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Volume, Performance, and Financial Changes since the Onset of the COVID-19 Pandemic (GAO-21-261)

Summary

A GAO report to congressional committees, GAO-21-261, dated April 2021, on the U.S. Postal Service (USPS). It reports that in 2020 USPS experienced a 9 percent drop in total mail volume compared to 2019, primarily due to a 4 percent dip in First-Class Mail and a 14 percent decline in Marketing Mail. Package volume rose by 32 percent in 2020, and a surge of election-related mail caused a temporary spike in total volume in September and October 2020. GAO notes that USPS's financial viability is not on a sustainable path and has been on GAO's High Risk List since 2009.

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             United States Government Accountability Office
             Report to Congressional Committees




             U.S. POSTAL
April 2021




             SERVICE

             Volume, Performance,
             and Financial
             Changes since the
             Onset of the COVID-
             19 Pandemic




GAO-21-261
                                           April 2021

                                           U.S. POSTAL SERVICE
                                           Volume, Performance, and Financial Changes since
                                           the Onset of the COVID-19 Pandemic
Highlights of GAO-21-261, a report to
congressional committees




Why GAO Did This Study                     What GAO Found
USPS plays a critical role in the          In 2020, the majority of which was affected by the COVID-19 pandemic, the U.S.
nation’s communications and                Postal Service (USPS) experienced a 9 percent drop in total mail volume when
commerce. However, USPS’s financial        compared to 2019. The overall drop was primarily due to a 4 percent dip in First-
viability is not on a sustainable path     Class Mail and a 14 percent decline in Marketing Mail (such as advertisements).
and has been on GAO’s High Risk List       Despite a drop in total volume, 2020 package volume rose by 32 percent. A
since 2009. The COVID-19 pandemic          surge of election-related mail caused a temporary spike in total mail volume in
has highlighted the role of USPS in the    September and October 2020, before falling again by year end.
nation’s economy as well as USPS’s
financial difficulties. Responding to      Overall, USPS’s nationwide on-time performance fell in 2020. Average monthly
these concerns, the CARES Act, as          on-time performance for First-Class Mail decreased from 92 percent in 2019 to
amended in late 2020, provided USPS        87 percent in 2020. However, decreases were more significant in certain USPS
up to $10 billion in additional funding.   districts at different times, and nationally in December 2020. On-time
The CARES Act included a provision         performance was 48 percent in New York in April and 61 percent in Baltimore in
for GAO to report on its monitoring and    September—both of which were nearly 90 percent prior to the pandemic (see
oversight efforts related to the COVID-    figure). Further, national on-time performance dipped to 69 percent in December.
19 pandemic. This report examines          In February 2021, the Postmaster General stated that on-time performance was
changes in USPS’s (1) mail volume,         affected by employees’ decreased availability in COVID-19 hot spots and a surge
(2) on-time performance, and (3)           in holiday package volume.
revenue and expenses from January
through December 2020.                     2020 Average Monthly On-Time Performance for First-Class Mail in Baltimore, Detroit, and
                                           New York Postal Districts
GAO analyzed USPS mail volume, on-
time performance, revenue, and
expense data by month for 2020, and
compared these data to similar data for
2019. GAO also reviewed its prior
work, including its May 2020 report.
That report had three matters for
congressional consideration on: (1)
determining the level of postal
services, (2) the extent to which those
services should be financially self-
sustaining, and (3) the appropriate
institutional structure of USPS. GAO
also reviewed reports by USPS and
the USPS Inspector General. Finally,
GAO interviewed USPS officials, two
package delivery companies that            USPS’s revenue increased in 2020 but not enough to avoid a net loss of $8.1
compete with USPS, and                     billion. Rapid growth and price increases for packages, resulted in a net revenue
representatives from four mailing          increase of $4.3 billion. However, USPS’s expenses grew by $4.4 billion,
associations whose members send the        including COVID-19 related expenses, such as personal protective equipment.
types of mail with the highest volumes     USPS took some cost-reduction actions in 2020 and released a new strategic
in 2020.                                   plan in March 2021 that also has cost-reduction actions. In May 2020, GAO
                                           concluded that absent congressional action to transform USPS, USPS’s financial
                                           problems would worsen, putting its mission and financial solvency in greater
                                           peril. The further deterioration of USPS’s financial position since the start of the
View GAO-21-261. For more information,     pandemic makes the need for congressional action even more urgent.
contact Jill Naamane, 202-512-2834 or
naamanej@gao.gov.


                                                                                        United States Government Accountability Office
Contents


Letter                                                                                 1
              Background                                                               3
              Total Mail Volume Decreased in 2020, Mostly Due to a Sharp
                Decline Early in the Year                                              6
              National On-Time Performance Declined through November and
                Significantly Declined in December, with Some Districts
                Experiencing Significant Declines throughout 2020                    11
              USPS’s Revenue Increased but Did Not Offset Increased
                Expenses, Highlighting the Need for Transformation of USPS’s
                Business Model                                                       15
              Agency Comments                                                        21

Appendix I    Comments from the United States Postal Service                         24



Appendix II   GAO Contact and Staff Acknowledgments                                  26


Tables
              Table 1: USPS’s Revenue, Expenses, and Net Loss, 2020
                      Compared to 2019                                               18
              Table 2: Selected and Total USPS Expenses for 2020 and 2019            18

Figures
              Figure 1: Total 2020 Monthly USPS Mail Volume, as Compared to
                       Same Month in 2019                                              7
              Figure 2: 2020 Monthly Market-Dominant Mail Volume as
                       Compared to the Same Month in 2019                              8
              Figure 3: USPS 2020 Monthly Competitive Product Volume
                       Compared to the Same Month in 2019                            10
              Figure 4: 2020 Average Monthly On-Time Performance for First-
                       Class Mail in Baltimore, Detroit, and New York Postal
                       Districts                                                     13
              Figure 5: Total Market-Dominant Products’ Revenue by Month,
                       2019 and 2020                                                 16
              Figure 6: USPS’s Total Revenue from Competitive Products by
                       Month, 2019 and 2020                                          17




              Page i                               GAO-21-261 USPS Changes since COVID-19
Abbreviations

CARES              Coronavirus Aid, Relief, and Economic Security Act
COVID-19           Coronavirus Disease 2019
FFCRA              Families First Coronavirus Response Act
OIG                U.S. Postal Service’s Office of the Inspector General
PRA                Postal Reorganization Act
UPS                United Parcel Service
USPS               U.S. Postal Service



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Page ii                                         GAO-21-261 USPS Changes since COVID-19
                       Letter




441 G St. N.W.
Washington, DC 20548




                       April 29, 2021

                       Congressional Committees

                       The U.S. Postal Service (USPS) plays a critical role in the nation’s
                       communication and commerce—collecting, transporting, and delivering
                       billions of letters, bills, ballots, magazines, newspapers, packages, and
                       other types of mail to about 161 million addresses nationwide.
                       Coronavirus Disease 2019 (COVID-19) has had a profound effect on the
                       economy and on USPS, which has continued to provide postal services
                       nationwide since the pandemic was declared a national emergency in
                       March 2020. Mailers have changed how they use USPS due to COVID-
                       19’s spread, affecting USPS’s mail volume, revenues, and expenses. In
                       response, the CARES Act, as amended in late 2020, provided USPS up
                       to $10 billion in additional funding. 1 USPS has requested additional
                       federal financial assistance, which would require further congressional
                       action.

                       We and members of Congress continue to be concerned with USPS’s
                       financial condition. In 2009, we placed USPS on our High-Risk List and
                       found that its financial condition needed attention by Congress and the
                       executive branch to achieve broad-based restructuring. 2 Since then,
                       USPS’s finances have worsened and USPS’s financial viability has
                       remained on our 2021 update to our High Risk list. 3 In May 2020, we
                       found that USPS’s business model was unsustainable, due in part to



                       1The Consolidated Appropriations Act, 2021 amended CARES Act authority to borrow this
                       amount by providing that USPS shall not be required to repay such amounts borrowed
                       (Pub. L. No. 116-260, div, N, tit. VIII, § 801, 134 Stat. 1182, 2119 (2020)). As of March
                       2021, USPS accessed about $8.6 billion of this CARES Act funding. Funds available
                       under the CARES Act (Pub. L. No. 116-136, div. A, tit. VI, § 6001, 134 Stat. 281, 504-05
                       (2020)), as amended, are in addition to USPS’s borrowing authority under the Postal
                       Reorganization Act (PRA) (Pub. L. No. 91-375, § 2, 84 Stat. 719, 740 (1970)) (codified as
                       amended at 39 U.S.C. § 2005(a)). The PRA authorizes USPS to borrow up to $3 billion in
                       any one fiscal year and not more than $15 billion in total. As of the end of fiscal year 2020,
                       USPS had borrowed $14 billion of this $15 billion total.
                       2GAO, High Risk Series: Restructuring the U.S. Postal Service to Achieve Sustainable
                       Financial Viability, GAO-09-937SP (Washington, D.C.: July 2009).
                       3GAO, High Risk Series: Dedicated Leadership Needed to Address Limited Progress in
                       Most High-Risk Areas, GAO-21-119SP (Washington, D.C.: Mar. 2, 2021).




                       Page 1                                           GAO-21-261 USPS Changes since COVID-19
declining mail volume and to expenses rising faster than revenue. 4
Congressional committees held hearings in August 2020 and February
2021 on USPS, and several bills have been introduced that are designed
to affect USPS’s financial viability. 5

We conducted this engagement under the authority of the CARES Act,
which includes a provision for us to conduct monitoring and oversight of
the federal government’s efforts to prepare for, respond to, and recover
from the COVID-19 pandemic. 6 This report describes how USPS’s (1)
mail volume, (2) on-time service performance for mail delivery, and (3)
revenues and expenses have changed since the COVID-19 pandemic.

This report covers January 1, 2020, through December 31, 2020. We
used January 1, 2020 as the start date of our analysis because this date
marks the beginning of the fiscal quarter in which the pandemic was
declared. We used December 31, 2020, as the end date of our analysis
as it is the most recent month for which data were available and because
it allows us to include the 2020 general election and holiday periods
where USPS experienced high mail volumes. Because nearly all of
USPS’s 2020 mail volume and revenue (about 99 percent and 97
percent, respectively) consists of domestic mail products such as
domestic First-Class Mail, Marketing Mail and packages, we excluded
USPS’s international mail from our analysis.

To determine how USPS’s mail volume changed during 2020, we
reviewed USPS data on mail volumes by mail type and by month for 2020
and compared these 2020 data to 2019 data. 7 To describe how USPS’s
on-time service performance changed, we analyzed USPS national on-

4GAO, U.S. Postal Service: Congressional Action Is Essential to Enable a Sustainable
Business Model, GAO-20-385 (Washington, D.C.: May 7, 2020).
5E.g., H.R. 695, 117th Cong. (2021); S. 145, 117th Cong. (2021).

6We regularly issue government-wide reports on the federal response to COVID-19. For

the latest report, see GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic
Enters Its Second Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021). Our next
government-wide report will be issued in July 2021 and will be available on GAO’s website
at https://www.gao.gov/coronavirus.
7Specifically, we used publicly-available postal volume data from USPS Preliminary
Financial Information, Unaudited reports that USPS submitted to the Postal Regulatory
Commission. USPS officials told us that there is usually a relatively small but noticeable
difference between the data in the monthly unaudited reports and their quarterly reports
which include volume data that have been reconciled.




Page 2                                           GAO-21-261 USPS Changes since COVID-19
             time performance data by month for 2020 and compared them to 2019.
             We also analyzed monthly on-time performance during 2020 for the
             Baltimore, Detroit, and New York postal districts. 8 We selected these
             districts because postal associations and package delivery companies we
             interviewed noted that these districts had experienced significant COVID-
             19 related service delays during the initial months of the pandemic. We
             also reviewed USPS’s and USPS Office of the Inspector General’s (OIG)
             reports regarding USPS’s service performance for 2020. To determine
             how USPS’s revenues and expenses changed and how USPS responded
             to these changes, we reviewed USPS data on revenues and expenses by
             month for 2019 and 2020.

             For all of our objectives, we interviewed USPS officials, two major
             package delivery companies that directly compete with USPS in the
             products they offer, and four associations that represent companies that
             send the highest-volume categories of mail: First-Class Mail, Marketing
             Mail, and packages. We also interviewed relevant USPS officials about
             volume, on-time performance, and financial data that they either provided
             us directly or that we obtained from publicly available reports. They
             described where the data came from, how they were collected, and
             controls in place to provide assurance the data were complete and
             accurate. Based on these interviews and relevant USPS documents we
             reviewed, we determined all data used were sufficiently reliable for the
             purposes of reporting on USPS mail volumes, on-time performance
             levels, revenues, and expenses.

             We conducted this performance audit from July 2020 to April 2021 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.

             USPS’s mission is to provide prompt, reliable, and efficient universal
Background   service to the public, while covering its expenses primarily through



             8USPS divides the country into seven postal areas and 67 postal districts. A postal area is
             the administrative level directly below national headquarters. A postal district is the
             administrative level directly below a postal area.




             Page 3                                            GAO-21-261 USPS Changes since COVID-19
revenues generated from the sale of its products and services. 9 USPS’s
two main types of mail products—market-dominant and competitive—vary
in terms of volume, profitability, and pricing.

•   Market-dominant products—which include products such as First-
    Class Mail, Marketing Mail, and Periodicals—account for over 90
    percent of USPS’s total mail volume and over half of USPS’s
    revenue. 10 We found in May 2020 that First-Class Mail, Marketing
    Mail, and total mail volumes have experienced significant declines
    since their peaks in 2006. USPS is limited in its ability to set prices for
    market-dominant products. 11
•   Competitive products, which consist of mostly packages but also of
    other products such as express letters, are those for which USPS
    competes with other package delivery companies, such as United
    Parcel Service (UPS) and FedEx, on pricing and service. 12 USPS


9USPS’s universal service obligation is governed by several statutory provisions, including
the requirement to provide a maximum degree of effective and regular postal services to
rural areas, communities, and small towns where post offices are not self-sustaining. See
39 U.S.C. §§ 101, 403(a), 3691. For more information, see GAO, U.S. Postal Service:
Strategies and Options to Facilitate Progress toward Financial Viability, GAO-10-455
(Washington, D.C.: Apr. 12, 2010) and Postal Regulatory Commission, Report on
Universal Postal Service and Postal Monopoly (Washington, D.C.: Dec. 19, 2008).
10USPS’s market-dominant products are those for which it has a statutory monopoly or
provides a large share of the product with limited competition. Such market dominance in
an unregulated market would likely enable a firm to exercise market power through the
setting of price above costs without the risk of losing a significant level of business to other
firms offering similar products.
11Price increases for market-dominant products are generally subject to a price cap based
on the Consumer Price Index for All Urban Consumers (“CPI-U”). USPS’s Governors
establish the prices for market-dominant services, subject to a review process by the
Postal Regulatory Commission (PRC) for compliance with requirements such as the price
cap. PRC issued an order adopting final rules in November 2020; the order, among other
things, modifies USPS’s price cap for market-dominant products, thereby providing USPS
with additional rate adjustment authority. Postal Regulatory Commission, Order No. 5763
(Nov. 20, 2020). PRC is an independent establishment of the executive branch that has
exercised regulatory oversight over USPS since PRC’s creation (as the Postal Rate
Commission) by the Postal Reorganization Act of 1970 (Pub. L. No. 91-375, § 2, 84 Stat.
719, 759 (1970)), with expanded responsibilities (and a re-designation as PRC) under the
Postal Accountability and Enhancement Act of 2006 (Pub. L. No. 109-435, 120 Stat. 3198
(2006)).
12Competitive products—which include Priority Mail, Priority Mail Express, First-Class
Package Service, Parcel Select and Parcel Return Service, and some types of
international mail—have greater pricing flexibility than market-dominant products and are
not limited by a price cap.




Page 4                                            GAO-21-261 USPS Changes since COVID-19
    must price these products to at least cover their attributable costs. 13
    As we found in May 2020, competitive products have become more
    important to USPS, as its competitive product volumes more than
    tripled between fiscal year 2007 and fiscal year 2019. 14 However,
    according to USPS officials, competitive products have lower profit
    margins than some market-dominant products, although profit
    margins for competitive products have increased in recent years.
USPS establishes public delivery service standards for most of its market-
dominant mail products, which define the number of days USPS is to take
to deliver the mail in a timely manner. 15 USPS measures its delivery
performance as the percentage of mail pieces delivered within its service
standards. To determine whether a piece of mail is delivered on time,
USPS compares the mail’s transit time—that is, the number of days it
takes USPS to deliver the mail once it enters USPS’s system—with its
delivery service standards. 16 For the purposes of this report, we refer to
this performance measurement as “on-time performance”.




13Prices for competitive products are set by the USPS Board of Governors and reviewed
by PRC for compliance with applicable requirements. By statute, prices for each
competitive product must at least cover “attributable costs” (meaning USPS’s direct and
indirect costs attributable to the products through reliably identified causal relationships),
and competitive products collectively must contribute an appropriate share to USPS’s
institutional costs, 9.1 percent for fiscal year 2021, as determined by PRC.
14GAO-20-385.

15The Postal Accountability and Enhancement Act of 2006 requires USPS to create
service standards for market-dominant products. Pub. L. No. 109-435, § 301, 120 Stat.
3198, 3218 (2006)) (codified at 39 U.S.C. § 3691). These standards include measuring
and reporting on delivery performance. USPS does not publicly report on the extent
service performance meets the standards for its competitive products, as USPS considers
this information proprietary.
16USPS’s service standards for its market-dominant mail products define the number of
days USPS is to take to deliver the mail in a timely manner. Its service standards are set
forth in federal regulations (see 39 C.F.R. §§ 121.1 - 121.4) and differ depending on the
type of mail, the time of day and location at which USPS receives the mail, and the mail’s
final destination. For example, USPS standards for delivery of 2-day single-piece First-
Class Mail require the mail to be received by a specified cutoff time on the day it is
accepted, which varies depending on geographic location and where the mail is deposited
(e.g., in a collection box, at a post office, or at a mail-processing facility). This mail must
then be delivered on the second regular delivery day (Monday to Saturday) to be
considered “on time.” USPS measures delivery performance against its delivery service
standards to determine its on-time performance. In fiscal year 2020, the USPS annual
target for on-time performance for single-piece, two-day First-Class Mail was 96.5 percent.




Page 5                                            GAO-21-261 USPS Changes since COVID-19
Total Mail Volume
Decreased in 2020,
Mostly Due to a
Sharp Decline Early
in the Year
Total Mail Volume           During 2020, total USPS mail volume decreased by 8.6 percent (11.9
Decreased in Early 2020,    billion pieces) when compared to 2019. 17 Market-dominant mail made up
Spiked Prior to the 2020    94 percent of total mail volume, and competitive mail made up the
                            remaining 6 percent of total mail volume in 2020. While total mail monthly
General Election and Fell   volume at the beginning of 2020 was similar to the total mail monthly
Back Below 2019 Levels      volume during 2019, it dropped to significantly lower levels with the onset
by the End of 2020          of the COVID-19 pandemic in March (see fig. 1). However, during
                            September and October, total mail volumes briefly spiked. According to
                            USPS officials, this increase was due in part to election mail sent prior to
                            the 2020 general election. After the election in early November,
                            November and December total mail volume again decreased to below
                            2019 levels.




                            17These figures do not include international mail.




                            Page 6                                           GAO-21-261 USPS Changes since COVID-19
                          Figure 1: Total 2020 Monthly USPS Mail Volume, as Compared to Same Month in
                          2019




                          Note: Total mail volume consists of market-dominant (such as First-Class Mail and Marketing Mail)
                          and competitive (mainly packages) mail volumes, which comprised 94 percent and 6 percent of total
                          mail volume, respectively. International mail, which comprised approximately 0.5 percent of annual
                          mail volume in 2020, is excluded from this figure.


Market-Dominant Mail      When compared to the 2019 levels, the drop, brief spike, and subsequent
Volume Drove Changes in   decline in total mail volume during 2020 was primarily due to changes in
                          market-dominant mail volume. USPS’s total mail volume has dropped
Total Mail Volume
                          every year but one since 2007. These year-over-year declines have been
                          driven by declines in market-dominant products. We found in May 2020
                          that as online communication and payments have expanded, USPS
                          continued to face decreases in mail volume. For example, we found that
                          First-Class Mail volume declined 44 percent since fiscal year 2006 and
                          that Marketing Mail declined 27 percent from fiscal year 2007 to fiscal
                          year 2019. 18 The two types of market-dominant mail that account for the
                          greatest share of USPS’s mail volume—First-Class Mail and Marketing
                          Mail— declined 4 percent and 14 percent, respectively, over the course of


                          18GAO-20-385.




                          Page 7                                              GAO-21-261 USPS Changes since COVID-19
2020 compared to 2019. However, both products experienced significant
volume fluctuations during 2020.

As shown in figure 2, monthly market-dominant mail volume at the
beginning of 2020 was similar to the same period in 2019. However,
monthly market-dominant mail volume decreased significantly at the
onset of the pandemic—by almost 30 percent in April 2020—and
remained below prior-year levels through August 2020. For example, in
April 2020, First-Class Mail declined by about 9 percent and Marketing
Mail declined by about 45 percent compared to April 2019, and in August
volumes were still 10 percent and 25 percent below 2019 levels,
respectively. However, September and October volumes increased to or
above previous-year levels. In September, both First-Class Mail and
Marketing Mail were within less than 1 percent of prior year levels, and in
October 2020 volumes exceeded 2019 volumes by 2 percent and 12
percent, respectively. According to USPS, this increase in volume was in
part because of a surge of election-related mail.

Figure 2: 2020 Monthly Market-Dominant Mail Volume as Compared to the Same
Month in 2019




Note: Market-dominant mail includes products such as First-Class Mail, Marketing Mail, Periodicals,
Package Services and Special Services.




Page 8                                               GAO-21-261 USPS Changes since COVID-19
                           USPS and a postal stakeholder identified key factors underlying these
                           changes in volume during 2020. For example, USPS told us that the
                           decline in First-Class Mail volume during 2020 would have been even
                           greater if not for volume increases associated with the 2020 decennial
                           U.S. Census and mailed recovery rebates (commonly referred to as
                           stimulus checks). 19 Further, USPS and a mailing association told us that
                           Marketing Mail declined after the start of the COVID-19 pandemic
                           because businesses that use Marketing Mail—such as local businesses
                           for instance—needed to preserve cash during the shutdown. Officials at
                           the mailing association told us that some of this mail volume returned as
                           some businesses began to re-open.

                           In November 2020, USPS projected that market-dominant mail volume
                           would decrease in fiscal year 2021 due to several factors, including:

                           •   the continuing long-term trend of migration from First-Class Mail to
                               electronic media,
                           •   the ongoing effects of the COVID-19 pandemic, and
                           •   the lack of the bolstering effects that the 2020 Census and recovery
                               rebates had on First-Class Mail volume in 2020 but that will not
                               continue in 2021. 20
Competitive Product        Competitive product volume was 32 percent greater in 2020 than 2019,
Volume Grew Rapidly        with nearly all of the volume increase occurring in packages after the
                           pandemic began in March 2020 (see fig. 3). 21 Competitive volumes in
during 2020 but Remained
                           2020 remained over 20 percent higher than 2019 volumes from April
a Small Percentage of      through December, with June 2020 volume peaking at over 71 percent
Total Mail Volume          higher than June 2019 volume. Additionally, USPS recorded its highest

                           19The CARES Act included a credit for tax year 2020 of up to $1,200 per eligible individual
                           or $2,400 for individuals filing a joint tax return, plus up to $500 per qualifying child (as
                           defined in section 24(c) of the Internal Revenue Code). The act also provided for an
                           advance refund of the credit. Pub. L. No. 116-136, div. A, tit. II, § 2201(a), 134 Stat. 281
                           335–40 (2020). The CARES Act refers to the credit and the advance payments as
                           Recovery Rebates.
                           20USPS, Fiscal Year 2021 Integrated Financial Plan, (Washington, D.C.) Nov. 24, 2020.
                           After the publication of this plan, a second round of recovery rebates was authorized by
                           the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260, div. N, tit. II, § 272, 134
                           Stat. 1182, 1965 (2020)) and scheduled to be sent in 2021. A third round of recovery
                           rebates was authorized by the American Rescue Plan Act of 2021, (Pub. L. No. 117-7, tit.
                           IX, sub. tit. G, Part 1, § 9601, 135 Stat. 4, 138 (2021)) to be provided prior to December
                           31, 2021.
                           21We did not compare competitive product volumes to USPS projections, because USPS
                           considers its projected competitive volumes to be business proprietary information.




                           Page 9                                            GAO-21-261 USPS Changes since COVID-19
competitive package volume ever in December 2020 with over 811 million
packages processed, about 147 million more packages than in December
2019.

Figure 3: USPS 2020 Monthly Competitive Product Volume Compared to the Same
Month in 2019




Note: Competitive products consist of mostly packages, but also of other products such as express
letters. We excluded international mail from our analysis.


Despite USPS experiencing record volume growth in competitive
products, these products continue to be a small albeit growing contributor
to total mail volume. We found in May 2020 that the volume of
competitive products (most of which are packages) more than tripled from
fiscal year 2007 through fiscal year 2019. 22 While competitive products
significantly increased over 2019 levels in 2020, they constituted only 6
percent of USPS’s total mail volume for 2020.

USPS officials, two major package delivery companies, and an
association representing mailers told us that the growth in 2020 was due

22GAO-20-385.




Page 10                                             GAO-21-261 USPS Changes since COVID-19
                         in part to increased business-to-consumer shipping, as household
                         purchasing moved online during the pandemic, including during the 2020
                         holiday season. In addition, USPS officials told us that other package
                         delivery companies were also experiencing volume increases, which
                         resulted in their sending additional package volume to USPS for “last
                         mile” delivery. 23 For instance, one package delivery company told us that
                         it had experienced volumes typical of its November-December holiday
                         season since the pandemic began in March 2020 and that the volume
                         growth it had anticipated over the next 3 to 5 years had manifested itself
                         over just a few months. Another package delivery company told us it had
                         increased its use of USPS’ last-mile delivery service to manage its
                         volume increases. In November 2020, USPS reported that it expects
                         future package volume to decline from 2020’s elevated levels. 24

                         During 2020, USPS nationwide on-time performance for market-dominant
National On-Time         mail fell when compared to 2019. 25 USPS stated that the average monthly
Performance              on-time performance for First-Class Mail decreased from 92.0 percent in
                         2019 to 86.7 percent in 2020. Likewise, USPS stated that the average
Declined through         monthly on-time performance for Marketing Mail decreased from 90.1
November and             percent in 2019 to 87.5 percent in 2020. While the average on-time
                         performance declined by 5 percentage points over the course of 2020 for
Significantly Declined   First-Class Mail, it declined more so in December 2020. Specifically,
in December, with        monthly on-time performance levels for First-Class Mail ranged from 84
                         percent to 93 percent from January through November 2020, and in
Some Districts           December 2020 dipped to 69 percent. In February 2021, the Postmaster
Experiencing             General testified that this significant decline in on-time performance
                         during the 2020 holiday season was due to, among other things, COVID-
Significant Declines     related issues affecting employee availability, increased package volume,
throughout 2020          and access to transportation. In March 2021, the Postmaster General
                         joined with union leadership and management associations to form a joint
                         task force on service performance to improve service in certain facilities
                         around the country.




                         23Package delivery companies, such as UPS, pay USPS to deliver packages that they
                         enter into USPS’s system at local post offices where carriers pick up their mail for “last
                         mile” delivery.
                         24USPS, Fiscal Year 2021 Integrated Financial Plan.

                         25USPS reports on-time performance for its First-Class Mail, Marketing Mail, Periodicals,
                         Packages and Special Services. USPS does not report its on-time performance for its
                         competitive products, as USPS regards that information as proprietary.




                         Page 11                                          GAO-21-261 USPS Changes since COVID-19
Representatives we spoke with from mailers associations and package
delivery companies in September and October 2020 stated that while the
effect of COVID-19 on national on-time performance has been relatively
small, certain postal districts—such as New York, Detroit, and
Baltimore—have experienced periods of significant declines during the
pandemic. USPS data show that on-time performance for First-Class Mail
in these districts were all nearly 90 percent and in close proximity to the
national average prior to the COVID-19 pandemic but significantly
declined for various periods after the pandemic was declared (see fig. 4).
For example, USPS’s New York district had an on-time performance
rating of about 48 percent in April, and Baltimore’s on-time performance
dipped to about 61 percent in September. USPS officials stated that they
took several actions to respond to these on-time performance declines,
such as shifting mail volume within their mail-processing network,
expediting the hiring of new employees, and adjusting delivery schedules.

While each of these districts may have experienced differing trends at
different times, on-time performance for these districts in December 2020
was similar to national on-time performance in that they all experienced
significant declines. Specifically, the December 2020 First-Class Mail on-
time performance for the New York, Detroit, and Baltimore districts dipped
to 64 percent, 51 percent, and 42 percent, respectively. In January 2021,
officials from one mailing association told us that the poor on-time
performance in December has renewed some of its members’ efforts
toward digital alternatives to mail, which could result in even greater
reductions in First-Class Mail volumes over the next 12 to 18 months.




Page 12                                GAO-21-261 USPS Changes since COVID-19
Figure 4: 2020 Average Monthly On-Time Performance for First-Class Mail in
Baltimore, Detroit, and New York Postal Districts




USPS and the USPS OIG identified several COVID-19-related factors
related to the decline in on-time performance. Specifically, USPS officials
attributed decreases in on-time performance to a combination of COVID-
19-related factors, such as reduced employee and transportation
availability, increased package volume, and the overall economic
impacts. 26 The USPS OIG also reported that several factors associated
with COVID-19 affected USPS’s on-time performance, such as decreased
employee availability and package volume increases. 27




26USPS officials also stated that it is not possible to precisely quantify the direct effects of
COVID-19 on on-time performance it is influenced by several other factors such as
transportation availability, operational changes and USPS’s focus on election mail in 2020.
27OIG, USPS, Operational Changes to Mail Delivery, Report Number 20-292-R21
(Arlington, VA: Oct. 19, 2020).




Page 13                                           GAO-21-261 USPS Changes since COVID-19
In addition to the factors associated with COVID-19, USPS took actions
that may have also reduced its on-time performance. For example, in
June 2020, the USPS OIG found that USPS spent $550 million in fiscal
year 2019 for such things as overtime and charter air flights to mitigate
delays in its mail transportation network. 28 In an August 2020 testimony,
the Postmaster General stated that USPS attempted to cut this cost by
reducing late and extra mail transportation trips between USPS’s mail-
processing plants and its post offices for final delivery among other
actions that he said were designed to cut costs. 29 However, the
Postmaster General also stated that to avoid the appearance of any
potential effect on election mail, he suspended several of these actions
until after the general election on November 3, 2020. There has also been
a number of lawsuits in federal court challenging the implementation of
this and other actions. 30 Many of these lawsuits resulted in preliminary




28OIG, USPS, Transportation Network Optimization and Service Performance, Report
Number 20-144-R20 (Arlington, VA: June 5, 2020).
29USPS, Statement of Postmaster General and Chief Executive Officer Louis DeJoy
before the House Committee on Oversight and Reform, Protecting the Timely Delivery of
Mail, Medicine, and Mail-in Ballots. Aug. 24, 2020.
30The plaintiffs consisted of both state governments and private parties, and their
challenges included alleged procedural violations because USPS did not seek a statutorily
required (39 U.S.C. § 3661) advisory opinion from the PRC prior to making changes that
will affect service on a nationwide or substantially nationwide basis, and alleged
constitutional violations because the changes affected people’s ability to vote by mail.
See, for example, Washington v. Trump, No. 20-cv-03127, 2020 WL 5568557 (E.D. Wash.
2020) (challenging the reduction of late and extra delivery trips, the reduction of overtime,
the decommission of sorting machines, the removal of mailboxes, the reduction in
operating hours, and the change in election-mail classification); see also New York v.
Trump, No. 20-cv-2340, 2020 WL 5763775 (D. D.C. 2020) (challenging the reduction of
late and extra delivery trips, the prohibition of mail carriers in certain cities spending time
in the morning sorting mail, the removal of sorting machines, and the decision to no longer
treat Election Mail on an expedited First-Class basis); see also Vote Forward v. DeJoy,
No. 20-cv-2405, 2020 WL 5763869 (D. D.C. 2020) (challenging the reduction of late and
extra trips and the alleged delay of election mail); see also Bullock v. USPS, No. 20-cv-
00079 (D. Mont. 2020) (challenging the reduction of overtime, removal of mailboxes,
decommission of sorting machines, and changes in the classification of Election Mail).




Page 14                                           GAO-21-261 USPS Changes since COVID-19
                           injunctions, temporarily prohibiting USPS from continuing to implement
                           these actions, and full resolution in some of the cases is still pending. 31


USPS’s Revenue
Increased but Did Not
Offset Increased
Expenses,
Highlighting the Need
for Transformation of
USPS’s Business
Model

USPS Total 2020 Revenue    Decreasing revenue from market-dominant products was more than offset
Increased Due to Growth    by increasing revenue from competitive products in 2020, resulting in a
                           net revenue increase of 6.1 percent (about $4.3 billion). 32 Revenue from
in Competitive Products’
                           market-dominant products decreased overall by $3.8 billion from 2019 to
Volume and Prices          2020, with some significant monthly changes (see fig. 5). To some extent,
                           this overall decline in market-dominant revenue reflects the long-term
                           downward trend starting in fiscal year 2007. At the same time, USPS
                           reported that the decline in market-dominant revenue during 2020 was a
                           result of significantly lower mail volume for these products. 33




                           31While preliminary injunctions often apply until the respective court reaches a final
                           judgment, some of these injunctions appear to have been specifically limited to the
                           November election. See, for example, Jones v. USPS, No. 20-cv-6516, 2020 WL
                           5627002, at *28 (S.D.N.Y. 2020) (referencing a November end-date for the injunctive
                           order that USPS approve overtime). USPS settled one of the cases by agreeing to
                           postpone operational changes until after the November election. Joint Stipulation to Stay
                           Case in Light of Settlement Agreement, at *4, Bullock v. USPS, No. 20-cv-00079 (D. Mont.
                           2020) (referencing USPS Guidance “making clear that the operational changes . . . have
                           been and will be resolved until after the 2020 November Election”). Plaintiffs voluntarily
                           dismissed some of the other cases, such as Washington v. Trump, after the elections.
                           32As stated above, we did not include USPS’s international mail products in our analysis.
                           However, USPS’s net loss figure includes revenue from international mail products and
                           interest income. Revenue from international mail products and interest income accounted
                           for about $2.4 billion and $60 million, respectively, in 2020.
                           33USPS, 2020 Report on Form 10-K (Washington, D.C.: Nov. 13, 2020).




                           Page 15                                          GAO-21-261 USPS Changes since COVID-19
Figure 5: Total Market-Dominant Products’ Revenue by Month, 2019 and 2020




Note: Market-dominant mail includes products such as First-Class Mail, Marketing Mail, Periodicals,
Package Services and Special Services.


USPS’s competitive product revenue increased by about $8.4 billion in
2020 compared to 2019 (see fig. 6). Even though competitive products
are a much smaller percentage of USPS’s total mail volume than its
market-dominant products, this increase in revenue more than offset the
decrease in revenue of its market-dominant products. USPS reported that
higher competitive product revenue reflected more e-commerce packages
sent during the pandemic, as well as USPS price increases implemented
in January 2020 and a temporary price increase from October 18 to
December 27, 2020 for certain competitive products. While competitive
product revenue increased, as noted earlier, USPS also reported that
costs to provide these products (e.g., packages) are greater as they are
more labor-intensive. Therefore, according to USPS, competitive products
are not as profitable as some market-dominant products (e.g., letters). 34




34USPS, 2020 Report on Form 10-K.




Page 16                                              GAO-21-261 USPS Changes since COVID-19
                       Figure 6: USPS’s Total Revenue from Competitive Products by Month, 2019 and
                       2020




                       Note: Competitive products consist of mostly packages, but also of other products such as express
                       letters. We excluded international mail from our analysis.


                       USPS reported that in the long term, it does not expect that the growth in
                       revenues associated with increases in competitive products’ volume will
                       continue to offset revenue losses in other mail services. 35 As discussed
                       above, USPS has projected that market-dominant volume, which
                       accounted for about 55 percent of USPS’s total revenue in 2020, will
                       continue to decline. USPS based its projection on the continuing
                       migration from mail to electronic communication. This trend has been
                       magnified by the effects of COVID-19 on mailer and consumer demand.

USPS’s 2020 Expenses   As we found in May 2020, USPS’s poor financial condition is due to
Increased More than    expenses increasing faster than revenue. Since fiscal year 2007, USPS
                       has reported 14 straight fiscal years of net losses. 36 USPS’s $4.3 billion
Revenue
                       35USPS, 2020 Report on Form 10-K.

                       36GAO-20-385. USPS’s net loss for fiscal year in 2020 was $9.2 billion, bringing USPS’s
                       total net loss from fiscal year 2007 through fiscal year 2020 to $87 billion.




                       Page 17                                             GAO-21-261 USPS Changes since COVID-19
increase in revenue in 2020 was more than offset by its $4.4 billion
increase in expenses—resulting in an increase of $100 million in USPS’s
net loss for 2020 ($8.1 billion) over 2019’s net loss ($8 billion)(see table
1).

Table 1: USPS’s Revenue, Expenses, and Net Loss, 2020 Compared to 2019

                                            2020                                 Difference       Percentage
                                     (dollars in                              between 2020      change, 2020
                                       billions)               2019               and 2019          and 2019
 Revenue                                      75.3              71.0                     +4.3            +6.1
 Expenses                                     83.4              79.0                     +4.4            +5.7
 Net Income (Loss)                            (8.1)            (8.0)                     -0.1            +1.0
Source: GAO analysis of U.S. Postal Service (USPS) data. | GAO-21-261

Notes: Numbers may not equate due to rounding. These figures include international revenue and
interest revenue and expenses. USPS’s expenses include required payments for retiree health care
and pensions that USPS did not make.


According to USPS, the increase in total expenses in 2020 was driven by
a rise in certain operating expenses. For example, cost increases were
greater than in 2019 for USPS’s three largest expense categories:
personnel compensation and benefits; transportation (i.e., the costs of
contracts to move mail between USPS facilities); and supplies and
services (see table 2). 37 USPS officials noted that some expenses
decreased during 2020, such as for fuel and vehicle maintenance.

Table 2: Selected and Total USPS Expenses for 2020 and 2019

                                                               2020                       Percentage Change,
 Expense Category                             (dollars in billions)              2019            2020 to 2019
 Personnel Compensation                                             64.1          60.6                   +5.8
 and Benefits
 Transportation                                                         9.0        8.2                   +9.5
 Supplies and Services                                                  3.1        2.8                  +10.6
 All Other Expenses                                                     7.2        7.3                   -1.8
 (including interest)
 Total Expenses                                                     83.4          79.0                   +5.7
Source: GAO analysis of U.S. Postal Service (USPS) data. | GAO-21-261


37USPS’s total personnel compensation and benefits expenses represented about 77
percent, transportation about 10 percent, and supplies and services about 4 percent of
USPS’s total expenses in 2020. Personnel compensation and benefits consists of
expenses such as compensation, current employee and retiree health benefits, retirement
benefits, worker’s compensation and other items.




Page 18                                                           GAO-21-261 USPS Changes since COVID-19
                           Note: Numbers may not equate due to rounding. USPS’s total personnel compensation and benefits
                           expenses include required payments for retiree health care and pensions that USPS did not make.


                           According to USPS, some of its increase in expenses were also due to
                           the COVID-19 pandemic. USPS stated that under the CARES Act as
                           amended, it has received about $7.2 billion for operating expenses
                           needed due to the COVID-19 emergency from March to December 2020.
                           These expenses included categories such as overtime, hiring and training
                           costs of new employees, absenteeism, and costs of sanitizing work
                           areas. For example, USPS reported an estimated $763 million in
                           expenses as a direct result of COVID-19 for certain expenses such as:

                           •   COVID-19 Leave. By the end of December 2020, increased use of
                               leave and the additional paid leave provided by the Families First
                               Coronavirus Response Act (FFCRA) had cost USPS a total of about
                               $433 million. 38
                           •   Supplies and Services. Supplies and services expenses increased by
                               about $257 million largely due to personal protective equipment and
                               cleaning supplies procured in response to the COVID-19 pandemic.
                           •   Transportation. USPS officials stated that transportation costs had
                               increased by about $73 million due to increased costs of air and
                               highway mail transportation contract costs resulting from a reduction
                               in commercial air service during the pandemic and the increase in
                               package volume.
USPS Has Taken Some        As discussed above, USPS has taken actions that were intended to
Steps to Address the Gap   address the growing gap between revenues and expenses by reducing
                           costs. USPS released a new strategic plan in March 2021 that includes
between Revenues and
Expenses, but
Congressional Action
Remains Essential to
Transforming USPS



                           38The FFCRA was enacted in March 2020 (Pub. L. No. 116-127, 134 Stat. 178 (2020).
                           FFCRA authorized new paid sick leave that may be used by an employee in COVID-19
                           situations for themselves, or to care for others such as sick family members, as well as
                           Family and Medical Leave Act-protected unpaid and paid leave if a school/child care is
                           closed.




                           Page 19                                            GAO-21-261 USPS Changes since COVID-19
more cost-reduction measures as well. 39 To increase revenue, USPS also
imposed a time-limited price increase on some competitive products for
its traditionally busy holiday period from October 18 through December
27, 2020. 40

In addition to these changes, USPS continued to forego making certain
required payments for retiree health care and pensions 41 and reported
that it would continue to forego these payments, to ensure that it can
maintain its normal operations to provide postal service. 42 As a result,
despite USPS’s net loss of $8.1 billion in 2020, USPS’s cash balance
increased from about $9 billion at the end of March 2020 to about $15.2
billion at the end of December 2020, in large part due to not making these
required payments and by borrowing more from USPS’s existing debt
authority with the federal government.

Although USPS preserved enough cash and obtained increased loan
capacity to continue to provide daily postal service during a time of
significant change, the trends we previously identified in USPS’s mail
volume revenue and expenses that make USPS’s business model
unsustainable have continued. We found in May 2020 that the steps
USPS had taken to date were not sufficient to restore its financial
sustainability without congressional action. We concluded that without
congressional action, USPS’s financial problems would only worsen,
putting its mission at greater risk and potentially limiting Congress’s ability



39USPS, Delivering For America: Our Vision and Ten-Year Plan to Achieve Financial
Sustainability and Service Excellence (Washington, D.C.: Mar. 23, 2021). USPS also
continued to call for legislative and regulatory changes, such as eliminating the price cap
for market-dominant products and integrating USPS’s retiree health care benefits with
Medicare. We reported in August 2018 that increased postal retiree participation in
Medicare would decrease USPS’s costs but increase Medicare’s costs, according to
analyses by the Congressional Budget Office. GAO, Postal Retiree Health Benefits:
Unsustainable Finances Need to Be Addressed, GAO-18-602 (Washington, D.C.: Aug. 31,
2018).
40USPS stated that it earned $361.8 million from this limited price increase.

41USPS did not make about $7.8 billion in required payments for retiree health benefits
and pensions in fiscal year 2020. USPS has not made its required prefunding payments
for retiree health benefits since fiscal year 2012. USPS’s total unpaid required payments
for retiree health benefits and pensions for fiscal years 2012 through 2020 now total $63.3
billion. USPS, FY2020 Report on Form 10-K. The missed payments for fiscal years 2020
and 2019 are included in USPS’s expenses in tables 1 and 2 above.
42USPS, FY2020 Report on Form 10-K.




Page 20                                          GAO-21-261 USPS Changes since COVID-19
                  to make the most appropriate or sustainable policy decisions. As a result,
                  we urged Congress to consider determining:

                  •   the level of universal postal service the nation requires;
                  •   the extent to which USPS should be financially self-sustaining; and
                  •   the most appropriate institutional structure for USPS.
                  The further deterioration of USPS’s financial position since the start of the
                  COVID-19 pandemic makes the need for congressional action to
                  transform USPS’s business model even more urgent.

                  We provided a draft of this report to USPS for comment. USPS provided
Agency Comments   a written response, which is reproduced in appendix I. USPS found that
                  the report correctly reflected its current financial and operational situation.
                  USPS also provided technical comments, which we incorporated as
                  appropriate.

                  We are sending copies of this report to the appropriate congressional
                  committees, the Postmaster General, and other interested parties. In
                  addition, the report is available at no charge on the GAO website at
                  https://www.gao.gov.

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




                  Jill Naamane, Acting Director
                  Physical Infrastructure Issues




                  Page 21                                   GAO-21-261 USPS Changes since COVID-19
List of Committees

The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate

The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Gary C. Peters
Chair
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives


Page 22                             GAO-21-261 USPS Changes since COVID-19
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives

The Honorable Richard Neal
Chair
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives




Page 23                             GAO-21-261 USPS Changes since COVID-19
Appendix I: Comments from the United
             Appendix I: Comments from the United States
             Postal Service


States Postal Service




             Page 24                                       GAO-21-261 USPS Changes since COVID-19
Appendix I: Comments from the United States
Postal Service




Page 25                                       GAO-21-261 USPS Changes since COVID-19
Appendix II: GAO Contact and Staff
                  Appendix II: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Jill Naamane, (202) 512-2834 or naamanej@gao.gov.
GAO Contact
                  In addition to the individual named above, Derrick Collins (Assistant
Staff             Director); Greg Hanna (Analyst-in-Charge); Amy Abramowitz; Geoff
Acknowledgments   Hamilton; Delwen Jones; Serena Lo; Steven Rabinowitz; Malika Rice;
                  Mike Soressi; and Laurel Voloder made key contributions to this report.




(104435)
                  Page 26                                GAO-21-261 USPS Changes since COVID-19
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