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United States General Accounting Office:



November 13, 2002:



The Honorable Daniel K. Akaka:



Chairman:



The Honorable Thad Cochran:



Ranking Minority Member:



Subcommittee on International Security,



Proliferation, and Federal Services:



Committee on Governmental Affairs:



United States Senate:



Subject: U.S. Postal Service Actions to Improve Its Financial 

Reporting:



Given the vital role of the nation’s postal system and the importance 

of its financial viability, it is imperative that the U.S. Postal 

Service (the Service), the Congress, stakeholders, and the public have 

adequate information available to them to understand the Service’s 

financial situation and assess its progress towards meeting its 

performance goals and planning for its future. During the first part of 

fiscal year 2001, the Service made numerous revisions to its estimated 

net income with little or no public explanation. The Service’s 

financial outlook changed from a $480 million deficit in its fiscal 

year 2001 budget approved in November of 2000, to a $2 billion to $3 

billion deficit projected 3 months later in February 2001. Likewise, at 

the beginning of fiscal year 2002, the Service estimated that it would 

end the year with a $1.35 billion deficit and then stated, in May 2002, 

that its net loss for the year could have reached $4.5 billion. Despite 

the fact that the Service publicly released periodic financial 

information, these significant changes in financial outlook were not 

evident from publicly available information and came as a surprise to 

many stakeholders. More recently, the Service announced the results of 

a new financial analysis that could significantly reduce its Civil 

Service Retirement System (CSRS) pension liability if Congress takes 

related legislative action, which would significantly impact the 

Service’s financial outlook.[Footnote 1] It will be important for the 

Service to keep stakeholders well informed about this issue.



Over the past 2 years, we have been raising concerns and have made 

recommendations regarding the lack of sufficient and timely periodic 

information on the Service’s financial condition and outlook available 

to the public between publications of its audited year-end financial 

statements. This report responds to your July 31, 2002, request that we 

provide periodic updates on several key areas related to the Service’s 

financial outlook, including improvements in financial and performance 

reporting. Specifically, this report discusses the actions taken by the 

Service to address our past recommendations to provide sufficient, more 

timely, and accessible financial reports as well as our assessment of 

the Service’s responses. Our specific recommendations and the Service’s 

initial responses were as follows:



In April 2001, we recommended that the Service provide summary 

financial reports to Congress and the public on a quarterly basis. 

These quarterly reports were to present sufficiently detailed 

information for stakeholders to understand the Service’s current and 

projected financial condition, how its outlook may have changed since 

the previous quarter, and its progress towards achieving its desired 

results.[Footnote 2] In a letter dated June 2001 to congressional 

oversight and appropriation committees and subcommittees, the Service 

agreed to provide additional transparency related to its financial 

condition and said that it would create, and post to its Web site, 

financial statements “similar to what publicly traded enterprises 

provide” and continue this practice quarterly. 



In February 2002, we recommended that the Service provide its monthly 

and quarterly financial reports on its Web site in a user-friendly 

format and in a timelier manner.[Footnote 3] In its February 2002 

comments on a draft of our report, the Service agreed with our 

recommendation and said it was providing financial reports on its Web 

site in a more timely and user-friendly manner.



In September 2002, we reported that the Service should carefully 

reassess its overall accounting treatment for pension and 

postretirement health obligations and reaffirmed a recommendation that 

we previously made to the Service to enhance disclosure of its 

postretirement health benefit obligations in its financial statements. 

In its September 10 letter commenting on the report, the Service stated 

that it planned to address its pension and postretirement health 

obligations in the Management Discussion and Analysis (MD&A) section of 

its annual report.[Footnote 4]



This report on the Service’s financial reporting is based on our 

previous work, review of the Service’s monthly and quarterly financial 

reports from the third quarter of fiscal year 2001 through the third 

quarter of fiscal year 2002, the Service’s written responses to our 

recommendations, and discussions with Service officials about their 

responses to our recommendations. 



We compared the Service’s quarterly financial report for the third 

quarter ending in May 2002, with those of a similar period completed by 

two of its major publicly traded competitors--FedEx and United Parcel 

Service (UPS). Publicly traded companies are subject to Securities and 

Exchange Commission (SEC) quarterly financial reporting 

requirements.[Footnote 5] These quarterly reports include three major 

components: (1) financial statements, which consist of an income 

statement, balance sheet, cash flow statement, and related footnotes; 

(2) management’s discussion and analysis (MD&A) of financial condition 

and results of operations; and (3) quantitative and qualitative 

disclosures about market risk.[Footnote 6] The SEC requires that 

information in quarterly reports from publicly traded entities provide 

investors and others with an accurate understanding of the company’s 

current and prospective financial position and operating results. 

Although the Service is not subject to SEC reporting requirements, the 

purpose of these requirements is similar to the intent of our 

recommendations for improved transparency to enable stakeholders to 

better understand the Service’s financial condition and outlook. 



We conducted our review between July 2002 and September 2002 in 

accordance with generally accepted government auditing standards. We 

requested comments on a draft of this report from the Postal Service, 

and its comments are discussed near the end of this letter and are 

reproduced in enclosure IV.



Results In Brief:



Transparency is particularly important because the Service is the hub 

of a $900 billion mailing industry and is a vital part of the nation’s 

communications network. Its recent financial difficulties have 

accentuated the need for stakeholders--including the Congress, Postal 

Rate Commission (PRC), and mailers--to be well apprised of the 

Service’s financial situation and understand how future operating 

results may be affected by impending events. Further, we recently 

reported that the Service’s financial situation is significantly 

impacted by its pension and postretirement health obligations and that 

the Service should reassess its accounting treatment and reporting of 

these obligations. We also reaffirmed our previous recommendation that 

the Service disclose the full amount of the accrued postretirement 

health benefits earned by its employees and retirees in notes to its 

financial statements. The importance of these obligations was recently 

highlighted when the Service announced the results of a new analysis 

that could significantly reduce its CSRS pension liabilities if 

Congress takes related legislative action. This change would improve 

its overall financial condition and provide opportunities to address 

other key financial issues, such as its postretirement health benefit 

obligations and outstanding debt.



Although the Service has traditionally provided a range of detailed 

financial and operating data to stakeholders throughout the fiscal 

year, its periodic financial reports have not clearly explained changes 

in its financial condition, results of operations, and outlook and have 

not always been readily available to the public. In response to our 

recommendations, the Service committed to provide quarterly financial 

statements “similar to what publicly traded enterprises provide.” The 

Service also has begun posting its quarterly reports on mail volumes 

and revenues, along with its monthly operating statements, to its Web 

site. However, we do not believe that the quarterly financial reports 

provided to date meet the intent of our recommendations, because the 

Service provided only limited analysis and explanations to help 

stakeholders understand what had changed, why it had changed, and how 

these changes affected the Service’s current financial situation and 

expected outlook.



The SEC requires that quarterly reports submitted by publicly traded 

companies include a discussion of material changes in a company’s 

financial condition and results of operations.[Footnote 7] This type of 

discussion is consistent with the intent of our recommendations. When 

we compared the Service’s most recent quarterly report with those of 

two of its publicly traded competitors--FedEx and UPS--we found that 

the Service’s quarterly report generally provided the same basic 

financial statements as did its competitors. However, unlike the 

Service, FedEx and UPS also provided very detailed “Management’s 

Discussion and Analysis” sections in their reports that discussed 

events during the period that may have had a significant impact on the 

financial condition of the company and the outlook for the future, and 

compared the results of operations with the prior year’s results. FedEx 

and UPS’s reports also included explanatory footnotes to the financial 

statements that provided details about significant changes that have 

occurred and material contingencies that were not included in the 

Service’s reports. Further, the Service’s quarterly reports were not 

consistent in format and content, or as available to the public as the 

FedEx and UPS quarterly reports. These changes in subsequent quarterly 

reports and their limited availability made it difficult to make 

comparisons and analyze trends.



In commenting on our draft report, the Service said that it would 

provide additional information in its periodic financial reports to 

improve stakeholder understanding of its business and that it would 

retain the data placed on its Web site for 3 years. The Service also 

cautioned that public discussion of retirement obligations must be 

undertaken with great care, and that it would ensure greater public 

understanding in this area. Due to the magnitude of these costs, the 

potential effects on current and future ratepayers, and the complexity 

of the issues involved in reporting retirement-related obligations, we 

agree that greater public understanding of these obligations is 

important and that the Service can help accomplish this through 

enhanced disclosure in its financial and related statements. The 

Service also said that it makes more financial and operating 

information available than we reflected in our report. We discuss this 

issue near the end of this letter.



Background:



Traditionally, between the annual issuance of its audited year-end 

financial statements, the Service has provided several types of 

periodic financial reports, including its monthly Financial and 

Operating Statements; quarterly Revenue, Piece, and Weight (RPW) 

Reports; and most recently, quarterly financial reports.[Footnote 8] 

The information provided in its periodic monthly operating statements 

and quarterly RPW reports is as follows:



Monthly Financial and Operating Statements: Cover a 4-week period and 

include data that provide an overview of financial results for that 

period, compare results with the budget, compare results with the same 

period in the previous year, and provide year-to-date information. 

These statements also include detailed information on revenues, 

expenses, volumes, and work hours; a balance sheet; a cash flow 

statement; and capital commitments and outlays. Traditionally, these 

reports were sent to stakeholders by request or posted on the PRC’s Web 

site. The Service began posting the most recently completed financial 

and operating statement to its Web site in early 2002.



Quarterly Revenue, Piece, and Weight Reports: Contain information 

relating to the Service’s mail classes and special services. RPW 

reports document the total revenue, pieces, and weights for each mail 

class, subclass, and service for that quarter; in addition, the reports 

provide data on the amount and percentage change from the same period 

in the previous year and year-to-date information. Quarterly RPW 

reports dating back to fiscal year 1999 are currently available on the 

Service’s Web site.



During the fall of 2001, when the Service experienced sharp declines in 

its mail volumes and revenues, and it requested additional 

appropriations from Congress, readily available and detailed 

information on the Service’s changing financial situation was scarce. 

Our February 2002 report noted that from October 2001 to mid-January 

2002, the Service did not publicly release its monthly statements for 

the last accounting period of fiscal year 2001 and for the first three 

accounting periods of fiscal year 2002.[Footnote 9] Although the 

Service issued its annual report for fiscal year 2001 in December 2001, 

it did not publicly release financial results for the fourth quarter of 

fiscal year 2001.[Footnote 10] We reported that more timely 

availability of monthly and quarterly reports, even if they contain 

preliminary data subject to revision, would be useful to improve 

transparency for congressional oversight, the stakeholder community, 

and the public.[Footnote 11]



The Service’s Quarterly Financial Reports Lacked Explanatory 

Information, Consistency, and Public Availability:



Much attention has recently been focused on efforts to improve 

accountability and the usefulness of financial information, in both the 

public and private sectors. One of the key components of the 

President’s Management Agenda is to improve accountability to the 

American people by enhancing the timeliness, usefulness, and 

reliability of financial information provided by federal agencies. 

Likewise, recently enacted legislation--the Sarbanes-Oxley Act of 2002 

(Public Law 107-204, enacted into law on July 30, 2002)--seeks to 

protect investors by improving the accuracy and reliability of 

corporate disclosures made pursuant to the securities laws. Given the 

importance of the Service’s financial condition and outlook, timely, 

accurate, and complete financial information is needed for oversight 

purposes and for stakeholders to better understand the Service’s 

changing financial situation and its potential effect on stakeholders’ 

future plans.



The key limitations of the Service’s quarterly financial reports were 

that they have lacked sufficient analysis and explanation of what has 

changed and why in its financial condition, operating results, and 

outlook. This type of explanatory information is typically provided in 

quarterly financial reports of publicly traded companies and is 

consistent with the intent of our previous recommendations. Further, 

the Service’s quarterly reports have not been consistent in format and 

content or readily available to the public. Sufficient, consistent, and 

accessible financial information helps provide the necessary 

transparency and accountability that are fundamental principles in 

ensuring public confidence in an organization and proper oversight.



The Service’s Quarterly Financial Reports Lacked Sufficient Analysis 

and Explanations:



When we compared the most recent quarterly reports of the Service with 

those of its publicly traded competitors--FedEx and UPS--we found that 

the greatest differences were in the level of analysis and explanation 

provided for changes in financial condition, operating results, and 

outlook.[Footnote 12] This information is generally included in the 

sections titled MD&A in the publicly traded quarterly reports and in 

the notes to the financial statements.



Management’s Discussion and Analysis (MD&A):



The SEC requires publicly traded enterprises to provide a management’s 

discussion and analysis of the entities’ financial condition and 

results of operations, both in quarterly and annual reports. The SEC 

guidance for interim financial reports states:



“the MD&A requirements are intended to provide in one section of a 

filing, material historical and prospective textual disclosure enabling 

investors and other users to assess the financial condition and results 

of operations of the registrant, with particular emphasis on the 

registrant’s prospects for the future . . .. Disclosure is mandatory 

where there is a known trend or uncertainty that is reasonably likely 

to have a material effect on the registrant’s financial condition or 

results of operations. Accordingly, the development of an MD&A should 

begin with management’s identification and evaluation of what 

information, including the potential effects of known trends, 

commitments, events, and uncertainties, is important to providing 

investors and others an accurate understanding of the company’s current 

and prospective financial position and operating results.”[Footnote 13]



In comparing the most recent quarterly reports of the Service, FedEx, 

and UPS, we found that the most notable differences were in the level 

of detail provided in the MD&A sections of the reports.[Footnote 14] 

For example, FedEx and UPS provided explanations in their MD&A sections 

of how they planned to meet their working capital needs for the future; 

causes of changes in revenues and volume, by business line, compared 

with prior periods; and their outlook for the future, including the 

effect of significant events, such as the terrorist-related events of 

the fall of 2001. In contrast, the Service provided minimal 

explanations in these areas. Given the potential impact of these and 

other key factors, such as the timing and amount of proposed rate 

increases, it would be helpful to know how these factors affect the 

Service’s changing year-end outlook. Specific examples of the 

differences between the MD&A section of the Service’s quarterly report 

and those in FedEx’s and UPS’s quarterly reports are provided below. 

The full text of the quarterly reports we compared can be found in 

enclosure I for the Service, enclosure II for FedEx, and enclosure III 

for UPS.



Postal Service discussion of outlook: 



“Volume trends of the past three quarters are expected to continue 

through the fiscal year end in September. Taking the June 30, 2002 rate 

increase into account, volume losses in the 3 to 4 percent range are 

anticipated for the quarter, compared to the same quarter last year.



With expense reductions in excess of $2.5 billion and the rate increase 

on June 30, the estimated net loss for the year will be in the range 

$1.0 billion to $1.5 billion.”



FedEx discussion of outlook: 



“While we believe there is evidence that a modest economic recovery is 

underway, a significant portion of our U.S. domestic express business 

comes from the manufacturing and wholesale sectors, especially in the 

high technology area. Recovery in these sectors is still lagging the 

rest of the economy on a year-over-year basis. Until these key sectors 

experience sustained growth, volumes at FedEx Express are expected to 

remain soft. 



“Our fourth quarter volume outlook for FedEx Express is for U.S. 

domestic average daily package volume to be approximately 2% below last 

year’s fourth quarter and for IP shipments to be down about 1%. In 

addition, our dynamic fuel surcharge at FedEx Express effectively has a 

six-week lag before the surcharge is adjusted for increased fuel 

prices. Therefore, our operating income may be negatively affected 

should the spot price of jet fuel increase significantly in the fourth 

quarter. At FedEx Ground, fourth quarter volume is expected to grow 

about 16% year-over-year.



“We believe our diverse portfolio of services is the key factor to our 

long-term growth. The expansion of our Home Delivery network and 

continued development and cross selling of the diverse FedEx portfolio 

of services, particularly to small-and medium-sized businesses, is 

central to our strategy. Our website, fedex.com, is heavily utilized 

and has helped us reduce costs and improve customer satisfaction. We 

believe that our substantially fixed cost express network 

infrastructure will allow us to realize incremental profits when the 

economy recovers.



“Maintenance costs during the fourth quarter of 2002 are expected to be 

higher due to scheduled maintenance activities. Also, we accrued 

increased variable compensation in the third quarter of 2002 and expect 

to continue to do so in the fourth quarter. Our 2002 incentive 

compensation costs will be sharply reduced for most employees 

(including senior management). However, fourth quarter incentive 

compensation provisions will be higher year-over-year since the prior 

year’s fourth quarter included reversals of incentive compensation that 

had been previously accrued.



“We expect pension and health care costs to continue to increase over 

the near term. Our net pension cost for 2002 will increase by 

approximately $90 million due to lower interest rates and a reduction 

in the value of plan assets. We expect next year’s pension cost to 

increase by $90-100 million based on a continued decline in interest 

rates and a decrease in the expected return on pension plan assets. 

While employee retirement costs continue to rise, our retirement 

programs are well funded, with assets more than sufficient to meet our 

current obligations.”:



UPS excerpts of significant events and outlook: 



“… Due to the events of September 11, 2001, increased security 

requirements for air carriers may be forthcoming; however, we do not 

anticipate that such measures will have a material adverse effect on 

our financial condition, results of operations or liquidity. In 

addition, our insurance premiums have risen and we have taken several 

actions, including self-insuring certain risks, to mitigate the expense 

increase.





        “As of December 31, 2001, we had approximately 232,500 

employees (64% of total employees) employed under a national master 

agreement and various supplemental agreements with local unions 

affiliated with the International Brotherhood of Teamsters 

(“Teamsters”). These agreements run through July 31, 2002. The majority 

of our pilots are employed under a collective bargaining agreement with 

the Independent Pilots Association, which becomes amendable January 1, 

2004. Our airline mechanics are covered by a collective bargaining 

agreement with Teamsters Local 2727, which became amendable on 

August 1, 2001. Members of Teamsters 2727 recently voted down a 

proposed new contract, and negotiations resumed in April 2002 with the 

assistance of the National Mediation Board. In addition, the majority 

of our ground mechanics who are not employed under agreements with the 

Teamsters are employed under collective bargaining agreements with the 

International Association of Machinists and Aerospace Workers. These 

agreements have various expiration dates between July 31, 2002 and 

May 31, 2003.



        “We entered into negotiations with the Teamsters in 

January 2002 for a new national master agreement. It is our desire 

through these discussions to reach an agreement on a new contract prior 

to the end of our current five-year agreement on July 31, 2002. Any 

strike, work stoppage or slowdown that results from our failure to 

reach a timely agreement with the Teamsters, and any change in shipping 

behavior by our customers or potential customers due to perceptions 

that we will not reach a timely agreement with the Teamsters, could 

have a material adverse effect on our financial condition and results 

of operations. We do not, however, anticipate that this will occur.



        “We believe that funds from operations and borrowing programs 

will provide adequate sources of liquidity and capital resources to 

meet our expected long-term needs for the operation of our business, 

including anticipated capital expenditures such as commitments for 

aircraft purchases, through 2009.”:



*	 Postal Service discussion of changes in revenue:



“U.S. domestic package revenue decreased 1.2% compared to last year. 

This decline was driven by a 1.5% reduction in average daily package 

volume which was primarily a result of the continued weakness in the 

U.S. economy. Revenue for our Next Day Air products was also adversely 

affected by a decline in revenue per piece. The decline results in part 

from lower package weights combined with a mix shift favoring letters 

to packages. This reflected what we believe to be continued slowness in 

the manufacturing sector. Conversely, revenue for our Ground products 

increased slightly due to a 3.5 % increase in average revenue per 

piece. This improvement resulted in part from having a rate increase 

that occurred four weeks earlier than compared to the pr”Revenue: 

Revenue of $15.3 billion was 4.9 percent ($796 million) below plan and 

2.0 percent 

($322 million) below Quarter III of last year. Planned revenue growth 

for Quarter III was 3.1 percent.



“Volume in Quarter III was 2.5 percent below last year. We processed 

and delivered 47.1 billion pieces as compared to 48.3 billion pieces 

last year. Revenue loss from the volume decline of 1.2 billion pieces 

was offset through expense reductions.”



*	 UPS excerpts of changes in revenue:



UPS reports its operations in three segments: U.S. domestic package 

operations, international package operations, and nonpackage 

operations, as well as on a consolidated basis. Although the entire 

revenue discussion is included in enclosure III, for brevity purposes, 

only the U.S. domestic package revenue discussion is presented here, as 

follows:



“U.S. domestic package revenue decreased 1.2% compared to last year. 

This decline was driven by a 1.5% reduction in average daily package 

volume which was primarily a result of the continued weakness in the 

U.S. economy. Revenue for our Next Day Air products was also adversely 

affected by a decline in revenue per piece. The decline results in part 

from lower package weights combined with a mix shift favoring letters 

to packages. This reflected what we believe to be continued slowness in 

the manufacturing sector. Conversely, revenue for our Ground products 

increased slightly due to a 3.5% increase in average revenue per piece. 

This improvement resulted in part from having a rate increase that 

occurred four weeks earlier than compared to the prior year.



“On January 7, 2002, we increased rates for standard ground shipments 

an average of 3.5% for commercial deliveries. The ground residential 

charge increased $0.05 to $1.10 over the commercial ground rate, and 

this charge will also be applied to express deliveries in 2002. The 

additional delivery area surcharge, which is added to ground deliveries 

in certain less accessible areas, remained at $1.50. In addition, in 

2002, this charge will also be applied to express deliveries to these 

addresses. Rates for UPS Hundredweight increased 5.9%.



“We also increased rates for UPS Next Day Air, UPS Next Day Air Saver, 

UPS 2nd Day Air, and 3 Day Select an average of 4.0%. The surcharge for 

UPS Next Day Air Early A.M. increased from $27.50 to $28.50. Rates for 

international shipments originating in the United States (Worldwide 

Express, Worldwide Express Plus, UPS Worldwide Expedited and UPS 

International Standard service) increased an average of 3.9%. Rate 

changes for shipments originating outside the U.S. were made throughout 

the past year and varied by geographic market.



“An index-based fuel surcharge, which became effective December 10, 

2001, continued and resets on a monthly basis beginning in 

February 2002. The index-based surcharge is based on the National U.S. 

Average On-Highway Diesel Fuel Prices as reported by the U.S. 

Department of Energy.”:



*	 FedEx discussion of changes in revenue:



FedEx also reports its operations on a consolidated basis and for its 

major business segments: FedEx Express, FedEx Ground, FedEx Freight, 

and other Operations. See enclosure II for the complete tables and 

discussion in each of these areas.



As these examples indicate, the level of explanations in the FedEx and 

UPS quarterly MD&A sections is significantly greater than that provided 

by the Service and helps provide the reader with a better understanding 

not only of what has changed, but why. In comparing the quarterly 

reports, we developed the following questions that we believe would 

provide meaningful information for the Service to include in its 

quarterly report in order to make it a more useful document to its 

stakeholders:



Information regarding the current reporting period:



What were the major changes in revenue, expense, and volume and the 

causes of these changes? How do these results compare with the prior 

period’s?



What major challenges or risks did the Service face during the period, 

and what was done to respond to them?



What were the financial consequences of these occurrences?



Information regarding the upcoming reporting period:



What challenges are expected, by business line? How will they be 

overcome?



What are the financial expectations of the Service as a whole and on a 

business line basis?



What impact will competitors have in the upcoming period?



What significant trends, events, commitments, or uncertainties may 

affect the Service’s expectations?



What are the expected cash requirements and year-end cash position?



What are the expected capital commitments and outlays?



What is the expected net income, and what actions may be taken to 

address specific situations or conditions? Specifically, focus on the 

causes of any losses and specific plans to correct them, if known.



By major business line, what are the major challenges faced, 

accomplishments, and plans to generate revenue, reduce costs, and pay 

down the debt with the U.S. Treasury?



Information regarding long-term outlook:



What are the capital expansion plans, projects, time periods, amounts, 

and return on investment? What are current projects, their status, and 

planned projects? How will these projects be funded and implemented? 

How will changing economic factors affect these plans? What risk 

analysis and contingency plans have been developed? What are the 

changes to the previously reported plans?



What are the plans to remain within the present debt limit and plans to 

pay off long-term debt?



How is the Service prepared to meet its long-term obligations, such as 

funding postretirement health care costs?



While not all of these issues would necessarily be included in every 

report, they do represent items that should be considered for 

disclosure each quarter, giving special consideration to changes that 

have occurred since the annual report was issued. In addition, some of 

these disclosures would most appropriately be made in the footnotes 

accompanying the quarterly financial statements, as are discussed in 

more detail below.



Financial Statement Footnotes:



The Service’s most recent quarterly report provided financial 

statements that were generally comparable to those provided by FedEx 

and UPS in that they included the basic statements of income, balance 

sheet, and cash flow. However, unlike the Service, FedEx and UPS 

provided notes to the quarterly financial statements that included 

explanations on a variety of issues, including changes in accounting 

policies, business segment information, major new commitments and 

contingencies, and supplemental cash flow information. The SEC guidance 

for the content of interim financial statements states, in part, that:



“… disclosure shall be provided where events subsequent to the end of 

the most recent fiscal year have occurred which have a material impact 

on the registrant. Disclosures should encompass, for example, 

significant changes since the end of the most recently completed fiscal 

year in such items as: accounting principles and practices; estimates 

inherent in the preparation of financial statements; status of long-

term contracts; capitalization including significant new borrowings or 

modification of existing financing arrangements; and the reporting 

entity resulting from business combinations or dispositions. 

Notwithstanding the above, where material contingencies exist, 

disclosure of such matters shall be provided even though a significant 

change since year end may not have occurred...”[Footnote 15]



These footnote explanations can greatly enhance the reader’s 

understanding of the quarterly financial statements. For example, in 

their quarterly reports, FedEx and UPS each discuss in detail 

contingent losses due to pending lawsuits, whereas the Service does not 

present similar information on contingent losses, even though such 

contingencies exist.[Footnote 16]



Another area where footnote disclosures would be helpful to the 

understanding of the Service’s quarterly reports is a more detailed 

breakdown of certain key line items in the financial statements. For 

example, the Service includes in its income statement a single line 

item for “revenues,” with no further breakdown provided. UPS also 

reports a single line item for revenue in its income statement, but 

then provides breakdowns of revenue for each of its reporting segments, 

including comparative numbers for the prior quarter. Similarly, details 

of financial statement line items for “other expenses” and “other 

assets” are provided in UPS footnotes, which would also be helpful for 

the Service. “Other liabilities” is also a significant line item on the 

Service’s balance sheet at $41.8 billion, out of $63 billion in total 

liabilities. Within this number is approximately $30 billion related to 

deferred pension liabilities that warrant explanation in the footnotes, 

as well as other liabilities related to employee benefits that are 

included in this line item. Further, we have recommended that the 

Service disclose the amount of postretirement health benefits earned by 

postal employees and retirees in notes to its financial statements to 

provide more complete information about these significant 

obligations.[Footnote 17] In our September 2002 report, we stated that 

the Service should reassess its accounting treatment for both its 

pension and postretirement health obligations and reiterated our 

previous recommendation that the Service should fully disclose its 

postretirement health obligations because they represent a very 

material commitment that affects the future viability of the Service.



An additional useful footnote disclosure for the recent quarterly 

report would have been a discussion of the $675 million in supplemental 

funds appropriated to the Service during fiscal year 2002 to deal with 

expenses relating to the terrorist attacks of September 11 and 

subsequent anthrax attacks.[Footnote 18] These funds are significant 

because the Service, as an entity that is substantially self-financing, 

generally receives only a small annual appropriation. For example, in 

fiscal year 2002, the Service was appropriated only about $77 million 

in its general fiscal year appropriation.[Footnote 19] Further, 

disclosure of the approximately $4 billion projected to be needed over 

the next 5 years for improving the Service’s mail processing systems to 

protect postal employees and the general public from future attacks 

through the mail would have informed the reader of the potentially 

material effect these expenses may have on the Service’s financial 

results in the future.[Footnote 20]



Consideration of the level of detail included in FedEx’s and UPS’s 

quarterly reports, as well as that of other organizations’ reports, may 

be helpful to the Service as it makes enhancements to future quarterly 

reports. We recognize that judgments must be made about the level of 

detail that should be provided in quarterly financial reports and that 

not all quarterly reports will be the same. However, it is clear from 

recently publicized problems in financial reporting that more detailed 

information and transparency are called for by both Congress and the 

public. Such transparency is critical for the Service because of the 

importance of its financial situation and the implications for 

stakeholders in making their own financial plans. These factors help 

support stakeholders’ need for timely, accurate, and complete financial 

information that is provided on a consistent basis.



The Service’s Quarterly Financial Reports Lacked Consistent Format and 

Adequate Availability to the Public:



The first quarterly report that the Service posted to its Web site for 

the third quarter of fiscal year 2001 was a good starting point for 

providing information to Congress and the public. However, changes in 

subsequent quarterly reports and their limited availability made it 

difficult to make comparisons and analyze trends. Table 1 shows 

quarterly financial information provided since our recommendation.



Table 1: The Service’s Quarterly Financial Reports from Third Quarter 

Fiscal Year 2001 through Third Quarter Fiscal Year 2002:



(Continued From Previous Page)



Fiscal quarter; The Service’s actions.



Third quarter, FY 2001; Posted quarterly report to its Web site.



Fourth quarter, FY 2001; Annual report, no quarterly report available.



First quarter, FY 2002; Posted slide presentation to its Web site.



Second quarter, FY 2002; Posted slide presentation to its Web site.



Third quarter, FY 2002; Posted quarterly report to its Web site.



[End of table]



Source: U.S. Postal Service.



The Service stated that its audited fiscal year 2001 annual report 

would serve as its fourth quarter report, which is a common reporting 

practice for publicly traded companies under SEC’s rules. Although 

neither FedEx nor UPS are required to submit fourth quarter reports to 

the SEC, they do issue press releases on their Web sites that include 

detailed fourth quarter financial information, such as income statement 

and balance sheet information, and a discussion of quarterly results. 

The Service occasionally releases financial information via press 

releases; however, no press release was provided that included 

financial results for the fourth quarter of fiscal year 2001. Utilizing 

press releases to discuss fourth quarter results would compensate for 

the time lapses between the release of its third quarter report and its 

annual report, thus providing stakeholders with more timely financial 

information.



Another concern we raised was that the format for quarterly reports was 

not consistent, so that it was difficult to compare results and analyze 

trends over time. For the first quarter of fiscal year 2002, the 

Service changed its reporting format from what was provided in its 

first publicly available quarterly report for the third quarter of 

fiscal year 2001. The Service used the Chief Financial Officer’s (CFO) 

first quarter slide presentation to the Board of Governors as its 

quarterly financial report and stated that it was posted on its Web 

site. In spring of 2001, the Service stated that for future quarterly 

reports these slide presentations would be used. The Service then 

posted the CFO’s slide presentation for the second quarter of fiscal 

year 2002 to its Web site. We testified in May of 2002 that the CFO’s 

slide presentations contained less information than the fiscal year 

2001 third quarter report.[Footnote 21] The slide presentations 

included summary information on total revenues, expenses, and work-hour 

information, but did not include any discussion of the Service’s 

current position and outlook. For the third quarter of fiscal year 

2002, the Service posted to its Web site a quarterly report that was 

similar to its third quarter report for fiscal year 2001.



Finally, we raised a concern that the Service’s financial reports were 

not readily available to the public. Although the Service has begun to 

post both its monthly and quarterly reports to its Web site, it only 

posted the two most recent monthly reports and the latest quarterly 

report. In comparison, FedEx and UPS make available not only their most 

recent report, but also past quarterly reports. For example, FedEx’s 

quarterly reports dating back to April 1998 and UPS’s quarterly reports 

dating back to May 2000 are currently available on their Web sites. 

Posting past monthly and quarterly reports to the Service’s Web site 

would improve accessibility to past financial information and would 

assist stakeholders in understanding the Service’s changing financial 

condition and allow for trend analysis and comparisons.



Agency Comments and Our Evaluation:



The Service provided comments on a draft of this report in a letter 

from the Chief Financial Officer dated October 17, 2002. These comments 

are summarized below and reproduced in enclosure IV. In commenting on 

our draft report, the CFO stated that the Service would provide 

additional information in its periodic financial reports to improve 

stakeholder understanding of its business and that it would retain the 

data placed on its Web site for 3 years. Specifically, the Service 

agreed to provide explanations about variances from budgeted amounts, 

financial expectations, and the projected financial and operational 

impact of material events or transactions. 



The CFO pointed out that while the Service received many suggestions 

for fine-tuning certain disclosures, the financial community expressed 

overall satisfaction with the quantity and quality of data the Service 

provides. The CFO commented that the Service publicly discloses 

information to the PRC during rate case filings that exceeds the amount 

of information required by SEC-regulated companies and most other 

government agencies. We acknowledge that the Service provides a 

significant amount of information in its rate case filings; however, 

this information is provided only for rate-setting purposes, and rate 

cases are not filed on a regular cycle. Thus, rate case information 

does not provide stakeholders timely information about the Service’s 

current financial condition and changes to its expected outlook. As we 

have reported, stakeholders have been surprised by the significant 

changes that have occurred during the fiscal year to the Service’s net 

income estimates and financial outlook.



The CFO also stated that our report did not adequately or completely 

reflect the Service’s ongoing financial reporting, including its 

detailed revenue, volume, and weight information; annual billing 

determinants data; and 4-week Financial and Operating Statements. Our 

report does provide descriptions of the Service’s periodic financial 

information, including its quarterly Revenue, Piece, and Weight reports 

and its monthly Financial and Operating Statements. As we noted, 

however, these periodic financial reports do not clearly explain 

changes in its financial condition, outlook, and results of operations, 

and have not always been readily available to the public. The Service 

also provides annual information, such as its Annual Auditor’s Report 

and annual billing determinants data, but this information is not 

available throughout the year for use in periodic analysis. Moreover, 

the billing determinants data for fiscal year 2001, which ended in 

September 30, 2001, was not released until October of 2002.



With regard to the CFO’s point about the Service’s retirement 

obligations, he cautioned that public discussion of retirement 

obligations must be undertaken with great care and that the Service 

would ensure greater public understanding in this area. Due to the 

magnitude of these costs, the potential effects on current and future 

ratepayers, and the complexity of the issues involved in reporting 

retirement-related obligations, we agree that greater public 

understanding of these obligations is important. The Service’s 

announcement regarding its CSRS pension liability at its November 2002 

Board of Governors meeting further emphasizes the importance of 

enhanced disclosure and discussion of the implications of all of its 

retirement-related obligations. Further, the reduction in future 

pension obligations would increase the Service’s options for dealing 

with its postretirement health obligations and other financial 

challenges. For these:



reasons, we believe that the Service needs to enhance its disclosure of 

its postretirement health obligations in its financial reports. 

Importantly, a number of major employers have provided disclosures 

relating to these types of obligations for several years. In addition, 

the consolidated financial statements of the U.S. government include 

extensive disclosures of these obligations on a government-wide basis. 

Without sufficient disclosure of these obligations in the Service’s 

financial statements or the related footnotes, neither Congress nor 

stakeholders can have adequate information needed to make appropriate 

decisions related to these issues. We continue to believe that, at a 

minimum, these obligations should be discussed in the notes to the 

financial statements.



- - - --:



We are sending copies of this report to the Chairman and Ranking 

Minority Member of the Senate Committee on Governmental Affairs, 

Chairman and Ranking Minority Member of the House Committee on 

Government Reform, the Service’s Postmaster General/Chief Executive 

Officer, the Service’s Chief Financial Officer, the Chairman of the 

Postal Rate Commission, and other interested parties. We will also make 

copies available to others on request. In addition, the report will be 

available at no charge on the GAO Web site at http://www.gao.gov.



If you have any questions about this report or the enclosures, please 

contact Bernard Ungar at (202) 512-2834, ungarb@gao.gov, or Linda 

Calbom at (202) 512-8341, calboml@gao.gov. Key contributors to this 

assignment were Teresa Anderson, Tida Barakat, Joshua Bartzen, Heather 

Dunahoo, and Michael Fischetti.



Bernard L. Ungar:



Director, Physical Infrastructure Issues:



Signed by Bernard L. Ungar:



Linda Calbom:



Director, Financial Management and Assurance:



Signed by Linda Calbom



[End of Section]



Enclosure 1: Postal Service Fiscal Year 2002 Third Quarter Financial 

Report:



[See PDF for image]



[End of enclosure]



FedEx Fiscal Year 2002 Third Quarter Financial Report:



[See PDF for image]



[End of enclosure]



United Parcel Service Quarterly Report:



[See PDF for image]



[End of enclosure]



Comments from the U.S. Postal Service:



[See PDF for image]



[End of enclosure]



(543036):



FOOTNOTES



[1] In May 2002, we asked the Office of Personnel Management (OPM) to, 

among other things, estimate how much of the underfunded CSRS pension 

liability is attributable to the Service. OPM’s projections indicate 

that the Service’s future payments required under current legislation 

would overfund the CSRS liability by $71 billion over the remaining 

benefit period. Legislation would be required to modify the existing 

funding method so as to prevent overfunding of benefits in the future.



[2] U.S. General Accounting Office, U.S. Postal Service: Transformation 

Challenges Present Significant Risks, GAO-01-598T (Washington, D.C.: 

Apr. 4, 2001).



[3] U.S. General Accounting Office, U.S. Postal Service: Deteriorating 

Financial Outlook Increases Need for Transformation, GAO-02-355 

(Washington, D.C.: Feb. 28, 2002).



[4] U.S. General Accounting Office, U.S. Postal Service: Accounting for 

Postretirement Benefits, GAO-02-916R (Washington, D.C.: Sept. 12, 

2002).



[5] See 17 C.F.R. §240.13a-13.



[6] Such risks are typically associated with derivative instruments 

utilized to hedge changing market conditions and may not be applicable 

to activities of the Service. 



[7] See 17 C.F.R. §229.303 (b)(2002).



[8] The Service uses a 52-week “postal fiscal year” for management 

purposes that contains 364 days and thus starts and ends on a different 

day each postal fiscal year. The Service divides each postal fiscal 

year into 13 accounting periods of 4 weeks each. The first postal 

quarter corresponds to the first three accounting periods, and the last 

postal quarter includes the last four accounting periods of the postal 

fiscal year.



[9] GAO-02-355.



[10] The Service has a long-standing practice of withholding detailed 

financial information on the fourth quarter of a fiscal year and the 

first accounting periods of the following fiscal year until its annual 

financial statements have been audited and approved by the Board of 

Governors. The board approved the Service’s audited financial 

statements for fiscal year 2001 in December 2001.



[11] GAO-02-355, pp. 44-45.



[12] Our comparisons were based on the most recent publicly available 

quarterly reports by the Postal Service, FedEx, and UPS, which covered 

different periods. The Postal Service’s third quarter report for fiscal 

year 2002 covered the period February 23-May 17, 2002, and was made 

publicly available in July 2002. FedEx’s third quarter report for 

fiscal year 2002 covered the period December 1, 2000-February 28, 2002, 

and was filed with the SEC in April 2002. UPS’s first quarter report 

for fiscal year 2002 covered the period January 1, 2002-March 31, 2002, 

and was filed with the SEC in May 2002.



[13] See SEC Rel. Nos. 33-8056; 34-45321; FR-61 (Jan. 22, 2002).



[14] The Service did not have a section titled Management’s Discussion 

and Analysis in its quarterly report, but it did have similar sections 

titled “Operating Results” and “Message from the Chief Financial 

Officer.” In our analysis, we compared these sections with the MD&A 

sections of FedEx and UPS quarterly reports.



[15] See 17 C.F.R. §210.10-01(a)(5)(2002).



[16] A general discussion in the footnotes to the U.S. Postal Service 

Annual Report 2001 discloses contingent liabilities. 



[17] In May 1992, we recommended that the Service provide additional 

information on its postretirement health benefits as part of its annual 

financial statement (U.S. General Accounting Office, Financial 

Reporting: Accounting for the Postal Service’s Postretirement Health 

Care Costs, GAO/AFMD-92-32, Washington, D.C.: May 20, 1992). The 

Service did not agree with and did not implement this recommendation. 

We reiterated this recommendation and also discussed the accounting 

treatment of these obligations in our recent report, U.S. General 

Accounting Office, U.S. Postal Service: Accounting for Postretirement 

Benefits, GAO-02-916R (Washington, D.C.: Sept. 12, 2002).



[18] On November 20, 2001, the President released $175 million to the 

Postal Service from the Emergency Response Fund for expenses relating 

to the terrorist attacks. In January 2002, the Service was appropriated 

an additional $500 million for emergency expenses.



[19] Public Law 107-67.



[20] Public Law 107-117 appropriated $500 million to the Service for 

emergency expenses and required the Service to develop an Emergency 

Preparedness Plan with its planned expenditures to support this Plan.



[21] GAO-02-694T.



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