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entitled 'U.S. Postal Service: The Program for Reassessing Work 
Provided to Injured Employees Is Under Way, but Actions Are Needed to 
Improve Program Management' which was released on December 14, 2009. 

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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

December 2009: 

U.S. Postal Service: 

The Program for Reassessing Work Provided to Injured Employees Is Under 
Way, but Actions Are Needed to Improve Program Management: 

GAO-10-78: 

GAO Highlights: 

Highlights of GAO-10-78, a report to congressional requesters. 

Why GAO Did This Study: 

Between 50,000 and 60,000 United States Postal Service (Service) 
employees, or 7 to 8 percent of the Service’s workforce, occupied a 
modified work assignment during fiscal year 2008. The Service must 
provide these assignments to employees with workplace injuries if work 
is available to perform within their medical restrictions. 
Historically, the Service has returned employees to work as soon as 
possible, partly to reduce its costs for workers’ compensation. In 
2006, the Service initiated a program, the National Reassessment 
Process, to ensure that modified work assignments are medically 
suitable and necessary to carry out the Service’s mission. This 
requested report addresses (1) the goal of the program, (2) how it is 
being implemented, and (3) the program’s status and outcomes. To 
perform its work, GAO analyzed data and documentation, visited four 
districts selected to illustrate a range of conditions, and interviewed 
Service officials. 

What GAO Found: 

The goal of the National Reassessment Process is to ensure that all 
employees in modified work assignments are performing work that is both 
suitable to their medical restrictions and necessary to the Service’s 
mission. Among other things, the program aims to eliminate what Service 
officials call “make–work” assignments which, over time, occurred when 
factors such as increasing automation and declining mail volumes 
reduced the amount of manual, sedentary, and useful work available for 
these employees to perform. The number of employees reassessed under 
the program is not readily available nationwide because the Service 
does not aggregate district data. However, on September 30, 2008, there 
were 31,044 employees in modified work assignments, all of whom may 
have been reassessed under the program. 

The program is being implemented in three phases in the Service’s 74 
districts. In Phase 1, the Service ensures that all employee medical 
records are current, and categorizes the employees based on their 
medical status. In Phases 2 and 3, the Service attempts to find each 
employee medically suitable and necessary work. If successful, the 
Service provides these employees with modified work assignments. 
However, when suitable work is not available, employees become eligible 
for wage loss compensation (workers’ compensation). Specifically, 
because employees in Phase 2 have reached their maximum medical 
improvement, they are not expected to return to work for the Service 
and, thus, may receive workers’ compensation indefinitely, whereas 
Phase 3 employees are eligible for workers’ compensation for only the 
number of hours they cannot work for the Service. Initially, the 
Service implemented each phase of the program sequentially; however, in 
July 2009, it began allowing some districts to conduct Phases 2 and 3 
concurrently to expedite the program’s completion. The Service has not 
established milestones for completing the program, but, according to 
Service officials, they expect the program to be fully implemented by 
September 30, 2010. 

After 3 years, none of the Service’s districts had completely 
implemented the program, and implementation in most is far from 
complete. Available data on employee outcomes are limited and 
preliminary because implementation is ongoing, and the Service does not 
track employees who receive medically suitable and necessary work—the 
goal of the program. The Service achieves program cost savings when, 
for example, employees return to full duty, retire, resign, or perform 
modified work assignments. However, when suitable work is not 
available, some employee outcomes could increase the Service’s short- 
and long-term costs for workers’ compensation. For the year ending June 
30, 2009, workers’ compensation costs totaled about $1.1 billion and, 
in 2008, the Service estimated that its future liability for these 
costs totaled about $8 billion. The Service reported to the Congress 
that the program saved $146 million in fiscal year 2008. However, the 
Service did not disclose that these reported savings reflect neither 
the Service’s total gross savings nor its net savings, nor any other 
limitations in its cost estimation methodology. 

What GAO Recommends: 

GAO recommends that the Service establish program completion timelines, 
track and measure outcomes, and disclose limitations of its reported 
cost savings. The Service agreed with GAO’s third recommendation and 
disagreed with the other two. While GAO modified one recommendation in 
response to the Service’s comments, GAO retained all three to encourage 
program completion, accountability, and transparency. 

View GAO-10-78 or key components. For more information, contact Phillip 
Herr, (202) 512-2834, or Herrp@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

The Goal of the NRP Is to Ensure That All Employees in Modified Work 
Assignments Are Performing Medically Suitable, Necessary Work: 

The Service Is Implementing the NRP in Three Phases, Which Take Many 
Months to Complete: 

Despite Incomplete NRP Implementation, the Service Estimated $146 
Million in Savings during Fiscal Year 2008: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Methodology for Determining Number of Service Employees 
Who Occupied (or Could Have) a Modified Work Assignment: 

Appendix III: Number, Percentage, and Distribution of Modified Work 
Assignments Nationwide during Fiscal Year 2008: 

Appendix IV: Description of NRP Activities, by Phase and Step: 

Appendix V: Comments from the United States Postal Service: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

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

Table 2: Number, Percentage, and Distribution of Service Employees in 
Modified Work Assignments Nationwide during Fiscal Year 2008: 

Figures: 

Figure 1: How a Physician's Determination about a Service Employee's 
MMI Status Affects the Type of Modified Work Assigned to the Employee: 

Figure 2: Key NRP Activities, Stages, and Possible Employee Outcomes, 
by Phase: 

Figure 3: NRP Outcomes Experienced by Service Employees in Modified 
Work Assignments: 

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

Figure 5: Status of NRP Implementation for Phases 1 and 2, by Step, as 
of August 31, 2009A: 

Figure 6: Description of NRP Activities in Phase 1: 

Figure 7: Description of NRP Activities in Phase 2: 

Figure 8: Description of NRP Activities in Phase 3: 

Abbreviations: 

DOL: Department of Labor: 

GAO: Government Accountability Office: 

MMI: maximum medical improvement: 

NRP: National Reassessment Process: 

NWA: no work available: 

OWCP: Office of Workers Compensation Programs: 

Service: United States Postal Service: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

December 14, 2009: 

The Honorable Stephen F. Lynch: 
Chairman: 
Subcommittee on Federal Workforce, Postal Service, and the District of 
Columbia: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Danny K. Davis: 
House of Representatives: 

In fiscal year 2008, the United States Postal Service (Service) had 
about 748,000 employees, representing about 25 percent of all federal 
employees. These employees also accounted for about 42 percent of all 
federal traumatic workplace injuries and occupational illnesses 
(injuries).[Footnote 1] According to Service officials, the high rate 
of employee injuries arises largely from the often physically 
demanding, industrial, and highly repetitive nature of their work. Some 
injured employees recover from their injuries quickly and return to 
work without medically prescribed physical restrictions (medical 
restrictions), while others require long-term, modified work 
assignments to accommodate their medical restrictions. Based on our 
analysis, there were between 50,000 and 60,000 postal employees, or 
about 7 to 8 percent of the Service's workforce, in these assignments 
at some point during fiscal year 2008, the most recent year for which 
complete data were available. Not included in this number are employees 
with workplace injuries who have medical restrictions that preclude 
them from returning to work for the Service in any capacity.[Footnote 
2] 

When employees are able to return to work after a compensable workplace 
injury, federal agencies, including the Service, are required to employ 
them if work is available that they can accomplish within their medical 
restrictions.[Footnote 3] In the 1990s, the Service aggressively 
pursued the return of employees to work as soon as possible as a means 
to (1) help employees recover more quickly and stay up to date with 
workplace changes and (2) reduce the Service's costs for workers' 
compensation.[Footnote 4] According to senior headquarters officials, 
the Service's previous practice often resulted in bringing employees 
back to work in "make-work" assignments without regard to productivity. 
In addition, they said that the practice created a workplace culture in 
which employees believed they were entitled to modified work 
assignments, regardless of whether the assignment was needed for the 
Service's mission. 

In 2006, the Service introduced a new, agencywide initiative--the 
National Reassessment Process (NRP)--to revise its practices for 
assigning modified work to injured employees. The Service's Office of 
Health and Resource Management is responsible for implementing the NRP. 
Numerous other postal officials are also involved through a phased 
implementation approach. The NRP is being carried out in the Service's 
74 districts,[Footnote 5] with supervision from headquarters and area 
officials, and focuses on reassessing employees in modified work 
assignments to determine whether the assignments are (1) within the 
employees' medical restrictions (medically suitable work) and (2) 
necessary to carry out the Service's mission. 

Because of congressional interest in the large number of postal 
employees in modified work assignments and whether these employees are 
being productively employed, we were asked to review the NRP. This 
report addresses the following objectives: (1) What is the goal of the 
NRP? (2) How is the program being implemented? (3) What is the status 
of the NRP, and what outcomes have been achieved? 

To address these objectives, we reviewed and analyzed, among other 
documentation, (1) applicable laws, regulations, and postal policies 
and procedures for protecting federal employees who sustain compensable 
workplace injuries, including their rights with respect to job 
restoration; (2) documentation describing the NRP's goal and the 
process for implementing the initiative, as well as available data on 
its status and outcomes; and (3) documentation and views on the NRP 
from the four largest postal unions. We also interviewed a wide range 
of Service officials, and officials within the Department of Labor's 
(DOL) Office of Workers' Compensation Programs (OWCP), which makes wage 
loss and other payments to federal employees with compensable workplace 
injuries. To determine the number of employees in modified work 
assignments during fiscal year 2008, we analyzed data from each of the 
Service's districts and headquarters and determined that the Service's 
data were sufficiently reliable for our reporting purposes. To obtain 
views on the NRP, we also visited four postal districts--San Francisco, 
Westchester, the Dakotas, and Dallas--and contacted officials in four 
other districts--Sierra Coastal, Southeast New England, Los Angeles, 
and Santa Ana.[Footnote 6] Finally, we reviewed prior reports and 
literature on the value of returning injured employees to work as soon 
as possible; reports on the Service's declining financial 
circumstances, including our high-risk report and the Service's recent 
annual financial reports and comprehensive statements for fiscal years 
2007 and 2008,[Footnote 7] which included data on the NRP's cost 
savings; and guidance on key principles for managing agency initiatives 
and reporting program outcomes. Additional information on our (1) scope 
and methodology, including information on how we selected the eight 
postal districts we contacted and (2) methodology for determining the 
number of employees with workplace injuries who occupied (or could have 
occupied) a modified work assignment during 2008 are provided in 
appendixes I and II, respectively. 

We conducted this performance audit from October 2008 to December 2009, 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Background: 

The Service's mission is to provide universal mail service 6 days a 
week to, as nearly as practicable, the entire U.S. population. The 
Service delivered mail to over 149 million addresses in 2008 and is 
broadly organized into nine large, geographic areas. Each of these 
areas comprises many postal districts, which collectively accomplish 
the Service's mission. To carry out its mission, the Service maintains 
a network of facilities, including over 36,700 retail and delivery 
facilities, such as local post offices and approximately 400 major mail-
processing facilities. In addition, the Service operates one of the 
largest vehicle fleets in the United States. The Service also employs 
career and noncareer employees to carry out its mission.[Footnote 8] 
Most of the Service's employees are in occupations (crafts) represented 
by one of the four largest postal unions. Table 1 identifies the four 
largest unions and the primary crafts each represents. 

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

Union: American Postal Workers Union; 
Primary crafts represented: 
Clerks: Provide customer services at retail and delivery facilities 
including selling postage, accepting packages for shipment, and 
dispensing Certified Mail or Registered Mail. They also operate 
machinery for sorting mail in facilities like processing and 
distribution plants; 
Technicians and mechanics: Diagnose and repair equipment and vehicles. 

Union: National Association of Letter Carriers; 
Primary crafts represented: 
City carriers: Organize mail into delivery sequence at postal 
facilities and deliver the mail along established routes, either by 
foot, or in a vehicle. 

Union: National Postal Mail Handlers Union; 
Primary crafts represented: 
Mail handlers: Load, unload, and move bulk mail, including sacks and 
trays at processing facilities; 
Equipment operators: Move mail throughout a facility using equipment 
such as a forklift or pallet truck. 

Union: National Rural Letter Carriers' Association; 
Primary crafts represented: 
Rural carriers: Organize mail into delivery sequence and deliver it by 
vehicle along established rural routes that vary in length. They also 
collect mail and sell stamps, money orders, and other products to 
customers along their routes. 

Source: GAO analysis of Service documentation. 

[End of table] 

Postal employees generally sustain two types of employment-related 
injuries--traumatic injuries and occupational illnesses. Traumatic 
injuries are linked to a specific event, such as when a letter carrier 
trips and falls while delivering mail, or when an employee is injured 
operating automated machinery in a processing plant. In contrast, 
occupational illnesses can develop from prolonged workplace exposure 
and repetitive motion activities, such as when a rural letter carrier 
develops a back, shoulder, or rotator cuff injury by repeatedly 
twisting and stretching to reach mail in the back of his or her 
vehicle. 

When federal employees suffer a compensable workplace injury, they are 
entitled to available work within their medical restrictions, in 
accordance with the Rehabilitation Act of 1973.[Footnote 9] The right 
to available work and the obligation to provide it (restoration rights) 
are contained in statute and regulations promulgated by the Office of 
Personnel Management, which has delineated different job restoration 
rights for employees, depending on their recovery status.[Footnote 10] 
These rights are also specified in various Service manuals, including 
the Employee and Labor Relations Manual. According to this manual, the 
Service will provide the following: 

* "rehabilitation" assignments to an employee "when the effects of the 
injury are considered permanent and/or the employee has reached his/her 
maximum medical improvement" (MMI), which means that, according to the 
employee's treating physician, the employee is unlikely to recover 
further; and: 

* "limited duty" assignments to an employee who has not reached his or 
her MMI and is expected to fully recover. 

Service employees remain in limited duty assignments until either they 
fully recover and return to work (i.e., return to full duty) or their 
physician determines that they have reached their MMI. Once a physician 
determines that an employee has reached his or her MMI and is able to 
work for the Service, the Service may provide the individual with a 
rehabilitation work assignment. If an employee is unable to work for 
the Service, the Service refers the employee to OWCP for wage loss 
compensation. 

Under the Federal Employees' Compensation Act and implementing 
regulations, injured employees must be examined by a medical officer or 
approved physician, the results of which are to be provided to the 
employer--in this case the Service. If a physician specifies medical 
work restrictions for the employee, the Service must consider these 
restrictions in providing a modified work assignment. For example, if 
after a compensable on-the-job injury, a physician determines that a 
city carrier can walk only 2 hours a day, the Service may try to find 
the employee a driving mail route that will allow the employee to 
remain seated most of the day. Similarly, if a clerk's medical 
restrictions specify that the clerk can neither stand nor extend his or 
her arms above shoulder height, the Service could physically lower the 
workstation the clerk uses to organize mail into delivery route 
sequence so that the task can be done while seated. 

The Service's Employee and Labor Relations Manual specifies different 
job restoration rights, depending on the length of time between (1) 
OWCP's approval of the employee's injury claim for compensation and (2) 
the date that the employee's physician specified that the employee 
reached his or her MMI.[Footnote 11] Figure 1 illustrates how a 
physician's determination about whether an employee has (or has not) 
reached his or her MMI affects the type of modified work assignment 
provided. 

Figure 1: How a Physician's Determination about a Service Employee's 
MMI Status Affects the Type of Modified Work Assigned to the Employee: 

[Refer to PDF for image: illustration] 

Injured employees: 

Employees injured off the job[A]; 

Employees injured on the job: 
* Employees who have not yet reached their MMI; 
* Employees in limited duty assignments. 

Employees injured on the job: 
* Employees who have reached their MMI; 
* Employees in rehabilitation assignments: 
- Employees who reached MMI in less than one year; 
- Employees who reached MMI in more than one year. 

Source: GAO analysis of Service data. 

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

[End of figure] 

OWCP handles employees who suffer a compensable on-the-job injury by 
placing the employees on either its (1) "periodic rolls" (for employees 
with long-term or permanent injuries that are expected to keep them out 
of work for more than 90 days) or (2) "daily rolls" (i.e., employees 
who are expected to return to work within 90 days). In general, 
employees are entitled to receive 66 and two-thirds percent of their 
basic compensation during the period of their disability.[Footnote 12] 

As discussed in appendix II, our analysis of Service data indicates 
that 50,031 employees with workplace injuries occupied a modified work 
assignment during fiscal year 2008. Up to 9,740 other employees could 
have been in such an assignment during the same period.[Footnote 13] 
Collectively, these employees represent about 7 to 8 percent of the 
Service's workforce in fiscal year 2008. In addition, our analysis 
found wide variability in the number, percentage, and distribution of 
employees in these assignments among districts. For example, in Dallas, 
over 12 percent of all employees in the district at the end of fiscal 
year 2008 were in a modified work assignment; while in the Metro 
Caribbean district, fewer than 2 percent occupied one of these 
assignments at the end of that fiscal year. Additional information on 
the nationwide distribution of employees in modified work assignments 
during fiscal year 2008, by district, is available in appendix III. 

According to senior postal officials, in the past, the Service 
aggressively returned employees to work as soon as possible. This 
practice occurred when the Service (1) had many manual, sedentary jobs 
that were useful for its injured employees to perform (e.g., filling 
out customers' change of address forms manually) and (2) enjoyed steady 
growth in mail volume and revenues. Neither of these circumstances 
exists today. In addition, as we previously reported[Footnote 14], 
since 2007, the Service has been experiencing its steepest decline in 
mail volume since the Great Depression. In fiscal year 2009, the 
Service incurred an unprecedented net loss of $3.8 billion and 
experienced a decline in mail volume of over 25 billion pieces--its 
steepest decline ever. 

To respond to its deteriorating financial circumstances, the Service 
has, among other actions, downsized its workforce through "early out" 
retirement offers, closed some facilities, removed underutilized mail 
collection boxes, realigned its delivery routes to enhance efficiency 
(route realignments), and eliminated one of three work shifts (tours) 
in many mail processing and distribution facilities and about 114 
million work hours from its 2009 operations. 

Given the Service's deteriorating financial condition, in July 2009, we 
placed the Service on our list of high-risk areas needing attention by 
the Congress and the executive branch to achieve broad-based 
transformation.[Footnote 15] At that time, we reported that a key 
action for reducing the Service's costs was to reduce its employee 
costs for compensation and benefits and suggested that the Service 
align costs and revenues, including its costs for compensation and 
benefits. These costs account for about 80 percent of the Service's 
costs. 

When implementing major initiatives, agencies--such as the Service-- 
need to ensure that these initiatives will be accomplished effectively 
and efficiently. Fundamentally, the success of any initiative, such as 
the NRP, begins at the top--with clear management support for the 
purpose, goals, and time frames established for completing the 
initiative. Clear upper-level support and direction help managers 
throughout the organization properly prioritize the initiative relative 
to others. Such support and direction also help ensure that managers 
devote sufficient time and resources to complete the initiative 
successfully and in a timely manner. In addition, to help ensure the 
success of key initiatives, an agency should establish measures for 
determining whether program goals are being met, such as measures of 
expected outcomes. Furthermore, when an agency reports data on these 
outcomes to the Congress and others, the agency needs to ensure that 
the data are reliable and understandable, and that any limitations 
applicable to the data are clearly disclosed.[Footnote 16] 

The Goal of the NRP Is to Ensure That All Employees in Modified Work 
Assignments Are Performing Medically Suitable, Necessary Work: 

The Service began implementing the NRP in November 2006 to help ensure 
that all postal employees placed in modified work assignments because 
of a workplace injury are performing work that is medically suitable 
and necessary to the execution of the Service's mission. Although the 
number of employees being reassessed under the NRP is available at a 
district level, this number is not readily available nationwide because 
the Service does not aggregate these data. However, according to senior 
headquarters officials responsible for implementing the NRP, there were 
31,044 employees in modified work assignments on September 30, 2008, 
all of whom were potentially subject to review under the NRP, depending 
on their work status when the Service began implementing the NRP in 
their district. In addition, according to these officials, employees 
injured after the NRP's initiation were "rolled into" the NRP process 
at each applicable district.[Footnote 17] 

According to Service and DOL officials, the Service began accumulating 
large numbers of employees in modified work assignments when it was 
financially healthy and before the introduction of widespread 
automation, which decreased the availability of manual and sedentary 
jobs that, nevertheless, were useful to the execution of the Service's 
mission. Many of these jobs have disappeared over time and, thus, 
managers began assigning make-work, such as answering phones or serving 
as a lobby greeter, to accommodate employees with workplace injuries-- 
even when these assignments were not required at a particular facility. 
Thus, according to senior headquarters officials, they will consider 
the NRP a success when every employee with a workplace injury is 
working in a modified work assignment that accommodates both the 
employee's medical restrictions and the Service's needs. 

While the Service specifically precluded make-work assignments, senior 
headquarters officials purposely did not specify which of the Service's 
work assignments nationwide involve necessary work or, alternatively, 
identify those assignments that do not. According to these officials, 
they did not do so because the Service's needs vary by location and, as 
a consequence, they wanted to provide facility supervisors and district 
managers with flexibility to identify necessary work in their 
facilities and districts. Thus, under the NRP, work assignments that 
might be considered unnecessary in one facility may be considered 
necessary in another, depending on the facility's needs. While the 
Service purposely did not specify a list of necessary work assignments, 
it precluded local managers from assigning work to an injured employee 
when the work is part of another employee's duties. According to 
officials at the four districts we visited, prior to the NRP, they 
routinely assigned portions of one or more employees' duties to other 
employees to create modified work assignments for injured workers. 

The Service Is Implementing the NRP in Three Phases, Which Take Many 
Months to Complete: 

The Service is implementing the NRP in three phases, involving a total 
of 56 steps and the participation of a wide variety of officials at all 
levels of the organization and, in some cases, affected employees and 
their union representatives. Some employee outcomes arising from the 
NRP vary by phase, while others do not. For example, during any phase 
of the NRP, employees may return to full duty, retire, or resign from 
the Service. In addition, assuming that necessary and medically 
suitable work exists, employees may continue working in either a new 
assignment or their prior modified assignment. Employee outcomes vary 
between Phases 2 and 3, however, when sufficient necessary and 
medically suitable work is not available for the employees to perform. 
Until recently, the Service has been implementing the NRP in a 
staggered manner, with each phase performed sequentially. However, 
instead of waiting for each of the districts to complete Phase 2 before 
initiating Phase 3, in July 2009, the Service began implementing these 
phases concurrently. According to senior headquarters officials, the 
Service took this approach to stimulate progress and expedite the NRP's 
overall implementation. While the NRP takes many months to fully 
implement in each district, in part, because large numbers of employees 
are being reassessed, senior Service officials told us in August 2009 
that they expected the entire NRP process will be completed by 
September 30, 2010. However, given that none of the districts has 
completed all of the phases of the NRP since its initiation more than 3 
years ago, and absent established milestones and clear program 
priorities for completing the NRP nationwide, it is unclear when the 
NRP will be completed. 

The NRP Has Three Phases and Involves 56 Prescribed Steps: 

The NRP has three phases,[Footnote 18] involving 56 prescribed steps. 
Phase 1 principally involves identifying all employees with compensable 
on-the-job injuries; ensuring that information about all employees, 
such as their medical restrictions, is up to date; and categorizing the 
employees into one of two groups, according to their medical status 
(i.e., whether they have, or have not, reached their MMI). The Service 
uses the employees' updated information for Phases 2 and 3, during 
which the Service attempts to find medically suitable and necessary 
work for each employee; however, the focus of these phases varies-- 
depending on whether an employee has reached his or her MMI (Phase 2) 
or has not reached his or her MMI (Phase 3). Figure 2 describes the key 
NRP activities, stages, and possible employee outcomes in each of the 
three phases. See appendix IV for a complete list of all NRP steps, by 
phase. 

Figure 2: Key NRP Activities, Stages, and Possible Employee Outcomes, 
by Phase: 

[Refer to PDF for image: table] 

Phase 1 – All employees with workplace injuries; 
Stages in phase: None; 
13 steps; 
Key activities: 
* Identify all employees with workplace injuries who are in (or capable 
of working in) modified work assignments; 
* Ensure that employee information, including medical documentation of 
the employee’s work restrictions, is up to date and, where necessary, 
request updated documentation; 
* Ensure that all employees are properly classified according to 
whether they have, or have not, reached their MMI; 
* Validate that all records have been updated and that employees have 
been properly sorted according to their physician’s determination of 
each employee’s MMI status (done by headquarters officials); 
Possible employee outcomes: Employee may: 
* Return to full duty if the employee’s medical documentation 
indicates, for example, that he or she has fully recovered from his or 
her injury. 

Phase 2 – Employees who have reached their MMI; 
Stages in phase: 
* Job search (9 steps); 
* Job offer (6 steps); 
* No work available (NWA) (15 steps); 
30 steps; 
Key activities: 
* Identify all necessary work available within the district.[A, B]; 
* Assess whether the available work can be accomplished within an 
employee’s medical restrictions; 
* Where medically suitable work is available, prepare a job offer for 
each employee. (This may be either a new job offer, or a job reflecting 
the employee’s prior modified assignment); 
* When no medically suitable work is available, develop a preliminary 
list of employees with NWA determinations for review and approval by 
district management, and double check each of these employees’ files 
for accuracy to ensure, for example, that job searches for each 
employee were performed correctly; 
* Approve preliminary NWA list and meet with unions to discuss the 
list; 
* Notify affected employees of the Service’s NWA determination; 
* Meet with employee and, when requested, the employee’s union 
representative to discuss the job offer and provide the employee with 
an opportunity to update his or her medical records[C]; 
Possible employee outcomes: Employee may: 
* Be placed in a modified work assignment (i.e., either the same 
medically suitable and necessary work assignment that he or she 
performed before the NRP or a new medically suitable and necessary work 
assignment); 
* Return to full duty; 
* Retire or resign from the Service; or; 
* Receive an NWA determination—(i.e., the Service was unable to find a 
necessary and medically suitable work assignment for the employee). 

Phase 3 – Employees who have not reached their MMI; 
Stages in phase: 
* Implementation (6 steps); 
* Job offer (4 steps)[E]; 
* New medical documentation/new injury (3 steps); 
13 steps; 
Key activities: 
* Identify all available necessary work (from work conducted during 
Phase 2)[A]; 
* Update records to ensure that all employees who have not reached 
their MMI are listed and that all employees’ files are complete and 
still up to date; 
* Conduct job searches within the Service for employees and hold work 
status meetings with employees to discuss possible work assignments[D]; 
* Assess employees with new medical documentation or a new injury to 
determine whether medically suitable and necessary work is available 
for these employees; 
Possible employee outcomes: Employee may: 
* Return to full duty, or; 
* Retire or resign from the Service; 
The remaining employees receive one of three possible work 
determinations: 
* a “full day work” determination—-(i.e., the number of hours of 
medically suitable and necessary work identified by the Service matches 
the number of hours the employee is allowed to work by his or her 
physician); 
* a “partial day work” determination-—(i.e., the number of hours of 
medically suitable and necessary work identified by the Service is less 
than the number of hours the employee is permitted to work;[E] or; 
* a “complete day no work” determination—(i.e., the Service could not 
identify any necessary work within the employee’s craft, tour, and 
facility, and within his or her medical restrictions).[E] 

Source: GAO analysis of Service data. 

[A] The lists of necessary work are developed by each district's 
Service operations managers and are subject to change, based on 
agencywide or local changes in job availability resulting from, among 
other matters, reductions in staffing due to, among other actions, 
route realignment activities, and fluctuations in mail volume. 

[B] Beginning in July 2009, the Service began allowing certain 
districts implementing Phase 2--those that had already developed their 
list of necessary work (Phase 2, step 5)--to begin simultaneously 
implementing Phase 3. This matter is discussed in more detail later in 
this report. 

[C] These meetings include a review and discussion of the proposed 
employee job offer and are designed to elicit feedback from the 
employee on (1) his or her ability to perform the duties identified and 
(2) other necessary work that might be available and medically suitable 
for the employee to perform. The Service is expected to consider the 
employee's feedback and, consequently, can make changes to the job 
offer on that basis. 

[D] "Work status" refers to the stage in which facility supervisors 
determine what, if any, necessary work is available for each employee. 

[E] Before the Service provides a "partial day work" or a "complete day 
no work" determination to an employee, it must first search for 
necessary work in the employee's facility. If suitable work is not 
found, the Service must expand the search to other postal facilities 
within the district's boundaries. 

[End of figure] 

Each of the NRP phases is highly participative, involving a wide 
variety of postal employees representing headquarters, areas, and 
districts, including senior operations managers, injury compensation 
specialists, and medical staff in the Service's districts. Officials 
from health and resource management, injury compensation, and labor 
relations offices, and the Office of General Counsel in headquarters 
also participate in the NRP. In Dallas, Texas, for example, we met with 
more than 25 postal employees who, in addition to their normal duties, 
also were involved in carrying out some portion of the NRP. Many of 
these individuals also served as members of the district's assessment 
team that implements many of the NRP-related tasks. According to senior 
headquarters officials, the average size of the district assessment 
teams ranges from six to eight officials. In addition, because the NRP 
requires discussions between managers and affected employees when, for 
example, they receive an NWA determination, the employees and, when 
required, their union representatives, also participate in the NRP. 

Currently, the Service is using the NRP process principally to reassess 
the 31,044 employees who were in modified assignments on September 30, 
2008 (i.e., the "backlog" of these employees).[Footnote 19] However, in 
the future, the focus of the process will be to determine whether 
medically suitable and necessary work assignments are available for (1) 
newly injured employees and (2) employees who have reached their MMI 
and, thus, require reevaluation. The future process will be referred to 
as the "National Assessment Process," according to senior headquarters 
officials. 

Some Employee Outcomes Vary, Depending on Phase: 

According to Service officials, during any phase of the NRP, employees 
may return to full duty (i.e., return to their preinjury job), retire, 
or resign from the Service. In addition, assuming that necessary and 
medically suitable work exists, the outcomes for employees in Phases 2 
and 3 are the same--employees may continue working in either a new, 
medically suitable assignment, or in their prior modified assignment. 
[Footnote 20] Employee outcomes vary between these phases, however, 
when sufficient necessary and medically suitable work is not available 
for the employees to perform. For example, when work is not available, 
the Service provides employees in Phase 2 (those who have reached their 
MMI) with an NWA determination and sends them home, along with the 
necessary forms for filing a wage loss claim to receive compensation 
from DOL's OWCP for the number of hours they could not work for the 
Service.[Footnote 21] In contrast, in Phase 3, when sufficient 
necessary and medically suitable work is not available, the Service 
provides employees who have not reached their MMI with either a (1) 
"partial day work" determination or a (2) "complete day no work" 
determination. These employees also are referred to DOL's OWCP for wage 
loss compensation.[Footnote 22] Figure 3 illustrates the various NRP 
outcomes experienced by employees in modified work assignments, 
depending on the employees' MMI status. 

Figure 3: NRP Outcomes Experienced by Service Employees in Modified 
Work Assignments: 

[Refer to PDF for image: illustration] 

Employees in modified work assignments: NRP: 
* Return to full duty; 
* Retire or resign; 
* NWA for employees who have reached their MMI (referred to OWCP): 
OWCP: 
- Return to full duty (upon successful appeal)[A]; 
- Retire or resign (decline OWCP); 
- Vocational rehabilitation; 
- New occupation/employer; 
- Daily or periodic rolls; 
* Necessary work assignments for employees who have reached their MMI; 
* Daily work determinations for employees who have not reached their 
MMI: 
- Full daywork; 
- Partial daywork
- Complete day no work; 
- Daily or periodic rolls; 

NRP: Administered by the Service, except for OWCP, which is administers 
by DOL. 

Source: GAO analysis of Service data. 

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

[End of figure] 

Another distinction between Phases 2 and 3 relates to the frequency of 
employee outcome determinations. Phase 2 NWA determinations, for 
example, occur once[Footnote 23] and, as discussed previously, result 
in the employee's referral to OWCP for wage loss compensation. Because 
these individuals have reached their MMI, according to senior 
headquarters officials, they likely would be placed on OWCP's "periodic 
rolls." Thus, the senior headquarters officials said, they do not 
expect these employees will ever return to work for the Service. In 
contrast, Phase 3 "full day work," "partial day work," and "complete 
day no work" determinations are dynamic and subject to frequent change, 
sometimes on a daily basis, because of fluctuations in factors such as 
staff availability and mail volume that affect the availability of 
necessary and medically suitable work. Thus, depending on the 
availability of work, postal managers may be required to make daily 
determinations about whether suitable work is available for these 
employees. 

Each of these three Phase 3 employee outcomes has somewhat different 
consequences for an employee, including the frequency with which the 
employee is expected to report to the Service for possible work and the 
length of his or her anticipated duration on OWCP's compensation rolls. 
For example, when a facility supervisor determines that there is no 
necessary and medically suitable work available for an employee to 
perform (i.e., a "complete day no work" determination), the employee is 
sent home and instructed to return to work only if the employee's (1) 
medical restrictions change or (2) supervisor informs him or her that 
necessary work has become available for the employee to perform. In 
contrast, employees with "full day work" [Footnote 24] and "partial day 
work" determinations are required to report to work every day to see if 
necessary work is available for them to perform. These employees are 
eligible to receive wage loss compensation from OWCP, depending on the 
number of hours the employees could not work for the Service. However, 
whether OWCP places them on its "periodic rolls" or "daily rolls," is 
likely to depend on how long the Service estimates the employee will be 
out of work.[Footnote 25] 

The Service Staggered the NRP's Implementation and, Until Recently, 
Required Each Phase to Be Implemented Sequentially: 

After spending about 3 years developing the NRP, the Service began 
implementing the NRP nationwide in November 2006. The Service initiated 
the NRP in a staggered manner, varying the dates when districts within 
an area could begin Phase 1. According to senior headquarters 
officials, this approach was needed to train, assist, and oversee the 
NRP's initiation in each of the districts. In addition, once 
implementation began, the Service required each district to carry out 
the three NRP phases sequentially. Specifically, each district had to 
complete each step in a phase before it could proceed to the next step 
in the phase and, similarly, it had to complete each phase before 
proceeding to the next one. According to senior headquarters officials 
responsible for implementing the NRP, the sequential approach was 
needed to ensure that each of the Service's districts implemented the 
NRP correctly and consistently. Furthermore, to help ensure this 
objective would be realized, according to these officials, they 
purposefully did not provide a district with guidance for implementing 
the next NRP step until they had (1) determined that the district had 
implemented the prior step correctly and (2) approved the district to 
start the next step, or phase.[Footnote 26] 

Until recently, the Service's implementation of the NRP was confined to 
Phases 1 and 2. However, instead of waiting for each of the districts 
to complete these phases before initiating Phase 3, in July 2009, the 
Service began implementing Phases 2 and 3 concurrently for some 
districts. Senior headquarters officials told us that they did this to 
stimulate progress within the districts and, consequently, to expedite 
the NRP's overall implementation. According to these officials, this 
decision was necessary, in part, because area and district managers' 
commitment to the NRP's timely implementation varied greatly between 
the Service's areas and districts. They explained that, in addition to 
the daily effort required to "move the mail," managers must 
simultaneously implement a host of other operational initiatives. 

According to senior headquarters officials, districts are now 
"eligible" to begin simultaneously implementing Phases 2 and 3 when 
they have identified all of their necessary work assignments (Phase 2, 
step 5). However, the Service is staggering the introduction of Phase 3 
in the districts, much as it did the earlier phases of the NRP. 
Specifically, at the conclusion of our review, senior headquarters 
officials were precluding managers in each of the Service's nine large, 
geographic areas from initiating Phase 3 in more than one district at a 
time.[Footnote 27] 

Absent Time Frames and Clear Program Priorities It Is Unclear When the 
NRP Will Be Completed Agencywide: 

The Service initiated the NRP without establishing milestones or clear 
program priorities for its completion. According to senior headquarters 
officials, they intentionally did this because they do not have the 
authority to require area and district managers to prioritize the NRP's 
completion over competing operational initiatives. In addition, the 
officials were unable to identify or provide any Service documentation: 

* describing, among other matters, upper level management's support for 
the purpose of the initiative and time frames for completing it, or: 

* specifying the NRP's strategic importance relative to the Service's 
other initiatives. 

Despite the absence of an overall implementation time frame, progress 
has been made. Of the 62 districts implementing Phase 2 as of August 
31, 2009, almost one-half (30) had been doing so for more than 1 year. 
Of these, 5 districts had been implementing Phase 2 for longer than 2 
years, and 9 others had been implementing this phase for more than 18 
months. Senior headquarters officials acknowledge that, after 3 years, 
none of its districts have fully implemented the NRP, largely because 
of (1) the large number of employees being reassessed, (2) competing 
demands on the managers' time resulting from the ongoing implementation 
of various Service initiatives, and (3) the rigorous nature of the NRP. 
In addition, these managers explained that certain NRP steps, such as 
the job search process for each employee, are particularly time- 
consuming. Specifically, the Service's Employee and Labor Relations 
Manual requires postal managers to "make every effort" to identify 
potential positions for employees who have reached their MMI. In 
addition, the manual specifies that the Service's job offers "should 
minimize any adverse or disruptive impact on the employee." Thus, in 
conducting job searches for these employees, postal managers must first 
look for necessary and medically suitable work in each employee's 
craft, tour, and facility. If this search does not identify a necessary 
and medically suitable assignment, postal managers must conduct 
additional searches to try to find work for the employee within his or 
her current facility (i.e., work in a different craft or tour). 
[Footnote 28] If work cannot be identified for an employee at his or 
her current facility--for employees who reached their MMI in 1 year or 
less--managers must search for necessary and medically suitable work 
within each employee's commuting area. If still unsuccessful, the 
Service must (for these employees) expand its job search to other 
facilities beyond the boundary of each employee's current district. 
[Footnote 29] 

According to senior headquarters officials, the time and resources 
required to correctly and consistently implement the NRP are necessary 
to ensure that each employee's job restoration rights are fully 
protected. These officials also noted that the rigorous process is 
needed because the NRP can affect whether an employee retains a postal 
job. They further explained that the methodical nature of the NRP 
process: 

* helps ensure that the Service complies with all applicable laws, 
regulations, and contractual obligations related to employees with 
workplace injuries, and: 

* decreases the likelihood of successful grievances, appeals, and other 
actions against the Service.[Footnote 30] 

Senior headquarters officials told us that in 2006 they initially 
expected that all phases of the NRP would be completed by January 2010. 
The NRP's implementation, however, has taken longer than anticipated. 
Thus, as of August 2009, these officials estimated that the entire 
process would be completed by September 30, 2010. However, without 
specific milestones and clear upper management support across the 
Service's areas and districts, it is unclear when the NRP will be 
completed. 

Despite Incomplete NRP Implementation, the Service Estimated $146 
Million in Savings during Fiscal Year 2008: 

While the implementation of the NRP is incomplete, the initiative has 
begun to produce cost savings. These savings resulted from the 
placement of injured employees in medically suitable and necessary work 
assignments that contribute to the Service's bottom line, as well as 
from retirements and resignations. Data on these outcomes, however, are 
both limited and preliminary, partly because the Service does not track 
or aggregate information on all employee outcomes. Moreover, although 
some outcomes, such as retirements, result in cost savings, others, 
such as NWA determinations, result in short-and, possibly, long-term 
cost increases. The Service reported in its most recent comprehensive 
report to the Congress that it saved $146 million in fiscal year 2008 
as a result of the NRP, but it reported these savings without 
disclosing the limitations that applied. Specifically, the estimate 
accounted for neither (1) all potential savings (total gross savings) 
nor (2) additional costs resulting from some employee outcomes and the 
cost of implementing the NRP and thus was not an estimate of total net 
savings after costs. 

NRP Implementation Is Incomplete: 

As discussed, the Service did not set specific time frames for 
completing the NRP or establish program priorities for its completion 
nationwide, and implementation, thus far, has taken longer than senior 
headquarters officials expected. While the NRP began in 2006, according 
to data provided by the Service, none of the districts had completed 
all phases of the NRP as of August 31, 2009.[Footnote 31] Specifically: 

* 69 of the Service's 75 districts (92 percent) had completed Phase 1 
of the NRP as of August 31, 2009,[Footnote 32] and the remaining 6 
districts had nearly completed this phase; 

* 7 of 75 districts (9 percent) had completed Phase 2, 62 districts (83 
percent) were in the process of implementing this phase, and 6 
districts had not yet begun this phase; and: 

* 17 of 75 districts (23 percent) had begun implementing Phase 3 as of 
August 31, 2009, while 58 had not begun. However, 14 of the remaining 
58 districts were scheduled to begin implementing Phase 3 by the end of 
October 2009. 

Figure 4 illustrates the overall status of NRP implementation among the 
Service's 75 districts, as of August 31, 2009. 

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

[Refer to PDF for image: horizontal bar graph] 

Phase: Phase 1: 
Complete implementation: 69; 
Incomplete implementation: 6; 
Have not begun implementation: 0. 

Phase: Phase 2; 
Complete implementation: 7; 
Incomplete implementation: 62; 
Have not begun implementation: 6. 

Phase: Phase 3: 
Complete implementation: 0; 
Incomplete implementation: 17; 
Have not begun implementation: 58. 

Source: GAO analysis of Service data. 

[End of figure] 

Although 6 districts had not completed Phase 1 as of August 31, 2009, 
each of these districts was concluding this phase and awaiting final 
validation of results by headquarters. In contrast, according to data 
provided by the Service, of the 69 districts that had completed or were 
implementing Phase 2, the majority were in the first stage. 
Specifically, 

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

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

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

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

Figure 5 illustrates the status of the NRP for phases 1 and 2, by step, 
as of August 31, 2009. 

Figure 5: Status of NRP Implementation for Phases 1 and 2, by Step, as 
of August 31, 2009[A]: 

[Refer to PDF for image: vertical bar graph] 

Phase 1: 

Step: 1: 0;
Step: 2: 0;
Step: 3: 0;
Step: 4: 0;
Step: 5: 0;
Step: 6: 0;
Step: 7: 0;
Step: 8: 0;
Step: 9: 0;
Step: 10: 0;
Step: 11: 0;
Step: 12: 0;
Step: 13: 6 districts. 

Search Phase 2: 

Step: 1: 2 districts; 
Step: 2: 0;
Step: 3: 0;
Step: 4: 0;
Step: 5: 13 districts; 
Step: 6: 9 districts; 
Step: 7: 12 districts; 
Step: 8: 3 districts; 
Step: 9: 1 districts. 

Other: 

Step: 1: 0;
Step: 2: 1 districts; 
Step: 3: 0;
Step: 4: 4 districts; 
Step: 5: 0;
Step: 6: 7 districts. 

NWA: 

Step: 1: 0;
Step: 2: 0;
Step: 3: 0;
Step: 4: 2 districts; 
Step: 5: 2 districts; 
Step: 6: 1 districts; 
Step: 7: 0;
Step: 8: 0;
Step: 9: 0;
Step: 10: 0;
Step: 11: 0;
Step: 12: 3 districts; 
Step: 13: 0;
Step: 14: 0;
Step: 15: 2 districts. 

Composite: 
Step: 7. 

Source: GAO analysis of Service data. 

[A] Data on 17 of the 75 districts that had begun implementing Phase 3 
as of August 31, 2009, are not presented because similar data, by step, 
were not available. 

[End of figure] 

Employee Outcomes Are Beginning to Be Realized, but Available Data Are 
Limited and Preliminary: 

Although implementation of the NRP is incomplete, the initiative is 
beginning to realize outcomes for Service employees. However, partly 
because of incomplete implementation of the NRP and tracking of all NRP 
employee outcomes, agencywide data on NRP outcomes are both limited and 
preliminary. As previously shown in table 2, the potential employee 
outcomes of Phase 2 for employees (employees who have reached their 
MMI) are as follows: 

* return to full duty, 

* retirement, 

* resignation, 

* continuation in the employee's prior modified work assignment, 

* reassignment to a new medically suitable and necessary work 
assignment, or an: 

* NWA determination (i.e., the Service could not find necessary and 
medically suitable work for employees to perform). 

Although the Service tracks and aggregates data on some NRP employee 
outcomes, it does not track or aggregate data on others. According to 
senior headquarters officials, they do not track or aggregate data on 
all employee outcomes because the data are employee-specific and 
recorded and stored at each of its districts. They explained that 
aggregating data for the thousands of employees nationwide is 
challenging, given limited staff resources, the scope of effort 
required, and the absence of an automated system for tracking and 
reporting information on the status of employees in modified work 
assignments. While senior headquarters officials were able to provide 
data on employee outcomes for 616 of 1,738 (about 35 percent) employees 
that were reviewed in the eight districts that had completed, or nearly 
completed, Phase 2 as of June 30, 2009,[Footnote 33] they were unable 
to provide similar data for the remaining 1,122 employees (about 65 
percent). Senior headquarters officials told us that data on these 
employee outcomes were unavailable principally because the Service does 
not track or aggregate the number of employees who: 

* remained in their prior work assignment because the Service 
determined through the employees' NRP review that the work assignment 
was medically suitable and necessary work, or: 

* received a new modified work assignment because their prior 
assignment was determined to be either medically unsuitable or 
unnecessary to the Service's mission.[Footnote 34] 

According to senior headquarters officials, the Service does not need 
to track or aggregate these outcomes because both outcomes indicate 
that the goal of the NRP has been achieved. In its comments on a draft 
of this report, the Service said that it intends to deploy a new 
national claims management program in February 2010 that will enhance 
its ability to track and measure NRP progress and enable cost efficient 
aggregation of NRP data. However, the Service did not indicate that it 
planned to use the new program to track and measure NRP employee 
outcomes. 

For the remaining 616 employees (of 1,738) whose specific outcomes 
headquarters tracked data indicate that: 

* 103 employees returned to full duty, 

* 223 employees retired, 

* 257 employees received NWA determinations, and: 

* 33 employees had "other" outcomes.[Footnote 35] 

Senior headquarters officials also provided us with preliminary data on 
some employee outcomes for the districts implementing Phase 3 as of 
August 31, 2009. Most of these data were very limited because the 
majority of the districts were in the early stages of implementing 
Phase 3 and, thus, had very few employee outcomes to report. Available 
data were most complete for the four districts that piloted Phase 3 
and, consequently, had been implementing Phase 3 the longest. Outcomes 
for the 2,301 employees reviewed in these four districts indicated 
that: 

* 1,039 employees received a "full day work" determination (about 45 
percent), 

* 589 employees received a "partial day work" determination (about 26 
percent), and: 

* 673 employees received a "complete day no work" determination (about 
29 percent). 

While these data provide some useful insights into the districts' early 
experience with implementing Phase 3, outcomes in this phase are 
dynamic and subject to frequent change because, as discussed, district 
managers are required to perform daily work determinations for many of 
these employees. 

Some Employee Outcomes Result in Cost Savings, while Others Increase 
the Service's Short-and Long-term Costs: 

While some employee outcomes result in cost savings for the Service, 
others increase the Service's costs. Savings accrue when, for example, 
an employee returns to full duty, and the Service no longer has to pay 
for overtime or temporary employees to perform the work the injured 
employee could not perform. Savings also may accrue when an employee 
retires or resigns because the Service's obligation to this employee is 
either greatly reduced or eliminated.[Footnote 36] Furthermore, 
according to senior headquarters officials, if an employee receives an 
NWA determination as a result of Phase 2, savings can result over the 
long term if (1) the employee is retrained and reemployed through 
OWCP's vocational rehabilitation training program; (2) OWCP reduces the 
employee's compensation for an administrative reason, such as the 
employee's refusal to fully participate in OWCP's vocational 
rehabilitation training program; or (3) the employee finds another job 
on his or her own. Each of these cases would result in a reduction in 
the Service's overall OWCP costs.[Footnote 37] While only about one- 
third of all employees enrolled in OWCP's vocational rehabilitation 
training program eventually receive employment elsewhere, according to 
DOL officials, senior headquarters officials at the Service told us 
that, for every employee who is successfully placed by OWCP with a new 
employer, more than three employees either retire or have their 
compensation reduced for an administrative reason. 

However, in addition to creating savings, the NRP creates short-and 
long-term costs. These costs arise in part from the increased numbers 
of employees on OWCP's periodic or daily rolls and increased 
operational costs for the NRP's implementation. Specifically, each NWA 
determination in Phase 2 and each "complete day no work" or "partial 
day" determination in Phase 3 increases the number of Service employees 
eligible to receive OWCP wage loss compensation.[Footnote 38] Increases 
in the number of employees receiving these determinations also will 
increase the Service's annual OWCP costs, at least in the short term. 
OWCP's most recent bill totaled about $1.1 billion for the period 
between July 1, 2008, and June 30, 2009. Thus, to the extent that 
employees remain on OWCP's rolls, increasing the number of Service 
employees receiving OWCP compensation will also increase the Service's 
long-term costs.[Footnote 39] For example, about $18 million of the 
Service's most recent OWCP bill was for the approximately 500 employees 
injured before 1971 who still remain on OWCP's periodic rolls about 40 
years later. Finally, increases in the number of Service employees 
receiving OWCP wage loss compensation as a result of their NRP 
reassessment could accelerate, given the Service's efforts to reduce 
its employee work hours and the continuing decline in mail volume. 
Increases in the number of employees receiving workers' compensation 
are problematic because, at the end of 2008, the Service estimated that 
its total liability for workers' compensation costs was about $8 
billion--an increase of about $197 million, or 2.5 percent, from 2007. 

The NRP also has increased the Service's operational costs for 
developing, implementing, and integrating the NRP into the Service's 
management practices.[Footnote 40] These include, for example, the 
costs for headquarters staff to travel to each of its districts to 
implement the NRP over the past 3 years. In addition, based on our 
interviews of district officials implementing Phases 2 and 3, the 
rigors of the NRP process have placed additional demands on available 
staff, such as the requirement to perform daily work determinations for 
many Phase 3 employees. Senior headquarters officials responsible for 
implementing the NRP, however, view these additional costs as "up- 
front" costs associated with reassessing the large number of employees 
in modified work assignments (i.e., the backlog)--costs that no longer 
will be incurred after the NRP reassessment process has been fully 
implemented. As discussed previously, the Service intends to use the 
NRP process moving forward for newly injured employees and employees 
who reach their MMI (and require reevaluation). According to senior 
headquarters officials, once the NRP reassessment is complete, future 
costs for NRP activities will be part of the routine cost of managing 
these assignments. 

While the NRP's up-front costs will no doubt decline as implementation 
is completed, to the extent that the NRP process creates permanent 
managerial requirements where none previously existed or were carried 
out, the process may create additional operational costs moving 
forward. As in the case of the Service's OWCP costs, the increase in 
the Service's operational costs likely will vary, depending on, among 
other factors, 

* the number of employees in these assignments; 

* the duration of their assignments;[Footnote 41] 

* the number of hours the employees are able to work, as well as their 
productivity; and: 

* the extent to which the employees' absence or diminished productivity 
requires the Service to use overtime or hire temporary employees to 
accomplish the injured employees' duties. 

The Service Reported That NRP Saved $146 Million in Fiscal Year 2008 
but Did Not Disclose the Limitations That Applied: 

The Service attributed $146 million in cost savings to the NRP in its 
comprehensive report to the Congress for fiscal year 2008 without 
disclosing how it derived these savings or disclosing that this figure 
was based on estimates.[Footnote 42] In addition, the Service did not 
disclose that its protocols for estimating cost savings have several 
limitations and, as a consequence, its estimate reflects neither the 
Service's total gross savings nor its total net savings. For example, 
the protocols used to estimate the Service's savings from Phases 1 and 
2: 

* do not account for savings accruing from all of the possible NRP 
employee outcomes. For example, although the protocols account for 
savings accruing for three of the Phase 2 employee outcomes--return to 
full duty, retirement, and resignation--the Service does not account 
for savings that, in some cases, might accrue from NWA determinations. 
[Footnote 43] 

* use "benchmark" cost savings, such as the Service's "lowest fully 
loaded work hour" for employees--regardless of their actual salaries-- 
to quantify savings associated with the employee outcomes.[Footnote 44] 

* do not account for savings from employee outcomes that accrue beyond 
12 months after the outcome occurred. For example, when an employee 
retires as a result of the NRP, the Service only counts the savings 
that accrue for the first 12 months after the date of retirement. 

* do not offset costs, such as the additional OWCP expenses that accrue 
from Phase 2 NWA determinations, and do not offset increases in the 
Service's operational costs resulting from the NRP's implementation. 

Because the goal of the NRP is to ensure that all employees with 
workplace injuries in modified work assignments are performing 
medically suitable and necessary work--not to produce cost savings-- 
senior headquarters officials told us that they intentionally designed 
the protocols to arrive at rough estimates that understate the NRP's 
savings. In addition, they told us that it was not feasible to 
precisely estimate savings resulting from the NRP because the savings 
are specific to each employee's circumstances. Furthermore, they said 
that implementing a more rigorous process for more precisely estimating 
NRP savings would place unreasonable and unnecessary demands on 
available staff. Thus, in their view, their current estimating approach 
is adequate for the Service's needs. 

Conclusions: 

By implementing the NRP, the Service has taken an important step to 
balance its obligation to provide work to employees with compensable 
workplace injuries (when necessary work is available for them to 
perform within their medical restrictions) with its obligation to the 
Congress, its employees, and the public to operate as effectively and 
efficiently as possible. In addition, because the NRP has the potential 
to cut some of the Service's costs, the NRP may represent a step toward 
addressing the Service's future financial viability. However, thus far, 
the NRP has been carried out without a strong management framework for 
ensuring timely implementation. For example, absent upper management's 
clearly articulated support for the initiative, specified time frames 
for its completion, and information about the NRP's relative priority 
compared to competing Service initiatives, area and district managers' 
commitment to the NRP's timely implementation has varied. Thus, after 
more than 3 years, none of the districts has completed all NRP phases. 
Furthermore, although Service officials estimate that the NRP will be 
completed by September 30, 2010, without milestones for its completion, 
it is uncertain when the NRP will be completed. In addition, because 
the Service has not tracked and aggregated data on NRP employee 
outcomes, it is difficult to measure the success of the program or 
accurately report on employee outcomes. Finally, while the Service 
believes its process for estimating savings is adequate for its needs, 
when an agency reports data on its program outcomes to the Congress and 
others, to help ensure that the data are not used inappropriately, it 
is important to fully disclose any limitations that apply. 

Recommendations for Executive Action: 

To enhance the NRP's implementation, we recommend that the Postmaster 
General take the following three actions to improve program management 
and enhance accountability and transparency: 

* Articulate senior management's commitment to the NRP by setting 
program milestones, including a timeline for all districts to complete 
the NRP; 

* When deployed, use the Service's new claims management process to 
track and measure whether the NRP's goals are being met, including 
tracking the number of employees placed in necessary and medically 
suitable modified work assignments; and: 

* Fully disclose any limitations that apply to NRP-related cost savings 
reported to the Congress and others. 

Agency Comments and Our Evaluation: 

The Service provided its written comments on a draft of this report by 
letter dated December 1, 2009. These comments are summarized below and 
are included, in their entirety, as appendix V of this report. 

The Service agreed with our third recommendation, indicating that, in 
the future, it will fully disclose any limitations that apply to NRP- 
related cost savings it reports to the Congress and others; however, 
the Service disagreed with our first and second recommendations. In 
commenting on our first recommendation, the Service stated that it does 
not believe that setting an "arbitrary deadline" for the NRP's 
completion is in the best interests of its employees. We agree that 
establishing an arbitrary deadline is inappropriate because it could 
result in unacceptable and unintended employee outcomes. Thus, we 
clarified our draft to exclude any unintended suggestion that the NRP 
should be completed by September 30, 2010, which, according to senior 
headquarters officials, is the current estimated date for completing 
the NRP. The Service also stated that the NRP received "complete senior 
management support as evidenced by the commitment of resources by each 
area." While we believe that many senior managers fully committed to 
the NRP's timely implementation, according to senior headquarters 
officials and, as discussed in our report, the level of commitment at 
the local level has varied greatly. Consequently, we continue to 
believe that the Service should, after careful consideration of the 
time required to reasonably complete the remaining portion of the NRP, 
establish timelines for its completion nationwide and, where 
practicable, track progress against those timelines. This would help 
ensure that local managers properly prioritize the NRP, which is 
especially important given that more than 3 years have passed since 
implementation of the NRP began. 

The Service disagreed with our second recommendation that it establish 
methods for tracking and measuring whether the NRP's goals are being 
met. The Service stated that the reports it uses to monitor the program 
are sufficient for its purposes and that in February 2010 it intends to 
deploy a new national claims management program that will enhance its 
ability to aggregate NRP-related data. While the Service's current 
reports may be sufficient for its senior management officials, given 
the importance of this program and its potential impact on thousands of 
employees, we believe it is important to fully track whether the NRP's 
goals are being met. Thus, we have revised our recommendation to 
clarify that we believe the Service should use its new program, when 
available, to track and measure all NRP employee outcomes, including 
the number of employees placed in necessary and medically suitable 
modified work assignments. This will enhance transparency in reporting 
program outcomes to employees, unions, congressional stakeholders, and 
others. 

In its comments, the Service also stated that it did not agree that its 
"tracking data for the NRP is unknown." While our draft report 
indicated that "the number of employees reassessed under the program is 
unknown," we revised the report to clarify that the Service does not 
aggregate NRP data, and therefore, that it could not specify the number 
of employees being reviewed under the NRP nationwide. 

Service officials, including the Manager of the Service's Office of 
Health and Resource Management, also provided oral technical comments, 
which we incorporated as appropriate. 

We are sending copies of this report to appropriate congressional 
committees and the U.S. Postal Service. The report also is available at 
no charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you have any questions about this report, please contact me at 
Herrp@gao.gov or (202) 512-2834. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report are listed in 
appendix VI. 

Signed by: 

Phillip Herr: 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Because of congressional interest in whether the large number of United 
States Postal Service (Service) employees in modified work assignments 
are being productively employed, we were asked to review the Service's 
National Reassessment Process (NRP). Our work focused on three 
objectives: (1) What is the goal of the NRP? (2) How is the initiative 
being implemented? (3) What is the status of the NRP, and what outcomes 
have been achieved? 

To address these objectives, we reviewed and analyzed, among other 
documentation, (1) applicable laws, regulations, and postal policies 
and procedures for protecting federal employees who sustain a 
compensable workplace injury, including their rights with respect to 
job restoration; (2) Service documentation describing the goals of the 
NRP and the process for implementing the initiative, as well as 
available Service data on the status and outcomes of the NRP;[Footnote 
45] (3) documentation from the four largest postal unions,[Footnote 46] 
including information about the unions' views on the NRP; and (4) 
information about the Department of Labor's (DOL) Office of Workers' 
Compensation Programs (OWCP), which makes wage loss and other payments 
to employees with compensable workplace injuries. We also interviewed a 
wide range of postal officials, including senior headquarters health 
and resource management officials who are responsible for the NRP's 
implementation, injury compensation, and labor relations, and the 
Service's Office of General Counsel. In addition, we interviewed 
national-level representatives from each of the Service's four largest 
unions, DOL officials, some postal employees affected by the NRP, and 
other postal personnel, as applicable. To accomplish our objectives, we 
also visited four districts--San Francisco, Westchester, the Dakotas, 
and Dallas--and conducted in-depth, semistructured interviews with a 
broad range of individuals, including members of each district's 
District Assessment Team, district and facility managers, and local 
union representatives, and contacted officials in four other districts-
-Sierra Coastal, Southeast New England, Los Angeles, and Santa 
Ana.[Footnote 47] The results of our discussions with officials in 
these districts are not generalizable to all of the Service's 
districts. Finally, we reviewed prior reports and literature on, for 
example, the value of returning injured employees to work as soon as 
possible; reports on the Service's declining financial circumstances, 
including GAO's high-risk reports and the Service's recent annual 
financial reports and comprehensive statements for fiscal years 2007 
and 2008; and guidance on key principles for managing agency 
initiatives and reporting program outcomes. Because the Service did not 
begin Phase 3 of the NRP until July 2009, our work primarily focuses on 
Phases 1 and 2 of the NRP. Using data supplied by the Service, we also 
determined the number of employees who either occupied (or could have 
occupied) a modified assignment during fiscal year 2008. Our 
methodology for this analysis is contained in appendix II. 

While the Service has ergonomics and other safety-related programs to 
reduce workplace injuries, we did not evaluate their effectiveness in 
controlling the numbers of employees with workplace injuries in 
modified work assignments. In addition, we excluded from our review 
postal employees who sustained off-the-job injuries. Similarly, we 
excluded postal employees who had sustained compensable workplace 
injuries but have medical restrictions that preclude them from 
continuing to work for the Service because they are not in modified 
work assignments.[Footnote 48] Related to this, because of the time and 
complexity involved in cross-matching individuals in modified work 
assignments with DOL's OWCP payment records, we did not determine the 
portion of the Service's costs for workers' compensation that is 
attributable to individuals in modified work assignments. Finally, 
while we evaluated the Service's methods for estimating cost savings 
arising from the NRP, we did not attempt to arrive at an independent 
assessment of the overall savings attributable to the NRP initiative 
because it was not feasible to analyze thousands of individual employee 
records at each of the Service's districts to determine, among many 
other matters, the (1) number of hours worked (or not worked) by each 
employee in a modified work assignment, (2) each employee's hourly wage 
rate with benefits, or (3) possible differences in productivity between 
each employee's pre-and post-NRP work assignments. In addition, data 
needed to offset these savings against additional costs incurred (i.e., 
determine the Service's net savings), such as the cost of implementing 
the NRP and increased OWCP costs associated with some employee 
outcomes, were either not available or not feasible to determine. 
[Footnote 49] 

We conducted this performance audit from October 2008 to December 2009, 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Methodology for Determining Number of Service Employees 
Who Occupied (or Could Have) a Modified Work Assignment: 

According to senior headquarters officials responsible for implementing 
the NRP, there were 31,044 Service employees in modified work 
assignments on September 30, 2008--the last day of fiscal year 2008. 
Because this number understates the total number of employees in these 
assignments throughout the year, we analyzed Service data to determine 
the total number of employees in these assignments at any time during 
fiscal year 2008.[Footnote 50] Our analysis found that over 50,031 
employees with workplace injuries occupied a modified work assignment 
during fiscal year 2008. In addition, another 9,740 employees with 
workplace injuries could have occupied such an assignment, for a total 
of 59,771 employees who either occupied (or, could have occupied) a 
modified work assignment in fiscal year 2008.[Footnote 51] We 
determined that the Service's data were sufficiently reliable for our 
reporting purposes. 

The following information describes our methodology for conducting this 
analysis. We obtained Service data on employees in modified assignments 
during fiscal year 2008--the period from October 1, 2007 through 
September 30, 2008. These data are contained in one or more Excel 
workbooks from headquarters and each of the 80 districts that existed 
when we began our review.[Footnote 52] The workbooks contain various 
information about the employees, including their name; work location; 
work status;[Footnote 53] and a unique identifier, such as their Social 
Security numbers. 

Because data in these workbooks were not presented uniformly, we 
standardized the data before beginning our analysis. In addition, we 
performed other data cleaning activities to address other anomalies. 
For example, because certain employee records had obvious errors, such 
as Social Security numbers with fewer than nine digits, or beginning 
with "000," we eliminated these data from further analysis. Finally, we 
eliminated data fields that were not relevant to our review, such as 
information about the employees' pay locations. 

We then analyzed the data to determine the number of unique employees 
contained in the Service's workbooks.[Footnote 54] In total, there were 
59,824 unique employees at the start of our analysis. The majority of 
these employees (51,516 of 59,824 or, about 86 percent) had only one 
line of data, or "record," in the workbooks. However, the remaining 
8,308 employees had more than one record during fiscal 2008.[Footnote 
55] To ascertain the correct employee record to use in these cases, we 
devised a protocol for deleting all but the most recent of the 
employees' records.[Footnote 56] Thus, at the completion of this 
activity, we had one record for each of these 8,308 employees. 

To determine which of the 59,824 employees occupied a modified work 
assignment during fiscal year 2008, we ran a frequency analysis on the 
employees' work status data. In total 50,031 of the 59,824 employees 
were coded "1," meaning that they were in a modified assignment at some 
point during fiscal year 2008. The remaining 9,793 employees, however, 
had a variety of other work status codes, including 53 that we 
eliminated because data irregularities precluded us from determining 
anything about the employees' work status. This left us with 9,740 
employees with data indicating that the employees had occupied a 
modified work assignment at some point in the past, but, for example, 
subsequently had retired or otherwise separated from the Service. Thus, 
sufficient data were not available for us to determine whether these 
employees actually occupied a modified work assignment during fiscal 
year 2008. However, based on our knowledge of the Service's data, and 
our discussions with senior headquarters officials, we determined that 
each of these 9,740 employees could have occupied a modified work 
assignment during fiscal year 2008. We shared our findings with senior 
headquarters officials who indicated that the results of our analysis 
were reasonable. 

[End of section] 

Appendix III: Number, Percentage, and Distribution of Modified Work 
Assignments Nationwide during Fiscal Year 2008: 

[End of section] 

As discussed in the body of this report, our analysis of Service data 
found wide variability among Service districts nationwide in the 
number, percentage, and distribution of employees in limited duty and 
rehabilitation assignments (modified work assignments) during fiscal 
year 2008. For example, in Dallas, over 12 percent of all employees in 
the district (1,719 of 14,150) were in a modified work assignment; 
while in the Metro Caribbean district, fewer than 2 percent occupied 
one of these assignments during fiscal year 2008.[Footnote 57] In 
addition, about 50 percent of the 50,031 employees in modified work 
assignments during fiscal year 2008 worked in 30 percent of the 
Service's organizations (24 of 81 organizations, including 
headquarters).[Footnote 58] Table 2 shows the number and percentage of 
employees in modified work assignments nationwide and the distribution 
of these assignments, by organization, during fiscal year 2008. 

Table 2: Number, Percentage, and Distribution of Service Employees in 
Modified Work Assignments Nationwide during Fiscal Year 2008: 

Rank: 1; 
Service organization (district or headquarters): Dallas; 
Number of employees in limited duty assignments: 792; 
Number of employees in rehabilitation assignments: 927; 
Total number of employees in modified assignments: 1,719; 
Total number, all employees: 14,150; 
Percentage of workforce in modified assignments: 12.15%. 

Rank: 2; 
Service organization (district or headquarters): San Francisco; 
Number of employees in limited duty assignments: 479; 
Number of employees in rehabilitation assignments: 684; 
Total number of employees in modified assignments: 1,163; 
Total number, all employees: 9,651; 
Percentage of workforce in modified assignments: 12.05%. 

Rank: 3; 
Service organization (district or headquarters): Bay Valley; 
Number of employees in limited duty assignments: 1,255; 
Number of employees in rehabilitation assignments: 189; 
Total number of employees in modified assignments: 1,444; 
Total number, all employees: 12,276; 
Percentage of workforce in modified assignments: 11.76%. 

Rank: 4; 
Service organization (district or headquarters): Detroit; 
Number of employees in limited duty assignments: 698; 
Number of employees in rehabilitation assignments: 253; 
Total number of employees in modified assignments: 951; 
Total number, all employees: 8,412; 
Percentage of workforce in modified assignments: 11.31%. 

Rank: 5; 
Service organization (district or headquarters): Los Angeles; 
Number of employees in limited duty assignments: 1,131; 
Number of employees in rehabilitation assignments: 181; 
Total number of employees in modified assignments: 1,312; 
Total number, all employees: 11,932; 
Percentage of workforce in modified assignments: 11%. 

Rank: 6; 
Service organization (district or headquarters): Northern Ohio; 
Number of employees in limited duty assignments: 1,096; 
Number of employees in rehabilitation assignments: 186; 
Total number of employees in modified assignments: 1,282; 
Total number, all employees: 12,019; 
Percentage of workforce in modified assignments: 10.67%. 

Rank: 7; 
Service organization (district or headquarters): Santa Ana; 
Number of employees in limited duty assignments: 720; 
Number of employees in rehabilitation assignments: 753; 
Total number of employees in modified assignments: 1,473; 
Total number, all employees: 14,059; 
Percentage of workforce in modified assignments: 10.48%. 

Rank: 8; 
Service organization (district or headquarters): Colorado Wyoming; 
Number of employees in limited duty assignments: 671; 
Number of employees in rehabilitation assignments: 704; 
Total number of employees in modified assignments: 1,375; 
Total number, all employees: 13,708; 
Percentage of workforce in modified assignments: 10.03%. 

Rank: 9; 
Service organization (district or headquarters): Seattle; 
Number of employees in limited duty assignments: 954; 
Number of employees in rehabilitation assignments: 174; 
Total number of employees in modified assignments: 1,128; 
Total number, all employees: 11,282; 
Percentage of workforce in modified assignments: 10%. 

Rank: 10; 
Service organization (district or headquarters): Louisiana; 
Number of employees in limited duty assignments: 794; 
Number of employees in rehabilitation assignments: 132; 
Total number of employees in modified assignments: 926; 
Total number, all employees: 9,413; 
Percentage of workforce in modified assignments: 9.84%. 

Rank: 11; 
Service organization (district or headquarters): Atlanta; 
Number of employees in limited duty assignments: 1,245; 
Number of employees in rehabilitation assignments: 166; 
Total number of employees in modified assignments: 1,411; 
Total number, all employees: 14,502; 
Percentage of workforce in modified assignments: 9.73%. 

Rank: 12; 
Service organization (district or headquarters): Pittsburgh; 
Number of employees in limited duty assignments: 508; 
Number of employees in rehabilitation assignments: 127; 
Total number of employees in modified assignments: 635; 
Total number, all employees: 6,737; 
Percentage of workforce in modified assignments: 9.43%. 

Rank: 13; 
Service organization (district or headquarters): Cincinnati; 
Number of employees in limited duty assignments: 740; 
Number of employees in rehabilitation assignments: 289; 
Total number of employees in modified assignments: 1,029; 
Total number, all employees: 10,953; 
Percentage of workforce in modified assignments: 9.39%. 

Rank: 14; 
Service organization (district or headquarters): Sacramento; 
Number of employees in limited duty assignments: 549; 
Number of employees in rehabilitation assignments: 430; 
Total number of employees in modified assignments: 979; 
Total number, all employees: 10,863; 
Percentage of workforce in modified assignments: 9.01%. 

Rank: 15; 
Service organization (district or headquarters): Southeast Michigan; 
Number of employees in limited duty assignments: 567; 
Number of employees in rehabilitation assignments: 79; 
Total number of employees in modified assignments: 646; 
Total number, all employees: 7,271; 
Percentage of workforce in modified assignments: 8.88%. 

Rank: 16; 
Service organization (district or headquarters): San Diego; 
Number of employees in limited duty assignments: 496; 
Number of employees in rehabilitation assignments: 495; 
Total number of employees in modified assignments: 991; 
Total number, all employees: 11,262; 
Percentage of workforce in modified assignments: 8.8%. 

Rank: 17; 
Service organization (district or headquarters): South Florida; 
Number of employees in limited duty assignments: 534; 
Number of employees in rehabilitation assignments: 319; 
Total number of employees in modified assignments: 853; 
Total number, all employees: 9,832; 
Percentage of workforce in modified assignments: 8.68%. 

Rank: 18; 
Service organization (district or headquarters): Sierra Coastal; 
Number of employees in limited duty assignments: 365; 
Number of employees in rehabilitation assignments: 531; 
Total number of employees in modified assignments: 896; 
Total number, all employees: 10,332; 
Percentage of workforce in modified assignments: 8.67%. 

Rank: 19; 
Service organization (district or headquarters): Ft. Worth; 
Number of employees in limited duty assignments: 363; 
Number of employees in rehabilitation assignments: 371; 
Total number of employees in modified assignments: 734; 
Total number, all employees: 8,540; 
Percentage of workforce in modified assignments: 8.59%. 

Rank: 20; 
Service organization (district or headquarters): Chicago; 
Number of employees in limited duty assignments: 571; 
Number of employees in rehabilitation assignments: 178; 
Total number of employees in modified assignments: 749; 
Total number, all employees: 9,315; 
Percentage of workforce in modified assignments: 8.04%. 

Rank: 21; 
Service organization (district or headquarters): Columbus; 
Number of employees in limited duty assignments: 440; 
Number of employees in rehabilitation assignments: 87; 
Total number of employees in modified assignments: 527; 
Total number, all employees: 6,719; 
Percentage of workforce in modified assignments: 7.84%. 

Rank: 22; 
Service organization (district or headquarters): Houston; 
Number of employees in limited duty assignments: 840; 
Number of employees in rehabilitation assignments: 170; 
Total number of employees in modified assignments: 1,010; 
Total number, all employees: 13,010; 
Percentage of workforce in modified assignments: 7.76%. 

Rank: 23; 
Service organization (district or headquarters): Alaska; 
Number of employees in limited duty assignments: 118; 
Number of employees in rehabilitation assignments: 25; 
Total number of employees in modified assignments: 143; 
Total number, all employees: 1,867; 
Percentage of workforce in modified assignments: 7.66%. 

Rank: 24; 
Service organization (district or headquarters): Suncoast; 
Number of employees in limited duty assignments: 585; 
Number of employees in rehabilitation assignments: 324; 
Total number of employees in modified assignments: 909; 
Total number, all employees: 11,914; 
Percentage of workforce in modified assignments: 7.63%. 

Rank: 25; 
Service organization (district or headquarters): Oklahoma; 
Number of employees in limited duty assignments: 275; 
Number of employees in rehabilitation assignments: 328; 
Total number of employees in modified assignments: 603; 
Total number, all employees: 8,053; 
Percentage of workforce in modified assignments: 7.49%. 

Rank: 26; 
Service organization (district or headquarters): Lakeland; 
Number of employees in limited duty assignments: 702; 
Number of employees in rehabilitation assignments: 253; 
Total number of employees in modified assignments: 955; 
Total number, all employees: 12,923; 
Percentage of workforce in modified assignments: 7.39%. 

Rank: 27; 
Service organization (district or headquarters): Northern Illinois; 
Number of employees in limited duty assignments: 387; 
Number of employees in rehabilitation assignments: 392; 
Total number of employees in modified assignments: 779; 
Total number, all employees: 10,729; 
Percentage of workforce in modified assignments: 7.26%. 

Rank: 28; 
Service organization (district or headquarters): Philadelphia; 
Number of employees in limited duty assignments: 722; 
Number of employees in rehabilitation assignments: 140; 
Total number of employees in modified assignments: 862; 
Total number, all employees: 11,926; 
Percentage of workforce in modified assignments: 7.23%. 

Rank: 29; 
Service organization (district or headquarters): Northern Virginia; 
Number of employees in limited duty assignments: 302; 
Number of employees in rehabilitation assignments: 157; 
Total number of employees in modified assignments: 459; 
Total number, all employees: 6,457; 
Percentage of workforce in modified assignments: 7.11%. 

Rank: 30; 
Service organization (district or headquarters): Portland; 
Number of employees in limited duty assignments: 578; 
Number of employees in rehabilitation assignments: 40; 
Total number of employees in modified assignments: 618; 
Total number, all employees: 8,803; 
Percentage of workforce in modified assignments: 7.02%. 

Rank: 31; 
Service organization (district or headquarters): S.E. New England; 
Number of employees in limited duty assignments: 337; 
Number of employees in rehabilitation assignments: 139; 
Total number of employees in modified assignments: 476; 
Total number, all employees: 6,896; 
Percentage of workforce in modified assignments: 6.9%. 

Rank: 32; 
Service organization (district or headquarters): North Florida; 
Number of employees in limited duty assignments: 351; 
Number of employees in rehabilitation assignments: 295; 
Total number of employees in modified assignments: 646; 
Total number, all employees: 9,531; 
Percentage of workforce in modified assignments: 6.78%. 

Rank: 33; 
Service organization (district or headquarters): Capital District; 
Number of employees in limited duty assignments: 423; 
Number of employees in rehabilitation assignments: 188; 
Total number of employees in modified assignments: 611; 
Total number, all employees: 9,347; 
Percentage of workforce in modified assignments: 6.54%. 

Rank: 34; 
Service organization (district or headquarters): N. New Jersey; 
Number of employees in limited duty assignments: 580; 
Number of employees in rehabilitation assignments: 213; 
Total number of employees in modified assignments: 793; 
Total number, all employees: 12,132; 
Percentage of workforce in modified assignments: 6.54%. 

Rank: 35; 
Service organization (district or headquarters): Greater Indiana; 
Number of employees in limited duty assignments: 557; 
Number of employees in rehabilitation assignments: 286; 
Total number of employees in modified assignments: 843; 
Total number, all employees: 13,161; 
Percentage of workforce in modified assignments: 6.41%. 

Rank: 36; 
Service organization (district or headquarters): Salt Lake City; 
Number of employees in limited duty assignments: 185; 
Number of employees in rehabilitation assignments: 92; 
Total number of employees in modified assignments: 277; 
Total number, all employees: 4,332; 
Percentage of workforce in modified assignments: 6.39%. 

Rank: 37; 
Service organization (district or headquarters): Central Illinois; 
Number of employees in limited duty assignments: 719; 
Number of employees in rehabilitation assignments: 50; 
Total number of employees in modified assignments: 769; 
Total number, all employees: 12,444; 
Percentage of workforce in modified assignments: 6.18%. 

Rank: 38; 
Service organization (district or headquarters): Big Sky; 
Number of employees in limited duty assignments: 106; 
Number of employees in rehabilitation assignments: 55; 
Total number of employees in modified assignments: 161; 
Total number, all employees: 2,614; 
Percentage of workforce in modified assignments: 6.16%. 

Rank: 39; 
Service organization (district or headquarters): Triboro; 
Number of employees in limited duty assignments: 476; 
Number of employees in rehabilitation assignments: 150; 
Total number of employees in modified assignments: 626; 
Total number, all employees: 10,217; 
Percentage of workforce in modified assignments: 6.13%. 

Rank: 40; 
Service organization (district or headquarters): Central Pennsylvania; 
Number of employees in limited duty assignments: 651; 
Number of employees in rehabilitation assignments: 51; 
Total number of employees in modified assignments: 702; 
Total number, all employees: 11,536; 
Percentage of workforce in modified assignments: 6.09%. 

Rank: 41; 
Service organization (district or headquarters): Connecticut; 
Number of employees in limited duty assignments: 433; 
Number of employees in rehabilitation assignments: 180; 
Total number of employees in modified assignments: 613; 
Total number, all employees: 10,082; 
Percentage of workforce in modified assignments: 6.08%. 

Rank: 42; 
Service organization (district or headquarters): Erie; 
Number of employees in limited duty assignments: 241; 
Number of employees in rehabilitation assignments: 23; 
Total number of employees in modified assignments: 264; 
Total number, all employees: 4,353; 
Percentage of workforce in modified assignments: 6.06%. 

Rank: 43; 
Service organization (district or headquarters): Arizona; 
Number of employees in limited duty assignments: 500; 
Number of employees in rehabilitation assignments: 176; 
Total number of employees in modified assignments: 676; 
Total number, all employees: 11,265; 
Percentage of workforce in modified assignments: 6%. 

Rank: 44; 
Service organization (district or headquarters): Long Island; 
Number of employees in limited duty assignments: 450; 
Number of employees in rehabilitation assignments: 44; 
Total number of employees in modified assignments: 494; 
Total number, all employees: 8,333; 
Percentage of workforce in modified assignments: 5.93%. 

Rank: 45; 
Service organization (district or headquarters): Massachusetts; 
Number of employees in limited duty assignments: 339; 
Number of employees in rehabilitation assignments: 249; 
Total number of employees in modified assignments: 588; 
Total number, all employees: 9,989; 
Percentage of workforce in modified assignments: 5.89%. 

Rank: 46; 
Service organization (district or headquarters): Gateway; 
Number of employees in limited duty assignments: 504; 
Number of employees in rehabilitation assignments: 239; 
Total number of employees in modified assignments: 743; 
Total number, all employees: 12,679; 
Percentage of workforce in modified assignments: 5.86%. 

Rank: 47; 
Service organization (district or headquarters): Nevada Sierra; 
Number of employees in limited duty assignments: 275; 
Number of employees in rehabilitation assignments: 30; 
Total number of employees in modified assignments: 305; 
Total number, all employees: 5,216; 
Percentage of workforce in modified assignments: 5.85%. 

Rank: 48; 
Service organization (district or headquarters): Rio Grande; 
Number of employees in limited duty assignments: 677; 
Number of employees in rehabilitation assignments: 85; 
Total number of employees in modified assignments: 762; 
Total number, all employees: 13,084; 
Percentage of workforce in modified assignments: 5.82%. 

Rank: 49; 
Service organization (district or headquarters): Greensboro; 
Number of employees in limited duty assignments: 559; 
Number of employees in rehabilitation assignments: 69; 
Total number of employees in modified assignments: 628; 
Total number, all employees: 10,880; 
Percentage of workforce in modified assignments: 5.77%. 

Rank: 50; 
Service organization (district or headquarters): South Jersey; 
Number of employees in limited duty assignments: 253; 
Number of employees in rehabilitation assignments: 143; 
Total number of employees in modified assignments: 396; 
Total number, all employees: 7,027; 
Percentage of workforce in modified assignments: 5.64%. 

Rank: 51; 
Service organization (district or headquarters): Central New Jersey; 
Number of employees in limited duty assignments: 288; 
Number of employees in rehabilitation assignments: 125; 
Total number of employees in modified assignments: 413; 
Total number, all employees: 7,494; 
Percentage of workforce in modified assignments: 5.51%. 

Rank: 52; 
Service organization (district or headquarters): Honolulu; 
Number of employees in limited duty assignments: 101; 
Number of employees in rehabilitation assignments: 55; 
Total number of employees in modified assignments: 156; 
Total number, all employees: 2,836; 
Percentage of workforce in modified assignments: 5.5%. 

Rank: 53; 
Service organization (district or headquarters): Boston; 
Number of employees in limited duty assignments: 176; 
Number of employees in rehabilitation assignments: 169; 
Total number of employees in modified assignments: 345; 
Total number, all employees: 6,506; 
Percentage of workforce in modified assignments: 5.3%. 

Rank: 54; 
Service organization (district or headquarters): New Hampshire - 
Vermont; 
Number of employees in limited duty assignments: 224; 
Number of employees in rehabilitation assignments: 91; 
Total number of employees in modified assignments: 315; 
Total number, all employees: 6,024; 
Percentage of workforce in modified assignments: 5.23%. 

Rank: 55; 
Service organization (district or headquarters): Baltimore; 
Number of employees in limited duty assignments: 274; 
Number of employees in rehabilitation assignments: 182; 
Total number of employees in modified assignments: 456; 
Total number, all employees: 9,044; 
Percentage of workforce in modified assignments: 5.04%. 

Rank: 56; 
Service organization (district or headquarters): Greater Michigan; 
Number of employees in limited duty assignments: 375; 
Number of employees in rehabilitation assignments: 113; 
Total number of employees in modified assignments: 488; 
Total number, all employees: 9,727; 
Percentage of workforce in modified assignments: 5.02%. 

Rank: 57; 
Service organization (district or headquarters): Mid-Carolinas; 
Number of employees in limited duty assignments: 427; 
Number of employees in rehabilitation assignments: 60; 
Total number of employees in modified assignments: 487; 
Total number, all employees: 9,796; 
Percentage of workforce in modified assignments: 4.97%. 

Rank: 58; 
Service organization (district or headquarters): Appalachian; 
Number of employees in limited duty assignments: 315; 
Number of employees in rehabilitation assignments: 47; 
Total number of employees in modified assignments: 362; 
Total number, all employees: 7,400; 
Percentage of workforce in modified assignments: 4.89%. 

Rank: 59; 
Service organization (district or headquarters): Richmond; 
Number of employees in limited duty assignments: 238; 
Number of employees in rehabilitation assignments: 204; 
Total number of employees in modified assignments: 442; 
Total number, all employees: 9,064; 
Percentage of workforce in modified assignments: 4.88%. 

Rank: 60; 
Service organization (district or headquarters): Tennessee; 
Number of employees in limited duty assignments: 571; 
Number of employees in rehabilitation assignments: 124; 
Total number of employees in modified assignments: 695; 
Total number, all employees: 14,578; 
Percentage of workforce in modified assignments: 4.77%. 

Rank: 61; 
Service organization (district or headquarters): Albuquerque; 
Number of employees in limited duty assignments: 74; 
Number of employees in rehabilitation assignments: 111; 
Total number of employees in modified assignments: 185; 
Total number, all employees: 3,884; 
Percentage of workforce in modified assignments: 4.76%. 

Rank: 62; 
Service organization (district or headquarters): Western New York; 
Number of employees in limited duty assignments: 291; 
Number of employees in rehabilitation assignments: 69; 
Total number of employees in modified assignments: 360; 
Total number, all employees: 7,747; 
Percentage of workforce in modified assignments: 4.65%. 

Rank: 63; 
Service organization (district or headquarters): Central Florida; 
Number of employees in limited duty assignments: 342; 
Number of employees in rehabilitation assignments: 121; 
Total number of employees in modified assignments: 463; 
Total number, all employees: 9,974; 
Percentage of workforce in modified assignments: 4.64%. 

Rank: 64; 
Service organization (district or headquarters): Hawkeye; 
Number of employees in limited duty assignments: 249; 
Number of employees in rehabilitation assignments: 166; 
Total number of employees in modified assignments: 415; 
Total number, all employees: 9,120; 
Percentage of workforce in modified assignments: 4.55%. 

Rank: 65; 
Service organization (district or headquarters): South Georgia; 
Number of employees in limited duty assignments: 179; 
Number of employees in rehabilitation assignments: 104; 
Total number of employees in modified assignments: 283; 
Total number, all employees: 6,365; 
Percentage of workforce in modified assignments: 4.45%. 

Rank: 66; 
Service organization (district or headquarters): Maine; 
Number of employees in limited duty assignments: 93; 
Number of employees in rehabilitation assignments: 84; 
Total number of employees in modified assignments: 177; 
Total number, all employees: 4,067; 
Percentage of workforce in modified assignments: 4.35%. 

Rank: 67; 
Service organization (district or headquarters): Greater S.Carolina; 
Number of employees in limited duty assignments: 212; 
Number of employees in rehabilitation assignments: 83; 
Total number of employees in modified assignments: 295; 
Total number, all employees: 7,283; 
Percentage of workforce in modified assignments: 4.05%. 

Rank: 68; 
Service organization (district or headquarters): Arkansas; 
Number of employees in limited duty assignments: 222; 
Number of employees in rehabilitation assignments: 38; 
Total number of employees in modified assignments: 260; 
Total number, all employees: 6,427; 
Percentage of workforce in modified assignments: 4.05%. 

Rank: 69; 
Service organization (district or headquarters): Mid-America; 
Number of employees in limited duty assignments: 259; 
Number of employees in rehabilitation assignments: 173; 
Total number of employees in modified assignments: 432; 
Total number, all employees: 11,044; 
Percentage of workforce in modified assignments: 3.91%. 

Rank: 70; 
Service organization (district or headquarters): Alabama; 
Number of employees in limited duty assignments: 212; 
Number of employees in rehabilitation assignments: 171; 
Total number of employees in modified assignments: 383; 
Total number, all employees: 9,857; 
Percentage of workforce in modified assignments: 3.89%. 

Rank: 71; 
Service organization (district or headquarters): Albany; 
Number of employees in limited duty assignments: 151; 
Number of employees in rehabilitation assignments: 150; 
Total number of employees in modified assignments: 301; 
Total number, all employees: 7,813; 
Percentage of workforce in modified assignments: 3.85%. 

Rank: 72; 
Service organization (district or headquarters): Spokane; 
Number of employees in limited duty assignments: 139; 
Number of employees in rehabilitation assignments: 45; 
Total number of employees in modified assignments: 184; 
Total number, all employees: 5,022; 
Percentage of workforce in modified assignments: 3.66%. 

Rank: 73; 
Service organization (district or headquarters): Central Plains; 
Number of employees in limited duty assignments: 211; 
Number of employees in rehabilitation assignments: 156; 
Total number of employees in modified assignments: 367; 
Total number, all employees: 10,338; 
Percentage of workforce in modified assignments: 3.55%. 

Rank: 74; 
Service organization (district or headquarters): Dakotas; 
Number of employees in limited duty assignments: 112; 
Number of employees in rehabilitation assignments: 52; 
Total number of employees in modified assignments: 164; 
Total number, all employees: 5,134; 
Percentage of workforce in modified assignments: 3.19%. 

Rank: 75; 
Service organization (district or headquarters): New York; 
Number of employees in limited duty assignments: 407; 
Number of employees in rehabilitation assignments: 67; 
Total number of employees in modified assignments: 474; 
Total number, all employees: 15,146; 
Percentage of workforce in modified assignments: 3.13%. 

Rank: 76; 
Service organization (district or headquarters): Northland; 
Number of employees in limited duty assignments: 451; 
Number of employees in rehabilitation assignments: 31; 
Total number of employees in modified assignments: 482; 
Total number, all employees: 15,781; 
Percentage of workforce in modified assignments: 3.05%. 

Rank: 77; 
Service organization (district or headquarters): Kentuckiana; 
Number of employees in limited duty assignments: 159; 
Number of employees in rehabilitation assignments: 139; 
Total number of employees in modified assignments: 298; 
Total number, all employees: 10,034; 
Percentage of workforce in modified assignments: 2.97%. 

Rank: 78; 
Service organization (district or headquarters): Mississippi; 
Number of employees in limited duty assignments: 103; 
Number of employees in rehabilitation assignments: 53; 
Total number of employees in modified assignments: 156; 
Total number, all employees: 5,576; 
Percentage of workforce in modified assignments: 2.8%. 

Rank: 79; 
Service organization (district or headquarters): Westchester; 
Number of employees in limited duty assignments: 73; 
Number of employees in rehabilitation assignments: 54; 
Total number of employees in modified assignments: 127; 
Total number, all employees: 6,424; 
Percentage of workforce in modified assignments: 1.98%. 

Rank: 80; 
Service organization (district or headquarters): Metro Caribbean; 
Number of employees in limited duty assignments: 27; 
Number of employees in rehabilitation assignments: 35; 
Total number of employees in modified assignments: 62; 
Total number, all employees: 3,404; 
Percentage of workforce in modified assignments: 1.82%. 

Rank: 81; 
Service organization (district or headquarters): Headquarters; 
Number of employees in limited duty assignments: 34; 
Number of employees in rehabilitation assignments: 36; 
Total number of employees in modified assignments: 70; 
Total number, all employees: 11,370; 
Percentage of workforce in modified assignments: 0.62%. 

Rank: Total; 
Number of employees in limited duty assignments: 35,082; 
Number of employees in rehabilitation assignments: 14,949; 
Total number of employees in modified assignments: 50,031; 
Total number, all employees: 748,307. 

Source: GAO analysis of Service data. 

[End of table] 

[End of section] 

Appendix IV: Description of NRP Activities, by Phase and Step: 

Figures 6, 7, and 8 provide additional information about the NRP, 
including a description of activities, by phase and step. 

Figure 6: Description of NRP Activities in Phase 1: 

[Refer to PDF for image: table] 

Phase 1: 

Step: 1; 
Responsible team member: 
* District Injury Compensation Specialist; 
Activity description: Identify all employees in modified work 
assignments. 

Step: 2; 
Responsible team member: 
* Area National Assessment Process Injury Compensation Specialist; 
Activity description: Transfer information about these employees to the 
NRP workbook; 

Step: 3; 
Responsible team member: 
* Area Injury Compensation Manager; 
* Area Medical Function Representative; 
* Area Operations Team Leader; 
Activity description: Brief senior district management on NRP Phase 1. 

Step: 4; 
Responsible team member: 
* District injury compensation staff; 
Activity description: Identify employees in modified work assignments 
who require medical review. 

Step: 5; 
Responsible team member: 
* District medical staff; 
* District injury compensation staff; 
Activity description: Review all employees identified in step 4; 
determine if medical updates are required. 

Step: 6; 
Responsible team member: 
* District medical staff; 
* District injury compensation staff; 
* District labor relations staff; 
Activity description: Follow up on employee medical update requests. 

Step: 7; 
Responsible team member: 
* District Assessment Team (DAT) including operations, injury 
compensation and medical staffs; 
Activity description: DAT verifies current job offer matches tasks 
performed. 

Step: 8; 
Responsible team member: 
* District medical staff; 
* District labor relations staff; 
Activity description: Ensure procedures for light duty assignments are 
in effect, enabling identification and tracking of these employees[A]. 

Step: 9; 
Responsible team member: 
* District medical staff; 
Activity description: Identify veterans-preference eligible employees 
in light duty assignments. 

Step: 10; 
Responsible team member: 
* District Injury Compensation Specialist or staff; 
Activity description: Update NRP workbook to ensure all veterans in 
modified work assignments are properly recorded. 

Step: 11; 
Responsible team member: 
* District Injury Compensation Specialist or staff; 
Activity description: Create NRP file for all employees in modified 
work assignments to ensure that all necessary documents are on file. 

Step: 12; 
Responsible team member: 
* Area injury compensation team; 
Activity description: Review injury compensation file and NRP file for 
employees in all modified work assignments to verify that the NRP file 
is complete and accurate in preparation for reassessing employees. 

Step: 13; 
Responsible team member: 
* Area Injury Compensation Manager; 
Activity description: Area injury compensation staff review NRP Phase 1 
actions – all aspects must be verified as accurately completed. 

Source: GAO analysis of Service data. 

[A] In some cases, the Service also provides modified work assignments 
to employees injured off-the-job. These assignments are called "light 
duty" assignments. However, they are beyond the scope of our review. 

[End of figure] 

Figure 7: Description of NRP Activities in Phase 2: 

[Refer to PDF for image: table] 

Phase 2[A], Stage 1: Search: 

Step: 1; 
Responsible team member: 
* Headquarters Injury Compensation Team Leader; 
Activity description: Train area and district NRP teams on Phase 2 
search process. 

Step: 2; 
Responsible team member: 
* Area NRP team; 
Introduce and initiate NRP Phase 2 with district senior staff. 

Step: 3; 
Responsible team member: 
* District senior management; 
* Area and district injury compensation team leaders; 
* Area and district operations team leaders; 
* Area and district labor relations managers; 
Activity description: Hold meeting with all applicable union 
representatives. 

Step: 4; 
Responsible team member: 
* Area injury compensation team; 
* District injury compensation staff; 
Activity description: Update NRP workbooks to include all employees who 
have reached their maximum medical improvement (MMI), i.e., employees 
in rehabilitation assignments, and employees who have not reached their 
MMI, i.e., employees in limited duty assignments. 

Step: 5; 
Responsible team member: 
* Area NRP team; 
Activity description: Meet with district NRP team to discuss “necessary 
work” assignments. 

Step: 6; 
Responsible team member: 
* Area and district NRP teams; 
* Area NRP team; 
Activity description: Prepare local commuting area documentation for 
employees who have reached their MMI. 

Step: 7; 
Responsible team member: 
* Area NRP team; 
Activity description: Perform job searches for all employees who 
reached their MMI in less than a year to identify potential 
rehabilitation assignments within their local commuting area. 

Step: 7; 
Responsible team member: 
* Area and district NRP teams; 
Activity description: Perform job searches for all employees who 
reached their MMI in more than a year to identify potential 
rehabilitation assignments within their local commuting area. 

Step: 8; 
Responsible team member: 
* Area and district NRP teams; 
Activity description: Meet to discuss the status of all employees who 
have reached their MMI. 

Stage 2: Job offer: 

Step: 1; 
Responsible team member: 
* District Injury Compensation Manager; 
* District operations team; 
Activity description: District operations team submits the DAT-approved 
proposed job offers (i.e., rehabilitation duties worksheets) to the 
senior manager for approval, thus demonstrating that the position had 
been identified and approved by senior management. 

Step: 2; 
Responsible team member: 
* District injury compensation staff; 
* District operations team leaders; 
Activity description: Prepare and complete formal job offers. 

Step: 3; 
Responsible team member: 
* District NRP team (operations and injury compensation); 
* District labor relations team; 
Activity description: Schedule employee interviews to discuss and 
present job offers; notify employees and union representatives. 

Step: 4; 
Responsible team member: 
* District NRP team; 
Activity description: Conduct interviews for the approved job offers 
with employees. 

Step: 5; 
Responsible team member: 
* District NRP team; 
* District Injury Compensation Manager; 
* District NRP Labor Relations Representative; 
Activity description: Two weeks after each interview, follow up to 
ensure that each employee has responded to their job offer. 

Step: 6; 
Responsible team member: 
* District Injury Compensation Manager; 
Activity description: When the job offer is accepted, the Injury 
Compensation Manager must coordinate with the manager of the new 
facility to prepare for the employee to start work there. 

Stage 3: NWA (no work available): 

Step: 1; 
Responsible team member: 
* Area Injury Compensation Manager; 
* Area Injury Compensation Team Leader; 
Activity description: Meet with DOL‘s OWCP District Director to discuss 
the NRP and the Service’s preliminary NWA list. 

Step: 2; 
Responsible team member: 
* Area and district NRP teams; 
Activity description: Area and district teams review all NWA employee 
files and review them for accuracy. 

Step: 3; 
Responsible team member: 
* Area and district NRP team leaders; 
Activity description: Meet with district managers on the status of the 
NRP and discuss the job searches that senior managers will have to 
approve. 

Step: 4; 
Responsible team member: 
* Area NRP team leaders; 
Activity description: Brief surrounding district managers in the local 
commuting area on the NRP, and discuss the district's responsibility in 
completing the job searches. 

Step: 5; 
Responsible team member: 
* District injury compensation staff; 
* District NRP operations team; 
Activity description: Track and file job search results. 

Step: 6; 
Responsible team member: 
* District NRP team; 
Activity description: Schedule interviews with employees receiving NWA 
determinations. 

Step: 7; 
Responsible team member: 
* Area NRP team; 
Activity description: Brief the Service’s Inspection Service and its 
Office of Inspector General on NRP and NWA interviews[B]. 

Step: 8; 
Responsible team member: 
* Area NRP team; 
* District labor relations team; 
* District Operations Team Leader; 
Activity description: Brief local unions about ongoing and preliminary 
NWA employee results. 

Step: 9; 
Responsible team member: 
* District NRP team; 
Activity description: Prepare employee resource guide and meet with 
applicable Service staff to discuss the final steps of the NWA process. 

Step: 10; 
Responsible team member: 
* District NRP team; 
Activity description: Notify employees by letter at least 14 days in 
advance of employee interviews. 

Step: 11; 
Responsible team member: 
* Area NRP team; 
Activity description: Brief district NRP teams on the prescribed script 
for the interviews and select interview team leaders. 

Step: 12; 
Responsible team member: 
* District NRP team; 
* Area Operations Team Leader; 
* Area Injury Compensation Team Leader; 
Activity description: Conduct first interviews with all affected 
employees. 

Step: 13; 
Responsible team member: 
* District NRP Operations Team Leader or member; 
Activity description: Notify facility managers of upcoming second 
interview with employees receiving NWA determinations. 

Step: 14; 
Responsible team member: 
* District NRP team; 
* Area Operations Team Leader; 
* Area Injury Compensation Team Leader; 
Activity description: Conduct second interviews with employees 
receiving NWA determinations. 

Step: 15; 
Responsible team member: 
* District injury compensation staff; 
* District NRP operations team; 
Activity description: Track and identify activities related to 
employees placed on OWCP’s rolls due to NWA determinations. 

Source: GAO analysis of Service data. 

[A] The Service calls this phase, "Phase 2: Rehabilitation." To enhance 
the clarity of this report, we refer to this phase as "Phase 2." 

[B] The Service notifies representatives within its Postal Inspection 
Service and its Office of Inspector General in anticipation of problems 
that may be encountered during interviews with employees receiving an 
NWA determination. 

[End of figure] 

Figure 14: Description of NRP Activities in Phase 3: 

[Refer to PDF for image: table] 

Phase 3[A]: 

Stage 1: Implementation: 

Step: 1; 
Responsible team member: 
* Headquarters Health and Resource Management Team Leader; 
Activity description: Meet with area and selected district NRP team 
members and train them on this phase. 

Step: 2; 
Responsible team member: 
* Headquarters NRP team; 
* Area NRP team; 
Activity description: Meet with district senior managers to initiate 
this phase and confirm their support. 

Step: 3; 
Responsible team member: 
* District senior management; 
* DAT members; 
Activity description: Meet with union representatives and Service 
management organizations to inform them about this phase. 

Step: 4; 
Responsible team member: 
* Area Health and Resource Management Team Leader; 
* District health and resource management staff; 
Activity description: Review NRP workbook files to ensure that all 
employees who have not yet reached their MMI are listed. 

Step: 5; 
Responsible team member: 
* Area NRP team; 
* District NRP team; 
Activity description: Train district managers on their role in Phase 3. 

Step: 6; 
Responsible team member: 
* Area NRP team; 
* District NRP team; 
Activity description: DAT conducts initial modified work assignment 
determinations and area team commences its review of these 
determinations. 

Stage 2: Work status: 

Step: 1; 
Responsible team member: 
* Headquarters/area/district NRP teams; 
Activity description: Review all proposed modified work assignment 
determinations for accuracy. 

Step: 2; 
Responsible team member: 
* Headquarters/area/district NRP teams; 
Activity description: Train facility managers or supervisors on work 
status meetings and explain all possible work status determinations; 

Step: 3; 
Responsible team member: 
* DAT; 
Activity description: Review documentation for all modified work 
assignments for compliance. 

Step: 4; 
Responsible team member: 
* Facility Manager/Supervisor; 
Activity description: On a daily basis, review available necessary 
tasks and make assignment determinations, and conduct daily work status 
meetings with injured employees who have not yet reached their MMI. 

Stage 3: New medical/new injury: 

Step: 1; 
Responsible team member: 
* Facility Manager/Supervisor; 
Activity description: Employee presents updated medical documentation 
for an existing injury or new documentation for a recent injury. 

Step: 2; 
Responsible team member: 
* Facility Manager/Supervisor; 
Activity description: Managers/supervisors assess each employee based 
on recently presented medical documentation to determine the 
availability of necessary work. 

Step: 3; 
Responsible team member: 
* Facility Manager/Supervisor; 
Activity description: Managers/supervisors present work status 
determination to each employee, elicit employee feedback regarding the 
proposed assignment, and make adjustments if necessary. 

Source: GAO analysis of Service data. 

[A] The Service calls this phase, "Phase 2: Limited Duty." We refer to 
this phase as "Phase 3." 

[End of figure] 

[End of section] 

Appendix V: Comments from the United States Postal Service: 

United States Postal Service: 
Anthony J. Vegliante: 
Executive Vice President and Chief Human Resources Officer: 
475 L'Enfant Plaza, SW: 
Washington, DC 20280-4000: 
[hyperlink: http://www.usps.com] 

December 1, 2009: 

Mr. Phillip R. Herr: 
Director, Physical Infrastructure Issues: 
United States Government Accountability Office: 
Washington, DC 20548-0001: 

Dear Mr. Herr: 

Thank you for providing the U.S. Postal Service with the opportunity to 
review and comment on the draft report titled U.S. Postal Service: The 
Program for Reassessing Work Provided to Injured Employees Is Underway, 
but Actions Are Needed to Improve Program Management (GAO-10-78). 

We appreciate your understanding of the complex issues facing the 
Postal Service in our efforts to ensure that injured employees 
requiring modified work assignments within their medical restrictions 
perform necessary work. This has been a particularly difficult 
challenge in light of recent economic conditions, improved 
technological and engineering work processes, and complex federal 
regulations. As your report indicates, "By implementing the NRP, the 
Service has taken an important step to balance its obligation to 
provide work to employees with compensable workplace injuries (when 
necessary work is available for them to perform within their medical 
restrictions) with its obligation to Congress, its employees and the 
public to operate as effectively and efficiently as possible." 

The goal of the National Reassessment Process (NRP) is to place every 
injured employee requiring modified work within current medical 
restrictions in only necessary work assignments. This goal ensures that 
financial savings are not placed as a higher priority than the injured 
employee. 

In your report, you suggest that the NRP is hampered by a lack of 
senior management support and the lack of identified milestones toward 
the completion date. The NRP was given complete senior management 
support as evidenced by the commitment of resources by each area. We 
implemented the NRP with an end goal in sight; however, we fully 
understood that the
stakeholders in our process were many and varied and that we would have 
to constantly address new issues as they surfaced even at the expense 
of an on time completion. We do not believe that setting an arbitrary 
deadline for district completion of this process is in the best 
interests of our employees. Establishing a timeline could negatively 
impact our ability to ensure that each injured employee is given an 
individualized review that insures each resolution is specific to the 
individual and their medical restrictions. 

The Postal Service does not agree that the tracking data for the NRP is 
unknown. The Postal Service tracks and monitors each injured employee 
on a 51-field Excel spreadsheet report at each of the 74 district 
offices. We certainly recognize that because the data are not 
aggregated at the national level this provides audit challenges, 
however, the program was implemented to be reviewed and monitored at 
the district level, not nationally. The NRP summary reports monitored 
at the national level are sufficient for the experienced senior 
management officials responsible for this program. In February 2010 the 
new national claims management program will be deployed. This will 
enhance our abilities to track and measure NRP progress and enable cost 
efficient aggregation of data. 

We agree to fully disclose any limitations that apply to the NRP-
related cost savings reported to Congress and others as appropriate. As 
noted in the GAO report, often times the actual savings were 
consciously conservative. This conservative approach led to under 
reporting actual savings taking into account all new associated program 
costs such as increased travel. 

The goal of the NRP remains the same, ensuring that employees requiring 
medically restricted work are offered only necessary work assignments. 
We also recognize that as the Postal Service completes the NRP and 
moves into the next phase, which is the ongoing National Assessment 
Process, a growing number of postal employees who may require the 
services of the Vocational Rehabilitation Program will impact the 
Office of Workers' Compensation Programs. 

If you or your staff would like to discuss any of these comments 
further, Ron Henderson is available at your convenience at (202) 268-
3587. 

Sincerely, 

Signed by: 

Anthony Vegliante: 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Phillip Herr, (202) 512-2834, or Herrp@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Kathleen Turner, Assistant 
Director; Shirley Abel; Teresa Anderson; Lindsay Bach; Lauren Calhoun; 
Jay Cherlow; Tonnye Conner-White; Elizabeth Eisenstadt; Colin Fallon; 
Lauren Gilbertson; Brandon Haller; Elizabeth A. Marchak; Josh Ormond; 
Patricia Owens; Jerome Sandau; and Laura Shumway made key contributions 
to this report. 

[End of section] 

Footnotes: 

[1] For purposes of this report, we generally refer to both traumatic 
injuries, such as injuries arising from vehicular crashes, and 
occupational illnesses, such as carpal tunnel syndrome, as "injuries." 

[2] Because these employees are not in modified work assignments, they 
are not included in the scope of this review. 

[3] Under the Americans with Disabilities Act of 1990, codified as 
amended at 42 U.S.C. § 12101 et seq., employers are required to make 
"reasonable accommodations" for qualified individuals with 
disabilities, unless to do so would require undue hardship (e.g., 
creating a new position.) See 42 U.S.C. §§ 12112(b)(5), 12111(10). The 
Rehabilitation Act of 1973, Pub. L. No. 93-112, 87 Stat. 355, applies 
these standards to federal agencies, including the Postal Service. See 
29 U.S.C. § 791, 39 C.F.R. § 255.5, 29 C.F.R. § 1614.203. 

[4] Payments to federal employees for compensable work-related injuries 
and illnesses are authorized by the Federal Employees' Compensation 
Act, 39 Stat. 743 (1916), codified as amended at 5 U.S.C. chapter 81, 
and administered by the Office of Workers' Compensation Programs within 
the Department of Labor. The Department of Labor provides benefits to 
workers injured on the job, including wage loss compensation, payments 
for medical care and, where necessary, vocational rehabilitation 
training and assistance in returning to work. The department charges 
these expenses back to the federal agencies in order to be reimbursed 
for making payments to their employees. 

[5] When we began our review in October 2008, there were 80 postal 
districts. The Service subsequently eliminated 6 districts, and their 
activities were absorbed by other districts. While there are currently 
74 districts, we report available information on the status and 
outcomes of 75 districts because 1 of these had not fully distributed 
its employee files, including those related to the NRP, to other postal 
districts. 

[6] The results of our discussions with officials in these eight 
districts are not generalizable to all of the Service's districts. 

[7] GAO, High Risk Series: Restructuring the U.S. Postal Service to 
Achieve Sustainable Financial Viability, [hyperlink, 
http://www.gao.gov/products/GAO-09-937SP] (Washington, D.C.: July 28, 
2009). 

[8] Noncareer employees include "casual" and "transitional" staff with 
limited-term appointments. The Service hires these employees when it 
needs to temporarily augment the size of its workforce, such as during 
the Christmas season. 

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

[10] See 5 C.F.R. part 353. These regulations implement 5 U.S.C. § 
8151, part of the Federal Employees Compensation Act, as amended, Pub. 
L. No. 64-267, 39 Stat. 742 (1916), codified as amended at 5 U.S.C. 
chapter 81. Other legislative and regulatory protections also apply to 
injured federal employees, including protections afforded to employees 
in the Rehabilitation Act, and the Family Medical Leave Act of 1993, 
Pub. L. No. 103-3, 107 Stat. 6, as applicable. 

[11] Specifically, employees who reached their MMI within a year from 
the date they became eligible for compensation have the right to resume 
employment in their former job, or an equivalent position, agencywide. 
In contrast, employees who reach their MMI in more than a year from the 
date they became eligible for compensation are entitled to rights 
accorded to individuals who fully or partially recover, as applicable. 
49 C.F.R. § 353.301(c). 

[12] 5 U.S.C. §§ 8105, 8106. The calculation of basic compensation 
differs depending on whether the disability is total or partial. An 
employee may also be entitled to additional compensation depending on 
the nature of their injury and whether the employee has dependents. 5 
U.S.C. §§ 8107, 8110. Other considerations may also warrant more or 
less compensation. See 5 U.S.C. §§ 8111, 8112, 8113. Senior 
headquarters officials noted that Service employees receiving 
compensation from OWCP typically receive more than 66 and two-thirds 
percent of their prior salary. 

[13] Service data indicate that these employees had occupied a modified 
work assignment at some point, but, for example, subsequently had 
retired or otherwise separated from the Service. Thus, sufficient data 
were not available for us to determine whether these employees actually 
occupied a modified work assignment during fiscal year 2008. 

[14] GAO, U.S. Postal Service: Broad Restructuring Needed to Address 
Deteriorating Finances, [hyperlink, 
http://www.gao.gov/products/GAO-09-790T] (Washington, D.C.: July 30, 
2009). 

[15] [hyperlink, http://www.gao.gov/products/GAO-09-937SP]. 

[16] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]; Government 
Auditing Standards, [hyperlink, 
http://www.gao.gov/products/GAO-07-731G] (Washington, D.C.: July 2007 
Revision); Results Oriented Government: GPRA Has Established a Solid 
Foundation for Achieving Greater Results, [hyperlink, 
http://www.gao.gov/products/GAO-04-38] (Washington, D.C.: Mar. 10, 
2004); Tax Administration: IRS Needs to Further Refine Its Tax Filing 
Season Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22, 
2002); Managing for Results: Enhancing Agency Use of Performance 
Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: Sept. 9, 
2005); Statement of Federal Financial Accounting Standard Number 4, 
"Managerial Cost Accounting Concepts and Standards for the Federal 
Government," 2008 update. 

[17] Data on the number of these employees is also available at a 
district level, but is not aggregated by the Service agencywide. 

[18] The Service is implementing the NRP in two phases--Phase 1 and 
Phase 2--which includes "Phase 2 Rehabilitation" for employees who have 
reached their MMI and "Phase 2 Limited Duty" for those who have not yet 
reached their MMI. However, to enhance the clarity of this report, we 
refer to "Phase 2 Rehabilitation" as "Phase 2" and "Phase 2 Limited 
Duty" as "Phase 3." 

[19] Employees injured after the NRP's initiation also were included in 
the NRP process at each district. 

[20] In Phase 3, such an employee outcome is referred to as a "full day 
work" determination. 

[21] In certain cases, DOL may decide that an individual is eligible 
not only to receive wage loss compensation but also to participate in 
its vocational rehabilitation training program. 

[22] Wage loss compensation for these employees includes compensation 
for (1) the number of hours the employees could not work for the 
Service because of their medical restrictions and (2) the additional 
work hours for which the Service did not have medically suitable and 
necessary work for the employees to perform. 

[23] This assumes that the employee did not, for example, successfully 
appeal or grieve his or her initial NWA determination. 

[24] A "full day work" determination does not necessarily equal a 
typical 8-hour workday. For example, if an employee is capable of 
working only 4 hours a day, and the Service provides the employee with 
an assignment of that duration, such an assignment would constitute 
"full day work" for that employee. If, however, the Service provides 
only a 2-hour work assignment, the employee would be eligible to 
receive OWCP compensation for the 2 additional hours that he or she 
could have worked for the Service, as well as the remaining 4 hours 
that he or she could not have worked because of his or her medical 
restrictions. 

[25] Depending on the employee's expected date of recovery and the 
likelihood of future work at the Service, employees who receive a 
"complete day no work" determination may be placed on OWCP's "periodic 
rolls." In contrast, employees who receive a "partial day work" 
determination likely would be placed on OWCP's "daily rolls." 

[26] Senior headquarters officials acknowledged that mistakes were 
sometimes made, particularly early in the NRP's implementation. For 
example, in San Francisco, officials responsible for implementing the 
NRP told us that they moved forward with the NRP's implementation 
(using information provided by another district) without receiving 
necessary guidance from headquarters. As a consequence, headquarters 
required the district to repeat prior steps because the district had 
not implemented them correctly. 

[27] Like the other NRP phases, the order of Phase 3's implementation 
among the districts is determined by area managers in each of the 
Service's nine areas. 

[28] The additional searches are required to proceed in the following 
manner: (1) different craft, same tour and facility; (2) same craft, 
different tour, and same facility; and (3) different craft and tour, 
same facility. 

[29] The majority of the job search process is the same for employees 
who have reached their MMI regardless of when (i.e., more than 1 year, 
or less than 1 year, after their date of eligibility for compensation). 
However, for employees who reached their MMI in more than 1 year, 
postal managers do not need to expand their search for jobs beyond the 
district's boundaries. 

[30] As of July 2009, three of the four largest postal unions had filed 
a total of six national-level grievances related to the NRP process. 
The grievances cover a broad scope of issues, ranging from the 
consideration of seniority when making job offers under the NRP to a 
challenge of an entire phase of the NRP process. As of July 2009, one 
grievance had been settled, while the others were either pending a 
decision by the Service or pending arbitration. On the local level, 
employees have filed a number of grievances under their union contracts 
related to their NRP work determinations. In addition to filing 
grievances, employees have other avenues of redress, including filing 
actions before the Merit Systems Protection Board and before the Equal 
Employment Opportunity Commission. Generally, the board adjudicates 
individual federal employee appeals when an employee believes he or she 
has suffered an adverse personnel action. The commission adjudicates 
matters in which the federal employee believes he or she has suffered 
an action in violation of workplace discrimination laws. 

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

[32] As previously noted, while the Service currently has 74 districts, 
we report available information on the status and outcomes of 75 
districts because 1 of these had not fully distributed its employee 
files, including those related to the NRP, to other postal districts. 

[33] The Service provided us with data on Phase 2 employee outcomes for 
eight districts as of June 30, 2009. Six of these districts--Western 
New York, Dakotas, New Hampshire-Vermont, Westchester, Metro Caribbean, 
and Honolulu--had completed Phase 2, while the 2 others--San Diego and 
Boston--had essentially completed this phase at that time. The Service 
was unable to provide us with data for these districts as of August 31, 
2009. 

[34] In addition, senior headquarters officials do not track or 
aggregate data on employees with outcomes that have not been resolved 
because of grievances or appeals. 

[35] According to senior headquarter officials, "other" outcomes 
include, but are not limited to, employees who had (1) either been 
terminated or transferred, (2) their MMI status rescinded by their 
treating physician, or (3) received a new medical assessment from their 
physician stating that they were now totally disabled and unable to 
work for the Service. 

[36] According to Service officials, to date, the Service has prefunded 
retirement costs for its employees. Thus, except for the Service's 
continued payments for retired employees' health benefits, its 
obligation to retired employees is eliminated. In addition, the Service 
bears no future financial obligation to employees who resign. 

[37] In addition to cost savings, senior headquarters officials, 
officials in the four districts we visited, and some union officials 
noted several additional benefits arising from the NRP, such as (1) the 
creation of a systematic approach to managing the medical records of 
employees with workplace injuries, (2) better job offers that match 
injured employees' medical restrictions with necessary work 
assignments, and (3) increased morale among Service employees who, for 
example, had to perform mission critical tasks that could not be 
performed by injured employees. 

[38] As discussed, employees also are entitled to receive compensation 
for the hours they could not work for the Service because of their 
medical restrictions. 

[39] Over time, some of the additional costs may decline. For example, 
when former Service employees on OWCP's periodic rolls find work as a 
result of their enrollment in OWCP's vocational rehabilitation training 
program or on their own, their compensation is reduced to account for 
their additional income. According to OWCP officials, the vocational 
rehabilitation training program normally takes more than 2 years to 
complete. 

[40] While we requested data on the costs associated with developing, 
implementing, and integrating the NRP into the Service's management 
practices, the Service did not provide us with this information. 

[41] We were unable to ascertain from Service data the typical length 
of time in which employees were in a modified assignment. However, 
according to senior headquarters officials, some employees are in 
modified work assignments for many years, while others require only a 
short-term modified work assignment. 

[42] United States Postal Service Comprehensive Statement on Postal 
Operations, 2008, 29. The Service is required to provide this report to 
Congress in conjunction with its annual budget. 39 U.S.C. § 2401(e). 
According to the Service, this report summarizes customer, employee, 
and operations-focused developments during fiscal year 2008. 

[43] For example, as discussed, if an employee receives an NWA 
determination and is successful in obtaining a new job with a salary 
that is equal to or greater than the salary he or she received from the 
Service, the Service no longer incurs any OWCP costs for this employee. 

[44] The "lowest fully-loaded work hour" represents the salary and 
benefits, such as annual leave and retirement, that the Service pays to 
employees in its lowest clerk position. According to senior 
headquarters officials responsible for implementing the NRP, this 
position is a "Clerk 4." 

[45] Available data on employee outcomes arising from Phase 2 are as of 
June 30, 2009, while data on the outcomes of Phase 3 are as of August 
31, 2009. We determined these data were sufficiently reliable for our 
reporting purposes. 

[46] The four largest postal unions are the American Postal Workers 
Union, the National Association of Letter Carriers, the National Postal 
Mail Handlers Union, and the National Rural Letter Carriers' 
Association. The four unions represent about 85 percent of all postal 
employees. 

[47] We selected the four districts we visited to include districts 
that (1) had either relatively high or low percentages of employees in 
modified work assignments as of December 2008 and (2) were implementing 
various phases of the NRP (Phase 1 or 2) when we began our review. In 
addition, the four selected districts are geographically diverse and 
represent a mix of urban, suburban, and rural locations. Finally, we 
selected the four other districts we contacted because they had been 
implementing Phase 3 of the NRP the longest. 

[48] Unlike employees in modified work assignments, these individuals 
presumably receive the entirety of their work-related compensation from 
DOL's OWCP program. 

[49] While we requested data on the cost of implementing the NRP, the 
Service did not provide us with this information. Furthermore, although 
OWCP costs associated with employee outcomes resulting from the NRP can 
be determined, it was not feasible for us to do so for a wide variety 
of reasons, including the time and effort required to cross-match 
employees with specific NRP outcomes, such as "no work available" 
determinations (Phase 2) and "complete day no work" and "part-day no 
work" determinations (Phase 3), to DOL's OWCP payment records. 

[50] The number of employees in modified work assignments fluctuates 
both between years and within each year as employees, for example, (1) 
incur injuries and, possibly, begin working in modified assignments and 
(2) return to full duty, retire, or otherwise separate from the Service 
(i.e., leave their modified work assignments). 

[51] Collectively, these employees represent about 7 to 8 percent of 
the Service's workforce during fiscal year 2008. 

[52] While the Service has eliminated 6 of its districts, it had 80 
districts in fiscal year 2008. 

[53] Data on the employee's work status provides, for example, 
information on whether the employee was in a modified assignment during 
fiscal year 2008 and whether he or she retired, separated, or returned 
to full duty during that fiscal year. 

[54] To ensure that employees in these assignments were counted only 
once in our analysis, we generally used the employees' Social Security 
numbers as their unique identifier. However, five of the districts' 
workbooks did not provide the employees' Social Security numbers, so we 
created other, unique identifiers for these employees. 

[55] Multiple records occur when, for example, an employee reaches his 
or her maximum medical improvement and is moved from a limited duty 
assignment to a rehabilitation assignment. The 8,308 employees had from 
2 to 10 records. Determining why these employees had up to 10 records 
was beyond the scope of this review. 

[56] This protocol was approved by senior Service headquarters 
officials with overall responsibility for the workbooks and for 
implementing the NRP. 

[57] The Service's headquarters organization had the lowest percentage 
(70 of 11,370 employees or, fewer than 1 percent) of employees in 
modified work assignments during fiscal year 2008. 

[58] As discussed in appendix II, our analysis of Service data 
indicates that 50,031 employees with workplace injuries occupied a 
modified work assignment during fiscal year 2008. Up to 9,740 other 
employees could have been in such an assignment during the same time 
period. However, for the purpose of this analysis, we limited our 
analysis to the 50,031 employees who, based on the Service's data, 
definitely occupied a modified work assignment during this period. 

[End of section] 

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