GAO 

United States Government Accountability Office

Report to Congressional Requesters

U.S. POSTAL 

SERVICE 

The Program for 

Reassessing Work 

Provided to Injured 

Employees Is Under 

Way, but Actions Are 

Needed to Improve 

Program Management 

December 2009 

GAO-10-78 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

December 2009

U.S. POSTAL SERVICE

The Program for Reassessing Work Provided to 

Injured Employees Is Under Way, but Actions Are 

Highlights of GAO-10-78, a report to Needed to Improve Program Management 

congressional requesters 

Between 50,000 and 60,000 United 

States Postal Service (Service) 

employees, or 7 to 8 percent of the 

Service’s workforce, occupied a 

modified work assignment during 

fiscal year 2008. The Service must 

provide these assignments to 

employees with workplace injuries 

if work is available to perform 

within their medical restrictions. 

Historically, the Service has 

returned employees to work as 

soon as possible, partly to reduce 

its costs for workers’ 

compensation. In 2006, the Service 

initiated a program, the National 

Reassessment Process, to ensure 

that modified work assignments 

are medically suitable and 

necessary to carry out the Service’s 

mission. This requested report 

addresses (1) the goal of the 

program, (2) how it is being 

implemented, and (3) the 

program’s status and outcomes. To 

perform its work, GAO analyzed 

data and documentation, visited 

four districts selected to illustrate a 

range of conditions, and 

interviewed Service officials. 

What GAO Recommends

GAO recommends that the Service 

establish program completion 

timelines, track and measure 

outcomes, and disclose limitations 

of its reported cost savings. The 

Service agreed with GAO’s third 

recommendation and disagreed 

with the other two. While GAO 

modified one recommendation in 

response to the Service’s 

comments, GAO retained all three 

to encourage program completion, 

accountability, and transparency. 

The goal of the National Reassessment Process is to ensure that all employees 

in modified work assignments are performing work that is both suitable to 

their medical restrictions and necessary to the Service’s mission. Among 

other things, the program aims to eliminate what Service officials call “make–

work” assignments which, over time, occurred when factors such as 

increasing automation and declining mail volumes reduced the amount of 

manual, sedentary, and useful work available for these employees to perform. 

The number of employees reassessed under the program is not readily 

available nationwide because the Service does not aggregate district data. 

However, on September 30, 2008, there were 31,044 employees in modified 

work assignments, all of whom may have been reassessed under the program.

The program is being implemented in three phases in the Service’s 74 districts. 

In Phase 1, the Service ensures that all employee medical records are current, 

and categorizes the employees based on their medical status. In Phases 2 and 

3, the Service attempts to find each employee medically suitable and 

necessary work. If successful, the Service provides these employees with 

modified work assignments. However, when suitable work is not available, 

employees become eligible for wage loss compensation (workers’ 

compensation). Specifically, because employees in Phase 2 have reached their 

maximum medical improvement, they are not expected to return to work for 

the Service and, thus, may receive workers’ compensation indefinitely, 

whereas Phase 3 employees are eligible for workers’ compensation for only 

the number of hours they cannot work for the Service. Initially, the Service 

implemented each phase of the program sequentially; however, in July 2009, it 

began allowing some districts to conduct Phases 2 and 3 concurrently to 

expedite the program’s completion. The Service has not established 

milestones for completing the program, but, according to Service officials, 

they expect the program to be fully implemented by September 30, 2010. 

After 3 years, none of the Service’s districts had completely implemented the 

program, and implementation in most is far from complete. Available data on 

employee outcomes are limited and preliminary because implementation is 

ongoing, and the Service does not track employees who receive medically 

suitable and necessary work—the goal of the program. The Service achieves 

program cost savings when, for example, employees return to full duty, retire, 

resign, or perform modified work assignments. However, when suitable work 

is not available, some employee outcomes could increase the Service’s shortand long-term costs for workers’ compensation. For the year ending June 30, 

2009, workers’ compensation costs totaled about $1.1 billion and, in 2008, the 

Service estimated that its future liability for these costs totaled about $8 

billion. The Service reported to the Congress that the program saved $146 

million in fiscal year 2008. However, the Service did not disclose that these 

reported savings reflect neither the Service’s total gross savings nor its net 

savings, nor any other limitations in its cost estimation methodology. View GAO-10-78 or key components.

For more information, contact contact Phillip 

Herr, (202) 512-2834, or Herrp@gao.gov. 
Page i GAO-10-78 

Contents 

Letter 1

Background 4 

The Goal of the NRP Is to Ensure That All Employees in Modified 

Work Assignments Are Performing Medically Suitable, 

Necessary Work 10 

The Service Is Implementing the NRP in Three Phases, Which Take 

Many Months to Complete 11 

Despite Incomplete NRP Implementation, the Service Estimated 

$146 Million in Savings during Fiscal Year 2008 21 

Conclusions 30 

Recommendations for Executive Action 30 

Agency Comments and Our Evaluation 31 

Appendix I Objectives, Scope, and Methodology 33 

Appendix II Methodology for Determining Number of Service 

Employees Who Occupied (or Could Have) a 

Modified Work Assignment 36 

Appendix III Number, Percentage, and Distribution of 

Modified Work Assignments Nationwide during 

Fiscal Year 2008 38 

Appendix IV Description of NRP Activities, by Phase and 

Step 42 

Appendix V Comments from the United States Postal Service 45 

Appendix VI GAO Contact and Staff Acknowledgments 47 

 U.S. Postal Service 
Tables 

Table 1: The Four Largest Postal Unions and the Primary Crafts 

Each Union Represents 5 

Table 2: Number, Percentage, and Distribution of Service 

Employees in Modified Work Assignments Nationwide 

during Fiscal Year 2008 38 

Figures 

Figure 1: How a Physician’s Determination about a Service 

Employee’s MMI Status Affects the Type of Modified 

Work Assigned to the Employee 7 

Figure 2: Key NRP Activities, Stages, and Possible Employee 

Outcomes, by Phase 13 

Figure 3: NRP Outcomes Experienced by Service Employees in 

Modified Work Assignments 16 

Figure 4: Overall Status of NRP Implementation, by Phase, as of 

August 31, 2009 22 

Figure 5: Status of NRP Implementation for Phases 1 and 2, by 

Step, as of August 31, 2009 23 a

Figure 6: Description of NRP Activities in Phase 1 42 

Figure 7: Description of NRP Activities in Phase 2 43 

Figure 8: Description of NRP Activities in Phase 3 44 

Abbreviations 

DOL Department of Labor 

GAO Government Accountability Office 

MMI maximum medical improvement 

NRP National Reassessment Process 

NWA no work available 

OWCP Office of Workers Compensation Programs 

Service United States Postal Service 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page ii GAO-10-78 U.S. Postal Service
Page 1 GAO-10-78 

 

United States Government Accountability Office

Washington, DC 20548 

December 14, 2009 

The Honorable Stephen F. Lynch 

Chairman 

Subcommittee on Federal Workforce, Postal Service, 

 and the District of Columbia 

Committee on Oversight and Government Reform 

House of Representatives 

The Honorable Danny K. Davis 

House of Representatives 

In fiscal year 2008, the United States Postal Service (Service) had about 

748,000 employees, representing about 25 percent of all federal employees. 

These employees also accounted for about 42 percent of all federal 

traumatic workplace injuries and occupational illnesses (injuries).1

According to Service officials, the high rate of employee injuries arises 

largely from the often physically demanding, industrial, and highly 

repetitive nature of their work. Some injured employees recover from their 

injuries quickly and return to work without medically prescribed physical 

restrictions (medical restrictions), while others require long-term, 

modified work assignments to accommodate their medical restrictions. 

Based on our analysis, there were between 50,000 and 60,000 postal 

employees, or about 7 to 8 percent of the Service’s workforce, in these 

assignments at some point during fiscal year 2008, the most recent year for 

which complete data were available. Not included in this number are 

employees with workplace injuries who have medical restrictions that 

preclude them from returning to work for the Service in any capacity.2

When employees are able to return to work after a compensable 

workplace injury, federal agencies, including the Service, are required to 

employ them if work is available that they can accomplish within their 

1

For purposes of this report, we generally refer to both traumatic injuries, such as injuries 

arising from vehicular crashes, and occupational illnesses, such as carpal tunnel syndrome, 

as “injuries.” 

2

Because these employees are not in modified work assignments, they are not included in 

the scope of this review. 

 U.S. Postal Service
medical restrictions.3

 In the 1990s, the Service aggressively pursued the 

return of employees to work as soon as possible as a means to (1) help 

employees recover more quickly and stay up to date with workplace 

changes and (2) reduce the Service’s costs for workers’ compensation.4

According to senior headquarters officials, the Service’s previous practice 

often resulted in bringing employees back to work in “make-work” 

assignments without regard to productivity. In addition, they said that the 

practice created a workplace culture in which employees believed they 

were entitled to modified work assignments, regardless of whether the 

assignment was needed for the Service’s mission. 

In 2006, the Service introduced a new, agencywide initiative—the National 

Reassessment Process (NRP)—to revise its practices for assigning 

modified work to injured employees. The Service’s Office of Health and 

Resource Management is responsible for implementing the NRP. 

Numerous other postal officials are also involved through a phased 

implementation approach. The NRP is being carried out in the Service’s 74 

districts,5

 with supervision from headquarters and area officials, and 

focuses on reassessing employees in modified work assignments to 

determine whether the assignments are (1) within the employees’ medical 

restrictions (medically suitable work) and (2) necessary to carry out the 

Service’s mission. 

 

3

Under the Americans with Disabilities Act of 1990, codified as amended at 42 U.S.C. § 

12101 et seq., employers are required to make “reasonable accommodations” for qualified 

individuals with disabilities, unless to do so would require undue hardship (e.g., creating a 

new position.) See 42 U.S.C. §§ 12112(b)(5), 12111(10). The Rehabilitation Act of 1973, Pub. 

L. No. 93-112, 87 Stat. 355, applies these standards to federal agencies, including the Postal 

Service. See 29 U.S.C. § 791, 39 C.F.R. § 255.5, 29 C.F.R. § 1614.203. 

4

Payments to federal employees for compensable work-related injuries and illnesses are 

authorized by the Federal Employees’ Compensation Act, 39 Stat. 743 (1916), codified as 

amended at 5 U.S.C. chapter 81, and administered by the Office of Workers’ Compensation 

Programs within the Department of Labor. The Department of Labor provides benefits to 

workers injured on the job, including wage loss compensation, payments for medical care 

and, where necessary, vocational rehabilitation training and assistance in returning to 

work. The department charges these expenses back to the federal agencies in order to be 

reimbursed for making payments to their employees. 

5

When we began our review in October 2008, there were 80 postal districts. The Service 

subsequently eliminated 6 districts, and their activities were absorbed by other districts. 

While there are currently 74 districts, we report available information on the status and 

outcomes of 75 districts because 1 of these had not fully distributed its employee files, 

including those related to the NRP, to other postal districts. 

Page 2 GAO-10-78 U.S. Postal Service
Because of congressional interest in the large number of postal employees 

in modified work assignments and whether these employees are being 

productively employed, we were asked to review the NRP. This report 

addresses the following objectives: (1) What is the goal of the NRP? (2) 

How is the program being implemented? (3) What is the status of the NRP, 

and what outcomes have been achieved? 

To address these objectives, we reviewed and analyzed, among other 

documentation, (1) applicable laws, regulations, and postal policies and 

procedures for protecting federal employees who sustain compensable 

workplace injuries, including their rights with respect to job restoration; 

(2) documentation describing the NRP’s goal and the process for 

implementing the initiative, as well as available data on its status and 

outcomes; and (3) documentation and views on the NRP from the four 

largest postal unions. We also interviewed a wide range of Service 

officials, and officials within the Department of Labor’s (DOL) Office of 

Workers’ Compensation Programs (OWCP), which makes wage loss and 

other payments to federal employees with compensable workplace 

injuries. To determine the number of employees in modified work 

assignments during fiscal year 2008, we analyzed data from each of the 

Service’s districts and headquarters and determined that the Service’s data 

were sufficiently reliable for our reporting purposes. To obtain views on 

the NRP, we also visited four postal districts—San Francisco, Westchester, 

the Dakotas, and Dallas—and contacted officials in four other districts—

Sierra Coastal, Southeast New England, Los Angeles, and Santa Ana.6

Finally, we reviewed prior reports and literature on the value of returning 

injured employees to work as soon as possible; reports on the Service’s 

declining financial circumstances, including our high-risk report and the 

Service’s recent annual financial reports and comprehensive statements 

for fiscal years 2007 and 2008,7

 which included data on the NRP’s cost 

savings; and guidance on key principles for managing agency initiatives 

and reporting program outcomes. Additional information on our (1) scope 

and methodology, including information on how we selected the eight 

postal districts we contacted and (2) methodology for determining the 

number of employees with workplace injuries who occupied (or could 

 

6

The results of our discussions with officials in these eight districts are not generalizable to 

all of the Service’s districts. 

7

GAO, High Risk Series: Restructuring the U.S. Postal Service to Achieve Sustainable 

Financial Viability, GAO-09-937SP (Washington, D.C.: July 28, 2009). 

Page 3 GAO-10-78 U.S. Postal Service
have occupied) a modified work assignment during 2008 are provided in 

appendixes I and II, respectively. 

We conducted this performance audit from October 2008 to December 

2009, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

The Service’s mission is to provide universal mail service 6 days a week to, 

as nearly as practicable, the entire U.S. population. The Service delivered 

mail to over 149 million addresses in 2008 and is broadly organized into 

nine large, geographic areas. Each of these areas comprises many postal 

districts, which collectively accomplish the Service’s mission. To carry out 

its mission, the Service maintains a network of facilities, including over 

36,700 retail and delivery facilities, such as local post offices and 

approximately 400 major mail-processing facilities. In addition, the Service 

operates one of the largest vehicle fleets in the United States. The Service 

also employs career and noncareer employees to carry out its mission.8

Most of the Service’s employees are in occupations (crafts) represented by 

one of the four largest postal unions. Table 1 identifies the four largest 

unions and the primary crafts each represents. 

Background 

 

8

Noncareer employees include “casual” and “transitional” staff with limited-term 

appointments. The Service hires these employees when it needs to temporarily augment 

the size of its workforce, such as during the Christmas season. 

Page 4 GAO-10-78 U.S. Postal Service
Table 1: The Four Largest Postal Unions and the Primary Crafts Each Union 

Represents 

Union Primary crafts represented 

American Postal 

Workers Union 

Clerks: Provide customer services at retail and delivery facilities 

including selling postage, accepting packages for shipment, and 

dispensing Certified Mail or Registered Mail. They also operate 

machinery for sorting mail in facilities like processing and distribution 

plants. 

Technicians and mechanics: Diagnose and repair equipment and 

vehicles. 

National 

Association of 

Letter Carriers 

City carriers: Organize mail into delivery sequence at postal facilities 

and deliver the mail along established routes, either by foot, or in a 

vehicle. 

National Postal 

Mail Handlers 

Union 

Mail handlers: Load, unload, and move bulk mail, including sacks 

and trays at processing facilities. 

Equipment operators: Move mail throughout a facility using 

equipment such as a forklift or pallet truck. 

National Rural 

Letter Carriers’ 

Association 

Rural carriers: Organize mail into delivery sequence and deliver it by 

vehicle along established rural routes that vary in length. They also 

collect mail and sell stamps, money orders, and other products to 

customers along their routes. 

Source: GAO analysis of Service documentation. 

Postal employees generally sustain two types of employment-related 

injuries—traumatic injuries and occupational illnesses. Traumatic injuries 

are linked to a specific event, such as when a letter carrier trips and falls 

while delivering mail, or when an employee is injured operating automated 

machinery in a processing plant. In contrast, occupational illnesses can 

develop from prolonged workplace exposure and repetitive motion 

activities, such as when a rural letter carrier develops a back, shoulder, or 

rotator cuff injury by repeatedly twisting and stretching to reach mail in 

the back of his or her vehicle. 

When federal employees suffer a compensable workplace injury, they are 

entitled to available work within their medical restrictions, in accordance 

with the Rehabilitation Act of 1973.9

 The right to available work and the 

obligation to provide it (restoration rights) are contained in statute and 

regulations promulgated by the Office of Personnel Management, which 

has delineated different job restoration rights for employees, depending on 

 

9

Pub. L. No. 93-112, 87 Stat. 355. See also fn. 3. 

Page 5 GAO-10-78 U.S. Postal Service
their recovery status.10 These rights are also specified in various Service 

manuals, including the Employee and Labor Relations Manual. According 

to this manual, the Service will provide the following: 

• “rehabilitation” assignments to an employee “when the effects of the injury 

are considered permanent and/or the employee has reached his/her 

maximum medical improvement” (MMI), which means that, according to 

the employee’s treating physician, the employee is unlikely to recover 

further; and 

• “limited duty” assignments to an employee who has not reached his or her 

MMI and is expected to fully recover. 

Service employees remain in limited duty assignments until either they 

fully recover and return to work (i.e., return to full duty) or their physician 

determines that they have reached their MMI. Once a physician determines 

that an employee has reached his or her MMI and is able to work for the 

Service, the Service may provide the individual with a rehabilitation work 

assignment. If an employee is unable to work for the Service, the Service 

refers the employee to OWCP for wage loss compensation. 

Under the Federal Employees’ Compensation Act and implementing 

regulations, injured employees must be examined by a medical officer or 

approved physician, the results of which are to be provided to the 

employer—in this case the Service. If a physician specifies medical work 

restrictions for the employee, the Service must consider these restrictions 

in providing a modified work assignment. For example, if after a 

compensable on-the-job injury, a physician determines that a city carrier 

can walk only 2 hours a day, the Service may try to find the employee a 

driving mail route that will allow the employee to remain seated most of 

the day. Similarly, if a clerk’s medical restrictions specify that the clerk 

can neither stand nor extend his or her arms above shoulder height, the 

Service could physically lower the workstation the clerk uses to organize 

mail into delivery route sequence so that the task can be done while 

seated. 

 

10See 5 C.F.R. part 353. These regulations implement 5 U.S.C. § 8151, part of the Federal 

Employees Compensation Act, as amended, Pub. L. No. 64-267, 39 Stat. 742 (1916), codified 

as amended at 5 U.S.C. chapter 81. Other legislative and regulatory protections also apply 

to injured federal employees, including protections afforded to employees in the 

Rehabilitation Act, and the Family Medical Leave Act of 1993, Pub. L. No. 103-3, 107 Stat. 6, 

as applicable. 

Page 6 GAO-10-78 U.S. Postal Service
The Service’s Employee and Labor Relations Manual specifies different 

job restoration rights, depending on the length of time between (1) 

OWCP’s approval of the employee’s injury claim for compensation and (2) 

the date that the employee’s physician specified that the employee reached 

his or her MMI.11 Figure 1 illustrates how a physician’s determination about 

whether an employee has (or has not) reached his or her MMI affects the 

type of modified work assignment provided. fied work assignment provided. 

Figure 1: How a Physician’s Determination about a Service Employee’s MMI Status 

Affects the Type of Modified Work Assigned to the Employee 

a

In some cases, the Service also provides modified work assignments to employees injured off-thejob. These assignments, however, are beyond the scope of our review. 

OWCP handles employees who suffer a compensable on-the-job injury by 

placing the employees on either its (1) “periodic rolls” (for employees with 

long-term or permanent injuries that are expected to keep them out of 

Employees injured off the job Employees injured on the job a njured off the job E l i j d a

Injured

employees

Employees who have

not yet reached their MMI

Employees who have

reached their MMI 

Employees who reached

MMI in less than one year

Employees who reached

MMI in more than one year

Source: GAO analysis of Service data.

Employees in

limited duty assignments

Employees in

rehabilitation assignments

 

11Specifically, employees who reached their MMI within a year from the date they became 

eligibile for compensation have the right to resume employment in their former job, or an 

equivalent position, agencywide. In contrast, employees who reach their MMI in more than 

a year from the date they became eligible for compensation are entitled to rights accorded 

to individuals who fully or partially recover, as applicable. 49 C.F.R. § 353.301(c). 

Page 7 GAO-10-78 U.S. Postal Service
work for more than 90 days) or (2) “daily rolls” (i.e., employees who are 

expected to return to work within 90 days). In general, employees are 

entitled to receive 66 and two-thirds percent of their basic compensation 

during the period of their disability.12

As discussed in appendix II, our analysis of Service data indicates that 

50,031 employees with workplace injuries occupied a modified work 

assignment during fiscal year 2008. Up to 9,740 other employees could 

have been in such an assignment during the same period.13 Collectively, 

these employees represent about 7 to 8 percent of the Service’s workforce 

in fiscal year 2008. In addition, our analysis found wide variability in the 

number, percentage, and distribution of employees in these assignments 

among districts. For example, in Dallas, over 12 percent of all employees 

in the district at the end of fiscal year 2008 were in a modified work 

assignment; while in the Metro Caribbean district, fewer than 2 percent 

occupied one of these assignments at the end of that fiscal year. Additional 

information on the nationwide distribution of employees in modified work 

assignments during fiscal year 2008, by district, is available in appendix III. 

According to senior postal officials, in the past, the Service aggressively 

returned employees to work as soon as possible. This practice occurred 

when the Service (1) had many manual, sedentary jobs that were useful for 

its injured employees to perform (e.g., filling out customers’ change of 

address forms manually) and (2) enjoyed steady growth in mail volume 

and revenues. Neither of these circumstances exists today. In addition, as 

we previously reported,14 since 2007, the Service has been experiencing its 

steepest decline in mail volume since the Great Depression. In fiscal year 

2009, the Service incurred an unprecedented net loss of $3.8 billion and 

 

125 U.S.C. §§ 8105, 8106. The calculation of basic compensation differs depending on 

whether the disability is total or partial. An employee may also be entitled to additional 

compensation depending on the nature of their injury and whether the employee has 

dependents. 5 U.S.C. §§ 8107, 8110. Other considerations may also warrant more or less 

compensation. See 5 U.S.C. §§ 8111, 8112, 8113. Senior headquarters officials noted that 

Service employees receiving compensation from OWCP typically receive more than 66 and 

two-thirds percent of their prior salary. 

13Service data indicate that these employees had occupied a modified work assignment at 

some point, but, for example, subsequently had retired or otherwise separated from the 

Service. Thus, sufficient data were not available for us to determine whether these 

employees actually occupied a modified work assignment during fiscal year 2008. 

14GAO, U.S. Postal Service: Broad Restructuring Needed to Address Deteriorating 

Finances, GAO-09-790T (Washington, D.C.: July 30, 2009). 

Page 8 GAO-10-78 U.S. Postal Service
experienced a decline in mail volume of over 25 billion pieces—its 

steepest decline ever. 

To respond to its deteriorating financial circumstances, the Service has, 

among other actions, downsized its workforce through “early out” 

retirement offers, closed some facilities, removed underutilized mail 

collection boxes, realigned its delivery routes to enhance efficiency (route 

realignments), and eliminated one of three work shifts (tours) in many 

mail processing and distribution facilities and about 114 million work 

hours from its 2009 operations. 

Given the Service’s deteriorating financial condition, in July 2009, we 

placed the Service on our list of high-risk areas needing attention by the 

Congress and the executive branch to achieve broad-based 

transformation.15 At that time, we reported that a key action for reducing 

the Service’s costs was to reduce its employee costs for compensation and 

benefits and suggested that the Service align costs and revenues, including 

its costs for compensation and benefits. These costs account for about 80 

percent of the Service’s costs. 

When implementing major initiatives, agencies—such as the Service—

need to ensure that these initiatives will be accomplished effectively and 

efficiently. Fundamentally, the success of any initiative, such as the NRP, 

begins at the top—with clear management support for the purpose, goals, 

and time frames established for completing the initiative. Clear upper-level 

support and direction help managers throughout the organization properly 

prioritize the initiative relative to others. Such support and direction also 

help ensure that managers devote sufficient time and resources to 

complete the initiative successfully and in a timely manner. In addition, to 

help ensure the success of key initiatives, an agency should establish 

measures for determining whether program goals are being met, such as 

measures of expected outcomes. Furthermore, when an agency reports 

data on these outcomes to the Congress and others, the agency needs to 

 

15GAO-09-937SP. 

Page 9 GAO-10-78 U.S. Postal Service
ensure that the data are reliable and understandable, and that any 

limitations applicable to the data are clearly disclosed.16

The Service began implementing the NRP in November 2006 to help 

ensure that all postal employees placed in modified work assignments 

because of a workplace injury are performing work that is medically 

suitable and necessary to the execution of the Service’s mission. Although 

the number of employees being reassessed under the NRP is available at a 

district level, this number is not readily available nationwide because the 

Service does not aggregate these data. However, according to senior 

headquarters officials responsible for implementing the NRP, there were 

31,044 employees in modified work assignments on September 30, 2008, all 

of whom were potentially subject to review under the NRP, depending on 

their work status when the Service began implementing the NRP in their 

district. In addition, according to these officials, employees injured after 

the NRP’s initiation were “rolled into” the NRP process at each applicable 

district.17

The Goal of the NRP 

Is to Ensure That All 

Employees in 

Modified Work 

Assignments Are 

Performing Medically 

Suitable, Necessary 

Work 

According to Service and DOL officials, the Service began accumulating 

large numbers of employees in modified work assignments when it was 

financially healthy and before the introduction of widespread automation, 

which decreased the availability of manual and sedentary jobs that, 

nevertheless, were useful to the execution of the Service’s mission. Many 

of these jobs have disappeared over time and, thus, managers began 

assigning make-work, such as answering phones or serving as a lobby 

greeter, to accommodate employees with workplace injuries—even when 

these assignments were not required at a particular facility. Thus, 

according to senior headquarters officials, they will consider the NRP a 

success when every employee with a workplace injury is working in a 

 

16GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1;

Government Auditing Standards, GAO-07-731G (Washington, D.C.: July 2007 Revision); 

Results Oriented Government: GPRA Has Established a Solid Foundation for Achieving 

Greater Results, GAO-04-38 (Washington, D.C.: Mar. 10, 2004); Tax Administration: IRS 

Needs to Further Refine Its Tax Filing Season Performance Measures, GAO-03-143

(Washington, D.C.: Nov. 22, 2002); Managing for Results: Enhancing Agency Use of 

Performance Information for Management Decision Making, GAO-05-927 (Washington, 

D.C.: Sept. 9, 2005); Statement of Federal Financial Accounting Standard Number 4, 

“Managerial Cost Accounting Concepts and Standards for the Federal Government,” 2008 

update. 

17Data on the number of these employees is also available at a district level, but is not 

aggregated by the Service agencywide. 

Page 10 GAO-10-78 U.S. Postal Service
modified work assignment that accommodates both the employee’s 

medical restrictions and the Service’s needs. 

While the Service specifically precluded make-work assignments, senior 

headquarters officials purposely did not specify which of the Service’s 

work assignments nationwide involve necessary work or, alternatively, 

identify those assignments that do not. According to these officials, they 

did not do so because the Service’s needs vary by location and, as a 

consequence, they wanted to provide facility supervisors and district 

managers with flexibility to identify necessary work in their facilities and 

districts. Thus, under the NRP, work assignments that might be considered 

unnecessary in one facility may be considered necessary in another, 

depending on the facility’s needs. While the Service purposely did not 

specify a list of necessary work assignments, it precluded local managers 

from assigning work to an injured employee when the work is part of 

another employee’s duties. According to officials at the four districts we 

visited, prior to the NRP, they routinely assigned portions of one or more 

employees’ duties to other employees to create modified work 

assignments for injured workers. 

The Service is implementing the NRP in three phases, involving a total of 

56 steps and the participation of a wide variety of officials at all levels of 

the organization and, in some cases, affected employees and their union 

representatives. Some employee outcomes arising from the NRP vary by 

phase, while others do not. For example, during any phase of the NRP, 

employees may return to full duty, retire, or resign from the Service. In 

addition, assuming that necessary and medically suitable work exists, 

employees may continue working in either a new assignment or their prior 

modified assignment. Employee outcomes vary between Phases 2 and 3, 

however, when sufficient necessary and medically suitable work is not 

available for the employees to perform. Until recently, the Service has 

been implementing the NRP in a staggered manner, with each phase 

performed sequentially. However, instead of waiting for each of the 

districts to complete Phase 2 before initiating Phase 3, in July 2009, the 

Service began implementing these phases concurrently. According to 

senior headquarters officials, the Service took this approach to stimulate 

progress and expedite the NRP’s overall implementation. While the NRP 

takes many months to fully implement in each district, in part, because 

large numbers of employees are being reassessed, senior Service officials 

told us in August 2009 that they expected the entire NRP process will be 

completed by September 30, 2010. However, given that none of the 

districts has completed all of the phases of the NRP since its initiation 

The Service Is 

Implementing the 

NRP in Three Phases, 

Which Take Many 

Months to Complete 

Page 11 GAO-10-78 U.S. Postal Service
more than 3 years ago, and absent established milestones and clear 

program priorities for completing the NRP nationwide, it is unclear when 

the NRP will be completed. 

The NRP Has Three 

Phases and Involves 56 

Prescribed Steps 

The NRP has three phases,18 involving 56 prescribed steps. Phase 1 

principally involves identifying all employees with compensable on-the-job 

injuries; ensuring that information about all employees, such as their 

medical restrictions, is up to date; and categorizing the employees into one 

of two groups, according to their medical status (i.e., whether they have, 

or have not, reached their MMI). The Service uses the employees’ updated 

information for Phases 2 and 3, during which the Service attempts to find 

medically suitable and necessary work for each employee; however, the 

focus of these phases varies—depending on whether an employee has 

reached his or her MMI (Phase 2) or has not reached his or her MMI 

(Phase 3). Figure 2 describes the key NRP activities, stages, and possible 

employee outcomes in each of the three phases. See appendix IV for a 

complete list of all NRP steps, by phase. 

 

18The Service is implementing the NRP in two phases—Phase 1 and Phase 2—which 

includes “Phase 2 Rehabilitation” for employees who have reached their MMI and “Phase 2 

Limited Duty” for those who have not yet reached their MMI. However, to enhance the 

clarity of this report, we refer to “Phase 2 Rehabilitation” as “Phase 2” and “Phase 2 Limited 

Duty” as “Phase 3.” 

Page 12 GAO-10-78 U.S. Postal Service
Figure 2: Key NRP Activities, Stages, and Possible Employee Outcomes, by Phase 

-Identify all employees with workplace injuries who 

are in (or capable of working in) modified work 

assignments.

-Ensure that employee information, including 

medical documentation of the employee’s work 

restrictions, is up to date and, where necessary, 

request updated documentation.

-Ensure that all employees are properly classified 

according to whether they have, or have not, 

reached their MMI.

-Validate that all records have been updated and 

that employees have been properly sorted 

according to their physician’s determination of each 

employee’s MMI status (done by headquarters

officials).

-Return to full duty if the employee’s medical 

documentation indicates, for example, that he or 

she has fully recovered from his or her injury.

Employee may:

Phase 1 – All employees with workplace 

injuries

Stages in phase: None

13 steps 30 steps 13 steps

Stages in phase: 

 -Job search (9 steps)

 -Job offer (6 steps)

 -No work available (NWA) (15 steps)

Stages in phase: 

 -Implementation (6 steps)

 -Job offer (4 steps)e

 -New medical documentation/new injury (3 

steps)

Phase 2 – Employees who have reached 

their MMI

Phase 3 – Employees who have not 

reached their MMI

-Identify all necessary work available within the 

district.a,b

-Assess whether the available work can be 

accomplished within an employee’s medical 

restrictions.

-Where medically suitable work is available, 

prepare a job offer for each employee. (This may 

be either a new job offer, or a job reflecting the 

employee’s prior modified assignment.)

-When no medically suitable work is available, 

develop a preliminary list of employees with NWA 

determinations for review and approval by district 

management, and double check each of these 

employees’ files for accuracy to ensure, for 

example, that job searches for each employee 

were performed correctly.

-Approve preliminary NWA list and meet with 

unions to discuss the list.

-Notify affected employees of the Service’s NWA 

determination.

-Meet with employee and, when requested, the 

employee’s union representative to discuss the 

job offer and provide the employee with an 

opportunity to update his or her medical records.

c

-Identify all available necessary work (from work 

conducted during Phase 2).a

-Update records to ensure that all employees who 

have not reached their MMI are listed and that all 

employees’ files are complete and still up to date.

-Conduct job searches within the Service for 

employees and hold work status meetings with 

employees to discuss possible work assignments.

d

-Assess employees with new medical 

documentation or a new injury to determine 

whether medically suitable and necessary work is

available for these employees.

-Return to full duty, or

-Retire or resign from the Service.

-Be placed in a modified work assignment (i.e., 

either the same medically suitable and necessary 

work assignment that he or she performed before 

the NRP or a new medically suitable and 

necessary work assignment);

-Return to full duty;

-Retire or resign from the Service; or

-Receive an NWA determination—(i.e., the 

Service was unable to find a necessary and 

medically suitable work assignment for the 

employee).

-a “full day work” determination—(i.e., the number 

of hours of medically suitable and necessary work 

identified by the Service matches the number of 

hours the employee is allowed to work by his or 

her physician);

-a “partial day work” determination—(i.e., the 

number of hours of medically suitable and 

necessary work identified by the Service is less

than the number of hours the employee is

permitted to work;e or

-a “complete day no work” determination—(i.e., 

the Service could not identify any necessary work 

within the employee’s craft, tour, and facility, and 

within his or her medical restrictions).e

Possible employee outcomes:

Employee may:

Possible employee outcomes:

Employee may:

The remaining employees receive one of three 

possible work determinations;

Possible employee outcomes:

Key activities: Key activities: Key activities:

Source: GAO analysis of Service data.

Page 13 GAO-10-78 U.S. Postal Service
a

The lists of necessary work are developed by each district’s Service operations managers and are 

subject to change, based on agencywide or local changes in job availability resulting from, among 

other matters, reductions in staffing due to, among other actions, route realignment activities, and 

fluctuations in mail volume. 

b

Beginning in July 2009, the Service began allowing certain districts implementing Phase 2—those 

that had already developed their list of necessary work (Phase 2, step 5)—to begin simultaneously 

implementing Phase 3. This matter is discussed in more detail later in this report. 

c

These meetings include a review and discussion of the proposed employee job offer and are 

designed to elicit feedback from the employee on (1) his or her ability to perform the duties identified 

and (2) other necessary work that might be available and medically suitable for the employee to 

perform. The Service is expected to consider the employee’s feedback and, consequently, can make 

changes to the job offer on that basis. 

d

“Work status” refers to the stage in which facility supervisors determine what, if any, necessary work 

is available for each employee. 

e

Before the Service provides a “partial day work” or a “complete day no work” determination to an 

employee, it must first search for necessary work in the employee’s facility. If suitable work is not 

found, the Service must expand the search to other postal facilities within the district’s boundaries. 

Each of the NRP phases is highly participative, involving a wide variety of 

postal employees representing headquarters, areas, and districts, including 

senior operations managers, injury compensation specialists, and medical 

staff in the Service’s districts. Officials from health and resource 

management, injury compensation, and labor relations offices, and the 

Office of General Counsel in headquarters also participate in the NRP. In 

Dallas, Texas, for example, we met with more than 25 postal employees 

who, in addition to their normal duties, also were involved in carrying out 

some portion of the NRP. Many of these individuals also served as 

members of the district’s assessment team that implements many of the 

NRP-related tasks. According to senior headquarters officials, the average 

size of the district assessment teams ranges from six to eight officials. In 

addition, because the NRP requires discussions between managers and 

affected employees when, for example, they receive an NWA 

determination, the employees and, when required, their union 

representatives, also participate in the NRP. 

Currently, the Service is using the NRP process principally to reassess the 

31,044 employees who were in modified assignments on September 30, 

2008 (i.e., the “backlog” of these employees).19 However, in the future, the 

focus of the process will be to determine whether medically suitable and 

necessary work assignments are available for (1) newly injured employees 

and (2) employees who have reached their MMI and, thus, require 

 

19Employees injured after the NRP’s initiation also were included in the NRP process at 

each district. 

Page 14 GAO-10-78 U.S. Postal Service
reevaluation. The future process will be referred to as the “National 

Assessment Process,” according to senior headquarters officials. 

Some Employee Outcomes 

Vary, Depending on Phase 

According to Service officials, during any phase of the NRP, employees 

may return to full duty (i.e., return to their preinjury job), retire, or resign 

from the Service. In addition, assuming that necessary and medically 

suitable work exists, the outcomes for employees in Phases 2 and 3 are the 

same—employees may continue working in either a new, medically 

suitable assignment, or in their prior modified assignment.20 Employee 

outcomes vary between these phases, however, when sufficient necessary 

and medically suitable work is not available for the employees to perform. 

For example, when work is not available, the Service provides employees 

in Phase 2 (those who have reached their MMI) with an NWA 

determination and sends them home, along with the necessary forms for 

filing a wage loss claim to receive compensation from DOL’s OWCP for the 

number of hours they could not work for the Service.21 In contrast, in 

Phase 3, when sufficient necessary and medically suitable work is not 

available, the Service provides employees who have not reached their MMI 

with either a (1) “partial day work” determination or a (2) “complete day 

no work” determination. These employees also are referred to DOL’s 

OWCP for wage loss compensation.22 Figure 3 illustrates the various NRP 

outcomes experienced by employees in modified work assignments, 

depending on the employees’ MMI status. 

 

20In Phase 3, such an employee outcome is referred to as a “full day work” determination. 

21In certain cases, DOL may decide that an individual is eligible not only to receive wage 

loss compensation but also to participate in its vocational rehabilitation training program. 

22Wage loss compensation for these employees includes compensation for (1) the number 

of hours the employees could not work for the Service because of their medical restrictions 

and (2) the additional work hours for which the Service did not have medically suitable and 

necessary work for the employees to perform. 

Page 15 GAO-10-78 U.S. Postal Service
Figure 3: NRP Outcomes Experienced by Service Employees in Modified Work Assignments 

Employees in

modified work

assignments

Return to full duty

Necessary work

assignments for employees

who have reached their MMI

Retire or resign

NWA for employees

who have reached

their MMI

(referred to OWCP)

Source: GAO analysis of Service data.

OWCP

Vocational

rehabilitation

Daily or periodic rolls

Retire or resign

(decline OWCP)

Return to full duty

(upon successful appeal)a

New occupation/

employer 

Daily work determinations

for employees who have

not reached their MMI

a

w

NRP

Complete

day no work 

Partial day

work

Full day P

work

Administered by the Service

Administered by DOL

a

Employees may appeal, file suit, or grieve, if applicable, work determinations arising from the NRP. 

Another distinction between Phases 2 and 3 relates to the frequency of 

employee outcome determinations. Phase 2 NWA determinations, for 

example, occur once23 and, as discussed previously, result in the 

employee’s referral to OWCP for wage loss compensation. Because these 

individuals have reached their MMI, according to senior headquarters 

officials, they likely would be placed on OWCP’s “periodic rolls.” Thus, the 

senior headquarters officials said, they do not expect these employees will 

ever return to work for the Service. In contrast, Phase 3 “full day work,” 

“partial day work,” and “complete day no work” determinations are 

dynamic and subject to frequent change, sometimes on a daily basis, 

because of fluctuations in factors such as staff availability and mail 

volume that affect the availability of necessary and medically suitable 

 

23This assumes that the employee did not, for example, successfully appeal or grieve his or 

her initial NWA determination. 

Page 16 GAO-10-78 U.S. Postal Service
work. Thus, depending on the availability of work, postal managers may 

be required to make daily determinations about whether suitable work is 

available for these employees. 

Each of these three Phase 3 employee outcomes has somewhat different 

consequences for an employee, including the frequency with which the 

employee is expected to report to the Service for possible work and the 

length of his or her anticipated duration on OWCP’s compensation rolls. 

For example, when a facility supervisor determines that there is no 

necessary and medically suitable work available for an employee to 

perform (i.e., a “complete day no work” determination), the employee is 

sent home and instructed to return to work only if the employee’s (1) 

medical restrictions change or (2) supervisor informs him or her that 

necessary work has become available for the employee to perform. In 

contrast, employees with “full day work” 24 and “partial day work” 

determinations are required to report to work every day to see if necessary 

work is available for them to perform. These employees are eligible to 

receive wage loss compensation from OWCP, depending on the number of 

hours the employees could not work for the Service. However, whether 

OWCP places them on its “periodic rolls” or “daily rolls,” is likely to 

depend on how long the Service estimates the employee will be out of 

work.25

The Service Staggered the 

NRP’s Implementation and, 

Until Recently, Required 

Each Phase to Be 

Implemented Sequentially 

After spending about 3 years developing the NRP, the Service began 

implementing the NRP nationwide in November 2006. The Service initiated 

the NRP in a staggered manner, varying the dates when districts within an 

area could begin Phase 1. According to senior headquarters officials, this 

approach was needed to train, assist, and oversee the NRP’s initiation in 

each of the districts. In addition, once implementation began, the Service 

required each district to carry out the three NRP phases sequentially. 

 

24A “full day work” determination does not necessarily equal a typical 8-hour workday. For 

example, if an employee is capable of working only 4 hours a day, and the Service provides 

the employee with an assignment of that duration, such an assignment would constitute 

“full day work” for that employee. If, however, the Service provides only a 2-hour work 

assignment, the employee would be eligible to receive OWCP compensation for the 2 

additional hours that he or she could have worked for the Service, as well as the remaining 

4 hours that he or she could not have worked because of his or her medical restrictions. 

25Depending on the employee’s expected date of recovery and the likelihood of future work 

at the Service, employees who receive a “complete day no work” determination may be 

placed on OWCP’s “periodic rolls.” In contrast, employees who receive a “partial day work” 

determination likely would be placed on OWCP’s “daily rolls.” 

Page 17 GAO-10-78 U.S. Postal Service
Specifically, each district had to complete each step in a phase before it 

could proceed to the next step in the phase and, similarly, it had to 

complete each phase before proceeding to the next one. According to 

senior headquarters officials responsible for implementing the NRP, the 

sequential approach was needed to ensure that each of the Service’s 

districts implemented the NRP correctly and consistently. Furthermore, to 

help ensure this objective would be realized, according to these officials, 

they purposefully did not provide a district with guidance for 

implementing the next NRP step until they had (1) determined that the 

district had implemented the prior step correctly and (2) approved the 

district to start the next step, or phase.26

Until recently, the Service’s implementation of the NRP was confined to 

Phases 1 and 2. However, instead of waiting for each of the districts to 

complete these phases before initiating Phase 3, in July 2009, the Service 

began implementing Phases 2 and 3 concurrently for some districts. Senior 

headquarters officials told us that they did this to stimulate progress 

within the districts and, consequently, to expedite the NRP’s overall 

implementation. According to these officials, this decision was necessary, 

in part, because area and district managers’ commitment to the NRP’s 

timely implementation varied greatly between the Service’s areas and 

districts. They explained that, in addition to the daily effort required to 

“move the mail,” managers must simultaneously implement a host of other 

operational initiatives. 

According to senior headquarters officials, districts are now “eligible” to 

begin simultaneously implementing Phases 2 and 3 when they have 

identified all of their necessary work assignments (Phase 2, step 5). 

However, the Service is staggering the introduction of Phase 3 in the 

districts, much as it did the earlier phases of the NRP. Specifically, at the 

conclusion of our review, senior headquarters officials were precluding 

managers in each of the Service’s nine large, geographic areas from 

initiating Phase 3 in more than one district at a time.27

 

26Senior headquarters officials acknowledged that mistakes were sometimes made, 

particularly early in the NRP’s implementation. For example, in San Francisco, officials 

responsible for implementing the NRP told us that they moved forward with the NRP’s 

implementation (using information provided by another district) without receiving 

necessary guidance from headquarters. As a consequence, headquarters required the 

district to repeat prior steps because the district had not implemented them correctly. 

27Like the other NRP phases, the order of Phase 3’s implementation among the districts is 

determined by area managers in each of the Service’s nine areas. 

Page 18 GAO-10-78 U.S. Postal Service
The Service initiated the NRP without establishing milestones or clear 

program priorities for its completion. According to senior headquarters 

officials, they intentionally did this because they do not have the authority 

to require area and district managers to prioritize the NRP’s completion 

over competing operational initiatives. In addition, the officials were 

unable to identify or provide any Service documentation 

Absent Time Frames and 

Clear Program Priorities It 

Is Unclear When the NRP 

Will Be Completed 

Agencywide 

• describing, among other matters, upper level management’s support for 

the purpose of the initiative and time frames for completing it, or 

• specifying the NRP’s strategic importance relative to the Service’s other 

initiatives. 

Despite the absence of an overall implementation time frame, progress has 

been made. Of the 62 districts implementing Phase 2 as of August 31, 2009, 

almost one-half (30) had been doing so for more than 1 year. Of these, 5 

districts had been implementing Phase 2 for longer than 2 years, and 9 

others had been implementing this phase for more than 18 months. Senior 

headquarters officials acknowledge that, after 3 years, none of its districts 

have fully implemented the NRP, largely because of (1) the large number 

of employees being reassessed, (2) competing demands on the managers’ 

time resulting from the ongoing implementation of various Service 

initiatives, and (3) the rigorous nature of the NRP. In addition, these 

managers explained that certain NRP steps, such as the job search process 

for each employee, are particularly time-consuming. Specifically, the 

Service’s Employee and Labor Relations Manual requires postal 

managers to “make every effort” to identify potential positions for 

employees who have reached their MMI. In addition, the manual specifies 

that the Service’s job offers “should minimize any adverse or disruptive 

impact on the employee.” Thus, in conducting job searches for these 

employees, postal managers must first look for necessary and medically 

suitable work in each employee’s craft, tour, and facility. If this search 

does not identify a necessary and medically suitable assignment, postal 

managers must conduct additional searches to try to find work for the 

employee within his or her current facility (i.e., work in a different craft or 

tour).28 If work cannot be identified for an employee at his or her current 

facility—for employees who reached their MMI in 1 year or less—

managers must search for necessary and medically suitable work within 

 

28The additional searches are required to proceed in the following manner: (1) different 

craft, same tour and facility; (2) same craft, different tour, and same facility; and (3) 

different craft and tour, same facility. 

Page 19 GAO-10-78 U.S. Postal Service
each employee’s commuting area. If still unsuccessful, the Service must 

(for these employees) expand its job search to other facilities beyond the 

boundary of each employee’s current district.29

According to senior headquarters officials, the time and resources 

required to correctly and consistently implement the NRP are necessary to 

ensure that each employee’s job restoration rights are fully protected. 

These officials also noted that the rigorous process is needed because the 

NRP can affect whether an employee retains a postal job. They further 

explained that the methodical nature of the NRP process 

• helps ensure that the Service complies with all applicable laws, 

regulations, and contractual obligations related to employees with 

workplace injuries, and 

• decreases the likelihood of successful grievances, appeals, and other 

actions against the Service.30

Senior headquarters officials told us that in 2006 they initially expected 

that all phases of the NRP would be completed by January 2010. The 

NRP’s implementation, however, has taken longer than anticipated. Thus, 

as of August 2009, these officials estimated that the entire process would 

be completed by September 30, 2010. However, without specific 

milestones and clear upper management support across the Service’s 

areas and districts, it is unclear when the NRP will be completed. 

 

29The majority of the job search process is the same for employees who have reached their 

MMI regardless of when (i.e., more than 1 year, or less than 1 year, after their date of 

eligibility for compensation). However, for employees who reached their MMI in more than 

1 year, postal managers do not need to expand their search for jobs beyond the district’s 

boundaries. 

30As of July 2009, three of the four largest postal unions had filed a total of six national-level 

grievances related to the NRP process. The grievances cover a broad scope of issues, 

ranging from the consideration of seniority when making job offers under the NRP to a 

challenge of an entire phase of the NRP process. As of July 2009, one grievance had been 

settled, while the others were either pending a decision by the Service or pending 

arbitration. On the local level, employees have filed a number of grievances under their 

union contracts related to their NRP work determinations. In addition to filing grievances, 

employees have other avenues of redress, including filing actions before the Merit Systems 

Protection Board and before the Equal Employment Opportunity Commission. Generally, 

the board adjudicates individual federal employee appeals when an employee believes he 

or she has suffered an adverse personnel action. The commission adjudicates matters in 

which the federal employee believes he or she has suffered an action in violation of 

workplace discrimination laws. 

Page 20 GAO-10-78 U.S. Postal Service
While the implementation of the NRP is incomplete, the initiative has 

begun to produce cost savings. These savings resulted from the placement 

of injured employees in medically suitable and necessary work 

assignments that contribute to the Service’s bottom line, as well as from 

retirements and resignations. Data on these outcomes, however, are both 

limited and preliminary, partly because the Service does not track or 

aggregate information on all employee outcomes. Moreover, although 

some outcomes, such as retirements, result in cost savings, others, such as 

NWA determinations, result in short- and, possibly, long-term cost 

increases. The Service reported in its most recent comprehensive report to 

the Congress that it saved $146 million in fiscal year 2008 as a result of the 

NRP, but it reported these savings without disclosing the limitations that 

applied. Specifically, the estimate accounted for neither (1) all potential 

savings (total gross savings) nor (2) additional costs resulting from some 

employee outcomes and the cost of implementing the NRP and thus was 

not an estimate of total net savings after costs. 

Despite Incomplete 

NRP Implementation, 

the Service Estimated 

$146 Million in 

Savings during Fiscal 

Year 2008 

NRP Implementation Is 

Incomplete 

As discussed, the Service did not set specific time frames for completing 

the NRP or establish program priorities for its completion nationwide, and 

implementation, thus far, has taken longer than senior headquarters 

officials expected. While the NRP began in 2006, according to data 

provided by the Service, none of the districts had completed all phases of 

the NRP as of August 31, 2009.31 Specifically: 

• 69 of the Service’s 75 districts (92 percent) had completed Phase 1 of the 

NRP as of August 31, 2009,32 and the remaining 6 districts had nearly 

completed this phase; 

• 7 of 75 districts (9 percent) had completed Phase 2, 62 districts (83 

percent) were in the process of implementing this phase, and 6 districts 

had not yet begun this phase; and 

• 17 of 75 districts (23 percent) had begun implementing Phase 3 as of 

August 31, 2009, while 58 had not begun. However, 14 of the remaining 58 

 

31See appendix IV for a complete list of NRP steps, by phase. 

32As previously noted, while the Service currently has 74 districts, we report available 

information on the status and outcomes of 75 districts because 1 of these had not fully 

distributed its employee files, including those related to the NRP, to other postal districts. 

Page 21 GAO-10-78 U.S. Postal Service
districts were scheduled to begin implementing Phase 3 by the end of 

October 2009. 

Figure 4 illustrates the overall status of NRP implementation among the 

Service’s 75 districts, as of August 31, 2009. 

Figure 4: Overall Status of NRP Implementation, by Phase, as of August 31, 2009 

Although 6 districts had not completed Phase 1 as of August 31, 2009, each 

of these districts was concluding this phase and awaiting final validation 

of results by headquarters. In contrast, according to data provided by the 

Service, of the 69 districts that had completed or were implementing Phase 

2, the majority were in the first stage. Specifically, 

Phase

Number of districts

Complete implementation

Incomplete implementation

Have not begun implementation

Source: GAO analysis of Service data.

0 10 20 30 40 50 60 70 80

Phase 3

Phase 2

Phase 1 69 6

7 62 6

17 58

• 40 were in the job search stage (about 58 percent), 

• 12 were in the job offer stage (about 17 percent), 

• 10 were in the NWA stage (about 14 percent), and 

• 7 had completed Phase 2 (about 10 percent). 

Figure 5 illustrates the status of the NRP for phases 1 and 2, by step, as of 

August 31, 2009. 

Page 22 GAO-10-78 U.S. Postal Service
Figure 5: Status of NRP Implementation for Phases 1 and 2, by Step, as of August 31, 2009a

Number of districts

Source: GAO analysis of Service data.

NRP implementation phase/step

0

2

4

6

8

10

12

14

98765432165432198765432113121110987654321 151413121110

Search Offer NWA

Phase 1 Phase 2 Complete

a

Data on 17 of the 75 districts that had begun implementing Phase 3 as of August 31, 2009, are not 

presented because similar data, by step, were not available. 

Employee Outcomes Are 

Beginning to Be Realized, 

but Available Data Are 

Limited and Preliminary 

Although implementation of the NRP is incomplete, the initiative is 

beginning to realize outcomes for Service employees. However, partly 

because of incomplete implementation of the NRP and tracking of all NRP 

employee outcomes, agencywide data on NRP outcomes are both limited 

and preliminary. As previously shown in table 2, the potential employee 

outcomes of Phase 2 for employees (employees who have reached their 

MMI) are as follows: 

• return to full duty, 

• retirement, 

• resignation, 

• continuation in the employee’s prior modified work assignment, 

Page 23 GAO-10-78 U.S. Postal Service
• reassignment to a new medically suitable and necessary work assignment, 

or an 

• NWA determination (i.e., the Service could not find necessary and 

medically suitable work for employees to perform). 

Although the Service tracks and aggregates data on some NRP employee 

outcomes, it does not track or aggregate data on others. According to 

senior headquarters officials, they do not track or aggregate data on all 

employee outcomes because the data are employee-specific and recorded 

and stored at each of its districts. They explained that aggregating data for 

the thousands of employees nationwide is challenging, given limited staff 

resources, the scope of effort required, and the absence of an automated 

system for tracking and reporting information on the status of employees 

in modified work assignments. While senior headquarters officials were 

able to provide data on employee outcomes for 616 of 1,738 (about 35 

percent) employees that were reviewed in the eight districts that had 

completed, or nearly completed, Phase 2 as of June 30, 2009,33 they were 

unable to provide similar data for the remaining 1,122 employees (about 65 

percent). Senior headquarters officials told us that data on these employee 

outcomes were unavailable principally because the Service does not track 

or aggregate the number of employees who 

• remained in their prior work assignment because the Service determined 

through the employees’ NRP review that the work assignment was 

medically suitable and necessary work, or 

• received a new modified work assignment because their prior assignment 

was determined to be either medically unsuitable or unnecessary to the 

Service’s mission.34

According to senior headquarters officials, the Service does not need to 

track or aggregate these outcomes because both outcomes indicate that 

the goal of the NRP has been achieved. In its comments on a draft of this 

 

33The Service provided us with data on Phase 2 employee outcomes for eight districts as of 

June 30, 2009. Six of these districts––Western New York, Dakotas, New HampshireVermont, Westchester, Metro Caribbean, and Honolulu—had completed Phase 2, while the 

2 others—San Diego and Boston—had essentially completed this phase at that time. The 

Service was unable to provide us with data for these districts as of August 31, 2009. 

34In addition, senior headquarters officials do not track or aggregate data on employees 

with outcomes that have not been resolved because of grievances or appeals. 

Page 24 GAO-10-78 U.S. Postal Service
report, the Service said that it intends to deploy a new national claims 

management program in February 2010 that will enhance its ability to 

track and measure NRP progress and enable cost efficient aggregation of 

NRP data. However, the Service did not indicate that it planned to use the 

new program to track and measure NRP employee outcomes. 

For the remaining 616 employees (of 1,738) whose specific outcomes 

headquarters tracked data indicate that 

• 103 employees returned to full duty, 

• 223 employees retired, 

• 257 employees received NWA determinations, and 

• 33 employees had “other” outcomes.35

Senior headquarters officials also provided us with preliminary data on 

some employee outcomes for the districts implementing Phase 3 as of 

August 31, 2009. Most of these data were very limited because the majority 

of the districts were in the early stages of implementing Phase 3 and, thus, 

had very few employee outcomes to report. Available data were most 

complete for the four districts that piloted Phase 3 and, consequently, had 

been implementing Phase 3 the longest. Outcomes for the 2,301 employees 

reviewed in these four districts indicated that 

• 1,039 employees received a “full day work” determination (about 45 

percent), 

• 589 employees received a “partial day work” determination (about 26 

percent), and 

• 673 employees received a “complete day no work” determination (about 

29 percent). 

While these data provide some useful insights into the districts’ early 

experience with implementing Phase 3, outcomes in this phase are 

 

35According to senior headquarter officials, “other” outcomes include, but are not limited 

to, employees who had (1) either been terminated or transferred, (2) their MMI status 

rescinded by their treating physician, or (3) received a new medical assessment from their 

physician stating that they were now totally disabled and unable to work for the Service. 

Page 25 GAO-10-78 U.S. Postal Service
dynamic and subject to frequent change because, as discussed, district 

managers are required to perform daily work determinations for many of 

these employees. 

Some Employee Outcomes 

Result in Cost Savings, 

while Others Increase the 

Service’s Short- and Longterm Costs 

While some employee outcomes result in cost savings for the Service, 

others increase the Service’s costs. Savings accrue when, for example, an 

employee returns to full duty, and the Service no longer has to pay for 

overtime or temporary employees to perform the work the injured 

employee could not perform. Savings also may accrue when an employee 

retires or resigns because the Service’s obligation to this employee is 

either greatly reduced or eliminated.36 Furthermore, according to senior 

headquarters officials, if an employee receives an NWA determination as a 

result of Phase 2, savings can result over the long term if (1) the employee 

is retrained and reemployed through OWCP’s vocational rehabilitation 

training program; (2) OWCP reduces the employee’s compensation for an 

administrative reason, such as the employee’s refusal to fully participate in 

OWCP’s vocational rehabilitation training program; or (3) the employee 

finds another job on his or her own. Each of these cases would result in a 

reduction in the Service’s overall OWCP costs.37 While only about one-third 

of all employees enrolled in OWCP’s vocational rehabilitation training 

program eventually receive employment elsewhere, according to DOL 

officials, senior headquarters officials at the Service told us that, for every 

employee who is successfully placed by OWCP with a new employer, more 

than three employees either retire or have their compensation reduced for 

an administrative reason. 

However, in addition to creating savings, the NRP creates short- and longterm costs. These costs arise in part from the increased numbers of 

employees on OWCP’s periodic or daily rolls and increased operational 

costs for the NRP’s implementation. Specifically, each NWA determination 

 

36According to Service officials, to date, the Service has prefunded retirement costs for its 

employees. Thus, except for the Service’s continued payments for retired employees’ 

health benefits, its obligation to retired employees is eliminated. In addition, the Service 

bears no future financial obligation to employees who resign. 

37In addition to cost savings, senior headquarters officials, officials in the four districts we 

visited, and some union officials noted several additional benefits arising from the NRP, 

such as (1) the creation of a systematic approach to managing the medical records of 

employees with workplace injuries, (2) better job offers that match injured employees’ 

medical restrictions with necessary work assignments, and (3) increased morale among 

Service employees who, for example, had to perform mission critical tasks that could not 

be performed by injured employees. 

Page 26 GAO-10-78 U.S. Postal Service
in Phase 2 and each “complete day no work” or “partial day” determination 

in Phase 3 increases the number of Service employees eligible to receive 

OWCP wage loss compensation.38 Increases in the number of employees 

receiving these determinations also will increase the Service’s annual 

OWCP costs, at least in the short term. OWCP’s most recent bill totaled 

about $1.1 billion for the period between July 1, 2008, and June 30, 2009. 

Thus, to the extent that employees remain on OWCP’s rolls, increasing the 

number of Service employees receiving OWCP compensation will also 

increase the Service’s long-term costs.39 For example, about $18 million of 

the Service’s most recent OWCP bill was for the approximately 500 

employees injured before 1971 who still remain on OWCP’s periodic rolls 

about 40 years later. Finally, increases in the number of Service employees 

receiving OWCP wage loss compensation as a result of their NRP 

reassessment could accelerate, given the Service’s efforts to reduce its 

employee work hours and the continuing decline in mail volume. Increases 

in the number of employees receiving workers’ compensation are 

problematic because, at the end of 2008, the Service estimated that its total 

liability for workers’ compensation costs was about $8 billion—an 

increase of about $197 million, or 2.5 percent, from 2007. 

The NRP also has increased the Service’s operational costs for developing, 

implementing, and integrating the NRP into the Service’s management 

practices.40 These include, for example, the costs for headquarters staff to 

travel to each of its districts to implement the NRP over the past 3 years. 

In addition, based on our interviews of district officials implementing 

Phases 2 and 3, the rigors of the NRP process have placed additional 

demands on available staff, such as the requirement to perform daily work 

determinations for many Phase 3 employees. Senior headquarters officials 

responsible for implementing the NRP, however, view these additional 

costs as “up-front” costs associated with reassessing the large number of 

employees in modified work assignments (i.e., the backlog)––costs that no 

 

38As discussed, employees also are entitled to receive compensation for the hours they 

could not work for the Service because of their medical restrictions. 

39Over time, some of the additional costs may decline. For example, when former Service 

employees on OWCP’s periodic rolls find work as a result of their enrollment in OWCP’s 

vocational rehabilitation training program or on their own, their compensation is reduced 

to account for their additional income. According to OWCP officials, the vocational 

rehabilitation training program normally takes more than 2 years to complete. 

40While we requested data on the costs associated with developing, implementing, and 

integrating the NRP into the Service’s management practices, the Service did not provide 

us with this information. 

Page 27 GAO-10-78 U.S. Postal Service
longer will be incurred after the NRP reassessment process has been fully 

implemented. As discussed previously, the Service intends to use the NRP 

process moving forward for newly injured employees and employees who 

reach their MMI (and require reevaluation). According to senior 

headquarters officials, once the NRP reassessment is complete, future 

costs for NRP activities will be part of the routine cost of managing these 

assignments. 

While the NRP’s up-front costs will no doubt decline as implementation is 

completed, to the extent that the NRP process creates permanent 

managerial requirements where none previously existed or were carried 

out, the process may create additional operational costs moving forward. 

As in the case of the Service’s OWCP costs, the increase in the Service’s 

operational costs likely will vary, depending on, among other factors, 

• the number of employees in these assignments; 

• the duration of their assignments;41

• the number of hours the employees are able to work, as well as their 

productivity; and 

• the extent to which the employees’ absence or diminished productivity 

requires the Service to use overtime or hire temporary employees to 

accomplish the injured employees’ duties. 

The Service Reported That 

NRP Saved $146 Million in 

Fiscal Year 2008 but Did 

Not Disclose the 

Limitations That Applied 

The Service attributed $146 million in cost savings to the NRP in its 

comprehensive report to the Congress for fiscal year 2008 without 

disclosing how it derived these savings or disclosing that this figure was 

based on estimates.42 In addition, the Service did not disclose that its 

protocols for estimating cost savings have several limitations and, as a 

consequence, its estimate reflects neither the Service’s total gross savings 

 

41We were unable to ascertain from Service data the typical length of time in which 

employees were in a modified assignment. However, according to senior headquarters 

officials, some employees are in modified work assignments for many years, while others 

require only a short-term modified work assignment. 

42United States Postal Service Comprehensive Statement on Postal Operations, 2008, 29. 

The Service is required to provide this report to Congress in conjunction with its annual 

budget. 39 U.S.C. § 2401(e). According to the Service, this report summarizes customer, 

employee, and operations-focused developments during fiscal year 2008. 

Page 28 GAO-10-78 U.S. Postal Service
nor its total net savings. For example, the protocols used to estimate the 

Service’s savings from Phases 1 and 2 

• do not account for savings accruing from all of the possible NRP employee 

outcomes. For example, although the protocols account for savings 

accruing for three of the Phase 2 employee outcomes––return to full duty, 

retirement, and resignation––the Service does not account for savings that, 

in some cases, might accrue from NWA determinations.43

• use “benchmark” cost savings, such as the Service’s “lowest fully loaded 

work hour” for employees––regardless of their actual salaries––to quantify 

savings associated with the employee outcomes.44

• do not account for savings from employee outcomes that accrue beyond 

12 months after the outcome occurred. For example, when an employee 

retires as a result of the NRP, the Service only counts the savings that 

accrue for the first 12 months after the date of retirement. 

• do not offset costs, such as the additional OWCP expenses that accrue 

from Phase 2 NWA determinations, and do not offset increases in the 

Service’s operational costs resulting from the NRP’s implementation. 

Because the goal of the NRP is to ensure that all employees with 

workplace injuries in modified work assignments are performing 

medically suitable and necessary work––not to produce cost savings––

senior headquarters officials told us that they intentionally designed the 

protocols to arrive at rough estimates that understate the NRP’s savings. In 

addition, they told us that it was not feasible to precisely estimate savings 

resulting from the NRP because the savings are specific to each 

employee’s circumstances. Furthermore, they said that implementing a 

more rigorous process for more precisely estimating NRP savings would 

place unreasonable and unnecessary demands on available staff. Thus, in 

their view, their current estimating approach is adequate for the Service’s 

needs. 

 

43For example, as discussed, if an employee receives an NWA determination and is 

successful in obtaining a new job with a salary that is equal to or greater than the salary he 

or she received from the Service, the Service no longer incurs any OWCP costs for this 

employee. 

44The “lowest fully-loaded work hour” represents the salary and benefits, such as annual 

leave and retirement, that the Service pays to employees in its lowest clerk position. 

According to senior headquarters officials responsible for implementing the NRP, this 

position is a “Clerk 4.” 

Page 29 GAO-10-78 U.S. Postal Service
By implementing the NRP, the Service has taken an important step to 

balance its obligation to provide work to employees with compensable 

workplace injuries (when necessary work is available for them to perform 

within their medical restrictions) with its obligation to the Congress, its 

employees, and the public to operate as effectively and efficiently as 

possible. In addition, because the NRP has the potential to cut some of the 

Service’s costs, the NRP may represent a step toward addressing the 

Service’s future financial viability. However, thus far, the NRP has been 

carried out without a strong management framework for ensuring timely 

implementation. For example, absent upper management’s clearly 

articulated support for the initiative, specified time frames for its 

completion, and information about the NRP’s relative priority compared to 

competing Service initiatives, area and district managers’ commitment to 

the NRP’s timely implementation has varied. Thus, after more than 3 years, 

none of the districts has completed all NRP phases. Furthermore, although 

Service officials estimate that the NRP will be completed by September 30, 

2010, without milestones for its completion, it is uncertain when the NRP 

will be completed. In addition, because the Service has not tracked and 

aggregated data on NRP employee outcomes, it is difficult to measure the 

success of the program or accurately report on employee outcomes. 

Finally, while the Service believes its process for estimating savings is 

adequate for its needs, when an agency reports data on its program 

outcomes to the Congress and others, to help ensure that the data are not 

used inappropriately, it is important to fully disclose any limitations that 

apply. 

To enhance the NRP’s implementation, we recommend that the 

Postmaster General take the following three actions to improve program 

management and enhance accountability and transparency: 

Conclusions 

Recommendations for 

Executive Action 

• Articulate senior management’s commitment to the NRP by setting 

program milestones, including a timeline for all districts to complete the 

NRP; 

• When deployed, use the Service’s new claims management process to 

track and measure whether the NRP’s goals are being met, including 

tracking the number of employees placed in necessary and medically 

suitable modified work assignments; and 

• Fully disclose any limitations that apply to NRP-related cost savings 

reported to the Congress and others. 

Page 30 GAO-10-78 U.S. Postal Service
The Service provided its written comments on a draft of this report by 

letter dated December 1, 2009. These comments are summarized below 

and are included, in their entirety, as appendix V of this report. 

Agency Comments 

and Our Evaluation 

The Service agreed with our third recommendation, indicating that, in the 

future, it will fully disclose any limitations that apply to NRP-related cost 

savings it reports to the Congress and others; however, the Service 

disagreed with our first and second recommendations. In commenting on 

our first recommendation, the Service stated that it does not believe that 

setting an “arbitrary deadline” for the NRP’s completion is in the best 

interests of its employees. We agree that establishing an arbitrary deadline 

is inappropriate because it could result in unacceptable and unintended 

employee outcomes. Thus, we clarified our draft to exclude any 

unintended suggestion that the NRP should be completed by September 

30, 2010, which, according to senior headquarters officials, is the current 

estimated date for completing the NRP. The Service also stated that the 

NRP received “complete senior management support as evidenced by the 

commitment of resources by each area.” While we believe that many 

senior managers fully committed to the NRP’s timely implementation, 

according to senior headquarters officials and, as discussed in our report, 

the level of commitment at the local level has varied greatly. Consequently, 

we continue to believe that the Service should, after careful consideration 

of the time required to reasonably complete the remaining portion of the 

NRP, establish timelines for its completion nationwide and, where 

practicable, track progress against those timelines. This would help ensure 

that local managers properly prioritize the NRP, which is especially 

important given that more than 3 years have passed since implementation 

of the NRP began. 

The Service disagreed with our second recommendation that it establish 

methods for tracking and measuring whether the NRP’s goals are being 

met. The Service stated that the reports it uses to monitor the program are 

sufficient for its purposes and that in February 2010 it intends to deploy a 

new national claims management program that will enhance its ability to 

aggregate NRP-related data. While the Service’s current reports may be 

sufficient for its senior management officials, given the importance of this 

program and its potential impact on thousands of employees, we believe it 

is important to fully track whether the NRP’s goals are being met. Thus, 

we have revised our recommendation to clarify that we believe the Service 

should use its new program, when available, to track and measure all NRP 

employee outcomes, including the number of employees placed in 

necessary and medically suitable modified work assignments. This will 

Page 31 GAO-10-78 U.S. Postal Service
enhance transparency in reporting program outcomes to employees, 

unions, congressional stakeholders, and others. 

In its comments, the Service also stated that it did not agree that its 

“tracking data for the NRP is unknown.” While our draft report indicated 

that “the number of employees reassessed under the program is 

unknown,” we revised the report to clarify that the Service does not 

aggregate NRP data, and therefore, that it could not specify the number of 

employees being reviewed under the NRP nationwide. 

Service officials, including the Manager of the Service’s Office of Health 

and Resource Management, also provided oral technical comments, which 

we incorporated as appropriate. 

We are sending copies of this report to appropriate congressional 

committees and the U.S. Postal Service. The report also is available at no 

charge on the GAO Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me at 

Herrp@gao.gov or (202) 512-2834. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

Phillip Herr 

of this report. Key contributors to this report are listed in appendix VI. 

Director, Physical Infrastructure Issues 

Page 32 GAO-10-78 U.S. Postal Service
Appendix I: Objectives, Scope, and 

Methodology 

Page 33 GAO-10-78 

Appendix I: Objectives, Scope, and 

Methodology 

Because of congressional interest in whether the large number of United 

States Postal Service (Service) employees in modified work assignments 

are being productively employed, we were asked to review the Service’s 

National Reassessment Process (NRP). Our work focused on three 

objectives: (1) What is the goal of the NRP? (2) How is the initiative being 

implemented? (3) What is the status of the NRP, and what outcomes have 

been achieved? 

To address these objectives, we reviewed and analyzed, among other 

documentation, (1) applicable laws, regulations, and postal policies and 

procedures for protecting federal employees who sustain a compensable 

workplace injury, including their rights with respect to job restoration; 

(2) Service documentation describing the goals of the NRP and the 

process for implementing the initiative, as well as available Service data on 

the status and outcomes of the NRP;1

 (3) documentation from the four 

largest postal unions,2

 including information about the unions’ views on 

the NRP; and (4) information about the Department of Labor’s (DOL) 

Office of Workers’ Compensation Programs (OWCP), which makes wage 

loss and other payments to employees with compensable workplace 

injuries. We also interviewed a wide range of postal officials, including 

senior headquarters health and resource management officials who are 

responsible for the NRP’s implementation, injury compensation, and labor 

relations, and the Service’s Office of General Counsel. In addition, we 

interviewed national-level representatives from each of the Service’s four 

largest unions, DOL officials, some postal employees affected by the NRP, 

and other postal personnel, as applicable. To accomplish our objectives, 

we also visited four districts—San Francisco, Westchester, the Dakotas, 

and Dallas—and conducted in-depth, semistructured interviews with a 

broad range of individuals, including members of each district’s District 

Assessment Team, district and facility managers, and local union 

representatives, and contacted officials in four other districts—Sierra 

 

1

Available data on employee outcomes arising from Phase 2 are as of June 30, 2009, while 

data on the outcomes of Phase 3 are as of August 31, 2009. We determined these data were 

sufficiently reliable for our reporting purposes. 

2

The four largest postal unions are the American Postal Workers Union, the National 

Association of Letter Carriers, the National Postal Mail Handlers Union, and the National 

Rural Letter Carriers’ Association. The four unions represent about 85 percent of all postal 

employees. 

 U.S. Postal Service
Appendix I: Objectives, Scope, and 

Methodology 

Coastal, Southeast New England, Los Angeles, and Santa Ana.3 The results 

of our discussions with officials in these districts are not generalizable to 

all of the Service’s districts. Finally, we reviewed prior reports and 

literature on, for example, the value of returning injured employees to 

work as soon as possible; reports on the Service’s declining financial 

circumstances, including GAO’s high-risk reports and the Service’s recent 

annual financial reports and comprehensive statements for fiscal years 

2007 and 2008; and guidance on key principles for managing agency 

initiatives and reporting program outcomes. Because the Service did not 

begin Phase 3 of the NRP until July 2009, our work primarily focuses on 

Phases 1 and 2 of the NRP. Using data supplied by the Service, we also 

determined the number of employees who either occupied (or could have 

occupied) a modified assignment during fiscal year 2008. Our methodology 

for this analysis is contained in appendix II. 

While the Service has ergonomics and other safety-related programs to 

reduce workplace injuries, we did not evaluate their effectiveness in 

controlling the numbers of employees with workplace injuries in modified 

work assignments. In addition, we excluded from our review postal 

employees who sustained off-the-job injuries. Similarly, we excluded 

postal employees who had sustained compensable workplace injuries but 

have medical restrictions that preclude them from continuing to work for 

the Service because they are not in modified work assignments.4

 Related 

to this, because of the time and complexity involved in cross-matching 

individuals in modified work assignments with DOL’s OWCP payment 

records, we did not determine the portion of the Service’s costs for 

workers’ compensation that is attributable to individuals in modified work 

assignments. Finally, while we evaluated the Service’s methods for 

estimating cost savings arising from the NRP, we did not attempt to arrive 

at an independent assessment of the overall savings attributable to the 

NRP initiative because it was not feasible to analyze thousands of 

individual employee records at each of the Service’s districts to determine, 

among many other matters, the (1) number of hours worked (or not 

 

3

We selected the four districts we visited to include districts that (1) had either relatively 

high or low percentages of employees in modified work assignments as of December 2008 

and (2) were implementing various phases of the NRP (Phase 1 or 2) when we began our 

review. In addition, the four selected districts are geographically diverse and represent a 

mix of urban, suburban, and rural locations. Finally, we selected the four other districts we 

contacted because they had been implementing Phase 3 of the NRP the longest. 

4

Unlike employees in modified work assignments, these individuals presumably receive the 

entirety of their work-related compensation from DOL’s OWCP program. 

Page 34 GAO-10-78 U.S. Postal Service
Appendix I: Objectives, Scope, and 

Methodology 

worked) by each employee in a modified work assignment, (2) each 

employee’s hourly wage rate with benefits, or (3) possible differences in 

productivity between each employee’s pre- and post-NRP work 

assignments. In addition, data needed to offset these savings against 

additional costs incurred (i.e., determine the Service’s net savings), such 

as the cost of implementing the NRP and increased OWCP costs 

associated with some employee outcomes, were either not available or not 

feasible to determine.5

We conducted this performance audit from October 2008 to December 

2009, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

 

5

While we requested data on the cost of implementing the NRP, the Service did not provide 

us with this information. Furthermore, although OWCP costs associated with employee 

outcomes resulting from the NRP can be determined, it was not feasible for us to do so for 

a wide variety of reasons, including the time and effort required to cross-match employees 

with specific NRP outcomes, such as “no work available” determinations (Phase 2) and 

“complete day no work” and “part-day no work” determinations (Phase 3), to DOL’s OWCP 

payment records. 

Page 35 GAO-10-78 U.S. Postal Service
Appendix II: Methodology for Determining 

Number of Service Employees Who Occupied Appendix II: Methodology for Determining (or Could Have) a Modified Work Assignment 

Number of Service Employees Who Occupied 

(or Could Have) a Modified Work Assignment

According to senior headquarters officials responsible for implementing 

the NRP, there were 31,044 Service employees in modified work 

assignments on September 30, 2008—the last day of fiscal year 2008. 

Because this number understates the total number of employees in these 

assignments throughout the year, we analyzed Service data to determine 

the total number of employees in these assignments at any time during 

fiscal year 2008.1

 Our analysis found that over 50,031 employees with 

workplace injuries occupied a modified work assignment during fiscal 

year 2008. In addition, another 9,740 employees with workplace injuries 

could have occupied such an assignment, for a total of 59,771 employees 

who either occupied (or, could have occupied) a modified work 

assignment in fiscal year 2008.2

 We determined that the Service’s data were 

sufficiently reliable for our reporting purposes. 

The following information describes our methodology for conducting this 

analysis. We obtained Service data on employees in modified assignments 

during fiscal year 2008—the period from October 1, 2007 through 

September 30, 2008. These data are contained in one or more Excel 

workbooks from headquarters and each of the 80 districts that existed 

when we began our review.3

 The workbooks contain various information 

about the employees, including their name; work location; work status;4

and a unique identifier, such as their Social Security numbers. 

Because data in these workbooks were not presented uniformly, we 

standardized the data before beginning our analysis. In addition, we 

performed other data cleaning activities to address other anomalies. For 

example, because certain employee records had obvious errors, such as 

Social Security numbers with fewer than nine digits, or beginning with 

“000,” we eliminated these data from further analysis. Finally, we 

 

1

The number of employees in modified work assignments fluctuates both between years 

and within each year as employees, for example, (1) incur injuries and, possibly, begin 

working in modified assignments and (2) return to full duty, retire, or otherwise separate 

from the Service (i.e., leave their modified work assignments). 

2

Collectively, these employees represent about 7 to 8 percent of the Service’s workforce 

during fiscal year 2008. 

3

While the Service has eliminated 6 of its districts, it had 80 districts in fiscal year 2008. 

4

Data on the employee’s work status provides, for example, information on whether the 

employee was in a modified assignment during fiscal year 2008 and whether he or she 

retired, separated, or returned to full duty during that fiscal year. 

Page 36 GAO-10-78 U.S. Postal Service
Appendix II: Methodology for Determining 

Number of Service Employees Who Occupied 

(or Could Have) a Modified Work Assignment 

eliminated data fields that were not relevant to our review, such as 

information about the employees’ pay locations. 

We then analyzed the data to determine the number of unique employees 

contained in the Service’s workbooks.5

 In total, there were 59,824 unique 

employees at the start of our analysis. The majority of these employees 

(51,516 of 59,824 or, about 86 percent) had only one line of data, or 

“record,” in the workbooks. However, the remaining 8,308 employees had 

more than one record during fiscal 2008.6

 To ascertain the correct 

employee record to use in these cases, we devised a protocol for deleting 

all but the most recent of the employees’ records.7

 Thus, at the completion 

of this activity, we had one record for each of these 8,308 employees. 

To determine which of the 59,824 employees occupied a modified work 

assignment during fiscal year 2008, we ran a frequency analysis on the 

employees’ work status data. In total 50,031 of the 59,824 employees were 

coded “1,” meaning that they were in a modified assignment at some point 

during fiscal year 2008. The remaining 9,793 employees, however, had a 

variety of other work status codes, including 53 that we eliminated 

because data irregularities precluded us from determining anything about 

the employees’ work status. This left us with 9,740 employees with data 

indicating that the employees had occupied a modified work assignment at 

some point in the past, but, for example, subsequently had retired or 

otherwise separated from the Service. Thus, sufficient data were not 

available for us to determine whether these employees actually occupied a 

modified work assignment during fiscal year 2008. However, based on our 

knowledge of the Service’s data, and our discussions with senior 

headquarters officials, we determined that each of these 9,740 employees 

could have occupied a modified work assignment during fiscal year 2008. 

We shared our findings with senior headquarters officials who indicated 

that the results of our analysis were reasonable. 

 

5

To ensure that employees in these assignments were counted only once in our analysis, we 

generally used the employees’ Social Security numbers as their unique identifier. However, 

five of the districts’ workbooks did not provide the employees’ Social Security numbers, so 

we created other, unique identifiers for these employees. 

6

Multiple records occur when, for example, an employee reaches his or her maximum 

medical improvement and is moved from a limited duty assignment to a rehabilitation 

assignment. The 8,308 employees had from 2 to 10 records. Determining why these 

employees had up to 10 records was beyond the scope of this review. 

7

This protocol was approved by senior Service headquarters officials with overall 

responsibility for the workbooks and for implementing the NRP. 

Page 37 GAO-10-78 U.S. Postal Service
Appendix III: Number, Percentage, and 

Distribution of Modified Work Assignments Appendix III: Number, Percentage, and Nationwide during Fiscal Year 2008 

Distribution of Modified Work Assignments 

Nationwide during Fiscal Year 2008 

As discussed in the body of this report, our analysis of Service data found 

wide variability among Service districts nationwide in the number, 

percentage, and distribution of employees in limited duty and 

rehabilitation assignments (modified work assignments) during fiscal year 

2008. For example, in Dallas, over 12 percent of all employees in the 

district (1,719 of 14,150) were in a modified work assignment; while in the 

Metro Caribbean district, fewer than 2 percent occupied one of these 

assignments during fiscal year 2008.1

 In addition, about 50 percent of the 

50,031 employees in modified work assignments during fiscal year 2008 

worked in 30 percent of the Service’s organizations (24 of 81 

organizations, including headquarters).2

 Table 2 shows the number and 

percentage of employees in modified work assignments nationwide and 

the distribution of these assignments, by organization, during fiscal year 

2008. 

Table 2: Number, Percentage, and Distribution of Service Employees in Modified Work Assignments Nationwide during Fiscal 

Year 2008

Rank 

Service organization 

(district or headquarters) 

Number of 

employees in 

limited duty 

assignments

Number of 

employees in 

rehabilitation 

assignments

Total number of 

employees in 

modified 

assignments

Total number—

all employees 

Percentage of 

workforce in 

modified 

assignments

1 Dallas 792 927 1,719 14,150 12.15%

2 San Francisco 479 684 1,163 9,651 12.05

3 Bay Valley 1,255 189 1,444 12,276 11.76

4 Detroit 698 253 951 8,412 11.31

5 Los Angeles 1,131 181 1,312 11,932 11

6 Northern Ohio 1,096 186 1,282 12,019 10.67

7 Santa Ana 720 753 1,473 14,059 10.48

8 Colorado Wyoming 671 704 1,375 13,708 10.03

9 Seattle 954 174 1,128 11,282 10

10 Louisiana 794 132 926 9,413 9.84

 

1

The Service’s headquarters organization had the lowest percentage (70 of 11,370 

employees or, fewer than 1 percent) of employees in modified work assignments during 

fiscal year 2008. 

2

As discussed in appendix II, our analysis of Service data indicates that 50,031 employees 

with workplace injuries occupied a modified work assignment during fiscal year 2008. Up 

to 9,740 other employees could have been in such an assignment during the same time 

period. However, for the purpose of this analysis, we limited our analysis to the 50,031 

employees who, based on the Service’s data, definitely occupied a modified work 

assignment during this period. 

Page 38 GAO-10-78 U.S. Postal Service
Appendix III: Number, Percentage, and 

Distribution of Modified Work Assignments 

Nationwide during Fiscal Year 2008 

Rank 

Service organization 

(district or headquarters) 

Number of 

employees in 

limited duty 

assignments

Number of 

employees in 

rehabilitation 

assignments

Total number of 

employees in 

modified 

assignments

Total number—

all employees 

Percentage of 

workforce in 

modified 

assignments

11 Atlanta 1,245 166 1,411 14,502 9.73

12 Pittsburgh 508 127 635 6,737 9.43

13 Cincinnati 740 289 1,029 10,953 9.39

14 Sacramento 549 430 979 10,863 9.01

15 Southeast Michigan 567 79 646 7,271 8.88

16 San Diego 496 495 991 11,262 8.8

17 South Florida 534 319 853 9,832 8.68

18 Sierra Coastal 365 531 896 10,332 8.67

19 Ft. Worth 363 371 734 8,540 8.59

20 Chicago 571 178 749 9,315 8.04

21 Columbus 440 87 527 6,719 7.84

22 Houston 840 170 1,010 13,010 7.76

23 Alaska 118 25 143 1,867 7.66

24 Suncoast 585 324 909 11,914 7.63

25 Oklahoma 275 328 603 8,053 7.49

26 Lakeland 702 253 955 12,923 7.39

27 Northern Illinois 387 392 779 10,729 7.26

28 Philadelphia 722 140 862 11,926 7.23

29 Northern Virginia 302 157 459 6,457 7.11

30 Portland 578 40 618 8,803 7.02

31 S.E. New England 337 139 476 6,896 6.9

32 North Florida 351 295 646 9,531 6.78

33 Capital District 423 188 611 9,347 6.54

34 N. New Jersey 580 213 793 12,132 6.54

35 Greater Indiana 557 286 843 13,161 6.41

36 Salt Lake City 185 92 277 4,332 6.39

37 Central Illinois 719 50 769 12,444 6.18

38 Big Sky 106 55 161 2,614 6.16

39 Triboro 476 150 626 10,217 6.13

40 Central Pennsylvania 651 51 702 11,536 6.09

41 Connecticut 433 180 613 10,082 6.08

42 Erie 241 23 264 4,353 6.06

43 Arizona 500 176 676 11,265 6

44 Long Island 450 44 494 8,333 5.93

45 Massachusetts 339 249 588 9,989 5.89

Page 39 GAO-10-78 U.S. Postal Service
Appendix III: Number, Percentage, and 

Distribution of Modified Work Assignments 

Nationwide during Fiscal Year 2008 

Rank 

Service organization 

(district or headquarters) 

Number of 

employees in 

limited duty 

assignments

Number of 

employees in 

rehabilitation 

assignments

Total number of 

employees in 

modified 

assignments

Total number—

all employees 

Percentage of 

workforce in 

modified 

assignments

46 Gateway 504 239 743 12,679 5.86

47 Nevada Sierra 275 30 305 5,216 5.85

48 Rio Grande 677 85 762 13,084 5.82

49 Greensboro 559 69 628 10,880 5.77

50 South Jersey 253 143 396 7,027 5.64

51 Central New Jersey 288 125 413 7,494 5.51

52 Honolulu 101 55 156 2,836 5.5

53 Boston 176 169 345 6,506 5.3

54 New Hampshire - Vermont 224 91 315 6,024 5.23

55 Baltimore 274 182 456 9,044 5.04

56 Greater Michigan 375 113 488 9,727 5.02

57 Mid-Carolinas 427 60 487 9,796 4.97

58 Appalachian 315 47 362 7,400 4.89

59 Richmond 238 204 442 9,064 4.88

60 Tennessee 571 124 695 14,578 4.77

61 Albuquerque 74 111 185 3,884 4.76

62 Western New York 291 69 360 7,747 4.65

63 Central Florida 342 121 463 9,974 4.64

64 Hawkeye 249 166 415 9,120 4.55

65 South Georgia 179 104 283 6,365 4.45

66 Maine 93 84 177 4,067 4.35

67 Greater S.Carolina 212 83 295 7,283 4.05

68 Arkansas 222 38 260 6,427 4.05

69 Mid-America 259 173 432 11,044 3.91

70 Alabama 212 171 383 9,857 3.89

71 Albany 151 150 301 7,813 3.85

72 Spokane 139 45 184 5,022 3.66

73 Central Plains 211 156 367 10,338 3.55

74 Dakotas 112 52 164 5,134 3.19

75 New York 407 67 474 15,146 3.13

76 Northland 451 31 482 15,781 3.05

77 Kentuckiana 159 139 298 10,034 2.97

78 Mississippi 103 53 156 5,576 2.8

79 Westchester 73 54 127 6,424 1.98

80 Metro Caribbean 27 35 62 3,404 1.82

Page 40 GAO-10-78 U.S. Postal Service
Appendix III: Number, Percentage, and 

Distribution of Modified Work Assignments 

Nationwide during Fiscal Year 2008 

Rank 

Service organization 

(district or headquarters) 

Number of 

employees in 

limited duty 

assignments

Number of 

employees in 

rehabilitation 

assignments

Total number of 

employees in 

modified 

assignments

Total number—

all employees 

Percentage of 

workforce in 

modified 

assignments

81 Headquarters 34 36 70 11,370 0.62%

Total 35,082 14,949 50,031 748,307

Source: GAO analysis of Service data. 

Page 41 GAO-10-78 U.S. Postal Service
Appendix IV: D

by Ph

escription of NRP Activities, 

ase and Step 

Page 42 GAO-10-78 

Appendix IV: Description of NRP Activities, 

by Phase and Step 

Figures 6, 7, and 8 provide additional information about the NRP, 

including a description of activities, by phase and step. 

Figure 6: Description of NRP Activities in Phase 1 

Phase 1

Step Responsible team member Activity description

Source: GAO analysis of Service data.

1

2

3

4

5

6

7

8

9

10

11

12

13

• District Injury Compensation Specialist Identify all employees in modified work assignments

• Area National Assessment Process

 Injury Compensation Specialist 

Transfer information about these employees to the NRP workbook

• Area Injury Compensation Manager

• Area Medical Function Representative

• Area Operations Team Leader

Brief senior district management on NRP Phase 1

• District injury compensation staff

• District Injury Compensation Specialist or staff

• District Injury Compensation Specialist or staff

• Area injury compensation team

• Area Injury Compensation Manager

• District medical staff

• District injury compensation staff

• District medical staff

Identify employees in modified work assignments who require medical review

Review all employees identified in step 4; determine if medical updates are required

• District medical staff

• District injury compensation staff

• District labor relations staff

• District medical staff

• District labor relations staff

Follow up on employee medical update requests

• District Assessment Team (DAT) including DAT verifies current job offer matches tasks performed

operations, injury compensation and 

medical staffs

Ensure procedures for light duty assignments are in effect, enabling identification and tracking of these employeesa

Identify veterans-preference eligible employees in light duty assignments

Update NRP workbook to ensure all veterans in modified work assignments are properly recorded

Create NRP file for all employees in modified work assignments to ensure that all necessary documents are on file

Review injury compensation file and NRP file for employees in all modified work assignments to verify that the NRP file

is complete and accurate in preparation for reassessing employees

Area injury compensation staff review NRP Phase 1 actions – all aspects must be verified as accurately completed

a

In some cases, the Service also provides modified work assignments to employees injured off-thejob. These assignments are called “light duty” assignments. However, they are beyond the scope of 

our review. 

 U.S. Postal Service 
Appendix IV: Description of NRP Activities, 

by Phase and Step 

Figure 7: Description of NRP Activities in Phase 2 

• Headquarters Injury Compensation Team Leader Train area and district NRP teams on Phase 2 search process

• District senior management

• Area and district injury compensation team leaders • Area and district operations team leaders • Area and district labor relations managers

Hold meeting with all applicable union representatives

Phase 2a

Stage 1: Search

Stage 2: Job offer

Stage 3: NWA (no work available)

Step Activity description

• Area NRP team Introduce and initiate NRP Phase 2 with district senior staff

• Area injury compensation team • District injury compensation staff

Update NRP workbooks to include all employees who have reached their maximum medical improvement (MMI), i.e., employees

in rehabilitation assignments, and employees who have not reached their MMI, i.e., employees in limited duty assignments

• Area NRP team Meet with district NRP team to discuss “necessary work” assignments

• Area and district NRP teams

• Area NRP team 

Prepare local commuting area documentation for employees who have reached their MMI

Perform job searches for all employees who reached their MMI in less than a year to identify potential

rehabilitation assignments within their local commuting area

• Area and district NRP teams

• District NRP team 

• Area and district NRP teams

Perform job searches for all employees who reached their MMI in more than a year to identify potential

rehabilitation assignments within their local commuting area

Meet to discuss the status of all employees who have reached their MMI

• District Injury Compensation Manager 

• District operations team District operations team submits the DAT-approved proposed job offers (i.e., rehabilitation duties worksheets) to the senior

manager for approval, thus demonstrating that the position had been identified and approved by senior management.

• District injury compensation staff

• District operations team leaders Prepare and complete formal job offers

• District NRP team (operationsand injury compensation)

• District labor relations team Schedule employee interviews to discuss and present job offers; notify employees and union representatives

Conduct interviews for the approved job offers with employees

• District NRP team • District Injury Compensation Manager 

• District NRP Labor Relations Representative 

Two weeks after each interview, follow up to ensure that each employee has responded to their job offer

• District Injury Compensation Manager When the job offer is accepted, the Injury Compensation Manager must coordinate with the manager of the new facility

to prepare for the employee to start work there

Source: GAO analysis of Service data. 

1

1

1

2

2

2

3

3

3

4

4

4

5

5

5

6

6

6

7

7

8

8

9

9

10

11

12

• Area Injury Compensation Manager 

• Area Injury Compensation Team Leader

Meet with DOL‘s OWCP District Director to discuss the NRP and the Service’s preliminary NWA list

• Area and district NRP teams

• Area and district NRP team leaders

• Area NRP team leaders

Area and district teams review all NWA employee files and review them for accuracy

Meet with district managers on the status of the NRP and discuss the job searches that senior managers will have to approve

Brief surrounding district managers in the local commuting area on the NRP, and discuss the district's responsibility

in completing the job searches

• District injury compensation staff

• District NRP operations team

• District NRP team

• District NRP team

• District NRP team

• Area NRP team

• Area NRP team

Track and file job search results

13

14

15

Schedule interviews with employees receiving NWA determinations

Brief the Service’s Inspection Service and its Office of Inspector General on NRP and NWA interviewsb

• Area NRP team • District labor relations team • District Operations Team Leader

Brief local unions about ongoing and preliminary NWA employee results

Prepare employee resource guide and meet with applicable Service staff to discuss the final steps of the NWA process

Notify employees by letter at least 14 days in advance of employee interviews

Brief district NRP teams on the prescribed script for the interviews and select interview team leaders

• District NRP team • Area Operations Team Leader

• Area Injury Compensation Team Leader

• District NRP team • Area Operations Team Leader

• Area Injury Compensation Team Leader

Conduct first interviews with all affected employees

• District NRP Operations Team Leader or member Notify facility managers of upcoming second interview with employees receiving NWA determinations

Conduct second interviews with employees receiving NWA determinations

• District injury compensation staff 

• District NRP operations team Track and identify activities related to employees placed on OWCP’s rolls due to NWA determinations

Responsible team member

a

The Service calls this phase, “Phase 2: Rehabilitation.” To enhance the clarity of this report, we refer 

to this phase as “Phase 2.”

Page 43 GAO-10-78 U.S. Postal Service
Appendix IV: Description of NRP Activities, 

by Phase and Step 

b

The Service notifies representatives within its Postal Inspection Service and its Office of Inspector 

General in anticipation of problems that may be encountered during interviews with employees 

receiving an NWA determination. 

employees 

Figure 8: Description of NRP Activities in Phase 3

Phase 3a

Stage 1: Implementation

Stage 2: Work status

Stage 3: New medical/new injury

Step Responsible team member Activity description

Source: GAO analysis of Service data.

1

1

1

2

2

2

3

3

3

4

4

5

6

• Headquarters Health and Resource

 Management Team Leader

Meet with area and selected district NRP team members and train them on this phase

• Headquarters NRP team

• Area NRP team Meet with district senior managers to initiate this phase and confirm their support

• District senior management

• DAT members Meet with union representatives and Service management organizations to inform them about this phase

• Area Health and Resource Management Team Leader 

• District health and resource management staff

Review NRP workbook files to ensure that all employees who have not yet reached their MMI are listed

• Area NRP team

• District NRP team

• Area NRP team

• District NRP team

Train district managers on their role in Phase 3

DAT conducts initial modified work assignment determinations and area team commences its review of

these determinations

• Headquarters/area/district NRP teams

• Headquarters/area/district NRP teams

Review all proposed modified work assignment determinations for accuracy

Train facility managers or supervisors on work status meetings and explain all possible work

status determinations

• DAT Review documentation for all modified work assignments for compliance

• Facility Manager/Supervisor

• Facility Manager/Supervisor

• Facility Manager/Supervisor

• Facility Manager/Supervisor

On a daily basis, review available necessary tasks and make assignment determinations, and conduct daily work

status meetings with injured employees who have not yet reached their MMI

Employee presents updated medical documentation for an existing injury or new documentation for a recent injury

Managers/supervisors assess each employee based on recently presented medical documentation to determine

the availability of necessary work

Managers/supervisors present work status determination to each employee, elicit employee feedback regarding

the proposed assignment, and make adjustments if necessary

a

The Service calls this phase, “Phase 2: Limited Duty.” We refer to this phase as “Phase 3.”

Page 44 GAO-10-78 U.S. Postal Service
Appendix V: Comments from the United Appendix V: Comments from the United States Postal Service 

States Postal Service 

Page 45 GAO-10-78 U.S. Postal Service
Appendix V: Comments from the United 

States Postal Service 

Page 46 GAO-10-78 U.S. Postal Service
Appendix VI: 

A

GAO Contact and Staff 

cknowledgments 

Page 47 GAO-10-78 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

Phillip Herr, (202) 512-2834, or Herrp@gao.gov

In addition to the individual named above, Kathleen Turner, Assistant 

Director; Shirley Abel; Teresa Anderson; Lindsay Bach; Lauren Calhoun; 

Jay Cherlow; Tonnye Conner-White; Elizabeth Eisenstadt; Colin Fallon; 

Lauren Gilbertson; Brandon Haller; Elizabeth A. Marchak; Josh Ormond; 

Patricia Owens; Jerome Sandau; and Laura Shumway made key 

contributions to this report. 

 U.S. Postal Service 

GAO Contact 

Staff 

Acknowledgments 

(546011) 
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