U.S. Postal Service: Improved Management Procedures Needed for Parcel Select Contracts
Released: 2015-05-26T00:00:00

Letter

Background

The Package Delivery Market Is Complex and Changing Rapidly

The package delivery market is growing and changing rapidly. In 2013, U.S. businesses and consumers reportedly spent more than $68 billion to ship packages domestically using the three largest national package delivery providers in the U.S.—United Parcel Service (UPS), Federal Express Corporation (FedEx), and USPS. This spending is driven in large part by recent growth in electronic commerce, which is forecast to grow in the double digits year-over-year to bring electronic commerce’s share of overall U.S. retail sales to almost 9 percent, or $490 billion, by the end of 2018. According to USPS, revenues from its Shipping and Packages services—which includes Parcel Select—have grown from about $11.6 billion in fiscal year 2012 to over $13.7 billion in fiscal year 2014, and generate about 20 percent of USPS’s total operating revenues. USPS is placing increased emphasis on growth in these services to partially offset a continued decline in First-Class Mail.

Mailers have developed new delivery options to grow their businesses as the package delivery market evolves. For example, Amazon and Google started offering same-day package delivery service in select metropolitan areas. Some mailers have also introduced services that allow consumers to avoid package deliveries when they are not at home by picking-up packages themselves at alternative delivery locations. This development could reduce the need to provide last-mile delivery to individual residences. For example, Amazon allows customers to retrieve packages at self-service lockers in shopping centers, retail stores, transit stations, Similarly, in October 2014 and other access points in selected locations.UPS announced that consumers in two cities may retrieve packages from nearby locations—primarily neighborhood convenience and grocery stores—and it plans to expand the service to cover all major U.S. metropolitan markets in 2015.

In addition to large national mailers, smaller regional companies compete for business in the package delivery market. For example, LaserShip is a regional package delivery company that provides last-mile delivery to major East Coast markets. Similarly, OnTrac provides regional overnight package delivery service within several states on the West Coast.

As the package delivery market has changed, USPS must manage complex business relationships with its competitors. For example, although UPS and FedEx both pay USPS to deliver packages the last mile under certain circumstances, they also compete with USPS for end- to-end package delivery business—a concept that USPS officials refer to as “coopetition”. Similarly, FedEx is USPS’s largest contractor providing air transportation for Priority Mail Express (formerly Express Mail), Priority Mail, and First-Class Mail. UPS also is one of USPS’s largest contractors providing long-distance mail transportation.

Parcel Select NSAs Provide Increased Volume and Revenue to USPS and Discounted Prices to Mailers

USPS uses Parcel Select NSAs to encourage additional mail volume and revenue by providing mailers with discounted prices in exchange for meeting the contract’s terms and conditions. USPS data show that the Parcel Select product, including Parcel Select NSAs, is an increasingly important source of additional volume and revenue (see fig. 1).

While USPS uses Parcel Select NSAs to generate additional revenue, among other benefits, mailers use them to lower delivery costs and to take advantage of USPS’s extensive “last mile” network that serves more than 140 million residential delivery points 6 days a week. Contracts may require the mailer to ship a minimum volume of packages each contract year (minimum volume requirement) to qualify for discounted prices. Some contracts may require the mailer to pay USPS the difference between the discounted price and published price for Parcel Select if the mailer fails to meet this minimum volume requirement.

Shipping packages under Parcel Select lowers mailers’ delivery costs by allowing them to enter bulk shipments of packages into USPS’s network—generally at Destination Delivery Units (DDU)close to the final delivery point (see fig. 2). As a result, these packages generally bypass most of USPS’s mail processing and transportation network. Prices vary, depending on package weight, entry point, and the total volume shipped.

USPS must ensure that all Parcel Select NSAs comply with statutory requirements under the Postal Accountability and Enhancement Act (PAEA). Notably, each Parcel Select NSA is required to generate enough revenue to cover its attributable costs. For Parcel Select, these costs primarily include USPS labor involved in sorting packages at postal facilities and delivering them to the final delivery point. PRC reviews each Parcel Select NSA to ensure that it is projected to comply with this and other requirements before USPS can implement it. According to PRC, this pre-implementation review is justified to preserve fair competition.also reviews each contract after implementation to ensure compliance with statutory criteria—including the contract’s attributable cost coverage—in its Annual Compliance Determination Report.

USPS’s Recently Established Standard Procedures for Parcel Select NSAs Have Gaps

USPS Established Standard Procedures in June 2014

USPS’s Sales Department (Sales) has lead responsibility for managing Parcel Select NSAs and recently established standard procedures for managing NSA contracts. Specifically, in June 2014, Sales created the Standard Procedure for Managing NSA Contracts (Standard Procedures), which is an internal document that provides guidance that USPS departments should follow to manage all NSAs. Sales officials told us that they created the guidance in an effort to incorporate best practices and to improve USPS’s NSA contract management procedures by balancing standardization with flexibility. The Standard Procedures address, in part, some leading contract management practices. For example, as we discuss below, the procedures define some contract management responsibilities, such as performance monitoring and evaluation activities. Previously, USPS officials told us that no document or policy outlined USPS’s contract management procedures. Absent such guidance, USPS managers told us that they relied primarily upon their professional expertise and experience to manage the contracts.

Standard Procedures Define Some Contract Management Responsibilities

The Standard Procedures define some responsibilities for USPS departments involved in developing, monitoring, and evaluating the performance of Parcel Select NSAs, as indicated below. USPS officials told us about other responsibilities that are not specifically included in the Standard Procedures.

Contract Development

The Standard Procedures delineate contract development responsibilities for various departments within USPS, including Sales, USPS’s Finance Department (Finance), and USPS’s Legal Department (Legal) (see fig. 3).

After PRC issues an order approving a Parcel Select NSA, USPS begins to monitor and evaluate the performance of the contract. These responsibilities include internal performance reporting by Sales and Finance, submission of an annual compliance review to the PRC by Finance, periodic business reviews between USPS and mailers, and following contract termination or renewal procedures, as described below.

Internal performance reporting: The Standard Procedures call for Sales and Finance to use internal reports to monitor and evaluate performance under each Parcel Select NSA. Thus, Sales or Finance creates monthly, quarterly, and annual reports that analyze data that include the volume of packages shipped and revenue generated under the contract. For example, Finance develops a quarterly performance report that is used internally by Sales. This report communicates the Parcel Select NSA’s contractual requirements, actual and projected volume and revenue data, as well as descriptive information such as the contract’s effective and expiration dates.

Submission of compliance review to the PRC: In addition to internal reporting, USPS reports each NSA’s performance externally to the PRC. Specifically, Finance files USPS’s Annual Compliance Report to the PRC; this report covers the extent to which USPS finds that each NSA has met statutory requirements including whether each contract has covered its attributable costs. According to PRC officials, all Parcel Select NSAs have complied with these statutory requirements each year. However, PRC officials noted that they do not review and are not statutorily required to review the extent to which mailers or USPS have complied with other contractual requirements, such as minimum volume requirements and any payments to USPS for failure to meet these requirements as part of its Annual Compliance Determination Report.

Business reviews: USPS officials said that they use performance reports to conduct business reviews with mailers. Business reviews are meetings where USPS and the mailer discuss business opportunities, contract terms—such as volume requirements and pricing—and contract performance. The Standard Procedures define additional responsibilities USPS should perform if a mailer is at risk of failing to meet contractual conditions. For example, if Parcel Select NSA performance is below contractual terms, Sales should establish a plan and timeline for improved performance. Furthermore, Sales should schedule additional monthly or bi-monthly business reviews to ensure performance improves in accordance with the established plan.

Contract termination or renewal: According to Sales officials, the final activity for managing a Parcel Select NSA is to terminate, renew, or allow the contract to expire. Each Parcel Select NSA describes how the contract can be terminated. Contract terms and conditions typically allow USPS and mailers to terminate a Parcel Select NSA by mutual agreement in writing for convenience. According to the PRC, USPS should promptly notify the PRC if a Parcel Select NSA is terminated prior to the scheduled expiration date. Sales officials said that they generally contact mailers 3 to 6 months before a Parcel Select NSA expires to explore whether renewing the contract would be mutually beneficial. If both parties agree, Sales officials told us that USPS and the mailer should follow the same procedures used to create the original contract to execute the renewal. If either party does not wish to renew the contract, the Parcel Select NSA expires on its contractually specified date.

Standard Procedures Have Gaps in Contract Monitoring and Evaluation

While the Standard Procedures address some responsibilities involved in managing Parcel Select NSAs, some gaps exist. Specifically, the procedures lack documentation requirements and clearly defined management responsibilities for some contract monitoring and evaluation activities. A senior USPS official acknowledged that the Standard Procedures contained gaps when the document was initially established and that Sales had not reviewed or updated the procedures, which could have provided USPS with an opportunity to identify and address such gaps.

Documenting contract monitoring and evaluation activities: USPS’s Standard Procedures lack documentation requirements for some contract monitoring and evaluation activities such as the occurrence and results of business reviews for active Parcel Select NSAs. Each of the seven contracts that were effective in October 2014 requires USPS to conduct business reviews to discuss contract performance semiannually. However, Sales officials told us they did not know the extent to which they conduct business reviews for each contract, because they do not always document that the meetings actually happen. Sales officials verified—through emails, meeting agendas, and other documents—that staff scheduled or conducted at least one business review for five of these seven contracts.

Similarly, the Standard Procedures lack requirements for documenting some key management decisions pertaining to contract monitoring and evaluation. For example, USPS did not document management decisions about an underperforming contract. Specifically, according to Sales officials, when one mailer did not reach its minimum volume requirement, Sales did not document any discussions with the mailer to address the issue. Moreover, USPS did not require the mailer to pay the difference between the discounted price and the published price, as called for under the contract. Sales officials told us that they decided not to require the payment for business reasons, including maintaining this mailer as a source of package volume and allowing the mailer time to adjust to changing market conditions that influenced its performance. Although we recognize that USPS should have flexibility to reach management decisions based upon the facts and circumstances of each contract, Sales officials did not document the reasons for their decision to leave the performance issue unresolved and forgo the additional revenue. Documenting such information would help ensure that future decisions are based upon past results and enhance accountability for the effective and efficient use of USPS resources.

Internal control standards state that information should be documented in a form and within a time frame that enables individuals to carry out their internal control and other responsibilities and that the documentation should be properly managed and maintained. Reviewing and updating the Standard Procedures to include documentation requirements would provide additional assurance that USPS’s Parcel Select NSAs are effectively managed. Inconsistent management and maintenance of documentation also increases the risk that USPS may not retain important institutional knowledge. As previously mentioned, management responsibility for Parcel Select NSAs has transitioned among three different USPS entities since calendar year 2008 (see fig. 4). USPS officials told us that documentation of key management decisions was lost or discarded when lead responsibility for managing the contracts transitioned from Domestic Products to Sales in 2012. The projected importance of package shipping and Parcel Select NSAs to USPS’s financial future highlights the importance for USPS to document contract management activities to retain institutional knowledge and inform future decision-making.

Defining management responsibilities for contract monitoring and evaluation activities: USPS’s Standard Procedures do not define who is responsible for addressing unresolved contract performance issues and how staff should resolve them. Internal control standards state that organizations should clearly define key areas of responsibility and establish procedures to ensure that management promptly resolves performance issues. Without clearly defining who is responsible for promptly addressing performance issues and the procedures these individuals should follow, USPS is at risk of leaving performance issues unresolved—such as the example of a mailer’s failure to reach minimum volumes discussed above—issues that could impact future contract performance.

In addition, the Standard Procedures do not clearly define who is responsible for reporting contract changes, such as rate adjustments and amendments, to PRC. Internal control standards and leading contract management practices we identified state that organizations should establish appropriate lines of reporting. Without clearly defining who is responsible for reporting information to PRC in the Standard Procedures, USPS is at risk of not reporting contract changes to PRC as required. For example, although PRC requested that USPS file an amendment to a Parcel Select contract in November 2014, USPS did not file the requested amendment as ordered. Similarly, according to PRC notices, on several occasions USPS did not report discretionary rate adjustments for Parcel Select NSAs as required.

USPS Could Improve Its Method to Estimate Attributable Costs for Parcel Select NSAs

Each competitive product, including each Parcel Select NSA, must earn sufficient revenues to cover its attributable costs; however, USPS’s costing method to estimate attributable costs for individual Parcel Select contracts does not account for all key cost factors. USPS compiles attributable costs for the Parcel Select product by using data from various information systems—notably financial accounting systems—that collect data on employee compensation and benefit costs. USPS then estimates how much employee time is spent handling Parcel Select packages by collecting additional data.USPS then estimates the total attributable costs for the Parcel Select product. However, USPS officials told us that they do not collect or study some information that could improve these estimates for individual Parcel Select contracts. Specifically, while USPS does collect data on the weight of all Parcel Select packages, it does not collect information on the size of NSA packages and has not studied the impact of either of these factors on USPS’s delivery costs for specific contracts. This limits USPS’s analysis of attributable costs for Parcel Select NSAs.

USPS uses three basic delivery modes: door, “curbline,” and centralized delivery. Door delivery includes delivery to mail slots in the door as well as mailboxes attached to houses. Curbline delivery includes delivery to curbline mailboxes that are typically unlocked mail receptacles on a post and commonly used on routes serving residential customers. Centralized delivery is provided to centrally located mail receptacles, such as apartment house mailboxes and cluster box units. As we reported in May 2014, USPS estimated that its delivery costs in fiscal year 2012 ranged from about $380 annually for the average door delivery point to about $240 for curbline delivery and about $170 for centralized delivery. See GAO, U.S. Postal Service: Delivery Mode Conversions Could Yield Large Savings, but More Current Data Are Needed, GAO-14-444 (Washington, D.C.: May 12, 2014). or split routes, resulting in decreased operational efficiency and additional operating costs (see fig. 5).

Moreover, private sector mailers use package weight and size information to inform their own business decisions. For example, UPS and FedEx— both of which pay USPS to deliver packages the last mile under certain circumstances and compete with USPS for end-to-end package delivery business—recently began basing the ground delivery rates they charge on both the size and weight of packages, a concept called “dimensional Representatives from another mailer told us that in serving weighting.”their own customers, they continually assess the characteristics of each package—including weight and size—to determine the costs of handling each package and to make cost-effective decisions regarding the delivery method they choose. If mailers choose to route larger or heavier packages via Parcel Select, collecting and studying information on the weight and size of packages could position USPS to better understand how this affects its delivery costs and the extent to which revenues for individual Parcel Select NSAs cover their attributable costs.

In addition to not collecting detailed cost information that accounts for key package characteristics, USPS’s method to estimate attributable costs uses national averages for Parcel Select packages instead of contract- specific cost estimates for each NSA. This estimating further limits USPS’s analysis of the extent to which each contract covers its attributable costs. Specifically, because USPS does not have contract- specific cost estimates, USPS compares (a) the average cost per piece for Parcel Select packages with (b) the average revenue per piece for each Parcel Select NSA.

PRC officials told us that based on currently available information, they had not observed significant variations in the characteristics of packages shipped under individual Parcel Select NSAs that would suggest that using average costs is not reasonable. However, as we describe above, USPS does not collect or study information that could help inform the reasonableness of its method to estimate attributable costs. Finance officials stated that because the weight of packages shipped under the Parcel Select NSAs did not vary significantly from the average weight, they had no reason to believe that heavier Parcel Select packages delivered under the NSAs would be more costly to process and deliver than the average cost to deliver packages that are not under the NSAs. However, these officials noted that they had not studied the extent to which package characteristics—including package weight and dimension—varied under individual Parcel Select NSAs or whether they deviated from the characteristics of packages that USPS used to estimate the national average.

USPS officials questioned whether the time and expense required to develop contract-specific attributable cost estimates that account for package weight and dimension would significantly improve decision- making. Specifically, USPS officials said that for packages that mailers enter at DDUs, developing such estimates would require USPS to determine the costs that each DDU in its network would accrue— including costs associated with package size, package weight, delivery mode, and exact handling and delivery personnel—for each contract. For packages entered higher in USPS’s delivery stream (at sectional center facilities and network distribution centers), USPS officials noted that obtaining contract-specific information would require USPS to fully integrate the entire USPS mail data system and entirely replace its existing cost system, which would cost many hundreds of millions of dollars.

We recognize that USPS must carefully balance the costs and benefits associated with developing contract-specific attributable cost estimates for Parcel Select NSAs. However, without taking steps to collect and study key cost information to develop these estimates, limitations on USPS’s analysis of attributable costs will persist. In the past, USPS has used other less intensive methods to improve its cost estimates for other products. For example, USPS has used “special studies” to improve cost information by examining operations at a sample of USPS facilities over a limited period of time. According to USPS officials, such special studies have generally cost hundreds of thousands of dollars to conduct in the past, with costs varying depending on the study’s scope. For example, in 2008 PRC noted that disaggregated Parcel Select and Parcel To disaggregate these costs, USPS Return Service costs were needed.conducted a field study at sampled DDUs in the summer of 2008 and used the data it collected to isolate transportation and mail processing costs specifically for Parcel Select and Parcel Return Service products.

As another example, USPS recently conducted a comprehensive study of city carrier street time activities and costs, which involved collecting data on sampled city routes to help attribute city carrier costs to various types of mail, including parcels.

Conclusions

USPS continues to face significant financial challenges. Parcel Select helps to address these challenges by providing USPS with a revenue source that has increased from $466 million in fiscal year 2009 to over $2.5 billion in fiscal year 2014. Over time, USPS has taken important steps to standardize the procedures it uses to develop, monitor, and evaluate the performance of its Parcel Select NSAs, including developing its Standard Procedures in June 2014. However, the Standard Procedures lack documentation requirements and clearly defined management responsibilities for some contract monitoring and evaluation activities. Reviewing and updating the standard procedures to address these gaps would provide additional assurance that USPS’s Parcel Select NSAs are effectively managed. In addition, collecting and studying information on the size and weight of Parcel Select NSA packages could improve USPS’s analysis of attributable cost coverage for each contract and position USPS to better understand how mailers’ business decisions affect these costs. This may prove to be important, as mailers have developed more discrete costing methods based on both the size and weight of packages, which may influence the characteristics of packages that they provide to USPS for last-mile delivery.

Recommendations for Executive Action

To provide additional assurance that the procedures USPS uses to develop, monitor, and evaluate the performance of its Parcel Select NSAs are effective, the Postmaster General should direct executive leaders in Sales to: review the Standard Procedures to identify gaps in contract management responsibilities, including documentation requirements and assigning clearly defined management responsibilities for contract monitoring and evaluation activities, and update the procedures to address the identified gaps.

To better understand attributable costs for individual Parcel Select NSAs, the Postmaster General should direct the appropriate staff to: identify and implement cost-effective methods, such as using a sample, to collect and study information on the costs of delivering Parcel Select packages of varying characteristics in order to develop contract-specific attributable cost estimates.

Agency Comments and Our Evaluation

We provided a draft of this report to USPS and PRC for review and comment. USPS and PRC provided written comments, which are summarized below and reproduced in appendix II and appendix III, respectively. USPS and PRC also provided technical comments, which we incorporated, as appropriate.

In its comments, USPS agreed to update its Standard Procedures and concurred in principle to develop contract-specific attributable cost estimates for Parcel Select NSAs. USPS noted that it did not believe that package size and weight significantly affect the costs of Parcel Select NSAs, because most packages are entered at the DDU and thus bypass much of USPS’s processing and transportation network. However, as the report notes, while USPS does collect data on the weight of all Parcel Select packages, it does not collect information on the size of NSA packages and has not studied the impact of either of these factors on USPS’s delivery costs for specific contracts. This limits USPS’s analysis of attributable costs for Parcel Select NSAs. USPS stated it would explore obtaining additional mailer characteristics and ascertaining their relationships to costs for specific Parcel Select NSAs. USPS noted in its comments that it has already taken steps to obtain contract-specific characteristics for Sunday delivery of NSA packages. Sunday delivery, however, currently constitutes a relatively small percentage of Parcel Select volume.

As the report notes, collecting and studying information on the size and weight of Parcel Select packages is important, because larger and heavier packages can increase USPS’s delivery costs. The report also points out that private sector mailers use package weight and size information to inform their own business decisions, such as making cost- effective decisions regarding the delivery method they choose. As the report concludes, collecting and studying information on the size and weight of Parcel Select NSA packages could improve USPS’s analysis of attributable cost coverage for each contract and position USPS to better understand how mailers’ business decisions affect these costs. This understanding will be important given the rapidly changing package delivery market.

In its comments, PRC said that it found our draft report well-researched and balanced and agreed with both of our recommendations. PRC supported the cost-effective development of more accurate attributable cost estimates for Parcel Select NSAs. PRC also clarified that USPS’s method to estimate average costs for Parcel Select packages excludes Parcel Select mail weighing less than one pound. We modified the relevant text to note this clarification.

As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the appropriate congressional committees, Postmaster General, Acting Chairman of PRC, USPS Office of Inspector General, and other interested parties. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at 202-512-2834 or rectanusl@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff making key contributions to this report are listed in appendix IV.

Appendix I: Scope and Methodology

To examine the procedures that the U.S. Postal Service (USPS) has established to develop, monitor, and evaluate the performance of its Parcel Select negotiated service agreements (NSA), including implementation, we reviewed relevant laws and regulations such as the Postal Accountability and Enhancement Act (PAEA). We also examined USPS documents such as the Standard Procedure for Managing NSA Contracts that describe the procedures. We also reviewed copies of all 13 Parcel Select NSAs executed by USPS along with their supporting file documentation, such as contract performance and business review reports. This includes eight Parcel Select and five Parcel Select & Parcel Return Service contracts. For purposes of our report, we refer to both of these contract categories as Parcel Select NSAs, since each includes the Parcel Select product. We also examined Postal Regulatory Commission (PRC) documents, such as orders and notices. We did not review the extent to which USPS complied with all of its management procedures because this did not fall within the scope of this review. We also did not report volume, revenue, or mailer-specific information for individual NSAs because USPS and mailers consider the information proprietary, and according to USPS officials, public disclosure would violate contractual confidentiality provisions.

In addition, we conducted interviews with USPS officials from the Sales, Finance, and Legal departments, who are responsible for developing, monitoring, and evaluating the performance of Parcel Select NSAs; PRC officials responsible for reviewing the contracts; and representatives from eight mailers that signed 12 of the 13 Parcel Select NSAs to determine how USPS implements its procedures. The number of mailers is less than the number of implemented contracts because some mailers signed more than one contract. We did not interview representatives from one of the mailers that signed a Parcel Select NSA, because the company was sold and knowledgeable representatives were no longer available to meet with us. According to USPS, no packages were ever shipped under that contract. We compared USPS’s procedures for managing the contracts against selected leading contract management practices. To select these practices, we: Identified criteria sources that included leading contract management practices and then confirmed that these sources were appropriate through consultation with internal stakeholders. These sources included: (a) our standards for internal control in the federal government; (b) guidance documents and regulations for federal agencies, such as best practices issued by the Office of Federal Procurement Policy; and (c) documents from contract management and administration organizations including the National Contract Management Association and the Institute for Supply Management, which were recognized for their expertise in this area.

Reviewed information included in each criteria source to identify practices that are relevant to either (a) buyers and sellers or (b) just sellers. Because the Postal Service is the service provider (or seller) under Parcel Select NSAs, we excluded leading practices that are only pertinent to buyers. In addition, we identified practices that were applicable to USPS and its unique statutory and regulatory requirements as an independent establishment of the executive branch of the federal government.

Exercised professional judgment to select practices that we identified as particularly relevant to the managing Parcel Select NSAs.

Based upon these steps, we selected the following leading contract management practices: defining roles and responsibilities; establishing procedures for the contract management process; planning and negotiation; managing performance; communicating effectively; and documenting management activities and decisions. USPS agreed that these practices were relevant and reasonable.

To determine revenue and volume trends for Parcel Select, which we describe in the background of our report, we reviewed USPS Revenue, Pieces, & Weight reports, which present official USPS estimates. We assessed the reliability of these data by reviewing related documentation, such as a December 2007 USPS Office of Inspector General report on and by collecting information from knowledgeable USPS’s data system,USPS officials, and determined that the data were sufficiently reliable for our reporting purpose.

To examine the method that USPS uses to determine whether each Parcel Select NSA covers its attributable costs, we reviewed relevant laws and regulations that establish requirements for product categories and contracts such as PAEA. We also analyzed agency documents that describe or discuss the methodology that USPS uses, such as USPS’s fiscal year 2014 Annual Compliance Report and PRC’s Annual Compliance Determination Reports for fiscal years 2008 through 2013, the most recent reports available. We also reviewed relevant federal agency, academic, and GAO reports that describe USPS’s costing approach and related issues, such as the USPS Office of Inspector General’s audit reports. In addition, we conducted interviews with USPS and PRC officials to obtain their views on USPS’s cost coverage methodology. Finally, we made written requests for information regarding the methodology used to calculate attributable cost to USPS and PRC officials, who provided written responses on the subject. We did not review USPS’s postal costing methodology generally, such as methods to divide costs into attributable and institutional costs and methods to distribute attributable costs to various USPS products and services.

We conducted this performance audit from April 2014 through April 2015 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.

Appendix II: Comments from the United States Postal Service

Appendix III: Comments from the Postal Regulatory Commission

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, key contributors to this report were Lorelei St. James (Director); Derrick Collins (Assistant Director); Amy Abramowitz; Teresa Anderson; William Colwell; Aaron Colsher; Caitlin Dardenne; Colin Fallon; Kenneth John; DuEwa Kamara; Kimberly McGatlin; SaraAnn Moessbauer; Josh Ormond; Amelia Shachoy; Crystal Wesco; and Bill Woods.