Workforce performance goal.20 The Postal Service 

also did not set a FY 2023 target for Deliveries per Total Workhours % Change because it 

stopped using this metric as a performance indicator in FY 2021. See FY 2021 Analysis at 

118.

Third, the FY 2023 Plan must “express [performance] goals in an objective, quantifiable, 

and measurable form unless an alternative form is used under [section 2803](b)[.]” See 

39 U.S.C. § 2803(a)(2). Section 2803(a)(2) requires the FY 2023 Plan to express 

performance goals as quantitative targets that can be compared with objectively measured 

results for each performance indicator unless an alternative form is used under section 

2803(b). FY 2016 Analysis at 10. The FY 2023 Plan meets this requirement because the

FY 2023 target for each performance indicator is expressed in a measurable form, such as a 

percentage or dollar amount. See FY 2022 Annual Report at 33.

Fourth, the FY 2023 Plan must “briefly describe the operational processes, skills and 

technology, and the human, capital, information, or other resources required to meet the 

performance goals[.]” See 39 U.S.C. § 2803(a)(3). The FY 2023 Plan meets this requirement 

by explaining what resources are necessary to meet each performance goal. For example, to 

meet the High-Quality Service performance goal in FY 2023, the Postal Service states it will 

transform its processing facilities and transportation networks; prepare for the peak 

season; invest in new vehicles, equipment, systems, and facilities; and stabilize and 

empower its workforce. FY 2022 Annual Report at 35-37.

Fifth, the FY 2023 Plan must “establish performance indicators to be used in measuring or 

assessing the relevant outputs, service levels, and outcomes of each program activity[.]” See

39 U.S.C. § 2803(a)(4). Performance indicators are metrics established by the Postal 

Service for measuring progress toward each performance goal.21 The FY 2023 Plan meets 

this requirement because each performance goal has at least one performance indicator 

that evaluates outputs, service levels, and outcomes. For example, the Safe Workplace and 

Engaged Workforce performance goal uses two performance indicators to measure 

workplace safety and employee engagement outcomes. See FY 2022 Annual Report at 41-44.

19 See FY 2022 Annual Report at 33. The Postal Service also uses several non-public performance indicators for Competitive products to measure 

progress toward the High-Quality Service performance goal. See Section B.3., infra. FY 2023 target(s) are included in a non-public annex filed 

with the FY 2022 ACR. See FY 2022 Annual Report at 33 n.1; Library Reference USPS-FY22-NP30, December 29, 2022, folder “USPS-FY22-NP30”, 

file "NONPUBLIC Preface USPS-FY22-NP30.pdf," at 8 (Library Reference USPS-FY22-NP30, Preface).

20 Docket No. ACR2021, Library Reference USPS-FY21-17, December 29, 2021, file “FY 2021 Annual Report to Congress.pdf,” at 44 (FY 2021

Annual Report). The Grand Mean Engagement Score and Engagement Survey Response Rate are discussed in Chapter III, Section C., infra.

21 Specificall , a performance indicator is “a particular value or characteristic used to measure output or outcome[.]” 39 .S.C. § 2801(4).
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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Sixth, the FY 2023 Plan must “provide a basis for comparing actual program results with 

the established performance goals[.]” See 39 U.S.C. § 2803(a)(5). The FY 2023 Plan meets 

this requirement by listing the performance indicators that will provide a basis for 

comparing FY 2023 results with the targets established in the FY 2023 Plan. See FY 2022

Annual Report at 33.

Seventh, the FY 2023 Plan must “describe the means to be used to verify and validate 

measured values.” See 39 U.S.C. § 2803(a)(6). Section 2803(a)(6) requires the Postal 

Service to explain how it verifies and validates targets and results for each performance 

indicator using objective measurement systems. FY 2021 Analysis at 15. The FY 2023 Plan

meets this requirement by, for example, explaining that it uses an internal Service 

Performance Measurement (SPM) system “that measures and reports service performance 

from the time mail is deposited in a Postal Service facility to when a USPS employee 

delivers it to a home, business, or PO Box.” See FY 2022 Annual Report at 34.

For these reasons, the Commission finds that the FY 2023 Plan complies with all requirements 

of 39 U.S.C. § 2803(a).

Appendix B contains guidance to assist the Postal Service’s efforts to ensure the FY 2024

Plan complies with section 2803(a).

2. FY 2022 Report

The FY 2022 Report complies with 39 U.S.C. § 2804 except for the Excellent Customer 

Experience performance goal, which does not comply with section 2804(c). The FY 2022

Report is non-compliant with respect to this performance goal because Customer Care 

Center (CCC) performance indicator results are not comparable from FY 2019 through 

FY 2022, and the Postal Service did not provide the explanations required by the 

Commission.

a. Comparable FY 2022 Targets and Results

The annual performance report must “set forth the performance indicators established in 

the Postal Service performance plan, along with the actual program performance achieved 

compared with the performance goals expressed in the plan for that fiscal year.” 39 U.S.C. § 

2804(b)(1). Section 2804(b)(1) requires results expressed in the annual performance 

report to be comparable with targets set in the annual performance plan for that fiscal year. 

FY 2016 Analysis at 16. In the FY 2021 Analysis, the Commission stated that to comply with 

section 2804(b)(1), the FY 2022 Report “must set forth the same performance indicators 

and targets as the FY 2022 Plan and compare FY 2022 targets and results for each 

performance indicator.” FY 2021 Analysis at 16.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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Also, the Commission directed that the FY 2022 Report express results for each 

performance indicator that are comparable to the corresponding FY 2022 targets set in the 

FY 2022 Plan. Id. The Commission stated that if a comparable FY 2022 result is not

provided, the FY 2022 Report must explain why and address the lack of comparability by 

explaining either of the following: (1) how to compare results between the current and 

former methodologies; or (2) why making this comparison is not feasible. Id. It also 

recommended that the Postal Service maintain the same performance indicators, 

methodologies, and targets once they are set in the applicable annual performance plan. Id.

The FY 2022 Report includes the same performance indicators and targets set in the 

FY 2022 Plan and compares FY 2022 targets and results for each performance indicator.22

The Postal Service confirms that the FY 2022 target and result for each performance 

indicator are comparable. Response to CHIR No. 23, question 1.

The Commission finds that the FY 2022 Report complies with 39 U.S.C. § 2804(b)(1). To 

comply with 39 U.S.C. § 2804(b)(1) next year, the FY 2023 Report must set forth the same 

performance indicators and targets as the FY 2023 Plan and compare FY 2023 targets and 

results for each performance indicator.

Also, the FY 2023 result for each performance indicator must be comparable to the 

corresponding FY 2023 target set in the FY 2023 Plan. If a comparable FY 2023 result is not

provided, the FY 2023 Report must address the lack of comparability by explaining either of 

the following:

1. How to compare results between the current and former methodologies; or

2. Why making this comparison is not feasible.

The Commission recommends that the Postal Service not change performance indicators, 

methodologies, or targets once they are set for a given fiscal year.

b. Comparable Three-Year Results

The annual performance report must also “include actual results for the three preceding 

fiscal years” as required by 39 U.S.C. § 2804(c). The Commission previously found that 

“actual results” under section 2804(c) must be comparable across the three preceding 

fiscal years. See FY 2016 Analysis at 18. In the FY 2021 Analysis, the Commission stated that 

“[t]o comply with 39 U.S.C. § 2804(c) next year, the FY 2022 Report must include 

comparable results for each performance indicator for FYs 2019, 2020, 2021, and 2022. To 

be comparable, results for each fiscal year must be calculated and expressed using the 

same methodology.” FY 2021 Analysis at 19. If comparable results cannot be provided, the 

22 Compare FY 2022 Annual Report at 33, with FY 2021 Annual Report at 33.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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Commission directed the Postal Service to identify each performance indicator with noncomparable results and provide the required explanations in the FY 2022 Report. Id.

For the High-Quality Service, Safe Workplace and Engaged Workforce, and Financial Health 

performance goals, the FY 2022 Report is compliant.23 For 7 of the 8 performance indicators 

for the Excellent Customer Experience performance goal, the FY 2022 Report is compliant.24

However, with respect to the remaining performance indicator for the Excellent Customer 

Experience performance goal (CCC), the FY 2022 Report is non-compliant. The CCC 

performance indicator result is a composite of overall satisfaction with the Live Agent and 

Interactive Voice Response (IVR) system.25 In FY 2019 and FY 2020, the Live Agent result 

was weighted 25 percent, and the IVR system result was weighted 75 percent.26 In FY 

2021, the Postal Service discontinued weighting the Live Agent and IVR system results and 

instead consolidated all responses into one overall calculation. Id. This was a methodology 

change that affected the comparability of CCC results between the periods FYs 2019-2020 

(weighted) and FYs 2021-2022 (unweighted).

The FY 2022 Report lacks any reference to the non-comparability of CCC results from 

FY 2019 through FY 2022.

27 In the FY 2021 ACR, the Postal Service acknowledged that the 

methodology change affected comparability of results but asserted that the impact was 

minor because there was only a small difference in the result calculated using the new 

methodology compared to the former methodology. FY 2021 ACR at 58. By contrast, the 

FY 2022 ACR does not discuss or mention the comparability issue with the CCC 

performance indicator. For these reasons, the FY 2022 Report does not comply with 

39 U.S.C. § 2804(c) for the Excellent Customer Experience performance goal. Additionally, 

because FY 2020 CCC results will not be comparable to results from FY 2021 through 

FY 2023, the Postal Service will need to address this issue to comply with 39 U.S.C. 

§ 2804(c) in its FY 2023 Report.

28

23 Response to CHIR No. 17, question 3.c.; Response to CHIR No. 23, question 2.a.

24 Response to CHIR No. 23, question 2.a. The eight Excellent Customer Experience performance indicators are the Customer Experience (CX) 

Composite Index, Business Service Network (BSN), Point of Sale (POS), Delivery, CCC, Customer 360 (C360), usps.com, and Business Mail Entry 

Unit (BMEU). See FY 2022 Annual Report at 33.

25 United States Postal Service FY 2022 Annual Compliance Report, December 29, 2022, at 58 (FY 2022 ACR).

26 Docket No. ACR2021, United States Postal Service FY 2021 Annual Compliance Report, December 29, 2021, at 58 (FY 2021 ACR).

27 The FY 2022 Report does cross-reference a CHIR response in Docket No. ACR2020. See FY 2022 Annual Report at 33. However, that response 

only addresses comparability issues with the High-Quality Service and CX Composite Index performance indicators from FY 2017 through 

FY 2020. Docket No. ACR2020, Responses of the United States Postal Service to Questions 1-7 of Chairman’s Information Request No. 2, Januar 

21, 2021, question 4.

28 For example, the FY 2023 Report could express CCC results for FYs 2020 through 2023 using the new (unweighted) methodology. If the 

FY 2023 Report does not provide comparable CCC results, the Postal Service could, in the FY 2023 ACR, identify the comparability issue and 

explain how to compare results from FY 2020 through FY 2023.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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Also, in FY 2023, the Postal Service will change the methodology for calculating the CX 

Composite Index, which is a weighted composite based on results of the CX survey 

performance indicators. FY 2022 Annual Report at 37, 41. The POS survey weight will

increase to 20 percent, and the CCC survey weight will decrease to 15 percent.29 Because 

FY 2023 CX Composite Index results will not be comparable to results from FY 2020 

through FY 2022,30 the Postal Service will also need to address this issue to comply with 

39 U.S.C. § 2804(c) in its FY 2023 Report by following the Commission’s directives below.31

Except for the Excellent Customer Experience performance goal, the FY 2022 Report complies 

with 39 U.S.C. § 2804(c). The FY 2022 Report is non-compliant with respect to this

performance goal because CCC performance indicator results are not comparable from 

FY 2019 through FY 2022, and the Postal Service did not provide the explanations required by 

the Commission.

To comply with 39 U.S.C. § 2804(c) next year, the FY 2023 Report must include comparable 

results for each performance indicator for FYs 2020, 2021, 2022, and 2023. To be comparable, 

results for each fiscal year must be calculated and expressed using the same methodology. If 

comparable results from FY 2020 through FY 2023 are not provided for any performance 

indicator, the FY 2023 Report must:

1. Identify each performance indicator with non-comparable results from 

FY 2020 through FY 2023; and

2. Address the lack of comparability by explaining either of the following:

a. How to compare results from FY 2020 through FY 2023 between the 

current and former methodologies; or

b. Why making this comparison is not feasible.

The FY 2023 Report must include all information necessary to evaluate compliance with the 

requirements of 39 U.S.C. §§ 2803 and 2804, including section 2804(c). Inclusion of this 

information in the FY 2023 Report may be satisfied by either: (1) including the information 

itself in the text of the FY 2023 Report; or (2) including cross-references identifying the 

documents containing this information in the text of the FY 2023 Report.

29 Id. at 41. Performance indicator methodologies for the Excellent Customer Experience performance goal are discussed in Chapter III, Section 

B.3.a., infra.

30 See FY 2021 Analysis at 66-67.

31 For example, the FY 2023 Report could express CX Composite Index results for FYs 2020 through 2023 using the new weights. If the FY 2023 

Report does not provide comparable CX Composite Index results, the Postal Service could, in the FY 2023 ACR, identify the comparability issue 

and explain how to compare results from FY 2020 through FY 2023.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

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Appendix B contains guidance to assist the Postal Service’s efforts to comply with 

section 2804(c) and other statutory requirements for the FY 2023 Report. The 

requirements apply to each performance indicator used in FY 2023.

32

c. Goals Not Met

In FY 2022, the Postal Service met the Financial Health performance goal and partially met 

the High-Quality Service, Excellent Customer Experience, and Safe Workplace and Engaged 

Workforce goals. See Chapter I, Section B.1., supra. If a performance goal has not been met, 

the annual performance report must explain why the Postal Service did not meet the goal 

and describe the plans and schedules for achieving the goal. 39 U.S.C. § 2804(d)(3). The 

FY 2022 Report explains why it partially met the High-Quality Service, Excellent Customer 

Experience, and Safe Workplace and Engaged Workforce performance goals. FY 2022

Annual Report at 34-44. For each public performance indicator that did not meet its 

FY 2022 target, the Postal Service describes plans and schedules for meeting FY 2023 

targets. See id. The Postal Service provides more detailed explanations, plans, and 

schedules in the FY 2022 ACR. FY 2022 ACR at 56-84.

The Commission finds that the FY 2022 Report complies with 39 U.S.C. § 2804(d)(3) because it 

explains why performance goals were partially met and describes plans and schedules for 

meeting the goals in FY 2023. To comply with 39 U.S.C. § 2804(d)(3) next year, for each 

FY 2023 target that is not met, the FY 2023 Report must both explain why and describe plans 

and schedules for meeting the FY 2024 targets.

d. Other Annual Performance Report Requirements

The FY 2022 Report meets other requirements of 39 U.S.C. § 2804. First, the annual 

performance report must review the Postal Service’s success in achieving its performance 

goals by stating whether the Postal Service met targets for each performance indicator in 

FY 2022. 39 U.S.C. § 2804(d)(1). The FY 2022 Report provides this information in tables 

that compare targets and results and state whether the target was met. See FY 2022 Annual 

Report at 34, 38, 42-43, 47. These tables enhance the FY 2022 Report by allowing the reader 

to easily evaluate whether the Postal Service met targets.

Second, the annual performance report must “evaluate the performance plan for the 

current fiscal year relative to the performance achieved towards the performance goals in 

the fiscal year covered by the report[.]” 39 U.S.C. § 2804(d)(2). Section 2804(d)(2) requires 

the FY 2022 Report to evaluate the FY 2023 Plan relative to the performance achieved 

toward the performance goals during FY 2022. This provision requires the FY 2022 Report

32 These include all of the performance indicators listed under the Excellent Customer Experience goal: the CX Composite Index, BSN, POS, 

Delivery, CCC, C360, usps.com, and BMEU.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

- 22 -

to compare FY 2023 targets with FY 2022 results for each performance indicator the Postal 

Service will use during FY 2023. See FY 2016 Analysis at 15. The FY 2022 Report provides 

this information in a master table listing FY 2022 and FY 2023 targets, as well as results 

from FY 2019 through FY 2022. See FY 2022 Annual Report at 33.

Third, the annual performance report must “include the summary findings of those 

program evaluations completed during the fiscal year covered by the report.” 39 U.S.C. 

§ 2804(d)(4). “Program evaluations” are “assessment[s], through objective measurement 

and systematic analysis, of the manner and extent to which Postal Service programs 

achieve intended objectives.” Id. § 2801(6). Section 2804(d)(4) requires the FY 2022 Report

to include summary findings of program evaluations completed during FY 2022 that 

evaluate how programs helped the Postal Service meet targets in FY 2022. See FY 2017 

Analysis at 16. The FY 2022 Report meets this requirement by, for example, explaining that 

the Postal Service tracked District/Division level performance monthly and implemented 

quarterly business reviews focusing on facility level interventions by the field support staff. 

FY 2022 Annual Report at 42.

The Commission finds that the FY 2022 Report complies with 39 U.S.C. §§ 2804(d)(1), (2), 

and (4).

3. Non-Public Performance Indicators

The annual performance plan may include a non-public annex covering program activities 

or parts of program activities relating to the avoidance of interference with criminal 

prosecution or matters otherwise exempt from public disclosure under 39 U.S.C. § 410(c). 

39 U.S.C. § 2803(d). In FY 2022, the Postal Service measured progress toward the 

High-Quality Service performance goal using non-public performance indicator(s) for 

Competitive products. FY 2022 Annual Report at 33. To comply with 39 U.S.C. §§ 2803 and 

2804 in FY 2022, the FY 2021 Analysis directed the Postal Service to file under seal with the 

FY 2022 ACR: “(1) FY 2022 and FY 2023 targets; (2) comparable FY 2022 targets and 

results; and (3) comparable results from FYs 2019 through FY 2022” for each non-public 

performance indicator. FY 2021 Analysis at 22. The Commission further stated that if the

Postal Service does not meet the FY 2022 target(s), the Postal Service must explain why 

and describe the plans and schedules for meeting the FY 2023 target(s). Id. The 

Commission stated that the “FY 2022 ACR should continue to identify the library reference 

that contains this information.” Id.

The FY 2023 Plan and FY 2022 Report state that the Postal Service is providing non-public 

service performance data for certain Competitive products as part of the non-public annex 

of the ACR. FY 2022 Annual Report at 33 n.1. The Postal Service filed information on 

non-public performance indicator(s) in the preface to Library Reference USPS-FY22-NP30 
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

- 23 -

and identified this library reference in the FY 2022 ACR.33 The Postal Service confirms that 

for each non-public performance indicator, the FY 2022 Report contains comparable 

FY 2022 targets and results, as well as comparable results from FY 2019 through FY 2022. 

Response to CHIR No. 23, questions 3.a., 4.a. For each non-public performance indicator 

that did not meet the FY 2022 target, the Postal Service provides an explanation and 

describes plans for meeting the FY 2023 target. Library Reference USPS-FY22-NP30, 

Preface at 20-21. The Postal Service set FY 2023 target(s) for the Competitive products’ 

non-public performance indicator(s) the Postal Service will use in FY 2023. Id. at 20.

The Commission finds that Library Reference USPS-FY22-NP30 complies with the 

Commission’s directives in the FY 2021 Analysis. For the non-public performance indicators, 

the FY 2023 Plan complies with 39 U.S.C. § 2803(a)(2) by setting measurable FY 2023

target(s) for each performance indicator the Postal Service will use in FY 2023. See Section 

B.1., supra. The FY 2022 Report complies with 39 U.S.C. § 2804(b)(1) and 2804(c) because it 

provides comparable FY 2022 targets and results as well as comparable results from the past 

3 fiscal years. See Sections B.2.a., b., supra. The FY 2022 Report also complies with 39 U.S.C. § 

2804(d)(3) because the Postal Service explains why it did not meet FY 2022 target(s) and 

describes plans and schedules for meeting FY 2023 target(s).

To ensure that the FY 2024 Plan and FY 2023 Report comply with 39 U.S.C. §§ 2803 and 2804, 

respectively, the Commission recommends that the Postal Service continue to explain where to 

find information on the non-public service performance indicators, such as in a footnote in the 

master table of targets and results. For the Competitive products’ non-public performance 

indicator(s), the Postal Service must file under seal with the FY 2023 ACR: (1) FY 2023 and 

FY 2024 targets; (2) comparable FY 2023 targets and results; and (3) comparable results 

from FY 2020 through FY 2023. If the Postal Service does not meet the FY 2023 target for any 

non-public performance indicator, the Postal Service must explain why and describe the plans 

and schedules for meeting the FY 2024 target. The FY 2023 ACR should continue to identify 

the library reference that contains this information.

4. Performance Indicator Changes

The Commission previously recommended that the Postal Service describe any 

performance indicator or methodology changes in the Annual Report to Congress and 

analyze the impact of methodology changes on results. See FY 2016 Analysis at 18. The 

Commission also recommended that the Postal Service provide the rationale for making 

these changes. FY 2021 Analysis at 23.

33 Library Reference USPS-FY22-NP30, Preface at 19-21; FY 2022 ACR at 5 n.5.
Analysis of FY 2022 Performance Report Compliance with Legal Requirements

and FY 2023 Performance Plan

- 24 -

In FY 2022, the Postal Service did not make any performance indicator or methodology 

changes.34 Thus, the Postal Service adopted the Commission’s recommendation to limit the 

number of changes to performance indicators and methodologies for calculating targets 

and results. See FY 2021 Analysis at 23. Describing and explaining the rationale for these 

changes provides greater transparency into the Postal Service’s process for changing 

performance indicators and methodologies.

To ensure meaningful comparisons across fiscal years, the Commission recommends that the 

Postal Service continue to limit the number of changes to performance indicators and 

methodologies for calculating targets and results. If the Postal Service plans to add or change 

any performance indicators or methodologies, the Commission recommends that the Annual 

Report to Congress describe these changes, provide the rationale for making them, and 

analyze the impact of these changes on results. To help ensure compliance with 39 U.S.C. § 

2804(c), if the Postal Service changes a performance indicator or the methodology for 

calculating targets or results, the Commission recommends that the Postal Service maintain 

the same performance indicator or methodology for at least 3 consecutive fiscal years unless 

the change is clearly not beneficial or effective.

34 FY 2022 Annual Report at 37-38; Response to CHIR No. 17, question 3.c.; Response to CHIR No. 23, questions 2.a., 4.a.; FY 2022 ACR at 56-57.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

- 25 -

CHAPTER III: EVALUATION OF

PERFORMANCE GOALS

In this chapter, the Commission discusses each performance goal individually. It evaluates 

whether the Postal Service met the performance goals in FY 2022 as required by 39 U.S.C. 

§ 3653(d). The Commission also makes related observations and recommendations for 

each performance goal.

A. High-Quality Service

1. Background

In FY 2022, the Postal Service measured service performance using internal SPM, which 

provides data from the time a mailpiece is first scanned (either at the collection point by 

the carrier or during the first processing operation on mail processing equipment) to the 

time when the carrier scans the mailpiece at the delivery point. See FY 2022 Annual Report

at 34. For most Market Dominant products, the Postal Service sets a service standard for 

the number of days allowed for delivery of a mailpiece considered to be on-time. See FY 

2021 Analysis at 24. Service performance results are expressed as the percentage of mail 

meeting the applicable service standard. See id.

The Postal Service uses the percentage of selected and combined mail products delivered 

on-time to assess whether its performance meets the High-Quality Service performance 

goal.35 To evaluate progress toward the High-Quality Service performance goal in FY 2022, 

the Postal Service used eight performance indicators measuring service performance for 

Market Dominant products:

• Single-Piece First-Class Mail, 2-Day

• Single-Piece First-Class Mail, 3-5-Day

• Presorted First-Class Mail, Overnight

• Presorted First-Class Mail, 2-Day

35 The Postal Service also reports service performance on all Market Dominant products in the ACR. See 39 U.S.C. § 3652(a)(2)(B)(i). Service

performance measurement reporting in the ACR is independent of service performance measurement reporting in annual performance plans 

and annual performance reports under 39 U.S.C. §§ 2803 and 2804. The reporting of these service performance measurements in the FY 2022 

Annual Report does not meet the same class- or group-specific granular reporting criteria as the service performance measurements required 

in the Commission’s rules for purposes of the ACR. See 39 C.F.R. §§ 3055.20 through 3055.24. For instance, the Single-Piece First-Class Mail 

and the Presorted First-Class Mail performance indicators in the FY 2022 Annual Report combine service performance results for different 

products. By contrast, the ACR requires the Postal Service to disaggregate service performance results by mail subject to the Overnight, 2-Day, 

or 3-Day, 4-Day, and-5-Day service standards (as well as in the aggregate for the 3-to-5-day service standards and in the aggregate for all 

service standards combined) by First-Class Mail product. See, e.g., 39 C.F.R. § 3055.20(a).
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

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• Presorted First-Class Mail, 3-5-Day

• First-Class Mail Letter and Flat (FCLF) Composite

• USPS Marketing Mail and Periodicals Composite

• Market Dominant Composite

The Single-Piece First-Class Mail performance indicators measure the performance of 

Single-Piece First-Class Mail letters, postcards, and flats throughout the fiscal year. 

FY 2022 Annual Report at 34. Results are expressed as the estimated percentage of 

Single-Piece First-Class Mail by service standard (2-Day and 3-5-Day) delivered on-time. 

Id.

The Presorted First-Class Mail performance indicators measure the performance of 

commercial Presorted First-Class Mail letters, postcards, and flats delivered throughout 

the fiscal year. Id. Results are expressed as the estimated percentage of total Presorted 

First-Class Mail delivered on-time by service standard (Overnight, 2-Day, and 3-5-Day). Id.

The FCLF Composite performance indicator measures the weighted average of the 

performance of Single-Piece First-Class Mail and Presorted First-Class Mail across all 

service standards, weighted by volume. Id.

The USPS Marketing Mail and Periodicals Composite performance indicator measures the 

percentage of all USPS Marketing Mail and Periodicals mailpieces that were delivered 

within the applicable service standard during the fiscal year. Id. This performance 

indicator is a composite measuring USPS Marketing Mail letters and flats, as well as 

Periodicals. Id. Approximately two-thirds of the volume in this composite indicator 

consists of USPS Marketing Mail letters; the remainder is made up of USPS Marketing Mail 

flats and Periodicals. Id.

The Market Dominant Composite is a composite indicator measuring the percentage of 

First-Class Mail, USPS Marketing Mail, Periodicals, and Bound Printed Matter letters and 

flats, as well as Media Mail, Library Mail, and Bound Printed Matter parcels, that were 

delivered within their applicable service standards during the fiscal year. Id.

The Postal Service also provided non-public performance data for certain Competitive 

products. See id. at 33 n.1.

In FY 2022, the Postal Service failed to meet one of its targets for the Market Dominant 

performance indicators—Single-Piece First-Class Mail, 3-5-Day. Id. at 35.

The Postal Service explains that “[t]he primary variables that account for this product 

missing the established service standard can be attributed to ongoing network 

transportation changes and additional processing requirements for this product which 
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

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prohibit its ability to mitigate potential failures or disruptions.” Id. However, the Postal 

Service also notes that its performance for Single-Piece First Class Mail, 3-5-Day, “is a five 

year high and more than a full point higher than at any of the prior four years.” Id.

The Postal Service highlights its performance with respect to delivering COVID-19 test 

kits. See id. According to the Postal Service, it “packag[ed] and deliver[ed] more than 167 

million orders containing more than 668 million COVID-19 test kits to American 

households . . . with an average days to deliver of just 1.2 days.” Id.

The Commission commends the Postal Service for its efforts to deliver COVID-19 test kits. 

These efforts demonstrate the Postal Service’s vital role in the COVID-19 pandemic response.

To improve High-Quality Service in FY 2023, the Postal Service reports that it plans to 

continue implementing its 10-Year Strategic Plan.36 To that end, the Postal Service intends 

to transform its processing facilities and transportation networks; prepare for the peak 

season; invest in new vehicles, equipment, systems, and facilities; and stabilize and 

empower its workforce. FY 2022 Annual Report at 35.

The Postal Service reports that at the beginning of FY 2022, it implemented service 

standard changes for First-Class Mail and Periodicals, which, the Postal Service asserts, 

“will increase delivery reliability, consistency, and efficiency for customers.” Id. These 

changes increased service standards by up to two additional days for First-Class Mail and 

Periodicals mailpieces travelling longer distances.37 Prior to implementation, the Postal 

Service estimated that approximately 38.5 percent of First-Class Mail volume and 

approximately 7 percent of Periodicals volume would be affected by the changes. See

Docket No. N2021-1 Advisory Opinion at 1-2. The Postal Service is increasing interim 

targets for all High-Quality Service performance indicators in FY 2022. FY 2022 Annual 

Report at 35. The Postal Service’s plans are discussed in detail in Section A.3.c., infra.

2. Comments

The Public Representative “commends the Postal Service for meeting all but one of [its 

FY 2022 service performance] targets.” PR Comments at 5. Further, he states that the 

Postal Service’s performance for Single-Piece First-Class Mail, 3-5-Day, although below the 

target, “is still a considerable improvement over the prior year and still slightly better than 

in FY 2019, prior to the onset of the COVID-19 pandemic.” Id. However, he views the Postal 

Service’s description of its failure to meet the target for Single-Piece First-Class Mail, 3-5-

Day, as insufficient and recommends that the Commission seek additional information 

36 Id.; see 10-Year Strategic Plan. The Commission has opened a public inquiry in connection with the 10-Year Strategic Plan. See Docket No. 

PI2023-4, Notice and Order Initiating Public Inquiry Associated with the Delivering for America Plan, April 20, 2023 (Order No. 6488).

37 See Docket No. N2021-1, Advisory Opinion on Service Changes Associated with First-Class Mail and Periodicals, July 20, 2021, at 1-2 (Docket 

No. N2021-1 Advisory Opinion).
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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about “additional processing requirements and why they inhibit the Postal Service’s 

ability to mitigate potential failures or disruptions.” Id. at 6.

In addition, the Public Representative comments that there are “pockets of areas where 

mail delivery seems problematic.” Id. In this regard, he encourages the Postal Service to 

take steps identified by the Postal Service OIG “to identify and reduce the number of 

undelivered and partially delivered routes.”38 He also highlights the importance of 

initiatives to improve transportation operations. See id. at 10-11.

The National Association of Presort Mailers (NAPM) comments that upstream mail 

preparation, such as the commingling process, produces service performance benefits. 

NAPM Comments at 3-5. NAPM states that “the Postal Service should better utilize its 

pricing flexibility to give customers the incentive to move more mail into programs like 

commingle[.]” Id. at 5. Further, NAPM “encourages the Postal Service and the Commission 

to continue to explore ways to identify service performance issues and make 

improvements.” Id. at 5-6. NAPM also “urge[s] the Postal Service to implement a reporting 

solution that allows commingle mailers and others to obtain visibility at a level that helps 

them identify the specific mail being excluded” from service performance measurement. 

Id. at 6.

Further, NAPM comments specifically on FY 2022 flats performance. See id. at 6-8. NAPM 

requests that the Postal service “report service performance on a quarterly and annual 

basis” separately for Presorted First-Class Mail Flats and for Single-Piece First-Class Mail 

Flats. Id. at 6. Further, “NAPM is concerned that few of the specific initiatives laid out by 

the Postal Service in its FY2022 Performance Report or FY2023 Plan are designed to 

address First-Class Mail flats performance.” Id. at 7. NAPM is also “concerned that the 

USPS’ FY2023 performance targets for First-Class Mail may not be realistic or achievable, 

since they have been increased compared to FY2022, even though FY2022 performance 

was well below the lower targets.” Id. at 7-8. NAPM also notes that it “would like to see 

more detail and attention given to the Postal Service’s plans to improve service 

performance for [USPS] Marketing Mail flats.” Id. at 8.

In its reply comments, the Postal Service responds to the Public Representative by 

providing additional information about Single-Piece First-Class Mail, 3-5-Day, and 

asserting that pursuing the initiatives in the 10-Year Strategic Plan “will ensure continued 

service performance improvement[.]” Postal Service Reply Comments at 2-3.

In reply to NAPM, the Postal Service states that it reports quarterly and annual service 

performance information for Presorted First-Class Mail Flats and for Single-Piece FirstClass Mail Flats. Postal Service Reply Comments at 3. The Postal Service states that the 

38 Id. (citing United States Postal Service, Office of the Inspector General, Report No. 21-262-R23, Delivery Operations-Undelivered and 

Partially Delivered Routes, December 16, 2022, available at https://www.uspsoig.gov/reports/audit-reports/delivery-operations-undeliveredand-partially-delivered-routes (OIG Report No. 21-262-R23).
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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issue of using pricing flexibility to encourage the comingle process was addressed in 

connection with the FY 2022 ACR. See id. Further, the Postal Service asserts that its FY 

2023 performance targets remain “appropriate.” Id. at 4.

3. Commission Analysis

In FY 2022, the Postal Service achieved its targets for the performance indicators related 

to Market Dominant products that measure progress toward the High-Quality Service 

performance goal, apart from Single-Piece First-Class Mail 3-to-5-Day, which missed its 

target of 90.00 percent by 6.38 percentage points. FY 2022 Annual Report at 34.

The Commission finds that the High-Quality Service performance goal was partially met in 

FY 2022, with the Postal Service failing to meet one performance indicator related to Market 

Dominant products.

Below, the Commission provides observations and recommendations related to the Postal 

Service’s explanations for its ability to partially meet the High-Quality Service 

performance goal in FY 2022. The Commission also provides discussion and 

recommendations concerning the Postal Service’s plans to meet the High-Quality Service 

performance goal in FY 2023.

a. Observations on Results and Targets

The Commission notes that reports prepared pursuant to 39 U.S.C. § 2804 must “include 

actual results for the three preceding fiscal years[,]” and the Commission has previously 

found that such actual results must be comparable across all three preceding fiscal years. 

39 U.S.C. § 2804(c); see, e.g., FY 2021 Analysis at 17. A lack of comparability with respect to 

performance indicator results makes them less valuable to both the Postal Service and the 

Commission for reviewing progress in addressing service performance issues.

Although the datasets and calculations that inform performance indicator results for HighQuality Service remained constant (see Response to CHIR No. 17, question 3.c.), the Postal 

Service implemented new, lengthened service standards for First-Class Mail and 

Periodicals. FY 2022 Annual Report at 35; FY 2022 ACD at 103. These service standards 

were effective October 1, 2021, at the beginning of FY 2022. FY 2022 Annual Report at 35; 

FY 2022 ACD at 103. The implementation of the service standard changes for First-Class 

Mail and Periodicals at the beginning of FY 2022 affected the meaningfulness of comparing 

High-Quality Service performance indicator results for FY 2022 to prior fiscal years’ 

results. According to the Postal Service, the service standard changes “undoubtedly 

contributed to improved service performance for Market Dominant products” in FY 2022. 

Response to CHIR No. 17, question 3.c.

Thus, when comparing historical results and targets to the Postal Service’s FY 2022 results 

and FY 2022 (and FY 2023) targets, it is important to acknowledge the effect of the service 

standard changes to draw more meaningful comparisons. That said, the Postal Service 
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

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states that it is not feasible to provide estimates of the results that the FY 2022 HighQuality Service indicators would have yielded in the absence of the new service standards 

and that it cannot isolate the effect of the service standard changes from the effect of other 

factors, such as network changes. Id. Nevertheless, despite the service standard changes, 

the FY 2022 results and targets (as well as the FY 2023 targets) are comparable to prior 

years’ results and targets in that they represent the same concepts: the percentage of 

types of mail that met their respective service standards and the Postal Service’s target 

percentages. Id.; see Response to CHIR No. 23, questions 1, 3-4. Because the changes in 

service standards for First-Class Mail and Periodicals complicate the comparability of 

year-over-year on-time service performance results for these classes, and the Postal 

Service confirmed that it cannot calculate the precise impact of the change in service 

standards, the Commission recommends that the Postal Service endeavor to develop a 

method to measure accurately how service performance has changed for these mailpieces 

over time.39

39 See FY 2022 ACD at 134-35, 162; Responses of the United States Postal Service to Questions 1-3 of Chairman’s Information Request No. 7, 

February 3, 2023, question 30.a.; Responses of the United States Postal Service to Questions 1-19 of Chairman’s Information Request No. 11, 

February 15, 2023, question 11.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

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Table III-1

Market Dominant High-Quality Service Performance Indicators

Comparison of Targets (%)

High-Quality Service

Performance Indicators

Targets

FY 2023 FY 2022 FY 2021 FY 2014-

FY 2020

Single-Piece First-Class Mail

2-Day 93.00 90.25 87.81 96.50

3-5-Day 90.28 90.00 68.64 95.25

Presorted First-Class Mail

Overnight 95.00 94.75 93.99 96.80

2-Day 95.00 93.00 89.20 96.50

3-5-Day 92.20 90.50 84.11 95.25

First-Class Mail Letter and Flat Compositea 92.50 91.00 84.88 96.00

USPS Marketing Mail and Periodicals Compositea 93.37 91.50 86.62 91.80b

Market Dominant Composite 93.00 91.25 85.86 N/Ac

a The Postal Service did not begin using First-Class Mail Letter and Flat Composite and USPS Marketing Mail and Periodicals Composite until FY 

2017. Docket No. ACR2017, Library Reference USPS-FY17-17, ecem er 29, 2 17, file “ SPS-FY17.17.Annual Report.pdf,” at 1 FY 2017 

Annual Report).

b The FY 2017 USPS Marketing Mail and Periodicals Composite target was 91.00. Id. at 14.

c The Postal Service did not begin using the Market Dominant Composite as a performance indicator until FY 2021. Docket No. ACR2020, 

Library Reference USPS-FY20-17, December 29, 2020, file “FY 2020 Annual Report.USPS.FY20.REV.5.14.2021.pdf,” at 34 (FY 2020 Annual 

Report).

Source: FY 2022 Annual Report at 33; FY 2021 Annual Report at 33; FY 2020 Annual Report at 33; Docket No. ACR2019, Library Reference 

USPS-FY19-17, ecem er 27, 2 19, file “FY19.Annual.Report. SPS.FY19.17.pdf,” at 2 FY 2019 Annual Report); Docket No. ACR2018, Library 

Reference USPS-FY18-17, December 28, 2018, file “USPS.FY18.17_Annual Report to Congress.pdf,” at 17 (FY 2018 Annual Report); FY 2017 

Annual Report at 14; Docket No. ACR2016, Library Reference USPS-FY16-17, file “FY1 .17 2 1 Annual Report.pdf,” ecem er 29, 2 1 , at 1 

(FY 2016 Annual Report).
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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Table III-2

Market Dominant High-Quality Service Performance Indicators

Comparison of FY 2022 Targets and FY 2021-FY 2022 Results (%)

High-Quality Service 

Performance Indicators

FY 2022 FY 2021

Target Result Percentage Point 

Performance Gap

Delta 

FY 2021a Result

Single-Piece

First-Class Mail

2-Day 90.25 91.34 +1.09 +4.9 86.44

3-5-Day 90.00 83.62 -6.38 +20.42 63.20

Presorted

First-Class Mail

Overnight 94.75 94.92 +0.17 +1.54 93.38

2-Day 93.00 93.36 +0.36 +5.07 88.29

3-5-Day 90.50 91.49 +0.99 +10.62 80.87

First-Class Mail Letter 

and Flat Composite 91.00 91.00 0.00 +8.31 82.69

USPS Marketing Mail 

and Periodicals Composite 91.50 92.86 +1.36 +5.74 87.12

Market Dominant Compositeb 91.25 92.14 +0.89 +6.84 85.30

Note: Red text below target. Green text indicates met or above target. 

a This column calculates the absolute point differences between FY 2022 and FY 2021 results.

b The Postal Service did not begin using the Market Dominant Composite as a performance indicator until FY 2021. The Postal Service provided 

FY 2021 and FY 2020 results for comparison purposes only. FY 2022 Annual Report at 33 n.4.

Source: FY 2022 Annual Report at 33-34.

As Table III-2 shows, all but one of the FY 2022 performance indicator targets related to 

Market Dominant products were met. Like in FY 2021 and FY 2020, the shorter service 

standard categories exhibited better performance than the longer service standard 

categories. Within First-Class Mail, the Presorted categories outperformed their SinglePiece analogs. Despite missing the target for the Single-Piece First-Class Mail 3-to-5-Day 

performance indicator by 6.38 percentage points, the result improved by 20.42 

percentage points from FY 2021. All performance indicators show gains in FY 2022 

relative to FY 2021. See Table III-2, ‘Delta FY 2021’ column. The Postal Service attributes 

these service improvements to actions taken to implement its 10-Year Strategic Plan in 

FY 2022. See FY 2022 Annual Report at 35. In connection with implementing its 10-Year 

Strategic Plan, the Postal Service reviewed processing locations, implemented site-specific 

operating plans, proactively planned for the FY 2022 peak season, expanded its facility 

footprint, and increased processing capacity to achieve service improvement. See id.

For FY 2021, targets for High-Quality Service performance indicators were lowered 

considerably because of the COVID-19 pandemic with the expectation they would be 

adjusted upwards for FY 2022. See Table III-1; FY 2021 Analysis at 35. For both FY 2022 

and FY 2023, targets were increased for each performance indicator as the Postal Service 

recovered from the COVID-19 pandemic and factored in the effects of the lengthened 

service standard and other elements of its 10-Year Strategic Plan. Thus, the targets have 
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

- 33 -

moved incrementally closer to the 95 percent on-time level, which is the Postal Service’s 

stated long-term goal in its 10-Year Strategic Plan.40

In recent years, the Commission has looked to quarterly service performance and/or 

performance indicator results to attempt to trace the effect of the COVID-19 pandemic and 

other factors on the Postal Service’s operations.41 Historically, results during the second 

half of a given fiscal year (Quarters 3 and 4) tended to outperform results from the first 

half of the fiscal year (Quarters 1 and 2), largely owing to seasonal trends. See, e.g., 

FY 2019 ACD at 105. However, beginning in FY 2020 that historical pattern was disrupted. 

Tables III-3 through III-6 show results for each High-Quality Service performance 

indicator related to Market Dominant Products disaggregated by quarter for FY 2019, 

FY 2020, FY 2021, and FY 2022.

Table III-3

Market Dominant High-Quality Service Performance Indicators FY 2019 by Quarter (%)

High-Quality Service

Performance Indicators

FY 2019 

Target

FY 2019 Results

Q1 Q2 Q3 Q4

Single-Piece First-Class Mail

2-Day 96.50 89.53 91.55 93.90 93.97

3-5-Day 95.25 72.11 79.67 86.55 87.78

Presorted First-Class Mail

Overnight 96.80 94.68 94.80 96.30 96.20

2-Day 96.50 92.79 93.30 95.25 95.27

3-5-Day 95.25 89.90 90.43 93.61 94.10

First-Class Mail Letter and Flat Composite 96.00 88.47 90.33 93.38 93.76

USPS Marketing Mail and Periodicals Composite 91.80 84.57 88.21 90.93 91.79

Market Dominant Compositea N/A

a

The Postal Service did not begin using the Market Dominant Composite as a performance indicator until FY 2021. No targets or quarterly 

results exist for this performance indicator for FY 2019.

Source: FY 2019 Annual Report at 20, 21; Docket No. ACR2020, Responses of the United States Postal Service to Questions 1-17 of Chairman’s 

Information Request No. 24, March 18, 2021, question 5.

40 See FY 2022 Annual Report at 35; 10-Year Strategic Plan at 27; Table III-1; Response to CHIR No. 25, question 7.

41 See, e.g., FY 2021 Analysis at 37-40; FY 2020 Analysis at 36-37; see also FY 2022 ACD at 136; Docket No. ACR2021, Annual Compliance 

Determination Report, Fiscal Year 2021, March 29, 2022, at 145 (FY 2021 ACD); Docket No. ACR2020, Annual Compliance Determination 

Report, Fiscal Year 2020, March 29, 2021, at 164-65 (FY 2020 ACD).
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

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Table III-4

Market Dominant High-Quality Service Performance Indicators FY 2020 by Quarter (%)

High-Quality Service

Performance Indicators

FY 2020 

Target

FY 2020 Results

Q1 Q2 Q3 Q4

Single-Piece First-Class Mail

2-Day 96.50 91.88 93. 00 92.38 88.24

3-5-Day 95.25 78.18 83.31 81.37 72.06

Presorted First-Class Mail

Overnight 96.80 94.41 95.87 95.70 92.75

2-Day 96.50 93.50 94.41 93.25 89.64

3-5-Day 95.25 91.25 92.55 90.67 84.63

First-Class Mail Letter and Flat Composite 96.00 90.37 92.18 90.82 85.58

USPS Marketing Mail and 

Periodicals Composite 91.80 88.90 91.18 88.70 85.34

Market Dominant Compositea N/A 89.50 91.66 89.73 85.43

a The Postal Service did not begin using the Market Dominant Composite as a performance indicator until FY 2021. The Postal Service provided 

FY 2020 quarterly results for comparison purposes only. FY 2020 Annual Report at 33 n.5 (Docket No. ACR2020, Response to CHIR No. 22).

Source: FY 2020 Annual Report at 33, 35; Docket No. ACR2020, Responses of the United States Postal Service to Questions 1-24 of Chairman’s 

Information Request No. 22, March 9, 2021, questions 23.

Table III-5

Market Dominant High-Quality Service Performance Indicators FY 2021 by Quarter (%)

High-Quality Service

Performance Indicators

FY 2021 

Target

FY 2021 Results

Q1 Q2 Q3 Q4

Single-Piece First-Class Mail

2-Day 87.81 81.60 85.90 90.80 90.90

3-5-Day 68.64 54.60 57.90 73.80 75.10

Presorted First-Class Mail

Overnight 93.99 91.30 92.70 95.20 94.60

2-Day 89.20 84.70 84.80 92.20 92.30

3-5-Day 84.11 78.00 73.80 85.90 87.00

First-Class Mail Letter and Flat Composite 84.88 78.40 78.10 87.60 88.50

USPS Marketing Mail and 

Periodicals Composite 86.62 83.90 84.50 90.50 91.90

Market Dominant Composite 85.86 81.70 81.60 89.30 90.70

Source: FY 2021 Annual Report at 33, 34; Docket No. ACR2021, Responses of the United States Postal Service to Questions 1-19 of Chairman’s

Information Request No. 8., February 4, 2022, question 3.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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Table III-6

Market Dominant High-Quality Service Performance Indicators FY 2022 by Quarter (%)

High-Quality Service

Performance Indicators

FY 2022 

Target

FY 2022 Results

Q1 Q2 Q3 Q4

Single-Piece First-Class Mail

2-Day 90.25 90.30 90.04 92.46 92.19

3-5-Day 90.00 78.58 77.62 87.64 88.57

Presorted First-Class Mail

Overnight 94.75 94.76 94.10 95.43 95.30

2-Day 93.00 92.12 92.14 94.58 94.35

3-5-Day 90.50 89.98 87.51 94.10 93.86

First-Class Mail Letter and Flat Composite 91.00 89.09 87.88 93.29 93.11

USPS Marketing Mail and 

Periodicals Composite 91.50 91.82 91.55 94.20 94.46

Market Dominant Composite 91.25 90.75 90.15 93.90 93.90

Source: FY 2022 Annual Report at 33, 34; Response to CHIR No. 20, question 1.

In FY 2020, contrary to the normal pattern of seasonal variation, performance indicator 

scores began declining in Quarters 3 and 4, before ultimately reaching a nadir in Quarter 1 

of FY 2021. As the Commission has found previously, the timing of the service 

performance declines in late FY 2020 generally corresponds with the onset of the COVID19 pandemic.42 Beginning in FY 2021 Quarter 2, performance indicator results began to 

improve, and that pattern continued through the end of FY 2021 and through FY 2022. 

Table III-6 shows that service performance results reflect the normal pattern of seasonal 

variation as the second half of the fiscal year outperformed the first. See FY 2022 ACD 

at 136-37.

In the FY 2021 Analysis, the Commission recommended that the Postal Service develop 

more granular composite indicators for service performance based on significant class, 

shape, and product-level differences between mailpieces. See FY 2021 Analysis at 41. The 

Commission also recommended the Postal Service include the input and calculation of the 

High-Quality Service performance indicator results, to the extent that they are not 

included elsewhere in the ACR filing. Id. The Commission noted that the USPS Marketing 

Mail and Periodicals and Market Dominant Composites include items with various service 

standards. See id.

In response to a CHIR, the Postal Service stated that it did not develop more granular 

composites as it already reports service performance on components of its composites at a 

more granular level in its ACR filings. Response to CHIR No. 17, question 1.a., b. It states 

that the composites are provided in addition to, not instead of, more granular indicators. 

42 See FY 2021 ACD at 160; FY 2020 ACD at 165; FY 2020 Analysis at 37. However, the Postal Service acknowledged that COVID-19-related 

operational disruptions were not the sole cause of service declines over this period, which were also attributable, at least in part, to Postal 

Service operational initiatives. See FY 2020 Analysis at 37; FY 2020 ACD at 99-150.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

and FY 2023 Performance Plan

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See id. The Postal Service notes that the inputs for the composites were submitted in 

Docket No. ACR2022, Library Reference USPS-FY22-29. See id. question 2. After further 

Commission request, the Postal Service provided more detail relating to the calculation of 

the composites, including the total measured volume and on-time volume underlying the 

composite calculations. Response to CHIR No. 20, question 3.

The Commission continues to have concerns about the use of highly aggregated 

composites as performance indicators that incorporate disparate mail classes, shapes, and 

products. Such composites are subject to being affected by changes in weights arising from 

changes in the mail mix. As a result, such composites, without notes about how they are 

affected by the mail mix, do not provide a full account of the extent to which High-Quality 

Service is being achieved, which is the relevant inquiry with respect to the High-Quality 

Service performance goal.43

The Commission continues to recommend that the Postal Service develop more granular 

composite indicators for service performance based on significant class, shape, and productlevel differences between mailpieces. If the Postal Service continues using highly aggregated 

composites as performance indicators, then the Commission recommends that the Postal 

Service also develop more granular performance indicators, such as it currently uses for 

First-Class Mail, to supplement the highly aggregated composites. Finally, the Commission

expects the Postal Service to include with each Annual Report supporting workpapers 

containing the inputs for, and a detailed calculation of, the High-Quality Service performance 

indicator results, to the extent that they are not included elsewhere in the ACR filing.

The Commission recommended that the “Postal Service develop methods to quantitatively 

measure the effectiveness of its service improvement initiatives so as not to spend 

resources needlessly or ineffectively.” FY 2021 Analysis at 52. In response, the Postal 

Service developed the key performance indicator OPP to “measure the effectiveness of 

efforts to improve adherence to site-specific clearance times.” Response to CHIR No. 17, 

question 8.b.i. The Postal Service asserts that gains in OPP correlated with higher service 

performance for First-Class Mail in FY 2022. The Postal Service further asserts that 

increased OPP also led to greater achievement of site-specific clearance goals, and notes 

specifically that OPP increased from 79.64 percent at the beginning of FY 2022 to 94.97 

percent at the end of FY 2022. Id. question 8.b.ii. The Commission will continue to monitor 

the relationship between OPP and service performance. The Commission also encourages 

the Postal Service to track the correlation between OPP and other mail types.

43 The USPS ar eting ail and Periodicals Composite illustrates the Commission’s concern of highl aggregated indicators. The USPS 

Marketing Mail and Periodicals Composite FY 2022 target was 91.50 percent on-time service performance, and it met its performance 

indicator target achieving an actual result of 92.86 percent on-time service performance. FY 2022 Annual Report at 34. Despite the referenced 

composite meetings its target, both Periodicals products had on-time service performance results substantially below this target. In-County 

Periodicals and Outside County Periodicals respectively had 83.6 and 83.3 percent on-time service performance. FY 2022 ACD at 160. This is 

possible because Periodicals constitute a smaller portion of the composite volume; approximately two-thirds of the volume in this composite 

indicator consists of USPS Marketing Mail letters, while the remainder is made up of USPS Marketing Mail flats and Periodicals. FY 2022 

Annual Report at 34.
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In the FY 2023 Report, the Postal Service should address whether any service standard 

changes implemented in FY 202344 affected the comparability of performance indicator 

results. If comparability has been affected, the Postal Service should propose a way for the 

Commission to compare FY 2023 High-Quality Service performance indicator results to 

results from prior fiscal years. If the Postal Service asserts that comparability is unaffected, 

the Postal Service should fully explain the rationale and supporting basis for this assertion. 

The Postal Service should also consider methodologies to study the effect of service standard 

changes on OPP at affected facilities.

b. Explanations for Missing Target in FY 2022 and Planned 

Mitigations

The Postal Service missed its target for Single-Piece First-Class Mail 3-to-5-Day by 6.38 

percentage points, achieving on-time performance of 83.62 percent with a 90.00 percent 

target in FY 2022. FY 2022 Annual Report at 34. The Postal Service discusses two reasons 

for the failure to meet its High-Quality Service target for Single-Piece First-Class Mail 3-to5-Day. The Postal Service reports that ongoing network transportation changes and 

additional processing requirements for this product prohibit its ability to mitigate 

potential failures or disruptions.45 Despite missing its target, the Postal Service raised its 

target for this mail category from 90.00 percent in FY 2022 to 90.28 percent in FY 2023. 

FY 2022 Annual Report at 33. The Postal Service also discusses its plan for achieving this 

performance goal. The Commission evaluates the Postal Service’s reasons for missing this

target in FY 2022 and discusses the status of factors that impeded performance in 

previous years.

(1) Ongoing Network Transportation Changes

Since FY 2021, the Postal Service shifted approximately 93 percent of First-Class Mail air 

volume to surface transportation as a result of its ongoing network transportation 

strategy. See Response to CHIR No. 23, question 7.a. This change led to the development of 

new surface routings and added transportation and connections through transfer hubs. Id.

question 7.b. A more complex surface network made it more difficult for the Postal Service 

to minimize failures and disruptions and impeded the Postal Service from meeting its 

FY 2022 target for Single-Piece First-Class Mail 3-to-5-Day. Id. question 7.e.

For FY 2023, the Postal Service expects that, as it continues to shift from air volume to 

surface transportation, service performance will improve as it avoids unpredictable delays 

associated with air transportation. Id. question 9.b. The Postal Service also plans to review 

44 For example, the change in critical entry times (CET) for certain categories of Periodicals, effective January 29, 2023. See United States 

Postal Service, Changes to Periodical Critical Entry Times, Effective January 29, 2023, USPS Postal Pro (Dec. 29, 2022), available at 

https://postalpro.usps.com/node/11634; see also Docket No. N2022-2, Advisory Opinion on Changes to the Critical Entry Times for Certain 

Categories of Periodicals, November 30, 2022 (Docket No. N2022-2, Advisory Opinion).

45 See id. at 35; Postal Service Reply Comments at 2-3; Response to CHIR No. 23, question 7.
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and improve routings and increase operational precision to improve service performance 

in this category and others. See id. question 7.f.; Response to CHIR No. 17, question 6.b.

The Commission notes that there may be limited remaining potential to improve service 

performance for Single-Piece First-Class Mail 3-to-5-Day by shifting air volume to surface 

transportation because 93 percent of First-Class Mail air volume has already been moved

to surface transportation. See Response to CHIR No. 23, question 7.a. However, the 

Commission recognizes that, as other mail categories shift to surface transportation, the 

Postal Service may be able to initiate more direct and streamlined transportation. See id.

question 7.f.

The Commission encourages the Postal Service to continue reviewing routings and 

streamlining its network to reduce complexity, improve reliability, and improve service 

performance for the Single-Piece First-Class Mail 3-5-Day performance indicator.

(2) Additional Processing Requirements for First-Class 

Mail 3-to-5-Day

Single-piece volume requires collection, cancellation, and outgoing letter sortation before 

it can join presorted volumes in tray sortation and dispatch operations. Id. question 7.c. 

The additional handling required to process single-piece volumes creates more 

opportunities for failures in operations. Id. question 7.d.

For FY 2023, the Postal Service plans to continue focusing on increasing OPP and 

streamline and improve the Postal Service network to improve service performance for 

First-Class Mail 3-to-5-Day, as well as other categories. Id. question 7.f. The Commission 

encourages the Postal Service to continue measuring and managing OPP to achieve 

increased service performance.

At the same time, the Commission recommends that the Postal Service consider the 

additional processing requirements for single-piece volumes when devising targets in the 

future. As these requirements and associated challenges can be anticipated based on 

experience, they should be accounted for in developing applicable targets.

If the Postal Service experiences higher-than-expected failure in certain processes relating to 

the processing of single-piece volumes and does not achieve any of its single-piece

performance targets in FY 2023, it should explain the reasons why failures in processing 

single-piece volumes exceed expectations and identify the operational processes experiencing 

the failures.

(3) Other Factors Affecting Service Performance

During FY 2020 and FY 2021, various factors had negative effects on service performance. 

See FY 2021 ACD at 108-28. Although effects of some of these factors (such as those 

related to the COVID-19 pandemic) abated in FY 2022, these factors continued to affect the 

Postal Service’s Market Dominant service performance results. See FY 2022 ACD at 106.
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Moreover, the combination of these factors exacerbated the extent and duration of their 

individual effects. Id. Although these factors may not have led to failures to meet targets, 

they negatively affected service performance and are discussed below.

(a) Peak Season Performance

As a result of FY 2020 and FY 2021 peak season challenges, the Postal Service began to 

implement a variety of operational changes.46 For instance, the Postal Service reports 

initiating “extensive efforts to plan for the FY 2022 peak season” and to handle increased 

package volume through “facility space upgrades and procurement of new processing 

equipment[.]” FY 2022 ACR at 49, 50. It also hired over 40,000 seasonal, delivery, and 

plant personnel. FY 2022 Annual Report at 35. These initiatives are further discussed in the 

FY 2022 ACD. See FY 2022 ACD at 116-17. The Postal Service also managed inventory 

delays during the peak season of FY 2022 much better than in the peak season of FY 2021, 

with the number of inventory delays 56 percent lower in December 2021 compared with 

December 2020. Id. at 116.

In addition to recommending continued efforts to align labor more efficiently with 

expected volume in Quarter 1, the Commission recommended that the Postal Service’s 

peak planning operations consider whether additional flexibility is needed to align labor 

with expected volume beyond Quarter 1 to meet the applicable service standards. FY 2021 

Analysis at 43. With respect to this recommendation, the Postal Service hired seasonal 

employees to accommodate predicted upsurges in volume in the FY 2022 and FY 2023 

peak season and reduced those workhours as volumes declined. See Response to CHIR No. 

25, question 4.a., b.

The Commission commends the Postal Service’s FY 2022 and FY 2023 initiatives to make 

proactive plans to provide High-Quality Service during peak seasons, and it recommends that 

the Postal Service continue monitoring and optimizing peak season performance.

(b) Employee Availability

The Postal Service stated that high levels of employee absenteeism owing to the COVID-19 

pandemic negatively affected its ability to staff its operations appropriately during 

FY 2021. See FY 2021 Annual Report at 35. It undertook a variety of measures to improve 

employee availability. See FY 2021 Analysis at 44-45. The Commission found that these 

measures appeared reasonable, and it recommended that the Postal Service leverage data 

from the past 2 years to identify any patterns that might enable the Postal Service to 

better anticipate when and where future employee availability problems are likely to have 

the greatest effect on service performance. Id.at 45.

46 In FY 2020 and FY 2021, as a result of the COVID-19 pandemic, unprecedented package volume contributed to decreased Market Dominant 

service performance during the Postal Service’s peak season and subsequent months. See FY 2021 ACD at 117. Additionally, for FY 2021, the 

traditional Quarter 1 peak season volume continued into Quarter 2. FY 2021 Analysis at 43; cf. FY 2021 ACD at 117-19.
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The Postal Service considered a study of employee availability to be impractical because it 

would reflect anomalous fluctuations in employee availability caused by the effects of the 

COVID-19 pandemic that may have no bearing on future employee availability, would be 

unable to disentangle the causal effects of employee availability on service performance in 

the Postal Service’s complex system, and would be less relevant given that employee 

availability has stabilized in FY 2023.

47

In the FY 2022 ACD, the Commission observes that, despite the Postal Service’s statements 

that the effects of the COVID-19 pandemic on employee availability have lessened, 

“staffing challenges—particularly an inability to hire part-time workers—have persisted 

due to the national labor shortage.” FY 2022 ACD at 106. Overall employee availability 

decreased in FY 2022 compared to both FY 2020 and FY 2021. Id. at 107.

Because employee availability may continue to pose issues for the Postal Service, the 

Commission recommends that the Postal Service continue to monitor fluctuations in 

employee availability and its impact on service performance.

(c) Supplier Performance and Capacity

Figure III-1

First-Class Mail Number of Critically Late Trips, By District, FY 2022

Source: Library Reference USPS-FY22-29, cel file “C T FY22 11.3 .2 22. ls .”

47 See Response to CHIR No. 17, question 4.c.; Response to CHIR No. 23, question 10.a.; Responses of the United States Postal Service to 

Questions 1-9 of Chairman’s Information Request No. , January 17, 2023, question 4 (Response to CHIR No. 6); Response to CHIR No. 25, 

question 5.
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The Postal Service tracks surface trips that arrive more than 4 hours late, referred to as 

Critically Late Trips (CLTs).48 Figure III-1 shows the number of CLTs by District in 

FY 2022. The majority of CLTs were caused by contractors in FY 2021 and FY 2022. 

FY 2022 ACD at 114. In FY 2022, the total number of CLTs increased, in part because of an 

increase in contractor-caused CLTs. Id. at 113. The increase in contractor failures from 

FY 2021 to FY 2022 was a result of “growth in package volume and home delivery of goods 

due to the COVID-19 pandemic and the shortage of Highway Contract Drivers.” Response 

to CHIR No. 23, question 6.d. The Commission discusses the Postal Service’s actions and 

plans to improve supplier performance and capacity.

Although the Postal Service tracks the number of CLTs, it remains unable to quantify the 

impacts of CLTs on service performance. Response to CHIR No. 6, question 5. Nevertheless, 

the Postal Service states that it attempted to remediate CLTs through initiatives focused 

on achieving operational clearance targets, addressing issues with supplier performance, 

and training and developing employees. See Response to CHIR No. 3, question 5.b.; 

Response to CHIR No. 17, question 6.b.

In terms of CLTs related to supplier performance, the Postal Service states that it has 

continued to utilize Silver Track Training (STT) sessions for field personnel. See Response 

to CHIR No. 3, question 5.b. According to the Postal Service, these training sessions are for 

all Postal Service logistics professionals and are designed to increase their knowledge of 

how to improve and manage supplier performance. Id. The Postal Service states that, as its 

employees completed this STT, there has been a “reduction in the number of omitted 

trips” and “trips are beginning to show on time performance above the same period last 

year.” Id.

The Postal Service also intends to update supplier contracts to include liquidated damages

clauses49 to address supplier-caused CLTs, and it explains that it is developing a new 

transportation management system that “will provide a robust measuring tool to identify 

late shipments and begin to perform a root cause analysis on the failures.”50 The Postal 

Service is also taking “a more aggressive stance” regarding supplier omission of routes and 

trips and timely delivery. Response to CHIR No. 23, question 6.e. Lastly, the Postal Service 

performed regular reviews of the top ten national service providers, automatically paid 

exceptional service awards, updated and implemented accurate tracking of omitted 

service and the reduction of payments related to routes and trips not operated, and 

enhanced supplier performance dashboards. Id. question 6.f.

48 FY 2022 ACD at 111; see Docket No. ACR2015, Responses of the United States Postal Service to Questions 1-2 of Chairman’s Information 

Request No. 22, November 15, 2016, question 12.b.i.

49 iquidated damages are “[a]n amount contractually stipulated as a reasonable estimation of actual damages to be recovered by one party if 

the other part reaches.” DAMAGES, Black's Law Dictionary (11th ed. 2019).

50 Response to CHIR No. 3, question . . “The Postal Service e pects that most suppliers, along ith their equipment, ill e integrated into 

these systems by the end of FY 2023. . . . Once those conditions are in place, supplier contracts can be updated to reflect an efficient way to 

address supplier responsibility for CLTs.” Id.
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In terms of supplier capacity, the Postal Service OIG documented the significant challenges 

in recruiting and retaining truck drivers as a result of a nationwide truck driver shortage 

in FY 2021.51 This issue persisted in FY 2022, causing increases in the amount of CLTs. See 

Response to CHIR No. 23, question 6.d. The Commission recommended that the Postal 

Service consider implementing some of the best practices identified by the OIG to better 

recruit and retain truck drivers and increase the efficiency of truck usage. FY 2021 Analysis 

at 47. In response to this recommendation, the Postal Service increased recruitment 

efforts to attract and retain truck drivers amid the nationwide shortage. Response to CHIR 

No. 17, question 5.b. As a result of these efforts, from FY 2021 to FY 2022, the Postal 

Service reduced the vacancy for truck drivers (from 12.06 percent to 5.78 percent) and the 

time to hire (from 90.61 days to 56.02 days). Id.

It is important that the Postal Service is focusing on closely monitoring supplier 

performance. However, 28.80 percent of CLTs in FY 2022 were attributable not to 

contractors, but to processing failures by the Postal Service. FY 2022 ACD at 114, Figure 

V-7. The Commission recognizes the Postal Service’s success in decreasing Postal Service–

caused CLTs by 11 percent from FY 2021 to FY 2022.52 However, the Commission supports 

the Postal Service’s current and planned efforts to remediate these CLTs by training 

additional processing employees, increasing package sorting capacity, measuring and 

improving on OPP to optimize distribution operations, undertaking daily review of 

routings, and initiating weekly performance reviews with field Regional and Division 

managers. See Response to CHIR No. 17, question 6.b.

The Commission recommends that the Postal Service continue initiatives to reduce supplier 

failure, improve supplier capacity, and increase its efforts to address CLTs whose causes are 

within its direct control.

(d) Outside Factors

The Postal Service stated that it experienced significant challenges in FY 2021 owing to 

natural disasters and weather events. FY 2021 Annual Report at 35. The Postal Service 

states that “[i]n some cases, these events impacted postal suppliers and led to reduced ontime service performance.” Id. The Postal Service also experienced issues with weather in 

FY 2022 that affected service. See FY 2022 ACD at 112-13. In response to a CHIR, the 

Postal Service provided a trend chart correlating weekly service trends for Market 

Dominant products for FY 2022 and FY 2023 (through April 14, 2023) with discrete 

severe weather events. See Response to CHIR No. 25, question 6.a., b.

51 See generally United States Postal Service, Office of the Inspector General, Report No. RISC-WP-22-002, The Truck Driver Shortage: 

Implications for the Postal Service, March 7, 2022, available at https://www.uspsoig.gov/sites/default/files/reports/2023-01/RISC-WP-22-

002.pdf (OIG Report No. RISC-WP-22-002).

52 See FY 2022 ACD at 114, Figure V-7. (194,342-218,400)/218,400 = -11.0%.
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The Commission previously recommended that the Postal Service restart the Disruptive 

Events initiative in FY 2022. FY 2021 Analysis at 50. The Commission explained that this 

initiative could enable the Postal Service to quantify more accurately effects of, and 

diagnose service failures caused by, events outside of management control, such as 

weather-related emergencies and natural disasters. Id. at 49-50. The Commission is 

pleased that the Postal Service has restarted the Disruptive Events initiative (renamed as 

the Unexpected Events initiative). See Response to CHIR No. 17, question 7; Response to 

CHIR No. 25, question 5.c.

The Commission supports the Postal Service’s renewal of the Unexpected Events Initiative, 

and it recommends that the Postal Service report on its progress in developing, and any 

results from, the Unexpected Events Initiative in the FY 2023 Report, including any effect on 

reducing CLTs.

(e) CY 2022 Election Cycle

The Commission appreciates the efforts taken, and results achieved, by the Postal Service

during election seasons. The Postal Service notes that “[t]he Postal Service Board of 

Governors reconstituted the Election Mail Committee in August 2021 to oversee, review, 

and monitor the Postal Service’s preparations for the 2022 primary and general elections 

and made recommendations to the Board on this and related issues.” FY 2022 Annual 

Report at 35. “In preparation for the 2022 mid-year election, [the United States Postal 

Inspection Service (USPIS)] joined the Department of Justice Election Crime Task Force to 

respond to and investigate all reports of election-related threats and crimes.” Id. at 22. It 

also conducted election mail training, conducted cybersecurity and infrastructure 

preparation, and established Election Security Coordinators in every USPIS division. Id.

In response to a CHIR, the Postal Service provided data comparing FY 2022 Election Mail53

service performance to FY 2022 non-Election Mail service performance data. See, e.g., 

Response to CHIR No. 13, question 13. The Postal Service delivered 1.655 billion pieces of 

Political Mail and 321.4 million pieces of Election Mail in FY 2022. Id. question 11. The 

Postal Service achieved above 97 percent on-time performance for Election Mail in 

FY 2022 with an average days-to-deliver of 1.83, as compared to below 91 percent on-time 

performance and an average days-to-deliver of 2.55 for non-Election Mail. Id. question 13.

For the November 2022 General Election, the Postal Service implemented extraordinary 

measures for ballot mail, a subset of Election Mail.54 Some of these extraordinary measures 

included:

53 “ lection ail” refers to items such as allots, voter registration cards, and a sentee applications that an authorized election official creates 

for voters. CHIR No. 13, question 11 n.4. contrast “Political ail,” refers to an mailpiece sent for political campaign purposes by a 

registered candidate, a campaign committee, or a committee of a political party to promote candidates, referendums, or campaigns. Id.

question 11 n.3.

54 United States Postal Service, 2022 General Election Extraordinary Measures Memorandum, September 29, 2022, available at

https://about.usps.com/what/government-services/election-mail/pdf/2022-general-election-extraordinary-measures.pdf (September 29, 2022 

Memorandum); see Response to CHIR No. 13, questions 14-15; Response to CHIR No. 15, question 4.
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[E]xpedited handling, extra deliveries, and special pickups as used in 

past elections, to connect blank ballots entered by election officials 

to voters, or completed ballots returned by voters entered close to or 

on Election Day to their intended destination (e.g., Priority Mail 

Express, Sunday deliveries, special deliveries, running collected 

ballots to Boards of Elections on Election Day, etc.). These 

procedures may deviate from standard policies and procedures, 

including those found in the Postal Operations Manual and other 

Handbooks.

September 29, 2022 Memorandum at 2.

The Commission commends the Postal Service for its efforts devoted to delivering Election 

Mail and Political Mail during the CY 2022 election cycle. These efforts were undertaken 

notwithstanding the adverse effects of the COVID-19 pandemic, in furtherance of the vital 

role the Postal Service plays in the American democratic process.

In OIG Report No. 20-225-R20, among other things, the OIG recommended that the Postal 

Service “[l]everage established partnerships with state and local election officials to work 

toward creating a separate, simplified mail product exclusively for Election Mail that 

would support uniform mail processing, including mandatory mailpiece tracking and 

proper mailpiece design.”55 The Postal Service “agreed to evaluate adding a dedicated mail 

product for Election Mail after the 2020 general election.” OIG Report No. 20-225-R20 at

19. This recommendation remained open as of September 26, 2022.56 During FY 2023, the 

Postal Service “tentatively plans to examine the feasibility and utility of a potential 

product or rate category for ballot mail[.]”57 This process is at an “early stage.” Response 

to CHIR No. 15, question 5.b. For example, the Postal Service notes that it does not 

“currently have a measure of unit revenue for Election Mail, much less a full panoply of 

billing determinant information to assess revenue-determining characteristics.” Id.

question 4.f.

The Commission will review the Postal Service’s efforts in connection with evaluating the 

feasibility of developing an Election Mail product or products as appropriate (e.g., if the 

Postal Service seeks regulatory approval for such product(s)).

55 United States Postal Service, Office of the Inspector General, Report No. 20-225-R20, Processing Readiness of Election and Political Mail 

During the 2020 General Elections, August 31, 2020, at 4, available at https://www.uspsoig.gov/sites/default/files/reports/2023-01/20-225-

R20.pdf (OIG Report No. 20-225-R20).

56 See United States Postal Service, Office of the Inspector General, Report No. 22-093-R22, Election Mail Readiness for the 2022 Mid-Term 

Elections, September 26, 2022, at 10, available at https://www.uspsoig.gov/sites/default/files/reports/2023-01/22-093-R22.pdf (OIG Report 

No. 22-093-R22).

57 Response to CHIR No. 15, question 5.b.; see USPS Board of Governors open sessions (May 9, 2023), available at 

https://about.usps.com/who/leadership/board-governors/?video=bgs230509.
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c. Plans for Improving High-Quality Service in FY 2023

(1) Continued Implementation of 10-Year Strategic Plan

The Postal Service reports that in FY 2023, it will continue implementing elements of its 

10-Year Strategic Plan. FY 2022 Annual Report at 35. These efforts generally involve 

transforming its processing facilities and transportation networks; planning for the peak 

season; financial outlays for additional vehicles, equipment, systems, and facilities; and 

stabilizing and enhancing its workforce. See id.

The Postal Service states that Postal Service leadership will continue the region-by-region 

modernization of the legacy network of processing and distribution facilities that began in 

2022. Id. at 36. The Postal Service states that its successful delivery of COVID-19 tests in 

FY 2022 validated its plan because the COVID-19 Test Kit project “proved that a limited set 

of strategically placed sites can deliver to most American homes in less than two days.” Id.

The Postal Service reports that it will continue to invest in its network through obtaining 

new delivery vehicles, replacing and repairing facilities, modernizing technologies, 

acquiring new sortation equipment, modernizing distribution centers, and redesigning its 

retail and delivery network.58 For example, the majority of the Postal Service’s delivery 

vehicle fleet is approaching 30 years old, and the Postal Service expects to replace 

approximately 200,000 of its 236,532 vehicles in the future. FY 2022 Annual Report at 37.

According to the Postal Service, this investment will contribute to improved service 

performance by “minimizing impacts due to break downs and reducing delivery trips 

allowing mail and packages to be delivered on time.” Id.

The Postal Service states that the network redesign and rebalancing is the most “efficient 

and enduring” way to improve service performance. Id. The Postal Service’s plans to 

improve service performance for its missed target on Single-Piece First-Class Mail 3-to-5-

Day fall under this initiative. As discussed above, the Postal Service will continue 

reviewing routings and streamlining its network to reduce complexity and improve 

reliability by moving from air-to-surface transportation and improving and measuring 

site-specific clearance times through focus on OPP. See Section A.3.b., supra.

The Postal Service states that its service performance success depends on investing in its 

workforce. See FY 2022 Annual Report at 37. Thus, the Postal Service’s 10-Year Strategic 

Plan includes converting pre-career employees to career status; giving supervisors tools, 

trainings, and resources; developing its workforce; and improving organizational culture. 

Id.

In all future Annual Reports through the first year following completion of the 10-Year 

Strategic Plan, the Commission recommends that the Postal Service report how the 10-Year 

58 See id. at 36; cf. Response to CHIR No.19, question 2.
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Strategic Plan (as a whole and for applicable distinct initiatives) affected the High-Quality 

Service performance indicator result.

(2) Service Performance by District and/or Area

There are differences in service performance across geographic areas. For example, Figure 

III-2 and Figure III-3 shows geographic variation in on-time service performance of SinglePiece First Class Mail 3-5-Day Letters/Postcards and Outside County Periodicals, 

respectively.

Figure III-2

FY 2022 On-Time Service Performance, By District

Single-Piece First Class Mail, 3-5-Day Letters/Postcards

Source: United States Postal Service, FY 2022 Quarter 4 Service Performance Measurement Data, November 9, 2022, ZIP folder 

“QuartPerf_FY22_Q4.zip,” ZIP folder “FY22 Q4 SP Reports.zip,” ZIP folder “First-Class ail.zip,” cel file “SPFC C 224 Scores Report. ls,” 

ta “SPFC C YT .”
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Figure III-3

FY 2022 On-Time Service Performance, By Area

Outside County Periodicals

Source: United States Postal Service, FY 2022 Quarter 4 Service Performance Measurement Data, November 9, 2022, ZIP folder 

“QuartPerf_FY22_Q4.zip,” ZIP folder “FY22 Q4 SP Reports.zip,” ZIP folder “Periodicals.zip,” cel file “Periodicals 224 Scores Report. ls,” ta 

“P R YT .”

Beginning in FY 2019, the Commission recommended that the Postal Service examine the 

fact that service performance across the Postal Service’s Districts varies relative to 

geography.59 The Postal Service reports that it performed root cause analysis “for mail 

processing facilities and/or lanes (i.e., origin/destination pairs) with the lowest scores for 

certain mail products.” Response to CHIR No. 17, question 9.b. Improvement plans were 

created and performance was tracked for the targeted Districts using “heat maps,” which 

represent service performance scores over a period of several weeks. Id. The Postal 

Service states that Division and plant management have regular discussions regarding 

reasons for service performance issues and strategies for improvement for

low-performing plants. Id.

The Commission continues to recommend that the Postal Service explore ways to better 

balance service performance scores across the nation. It is likely that significant gains in 

national scores could be made by focusing efforts on low-performing Areas and/or Districts. 

Thus, the Commission recommends the Postal Service study the reasons for service 

performance issues in the lowest performing Areas/Districts.

d. Response to Comments

59 See FY 2019 Analysis at 35-37; FY 2020 Analysis at 57-59; FY 2021 Analysis at 55-57.
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The Public Representative views the Postal Service’s description of its failure to meet the 

target for Single-Piece First-Class Mail, 3-5-Day, as insufficient and recommends that the 

Commission seek additional information. See PR Comments at 5-6. In its reply comments, 

the Postal Service responds to the Public Representative’s comments by providing

additional information about Single-Piece First-Class Mail, 3-5-Day. Postal Service Reply 

Comments at 2-3; see Section A.2., supra. The Postal Service also provided additional 

information in response to a CHIR. See Response to CHIR No. 23, question 7.

Commenting that there are “pockets of areas where mail delivery seems problematic,” the 

Public Representative encourages the Postal Service to take steps identified by the Postal 

Service OIG “to identify and reduce the number of undelivered and partially delivered 

routes.”60 In response to a CHIR, the Postal Service notes that the OIG offered two 

recommendations: (1) to “finalize system enhancements to identify undelivered and 

partially delivered routes;” and (2) to “enhance processes and tools to notify customers of 

delayed mail and undelivered and partially delivered routes.” Response to CHIR No. 23, 

question 5 (quoting OIG Report No. 21-262-R23 at 6) (internal quotation marks omitted). 

The Postal Service states that it agreed with and followed up on the first recommendation, 

such as by updating the National Delivery Intelligence Application to incorporate weather 

emergency event-mapping capabilities and non-delivery days. Id. The Postal Service 

further notes that it declined the second recommendation, but it is discussing this OIG 

recommendation further with the OIG. Id. The Commission appreciates the Postal Service’s 

engagement with OIG.

The Public Representative also highlights the importance of initiatives to improve 

transportation operations. See PR Comments at 10-11. The Commission finds that this is 

an appropriate area for Postal Service focus. Thus, the Commission recommends that the 

Postal Service specifically focus on transportation initiatives in its negotiations with 

contractors and its network redesign. In particular, the Postal Service should endeavor to 

reduce the number of CLTs, especially given the 7.6 percent increase in CLTs from FY 2021 

to FY 2022.61 These initiatives and the Commission’s recommendations are discussed in 

Section A.3.b. and c.(1)., supra.

NAPM comments that “the Postal Service should better utilize its pricing flexibility to give 

customers the incentive to move more mail into programs like commingle[.]” NAPM 

Comments at 5. The Commission appreciates NAPM’s comments on the Postal Service’s 

use of pricing flexibility; however, this comment is not particularly applicable to the 

FY 2022 Annual Report, which does not address pricing details. The Commission already 

addressed this comment in its FY 2022 ACD and encourages the Postal Service to directly 

engage with NAPM and other stakeholders to determine what, if any, benefits can be 

achieved by an increased focus on commingled mail. See FY 2022 ACD at 120.

60 PR Comments at 6 citing OIG Report No. 21-262-R23.

61 See FY 2022 ACD at 113, Figure V-6 (675,312-627,418)/627,418 = 7.6 percent.
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NAPM also “urge[s] the Postal Service to implement a reporting solution that allows 

commingle mailers and others to obtain visibility at a level that helps them identify the 

specific mail being excluded” from service performance measurement. Id. at 6. The 

Commission encourages the Postal Service to reach out to NAPM to address this issue.

NAPM requests that the Postal Service “report service performance on a quarterly and 

annual basis” separately for Presorted First-Class Mail Flats and Single-Piece First-Class 

Mail Flats. Id. However, the Postal Service asserts that it already provides this information 

quarterly and annually.62 The Commission expects the Postal Service to continue to 

provide such information.

Further, NAPM comments that it “is concerned that few of the specific initiatives laid out 

by the Postal Service in its FY2022 Performance Report or FY2023 Plan are designed to 

address First-Class Mail flats performance.” NAPM Comments at 7. NAPM also “would like 

to see more detail and attention given to the Postal Service’s plans to improve service 

performance for [USPS] Marketing Mail flats.” Id. at 8. In terms of flats performance, the 

Commission issued a detailed review of Postal Service flats performance inefficiencies in 

its recently released Flats Operations Study Report, and the Postal Service has 6 months 

“either to develop and implement a plan to remedy each inefficiency identified in the Flats 

Study or else to provide an explanation as to why remedying such inefficiency is 

impracticable.”

63 The Commission expects the Postal Service’s initiatives to improve flats 

performance to be explained in detail at that time.

Lastly, NAPM states that the Postal Service’s performance targets for “First-Class Mail may 

not be realistic or achievable, since they have been increased compared to FY2022, even 

though FY2022 performance was well below the lower targets.” NAPM Comments at 7-8. 

Although the Postal Service raised its First-Class Mail targets for FY 2023 to above the 

results it achieved in FY 2022, the Postal Service previously raised its FY 2022 targets 

above its FY 2021 results. FY 2022 Annual Report at 33. Despite this, the Postal Service 

achieved all but one of its targets in FY 2022 and made notable service performance 

improvements in the category in which it missed its target (Single-Piece First-Class Mail 3-

to-5-Day). In order to drive similar improvement, and in light of the Postal Service’s track 

record in FY 2022, the Commission agrees with the Postal Service that its FY 2023 targets 

are “appropriate.”64 However, in response to the Postal Service’s partial explanation of 

weather events impeding its ability to achieve its projections, the Commission reminds the 

Postal Service that “it is important that targets not be set so high that they leave the Postal 

62 See Postal Service Reply Comments at 3; cf., e.g., United States Postal Service, FY 2023 Quarter 1 Service Performance Measurement Data, 

February 9, 2023, Excel file “FC Flats 231 Scores Report. ls,” ta “FCF Quarter Aggregation-1” providing quarterl data Library Reference

USPS-FY22-29, December 29, 2022, Excel file “FY22 ACR First Class ail. ls ,“ ta ”FCF Aggregation - 1" (providing annual data).

63 See Docket No. SS2022-1, Flats Operations Study Report, April 6, 2023, at 210.

64 See Postal Service Reply Comments at 4. Based on performance to date, the Postal Service reports that it unlikely that Single-Piece FirstClass Mail 3-5-Day will achieve the target level set for FY 2023, but it maintains the annual target for all purposes. See Response to CHIR No. 

23, question 8. . Ho ever, FY 2 23 has not concluded. The Postal Service’s FY 2 23 performance result ill e evaluated against its FY 2023 

target in ne t ear’s report.
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Service with little margin for error.” FY 2021 Analysis at 36. Targets should not be set so 

high that there is no buffer to account for potential atypical events.

B. Excellent Customer Experience

1. Background

a. Customer Experience Surveys

The Postal Service measures customer experience (CX) by conducting surveys of 

residential, small/medium business, and large business customers.65 In FY 2022, the 

Postal Service measured CX using the following eight surveys:

• Business Service Network (BSN)

• Point of Sale (POS)

• Delivery

• Customer Care Center (CCC)

• Customer 360 (C360)

• Business Mail Entry Unit (BMEU)

• usps.com

• Large Business Panel

The Postal Service provides copies of these surveys in the FY 2022 ACR.66 Each survey 

measures a customer touchpoint or interaction between the customer and the Postal 

Service. Each of the eight surveys is summarized below.

The BSN provides nationwide support to qualified business customers related to service 

issues, information, and requests. FY 2022 Annual Report at 37. The BSN survey measures 

business customers’ satisfaction with the overall experience provided by the BSN. Id.

Customers who initiate a service request within the BSN receive an email invitation to 

take the BSN survey online within 30 days. Library Reference USPS-FY22-38, Preface at 3. 

The BSN survey consists of 14 evaluation questions and 4 open-ended customer supplied 

responses. Id. These questions ask business customers about their satisfaction with their 

65 Residential customers live in United States households that receive mail delivery. Small/medium business customers have fewer than 250 

employees at one location. Large business customers have 500 or more employees. Library Reference USPS-FY22-38, December 29, 2022, file

“ SPS-FY22-38 Preface.pdf,” at 3, (Library Reference USPS-FY22-38, Preface).

66 See Library Reference USPS-FY22-38, folder “FY22.38.Files,” file “CX_Surveys_FY22.pdf” CX Surveys). The Commission’s rules require the 

ACR to include a copy of each customer survey; a description of the customer type targeted by the survey; the number of surveys initiated and 

received; and in the case of multiple-choice questions, the number of responses received for each question, disaggregated by each of the 

possible responses. 39 C.F.R. § 3055.92.
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overall experience with the BSN and interaction with the BSN representative. See Surveys 

at 9-21.

The POS survey measures customers’ overall satisfaction with their experience at retail 

locations that use POS equipment.67 After completing a retail transaction, customers 

receive a receipt inviting them to take the POS survey via website, telephone number, or 

Quick Response Code within 30 days. Library Reference USPS-FY22-38, Preface at 3. The 

POS survey is conducted through a web-based survey platform and consists of 12 

evaluation questions and 2 open-ended customer supplied responses. Id. These questions 

ask retail customers to evaluate their visit to the retail location, their interaction with the 

sales associate, and their wait time in line.68

The Delivery survey measures the level of satisfaction of residential and small/medium 

business customers with receiving mail and packages.69 There are different Delivery 

surveys for residential and small/medium business customers. Every week randomly 

selected residential and small/medium business customers are mailed a letter inviting 

them to take the survey either by phone or online. Library Reference USPS-FY22-38, 

Preface at 3. Residential customers are asked 19 evaluation questions and 2 open-ended 

customer supplied responses. Id. Small/medium business customers are asked 20 

evaluation questions and 2 open-ended customer supplied responses. Id. These questions 

ask customers to evaluate their experience receiving mail and packages as well as sending 

domestic and international products. See Surveys at 22-38.

The CCC survey measures customer satisfaction with calls made to the CCC, which handles 

customer calls to the Postal Service’s toll-free customer service line.70 Customers who call 

the CCC may use the Interactive Voice Response (IVR) system or speak to a live agent. 

Library Reference USPS-FY22-38, Preface at 4. There are two different CCC surveys that 

measure customers’ overall satisfaction with either the IVR system (IVR system survey) or 

the live agent (Live Agent survey). Id. For the IVR system survey, customers who call the 

toll-free number and only interact with the IVR system are asked at the beginning of the

call if they would like to complete a survey after the call. Id. For the Live Agent survey, 

customers who call the toll-free number and speak with a live agent receive phone 

invitations to take the survey. Id. The CCC surveys ask about customers’ overall experience 

provided by the IVR system or the live agent. See Surveys at 81-82.

67 FY 2022 Annual Report at 37; Library Reference USPS-FY22-38, Preface at 3.

68 See Surveys at 2-8. The Commission discussed wait time in line in the FY 2022 ACD. See FY 2022 ACD at 186-88.

69 FY 2022 Annual Report at 37. The Delivery survey also measures residential and small/medium business customer satisfaction with Market 

Dominant products, which the Commission discussed in the FY 2022 ACD. See FY 2022 ACD at 190-95.

70 FY 2022 Annual Report at 38; Library Reference USPS-FY22-38, Preface at 4.
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The C360 survey measures satisfaction with issue resolution for customers who open a 

service ticket through a CCC live agent, via usps.com, or at a local Post Office.71 The C360 

survey is sent to customers who provide an email address after their cases have been 

closed. Library Reference USPS-FY22-38, Preface at 4. Customers who only provide a 

phone number receive a call from the IVR system. Id. The C360 survey consists of 13 

evaluation questions and 2 open-ended customer supplied responses. Id. These questions 

ask customers whether their case was resolved successfully and how satisfied they were 

with the quality of service received in response to their issue. See Surveys at 39-49.

The BMEU is the area of a postal facility where business mailers present bulk, presorted, 

and permit mail for acceptance.72 The BMEU survey measures business customers’ overall 

satisfaction with their experience at the BMEU.73 After business customers produce and 

finalize a postage statement at the BMEU, they receive an email inviting them to take the 

web-based survey, which consists of nine evaluation questions and three open-ended 

customer supplied responses. Library Reference USPS-FY22-38, Preface at 2-3. These 

questions ask about business mailers’ overall satisfaction with their experience at the 

BMEU, as well as their experience with acceptance employees at the BMEU. See Surveys 

at 72-80.

The usps.com survey measures the level of satisfaction for customers who visit the Postal 

Service’s website. FY 2022 Annual Report at 38. The survey is offered to a random sample 

of users who become eligible visitors by meeting all of the following criteria: visited the 

website through a desktop, tablet, or phone; clicked through three or more web pages 

with a session more than 5 seconds long; did not decline a survey within the past 30 days; 

and did not submit feedback within the past 60 days. Library Reference USPS-FY22-38, 

Preface at 4. The survey consists of four evaluation questions and one open-ended 

customer supplied response. Surveys at 83. These questions ask about customer 

satisfaction with the overall experience provided by the website and whether customers 

accomplished what they wanted to on the website. See id.

The Large Business Panel survey is a relational panel survey that measures customer 

satisfaction of large business customers, which are those with 500 or more employees.74 A 

third-party vendor manages customers that sign up to participate in the panel. Id. In FY 

2022, the Large Business Panel survey was conducted monthly to account for seasonal 

variation in customer satisfaction with Market Dominant products.75 The survey consists 

of 21 evaluation questions and 2 open-ended customer supplied responses. Library 

71 FY 2022 Annual Report at 38; Library Reference USPS-FY22-38, Preface at 4.

72 “ usiness ail ntr nit,” nited States Postal Service, Glossary of Postal Terms (Publication 32), July 2013, available at 

https://about.usps.com/publications/pub32/pub32_terms.htm.

73 FY 2022 Annual Report at 38; Library Reference USPS-FY22-38, Preface at 2.

74 Library Reference USPS-FY22-38, Preface at 5.

75 Id. The Commission discusses large business customer satisfaction with Market Dominant products in the FY 2022 ACD. See FY 2022 ACD at 

190-95.
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Reference USPS-FY22-38, Preface at 5. These questions ask large business customers 

about their overall satisfaction with their recent experience with the Postal Service, as 

well as their usage of and satisfaction with domestic and international mail products. See 

Surveys at 50-71.

b. Performance Indicators

In FY 2022, the Postal Service used eight performance indicators or metrics to track 

progress toward the Excellent Customer Experience performance goal. Seven of those 

performance indicators correspond directly to one of the CX surveys described above.76

Results of these seven CX survey performance indicators are calculated as the percentage 

of customers who responded “Very Satisfied” or “Mostly Satisfied” on a six-point scale to a 

question about overall satisfaction on the particular survey. FY 2022 ACR at 57. The 

overall satisfaction question for each of the seven CX surveys is shown in Table III-7.

76 FY 2022 Annual Report at 38. The Large Business Panel survey is the exception. The Postal Service introduced the Large Business Panel as a 

performance indicator in FY 2018 but discontinued this performance indicator in FY 2019. See FY 2018 Analysis at 45. In FY 2019, the Postal 

Service explained that it discontinued using the Large Business Panel performance indicator because business CX was already measured by the 

BSN and BMEU surveys. FY 2018 Annual Report at 21. The Postal Service has continued to administer the Large Business Panel survey since 

FY 2019.
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Table III-7

Customer Experience Surveys

FY 2022 Overall Satisfaction Questions

Customer Experience Surveys Overall Satisfaction Questions

Business Service Network

• How satisfied are you with the overall experience provided by the 

Business Service Network?

Point of Sale

• Thinking about this visit to the Post Office, overall, how satisfied were 

you?

Delivery

• Thinking about your overall experience with receiving mail and/or 

packages delivered by the Postal Service recently, how satisfied are 

you?

Customer Care Center

• Live Agent survey: Please tell us how satisfied you were with the 

overall experience provided by the Customer Care Center.

• Interactive Voice Response survey: Please tell us how satisfied you 

were with the overall experience provided by the Postal Service 

automated system.

Customer 360

• Overall, how satisfied are you with the quality of service you received 

in response to the issue?

Business Mail Entry Unit

• Overall, how satisfied were you with your experience at the Business 

Mail Entry Unit?

usps.com

• How satisfied are you with the overall experience provided by the 

usps.com website?

Source: Library Reference USPS-FY22-38, Preface at 3-5.

The Postal Service uses the result of each of the seven CX survey performance indicators 

to calculate the CX Composite Index, which is the eighth performance indicator tracking 

progress toward the Excellent Customer Experience performance goal. FY 2022 Annual 

Report at 38. The CX Composite Index is a weighted composite based on results of the CX 

survey performance indicators. Id. While each survey measures CX based on specific 

touchpoints or interactions with the Postal Service, the CX Composite Index measures 

overall CX across the most frequently used customer-facing channels. Id. at 37. 

Methodologies for calculating results for the Excellent Customer Experience performance 

indicators are discussed in Section B.3.a., infra.

In FY 2022, results of the CX Composite Index, POS, Delivery, C360, and BMEU 

performance indicators did not meet their respective targets. FY 2022 Annual Report at 38. 

The Postal Service explains that the CX Composite Index result did not meet its target 

because results of the POS, Delivery, C360, and BMEU performance indicators missed their 
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respective FY 2022 targets. Id. Explanations for not meeting FY 2022 targets are shown in 

Figure III-5. See Section B.3.b., infra.

To improve progress toward the Excellent Customer Experience performance goal in 

FY 2023, the Postal Service states it will improve its measurement of CX by ensuring that 

CX survey questions accurately measure both customer sentiment and attributes of 

customer satisfaction. FY 2022 Annual Report at 41. It states it will continue providing 

scenario-based trainings, provide in-person conferences, and hold weekly customer 

satisfaction meetings. Id. Plans for meeting FY 2023 targets are shown in Figure III-5. See

Section B.3.b., infra.

2. Comments

The Public Representative observes that results for each performance indicator improved 

between FY 2021 and FY 2022. PR Comments at 12-13. However, he states that the 

FY 2022 CX Composite Index target was not met because four performance indicators 

missed their respective FY 2022 targets: POS, Delivery, C360, and BMEU. Id. at 12. He 

comments that the largest margin of improvement was for the CCC performance indicator, 

whose result increased by almost 9 percentage points in FY 2022. Id. at 13. He notes that 

the usps.com and C360 performance indicators also showed significant improvement 

between FY 2021 and FY 2022. Id. He states that although the BSN and BMEU performance 

indicators showed the least improvement in FY 2022, the results were already high 

compared to the other performance indicators, and the BSN performance indicator 

exceeded the FY 2022 target. Id. He concludes that the Postal Service’s planned initiatives 

to improve service performance will, in turn, improve C360 results and hopefully reduce 

the number of customer inquiries that need to be resolved. Id. at 14.

NAPM recommends several changes to the CX surveys. First, it asserts that news articles 

have reported an increase in reports of mail theft, missing mail, and non-delivery of mail 

for several days within different regions and communities. NAPM Comments at 8. It 

observes that the Delivery survey does not appear to have specific questions covering 

these topics and collecting data on these issues. Id. at 9. It recommends that the Postal 

Service consider adding questions concerning mail theft, missing mail, and non-delivery of 

mail, as well as “collect data from customers to identify the extent of these issues and drive 

improvements.” Id. NAPM suggests that the Postal Service add questions asking survey 

respondents whether they attempted to contact the Postal Service concerning their 

delivery issue and, if so, how they attempted such contact and whether they were 

successful in contacting the Postal Service. Id.

Also, NAPM observes that the Postal Service uses a Mail and Shipping Solutions Center 

(MSSC) Help Desk for business mailers and recently announced plans to move other 

existing Help Desk applications into the MSSC platform. Id. It states that it is unclear 

whether the existing CX surveys used for business mailers include questions about the 

MSSC experience. Id. If there are none, NAPM recommends that the CX surveys and 

metrics for business mailers include questions about the MSSC experience. Id.
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In its reply comments, the Postal Service responds that regarding mail theft, missing mail, 

and non-delivery of mail, it closely monitors reports of missing mail, and customers may 

initiate a C360 service request to report any service issue encountered. Postal Service 

Reply Comments at 7. It explains that when customers initiate service requests, they are 

encouraged to describe the issue they have experienced, including mail theft, missing mail, 

and non-delivery of mail, which is documented on the C360 platform. Id. The Postal 

Service states that it then works to resolve the issues described, and customers receive the 

C360 survey after the inquiry is closed. Id. It points out that the C360 survey gauges 

customer satisfaction with their experience based on the Postal Service’s responsiveness, 

promptness, and degree of success in achieving a resolution. Id. at 7-8.

The Postal Service confirms that it collects data points generated by service requests and 

submits to senior management a daily list of requests relating to daily mail service and 

mail not received for two or more days. Id. at 8. It states that it refers reported cases of 

mail theft to the Postal Inspection Service to review and investigate. Id. If the reported 

case does not involve mail theft, the Postal Inspection Service transfers the matter back to 

the Postal Service to review and resolve. Id. The Postal Service concludes that “it is the 

service request that generates information concerning the types of service problems that 

arise, while the C360 survey invites feedback on the Postal Service’s performance in 

resolving those problems.” Id.

Regarding the MSSC experience, the Postal Service responds that the BMEU survey does 

include specific questions related to the customers use of the MSSC. Id. It submits that 

adding questions concerning the MSSC experience are unnecessary. Id.

3. Commission Analysis

The Postal Service exceeded FY 2022 targets for the BSN, CCC, and usps.com performance 

indicators but missed FY 2022 targets for the other Excellent Customer Experience 

performance indicators (CX Composite Index, POS, Delivery, C360, and BMEU). FY 2022 

Annual Report at 38.

The Commission finds that the Postal Service partially met the Excellent Customer 

Experience performance goal in FY 2022 because it missed five targets and met or exceeded 

three targets.

NAPM recommends that the Postal Service consider adding questions to the CX surveys 

concerning mail theft, missing mail, and non-delivery of mail, as well as “collect data from 

customers to identify the extent of these issues and drive improvements.” NAPM 

Comments at 9. It also suggests that the Postal Service add questions asking survey 

respondents about their attempts to contact the Postal Service about their delivery issue, 

including how they attempted such contact and whether they were successful. Id.
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The Postal Service responds that customers may report service issues—including mail 

theft, missing mail, and non-delivery of mail—by submitting a C360 service request. Postal 

Service Reply Comments at 7. It states that it sends data regarding daily mail service and 

mail not received for two or more days to senior management, and data reporting cases of 

mail theft to the Postal Inspection Service. Id. at 8. Regarding theft of mail from collection 

boxes, the Postal Service acknowledges that FY 2022 CX results do not reflect customers’ 

experience with collection box theft because the CX surveys do not directly address 

collection box use. Response to CHIR No. 6, question 8.c. However, it notes that the 

Delivery and C360 surveys have open-ended comment boxes allowing customers to 

describe their experience with collection box theft. Id. It states that textual analytics that 

process these comments have not identified collection box theft “as a prevalent or 

significant area of customer concern.” Id.

The Commission observes that the Postal Service does collect information on mail theft, 

missing mail, and non-delivery of mail via the C360 service requests. However, the Postal 

Service could collect more data and improve efforts to resolve and prevent these issues by 

also adding questions to the CX surveys.

The Commission recommends that the Postal Service consider asking questions on the C360 

survey about mail theft to collect more data and evaluate its impact on C360 performance 

indicator results. The Commission also recommends that the Postal Service consider adding 

questions to the Delivery survey about missed mail or non-delivery of mail to gather more 

data on this issue.

In the sections below, the Commission describes and compares methodologies for 

calculating performance indicator results, as well as analyzes targets and results. The 

Commission also compares the Postal Service’s measurement of CX to metrics used in the 

private sector and other organizations, including the Net Promoter Score (NPS) and social 

media.

a. Performance Indicator Methodologies

This section describes and compares the methodologies for calculating results of the CX 

Composite Index and the seven CX survey performance indicators77 from FY 2019 through 

FY 2022.

(1) Customer Experience Composite Index

The CX Composite Index is a performance indicator that “provides a comprehensive view 

of the customer’s experience across the most frequently used customer-facing channels.” 

FY 2022 Annual Report at 37. The result is a weighted composite based on results of the CX 

survey performance indicators. Id. Figure III-4 shows how each performance indicator 

was weighted to calculate the FY 2022 CX Composite Index result. As Figure III-4 shows, 

77 The CX survey performance indicators are the BSN, POS, Delivery, CCC, C360, usps.com, and BMEU.
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the performance indicators are grouped into three core areas: Consumer, Business, and 

Delivery experience.

Figure III-4

Customer Experience Composite Index

Weights of Performance Indicators in FY 2022

Source: FY 2022 Annual Report at 37-38.

The Postal Service calculated the FY 2022 CX Composite Index result of 72.72 in three 

steps. First, the Postal Service determined the FY 2022 result for each CX survey 

performance indicator.78 Second, the Postal Service multiplied the result of each CX survey 

performance indicator by its respective weight listed in Figure III-4. Third, the Postal 

Service added the weighted results together to arrive at the FY 2022 CX Composite Index 

result of 72.72. Table III-8 illustrates the steps for calculating the FY 2022 CX Composite 

Index result.

78 See FY 2022 Annual Report at 38; Docket No. ACR2019, Responses of the United States Postal Service to Questions 1-8 of Chairman’s 

Information Request No. 18, March 3, 2020, question 3. FY 2022 results for the CX survey performance indicators were calculated as the 

percentage of customers ho responded “Ver Satisfied” or “ ostl Satisfied” on a si -point scale to the overall satisfaction question for the 

corresponding CX survey shown in Table III-7. See Section B.1.b., supra.

 usiness Service Net or 

 usiness ail ntr nit 

 eliver 

 Customer 3 

 

 Point of Sale 

 Customer Care Center 

 

1 

2 

2 

2 

1 

1 
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Table III-8

Customer Experience Composite Index

Steps for Calculating the FY 2022 Result

Customer Experience Survey 

Performance Indicatora

FY 2022 Result Weight (%)

Weighted 

Resultb

Business Service Network 98.20 x 10 = 9.82

Point of Sale 86.34 x 15 = 12.95

Delivery 73.91 x 20 = 14.78

Customer Care Center 70.75 x 20 = 14.15

Customer 360 38.44 x 20 = 7.69

Business Mail Entry Unit 96.48 x 10 = 9.65

usps.com 73.62 x 5 = 3.68

FY 2022 Customer Experience Composite Index Score 72.72c

a Targets for each of these performance indicators are listed in Table III-10, infra.

b Results are rounded to the nearest hundredth.

c The CX Composite Index score differs slightly from the sum of the weighted results due to rounding.

Source: FY 2022 Annual Report at 37-38.

Between FY 2019 and FY 2022, the Postal Service used the same methodology for 

calculating the CX Composite Index result. See FY 2021 Analysis at 66; FY 2022 Annual 

Report at 37-38. In FY 2023, the Postal Service is changing the methodology for calculating 

this performance indicator. FY 2022 Annual Report at 41. The POS survey weight will 

increase from 15 percent to 20 percent, and the CCC survey weight will decrease from 20 

percent to 15 percent. Id. It stated that “[t]hese modifications will allow the CX Composite 

Index score to more accurately reflect the interactions with postal customers.” Id.

Because FY 2023 CX Composite Index results will not be comparable to results from 

FY 2020 through FY 2022,79 the Postal Service will need to address this issue to comply 

with 39 U.S.C. § 2804(c) in its FY 2023 Report by following the Commission’s directives 

described in Chapter II. See Chapter II, Section B.2.b., supra.

(2) Customer Experience Survey Performance Indicators

Table III-9 shows the methodologies for calculating results of each CX survey performance 

indicator from FY 2019 through FY 2022.

79 See FY 2021 Analysis at 66-67.
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Table III-9

Customer Experience Survey

Performance Indicator Methodologies

FY 2019-FY 2022

Customer Experience 

Survey Performance 

Indicator

FY 2019 FY 2020 FY 2021 FY 2022

Business Service 

Network Overall customer satisfaction with the BSN experience

Point of Sale Overall customer satisfaction with the retail experience at the Post Office

Deliverya Composite of overall customer satisfaction with the delivery of mail and packages 

(unweighted)

Customer Care Center

Composite of satisfaction with the overall 

experience provided by the Live Agent 

(25 percent) and Interactive Voice 

Response system (75 percent)

Composite of satisfaction with the 

overall experience provided by the Live 

Agent and IVR system (unweighted)

Customer 360 Overall satisfaction with the quality of service received in response to a C360 case or 

issue

Business Mail Entry Unit Overall customer satisfaction with the BMEU experience

usps.com Overall customer satisfaction with the experience provided by the usps.com website

a Delivery survey results for residential and small/medium business customers are combined into one unweighted score.

Source: FY 2021 Analysis at 68; FY 2022 ACR at 58; FY 2021 ACR at 58; Library Reference USPS-FY22-38, folders “FY22.38.Files.zip” cel file 

“CX_Composite_A _S RV YS_Program vervie _FY22. ls .”

Table III-9 shows that from FY 2019 through FY 2022, the Postal Service used the same 

methodologies to calculate results for each CX survey performance indicator except for the 

CCC. As discussed in the FY 2021 Analysis, in FY 2021 the Postal Service changed its 

method for calculating the CCC results from a weighted to an unweighted score. See FY 

2021 Analysis at 68. Because FY 2020 CCC results will not be comparable to results from 

FY 2021 through FY 2023, the Postal Service will need to address this issue to comply with 

39 U.S.C. § 2804(c) in its FY 2023 Report by following the Commission’s directives 

described in Chapter II. See Chapter II, Section B.2.b., supra.
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b. Analysis of Targets and Results

(1) FY 2022 Targets and Results

For each Excellent Customer Experience performance indicator, Table III-10 shows results 

from FY 2019 through FY 2022 and compares FY 2022 targets and results. As Table III-10

shows, in FY 2022 the Postal Service met three targets and missed five targets.

Table III-10

Excellent Customer Experience Performance Indicators

Comparison of FY 2022 Targets and FY 2019-FY2022 Results

Performance Indicator FY 2022 

Targets

Performance Gap 

between FY 2021 and FY 

2022 Result

Results

FY 

2022

FY 

2021

FY 

2020

FY 

2019

Customer Experience 

Composite Indexa

72.99 4.23 72.72 68.49 72.40 69.04

Business Service Network 97.33% 0.31% 98.20% 97.89% 97.33% 96.68%

Point of Sale 87.46% 1.95% 86.34% 84.39% 87.46% 87.77%

Deliverya 80.94 3.50 73.91 70.41 80.94 80.40

Customer Care Centera 63.02 8.90 70.75 61.85 60.03 46.94

Customer 360 40.05% 5.10% 38.44% 33.34% 40.05% 37.45%

Business Mail Entry Unit 96.72% 0.82% 96.48% 95.66% 96.72% 96.00%

usps.com 73.41% 6.49% 73.62% 67.13% 73.41% 72.94%

Note: Red text indicates below target. Green text indicates above target.

a Targets and results for these performance indicators are not presented as percentages because they are calculated by weighting and 

aggregating various survey results.

Source: FY 2022 Annual Report at 33, 38.

Table III-10 shows that FY 2022 results range significantly from 38.44 percent (C360) to 

98.20 percent (BSN). While varied, FY 2022 results for each performance indicator 

improved compared to FY 2021. The largest margins of improvement were for the CCC 

performance indicator, which improved by 8.90 points, as well as the C360 and usps.com

performance indicators, which increased by 5.10 percent and 6.49 percent, respectively. 

The CX Composite Index, POS, Delivery, C360, and BMEU performance indicators missed 

their respective targets in FY 2022. However, for each performance indicator except for 

the Delivery survey, FY 2022 results only missed their respective FY 2022 targets by less 

than two points. The Delivery performance indicator result missed the target by 7.03 

points. The reasons given by the Postal Service for missing FY 2022 targets and the Postal 

Service’s plans for meeting FY 2023 targets are listed in Figure III-5.
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Figure III-5

Postal Service Reasons for Missing FY 2022 Targets and

Plans for Meeting FY 2023 Targets

a The SSK relocation initiative involves relocating SSKs from underutilized sites to new locations to improve wait time in line and CX. FY 2022 

ACR at 61. The Rapid Dropoff Station initiative will provide customers the option to scan prepaid packages and receive a receipt without 

waiting a full window service line. Id.

b The NP Box pilot was designed to replace existing Centralized Box Units with boxes with much larger compartments to accommodate more 

or larger packages. FY 2022 ACR at 64. The Smart Locker Project pilot was designed to install electronic keyless parcel lockers in indoor or 

outdoor locations to provide a secure storage solution and allow parcel notification on delivery. Id. at 64-65.

Source: FY 2022 Annual Report at 38-40; FY 2022 ACR at 59-73; Response to CHIR No. 29, question 1.

Reason for Missing FY 2022 Target: 

Point of Sale, Delivery, Customer 360, and 

Business Mail Entry Unit performance 

indicators missed FY 2022 targets

Plans for Meeting FY 2023 Target: 

Improve CX measurement; empower 

workforce to prevent undesirable 

customer experiences

Customer perience CX Composite Inde 

Reasons for Missing FY 2022 Target: 

Dissatisfaction with employee behavior; 

impact of the COVID-19 pandemic on 

employee availability

Plans for Meeting FY 2023 Target: 

Reduce wait time in line by deploying SelfService Kiosk (SSK) Relocation and Rapid 

Dropoff Station technology initiativesa

Reasons for Missing FY 2022 Target: 

Delays implementing Neighbor Post (NP) 

Box and Smart Locker pilotsb

Plans for Meeting FY 2023 Target:

Improve street performance and package 

delivery; enhance vehicle availability

 eliver 

Point of Sale

Reasons for Missing FY 2022 Target: 

Inability to successfully resolve customer 

issues due to new and inexperienced 

Customer 360 employees

Plans for Meeting FY 2023 Target: 

Update existing Customer 360 platform 

training and develop new scenario-based 

trainings to help resolve customer inquiries

Customer 3 

Reasons for Missing FY 2022 Target:

Issue resolution was a contributing factor 

due to customers’ e perience ith 

functions outside the 

Business Mail Entry Unit

Plans for Meeting FY 2023 Target: 

Increase employee engagement; mentor 

and guide managers by providing inperson conferences

 usiness ail ntr nit
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Overall, the Postal Service’s progress toward the Excellent Customer Experience goal 

improved in FY 2022 compared to FY 2021. In the FY 2021 Analysis, the Commission 

expressed concern that the FY 2021 Delivery and C360 performance indicator results 

missed their respective FY 2021 targets by more than 15 points and had the largest yearover-year declines. FY 2021 Analysis at 71. By contrast, results for both the Delivery and 

C360 performance indicators improved between FY 2021 and FY 2022. Although they 

both missed FY 2022 targets, the C360 performance indicator result fell short of the 

FY 2022 target of 40.05 percent by 1.61 percentage points.

Although the C360 performance indicator improved by 5.10 percentage points in FY 2022, 

the FY 2022 result (38.44 percent) continues to be the lowest among all of the Excellent 

Customer Experience performance indicators. In the FY 2021 Analysis, the Commission 

stated that targeting key drivers of overall satisfaction represents an opportunity for the 

Postal Service to improve performance indicator results.80

In FY 2023, the Commission recommends that the Postal Service strive to improve 

performance indicator results by targeting key drivers of overall satisfaction. For the C360 

performance indicator, the Commission recommends that the Postal Service strive to 

improve successful resolution of customer issues, which is a key driver for C360 overall 

satisfaction.

(2) FY 2023 Targets

The Postal Service set FY 2023 targets for each Excellent Customer Experience 

performance indicator, which are shown in Table III-11, along with FY 2022 targets and 

results.

80 Id. at 71. The Commission showed key drivers for overall satisfaction for each performance indicator in Figure III-7. See id. at 72.
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Table III-11

Excellent Customer Experience Performance Indicators

FY 2023 Targets and FY 2022 Targets and Results

Performance Indicators

Targets

FY 2022 Results

FY 2023 FY 2022

Customer Experience Composite Indexa 74.39 72.99 72.72

Business Service Network 98.00% 97.33% 98.20%

Point of Sale 87.46% 87.46% 86.34%

Deliverya 80.94 80.94 73.91

Customer Care Centera 69.88 63.02 70.75

Customer 360 40.05% 40.05% 38.44%

Business Mail Entry Unit 96.29% 96.72% 96.48%

usps.com 73.41% 73.41% 73.62%

Note: Red text indicates below target. Green text indicates met or above target. 

a Targets and results for these performance indicators are not presented as percentages because they are calculated by weighting and 

aggregating various survey results.

Source: FY 2022 Annual Report at 38, 40.

Table III-11 shows that FY 2023 targets for the POS, Delivery, C360, and usps.com

performance indicators are the same as FY 2022 targets. FY 2023 targets for the CX 

Composite Index, BSN, and CCC performance indicators increased compared to FY 2022, 

and the FY 2023 BMEU performance indicator target decreased slightly from 96.72 

percent in FY 2022 to 96.29 percent in FY 2023.

The Postal Service provides the rationale for setting FY 2023 targets in a CHIR response. It 

explains that it reviews Excellent Customer Experience targets in a holistic manner and 

does not set the CX Composite Index target individually. Response to CHIR No. 29, 

questions 2.a.-b. Instead, it states that it sets this target by combining the individual 

weighted targets for each CX survey performance indicator, and the FY 2023 CX 

Composite Index target was based on increases in FY 2023 targets for certain CX survey 

performance indicators. Id.

The Postal Service explains that it sets targets for each CX survey performance indicator 

“at the level that the Postal Service determines to be achievable based, in part, on previous 

years’ performance numbers.” Id. For this reason, it states that it set the FY 2023 POS, 

Delivery, and C360 performance indicator targets the same as FY 2022 even though 

FY 2022 targets were not met because it believes that the targets are achievable in 

FY 2023. Id. The Postal Service notes that for the POS and C360 performance indicators, 

almost 42 percent of scores at the Area, District, and unit levels did meet their targets in

FY 2022 even though the national targets were not met. Id. It maintains that the FY 2023 
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usps.com performance indicator target “continues to be appropriate” even though the FY 

2022 target was not met. Id.

The Postal Service’s method for setting targets is consistent with the Commission’s past 

recommendation that the Postal Service consider the prior year’s result when setting the 

subsequent year’s target. See FY 2019 Analysis at 42-43. For the BSN and CCC performance 

indicators, increasing the FY 2023 targets appears reasonable because they exceeded 

FY 2022 targets. See Table III-11, supra. The usps.com performance indicator also 

exceeded the FY 2022 target, but the FY 2023 target is the same as FY 2022. However, this 

FY 2023 target appears reasonable considering that the FY 2023 target is almost the same 

as the FY 2022 result (a 0.21 percentage point difference). See id.

For the BMEU performance indicator, the FY 2023 target is 96.29, which is less than 1

percentage point lower than both the FY 2022 target and the FY 2022 result. Thus, the 

Commission agrees with the Postal Service that the FY 2023 target appears reasonable.

For the POS, C360, and Delivery performance indicators, even though their respective 

targets were not met in FY 2022, the Postal Service represents that maintaining the same 

respective target level for FY 2023 is achievable. To meet the POS and C360 targets in 

FY 2023, the FY 2023 results for each indicator would need to increase over FY 2022 

results by 1.12 and 1.61 percentage points, respectively. Noting that the POS and C360 

results increased from FY 2021 to FY 2022 by 1.95 and 5.10 percentage points, 

respectively, the Commission finds the POS and C360 FY 2023 targets appear to be 

reasonable. To meet the Delivery target in FY 2023, the Commission observes that the FY 

2023 result would need to increase over FY 2022 results by 7.03 percentage points. The 

Commission further observes that the Delivery results increased by 3.50 percentage 

points from FY 2021 to FY 2022. The Commission finds that the FY 2023 Delivery target 

appears to be with the range of potential reasonable targets, as long as the Postal Service 

increases its focus on execution of its plans to achieve the Delivery target in FY 2023 

(enhancing vehicle availability and improving street performance and package delivery).

Similarly, the Postal Service raised the FY 2023 CX Composite Index target even though 

the FY 2022 target was not met because the FY 2023 target level is based on the Postal 

Service’s decisions to raise some of the underlying targets, which the Postal Service 

represents are set at achievable levels for FY 2023. The Commission finds that the FY 2023 

CX Composite Index target, which is 1.67 percentage points more than the FY 2022 result, 

appears to be reasonable, as long as the Postal Service focuses on increasing the 

underlying results in FY 2023.

The Commission finds that the FY 2023 targets for the Excellent Customer Experience 

performance indicators are reasonable. It reiterates its recommendation that the Postal 

Service consider the prior year’s result when setting the subsequent year’s target. To improve 

transparency, the FY 2024 Plan should discuss the rationale for setting the FY 2024 targets.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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c. Net Promoter Score

(1) Background

As previously discussed, the Postal Service evaluates progress toward the Excellent 

Customer Experience performance goal based on CX surveys measuring overall 

satisfaction. See Section B.1., supra. The Postal Service also measures CX using the NPS, 

which is a metric that is widely used in CX programs to measure the loyalty of customers 

to a company.81 It measures customer perception based on a single question: “How likely 

is it that you would recommend [Organization X/Product Y/Service Z] to a friend or 

colleague?” Id.

The Postal Service includes the NPS question on each of the CX surveys by asking 

customers how likely they are to recommend the Postal Service to a friend or colleague. 

The FY 2022 NPS question for each of the CX surveys is shown in Figure III-6.

81 What is NPS? Your ultimate guide to Net Promoter Score, Qualtricsxm, available at https://www.qualtrics.com/experiencemanagement/customer/net-promoter-score/ (Qualtricsxm NPS).
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Figure III-6

FY 2022 Net Promoter Score Questions

Source: CX Surveys at 2, 11, 23, 41, 73, 81-83.

The NPS allows a company to evaluate the totality of customer interactions with the 

company and values the long-term relationship between the customer and company.82 For 

example, a customer may be unhappy with a misdelivered package, but may continue to 

patronize the Postal Service because of a long history of dependable service and 

competitive prices. OIG Report No. RARC-WP-17-010 at 7. Because of its widespread 

adoption, the NPS allows organizations to benchmark themselves against competitors or 

similar companies. Id. Using the NPS metric allows the Postal Service to evaluate its long82 United States Postal Service, Office of the Inspector General, Report No. RARC-WP-17-010, Postal Customer Satisfaction: A Primer of Four 

Surveys, August 28, 2017, at 7, available at https://www.uspsoig.gov/sites/default/files/reports/2023-01/RARC-WP-17-010.pdf (OIG Report 

No. RARC-WP-17-010).

 e e e 

 u ne e e e n e e e 

 u e 3 0 u ne n n 

 

Thin ing a out our overall 

e perience ith the 

 usiness Service Net or , 

ho li el are ou to 

recommend the Postal 

Service to a colleague 

Thin ing a out this visit to the 

Post ce, ho li el are ou to 

recommend the Postal Service to 

a friend or colleague 

Thin ing a out our overall 

e perience ith receiving mail 

and or pac ages delivered 

the Postal Service recentl , ho 

li el are ou to recommend 

the Postal Service to a friend or 

famil mem er residen al 

customers or colleague 

 small medium usiness 

customers 

Thin ing a out the service ou 

received in response to this issue, 

ho li el are ou to recommend 

the Postal Service to a friend, 

famil mem er, or colleague 

Thin ing a out our most 

recent visit or call to this 

 usiness ail ntr nit, ho 

li el are ou to recommend 

the Postal Service to a 

colleague 

Thin ing a out our recent 

e perience ith the 

 e site, ho li el are ou to 

recommend the Postal Service 

to a friend or colleague 

 u e e en e 

Thin ing a out our recent 

e perience ith the contact 

center ive Agent or automated 

s stem Interac ve Voice 

Response , ho li el are ou to 

recommend the Postal Service to a 

friend or colleague 

.com
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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term relationship with customers and benchmark itself against other companies providing 

similar products or services. Id.

(2) Methodology and Results

The NPS question asks customers to rate how likely they are to recommend a company, 

product, or service to a friend or colleague on a scale of 0 (Not at All Likely) to 10 

(Extremely Likely). Qualtricsxm NPS. Depending on their response, customers fall into one 

of three categories:

• Promoters respond with a score of 9 or 10 and are typically loyal and enthusiastic 

customers

• Passives, who respond with a score of 7 or 8, are satisfied with the company, 

service, or product but not happy enough to be considered Promoters

• Detractors, who respond with a score of 0 to 6, are unhappy customers who are 

unlikely to buy from the company again and may even discourage others from 

buying from that company. Id.

The NPS score is calculated by subtracting the percentage of Detractors from the 

percentage of Promoters. Figure III-7 shows the NPS scale, customer segments, and 

formula for calculating the NPS result.

Figure III-7

Net Promoter Score

Scale, Customer Segments, and Formula

Source: Qualtricsxm NPS

Table III-12 shows FY 2022 NPS results and the percentages of Promoters and Detractors 

for each CX survey.

% PROMOTERS - % DETRACTORS = NET PROMOTER SCORE
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Table III-12

FY 2022 Net Promoter Score (NPS) Results

Promoters and Detractors

Customer Experience Survey Percentage of 

Promoters (9-10)a

Percentage of 

Detractors (0-6)a

FY 2022 Net Promoter 

Scoresb

Business Service Network 90.2 2.2 88.0

Point of Sale 81.2 10.9 70.3

Deliveryc 58.2 23.2 35.0

Customer Care Centerc 56.5 30.7 25.7

Customer 360 30.9 58.9 -27.9

Business Mail Entry Unit 92.0 3.1 88.9

usps.com 59.0 25.0 33.9

a The percentages of Promoters and Detractors were calculated by the Commission based on disaggregated CX survey response counts 

provided by the Postal Service.

b Some FY 2022 NPS results do not equal the percentage of Promoters minus the percentage of Detractors due to rounding.

c The NPS results are composite scores derived from results of two more specific surveys. The Delivery NPS is an unweighted composite of the 

residential and small/medium business customer surveys. The CCC NPS is an unweighted composite of the IVR and Live Agent surveys.

Source: Commission calculation using Postal Service survey responses provided in Library Reference USPS-FY22-38, file 

“CX_Question_Response_Counts_FY22.”

Table III-12 shows that in FY 2022, the BSN and BMEU surveys, which measure business 

CX, had the best NPS results (approximately 88.0). The POS survey had the third highest 

NPS score of 70.3. NPS scores for the Delivery, CCC, and usps.com surveys were lower, 

ranging from 35.0 (Delivery) to 25.7 (CCC). Each of the CX surveys had a higher 

percentage of Promoters than Detractors except for the C360 survey, which measures 

satisfaction with issue resolution for customers who file service requests with the Postal 

Service through a CCC live agent or usps.com. See Section B.1.a., supra. Thus, the C360 NPS 

result was the only one expressed as a negative number (-27.9). The C360 survey also had 

the highest percentage of Detractors (58.9), which was more than half of C360 survey 

respondents. Only 30.9 percent of C360 survey respondents were Promoters that were 

highly likely or extremely likely to recommend the Postal Service to a friend, family, or 

colleague.
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Table III-13 compares NPS results for each CX survey between FY 2019 and FY 2022.

Table III-13

Net Promoter Score (NPS) Results, FY 2019–FY 2022

Customer Experience Survey FY 2019 FY 2020 FY 2021 FY 2022

Business Service Network N/A 86.9% 86.2% 88.0%

Point of Sale N/A 62.6% 65.3% 70.3%

Deliverya 39.6 49.5 29.3 35.0

Customer Care Centera -9.7 15.6 10.0 25.7

Customer 360 N/A -23.3% -38.3% -27.9%

Business Mail Entry Unit 81.4% 85.3% 86.6% 88.9%

usps.com 32.4% 33.9% 20.0% 33.9%

N/A: In Docket No. ACR2019, the number of responses received for each survey question did not include responses for the 

NPS question on the following surveys: Business Service Network, Point of Sale, and Customer 360 (formerly called Enterprise 

Customer Care).

a The NPS numbers are composite scores derived from results of two more specific surveys. The Delivery NPS is an 

unweighted composite of the residential and small/medium business customer surveys. The CCC NPS is an unweighted 

composite of the IVR and Live Agent surveys.

Source: Docket No. ACR2019, Library Reference USPS-FY19-38, ecem er 27, 2 19, folder “Preface” file “CX Question 

Response Counts_FY19. ls ” oc et No. ACR2 2 , i rar Reference SPS-FY20-38, ecem er 29, 2 2 , folder “ SPS-FY20-

38” file “CX Question Response Counts_FY2 . ls ” oc et No. ACR2 2 , Responses of the United States Postal Service to 

Questions 1- of Chairman’s Information Request No. 2 , April 1, 2 21, question oc et No. ACR2 21, i rar Reference 

USPS-FY21-38, folders “ SPS-FY21-38” file “CX_Question_Response_Counts_FY21. ls ” i rar Reference USPS-FY22-38, file 

“CX_Question_Response_Counts_FY22.”

Table III-13 shows that between FY 2020 and FY 2022, the BSN survey maintained high 

NPS results (at least 86.2 percent), and the POS and BMEU surveys demonstrated year-toyear improvements. NPS results for the Delivery, CCC, C360, and usps.com surveys 

declined between FY 2020 and FY 2021 but rebounded between FY 2021 and FY 2022. 

The CCC survey showed the most improvement, with a negative NPS result in FY 2019 to 

positive results during the next three consecutive fiscal years (FY 2020-FY 2022). These 

results show that the CCC survey shifted from having a higher percentage of Detractors to 

consistently having a higher percentage of Promoters. The Postal Service could apply 

lessons learned and improvements made to the CCC survey to the C360 survey so that the 

C360 NPS result also reflects a higher percentage of Promoters than Detractors.

The Commission recommends that the Postal Service continue to use the NPS to measure and 

assess CX in FY 2023. The Commission also recommends the Postal Service focus its efforts on 

improving the C360 NPS result to have a higher percentage of Promoters than Detractors 

and continue its efforts to improve NPS results for the other CX surveys.

d. Social Media
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Research by Global WebIndex shows that approximately 60 percent of the world’s 

population use social media, and the average daily usage is 2 hours and 24 minutes as of 

April 2023.83 The Postal Service states that during FY 2022, it continued to use social 

media as an important platform for engaging customers who prefer interacting on social 

media rather than more traditional forms of communication such as email, chat, and 

telephone. FY 2022 ACR at 82. To evaluate customer perceptions and improve CX, the 

Postal Service used social media mainly to conduct social listening and respond to 

customer inquiries, which are each described below.

(1) Social Listening

Background. Social listening is the process of monitoring social media channels for 

mention of a brand, product, service, keyword, or competitors.84 It allows companies to 

know what customers are saying about them and how customers feel about the brand, as 

well as helps companies discover customer pain points and obtain actionable insights to 

help improve CX. See CMSWire Social Listening. During the COVID-19 pandemic, more 

than 50 percent of marketing companies used social listening to obtain information about 

customers. Id.

The Postal Service Social Business Intelligence (SBI) team “uses social listening to obtain 

an idea of the overall conversation about the Postal Service on traditional and social 

media.”85 The SBI team reviews the following platforms: Twitter, Facebook, Instagram, 

news, web, forums, blogs, radio, TV, Reddit, and reviews. Docket No. ACR2021, Response 

to CHIR No. 26, question 2.a. The Postal Service states that social listening helps the Postal 

Service understand “what overarching issues may be concerning to customers, such as 

delivery issues, operational issues, confusion about products or services and issues at the 

local [P]ost [O]ffice . . . .” FY 2022 ACR at 82. The SBI team then took data obtained from 

social listening and compiled and analyzed them to communicate lessons learned across 

the Postal Service to help specific groups solve problems at the root, before they become 

larger and less manageable. Id.

For example, the Postal Service states that in FY 2021, the SBI team identified two main 

customer concerns: (1) the COVID-19 pandemic safety; and (2) applying for a job with the 

Postal Service.86 It notes that it addressed these issues in FY 2021 and FY 2022, and they 

were not major issues in FY 2022. Response to CHIR No. 29, question 5.a. It explains that 

in FY 2022, the major overarching issues customers were concerned about were obtaining 

83 Dave Chaffey, Global social media statistics research summary 2023, Smart Insights, (May 11, 2023), available at 

https://www.smartinsights.com/social-media-marketing/social-media-strategy/new-global-social-media-research/.

84 Scott Clark, What Can Social Listening Do to Improve CX, CMSWire (Oct. 29, 2020), available at https://www.cmswire.com/customerexperience/what-can-social-listening-do-to-improve-cx/ (CMSWire Social Listening).

85 oc et No. ACR2 21, Revised Responses of the nited States Postal Service to Questions 2 and 3 of the Chairman’s Information Request No. 

26—Errata, April 25, 2022, question 2.b. (Docket No. ACR2021, Response to CHIR No. 26).

86 Response to CHIR No. 29, question 5.a. In the FY 2021 Analysis, the Commission discussed examples of situations the Postal Service assessed 

via social listening, including insights gained and actions taken in response. FY 2021 Analysis at 80, Figure III-10.
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COVID-19 tests and traveling. Id. To respond to these concerns, the Postal Service states it 

posted specific content on its social media sites, such as how to apply for a passport. Id.

question 5.b.

The Postal Service explains that in FY 2022, it used Search Engine Optimization findings 

when creating the content on the Postal Service’s social media pages, which attempted to 

anticipate customer concerns. Id. It points out that unlike in previous years, the Postal 

Service monitored questions about Operation Santa on its social media platforms instead 

of focusing on general education about Operation Santa at Post Offices across the country. 

Id. It states that monitoring Operation Santa questions on social media “informed 

operations of customer service hotspots where operations would perform targeted 

outreach.” Id.

Social media heat map. In 2019, the SBI team created a heat map to use information from 

social media to evaluate postal customer service.87 The social media heat map uses 

Tableau, a data visualization program, to geographically display comments left on the 

Postal Service’s official Facebook and Twitter accounts and from online review websites. 

Social Media Heat Map at 17. The heat map covers all domestic addresses served by the 

Postal Service and categorizes information by customer concern, which can be viewed by 

Area, District, and ZIP Code.88 The Postal Service states it used social media tags to identify 

certain categories of customer concern, which are shown in Figure III-8.

Figure III-8

Social Media Heat Map

Categories of Customer Concern

Source: Response to CHIR No. 14, question 3.b.

87 United States Postal Service, Temperature check: Social media used to gauge customer service, USPS News Link (Oct. 27, 2022); available at 

https://link.usps.com/2022/10/27/temperature-check/ (Social Media Heat Map).

88 Id. The Postal Service filed an image of the heat map under seal. Response to CHIR No. 14, question 1. It states that it considers the social 

media heat map proprietary and is currently available only to select Postal Service employees who have been granted access to it. Id.
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Field managers may use data from the heat map as a CX metric to identify patterns and 

make operational improvements. See Social Media Heat Map. The Postal Service provides 

examples of how it has used the social media heat map to improve CX in a CHIR response. 

Response to CHIR No. 14, question 2. First, the heat map has identified geographic areas in 

which Postal Service employees unaware of Operation Santa appear to be concentrated. Id.

Second, the heat map tracked customer concerns during the aftermath of natural 

disasters, which led the Postal Service to report the hours and availability of Post Offices in 

affected areas via usps.com and social media. Id. Third, the heat map identified hot spots of 

concern regarding the COVID-19 pandemic, while allowing the Postal Service to better 

equip Post Offices in the area with hand sanitizer and protective masks. Id.

The Postal Service states that it used the social media heat map to help the former South 

Florida District target trouble spots between 2019 and 2020. Id. question 4. Specifically, it 

explains that the heat map showed that South Florida had the highest volume of customer 

concerns expressed on social media. Id. It notes that of the top 10 ZIP Codes in the 

Southern Area with the most customer concerns, 8 of these ZIP Codes were in South 

Florida. Id. Based on this review, the Postal Service responded by holding in-person 

meetings at eight locations in South Florida and sharing the heat map results with local 

teams. Id. It concluded that these communications help increase awareness of CX issues 

and achieved the following results in the former South Florida District:

• A 31 percent reduction in “Where is My Package?” complaints

• A 51 percent reduction in Certified Mail exceptions

• An 85 percent drop in “Where is My Mail” concerns89

Another advantage of the social media heat map cited by the Postal Service is real-time 

feedback for employees. Figure III-9 shows three examples of customer feedback the 

Postal Service shared with employees in the 85301 ZIP Code shortly after customers left 

these comments. Response to CHIR No. 14, question 5.a. The Postal Services states that it 

sends all comment reviews from social media to select customer service and relations 

specialists in the applicable Area or District on a regular basis. Id. question 5.b.

89 See Social Media Heat Map.
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Figure III-9

Social Media Heat Map

Examples of Customer Feedback

Id. question 5.a.

The Postal Service explains that the social media heat map is being refined, has yet to be 

expanded nationwide or implemented systematically, and potential applications to CX are 

still being explored. Id. question 6.b-c. It states that preliminary results show that some 

benefits of the heat map include information sharing for both customers and Postal 

Service employees, as well as an enhanced ability to process and act upon feedback. Id.

The Postal Service notes that there are currently no plans to change the data or design of 

the heat map in FY 2023, but it is exploring how to implement the social media heat map 

on a wider scale. Id. question 7.

The Postal Service currently evaluates CX by mainly using customer surveys. Although 

surveys can be useful to gauge customer perceptions, some customers may not wish to 

communicate through these mechanisms. By listening and communicating through social 

media, the Postal Service may reach and engage more customers, including those who are 

most and least dissatisfied.

So beyond frustrated with this place. This problem has occurred multiple times. 

 pac ages aren’t eing delivered hen m comple has loc ers for larger pac ages 

 hich the aren’t utilizing. Then the send them ac here hich isn’t e actl close to me 

but the nearest post office assigned. I had set up a redelivery and even had an email 

confirmation and never got delivered. So no I’m forced to go clear up here to pic up m 

daughter’s pac age that should have een redelivered. ut it should have een delivered 

the first time as there were plenty of lockers available to place my package in. 

Extremely irritating!

WOW! I used to dread going to the post office, but now coming here is one of the 

highlights of my day. This seemingly ordinary little post office is fast-paced, full of 

knowledgeable staff, and just all-around really good people. If you need help with 

anything post-related, the people at the downtown Glendale PO are there to walk you 

through it. I had no idea how many affordable, or even free services they provide (like 

the Informed Delivery app, free package pickups at your home, free re-delivery on 

missed packages, etc.). The clerks, letter carriers, and supervisors at the downtown 

Glendale PO have taught me everything I know about all things mail; they're the BEST!

I did have good experience here. They gave me my lost keys earlier than 

the expected time. Also saved my mails and packages safely. They are 

professionals and nice and patient on [customers].
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The Commission finds that the Postal Service is effectively using social listening to determine 

what people are saying about its brand and services on social media. The social media heat 

map is an effective tool for visualizing customer comments and categorizing them by concern 

and geographic area. The Commission recommends that the Postal Service continue to use 

social listening and the social media heat map to improve CX in FY 2023.

(2) Responding to Customer Inquiries

Background. The Postal Service responds to customer inquiries and concerns primarily on 

two social media platforms: Twitter and Facebook. Docket No. ACR2021, Response to 

CHIR No. 26, question 3.a. Customers may contact the Postal Service via its corporate 

@USPS Facebook page, as well as @USPS or @USPSHelp on Twitter. Id. The Social 

Customer Response (SCR) team addresses Facebook and Twitter customer inquiries 

directly with the customer from inception to completion. FY 2022 ACR at 82. The Postal 

Service explains that to address customer issues and inquiries, SCR associates contacted 

local Post Office supervisors, managers, postmasters, District Managers, District Marketing 

Managers, and Consumer and Industry Contact Managers. Id. It states that SCR associates 

recognized in-the-moment patterns to inform postal operations both locally and 

nationally. Id. Their primary goals were to offer customers convenience, to help educate 

them about the Postal Service’s products and services, and to enhance their experience by 

interacting with customers on the social media platform of their choosing. Id. at 82-83.

Figure III-10 shows the reported number of inquiries the SCR team received, responded 

to, and resolved, as well as the average length of time for responding to customer 

inquiries.
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Figure III-10

Social Customer Response Team

FY 2022 Reported Inquiries and Responses

Source: FY 2022 ACR at 82-83; Response to CHIR No. 29, question 6.c. The Postal Service explains that customers who request assistance post 

a message on Twitter or Facebook. Docket No. ACR2021, Responses of the United States Postal Service to Questions 1-11 of Chairman’s 

Information Request CHIR No. 29, April 25, 2022, question 5 (Docket No. ACR2021, Response to CHIR No. 29). Each message is considered a 

single post. Docket No. ACR2021, Response to CHIR No. 29, question 5. Customer interaction with the SCR team consists of several posts. Id.

This interaction is considered a single conversation or case. Id.

The Postal Service states that in FY 2022, the most common customer inquiry the SCR 

team addressed stemmed from item delivery and/or tracking issues. Response to CHIR 

No. 29, question 6.a. Based on the information provided by the customer, an SCR associate 

would reach out to the customer’s local Post Office, including the station manager or 

Postmasters, to confirm the status of the customer’s item in the delivery network. Id.

question 6.b. After receiving this updated information, the SCR associate would message 

the customer about the status of the item. Id. Customers could follow up with the Postal 

Service and ask for other information or status updates as necessary. Id.

Customers who submit a question, concern, or inquiry via Twitter receive a customer 

survey after the situation is closed or resolved. Docket No. ACR2021, Response to CHIR 

No. 29, question 6.a. The question asks the customer “How satisfied are you with the level 

of customer service provided by our Social Customer Response Associate?” Id. In FY 2022, 

the SCR team achieved a customer satisfaction score of 3.2 out of 5 with a 42 percent 

survey completion rate.90 Due to Facebook’s internal algorithms, the Postal Service is 

90 FY 2022 ACR at 83; see Response to CHIR No. 29, question 7.
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unable to send a customer satisfaction survey to customers who submit inquiries or issues 

via Facebook and interact with an SCR associate. Response to CHIR No. 29, question 8. 

However, it does send surveys to customers who use the Facebook ChatBOT tool, which is 

described below.

Facebook ChatBOT. To address the large number of customers who contact the Postal 

Service for help, the Postal Service developed and implemented an artificial intelligence 

(AI) ChatBOT on its Facebook Messenger platform. FY 2022 ACR at 83. The interactive 

ChatBOT uses natural learning to assist the Postal Service’s self-help customers by offering 

hyperlinks directly to self-help tools and Frequently Asked Questions on the Postal 

Service’s website. Id. To improve the ChatBOT’s functionality, the Postal Service 

implemented a Spanish language translator to allow customers to continue their 

conversation in Spanish. Id. When interacting with the ChatBOT, customers have the 

option of being transferred to an SCR associate at any time. Response to CHIR No. 19, 

question 4.b.

In FY 2022, the ChatBOT responded to more than 90,440 conversations and resolved more 

than 44,915 customer needs without live agent interaction for basic tasks such as package 

tracking number lookup and stamp prices. FY 2022 ACR at 83. After interacting with the 

ChatBOT, customers were asked if the information they received was helpful. Response to 

CHIR No. 19, question 4.a. Those who answer affirmatively have their issue marked as 

resolved. Id. Customers who indicate that the ChatBOT was not helpful are directed to an 

SCR associate. Id. question 4.b. Based on this process, in FY 2022, 89,181 customers were 

transferred to the SCR team for follow up. Id. Of these customers, the SCR team reviewed 

70,023 customer matters within 48 hours and closed the case. Id. Due to the availability of 

SCR associates, the remaining 19,158 customer matters were not addressed within 48 

hours and were removed from the system. Id. The Postal Service asserts that “[a]ttempting 

to address customer matters after 48 hours is not an efficient practice given that 

customers may have already resolved their concerns or have sought alternative resolution 

options.” Id.

To evaluate customer satisfaction with the Facebook ChatBOT, the Postal Service sends a 

survey to customers after they indicate that the ChatBOT was helpful. Id. question 3.a. The 

survey question asks customers, “How would you rate your service experience with 

USPS?” Id. question 3.b.i. The customer then selects an option ranging from 1 (Very 

Dissatisfied) to 5 (Very Satisfied). Id. The Postal Service states that in FY 2022, the Postal 

Service initiated 22,712 Facebook ChatBOT surveys and received 10,486 surveys in 

response. Id. question 3.b.ii.(2)-(3). In FY 2022, the average customer satisfaction score 

was 2.9 out of 5.0, with a response rate of 46 percent. Id. question 3.b.ii.(4)-(5). Figure III11 shows the breakdown of customer responses to the Facebook ChatBOT customer 

satisfaction survey in FY 2022.
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Figure III-11

Facebook ChatBOT

FY 2022 Customer Satisfaction Survey Responsesa

a The time period shows the breakdown of customer responses from October 25, 2021 through September 30, 2022.

Source: Response to CHIR No. 27, question 2.

The Postal Service asserts that the Facebook ChatBOT has improved its ability to address 

needs and concerns of self-help customers, which it was unable to do previously due to 

limited resources. Response to CHIR No. 19, question 4.d. It states that the ChatBOT may 

promptly address simple customer issues and allow SCR associates to resolve more 

complex concerns, which may have positively impacted customer satisfaction and 

improved CX overall. Id. Regarding lessons learned from the ChatBOT, the Postal Service

notes that the ChatBOT may be a valuable customer service resolution tool. Id. question 

4.e. It states that it continues to improve the ChatBOT by using Natural Language 

Processing and integrating more information about customers’ evolving needs and 

concerns, which should improve the Postal Service’s ability to effectively resolve customer 

concerns in FY 2023. Id.

Other Artificial Intelligence Tools. Besides the Facebook ChatBOT, the Postal Service used 

the Artificial Intelligence Virtual Agent (AIVA) application as a tool to improve CX in 

FY 2022. Id. question 5. The AIVA is a voice application that interprets and understands 

customer inquiries using Natural Language Processing to provide scripted responses and 

execute requests based on specified business rules. Id. The Postal Service describes 

enhancements made to the AIVA in FY 2022, including the ability to track packages and 

0K

2K

4K

6K

Very Dissatisfied (1) Somewhat Dissatisfied (2) Indifferent (3) Somewhat Satisfied (4) Very Satisfied (5)

Number of Customer Responses

Survey Score
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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provide customers with an updated status, analyze that status and provide customers with 

next steps, and optionally enroll customers in proactive tracking text message 

notifications. Id.

In FY 2022, the AIVA application handled a total of 1,399,203 customer calls, with 871,947 

calls ending without live agent involvement. Id. questions 6.a.-b. The AIVA overall 

satisfaction score was 59.12 percent.91 The Postal Service states that the key takeaway 

from the AIVA expansion was the importance of the interaction with the caller, which 

should not only sound human, but also properly process free-form feedback and follow-up 

questions. Id. question 6.d. It states it is exploring ways to analyze the AIVA application’s 

current conversations and develop improvements. Id.

The Postal Service states it is investigating three major AIVA enhancements that may be 

implemented in FY 2023, including the ability to:

• Open a customer support service request when a customer asks for a live agent

• Proactively notify a customer when a package status with an open case is updated

• Create a testing platform to allow the Postal Service to test new conversations with 

a small subset of customers before general deployment92

The Commission acknowledges the SCR team’s efforts in FY 2022 to respond to a large 

number of customer inquiries considering the small size of the team. However, it is 

concerned about the average length of time for responding to customer inquiries, which 

was approximately 5 hours and 7 minutes in FY 2022. Response to CHIR No. 29, question 

6.c.v. The response time increased significantly compared to FY 2021, which was 3 hours 

and 54 minutes. See Docket No. ACR2021, Response to CHIR No. 26, question 3.c. 

According to a recent study, approximately 37 percent of customers who submit a 

question or complaint via social media expect a response within 30 minutes, and 

approximately 26 percent of customers expect a response within 4 hours.93 All other 

things being equal, using the Facebook ChatBOT, AIVA, and other AI tools could help field 

routine issues and decrease the response time for customer inquiries, which would 

improve overall CX.

The Commission commends the Postal Service for continuing to expand its efforts to respond 

to customer inquiries via social media. The Commission encourages the Postal Service to 

continue using the Facebook ChatBOT, AIVA, and other AI tools to continue helping 

customers and to improve the response time for customer inquiries.

91 Id. question 6.c. AIVA scores are separated from customer responses to the CCC IVR System survey. Id.

92 Id. question 7.

93 How to integrate social media into your CX program, available at https://www.qualtrics.com/uk/experience-management/customer/socialmedia-and-cx/ (Qualtricsxm Social Media).
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C. Safe Workplace and Engaged Workforce

1. Background

In FY 2022, the Postal Service used two performance indicators to evaluate progress 

toward the Safe Workplace and Engaged Workforce performance goal. The Total Accident 

Rate measures progress toward improving employee safety. The Grand Mean Engagement 

Score assesses overall engagement levels of survey respondents. Each metric is described 

below.

a. Total Accident Rate

In FY 2022, the Postal Service continued to use the Total Accident Rate as a performance 

indicator to measure progress toward improving employee safety. FY 2022 Annual Report

at 41. The Total Accident Rate is calculated by multiplying the total number of accidents 

during the year by 200,000, which is the average number of annual workhours per 

employee (2,000) multiplied by 100 to standardize accident rates. Id. This number is then 

divided by the annual number of exposure hours. Id. The Total Accident Rate formula is:

Total Number of Accidents x 200,000

Exposure Hours

Id.

The Total Accident Rate result yields an annual accident frequency per 100 employees. A 

lower result is a better outcome. The Total Accident Rate uses the same formula as the 

Occupational Safety and Health Administration Illness and Injury Rate (OSHA I&I Rate), 

which the Postal Service used as its employee safety performance indicator until FY 2016. 

Id. at 41-42. Unlike the OSHA I&I Rate, the Total Accident Rate includes accidents that do 

not result in medical expenses, days away from work, or restrictions from performing full 

work duties.94

The FY 2022 Total Accident Rate result was 12.39, which was better than the FY 2022 

target of 13.45. FY 2022 Annual Report at 42. The Postal Service reports that between 

FY 2021 and FY 2022, the number of recordable, non-recordable, and motor vehicle 

94 Id. The Total Accident Rate also includes accidents that result in only property damage, as well as all motor vehicle accidents. Docket 

No. ACR2016, Responses of the United States Postal Service to Questions 1- and 7 of Chairman’s Information Request No. 27, arch 1 , 

2017, questions 4.a., b. Specifically, the Total Accident Rate includes: accidents that resulted in damage of $500 or more to Postal Service 

property regardless of whether an injury was involved; motor vehicle accidents that result in death, injury, or only property damage, 

regardless of cost, who was injured (if anyone), or what property was damaged; and injury, illness, or death of a Postal Service employee on 

Postal Service premises or on the job. Id. The Total Accident Rate excludes other accidents that do not involve Postal Service employees; 

damage of $500 or more to customer property without injury, unless such damage involves a motor vehicle accident; and fire damage of $100 

or more without injury, unless such damage involves a motor vehicle accident. Id.
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accidents decreased.95 The largest decrease was for non-recordable accidents, which 

declined by 14.58 percent. FY 2022 Annual Report at 42.

The Postal Service explains it was able to meet the FY 2022 Total Accident Rate target for 

three main reasons. First, it continued the Safety Intervention and Recognition program 

that tracks District-level performance monthly. Id. Second, it added new visualizations and 

data analytical tools, which “provided immediate access to data and allowed each 

manager/supervisor insight into the accident trends in their facilities.” Id. Third, the Postal 

Service continued to enhance the Safety and Health Management Tool (SHMT) to provide 

field leadership with regular reporting and trend analysis information. Id. Tools and 

programs that helped the Postal Service improve employee safety in FY 2022 are 

discussed in more detail below. See Section C.3.a., infra.

The FY 2023 Total Accident Rate target is 13.25, which is lower and therefore more 

difficult to meet than the FY 2022 target of 13.45. See FY 2022 Annual Report at 42. The 

Postal Service explains that it will meet this target by continuing proactive safety and 

prevention efforts designed to address the most frequent workplace hazards, such as dog 

bites, extreme weather events, distracted driving, and slip, trip, and fall injuries. Id. It 

states it will target at-risk groups and continue to enhance the Occupational Safety and 

Health (OSH) Scorecard and SHMT to provide increased visibility into accident prevention 

opportunities. Id. Plans for meeting the FY 2023 target are discussed in more detail below. 

See Section C.3.a., infra.

b. Grand Mean Engagement Score

Each year, the Postal Service administers the Postal Pulse survey to all employees to 

measure the level of engagement at the Postal Service. FY 2022 Annual Report at 43. The 

Postal Pulse survey was developed by Gallup, Inc., which contracts with the Postal Service 

to measure employee engagement.96 Figure III-12 is a copy of the FY 2022 Postal Pulse 

survey.

95 Id. “Recorda le” accidents are those that result in medical treatment (beyond first aid), days away from work, restrictions or transfer to 

another job, death, or loss of consciousness. Recordable accidents must be reported to OSHA. See FY 2016 Analysis at 50 n.66.

96 See Gallup, Inc., Gallup Q12 and Employee Engagement FAQs: Frequently Asked Questions About Employee Engagement and the 

Engagement Survey, at 1-2, available at https://liteblue.usps.gov/emp-engagement/pdf/Employee-Engagement-FAQs.pdf (Gallup FAQ).
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Figure III-12

FY 2022 Postal Pulse Survey

Source: Response to CHIR No. 2 , question 8.a., file “postal pulse_surve _2 22.”
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As shown in Figure III-12, the Postal Pulse survey asks participants to rate their level of 

agreement with 16 statements concerning their work environment on a scale of 1 to 5, 

with higher numbers reflecting either a greater level of employee satisfaction or stronger 

agreement with a survey statement. Question 0 asks employees to rate their level of 

satisfaction with the Postal Service as a place to work. Questions 1 through 12 are the 

foundational elements of employee engagement that measure the core elements needed to 

attract, focus, and retain the most talented employees. Gallup FAQ at 2. Engaged 

employees are “involved in, enthusiastic about and committed to their work and 

contribute to their organization in a positive manner.”97 Question 13 was added to the 

Postal Pulse survey in FY 2020 to ask employees to rate their level of agreement with the 

statement, “[m]y immediate supervisor has recently spent one-on-one time with me to 

discuss my workplace needs.” FY 2020 Annual Report at 43; see FY 2021 Analysis at 87.

The Postal Pulse survey was administered from June 14, 2022 through July 15, 2022. 

FY 2022 Annual Report at 43. Non-bargaining employees received the survey link via 

Postal email when the survey began and continued receiving links to the survey until they 

responded or July 15, 2022, when the Postal Pulse survey closed. Id. The survey was 

administered to bargaining-unit employees via a paper survey distributed at the work 

unit, a paper survey mailed to the employee’s home address, and via postal email (if 

available). Id. All employees were invited to respond to the survey on-the-clock and were 

encouraged to complete the survey through other channels, such as email, scanner alerts, 

stand-up talks, and internal employee communications. Id.

In FY 2022, the Postal Service made two major changes to the Postal Pulse survey. First it 

added two new questions asking employees whether they would recommend the Postal 

Service as a great place to work and whether they would recommend postal products and 

services to friends and family. See Figure III-12, supra. These questions are similar to those 

asked on the Net Promoter Score survey, which measures customer experience.98 Second, 

the Postal Service removed the direct response comment box that was included in prior 

surveys. It explains that employees have other, more direct means of providing feedback, 

such as directly reporting positive changes to their supervisors, which facilitate timely 

employee engagement. Response to CHIR No. 26, question 9.b.

The Postal Service measures employee engagement using the Grand Mean Engagement 

Score and the Engagement Survey Response Rate. The Grand Mean Engagement Score 

assesses overall engagement levels of survey respondents, while the Engagement Survey 

Response Rate shows the level of participation among the entire employee population. 

FY 2022 Annual Report at 42. Between FY 2018 and FY 2021, the Postal Service used the 

Engagement Survey Response Rate as one of the performance indicators for measuring 

progress toward the Safe Workplace and Engaged Workforce performance goal. In 

97 United States Postal Service, Brief Guide to the 12 Elements of Engagement, at 1, available at https://liteblue.usps.gov/empengagement/pdf/Brief-Engagement-Guide.pdf.

98 The Net Promoter Score is discussed in Chapter III, Section B.3.c., supra.
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FY 2022, the Postal Service changed the performance indicator for measuring an engaged 

workforce from the Engagement Survey Response Rate to the Grand Mean Engagement 

Score, which is derived from the average scores of Questions 1-12 on the Postal Pulse 

Survey and expressed as a number between 1 and 5. The Postal Service explains that it 

made this change because “[a]nalysis of postal data has shown that grand mean 

engagement scores correlate significantly with a variety of key performance metrics, such 

as improved productivity, improved customer satisfaction, and reduced leave usage, 

accidents, and injuries.” FY 2021 Annual Report at 44. The Grand Mean Engagement Score 

and Engagement Survey Response Rate are described in more detail below. See Section 

C.3.b.(1) and (2), infra.

The FY 2022 Grand Mean Engagement Score was 3.31, which was slightly lower than both 

the FY 2022 target of 3.38 and the FY 2021 result of 3.36. FY 2022 Annual Report at 43. The 

FY 2022 Engagement Survey Response Rate was 25 percent, which was the same as 

FY 2021. Id. The Postal Service explains that changes in the United States workforce since 

the COVID-19 pandemic have contributed to the decline in employee engagement in 

FY 2022. Id. This explanation is discussed in more detail below. See Section C.3.b.(1)., infra.

The FY 2023 target for the Grand Mean Engagement Score is 3.33.99 The Postal Service 

states that it plans to meet this target by implementing new programs initiated under the 

10-Year Strategic Plan that focus on two major employee groups: front-line supervisors 

and newly hired pre-career employees. Id. Plans for improving employee engagement are 

discussed below. See Section C.3.b., infra.

2. Comments

Regarding a safe workplace, the Public Representative commends the Postal Service for 

exceeding the Total Accident Rate target by more than one full point and encourages it “to

continue implementing and refining its safety programs and data visualization tools, 

which appear to have been effective” in promoting a safe workplace. PR Comments at 16. 

However, he expresses concern that the FY 2023 Total Accident Rate target of 13.25 “may 

not be sufficiently ambitious” because it is more than the Total Accident Rate results in 

FY 2022 (12.39) and FY 2020 (13.09). Id. at 17. He also recommends that the Postal 

Service develop and implement tools to monitor the safety and performance of contractoroperated motor vehicles, as well as review its contracting practices to ensure that 

contractors comply with applicable laws and regulations. Id. at 16.

In its reply comments, the Postal Service responds that the FY 2023 Total Accident Rate 

target reflects new developments in FY 2023 that may increase the potential for accidents. 

Postal Service Reply Comments at 5. These developments include network modernization 

efforts that may affect employee work habits; moving operations previously performed by 

99 Id. Because the Engagement Survey Response Rate is not a performance indicator for the Safe Workplace and Engaged Workforce 

performance goal, no target was set for FY 2023.
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contractors in-house; and introducing new employees, carrier routes, reconfigured 

facilities, and work poses. Id. The Postal Service notes that despite the potential increase in 

accidents, the FY 2023 Total Accident Rate target is more ambitious than FY 2022. Id. The 

Postal Service also describes efforts to improve the safety and performance of contractoroperated motor vehicles, which are discussed in Section C.3.a.(2), infra.

Regarding an engaged workforce, the Public Representative comments that similar to 

other workplaces in the United States, the Postal Service workplace environment may 

have been negatively impacted by increased employee dissatisfaction and disengagement. 

PR Comments at 18. However, he asserts that “the Postal Service does not analyze reasons 

for employee disengagement that may be specific to the Postal Service, as opposed to the 

general population.” Id. He states that the Postal Service does not indicate whether any 

question or category of questions disproportionately contributed to the decreased Grand 

Mean Engagement Score, which makes it difficult to craft specific solutions to combat 

employee disengagement. Id. Because the Grand Mean Engagement Score rebounded to 

pre-pandemic levels in FY 2021 but decreased in FY 2022, the Public Representative 

questions whether the decline can reasonably be attributed to disengagement in the wake 

of the COVID-19 pandemic. Id. at 18-19.

The Public Representative agrees that the FY 2023 Grand Mean Engagement Score target 

of 3.33 is appropriate. Id. at 19. He encourages the Postal Service to continue pursuing 

initiatives for hiring, training, and retaining employees to promote an engaged workforce. 

Id. He expresses concern that the Engagement Survey Response Rate did not improve in 

FY 2022 and urges the Postal Service to increase communications with employees and 

their managers. Id. at 19-20.

The Postal Service responds that the Public Representative’s portrayal of the Postal Pulse 

survey and how it is used is incomplete. Postal Service Reply Comments at 9. It asserts 

that a “one-size-fits-all” approach for diagnosing and addressing employee engagement 

concerns is not appropriate for an organization as large as the Postal Service. Id. It 

maintains that the broader trends described in the FY 2022 Report account, in large part, 

for the overall decrease in employee engagement, which the Postal Service did not 

experience before the COVID-19 pandemic. Id. at 9-10. It concludes that the national 

initiatives described in the FY 2023 Plan, combined with efforts to address engagement 

issues at the local level, creates a comprehensive approach to improving employee 

engagement in FY 2023. Id. at 10.

3. Commission Analysis

In FY 2022, the Postal Service exceeded the Total Accident Rate target but missed the 

Grand Mean Engagement Score target. See FY 2022 Annual Report at 33.

The Commission finds that the Postal Service partially met the Safe Workplace and Engaged 

Workforce performance goal in FY 2022.
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In the sections below, the Commission examines issues related to workplace safety and an 

engaged workforce. The Commission makes observations and recommendations for 

improving performance in future years.

a. Safe Workplace

With regard to workplace safety, the Commission discusses the Total Accident Rate 

performance indicator and explores issues related to motor vehicle accidents.

(1) Total Accident Rate

The Total Accident Rate measures workplace safety, and the result is the annual accident 

frequency per 100 employees. A lower result is a better outcome. Figure III-13 shows 

Total Accident Rate results from FY 2019 through FY 2022.

Figure III-13

Total Accident Rate Results

FY 2019-FY 2022

Source: FY 2022 Annual Report at 33. The Total Accident Rate results provided in CHIR responses differ from 

the numbers reported in the Annual Report to Congress because these numbers are obtained from a dynamic 

database that reflect coding changes or additional claims submitted after the end of the fiscal year. FY 2021 

Annual Report at 43 n.2.

FY 2022 was the fourth year in a row that the Postal Service met the Total Accident Rate 

target. As Figure III-13 shows, the Total Accident Rate improved between FY 2019 and 

FY 2020, increased slightly in FY 2021, and improved to 12.39 in FY 2022, which was the 

best Total Accident Rate result since the Postal Service began using this performance 

indicator in FY 2017. See FY 2020 Analysis at 85, 90. In FY 2022, the Postal Service used 

data analysis tools related to workplace safety that “provided immediate access to data 

14.19

13.09

13.48

12.39

12

12.5

13

13.5

14

14.5

15

15.5

16

FY 2019 FY 2020 FY 2021 FY 2022

Number of Accidents Per 100 Employees

Year
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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and allowed each management/supervisor insight into the accident trends in their 

facilities[,]”100 which are shown in Figure III-14.

Figure III-14

Workplace Safety Data Analysis Tools

Used in FY 2022

Source: Response to CHIR No. 26, question 4.a.; Docket No. ACR2021, Responses of the United States Postal Service to Questions 1-15 of 

Chairman’s Information Request No. 2 , March 25, 2022, question 6.a. (Docket No. ACR2021, Response to CHIR No. 25).

The Postal Service combines all data from these tools related to accidents, workers’ 

compensation, and employee availability into a single OSH Scorecard, which allows it to 

visualize the complete impact of an accident and/or injury. Docket No. ACR2021, 

Response to CHIR No. 25, question 6.b. This scorecard “allows field leadership to track the 

costs and impacts of each accident and documents efforts to return injured workers to 

suitable employment as early as possible.” FY 2021 Annual Report at 43. Data on total 

accident reduction, disability compensation reduction, and returning employees to work 

are “drillable down to the facility level and can be exported or enlarged as needed for 

more detailed discussions regarding performance.” Id. question 8.b. The OSH Scorecard 

color codes each metric to identify those locations that are meeting targets and those that 

are not. Id.

The Postal Service explains that it met the FY 2022 Total Accident Rate target by 

“continuing the Safety Intervention and Recognition program that tracked 

[D]istrict/[D]ivision level performance each month.” FY 2022 Annual Report at 42. This 

program targets for intervention those Districts and Divisions that have high accident 

100 FY 2022 Annual Report at 42; Response to CHIR No. 26, question 4.a.

 

 

 

 J 

 

 

 

 

 

 

Trac s accidents, hazards, 

inspec on results, and 

accident inves ga ons

Trac s or ers 

compensa on data 

supplied to and the 

 nited States epartment 

of a or, ce of 

 or ers Compensa on 

Programs

Trac s accident data from 

prior ears and supplies 

e posure hour 

informa on used in 

calcula ng the Total 

Accident Rate

 etailed scorecard that 

trac s organiza onal 

performance for the Total 

Accident Rate NPA target
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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rates or show a trend toward an increasing Total Accident Rate.101 Each month, the Postal 

Service analyzed data from the OSH Scorecard to identify any District or Division not 

meeting minimum standards for performance. Response to CHIR No. 26, question 3.b. That 

District or Division is then required to implement an action plan designed to get 

performance back on track by the end of the year. Id. The Safety Intervention and 

Recognition program allows the Postal Service to identify trends of rising accident rates 

each month and allow Districts and Divisions not meeting minimum safety standards to 

analyze methods for improving workplace safety. Id.

The FY 2023 Total Accident Rate target is 13.25, which is lower and therefore a more 

difficult target to meet compared to the FY 2022 target of 13.45. See FY 2022 Annual 

Report at 33. To help meet the FY 2023 target, the Postal Service states it will continue to 

enhance the OSH Scorecard and the SHMT “to meet the needs of [its] operational partners 

to provide increased visibility into accident prevention opportunities.” Id. at 42. It explains 

that the OSH Scorecard will permit field users to easily identify trends and opportunities 

to improve workplace safety without having to sort through complex spreadsheet data. 

Response to CHIR No. 26, question 5.b. It states that the SHMT will allow users to identify 

and eliminate hazards, record accident details, document inspection findings, establish 

action plans to prevent accidents, and perform root cause analysis. Id.

The Public Representative comments that the Total Accident Rate target of 13.25 may not 

be sufficiently ambitious because it is higher than Total Accident Rate results from 

FY 2022 (12.39) and FY 2020 (13.09). PR Comments at 17. He asserts that achieving the 

target of 13.25 in FY 2023 “would not seem to be a noteworthy accomplishment” because 

the Postal Service has demonstrated its ability to achieve a considerably better Total 

Accident Rate result. Id. The Postal Service responds that the FY 2023 target reflects 

several changes that may increase the potential for accidents. Postal Service Reply 

Comments at 5. First, it notes that initial efforts to modernize the network may impact the 

work habits of a large number of employees. Id. Second, it explains that it plans to have 

employees conduct certain operations previously performed by contractors. Third, it 

states that introducing new employees, carrier routes, reconfigured facilities, and types of 

work poses could, in the short term, increase the potential for accidents. Id. However, it 

maintains that despite the increased potential for accidents, the FY 2023 Total Accident 

Rate target is more ambitious than the FY 2022 target. Id.

The Commission commends the Postal Service for meeting the Total Accident Rate target for 

the fourth year in a row and achieving the best result since the Postal Service began using 

the Total Accident Rate as a performance indicator in FY 2017. The Postal Service’s 

continued use of workplace safety data analysis tools and the Safety Intervention and 

101 FY 2020 Annual Report at 41. Specifically, intervention applies when any of the following occur: (1) any District exceeds a Total Accident 

Rate of 6; (2) any Division exceeds a Total Accident Rate of 11; or (3) any District or Division shows a 3 percent or greater increase in the 

num er of injured emplo ees receiving or ers’ compensation disa ilit compensation pa ments compared to the same period last year. 

Docket No. ACR2021, Response to CHIR No. 25, question 4.b.
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Recognition Program appear to have been effective in promoting a safe workplace in 

FY 2022 because the number of accidents decreased for each accident type.

The Commission finds that the FY 2023 Total Accident Rate target is reasonable considering 

the changes in FY 2023 that could increase the potential for safety incidents. The Postal 

Service’s plans to continue using the OSH Scorecard and SHMT in FY 2023 appear designed 

to improve employee safety and the Total Accident Rate. The Commission recommends that 

in the FY 2023 Report, the Postal Service describe efforts to promote a safe workplace in 

FY 2023 and plans to improve employee safety in FY 2024.

(2) Motor Vehicle Accidents

The Total Accident Rate includes motor vehicle accidents. Figure III-15 shows the number 

of motor vehicle accidents and the total number of accidents from FY 2019 through 

FY 2022.

Figure III-15

Total Accidents and Motor Vehicle Accidents

FY 2019-FY 2022

Source: Response to CHIR No. 26, question 2. The total number of accidents and number of motor vehicle accidents 

provided in CHIR responses differ from the numbers reported in the Annual Report to Congress because these 

numbers are obtained from a dynamic database that reflect coding changes or additional claims submitted after the 

end of the fiscal year. See FY 2021 Annual Report at 43 n.2.

As Figure III-15 shows, motor vehicle accidents represented 38.48 percent of the total 

number of accidents in FY 2022. The number of motor vehicle accidents decreased 

between FY 2019 and FY 2020 but increased slightly in FY 2021 and FY 2022. Motor 

vehicle accidents have been slowly increasing since their lowest numbers in FY 2020, but 

FY 2019 FY 2020 FY 2021 FY 2022

Motor Vehicle Accidents 28,933 26,210 27,800 27,984

Total Accidents 90,316 82,564 85,124 72,732

0

20,000

40,000

60,000

80,000

100,000

Number of Accidents
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still remain lower than pre-pandemic levels. The increase in the percentage of motor

vehicle accidents relative to total accidents is due to fewer total accidents in FY 2022.

During FY 2022, the Postal Service began issuing Area and Regional Updates, which are 

quarterly newsletters for employees that describe updates for Retail and Delivery 

Operations Areas and Districts as well as Logistics and Processing Operations Regions and 

Divisions.102 The Commission observes that these updates promote safe driving by 

recognizing management and employees’ commitment to motor vehicle safety.103

The Public Representative takes note of a news report on safety issues regarding motor 

vehicles contracted to transport mail for the Postal Service.104 The number of motor 

vehicle accidents reported in the Total Accident Rate does not include accidents related to 

motor vehicles driven by independent contractors to transport mail for the Postal Service. 

Response to CHIR No. 18, question 1. The Postal Service clarifies that accidents related to 

motor vehicles driven by independent contractors are not part of the Safe Workplace and 

Engaged Workforce performance goal because that goal concerns Postal Service 

employees and not third parties. Id. question 1.a. It explains that independent contractors 

retained by the Postal Service are responsible for the safety of their operations. Id.

question 1.b. However, Postal Service contracts with these contractors impose specific 

safety requirements, and the Postal Service reviews safety incidents involving contractors 

as they occur. Id.

In FY 2022, the Postal Service states it monitored the safety and performance of 

contractor-operated motor vehicles by discussing safety incidents with the relevant 

contractors as they occurred to determine the cause and reduce the likelihood of recurring 

incidents. Id. question 2. It notes that it continued its ongoing practice of reviewing 

transportation contractors to terminate relationships with those contractors that have 

unsatisfactory safety performance. Id. The Postal Service also states that it onboarded a 

new third-party software provider to help monitor and evaluate overall contractor safety 

102 United States Postal Service, Happy return USPS introduces new Update newsletter, Link (July 15, 2022), available at 

https://link.usps.com/2022/07/15/happy-return/ “Area and Regional Update replaces the Area Update newsletters that USPS published until 

2020. Since then, the organization has published a quarterly National Update.” .

103 See, e.g., United States Postal Service, Wonder workers keep district fleet in shape, Area and Regional Update-Atlantic Eastern Edition (June 

2022), at 4, available at https://liteblue.usps.gov/lite-blue/pdf/Atlantic-Eastern-Regional-UpdateJune2022.pdf?from=AreaUpdatesArchive&page=AtlanticEastern; United States Postal Service, Driver instructors tea h ‘staying in your lane,’

Area and Regional Update-Atlantic Eastern Edition (November 2022), at 13, available at https://liteblue.usps.gov/lite-blue/pdf/AtlanticEastern-Regional-Update-Fall-2022.pdf?from=AreaUpdatesArchive&page=AtlanticEastern.

104 PR Comments at 16 (citing Christopher Weaver, Trucks Hauling U.S. Mail Frequently Violate Safety Rules. Crashes Killed 79 People Since 

2020., The Wall Street Journal (Mar. 1, 2023), available at https://www.wsj.com/articles/trucks-mail-violate-safety-rules-deadly-crashes8b9a4c92). A follow-up article described that the Postal Service emailed its trucking contractors and directed them to immediately report 

details of accidents resulting in death, injuries, or significant property damage directly to several senior Postal Service officials. Christopher 

Weaver, U.S. Postal Service Trucking Contractors Must Now Disclose Serious Traffic Accidents, The Wall Street Journal (Mar. 15, 2023),

available at https://www.wsj.com/articles/u-s-postal-service-trucking-contractors-must-now-disclose-serious-traffic-accidents-6ceafe6b.

Subsequently, another article described how freight brokers that arrange discounted shipments for the Postal Service could lead to unsafe 

practices for contractors transporting mail for the Postal Service. Christopher Weaver, U S P tal Servi e’ Sear h f r Saving Bring Ri kier 

Drivers, The Wall Street Journal (June 15, 2023); available at https://www.wsj.com/articles/u-s-postal-services-search-for-savings-bringsriskier-drivers-33d5bf6c.
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performance. Response to CHIR No. 26, question 6. It notes that this software provider 

captures data from various government transportation agencies and compiles this 

information into a centralized database that the Postal Service may view via an online 

tool.105 The Postal Service explains that the online tool helps it consult overall contractor 

safety performance ratings and investigate any non-compliance violations issued to 

individual contractors. Id. It states that the online tool also provides almost real-time 

updates on reports related to contractor safety ratings, which allows the Postal Service to 

identify contractors who have lost their license to operate motor vehicles. Id.

To improve the safety and performance of contractor-operated motor vehicles in FY 2023, 

the Postal Service states it will continue to require independent contractors to operate 

motor vehicles safely; adhere to federal, state, and local laws; and properly compensate 

their employees. Response to CHIR No. 18, question 4. It explains that “[r]epeated safety 

incidents involving our independent contractors are, and will continue to be, grounds for 

termination when the Postal Service determines that such contractors are not pursuing 

consequential remedial actions.” Id.

Also, the Postal Service describes an ongoing initiative during the past several years to 

revamp its approach to managing its transportation portfolio, including that portion 

involving independent third-party contractors. Id. It states that it formed a new

transportation strategy team led by industry leaders outside the Postal Service to focus 

solely on transportation procurement. Response to CHIR No. 26, question 7.a-b. It explains 

that this strategy team focused on attracting contractors with a broad portfolio of 

customers and equipped with advanced technology. Id. The Postal Service notes that 

during the past 3 years, it has onboarded 188 new motor vehicle contractors while 

replacing 218 contractors. Id. It also describes changes to the way it contracts with 

third-party contractors to operate motor vehicles, such as simplifying contract terms and 

conditions and adopting revised safety criteria. Id.

In his comments, the Public Representative strongly urges the Postal Service to develop 

and implement tools for tracking serious incidents involving trucking contractors. PR 

Comments at 16. He also recommends that the Postal Service review its contracting 

practices “to ensure that its contractors comply with all applicable laws and regulations 

and promote the safety of drivers and the general public.” Id. He comments that because 

the Postal Service is switching over from air transportation to surface transportation, the 

role of third-party motor vehicle contractors could increase and thus require closer 

monitoring of their activities. Id. at 16-17.

In its reply comments, the Postal Service reiterates that it reviews safety incidents with 

contractors as they occur, discusses these incidents with the contractors to determine the 

cause, and evaluates transportation contractors to terminate relationships with those 

105 Id. These government agencies include the Federal Motor Carrier Safety Administration and the Department of Transportation. Id.
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contractors that have unsatisfactory safety performance. Postal Service Reply Comments 

at 6. It states that it hired a third-party software provider to help measure and monitor the 

safety and performance of contractor-operated motor vehicles and is engaged in an 

ongoing initiative to revamp its approach to managing its transportation portfolio. Id.

Although contractor-operated motor vehicle safety is not part of the Safe Workplace and 

Engaged Workforce performance goal, it is an important factor when evaluating the Postal 

Service as a safe place to work. Moreover, as the Postal Service increases its reliance on 

ground transportation (and shifts away from air transportation), the Postal Service should 

increase its efforts to monitor the safety and performance of contractor-operated motor 

vehicles, including vehicles operated by subcontractors of freight brokers. The ongoing 

efforts identified by the Postal Service appear designed to address and prevent the types 

of contractor-operated motor vehicle safety incidents at issue. In particular, onboarding a 

new third-party software provider that provides near real-time updates on reports related 

to contractor safety rates will help the Postal Service address accidents and other safety 

incidents as they occur.

The Commission recommends that the Postal Service continue to recognize employees that 

promote a safe workplace and motor vehicle safety in quarterly newsletters and other 

publications. Also, the Commission recommends that the Postal Service continue to monitor 

the safety and performance of contractor-operated motor vehicles (including vehicles 

operated by subcontractors of freight brokers) and address safety incidents shortly after they 

occur to help prevent future incidents and unsafe practices.

b. Engaged Workforce

In FY 2022, the Postal Service tracked progress toward the Safe Workplace and Engaged 

Workforce performance goal using the Grand Mean Engagement Score as one of the 

performance indicators. The Postal Service also measured employee engagement using 

the Engagement Survey Response Rate. Each of these metrics is explored below.

(1) Grand Mean Engagement Score

The Postal Service measures overall engagement levels of Postal Pulse survey respondents 

using the Grand Mean Engagement Score, which is derived from the average of ratings for 

survey Questions 1 through 12 provided by Postal Pulse survey respondents. Response to 

CHIR No. 26, question 12. To calculate the Grand Mean Engagement Score, responses to 

each survey question are averaged to calculate the mean score for each question using the 

5-point survey scale, with 5 being the highest score and 1 being the lowest. Id. Next, the 

mean scores for Questions 1 through 12 are averaged to calculate the Grand Mean 

Engagement Score. Id. Table III-14 shows results for the Grand Mean Engagement Score, 

as well as the mean score for each question on the Postal Pulse survey, from FY 2019 

through FY 2022.
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Table III-14

Postal Pulse Survey Grand Mean Engagement Scores and Mean Scores

FY 2019-FY 2022

Postal Pulse Survey Questions

Question-Specific Mean Scorea

FY 2019 FY 2020 FY 2021 FY 2022

Q0. How satisfied are you with the Postal Service as a place to 

work? 3.60 3.48 3.52 3.45

Grand Mean Engagement Score 3.36 3.29 3.36 3.31

Q1. I know what is expected of me at work. 4.30 4.26 4.29 4.29

Q2. I have the materials and equipment I need to do my work 

right. 3.61 3.54 3.60 3.55

Q3. At work, I have the opportunity to do what I do best every 

day. 3.80 3.74 3.81 3.78

Q4. In the last seven days, I have received recognition or praise 

for doing good work. 2.88 2.83 2.91 2.86

Q5. My supervisor, or someone at work, seems to care about me 

as a person.

3.48 3.41 3.48 3.42

Q6. There is someone at work who encourages my development. 3.12 3.01 3.12 3.08

Q7. At work, my opinions seem to count. 2.94 2.85 2.95 2.90

Q8. The mission or purpose of my company makes me feel my job 

is important. 3.61 3.60 3.62 3.54

Q9. My fellow employees are committed to doing quality work. 3.42 3.43 3.42 3.35

Q10. I have a best friend at work. 3.08 3.04 3.10 3.03

Q11. In the last six months, someone at work has talked to me 

about my progress. 2.87 2.73 2.83 2.80

Q12. This last year, I have had opportunities at work to learn and 

grow.

3.17 3.04 3.14 3.11

C01. My immediate supervisor has recently spent one-on-one 

time with me to discuss my workplace needs. N/A 2.73 2.83 2.77

C02. I would recommend my organization to friends and family as 

a great place to work. N/A 3.13

C03. I would recommend my n z n’ u n e e 

to friends and family members. N/A 3.79

N/A – Question was not asked on the Postal Pulse survey for that fiscal year.

a The mean score is the average score for each question on the Postal Pulse survey using the 5-point survey scale, with 5 being the highest score 

and 1 being the lowest.

Source: FY 2022 Annual Report at 33; Response to CHIR No. 26, question 8.b.; Docket No. ACR2021, Response to CHIR No. 25, question 13; 

Docket No. ACR2020, Responses of the United States Postal Service to Questions 1-10 of Chairman's Information Request No. 23, March 11, 

2022, question 7.d.; Docket No. ACR2019, Responses of the United States Postal Service to Questions 1-12 of Chairman's Information Request 

No. 21, March 19, 2020, question 4.a.
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Table III-14 shows that both the Grand Mean Engagement Score and mean scores for each 

question on the Postal Pulse survey either decreased or remained the same between 

FY 2021 and FY 2022.106 The Postal Service explains that the decrease in the Grand Mean 

Engagement Score and overall employee engagement was caused by changes to the United 

States workforce since the COVID-19 pandemic. FY 2022 Annual Report at 43. It states that 

many organizations have experienced an increase in turnover and decreased employee 

engagement and satisfaction, which has been described as the “great resignation” and 

“quiet quitting.” It asserts that employees are reacting to the COVID-19 pandemic by reevaluating whether their work is meaningful to them and deciding not to exert extra effort 

at work to improve work-life balance. Id. It points out that companies with lower-paying 

jobs, such as those in the service industry, are struggling to hire enough workers. Id.

The Public Representative comments that the Postal Service’s explanation for the decrease 

in Grand Mean Engagement Score does not identify reasons for employee disengagement 

specific to the Postal Service compared to the general population. PR Comments at 18. He 

states that the Postal Service does not offer any insight into whether any question or 

category of questions disproportionately contributed to the lower result. Id. He questions 

whether the decline should be attributed to the COVID-19 pandemic considering that the 

Grand Mean Engagement Score rebounded to pre-pandemic levels in FY 2021 but 

decreased in FY 2022. Id. at 19. The Postal Service responds that it conducts extensive 

analysis of Postal Pulse survey results at all levels because managers have access to the 

results, which they can use to identify key drivers of engagement for their respective work 

units. Postal Service Reply Comments at 9. It maintains that the broader workforce trends 

described in the FY 2022 Report account, in large part, for the decline in employee 

engagement. Id. at 9-10.

The Commission acknowledges that overall employee engagement has declined across the 

country since the COVID-19 pandemic. A recent Gallup article reported that employee

engagement in the United States experienced its first annual decline in a decade, dropping 

from 36 percent engaged employees in 2020 to 34 percent in 2021.107 This decline 

continued into 2022, with only 32 percent of full- and part-time employees engaged. See

U.S. Employee Engagement Needs a Rebound in 2023. These trends also apply to the Postal 

Service because the Gallup article was based on the Gallup Q12 survey, which is identical 

to Questions 1 through 12 on the Postal Pulse survey.

However, as the Public Representative notes, the overall decline in employee engagement 

across the country does not analyze or identify reasons for employee dissatisfaction 

specific to the Postal Service. In FY 2021, the Postal Service experienced an organizational 

106 This comparison does not include Questions C02 and C03, which were added in FY 2022.

107 Jim Harter, U.S. Employee Engagement Needs a Rebound in 2023, Gallup (Jan. 25, 2023), available at 

https://www.gallup.com/workplace/468233/employee-engagement-needs-rebound-2023.aspx (U.S. Employee Engagement Needs a Rebound 

in 2023).
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restructuring that could have led to increased employee anxiety and reduced engagement 

in FY 2022. See FY 2021 Annual Report at 44. The Postal Service is also implementing 

planned network changes associated with the 10-Year Strategic Plan, which the 

Commission is currently examining in Docket No. PI2023-4. See Order No. 6488. These 

changes will likely affect employee engagement in FY 2023. If the Grand Mean 

Engagement Score continues to decline or does not increase in FY 2023, the FY 2023 

Report could be improved by identifying all reasons for employee dissatisfaction that are 

specific to the Postal Service and analyzing the impact of postal-related changes on 

employee engagement.

For FY 2023, the Postal Service set the Grand Mean Engagement Score target at 3.33, an 

increase of 0.02 from the FY 2022 result. FY 2022 Annual Report at 43. The Postal Service 

explains that Grand Mean Engagement Scores have increased by 0.01 each year from 

FY 2016 through FY 2019 and asserts that the FY 2023 target is “optimistic, yet realistic.” 

Id. The Public Representative comments that the FY 2023 target seems appropriate 

considering the increase in results during the four fiscal years preceding the COVID-19 

pandemic. PR Comments at 19.

To meet the FY 2023 target, the Postal Service describes employee engagement initiatives 

focused on two major employee groups: front-line supervisors and newly hired pre-career 

employees. FY 2022 Annual Report at 43. It states that in FY 2023, it will continue to 

expand programs recently established for these employee groups. Id. at 44. For front-line 

supervisors, the Postal Service notes that it increased the number of authorized positions 

to align with earned staffing. Id. at 43. It states it also conducted an “aggressive internal 

recruitment campaign” to facilitate filling vacant positions, revised the USPS Supervisor 

Program to ensure that new supervisors had the most up-to-date training, and deployed 

new mobile tablets to front-line supervisors in mail processing to provide them access to 

technology while on the workroom floor. Id. It also deployed a new Front-Line Supervisor 

Tool Kit webpage on the postal intranet to provide quick access to the most frequently 

used systems, forms, and references. Id.

For newly hired employees, the Postal Service states that the onboarding process was 

standardized and documented to welcome them and ensure they receive the training, 

equipment, and information necessary for success. Id. It notes that it piloted 

enhancements to the onboarding programs to evaluate how revised schedules and peer 

mentors impact new employee engagement and retention. Id. The Postal Service asserts 

that the pilots have resulted in higher engagement and retention scores, and it plans to 

continue expanding them in FY 2023. Id. For example, the Postal Service piloted a new 

employee experience program for non-career city carrier assistants that set workhour 
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limits and scheduled days off, which resulted in turnover improvement at these pilot 

sites.108

The Commission is concerned that mean scores for almost every question on the Postal Pulse 

survey decreased in FY 2022 but acknowledges that none of the scores declined by more than 

0.08 points on the survey scale. The decline in employee engagement is consistent with 

employee engagement levels across the country in recent years. If the Grand Mean 

Engagement Score continues to decline or does not increase in FY 2023, the Commission 

recommends that the FY 2023 Report identify all reasons for employee dissatisfaction that 

are specific to Postal Service employees and analyze the impact of postal-related changes on 

employee engagement.

The FY 2023 target is reasonable considering the range of Grand Mean Engagement Scores 

during the past few years. The Postal Service’s plans to implement engagement initiatives for 

front-line supervisors and newly hired pre-career employees are reasonable steps for 

improving the Grand Mean Engagement Score and overall employee engagement. The 

Commission recommends that the Postal Service continue implementing and expanding pilot 

programs to improve employee engagement and retention for both career and non-career 

employees. Also, in the FY 2023 Report, the Commission recommends that the Postal Service 

describe how the implementation of these initiatives affected the FY 2023 Grand Mean 

Engagement Score.

(2) Engagement Survey Response Rate

The Engagement Survey Response Rate shows the Postal Pulse survey level of 

participation among the entire employee population. FY 2022 Annual Report at 42. The

result was calculated by dividing the total number of employees who responded to at least 

one question by the total number of employees who received the survey. Response to 

CHIR No. 26, question 10. In FY 2022, surveys were distributed to 578,705 employees, and 

142,640 responded to at least one question. Id. This calculation results in an Engagement 

Survey Response Rate of 24.65, which was rounded up to 25 percent. Id.

Figure III-16 shows the Engagement Survey Response Rate results from FY 2019 through 

FY 2022.

108 United States Postal Service, Office of the Inspector General, Report No. 22-180-R23, Postal Service's Non-Career Employee Turnover 

Follow-Up, April 18, 2023, at 1, 6, 8, available at www.uspsoig.gov/sites/default/files/reports/2023-04/22-180-r23.pdf (OIG Report No. 22-180-

R23).
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Figure III-16

Postal Pulse Engagement Survey Response Rate

Results from FY 2019-FY 2022

Source: FY 2022 Annual Report at 33.

Figure III-16 shows that the Engagement Survey Response Rate result has declined each 

year from FY 2019 through FY 2021, falling from a relative high of 38 percent in FY 2019 

to 25 percent in FY 2021. The FY 2022 result was the same as FY 2021. In the FY 2023 

Plan, the Postal Service states that it plans to increase communications around the Postal 

Pulse survey, which include internal employee publications highlighting the positive 

impact of engagement and leveraging survey results to improve the work environment. 

FY 2022 Annual Report at 44. It notes that it will provide guidance to managers on what 

they can do to improve engagement, such as scheduling one-on-one meetings with 

employees and increasing employee recognition. Id. To prepare for the next Postal Pulse 

survey administration, the Postal Service states it will provide advance notification to 

prepare managers and encourage employees to respond. Id.

The Public Representative acknowledges that the Postal Service no longer uses the 

Engagement Survey Response Rate as a performance indicator but expresses concern that 

the result did not improve between FY 2021 and FY 2022. PR Comments at 19. He urges 

the Postal Service to implement steps described in the FY 2023 Plan to improve the 

employee and manager communications. Id. at 19-20. Besides the lack of improvement, 

the Commission is concerned that the Engagement Survey Response Rate is lower than 

comparable response rates for the FY 2022 Federal Employee Viewpoint Survey (FEVS), 

38%

33%

25% 25%

0%

10%

20%

30%

40%

50%

FY 2019 FY 2020 FY 2021 FY 2022

Engangement Survey Response Rate (%)

Fiscal Year
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which is administered to all federal employees.109 In FY 2022, the governmentwide FEVS 

survey response rate was 35 percent,110 and the response rate for Very Large Agencies 

(those with more than 75,000 employees) was 32 percent. Id. at 5. Response rates 

improved slightly between FY 2021 and FY 2022 both governmentwide and by agency 

size categories (Very Small, Small, Medium, Large, and Very Large Agencies). Id.

The Commission acknowledges that the FY 2022 Engagement Survey Response Rate could 

have been affected by the decline in overall engagement across the country. Factors 

outside of the Postal Service’s control could affect Engagement Survey Response Rate. 

Nonetheless, the Commission is concerned that the FY 2022 result of 25 percent is 7 to 10 

percentage points lower than comparable response rates for the FEVS survey, and there 

was no improvement between FY 2021 and FY 2022 despite the Postal Service efforts to 

improve the Engagement Survey Response Rate in FY 2022. See Response to CHIR No. 26, 

question 11.a. To obtain an accurate picture of employee engagement, the Postal Service 

should continue to strive to improve employee survey response rates.

The Commission recommends that the Postal Service implement the programs described in 

the FY 2023 Plan to improve the Engagement Survey Response Rate in FY 2023. If the rate 

does not improve in FY 2023, the Commission recommends that the Postal Service investigate 

and address the root causes and describe its efforts to do so in the FY 2023 Report.

D. Financial Health

1. Background

In FY 2022, the Postal Service used one performance indicator to measure progress 

toward the Financial Health performance goal: Controllable Income (Loss). See FY 2022 

Annual Report at 45. The results for the Controllable Income (Loss) performance indicator 

are calculated as the Postal Service’s total revenue less controllable expenses. Id. Revenue 

includes funds received from the sale of postage, mailing, and shipping services; Post 

Office Box rentals; the sale and lease of property; and interest and investment income. See 

id. at 47.

Controllable expenses consist of salaries and benefits; the Federal Employees Retirement 

System (FERS) and Postal Service Retiree Health Benefits (RHB) normal costs; 

transportation; depreciation; supplies and services; and rent, utilities, and other 

controllable expenses.111 Controllable expenses exclude non-controllable expenses, which 

109 See Office of Personnel Management, Federal Employee Viewpoint Survey Results, at 1, available at 

https://www.opm.gov/fevs/reports/governmentwide-reports/governmentwide-reports/governmentwide-management-report/2022/2022-

governmentwide-management-report.pdf (2022 FEVS Report).

110 2022 FEVS Report at 1. Survey invitations were sent to 1,582,112 employees, with a total of 557,778 employees completing a survey. Id.

111 See id. at 45, 47-48. The Postal Service notes that RHB normal costs were “expensed from FY 2017 through FY 2021” id. at 45 n.8) and 

“eliminated the PSRA.” Id. at 46.
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are expenses that the Postal Service states do not reflect short-term operational decisions 

and are subject to large fluctuations that are outside of the Postal Service’s control. See id. 

at 45. According to the Postal Service, non-controllable expenses include:

• From FY 2017 through FY 2022, revaluations of the RHB normal cost by the Office 

of Personnel Management (OPM)

• From FY 2017 through FY 2022, amortization of the Postal Service’s unfunded RHB 

liabilities

• Amortization of the Postal Service’s unfunded liabilities for its participation in 

FERS and the Civil Service Retirement System (CSRS)

• Non-cash expenses related to changes in liability for participating in the federal 

workers’ compensation program

• For FY 2022, the non-cash impact of the Postal Service Reform Act (PSRA)

Id.; Pub. L. 117-108, 136 Stat. 1127 (2022).

Consistent with historical practice, the Commission published a separate financial analysis 

of the Postal Service’s FY 2022 financial results and 10-K statement.112 That analysis 

provides a detailed evaluation of the Postal Service's financial status by examining volume, 

revenue, and cost trends, as well as the Postal Service’s sustainability, liquidity, activity, 

and financial solvency.

In FY 2022, the Postal Service met its target for Controllable Income (Loss).113 The Postal 

Service’s total Controllable Income (Loss) for FY 2022 of $(0.5) billion114 was better than 

its target Controllable Income (Loss) of $(4.1) billion. Id. at 47. The Postal Service explains 

that FY 2022 revenue was $1.3 billion greater than the planned amount. Id. Controllable 

expenses were $2.3 billion less than planned. Id. at 46.

In the FY 2023 Plan, the target for Controllable Income (Loss) is $0.5 billion, a difference of 

$1.0 billion from the FY 2022 Controllable Income (Loss) of $(0.5) billion. See id. at 46, 48.

112 Postal Regulatory Commission, Financial Analysis of United States Postal Service Financial Results and 10-K Statement, Fiscal Year 2022, 

May 17, 2023 (FY 2022 Financial Analysis).

113 FY 2022 Annual Report at 33, 47. Projections of Controllable Income (Loss) are based on planned revenues and expenditures for every 

program activit included in the Postal Service’s Integrated Financial Plan IFP . The FY 2 22 Controlla le Income oss target was aligned with 

the FY 2022 IFP, November 18, 2021, available at https://www.prc.gov/docs/120/120221/FY2022%20IFP%20111821%20FINAL.pdf; see 

FY 2022 Annual Report at 33 n.6; Responses of the United States Postal Service to Questions 1-1 of Chairman’s Information Request No. 29, 

May 10, 2023, question 10 (Response to CHIR No.29) (confirming that the FY 2022 IFP information in the FY 2022 Annual Report was not, nor 

was planned to be, revised). Controllable Losses are shown in parentheses.

114 FY 2022 Annual Report at 47. The Postal Service generally describes its Controllable Income (Loss) result throughout the FY 2022 Annual 

Report as $(0.5) billion. See, e.g., id. at 47. However, it lists its total Controllable Income (Loss) as $(0.47) billion. Id. at 33. The Postal Service 

notes that numbers in the FY 2022 Annual Report “are rounded for additive purposes.” Id. at 46 n.1.
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Plans for meeting the FY 2023 Controllable Income (Loss) target are discussed in more 

detail below. See Section D.3.a.(1)., infra.

2. Comments

The Public Representative comments that the Postal Service achieved its FY 2022 target 

for the Controllable Income (Loss) performance indicator. PR Comments at 22. However, 

the Public Representative notes that the “Postal Service was able to meet that goal at least 

in part by being relieved of an anticipated $4.3 billion in PSRHBF expenses following the 

enactment of the Postal Service Reform Act of 2022. Otherwise, the Postal Service’s FY 

2022 controllable expenses would have been substantially higher than FY 2021.” Id. The 

Public Representative comments that “labor productivity declined noticeably from FY 

2021 to FY 2022” and recommends that the Postal Service increase its monitoring of its 

network improvement processes to maintain productivity levels. Id.

NAPM states that the FY 2023 Plan does not include volume retention and growth 

initiatives. NAPM Comments at 10-11. NAPM expresses concern that price increases 

intended to increase revenue will accelerate mail volume declines. See id. at 11. NAPM 

urges the Postal Service to engage with industry stakeholders to explore new initiatives 

designed to retain and grow mail volumes and revenues. See id. NAPM recommends that 

the Postal Service update its methodology to determine the impact of price increases on 

mail volumes, or price elasticity. See id. Lastly, NAPM supports Postal Service efforts to 

reform Postal Service liability for CSRS amortization expenses. See id.

In its reply comments, the Postal Service remarks that legislative reform, such as the PSRA, 

is an important strategy in its 10-Year Strategic Plan. Postal Service Reply Comments at 

10. The Postal Service estimates that inflation, which is outside of management’s control, 

led to a net $1.6 billion increase in costs, as compared to the FY 2022 IFP. Id. The Postal 

Service recognizes the existence of financial challenges such as inflation, but it points out 

its “progress toward enacting a more efficient, customer-oriented, and operationallyfocused organization.” Id. at 11. Lastly, the Postal Service notes that elements of the 10-

Year Strategic Plan, including the redesign of the processing and delivery network and 

modernization of the delivery fleet, is expected to lead to significant productivity gains in 

the future. Id.

3. Commission Analysis

a. Controllable Income (Loss)

In FY 2022, the Postal Service met the target for Controllable Income (Loss). See FY 2022 

Annual Report at 33, 47. The Postal Service’s $(0.5) billion Controllable Income (Loss) for 

FY 2022 was less than the target Controllable Income (Loss) of $(4.1) billion. Id. at 47.

Further, the Commission finds that the Financial Health indicator target for Controllable 

Income (Loss) for FY 2022 is comparable to the result for FY 2022 because each calculates 

Controllable Income (Loss) as total revenue less controllable expenses. See Response to 
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CHIR No. 23, question 1.a. This methodology was also used from FY 2019 through FY 

2022. See id. question 2.a.

The Commission finds that the Postal Service met the Financial Health performance goal in 

FY 2022.

Below, the Commission analyzes the Controllable Income (Loss) performance indicator in 

more detail.

(1) Postal Service Report

The FY 2022 Annual Report provides an explanation of the principal components used to 

calculate Controllable Income (Loss). See FY 2022 Annual Report at 46-48. The FY 2022 

Annual Report includes a table showing revenue and expenses and describes certain 

categories of revenue and controllable expenses. See id. at 46. The Postal Service explains 

how the FY 2022 Controllable Income (Loss) target was met and provides a rationale for 

the FY 2023 target. Id. at 45-49. Additionally, the FY 2022 Annual Report discusses 

non-controllable expenses. See id. at 45. This information improves the transparency and 

usefulness of the FY 2022 Annual Report by assisting interested persons better to 

understand how the Postal Service calculates targets and results.

The Commission recommends that the Postal Service continue to include information on 

Controllable Income (Loss) and non-controllable expenses in future annual performance 

plans and annual performance reports.

The Postal Service also provides the Controllable Income (Loss) results from FY 2019 

through FY 2022. Id. Controllable Income (Loss) has shown improvement, with annual 

losses decreasing in magnitude since FY 2020. See Figure III-17.
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Figure III-17

Controllable Income (Loss) Results

FY 2019-FY 2022

Source: FY 2022 Annual Report at 46. Results are rounded to the nearest tenth.

As explained above, the FY 2022 Annual Report includes a table listing the components of 

Controllable Income (Loss), which is adapted as Table III-15.
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Table III-15

Integrated Financial Plan Revenue and Expenses ($ in Billions)

Results and Targets, FY 2019-FY 2023

Results Target Result Target

FY 

2019

FY 

2020

FY 

2021

FY 

2022

FY 

2022

FY 

2023

Revenue 

First-Class Mail 24.4 23.8 23.3 24.2 24.0 24.9 

USPS Marketing Mail 16.4 13.9 14.6 15.2 16.0 16.4 

Shipping and Packages 22.8 28.5 32.0 30.6 31.3 31.9 

International Mail 2.5 2.4 2.2 2.2 1.7 1.8

Periodicals 1.2 1.0 1.0 1.0 1.0 1.0 

Othera 4.0 3.6 4.0 4.3 4.8 5.2 

Total Revenue 71.3 73.2 77.1 77.5 78.8 81.2 

Controllable Expenses 

Salaries and benefitsb 48.9 50.0 51.4 52.2 52.8 54.0 

FERS normal cost 3.5 3.8 4.1 4.4 4.5 4.6 

RHB normal costc 4.0 4.0 3.9 4.3 — —

Transportation 8.2 8.8 9.7 9.6 10.3 10.0 

Depreciation 1.7 1.7 1.7 1.7 1.7 1.8 

Supplies and services 2.8 3.1 2.9 3.2 3.2 3.4 

Rent, utilities and otherd 5.6 5.6 5.8 6.2 6.8 6.9 

Total Controllable Expenses 74.7 77.0 79.5 81.6 79.3 80.7 

Controllable Income (Loss) (3.4) (3.8) (2.4) (4.1) (0.5) 0.5

Non-Controllable Expenses 

Impact of Postal Service reform legislatione — — — — 57.0 —

RHB normal cost actuarial revaluation 0.2 0.1 (0.3) — — —

RHB unfunded liability amortization (0.8) (0.8) (0.9) (1.0) — —

FERS unfunded liability amortization (1.1) (1.3) (1.4) (1.4) (1.6) (1.9)

CSRS unfunded liability amortization (1.6) (1.8) (1.9) (1.9) (2.3) (3.1)

 e ’ en n ue n e n ncash adjustments (2.1) (1.6) 2.0 — 3.4 —

Total Non-Controllable Expenses (5.4) (5.4) (2.5) (4.3) 56.5 (5.0)

Net Income (Loss) (8.8) (9.2) (4.9) (8.4) 56.0 (4.5)

Note: The sum of columns may not equal total due to rounding. FY 2022 Annual Report at 46 n.1.

a

Includes investment and interest income, gain or loss on sale, and income from the out-lease of property. Id. at 46 n.2.

b

Includes salaries, health enefit e penses for active emplo ees, and or ers’ compensation cash outla s. Id. at 47.

C RHB normal costs were eliminated by the PSRA. Id. at 46.

d Rent, utilities, and other includes interest expense. Id. at 46 n.4.

e Represents the one-time non-cash benefit due to the reversal of $57.0 billion for past due retiree health benefit obligations that were 

canceled by the enactment of the PSRA. With the PSRA, RHB normal cost and amortization payments will be zero for FY 2022 and future 

years. RHB top-up payments, a new payment, are expected to begin in FY 2026. Id. at 46 n.5.

Source: FY 2022 Annual Report at 46.
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Total revenue in FY 2022 was $78.8 billion, which was $1.3 billion more than planned. 

FY 2022 Annual Report at 46, 47.

According to the Postal Service, “[t]he COVID-19 pandemic continued to impact the Postal 

Service’s financial health in FY 2022.” Id. at 44. However, the Postal Service states that 

“[t]he surge of package volume in 2020 and 2021 abated, though volumes remained above 

pre-pandemic levels. Mail volumes continued to decline, however [USPS] Marketing Mail 

volumes rebounded slightly from their depressed levels at the start of the pandemic.” Id.

Revenue for First-Class Mail (primarily consisting of Single-Piece and Presorted letters 

and postcards) was $24.0 billion, which was $0.2 billion below the planned amount, 

“mainly due to lower-than-expected volume recovery from the pandemic loss.” Id. at 47. 

Revenue for USPS Marketing Mail (which consists of mail weighing less than 16 ounces 

and not required to use First-Class Mail) was $16.0 billion, $0.8 billion above the planned 

amount, “primarily due to higher-than-expected volume recovery from the pandemic 

loss.” Id.

Shipping and Packages consist largely of Competitive services that can be priced to reflect 

current market conditions, such as Priority Mail and Parcel Select. See id. Revenue from 

Shipping and Packages was $31.3 billion, $0.7 billion more than the planned amount, “due 

to pricing initiatives and volumes from mailing of COVID-19 test kits.” Id. Smaller revenue 

sources included International Mail, Periodicals, and other revenue sources representing 

$1.7 billion, $1.0 billion, and $4.8 billion in revenues, respectively. Id.

In FY 2022, controllable expenses, including interest expense, were $79.3 billion. Id. at 46. 

Salaries and benefits expenses—which include salaries, employee health benefits 

expenses, and workers’ compensation cash outlays—totaled $52.8 billion, which was $0.6 

billion more than the planned amount, “primarily due to the impact of high inflation[.]” Id. 

at 47.

Transportation expenses totaled $10.3 billion, which was $0.7 billion above the planned 

amount; according to the Postal Service, this was “primarily because of the increase in fuel 

expenses for the transportation contracts and inflationary pressures in the trucking 

industry due to supply imbalances.” Id. at 48.

The FERS normal cost totaled $4.5 billion, which was $0.1 billion above the planned 

amount. Id. Other expense categories included depreciation (which totaled $1.7 billion, in 

line with the planned amount); supplies and services (which totaled $3.2 billion, in line 

with the planned amount); and rent, utilities, and other expenses (which totaled $6.8 

billion, $0.6 billion more than the planned amount, “primarily due to price of fuel and 

extending leases for Package Support Annexes (PSAs) for COVID-19 test kits”). Id.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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The Controllable Income (Loss) target for FY 2023 is a $0.5 billion gain, which anticipates 

“a $2.4 billion increase in revenue which is offset by a $1.4 billion increase in controllable 

expenses compared to FY 2022” Id. at 48.

In the FY 2023 Plan, the Postal Service states that it expects revenue in FY 2023 to increase 

by $1.3 billion compared to FY 2022.115 The Postal Service explains that in July 2022, it 

implemented price increases on products that included the above-consumer price index 

(CPI) sources of rate authority approved by the Commission in Order No. 5763.116

According to the Postal Service, these “increased prices are expected to offset the loss of 

revenue due to continued electronic diversion.” FY 2022 Annual Report at 48. International 

revenue is expected to increase by $0.1 billion, while “other sources” is expected to 

increase by $0.4 billion. Id.

In the FY 2023 Plan, the Postal Service anticipates that Shipping and Packages revenue will 

increase by $0.6 billion.117 The Postal Service explains that “[c]onsumers are expected to 

increase in-store shopping and the use of pickup services instead of online shopping[,]” 

and “competitors are increasing their efforts to capture sources of revenue,” although 

“supply chain shortages and a potential global recession could negatively impact 

consumer buying trends.” FY 2022 Annual Report at 48. The Postal Service, in setting its 

targets, projected expected aggregate annual U.S. e-commerce growth of 2.98 percent in 

FY 2023 relative to FY 2022. Response to CHIR No. 20, question 4.a. It explains that ecommerce growth suggests higher forecasted volumes and revenues for many of its 

products in “Shipping and Packages.” Id.

In terms of controllable expenses, the Postal Service reports that “[s]alaries and benefits 

expenses are planned to increase by $1.2 billion in FY 2023 due to wage increases from 

contractual general increases and high COLA [cost-of-living adjustments] based on 

increased inflation.” FY 2022 Annual Report at 48. The Postal Service explains that “[t]he 

cost-of-living adjustment issued in August 2022 (the full impact of which will be reflected 

in FY 2023) was equivalent to approximately [$2,455] per year for most full-time 

employees.”118 Furthermore, “[s]alary and benefit expenses are expected to increase 

despite a planned reduction in [workhours].” FY 2022 Annual Report at 48; see Response 

to CHIR No. 24, question 1.d.

115 Id. In a subsequent information request response, the Postal Service notes that it expects FY 2023 revenue to be lower than projections in 

the FY 2023 Plan because of greater-than-expected drops in mail revenues. It also expects personnel expenses to be higher than projected in 

the FY 2023 Plan. See Response to CHIR No. 24, question 2.b.

116 FY 2022 Annual Report at 48; see Docket No. RM2017-3, Order Adopting Final Rules for the System of Regulating Rates and Classes for 

Market Dominant Products, November 30, 2020 (Order No. 5763).

117 FY 2022 Annual Report at 48; see Response to CHIR No. 24, question 2.b. “Package revenue is trending slightly higher than projected by the 

plan because of higher-than-expected ecommerce and improved service to retain and grow package volume.” .

118 Id.; Response to CHIR No. 24, question 1.b. (correcting the FY 2022 Annual Report with the $2,455 figure per year for most full-time 

employees COLA).
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The Postal Service reports that the FERS normal cost expense in FY 2022 is expected to 

increase by $0.1 billion over FY 2022, “due to increased wages.” FY 2022 Annual Report 

at 48. RHB normal cost (controllable) expense was “canceled by the PSRA.” Id.

Transportation expenses are estimated to decrease by $0.3 billion, “largely due to lower 

air transportation costs resulting from a decrease in package volumes, a shift of assigned 

transportation from air to surface, and increased usage of lower-cost commercial 

carriers.” Id. at 49. However, “[a]n increase in surface transportation rates is expected to 

limit this reduction.” Id.

Depreciation expenses are expected to increase by $0.1 billion, while supplies and services 

expenses are expected to increase by $0.2 billion. Id. Rent, utilities, and other expenses are 

expected to increase by $0.1 billion “due to increased expenses to support modernization 

investments, as well as inflationary pressures including fuel.” Id. Furthermore, “[r]ent is 

also expected to increase due to an increased investment in annexes for processing 

packages.” Id.

(2) Response to Comments

The Public Representative notes that the “Postal Service was able to meet [its FY 2022 

financial health target] at least in part by being relieved of an anticipated $4.3 billion in 

PSRHBF expenses following the enactment of the Postal Service Reform Act of 2022.” PR 

Comments at 22. The Commission acknowledges that the absence of RHB normal costs 

(controllable) expense has observable effects on figures reported by the Postal Service for 

FY 2022 performance when compared to the figures reported for prior years’ 

performance when the Postal Service incurred such expense. Cf. FY 2022 ACD at 9.

The Public Representative comments that “labor productivity declined noticeably from 

FY 2021 to FY 2022” and recommends that the Postal Service increase its monitoring of its 

network improvement processes to maintain productivity levels. See PR Comments at 22. 

In response, the Postal Service states that “‘changes in labor productivity over a one-year 

period do not constitute a trend;’ and furthermore that the [10-Year Strategic Plan] is 

ushering in a wide and ambitious array of improvements.” Postal Service Reply Comments 

at 11 (quoting PR Comments at 22).

In all future Annual Reports through the first year following completion of the 10-Year 

Strategic Plan, the Postal Service should report on the effects of the 10-Year Strategic Plan 

on: (1) the Postal Service’s Financial Health performance indicator results; and (2) labor 

productivity.

NAPM states that the FY 2023 Plan does not include volume retention and growth 

initiatives and expresses concern that price increases intended to increase revenue will 

accelerate mail volume declines. NAPM Comments at 10-11. NAPM urges the Postal 

Service to engage with industry stakeholders to explore new initiatives designed to retain 
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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and grow mail volumes and revenues. See id. at 11. The Commission encourages the Postal 

Service to reach out to stakeholders in this regard.

NAPM recommends that the Postal Service update its methodology to determine the 

impact of price increases on mail volumes, or price elasticity. See id. The Commission notes 

that the Postal Service is required to “provide econometric estimates of demand elasticity 

for all postal products accompanied by the underlying econometric models and the input 

data sets used” each January.119 The Commission also notes that this work is ongoing by 

the Postal Service.120 The Commission encourages NAPM to reach out to the Postal Service 

regarding this issue.

The Commission encourages the Postal Service to communicate with its stakeholders to 

gather their views of the effects of rate increases on volume.

(3) Continuing Appropriateness of Controllable Income 

(Loss) as a Performance Indicator

The Postal Service uses Controllable Income (Loss) “as its principal indicator to assess its 

financial performance, as net income includes the effects of factors . . . that cannot be 

controlled or influenced by management.” FY 2022 Annual Report at 45. Controllable 

Income (Loss) is not a Generally Accepted Accounting Principle (GAAP) accounting 

measure; it excludes certain expenses that the Postal Service considers “not reflective of 

short-term operational decisions and . . . subject to large fluctuations outside the 

organization’s control.” Id.

The Postal Service states that it uses Controllable Income (Loss) rather than Net Income 

(Loss) because non-controllable expenses include the effect of factors that the Postal 

Service either cannot control or “can only marginally influence,” such as inflation, interest 

rates, and actuarial assumptions. Id.

The Commission notes the difficulty of characterizing expenses as controllable or noncontrollable in a practical and non-arbitrary manner. For example, employee salary and 

benefit expenses are considered controllable expenses. See FY 2022 Annual Report at 47. 

However, they include COLAs that are based on inflation (see id.; Response to CHIR No.24, 

question 1.a.), even though the Postal Service characterizes inflation as outside the Postal 

119 See 39 C.F.R. § 3050.26. For the January 2023 filing, see nited States Postal Service’s emand Equation Estimation and Volume 

Forecasting Methodologies, Application of USPS for Non- Public Treatment of Materials, January 20, 2023, available at 

https://www.prc.gov/dockets/document/124295. This filing included an attachment “Jan 2023 MD Demand Analysis.zip” Januar 2 , 2 23 

Demand Equation Estimation Attachment).

120 See Januar 2 , 2 23 emand quation stimation Attachment, folder “ ar et ominant,” “Changes.vs.2 22 md .doc ,” at 2. Unlike all 

other mandatory periodic reporting, prior Commission approval is not required for the Postal Service to modify the methodologies employed 

in the development of the demand elasticities and volume forecasts. See 39 C.F.R. § 3050.10.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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Service’s control.121 Moreover, according to the Postal Service, inflation increases the 

transportation and rent, utilities, and other categories of expenses categorized as 

controllable. See FY 2022 Annual Report at 48 (transportation), 49 (rent, utilities, and 

other); Postal Service Reply Comments at 10 (transportation). In contrast, a measure that 

is consistent with GAAP would obviate the need to attempt to categorize expenses as 

controllable or non-controllable.

In addition, with the enactment of the PSRA, the FY 2022 Report and the FY 2023 Plan

reflect fewer categories of non-controllable expenses. See FY 2022 Annual Report at 46. No 

FY 2022 expenses are reported for RHB Normal Cost Actuarial Revaluation and RHB 

Unfunded Liability Amortization. See id.; id. at 45 nn.8, 9.

Because of the challenges of characterizing expenses as controllable or non-controllable, and 

because of the limited categories of expenses that the Postal Service deems non-controllable, 

the Commission recommends that the Postal Service consider whether a GAAP measure such 

as Net Income (Loss) or Net Operating Income (Loss) offers a more useful indication of the 

Postal Service’s financial health and whether such a metric should be used as a performance 

indicator in lieu of, or in addition to, Controllable Income (Loss). If the Postal Service makes 

changes to, or supplements, the Controllable Income (Loss) performance indicator in its FY 

2023 Report, the Postal Service should also provide comparable performance indicator 

results for FY 2020 through FY 2023 to help ensure compliance with 39 U.S.C. § 2804(c).

b. Other Performance Measures

Although not used as performance indicators, the Postal Service also includes in the 

FY 2022 Annual Report results for Total Factor Productivity (TFP) and labor productivity. 

FY 2022 Annual Report at 50.

As the Postal Service explains, TFP measures how efficiently the Postal Service uses its 

resources, based on the ratio of work completed to resources used. Id. An increase in TFP 

indicates that the ratio of work completed to resources used is increasing, i.e., that the 

Postal Service as an organization is operating more efficiently, whereas a decrease in TFP 

indicates the opposite. See id.

Labor productivity measures the efficiency of labor in producing a unit of workload per 

unit of labor. See id. An increase in labor productivity indicates that more workload is 

being handled per unit of labor, i.e., that labor is more efficient, whereas a decrease in 

labor productivity indicates the opposite. See id.

The Postal Service states that TFP increased significantly between FY 2009 and FY 2015 

but began declining in FY 2016. Id. The Postal Service reports that TFP in FY 2022 declined 

121 See FY 2022 Annual Report at 4 Postal Service Repl Comments at 1 “Further, the [controllable expense] figures cited by the [Public 

Representative] can in part e e plained roader economic trends that lie e ond the Postal Service’s control. ost nota l , inflation had a 

significant impact on expenses, leading to higher labor costs . . . .” .
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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0.9 percent. Id. The Postal Service states that “[t]he decrease can largely be attributed to a 

decrease in labor productivity as [the Postal Service] focused on stabilizing [its] 

operations to drive operational precision as part of the [10-Year Strategic] plan.” Id. In 

addition, the Postal Service states that “the price of labor has the greatest effect on TFP.” 

Id. According to the Postal Service, “[t]he price of labor input increased 6.5 percent from 

FY 2021.” Id.

The Postal Service reports that labor productivity decreased 1.7 percent in FY 2022. Id.

For both TFP and labor productivity, the Postal Service cautions that “resource usage is 

based on constant-dollar amounts of labor, capital, and materials used.” Id. Therefore, in 

the Postal Service’s view, “[b]ecause some productivity improvements take years for the 

effects to be realized, it is more informative to consider changes in TFP and labor 

productivity over a period of years, rather than year-to-year.” Id.; see Section D.3.c., infra

for the Commission’s discussion of the potential use of TFP as a performance indicator.

Figure III-18 shows the change in TFP and labor productivity from FY 2007 through 

FY 2022.

Figure III-18

Total Factor Productivity and Labor Productivity Results FY 2007-FY 2022

Source: FY 2022 Annual Report at 50. Base year is FY 1971. Id.

The Commission appreciates that the Postal Service provided this information, as the 

Commission has recommended in the past. See, e.g., FY 2021 Analysis at 118. Even though 

46.1 47.1 46.2

49.9

52.7 54.1

57.9 59.2 59.9 61.3 61.5 62.2 61.7 61.8 62.3

59.5

21.6 21.0 19.8

22.2 23.9 25.1

27.4 27.8 27.9 27.7 27.0 27.0 26.5 25.1 25.8 24.6

0

10

20

30

40

50

60

70

2007200820092010201120122013201420152016201720182019202020212022

Percent Change Relative to Base Year

Fiscal Year

Labor Productivity

Total Factor Productivity
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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these two measures are not performance indicators, they provide additional insight into 

productivity trends.

The Commission recommends that the Postal Service continue monitoring and reporting TFP 

and labor productivity trends. The Commission recommends that future annual performance 

reports continue to include information on TFP, labor productivity, and other productivity 

measures. In addition, the Postal Service should explain the reason for any changes in TFP 

and/or labor productivity in FY 2023.

c. Additional Performance Indicator(s)

Prior to FY 2021, the Postal Service relied on two performance indicators: one a measure 

of income (or loss) and the other a measure of productivity. FY 2021 Analysis at 118. The 

performance indicator used to measure productivity was historically based on the number 

of annual deliveries completed per employee workhour, and was, in its final iteration, 

referred to as Deliveries per Total Workhours % Change. See, e.g., id.

In the FY 2021 Analysis, the Commission noted that it was concerned that the Postal 

Service would not replace DPTWH % Change with another performance indicator in 

FY 2021 and recommended that the Postal Service consider using either TFP or labor 

productivity as performance indicators. Id. at 118-19. In response to a CHIR, the Postal 

Service states that it “continues to assess and leverage TFP in conjunction with other 

performance indicators such as revenue, profitability, market share, and customer 

satisfaction to provide a more comprehensive picture of the business’s performance.” 

Response to CHIR No. 17, question 11.b. Further, the Postal Service states that TFP is used 

“to monitor long-term performance.” Response to CHIR No. 23, question 12. However, the 

Postal Service also states that TFP would “tend to misrepresent year-over-year 

productivity declines” because changes might be attributable to the relative inability of the 

Postal Service to reduce workhours to match reduced revenue and/or workloads and 

other background constraints. Id. The Commission finds that TFP and labor productivity 

are suitable metrics to monitor long-term postal performance.

The Commission continues to be concerned that, as the Commission explained in the 

FY 2020 Analysis and FY 2021 Analysis, Controllable Income (Loss) alone does not provide 

a complete and balanced picture of the Postal Service’s progress toward the Financial 

Health performance goal.122 The Financial Health performance goal includes: (1) achieving

financial stability; and (2) improving the Postal Service’s financial position by generating 

revenue, controlling expenses, and improving efficiency. See Chapter I, Section A, supra. 

Controllable Income (Loss) provides insight into the first two of these three ways of 

improving the Postal Service’s financial position, but not the third. Thus, adding one or 

more indicators that focus on operational efficiency would provide additional insight into 

the Postal Service’s progress towards achieving financial health.

122 See Section D.3.a.(3), supra; FY 2020 Analysis at 118; FY 2021 Analysis at 119.
Analysis of FY 2022 Performance Report Evaluation of Performance Goals

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A common measure for operational efficiency that may be useful to consider as a 

performance indicator is the operating ratio, measured as operating expenses as a 

percentage of revenues. The operating ratio measures how efficiently organizations can 

generate revenue, by tracking revenue per dollar of operating expenses. Operating 

expenses would include those expenses incurred through the Postal Service’s normal 

operations, such as salaries and benefits (including FERS normal cost), transportation, 

depreciation, supplies and services, rent, and utilities. Because the operating ratio 

considers a variety of operational expenses (and not just workhours), it would be less 

affected year-over-year by the background constraints that affect the Postal Service’s 

labor flexibility. Incorporating the operating ratio as a performance indicator could offer 

insight into whether the Postal Service is improving its financial position by improving 

efficiency.

The Commission continues to recommend that the Postal Service consider adopting one or 

more additional performance indicators for measuring progress towards the Financial 

Health performance goal. Specifically, the Commission recommends that the Postal Service 

consider incorporating the operating ratio, or another measure associated with operational 

efficiency, as a performance indicator.
Analysis of FY 2022 Performance Report Strategic Initiatives

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CHAPTER IV: STRATEGIC INITIATIVES

A. Background

39 U.S.C. § 2802 requires the Postal Service to prepare a strategic plan describing “general 

goals and objectives, including outcome-related goals and objectives, for the major 

functions and operations of the Postal Service[.]” 39 U.S.C. § 2802(a)(2). On March 23, 

2021, the Postal Service issued the Delivering for America Plan, a new strategic plan to 

achieve financial sustainability and service excellence during the next 10 years (10-Year 

Strategic Plan). The 10-Year Strategic Plan outlines the following strategic areas of focus to 

achieve financial sustainability and service excellence:

• Strengthen value of mail and sustain public service mission, including 6-day mail 

delivery.

• Implement service standards that achieve service excellence 95 percent of the time.

• Innovate and launch USPS Connect.

• Modernize delivery vehicle fleet, and with Congressional support, implement 

electric fleet by 2035.

• Implement best-in-class processing operations.

• Implement best-in-class delivery operations.

• Implement a modern, transformed network of retail Post Offices.

• Implement a fully optimized surface and air transportation network.

• Stabilize and empower workforce to include reducing pre-career turnover.

• Align organizational structure to support effectiveness.

• Support legislative and administrative actions.

• Implement a more rational pricing approach including a judicious implementation 

of new and existing pricing authorities.123

123 FY 2022 Annual Report at 32.
Analysis of FY 2022 Performance Report Strategic Initiatives

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In the FY 2022 Report and FY 2023 Plan, the Postal Service refers to these 12 strategic areas 

of focus as “strategic initiatives.”124 To assess its efforts in implementing the strategic 

initiatives, the Postal Service measures performance through progress against the four 

performance goals:

• High-Quality Service by delivering at least 95 percent of all mail and packages ontime, at all times during the fiscal year

• Excellent Customer Experience by improving customer satisfaction with services 

provided through every primary touchpoint measured by the CX surveys125

• Safe Workplace and Engaged Workforce by creating a safe workplace and 

increasing employee engagement

• Financial Health by achieving a break-even (net income > $0) cumulative net 

income during the next 10 years126

The FY 2022 Report and FY 2023 Plan describes how each strategic initiative aligns with the 

performance goals. FY 2022 Annual Report at 53. Descriptions of each strategic initiative 

appear in Figure IV-1, within the Commission Analysis below.

The Postal Service explains that “[e]ach strategic initiative has a specific set of measures to 

track performance against desired” outcomes in the 10-Year Strategic Plan. FY 2022 Annual 

Report at 52. It provided the performance measures and FY 2023 targets in a CHIR 

response. Response to CHIR No. 18, question 6. The performance measures and FY 2023 

targets for the strategic initiatives are the same as the performance indicators for each 

performance goal.127

The Postal Service states that it “continuously refines the initiatives within the portfolio 

based on performance achieved to date, market conditions, feedback from customers and 

the [Commission], and input from employees.” FY 2022 Annual Report at 52. In FY 2023, the 

Postal Service plans to implement the same strategic initiatives but notes each one may be 

refined.128

124 See id. at 53; Response to CHIR No. 18, question 6; Docket No. ACR2021, Responses of the United States Postal Service to Questions 1-2 of 

Chairman's Information Request No. 21, March 4, 2022, questions 1.b., 2.a. (Docket No. ACR2021, Response to CHIR No. 21). The 10-Year 

Strategic Plan lists 11 “ e strategies” that are the same as the strategic initiatives in the FY 2022 Report and FY 2023 Plan with one difference. 

In the 10-Year Strategic Plan, the e strateg “A old Approach to ro th, Innovation, and Continued Relevance” as divided into two 

strategic initiatives: “Innovate and aunch SPS Connect” and “Strengthen value of mail and sustain pu lic service mission, including -day mail 

delivery.” Compare 10-Year Strategic Plan at 22-24, with FY 2022 Annual Report at 32, 53.

125 The CX surveys are discussed in Chapter III. See Chapter III, Section B.1.a., infra.

126 FY 2022 Annual Report at 32; Docket No. ACR2020, Response to CHIR No. 27, question 2.b.ii.

127 Compare Response to CHIR No. 18, question 6, with FY 2022 Annual Report at 33.

128 See FY 2022 Annual Report at 53; Response to CHIR No. 18, question 6. The Postal Service notes that the strategic initiatives are subject to 

change the Postal Service oard of overnors “as changes in strateg ecome necessar or usiness conditions arrant.” FY 2022 Annual 

Report at 53.
Analysis of FY 2022 Performance Report Strategic Initiatives

and FY 2023 Performance Plan

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B. Commission Analysis

None of the commenters discuss the strategic initiatives. In the FY 2021 Analysis, the 

Commission made the following recommendations regarding the strategic initiatives:

• Identify and describe each strategic initiative the Postal Service used in FY 2022

• Explain how the strategic initiatives relate to the performance goals and 

performance indicators

• Describe the Postal Service’s progress toward completing each strategic initiative 

during FY 2022, and identify performance measures and results, if applicable

• Describe each strategic initiative the Postal Service will use in FY 2023, and provide 

performance measures and targets

• Explain in detail how the strategic initiatives changed between FY 2022 and 

FY 2023129

The Postal Service adopted some of these recommendations in the FY 2022 Report and FY 

2023 Plan and provided other information in CHIR responses. The Postal Service identifies 

each strategic initiative used in FY 2022 and aligns them with one or more performance 

goals. See FY 2022 Annual Report at 53. It previously described each strategic initiative in 

Docket No. ACR2021 and confirmed in a CHIR response that these descriptions apply to 

and remain current for the strategic initiatives implemented in FY 2022 and planned for 

FY 2023.130 The FY 2022 Report does not describe the Postal Service’s progress toward 

completing each strategic initiative in FY 2022. However, the Postal Service provided this 

information in three separate reports: the Delivering for America First-Year Progress 

Report (First-Year Progress Report); the report for FY 2022, Quarters 2 and 3 required by 

the Postal Service Reform Act (PSRA Report); and the Delivering for America Second-Year 

Progress Report (Second-Year Progress Report).

131

The Postal Service issued two progress reports on the 10-Year Strategic Plan that describe 

the Postal Service’s progress toward plan goals and reviews activities undertaken during 

the first two years after the 10-Year Strategic Plan was issued. The First-Year Progress 

129 FY 2021 Analysis at 124.

130 Docket No. ACR2021, Response to CHIR No. 21, question 2.a.; Response to CHIR No. 18, question 5.

131 United States Postal Service, Delivering for America First-Year Progress Report, April 7, 2022; available at 

https://about.usps.com/what/strategic-plans/delivering-for-america/assets/usps-dfa-one-year-report.pdf (First-Year Progress Report); United 

States Postal Service, Delivering for America, Responses of the United States Postal Service to the Reporting Requirements Specified in the Postal 

Service Reform Act of 2022, FY 2022 3rd and 4th Quarter, December 2, 2022; available at https://www.prc.gov/dockets/document/124453 (PSRA 

Report); United States Postal Service, Delivering for America Second-Year Progress Report, April 2023, at 3; available at 

https://about.usps.com/what/strategic-plans/delivering-for-america/assets/usps-dfa-two-year-report.pdf (Second-Year Progress Report). On 

June 2, 2023, the Postal Service filed with the Commission the Delivering for America progress report for FY 2023, Quarters 1 and 2. United 

States Postal Service, Delivering for America, Responses of the United States Postal Service to the Reporting Requirements Specified in the Postal 

Service Reform Act of 2022, FY 2023 1st and 2nd Quarter, June 2, 2023.
Analysis of FY 2022 Performance Report Strategic Initiatives

and FY 2023 Performance Plan

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Report describes progress through April 7, 2022, and the Second-Year Progress Report 

describes activities through April 2023. These reports also describe the Postal Service’s 

progress toward the strategic initiatives in FY 2022. For example, the Postal Service made 

progress toward the “Implement a More Rational Pricing Approach” strategic initiative by 

implementing new and existing pricing authority using the revised pricing framework for 

Market Dominant products. First-Year Progress Report at 7.

Section 207 of the PSRA requires the Postal Service to submit semi-annual reports to the 

President, the Commission, the Senate Committee on Homeland Security and Governmental 

Affairs, and the House Committee on Oversight and Reform describing the Postal Service’s 

operations and financial condition. PSRA § 207(a). Pursuant to this section, on December 2, 

2022, the Postal Service submitted the PSRA Report on the operations and financial 

condition of the Postal Service covering FY 2022 Quarters 3 and 4 (April 1, 2022 through 

September 30, 2022). The Postal Service must update the PSRA Report every six months 

through December 2, 2027. See PSRA § 207(a), (d).

The PSRA Report also describes the Postal Service’s progress toward the strategic 

initiatives during FY 2022, Quarters 3 and 4. The PSRA requires the Postal Service to report 

its progress on 15 postal areas, such as actual mail and package volume growth and the 

effect of pricing changes on product volume for Market Dominant and Competitive 

products. PSRA § 207(b). Most of these areas align with the strategic initiatives. Figure IV-1 

describes each strategic initiative and the Postal Service progress toward each one in 

FY 2022 based on the PSRA Report, First-Year Progress Report, and Second-Year Progress 

Report.
Analysis of FY 2022 Performance Report and FY 2023 Performance Plan Strategic Initiatives

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Figure IV-1

FY 2022 Strategic Initiatives, Descriptions,

a and FY 2022 Progress as Reported by the Postal Service

Strengthen Value of Mail and Sustain Public Service Mission, Including 6-Day Mail Deliveryb

• Increase the value of mail to senders by using new data-driven tools and 

promoting digital integration.

• Develop new programs, resources, and offerings that benefit businesses 

of all sizes, including enhancing Informed Delivery and Informed 

Visibility and mail promotions and incentives.

• Reinforced the Postal Service’s pu lic service mission and value of the mail committing to maintain -day 

delivery, expanding parcel delivery to 7 days a week.

• Processed/delivered more than 87 million COVID test kits in three weeks.

• Supported the 2021 election vote (FY 2022 Quarter 1) via:

o Delivery of 40.6 million ballots (to or from voters); and

o For ballots from voters to election officials specifically: an average delivery time of 1.4 days 

and 99.2 percent delivered within 3 days.

Implement Service Standards that Achieve Service Excellence 95 Percent of the Timec

• Modify existing service standards for letter- and flat-shaped First-Class 

Mail from a 1 to 3-Day Standard within the continental United States to a 

1 to 5-day service standard.

• Modify existing service standards for First-Class Package Service.

• Implemented new service standards for First-Class Mail, Periodicals, and First-Class Package Service.

• Increased on-time service performance results observed in FY 2022, Quarters 3 and 4 compared to FY 2021, 

Quarters 3 and 4 results for First-Class Mail, USPS Marketing Mail, Periodicals, and Package Services.

• Exceeded FY 2022 targets for First-Class Mail, USPS Marketing Mail, Periodicals, and Package Services during 

FY 2022, Quarters 3 and 4.

Innovate and Launch USPS Connect

• Support a new product offering, USPS Connect, which is a diverse suite of 

scalable and customizable solutions for businesses to reach their 

customers, including Local, Regional, National, and Returns offerings.d

• Implemented USPS Connect Local nationally to more than 3,400 facilities by the end of FY 2022 (with nearly 

2,100 facilities added in Quarters 3 and 4).

• Rebranded and implemented USPS Connect Regional to provide mailers with the ability to enter packages 

directly into the sortation network based on newly published Parcel machinable rates.

• Enhanced the USPS Connect Returns program by improving returns service and scanning performance in 

processing, delivery, and retail operations; adding automatic insurance of $100 for all Priority Mail packages, 

including returns; adding returns information to Informed Delivery; and enabling return labels printing at selfservice kiosks.
Analysis of FY 2022 Performance Report and FY 2023 Performance Plan Strategic Initiatives

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Modernize Delivery Vehicle Fleet and Implement Electric Fleet by 2035

• Upgrade the vehicle fleet, including the purchase and deployment of the 

Next Generation Delivery Vehicles.

• Leverage new technology to improve safety and comfort and increase 

delivery efficiency by providing more space for mail and packages.

• Congress passed the Inflation Reduction Act of 2022, which provided the Postal Service $1.29 billion to buy 

zero-emission delivery vehicles and $1.71 billion to develop infrastructure to support these vehicles.

• In December 2022, announced plans to acquire 106,000 new delivery vehicles, including at least 66,000 

battery electric-powered delivery vehicles, 45,000 battery electric-powered Next Generation Delivery 

Vehicles, and 21,000 commercial off-the-shelf vehicles that are expected to be battery electric-powered.

• Bought left-hand drive commercial off-the-shelf vehicles to replace minivans that reached the end of their 

useful life.

Implement Best-in-Class Processing Operations

• odernize the Postal Service’s operating plans.

• Invest in the logistics and processing network, including processing 

equipment investments, technology upgrades, and facility footprint 

realignment.

• Invested in processing automation and information technologies, including next general mobile delivery 

devices, package sorting systems, delivery unit sorters, and mail machine moves and disposals.

• Expanded facility footprint to an additional 13 million square feet across 100 locations.

• Leveraged National Distribution Centers and Processing and Distribution Centers to enter mail and package 

products via either:

o Origin-entry for processing and distribution to the entire country; or

o Destination-entry for processing and distribution to the local geographic area.

Implement Best-in-Class Delivery Operations

• Enhance delivery operations by driving operational precision; optimizing 

delivery units; modernizing route structures, investing in employees, 

technology, and systems; and deploying sortation equipment to delivery 

units.

• Bought and deployed Small Delivery Unit Sorter machines to support automated processing at delivery unit 

sites.

• Bought and deployed robotic induction systems for existing Parcel Sorting Machines to automate handling and 

induction of mail onto the machine sorters.

Implement a Modern, Transformed Network of Retail Post Offices

• Transform retail locations into a destination center for local businesses 

providing expert shipping and mailing solutions, including the alignment 

of retail locations to meet evolving customer needs.

• Expand partnerships with government partners to provide additional 

services to include passport services and fingerprint/biometric capture.

• In the process of investing in and designing retail locations to make them modern, go-to destinations meeting 

customer needs.

• Continued to build on partnership with the United States State Department to process passport applications.
Analysis of FY 2022 Performance Report and FY 2023 Performance Plan Strategic Initiatives

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• Since March 2021, implemented new programs, resources, and offerings designed to create a better customer 

experience, including launching Prepaid Acceptance Scanning, surpassing 50 million users for Informed 

Delivery, and partnering with e-commerce companies to expand the Label Broker service.

Implement a Fully Optimized Surface and Air Transportation Network

• Redesign the surface and air transportation network.

• Reduce reliance on air transportation for certain classes of mail.

• Deploy a state-of-the-art platform for end-to-end execution of a unified 

logistics operation.

• Used the most effective mode of transportation to reduce costs and improve reliability by implementing 

First-Class Mail and First-Class Package Service standard changes.

• Decreased the share of First-Class Mail and First-Class Package Service volumes transported via the air 

network.

Stabilize and Empower Workforce to Include Reducing Pre-Career Turnover

• Hire, develop, and retain capable and diverse employees.

• Reduce non-career employee turnover by half, expand career planning 

programs, elevate front-line leadership capabilities, establish an Executive 

Diversity Council, and enhance employee safety and wellbeing.

• Since October 2020, converted approximately 125,000 pre-careere employees into full-time career positions, 

including 50,000 conversions between April 2022 and March 2023.

• Hired 40,000 seasonal employees in early fall to allow adequate time for training and on-the-job experience.

o Reduced total workhours by 9.4 million (equivalent to $487 million in compensation and benefits) in FY 

2022 compared to FY 2021.

o Encouraged employees to take leave before the peak season and allowed flexible overtime during peak 

season.

• Implemented a right-sizing effort in mail processing to better align the workforce with operating plans and 

equipment needs, reduce the overtime demand on employees, achieve predictability and precision, and 

improve employee engagement and retention.

Align Organizational Structure to Support Effectiveness

• Design a high-performing organization with greater line of sight from 

strategy to business outcomes focusing on Retail and Delivery, Logistics 

and Processing, and Commerce and Business

• Accept, process, and deliver mail and packages more efficiently. Use 

infrastructure to enable growth.

• Design a high-performing organization with greater line of sight from strategy to business outcomes focusing 

on Retail and Delivery, Logistics and Processing, and Commerce and Business

• Accept, process, and deliver mail and packages more efficiently.

• Use infrastructure to enable growth.
Analysis of FY 2022 Performance Report and FY 2023 Performance Plan Strategic Initiatives

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Support Legislative and Administrative Actions

• Create a legislative and administrative framework that aligns with the 

Postal Service’s needs.

• Request integrating Medicare with Postal Service health plans and 

eliminating pre-funding obligations stemming from the PAEA.

• Correct the unfair allocation of CSRS benefits for legacy Post Office 

Department employees.

• Create a legislative and administrative frame or that aligns ith the Postal Service’s needs.

• Request integrating Medicare with Postal Service health plans and eliminating pre-funding obligations 

stemming from the PAEA.

• Correct the unfair allocation of CSRS benefits for legacy Post Office Department employees.

Implement a More Rational Pricing Approach

• Align the Postal Service’s pricing strategies ith operational and 

marketplace needs by applying new Commission rules on Market 

Dominant product pricing above CPI.

• Review all Competitive postal products and services for opportunities to 

drive higher revenue based on needs.

• Align the Postal Service’s pricing strategies ith operational and mar etplace needs appl ing ne 

Commission rules on Market Dominant product pricing above CPI.

• Review all Competitive postal products and services for opportunities to drive higher revenue based on needs.

Source: FY 2022 Annual Report at 18; First-Year Progress Report at 1-7; PSRA Report at 8-26; Second-Year Progress Report at 4-29.

a The Postal Service provided descriptions of each strategic initiative in Docket No. ACR2021, Response to CHIR No. 21, question 2.a.

b PSRA § 202(a) requires delivery to be made at least 6-days a week (codified in 39 U.S.C. § 101(b)).

c PSRA § 201(a) requires the Postal Service to file reasonable performance targets for each Market Dominant product with the Commission for each fiscal year both pre- and post-implementation (codified in 39 U.S.C. § 

3692(a)(1-2)).

d USPS Connect Local offers expected same-day or next-day delivery to customers who are located within the same ZIP Code as participating Postal Service facilities. PSRA Report at 12. USPS Connect Local shipping and 

mailing shipping and mailing supplies are available at no additional cost when postage is printed and paid through the Click-N-Ship application. Id. USPS Connect Regional provides shippers mailers who need expanded 

geographical reach direct access to plants and distribution centers across the country for next-day and two-day delivery services. Id. at 13. SPS Connect Returns enhances the Postal Service’s return shipping options 

through network and technology investments and improvements. Id. at 14.

e The Postal Service uses the term “pre-career” to refer to part-time workers. Response to CHIR No. 7, questions 29.a.- . “Through the collective argaining process, the Postal Service negotiated a provision that provides a 

path to career employment for all pre-career employees who remain in [the Postal Service’s] emplo for 24 months. The current agreements allo pre-career employees, who stay employed with the Postal Service for two 

 ears, to e automaticall converted to career status.” Id.

f See 39 C.F.R. part 3030; Order No. 5763.

g Docket No. R2022-1, Order on Price Adjustments for First-Class Mail, USPS Marketing Mail, Periodicals, Package Services, and Special Services Products and Related Mail Classification Changes, May 27, 2022 (Order No. 

 188 finding that the Postal Service’s planned pricing and classification adjustments were consistent with applicable law and may take effect as planned July 10, 2022).

h Docket No. CP2022-22, Order Approving Changes in Rates of General Applicability for Domestic Competitive Products, December 21, 2021 (Order No. 6071), as amended by Docket No. CP2022-22, Notice of Erratum, 

December 22, 2021 finding that the Postal Service’s planned pricing and classification adjustments ere consistent ith applica le la and ma take effect as planned January 9, 2022); Docket No. CP2022-62, Order 

Approving Changes in Rates and Classifications of General Applicability for Competitive Products, June 8, 2022 (Order No. 619 finding that the Postal Service’s planned pricing and classification adjustments were 

consistent with applicable law and may take effect as planned July 10, 2022).
Analysis of FY 2022 Performance Report Strategic Initiatives

and FY 2023 Performance Plan

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On April 20, 2023, the Commission found it would be beneficial to provide a forum to 

examine the recent and planned network changes associated with the Postal Service’s 10-

Year Strategic Plan and therefore initiated Docket No. PI2023-4 for such purpose. See Order 

No. 6488. Given the public interest and potential for significant impact on the postal 

industry, the Commission observes that the FY 2023 Report could be improved by including 

information and/or cross-references to the 10-Year Strategic Plan progress reports, PSRA 

reports, or other documents that describe the Postal Service’s progress in FY 2023 toward 

the goals and initiatives in the 10-Year Strategic Plan.

In the FY 2021 Analysis, the Commission recommended that the Postal Service describe 

each strategic initiative the Postal Service will use in FY 2023, provide related performance 

measures and targets, and explain in detail how the strategic initiatives changed between 

FY 2022 and FY 2023. FY 2021 Analysis at 124. In the FY 2023 Plan, the Postal Service 

identifies the strategic initiatives it will use in FY 2023 and provided performance 

measures and targets in a CHIR response.132 In the FY 2023 Plan, the Postal Service states 

that each strategic initiative was refined for FY 2023 but does not explain how they were 

refined. See FY 2022 Annual Report at 52-53. In a CHIR response, the Postal Service 

explained that the strategic initiatives are updated to reflect new annual targets set for the 

performance indicators, and all strategic initiatives have been refined to align with FY 2023 

targets. Response to CHIR No. 27, question 1. It provided tables showing, for each strategic 

initiative, the corresponding performance indicators and FY 2023 targets. Id. The FY 2024 

Plan could be improved by describing in detail how each strategic initiative changed 

between FY 2023 and FY 2024 or including specific cross-reference to other documents 

that contain this information.

In the FY 2023 Report and FY 2024 Plan, the Commission recommends that the Postal Service:

• Identify and describe each strategic initiative the Postal Service used in FY 2023.

• Explain how the strategic initiatives relate to the performance goals and performance 

indicators.

• Describe the Postal Service’s progress toward completing each strategic initiative 

during FY 2023 or include cross-references to the 10-Year Strategic Plan progress 

reports, PSRA reports, or other documents that contain this information.

• Describe each strategic initiative the Postal Service will use in FY 2024, and provide 

performance measures and targets, if applicable.

• Explain in detail how the strategic initiatives changed between FY 2023 and FY 2024.

132 FY 2022 Annual Report at 53; Response to CHIR No. 18, question 6.
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 1 of 8

Appendix A: Commission Findings and 

Recommendations

Chapter II - Compliance with 39 U.S.C. §§ 2803 and 2804:

• The Commission finds that the FY 2023 Plan complies with all requirements of 

39 U.S.C. § 2803(a).

• The Commission finds that the FY 2022 Report complies with 39 U.S.C. § 2804(b)(1). To 

comply with 39 U.S.C. § 2804(b)(1) next year, the FY 2023 Report must set forth the 

same performance indicators and targets as the FY 2023 Plan and compare FY 2023 

targets and results for each performance indicator.

• The FY 2023 result for each performance indicator must be comparable to the 

corresponding FY 2023 target set in the FY 2023 Plan. If a comparable FY 2023 result 

is not provided, the FY 2023 Report must address the lack of comparability by 

explaining either of the following:

1. How to compare results between the current and former methodologies; or

2. Why making this comparison is not feasible.

• The Commission recommends that the Postal Service not change performance 

indicators, methodologies, or targets once they are set for a given fiscal year.

• Except for the Excellent Customer Experience performance goal, the FY 2022 Report 

complies with 39 U.S.C. § 2804(c). The FY 2022 Report is non-compliant with respect to 

this performance goal because CCC performance indicator results are not comparable 

from FY 2019 through FY 2022, and the Postal Service did not provide the 

explanations required by the Commission.

To comply with 39 U.S.C. § 2804(c) next year, the FY 2023 Report must include 

comparable results for each performance indicator for FYs 2020, 2021, 2022, and 

2023. To be comparable, results for each fiscal year must be calculated and expressed 

using the same methodology. If comparable results from FY 2020 through FY 2023 are 

not provided for any performance indicator, the FY 2023 Report must:

1. Identify each performance indicator with non-comparable results from 

FY 2020 through FY 2023; and

2. Address the lack of comparability by explaining either of the following:

a. How to compare results from FY 2020 through FY 2023 between the 

current and former methodologies; or

b. Why making this comparison is not feasible.
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 2 of 8

• The FY 2023 Report must include all information necessary to evaluate compliance 

with the requirements of 39 U.S.C. §§ 2803 and 2804, including section 2804(c). 

Inclusion of this information in the FY 2023 Report may be satisfied by either: (1) 

including the information itself in the text of the FY 2023 Report; or (2) including 

cross-references identifying the documents containing this information in the text of 

the FY 2023 Report.

• The Commission finds that the FY 2022 Report complies with 39 U.S.C. § 2804(d)(3) 

because it explains why performance goals were partially met and describes plans and 

schedules for meeting the goals in FY 2023. To comply with 39 U.S.C. § 2804(d)(3) next 

year, for each FY 2023 target that is not met, the FY 2023 Report must both explain 

why and describe plans and schedules for meeting the FY 2024 targets.

• The Commission finds that the FY 2022 Report complies with 39 U.S.C. §§ 2804(d)(1), 

(2), and (4).

• The Commission finds that Library Reference USPS-FY22-NP30 complies with the 

Commission’s directives in the FY 2021 Analysis. For the non-public performance 

indicators, the FY 2023 Plan complies with 39 U.S.C. § 2803(a)(2) by setting 

measurable FY 2023 target(s) for each performance indicator the Postal Service will 

use in FY 2023. See Section B.1., supra. The FY 2022 Report complies with 39 U.S.C. § 

2804(b)(1) and 2804(c) because it provides comparable FY 2022 targets and results 

as well as comparable results from the past 3 fiscal years. See Sections B.2.a., b., supra. 

The FY 2022 Report also complies with 39 U.S.C. § 2804(d)(3) because the Postal 

Service explains why it did not meet FY 2022 target(s) and describes plans and 

schedules for meeting FY 2023 target(s).

• To ensure that the FY 2024 Plan and FY 2023 Report comply with 39 U.S.C. §§ 2803 

and 2804, respectively, the Commission recommends that the Postal Service continue 

to explain where to find information on the non-public service performance indicators, 

such as in a footnote in the master table of targets and results. For the Competitive 

products’ non-public performance indicator(s), the Postal Service must file under seal 

with the FY 2023 ACR: (1) FY 2023 and FY 2024 targets; (2) comparable FY 2023 

targets and results; and (3) comparable results from FY 2020 through FY 2023. If the 

Postal Service does not meet the FY 2023 target for any non-public performance 

indicator, the Postal Service must explain why and describe the plans and schedules for

meeting the FY 2024 target. The FY 2023 ACR should continue to identify the library 

reference that contains this information.

• To ensure meaningful comparisons across fiscal years, the Commission recommends 

that the Postal Service continue to limit the number of changes to performance 

indicators and methodologies for calculating targets and results. If the Postal Service 

plans to add or change any performance indicators or methodologies, the Commission 

recommends that the Annual Report to Congress describe these changes, provide the 

rationale for making them, and analyze the impact of these changes on results. To help 

ensure compliance with 39 U.S.C. § 2804(c), if the Postal Service changes a 
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 3 of 8

performance indicator or the methodology for calculating targets or results, the 

Commission recommends that the Postal Service maintain the same performance 

indicator or methodology for at least 3 consecutive fiscal years unless the change is 

clearly not beneficial or effective.

Chapter III – Evaluation of Performance Goals:

High-Quality Service:

• The Commission commends the Postal Service for its efforts to deliver COVID-19 test 

kits. These efforts demonstrate the Postal Service’s vital role in the COVID-19 pandemic 

response.

• The Commission finds that the High-Quality Service performance goal was partially 

met in FY 2022, with the Postal Service failing to meet one performance indicator 

related to Market Dominant products.

• The Commission continues to recommend that the Postal Service develop more 

granular composite indicators for service performance based on significant class, 

shape, and product-level differences between mailpieces. If the Postal Service 

continues using highly aggregated composites as performance indicators, then the 

Commission recommends that the Postal Service also develop more granular 

performance indicators, such as it currently uses for First-Class Mail, to supplement 

the highly aggregated composites. Finally, the Commission expects the Postal Service 

to include with each Annual Report supporting workpapers containing the inputs for, 

and a detailed calculation of, the High-Quality Service performance indicator results, 

to the extent that they are not included elsewhere in the ACR filing.

• In the FY 2023 Report, the Postal Service should address whether any service standard 

changes implemented in FY 20231 affected the comparability of performance indicator 

results. If comparability has been affected, the Postal Service should propose a way for 

the Commission to compare FY 2023 High-Quality Service performance indicator 

results to results from prior fiscal years. If the Postal Service asserts that comparability 

is unaffected, the Postal Service should fully explain the rationale and supporting basis 

for this assertion. The Postal Service should also consider methodologies to study the 

effect of service standard changes on OPP at affected facilities.

• The Commission encourages the Postal Service to continue reviewing routings and 

streamlining its network to reduce complexity, improve reliability, and improve service 

performance for the Single-Piece First-Class Mail 3- 5-Day performance indicator.

1 For example, the change in CETs for certain categories of Periodicals, effective January 29, 2023. See United States Postal Service, Changes to 

Periodical Critical Entry Times, Effective January 29, 2023, USPS Postal Pro (Dec. 29, 2022), available at https://postalpro.usps.com/node/11634; 

see also Docket No. N2022-2, Advisory Opinion on Changes to the Critical Entry Times for Certain Categories of Periodicals, November 30, 2022 

(Docket No. N2022-2, Advisory Opinion).
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 4 of 8

• The Commission recommends that the Postal Service consider the additional 

processing requirements for single-piece volumes when devising targets in the future. 

As these requirements and associated challenges can be anticipated based on 

experience, they should be accounted for in developing applicable targets.

• If the Postal Service experiences higher-than-expected failure in certain processes 

relating to the processing of single-piece volumes and does not achieve any of its 

single-piece performance targets in FY 2023, it should explain the reasons why failures 

in processing single-piece volumes exceed expectations and identify the operational 

processes experiencing the failures.

• The Commission commends the Postal Service’s FY 2022 and FY 2023 initiatives to 

make proactive plans to provide High-Quality Service during peak seasons, and it 

recommends that the Postal Service continue monitoring and optimizing peak season 

performance.

• The Commission recommends that the Postal Service continue to monitor fluctuations 

in employee availability and its impact on service performance.

• The Commission recommends that the Postal Service continue initiatives to reduce 

supplier failure, improve supplier capacity, and increase its efforts to address CLTs 

whose causes are within its direct control.

• The Commission supports the Postal Service’s renewal of the Unexpected Events 

Initiative, and it recommends that the Postal Service report on its progress in 

developing, and any results from, the Unexpected Events Initiative in the FY 2023 

Report, including any effect on reducing CLTs.

• The Commission commends the Postal Service for its efforts devoted to delivering 

Election Mail and Political Mail during the CY 2022 election cycle. These efforts were 

undertaken notwithstanding the adverse effects of the COVID-19 pandemic, in 

furtherance of the vital role the Postal Service plays in the American democratic 

process.

• In all future Annual Reports through the first year following completion of the 10-Year 

Strategic Plan, the Commission recommends that the Postal Service report how the 10-

Year Strategic Plan (as a whole and for applicable distinct initiatives) affected the 

High-Quality Service performance indicator result.

• The Commission continues to recommend that the Postal Service explore ways to 

better balance service performance scores across the nation and study the reasons for 

service performance issues in the lowest performing Areas/Districts.

Excellent Customer Experience:

• The Commission finds that the Postal Service partially met the Excellent Customer 

Experience performance goal in FY 2022 because it missed five targets and met or 

exceeded three targets.
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 5 of 8

• The Commission recommends that the Postal Service consider asking questions on the 

C360 survey about mail theft to collect more data and evaluate its impact on C360 

performance indicator results. The Commission also recommends that the Postal 

Service consider adding questions to the Delivery survey about missed mail or nondelivery of mail to gather more data on this issue.

• In FY 2023, the Commission recommends that the Postal Service strive to improve 

performance indicator results by targeting key drivers of overall satisfaction. For the 

C360 performance indicator, the Commission recommends that the Postal Service 

strive to improve successful resolution of customer issues, which is a key driver for 

C360 overall satisfaction.

• The Commission finds that the FY 2023 targets for the Excellent Customer Experience 

performance indicators are reasonable. It reiterates its recommendation that the 

Postal Service consider the prior year’s result when setting the subsequent year’s 

target. To improve transparency, the FY 2024 Plan should discuss the rationale for 

setting the FY 2024 targets.

• The Commission recommends that the Postal Service continue to use the NPS to 

measure and assess CX in FY 2023. The Commission also recommends the Postal 

Service focus its efforts on improving the C360 NPS result to have a higher percentage 

of Promoters than Detractors and continue its efforts to improve NPS results for the 

other CX surveys.

• The Commission finds that the Postal Service is effectively using social listening to 

determine what people are saying about its brand and services on social media. The 

social media heat map is an effective tool for visualizing customer comments and 

categorizing them by concern and geographic area. The Commission recommends that 

the Postal Service continue to use social listening and the social media heat map to 

improve CX in FY 2023.

• The Commission commends the Postal Service for continuing to expand its efforts to 

respond to customer inquiries via social media. The Commission encourages the Postal 

Service to continue using the Facebook ChatBOT, AIVA, and other AI tools to continue 

helping customers and to improve the response time for customer inquiries.

Safe Workplace and Engaged Workforce:

• The Commission finds that the Postal Service partially met the Safe Workplace and 

Engaged Workforce performance goal in FY 2022.

• The Commission commends the Postal Service for meeting the Total Accident Rate 

target for the fourth year in a row and achieving the best result since the Postal 

Service began using the Total Accident Rate as a performance indicator in FY 2017. 

The Postal Service’s continued use of workplace safety data analysis tools and the 

Safety Intervention and Recognition Program appear to have been effective in 
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 6 of 8

promoting a safe workplace in FY 2022 because the number of accidents decreased for 

each accident type.

• The Commission finds that the FY 2023 Total Accident Rate target is reasonable 

considering the changes in FY 2023 that could increase the potential for safety 

incidents. The Postal Service’s plans to continue using the OSH Scorecard and SHMT in 

FY 2023 appear designed to improve employee safety and the Total Accident Rate. The 

Commission recommends that in the FY 2023 Report, the Postal Service describe 

efforts to promote a safe workplace in FY 2023 and plans to improve employee safety 

in FY 2024.

• The Commission recommends that the Postal Service continue to recognize employees 

that promote a safe workplace and motor vehicle safety in quarterly newsletters and 

other publications. Also, the Commission recommends that the Postal Service continue 

to monitor the safety and performance of contractor-operated motor vehicles 

(including vehicles operated by subcontractors of freight brokers) and address safety 

incidents shortly after they occur to help prevent future incidents and unsafe practices.

• The Commission is concerned that mean scores for almost every question on the Postal 

Pulse survey decreased in FY 2022 but acknowledges that none of the scores declined 

by more than 0.08 points on the survey scale. The decline in employee engagement is 

consistent with employee engagement levels across the country in recent years. If the 

Grand Mean Engagement Score continues to decline or does not increase in FY 2023, 

the Commission recommends that the FY 2023 Report identify all reasons for employee 

dissatisfaction that are specific to Postal Service employees and analyze the impact of 

postal-related changes on employee engagement.

• The FY 2023 target is reasonable considering the range of Grand Mean Engagement 

Scores during the past few years. The Postal Service’s plans to implement engagement 

initiatives for front-line supervisors and newly hired pre-career employees are 

reasonable steps for improving the Grand Mean Engagement Score and overall 

employee engagement. The Commission recommends that the Postal Service continue 

implementing and expanding pilot programs to improve employee engagement and 

retention for both career and non-career employees. Also, in the FY 2023 Report, the 

Commission recommends that the Postal Service describe how the implementation of 

these initiatives affected the FY 2023 Grand Mean Engagement Score.

• The Commission recommends that the Postal Service implement the programs 

described in the FY 2023 Plan to improve the Engagement Survey Response Rate in FY 

2023. If the rate does not improve in FY 2023, the Commission recommends that the 

Postal Service investigate and address the root causes and describe its efforts to do so 

in the FY 2023 Report.

Financial Health:

• The Commission finds that the Postal Service met the Financial Health performance 

goal in FY 2022.
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 7 of 8

• The Commission recommends that the Postal Service continue to include information 

on Controllable Income (Loss) and non-controllable expenses in future annual 

performance plans and annual performance reports.

• In all future Annual Reports through the first year following completion of the 10-Year 

Strategic Plan, the Postal Service should report on the effects of the 10-Year Strategic 

Plan on: (1) the Postal Service’s Financial Health performance indicator results; and 

(2) labor productivity.

• The Commission encourages the Postal Service to communicate with its stakeholders 

to gather their views of the effects of rate increases on volume.

• Because of the challenges of characterizing expenses as controllable or noncontrollable, and because of the limited categories of expenses that the Postal Service 

deems non-controllable, the Commission recommends that the Postal Service consider 

whether a GAAP measure such as Net Income (Loss) or Net Operating Income (Loss) 

offers a more useful indication of the Postal Service’s financial health and whether 

such a metric should be used as a performance indicator in lieu of, or in addition to, 

Controllable Income (Loss). If the Postal Service makes changes to, or supplements, the 

Controllable Income (Loss) performance indicator in its FY 2023 Report, the Postal 

Service should also provide comparable performance indicator results for FY 2020 

through FY 2023 to help ensure compliance with 39 U.S.C. § 2804(c).

• The Commission recommends that the Postal Service continue monitoring and 

reporting TFP and labor productivity trends. The Commission recommends that future 

annual performance reports continue to include information on TFP, labor 

productivity, and other productivity measures. In addition, the Postal Service should 

explain the reason for any changes in TFP and/or labor productivity in FY 2023.

• The Commission continues to recommend that the Postal Service consider adopting 

one or more additional performance indicators for measuring progress towards the 

Financial Health performance goal. Specifically, the Commission recommends that the 

Postal Service consider incorporating the operating ratio, or another measure 

associated with operational efficiency, as a performance indicator.

Chapter IV - Strategic Initiatives:

In the FY 2023 Report and FY 2024 Plan, the Commission recommends that the Postal Service:

• Identify and describe each strategic initiative the Postal Service used in FY 2023.

• Explain how the strategic initiatives relate to the performance goals and performance 

indicators.

• Describe the Postal Service’s progress toward completing each strategic initiative 

during FY 2023 or include cross-references to the 10-Year Strategic Plan progress 

reports, PSRA reports, or other documents that contain this information.
Analysis of FY 2022 Performance Report Appendix A

and FY 2023 Performance Plan Page 8 of 8

• Describe each strategic initiative the Postal Service will use in FY 2024, and provide 

performance measures and targets, if applicable.

• Explain in detail how the strategic initiatives changed between FY 2023 and FY 2024.
Analysis of FY 2022 Performance Report Appendix B

and FY 2023 Performance Plan Page 1 of 2

Appendix B - Figure 1

FY 2024 Plan Checklist for Compliance

with Major Requirements of 39 U.S.C. § 2803(a)

Note: The statutory requirements apply to both public and non-public performance indicators. The FY 2024 Plan and FY 2023 Report must 

include all information necessary to evaluate compliance with 39 U.S.C. §§ 2803 and 2804, which may be satisfied by either: (1) including the 

information itself in the text of the FY 2024 Plan or FY 2023 Report; or (2) including cross-references identifying the documents containing this 

information in the text of the FY 2024 Plan or FY 2023 Report. Further information appears in Chapter II, Sections B.1 and B.3., supra.
Analysis of FY 2022 Performance Report Appendix B

and FY 2023 Performance Plan Page 2 of 2

Appendix B - Figure 2

FY 2023 Report Checklist for Compliance

with Major Requirements of 39 U.S.C. § 2804

Note: The statutory requirements apply to both public and non-public performance indicators. The FY 2024 Plan and FY 2023 Report must 

include all information necessary to evaluate compliance with 39 U.S.C. §§ 2803 and 2804, which may be satisfied by either: (1) including the 

information itself in the text of the FY 2024 Plan or FY 2023 Report; or (2) including cross-references identifying the documents containing this 

information in the text of the FY 2024 Plan or FY 2023 Report. Further information appears in Chapter II, Sections B.2. and B.3., supra.