This is the accessible text file for GAO report number GAO-03-267 
entitled 'U.S. Postal Service: More Consistent Implementation of 
Policies and Procedures for Cash Security Needed' which was released on 
December 02, 2002.



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Report to the Chairman, Committee on Government Reform, House of 

Representatives:



United States General Accounting Office:



GAO:



November 2002:



U.S. Postal Service:



More Consistent Implementation of Policies and Procedures for Cash 

Security Needed:



GAO-03-267:



Contents:



Letter:



Results in Brief:



Background:



Scope and Methodology:



Established Remittance Control Procedures Are Not Consistently 

Followed:



Background Checks Not Updated Before Employees Process Remittances:



Training May Not Be Adequate:



Recent Service Efforts to Improve Remittance Security:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Appendix I: GAO Contacts and Staff Acknowledgments:



GAO Contacts:



Acknowledgments:



Abbreviations:



FBI: Federal Bureau of Investigation:



OIG: Office of Inspector General, U.S. Postal Service:



OPM: Office of Personnel Management:



PPO: Postal Police Officer:



November 15, 2002:



The Honorable Dan Burton

Chairman, Committee on Government Reform

House of Representatives:



Dear Mr. Chairman:



In fiscal year 2001, the United States Postal Service (the Service) 

reported that it lost about $6.3 million in remittances (cash and 

checks) to robberies, internal theft, and mishandling.[Footnote 1] One 

particular loss--a June 2001 theft of over $3.2 million from a Phoenix, 

AZ, postal facility by a career Service employee--received considerable 

media attention. Pursuant to your request, we agreed to review Service 

policies and procedures for the security of remittances by addressing 

the following questions:



* Does the Service have reasonable physical controls and security to 

safeguard its remittances?



* Does the Service have policies for conducting background checks of 

employees who process remittances?



* Does the Service provide training to its employees who process 

remittances?:



The Service considers the specific policies and procedures for securing 

and transferring its remittances from postal retail facilities to banks 

as law enforcement sensitive information. Therefore, these policies and 

procedures are not described or discussed in detail in this report. 

Similarly, for the same reason, our specific observations and 

information that the United States Postal Inspection Service included 

in its reports we reviewed relating to instances where Service policies 

and procedures were not followed are described only in general terms in 

this report.



Results in Brief:



The Service has policies and procedures for physically controlling and 

securing remittances. These include a number of control activities 

that, if properly implemented, would be effective in helping to 

safeguard vulnerable assets, such as cash. The control activities 

include, among others, requirements for continuous individual 

accountability of remittances. However, Service management does not 

always provide appropriate oversight of these activities and Service 

employees do not always follow the Service’s policies, procedures, and 

activities for controlling and physically securing remittances. For 

example, the Postal Inspection Service found that the June 2001 

employee theft of remittances in Phoenix occurred and was not promptly 

identified and reported because established control procedures were not 

followed. This occurred even though the previous failure of employees 

to follow established policies and procedures had been brought to the 

attention of the facility’s management by the Postal Inspection Service 

prior to the incident. Further, at selected postal facilities, we 

observed that Service policies and procedures for controlling and 

securing remittances were not always followed, and accountability for 

remittances was not always maintained. Over the last few years, the 

Postal Inspection Service has made similar observations at numerous 

postal facilities throughout the country.



The Service requires a background check as part of a suitability test 

for all prospective new employees. The background check includes a 

review of any criminal or military records, a fingerprint check by the 

Federal Bureau of Investigation (FBI), and a drug screening. Although 

only career employees are allowed to process remittances, there is no 

requirement to update the background checks of these employees 

regardless of how much time has elapsed since the initial check was 

performed.



The Service’s training for postal employees who process remittances 

includes both on-the-job training and the use of self-paced training 

and development manuals related to the control and security of 

remittances. However, the Service’s training manuals have not been 

appropriately updated, and in August 2001, the Service’s Chief Postal 

Inspector cited the lack of training as a possible condition leading to 

the Postal Service’s remittance losses.



The Service has recently initiated efforts to strengthen security for 

remittances. However, until these policies and procedures are 

effectively implemented, the Service’s remittances remain at risk. 

Accordingly, we are making recommendations to the Postmaster General 

concerning the need to (1) more rigorously reinforce to managers and 

employees the importance of and need to follow Service policies and 

procedures for controlling and physically securing remittances and hold 

managers and employees accountable for following the policies and 

procedures, (2) reassess its policies for updating background checks on 

employees selected to process remittances, and (3) update its training 

manuals and determine whether additional training on the control and 

security of remittances is needed.



The Service agreed with our recommendations and stated that it is 

already well on the way to implementing procedures that will fully 

address them. It said it had some legal and cost concerns relating to 

updating background checks of career employees and said that it would 

need to consider these issues as it studies this matter. We agree that 

the issues the Service identified are valid concerns that should be 

considered.



Background:



Traditionally, the Service’s local post offices deposited their daily 

remittances of coin, cash, and checks in accounts with local banks. 

Before 1997, according to the Service’s Assistant Treasurer for 

Banking, the thousands of individual retail postal units deposited 

their daily remittances in some 9,300 bank accounts with 5,500 banks 

across the country. In 1997, to help reduce banking costs and improve 

funds availability, the Postal Service implemented consolidated 

banking--a Service-wide process whereby the daily remittances from the 

Service’s retail postal facilities are consolidated and transferred by 

armed bank couriers to a relatively few commercial banks for deposit.



The Postal Inspection Service, one of the nation’s oldest law 

enforcement agencies, is the Postal Service’s law enforcement arm. With 

a force of about 1,400 uniformed Postal Police Officers (PPOs), over 

1,900 postal inspectors, and five forensic crime laboratories, the 

Postal Inspection Service is responsible for ensuring the safety and 

security of postal employees, facilities, and assets. PPOs provide 

security at postal facilities where the Postal Inspection Service has 

determined that risk and vulnerability demonstrate a need for this 

level of security. Postal inspectors help enforce and investigate 

infractions of over 200 federal laws applicable to crimes that 

adversely affect or involve fraudulent use of the U.S. mail. Matters 

investigated include criminal incidents, such as mail theft, robberies, 

burglaries, and embezzlement; and the criminal use of the mail for 

money laundering, fraud, child exploitation, and the movement of 

illegal drugs.



The Postal Inspection Service periodically performs reviews of 

remittance-processing procedures at selected individual postal 

facilities or at a cross section of facilities within a postal 

district. These reviews are security reviews focused primarily on 

compliance with the applicable policies and procedures to help prevent 

instances of mishandling and losses. Results of these reviews are 

reported to the appropriate postal district manager, and districtwide 

review results are reported to the appropriate postal area manager. 

According to the Postal Inspection Service, although its reports 

apprise postal officials of its findings and recommend corrective 

action(s), district and area managers are not required to implement 

these recommendations.



Scope and Methodology:



To meet our objectives, we obtained and reviewed Service policies and 

procedures for controlling and securing remittances and for requiring 

background checks and training for employees who work with remittances. 

We used the Standards for Internal Control in the Federal Government, 

as well as the Internal Control Management and Evaluation 

Tool,[Footnote 2] to help assess the Service’s policies and procedures. 

We also obtained and reviewed applicable training manuals, orders, 

directives, and handbooks. Also, for each of our objectives, we 

discussed the applicable policies, procedures, and practices with 

appropriate Service officials, including headquarters officials in 

Postal Operations, Corporate Accounting, Corporate Treasury, Human 

Resources, Network Operations Management, and the Postal Inspection 

Service. Further, we had similar discussions with postal facility 

managers, supervisors, employees who process remittances, and Postal 

Inspection Service inspectors in the various field locations we 

visited.



We did not review all aspects of the Service’s internal controls or its 

systems for accounting for remittances. For example, we did not 

evaluate the Service’s assessment of the risks that it faces from both 

internal and external sources or perform a comprehensive assessment of 

the Service’s security for its post offices or processing centers.



To help determine how well the Service’s policies, procedures, and 

control activities are working, we obtained and reviewed Postal 

Inspection Service reports of investigations and other Postal 

Inspection Service reports dating back to fiscal year 1999. We 

judgmentally selected reports for review on the basis of our 

discussions with Postal Inspection Service officials about the 

remittance loss history of the various postal districts and to provide 

geographic dispersion. We also visited Service facilities at six 

locations--three in Arizona; one in Texas; one in Maryland; and one in 

Washington, D.C.--to observe Service policies and procedures in 

practice.[Footnote 3] The facilities in Arizona were chosen because 

they were at or near the location where a postal employee stole a 

substantial amount of remittances in June 2001. The other facilities 

were chosen to provide geographic dispersion for our observations. We 

performed our work between July 2001 and November 2002 in accordance 

with generally accepted government auditing standards. We obtained 

comments on a draft of this report from the Postal Service.



Established Remittance Control Procedures Are Not Consistently 

Followed:



The Service’s policies and procedures include a number of remittance 

control activities that, if properly implemented, would help prevent 

remittance losses. However, Service employees are not always following 

established policies and procedures, and Postal Service management does 

not appear to have taken effective actions to address this problem.



Service Policies and Procedures for Controlling and Securing 

Remittances:



The GAO-issued Standards for Internal Control in the Federal Government 

defines the minimum level of acceptable internal controls in 

government. Although the standards provide a general framework, the 

management of each agency is responsible for developing the detailed 

policies, procedures, and practices to fit its operations. For example, 

one of the standards for internal control states that internal control 

activities--the policies, procedures, techniques, and mechanisms that 

enforce management directives--should be effective and efficient in 

accomplishing the agency’s control objectives. A key control activity 

includes establishing physical control to secure and safeguard 

vulnerable assets, including limiting access to such assets and 

ensuring that they are periodically counted and compared with control 

records. Thus, effective control activities at the Service would be 

expected to include such reasonable activities as are necessary to 

physically secure, safeguard, and account for its remittances.



Service polices and procedures incorporate a number of activities for 

controlling and securing remittances that we believe, if effectively 

implemented, would help prevent loss of these assets. The Service’s 

control activities or procedures include, among others, the requirement 

that there is to be continuous individual accountability of 

remittances, including hand-to-hand exchanges at all transfers. In 

addition, employees are to document the progress of remittances moving 

through the system to banks and notify the Postal Inspection Service 

immediately when discrepancies or losses are noted. Finally, postal 

district accounting personnel are to reconcile the electronic record of 

each post office’s daily sales with the bank information showing 

remittance deposits received from each post office.



Service Policies and Procedures for Controlling and Securing 

Remittances Are Not Always Followed:



Our observations and the findings of the Postal Inspection Service show 

that many of these policies, procedures, and activities for controlling 

and securing remittances are not always followed or practiced by 

employees at numerous postal facilities across the country. In 

addition, even though the Postal Inspection Service has brought this 

issue to the attention of Service management over a period of several 

years, it appears that the Service has not taken effective actions to 

address the problem.



In July 2002, we visited three locations in the Service’s Arizona 

district. At each location, Postal Inspection Service officials 

accompanied us. The officials agreed with our observations that at each 

of these locations, Service employees carried out a number of practices 

that are inconsistent with Service policies and procedures for 

controlling and securing remittances.



Each year, the Postal Inspection Service reviews control and security 

procedures at selected postal districts and facilities throughout the 

country to identify opportunities for security improvements and to 

measure and improve compliance with the Service’s policies and 

procedures. A primary goal of these reviews is to help protect 

remittances from mishandling, loss, and theft. The findings from these 

reviews are reported to Service management at the respective districts. 

We reviewed a number of Postal Inspection Service reports on the 

results of these reviews, which were completed in fiscal years 1999, 

2000, 2001, and 2002.



A May 1999 Postal Inspection Service report on performance audits 

performed at various postal facilities in the Service’s Northeast Area 

found that a number of policies and procedures for processing and 

securing remittances were not being followed. Specifically, the Postal 

Inspection Service found that individual accountability for remittances 

was not being maintained as required by Service policy and procedures. 

Also, in a February 1999 performance audit report, the Postal 

Inspection Service found that at a California postal district, postal 

personnel were handling remittances without signing for and accepting 

accountability for them.



Postal Inspection Service reports of districtwide reviews conducted 

during May through July 2000 in six districts in the Service’s Western 

Area disclosed that local post offices in each of these districts often 

failed to take the appropriate actions required for ensuring that 

remittances could always be accounted for. For example, remittances 

were sometimes left unattended and unsecured. Also, certain restricted 

access areas were not locked, and unauthorized personnel were permitted 

entry.



In August 2001, the Postal Inspection Service reviewed remittance-

handling practices at 25 post offices in a district in the Service’s 

Southeast Area. Its report on these reviews stated that losses due to 

internal causes (employee theft and mishandling) in the district during 

fiscal year 2001 to date totaled about $150,000, an increase of 375 

percent over the previous year’s total. The report said that these 

losses were attributable to practices in the district that failed to 

establish individual accountability for remittances and to properly 

secure them.



During the period from early September through late December of 2001, 

the Postal Inspection Service reported visiting over 2,000 postal 

facilities nationwide and observed 252 lapses of remittance security. 

Its inspectors also found lapses in individual accountability of 

remittances and instances of unauthorized access into postal facilities 

through unsecured doors, including doors that were propped open and 

left unattended.



Service Management Has Not Effectively Addressed Weaknesses in 

Remittance Controls:



An important internal control standard established in the Standards for 

Internal Control in the Federal Government pertains to the control 

environment. It states that management and employees should establish 

and maintain an environment throughout the organization that sets a 

positive and supportive attitude toward internal control and 

conscientious management. However, it appears that even though 

significant weaknesses in the Service’s controls over its remittances 

have been brought to the attention of Service management by the Postal 

Inspection Service numerous times over the last few years, Postal 

Service management has not taken effective action to address these 

weaknesses--leaving its remittances vulnerable to theft or loss. For 

example, during our visit to the Phoenix mail processing facility, a 

manager acknowledged that there had been deficiencies and that 

compliance with procedures had probably been lax for several years.



In August 2001, after the theft in Phoenix, the Chief Postal Inspector, 

who is the head of the Postal Inspection Service, wrote to the Postal 

Service’s Chief Operating Officer about the Postal Inspection Service’s 

concern over continuing problems with remittances. The Chief Postal 

Inspector pointed out that losses had begun to increase in late fiscal 

year 1999 and were continuing to increase. He stated that since 1997, 

the Postal Inspection Service has frequently brought proper procedures 

and policy to the attention of postal management through its 

investigations and other reviews, and the intention of management to 

adopt the recommendations of the Postal Inspection Service appears 

genuine. He stated, however, that the implementation of proper 

procedures and ongoing security of remittances continue to erode and 

that causes could include the following:



* Postal Service management has been unable or unwilling to comply with 

procedures that will properly secure remittances. Some postal district 

managers have refused to comply with certain procedures to protect 

remittances. (In our discussions with the Postal Inspection Service, we 

were told that some postal district managers balked at implementing 

certain remittance handling procedures because they believed that the 

procedures would result in additional costs that would have to be 

absorbed by each Service district.):



* Other postal areas have not implemented Postal Inspection Service 

recommendations to improve the security of remittances. For example, in 

2000 a report was issued to the manager of the Phoenix facility that 

detailed security issues that, had they been corrected, the Postal 

Inspection Service believes could have deterred or prevented the June 

2001 loss of over $3 million.



* Historically, employees have not been held accountable for 

mishandling and subsequently losing remittances. For example, in the 

Postal Inspection Service’s Mid-Atlantic Division, an employee left 

remittances in a 24-hour lobby after the post office had closed. The 

remittances were stolen, but no disciplinary action was initiated 

against the employee.



* Employees may not be trained properly in processing remittances. For 

example, in a Washington, D.C., postal facility, a training course for 

clerks was discontinued in 1986. Although a reliable Service-wide 

sample has not been taken, the Postal Inspection Service sees this lack 

of training as a common inadequacy throughout the Postal Service. 

Certain reference material has not been updated since 1982.



* During a postal reorganization, a key supervisor position was 

abolished, leaving employees without direct supervision.



* The security of remittances or prevention of losses was never an 

established goal for postal management, unlike overnight and 2-to 3-day 

mail delivery scores. Therefore, compliance is not a priority. He said 

that a measurable security goal that includes the security of 

remittances should be considered.



He closed by stating that the Postal Inspection Service is committed to 

assisting the Postal Service through aggressive remittance loss and 

other investigations and initiatives. He said that the Postal 

Inspection Service recognizes the risk this matter poses to Service 

employees and to the Service, and he wants to ensure this risk is 

minimized through proper remittance handling procedures.



In December 2001, the Service’s Chief Operating Officer issued a 

memorandum to the Service’s Area Vice Presidents; District Managers; 

Processing and Distribution Center Plant Managers; and the Manager, 

Capital Metro Operations, stating that the Postal Inspection Service’s 

recent oversight work had repeatedly found that remittances were not 

always being controlled and protected as required. He said that this 

was not an issue of incidental oversight, but rather a condition in 

which “basic work processes were either not in place, or were being 

routinely compromised.” He concluded by pointing out that postmasters 

and postal employees are personally responsible for depredation or loss 

of remittances due to negligence or disregard of instructions and 

asking the addressees to ensure that appropriate controls are in place 

throughout their respective operations.



Background Checks Not Updated Before Employees Process Remittances:



The Service performs background checks for all prospective employees as 

part of a suitability test to identify applicants who possess the 

necessary skills, abilities, and qualifications to perform specific 

jobs in the Postal Service. The Service does not, however, require 

updated background checks for employees who are selected to process 

remittances.



The employee suitability test is a two-part review. The first part 

includes an examination, which tests memorization and provides a 

behavioral rating; veterans’ preference check; criminal records check; 

military records review; drug screen; driving record review; and 

interview.



The second part of the review takes place after the job offer and 

includes a medical assessment, fingerprint and Office of Personnel 

Management (OPM) Special Agency Check, and an evaluation that places 

the employee into a 90-day probationary period during which he/she 

receives orientation and whatever training is needed.



Our review of summary documentation on remittance losses during 2001 

and discussion with Postal Inspection Service officials did not 

indicate that updated background checks of employees selected to 

process remittances would have prevented any losses that have occurred. 

However, because employees’ background checks could have been performed 

years earlier, when they were initially hired, additional or updated 

background checks for employees before they are allowed to process 

remittances might reduce the risk of theft to an asset as vulnerable as 

cash.



In our discussions of this issue with Postal Service officials, they 

pointed out that the Service had legal concerns about its authority to 

unilaterally impose a requirement for updated employee background 

checks on bargaining unit employees and that such a requirement would 

be subject to collective bargaining with various postal employee 

unions. They also said that certain employment law issues would have to 

be considered, such as the permissibility of drug testing and the use 

of arrest and conviction information. We agree that these types of 

issues would need to be considered in any reassessment the Service 

would do in connection with requiring updated background checks for 

employees processing remittances. However, we believe that such a 

reassessment is warranted given the higher risk levels associated with 

responsibilities that involve processing remittances. Furthermore, if 

the Service determines that requiring employees to undergo periodic 

background check updates is subject to the collective bargaining 

process, the issue could be raised by the Service during negotiation of 

the next collective bargaining agreement.



Training May Not Be Adequate:



The Service provides training to its employees who process remittances. 

However, the training materials for clerks and supervisors are 

outdated. In addition, the Postal Inspection Service has indicated that 

a lack of training could be contributing to remittance losses.



Postal career employees who apply for the job are selected to process 

remittances on the basis of their seniority. There are no special 

skills or abilities required for selection other than those required of 

a mail distribution clerk. Those who are selected are to be trained in 

the specific roles they will be performing with remittances. Unit 

supervisors are responsible for ensuring that the employees in their 

units are trained. The training includes on-the-job training as well as 

a requirement that the employees complete self-paced training manuals 

pertaining to their specific responsibilities.



Service training manuals have not been updated to address the 

processing of remittances. For example, one of the Service’s principal 

policy handbooks for operations that include processing remittances was 

updated in 1997; however, the training manual that addresses certain 

remittance processing procedures has not been similarly updated.



Although we cannot say that the failure of employees to follow Service 

policies and procedures for securing remittances that we observed was 

the result of inadequate or incomplete training, the Chief Postal 

Inspector stated in his letter to the Postal Service’ Chief Operating 

Officer mentioned earlier that a lack of employee training in proper 

handling of remittances was among the conditions contributing to 

remittance losses.



Recent Service Efforts to Improve Remittance Security:



Within the last year, the Service established a team to develop a 

standard operating plan that provides detailed policies and procedures 

for processing remittances. According to the Service, the draft plan 

was recently completed, and the plan should be approved by, and 

implementation should begin in, November 2002. The plan is to become 

the national standard for processing remittances through the Service. 

The Service’s new policies and procedures do not address the issue of 

background checks for employees.



According to the Service, Area managers will have responsibility for 

ensuring that field management train and hold accountable employees who 

process remittances, and all deviations from the plan are to be 

reported and approved by Area management. All approved deviations are 

to be submitted to Service headquarters. In addition, according to the 

Service, it is in the process of redesigning training for employees who 

process remittances. It said that the new training manuals and 

handbooks would incorporate the new policies and procedures for 

processing remittances. Finally, according to the Service, the 

Service’s Chief Operating Officer will disseminate the new plan through 

formal channels of the organization to the Area Vice Presidents, who 

will be instructed in their responsibility for providing the proper 

training in policies and procedures to employees who process 

remittances. In addition, the message to the Area Vice Presidents is to 

be reinforced by having employees watch a recently developed video that 

pertains to their areas of responsibility, and all training is to be 

documented by management.



The establishment of these new policies and procedures for processing 

remittances is an important step in the right direction. Also, it is 

particularly encouraging that the Service plans to emphasize management 

accountability for implementing the new policies and procedures. 

However, until these new policies and procedures are finalized and 

address the remittance control problems we have identified, employees 

are trained in how to follow them, and they are effectively 

implemented, the Service’s remittances continue to be at risk.



Conclusions:



The Service has policies and procedures that, if properly implemented, 

would help to control and physically secure its remittances. However, 

the Service’s policies, procedures, and control activities are not 

consistently followed by employees and it appears that Service 

management has not taken effective actions to address the problem. The 

Chief Postal Inspector has cited a lack of (1) training, (2) adequate 

supervision, (3) postal management follow-through, and (4) 

accountability as contributing factors. The Service has not updated its 

relevant training manuals and does not update background checks for 

employees selected to process remittances--thus possibly subjecting the 

Service to increased vulnerability to the theft of its cash. Until 

Service management actively addresses the problems of controlling and 

securing its cash remittances, widely identified throughout the Service 

by the Postal Inspection Service and by us at locations we visited, its 

remittances will continue to be vulnerable to mishandling, loss, and 

theft.



Recommendations for Executive Action:



We recommend that the Postmaster General:



* more rigorously reinforce to managers and employees at facilities 

throughout the Postal Service the importance of following Service 

policies and procedures for controlling and securing remittances;



* hold Service managers and employees accountable for following Service 

policies and procedures for controlling and securing remittances and 

correcting the control problems identified by the Postal Inspection 

Service;



* include adherence to policies and procedures for securing remittances 

and minimizing remittance losses in its organizational goals and 

performance management and pay systems and define and enforce 

supervisory responsibilities to achieve these reinforcement and 

accountability objectives;



* reassess current Service policy of not updating background checks of 

career employees prior to their being selected to process remittances; 

and:



* update applicable training manuals that predate the Service’s 

adoption of its consolidated banking policy and determine whether 

additional training for managers and employees on the Service’s 

policies and procedures for physically controlling and securing 

remittances is needed and, if so, see that such training is developed 

and provided.



Agency Comments and Our Evaluation:



We received written comments on a draft of this report from the Postal 

Service’s Chief Operating Officer. In his comments he stated that the 

Service appreciated the thoroughness of our review and the disclosure 

of some shortfalls in the physical security of postal remittances. He 

said that our findings are extremely serious, and the Service is 

committed to improving the current process. He said that to that end, 

management teams from several departments have already developed 

changes in procedures to address our findings, including improvements 

to the procedures to secure and account for remittances. He said that 

the Service is well on the way to implementing procedures that will 

fully address the recommendations contained in our report. For example, 

he said that the Service is establishing an internal control unit in 

each district office to assess risk and compliance with remittance 

handling as well as other financial and operational policies and 

procedures. He further said that the Area Vice Presidents will be held 

responsible for ensuring that field managers provide training to all 

employees who process remittances.



Specifically regarding our recommendation that the Service reassess its 

current policy of not updating background checks of career employees 

prior to their being assigned to process remittances, he said the 

Service is already in continuing discussion with its General Counsel on 

the matter. He said that the Service has legal concerns about its 

authority to unilaterally require updated background checks on 

bargaining unit employees because such a requirement could be viewed as 

a “term or condition of employment” subject to collective bargaining. 

Also, he said that it would be very costly to periodically recheck the 

thousands of employees who process remittances. He stated that with 

implementation of the new standardized remittance-processing 

procedures, the Service believes that it will have in place 

compensating controls that will be more cost effective than periodic 

background checks.



We agree that all of these issues are important issues for the Service 

to consider as it reassesses its background check policy. If the 

Service determines that requiring periodic updated employee background 

checks is subject to the collective bargaining process, that issue 

could be addressed when the collective bargaining agreement comes up 

for renewal. As to the issue of the cost involved in periodically 

rechecking the backgrounds of thousands of employees, we believe that 

the Service’s reassessment could include considering updating the 

background checks only for employees who process high-value 

remittances. As for the issue of the Service having in place 

compensating controls that will be more cost effective than periodic 

background checks, we plan to do future follow-up work to determine the 

effectiveness of the new standardized remittance-processing procedures 

once they are in place. (Written comments received from the Chief 

Operating Officer are not included in this report because they contain 

information the Service considers law enforcement sensitive.) Other 

Service officials suggested technical changes, including the exclusion 

of information that the Service considers law enforcement sensitive, to 

our draft report. We have made these changes where appropriate.



As agreed with your office, unless you publicly announce the contents 

of this report earlier, we plan no further distribution until 30 days 

from the report date. At that time, we will send copies of this report 

to the Ranking Minority Member of your Committee; the Chairman and 

Ranking Minority Member of the Senate Subcommittee on International 

Security, Proliferation, and Federal Services; the Chairman and Ranking 

Minority Member of the Senate Subcommittee on Treasury and General 

Government; the Chairman and Ranking Minority Member of the House 

Subcommittee on Treasury, Postal Service and General Government; and 

the Postmaster General. We also will make copies available to others 

upon request. In addition, the report will be available at no charge on 

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



Major contributors to this report are acknowledged in appendix I. If 

you have any questions about this report, please contact me on (202) 

512-2834 or at ungarb@gao.gov.



Sincerely yours,



Signed by Bernard L. Ungar:



Director, Physical Infrastructure Issues:



[End of section]



Appendix I: GAO Contacts and Staff Acknowledgments:



GAO Contacts:



Bernard L. Ungar (202) 512-2834

Sherrill H. Johnson (214) 777-5600:



Acknowledgments:



In addition to those individuals named above, Tyrone Griffis, Michael 

J. Fischetti, Gladys Toro, Heather Dunahoo, Walter Vance, and Donna 

Leiss made key contributions to this report.



FOOTNOTES



[1] According to the Service, a substantial portion of these initial 

losses was eventually recovered.



[2] GAO issues standards for internal control in the federal government 

as required by the Federal Managers’ Financial Integrity Act of 1982. 

See 31 U.S.C. 3512(c). GAO first issued the standards in 1983. GAO 

revised the standards and reissued them as Standards for Internal 

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implemented.



[3] The specific locations we visited are not provided because of 

security concerns expressed by the Service.



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