National Mediation Board: Agency Should Take Steps to Regularly Update Its Plans and Policies and Ensure Staff Receive Necessary Training
Fast Facts
The National Mediation Board, a federal agency, helps railroads and airlines resolve labor disputes to avoid work stoppages and prevent disruptions to interstate commerce.
We found that this agency has had challenges keeping important plans and policies current. For example, despite vacancies in nearly a third of its positions and almost half its staff eligible for retirement within 5 years, the agency had no process for regularly updating its workforce plan. The agency's training policy and several personnel policies were also out of date.
Our recommendations address these and other issues we found.
Highlights
What GAO Found
The National Mediation Board (NMB), which facilitates labor relations for railroads and airlines, has implemented two of GAO's four remaining recommendations from past reports. Specifically, NMB has updated its privacy policy and developed a process to track issues raised by the National Labor Relations Board (NLRB) Inspector General's (IG) office, which operates a hotline on NMB's behalf. However, NMB has not yet fully implemented the other two recommendations. NMB has not updated its continuity of operations plan, a key component of an information security program. The agency also continues to use two cloud services that are not federally approved. By not fully implementing these recommendations, NMB is increasingly vulnerable to information security risks to its data and systems.
Status of GAO Recommendations to the National Mediation Board
In addition, NMB faces challenges related to its workforce planning, training, and personnel policies.
- NMB has no procedures for regularly reviewing and updating its workforce and succession plan. NMB has had difficulty filling its many vacant positions, and more than half of NMB's current staff are eligible for retirement within the next 5 years. NMB has initiated efforts to update the plan, but without procedures for keeping it up to date, NMB will not be positioned to effectively manage its workforce needs.
- NMB lacks procedures for regularly updating its training policy. Moreover, some officials have been assigned essential duties outside of their primary expertise but received little training related to these roles. Without procedures to keep NMB's training policy up to date, and sufficient training for officials with essential additional roles, NMB cannot ensure all officials have the knowledge and skills required to meet the agency's mission.
- NMB also lacks procedures for ensuring its personnel policies are complete and updated. Without such procedures, NMB risks operating without needed policies or being out of compliance with federal regulations.
Why GAO Did This Study
NMB was created by a 1934 amendment to the Railway Labor Act. It plays a critical role in helping airline and railway carriers resolve labor disputes to avoid work stoppages and prevent disruptions to interstate commerce.
The FAA Modernization and Reform Act of 2012 includes a provision for GAO to evaluate NMB programs and activities every 2 years. Between 2013 and 2022, GAO issued five reports that included a total of 18 recommendations. As of the start of this review in May 2023, NMB had implemented 14 of those recommendations.
This sixth report examines (1) the extent to which NMB has taken actions to implement the four remaining recommendations from GAO's prior reports; and (2) any other challenges NMB faces in key management areas and in overseeing its operations.
GAO reviewed relevant federal laws and regulations and examined NMB documents, plans, policies, and practices. GAO also interviewed officials from NMB, an NMB advisory group, the NLRB IG, and NMB's independent financial auditor.
Recommendations
GAO is making four recommendations to NMB to establish procedures to (1) regularly update its workforce and succession plan, (2) regularly update its training policy, (3) ensure staff with additional roles receive necessary training, and (4) ensure its personnel policies are complete and up to date. NMB agreed with GAO's recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| National Mediation Board | The NMB Board should establish procedures for regularly updating its workforce and succession plan. These procedures should help ensure that NMB's workforce and succession plan is long-term in focus and includes a workforce analysis that identifies skills gaps, an action plan with strategies to close gaps, plans to implement those strategies, and measures to assess progress as described in OPM's Workforce Planning Guide. (Recommendation 1) |
NMB agreed with this recommendation. On April 1, 2026, NMB reported that the agency reviews its succession plan as needed. NMB stated that updates to the plan are considered when there is a substantial change to the agency's organizational structure, new positions are created or abolished, or the overall agency FTE level in the Congressional Budget Justification is changed. According to NMB, in April 2025 OPM eliminated 11 positions at NMB, resulting in a new level of 40 full-time equivalent employees. NMB reported that the succession plan was updated in June 2025 to reflect this change. However, as we reported in 2024, at that time NMB had not updated its workforce and succession plan in 10 years, despite significant workforce challenges. It is essential for NMB to update its workforce and succession plan in response to specific changing circumstances, such as those noted by the agency. However, at of April 2026, NMB has not developed a procedure for regularly updating its workforce and succession plan that helps ensure this plan is long-term in focus and includes a workforce analysis that identifies skills gaps, an action plan with strategies to close gaps, plans to implement those strategies, and measures to assess progress as described in OPM's Workforce Planning Guide. We will close this recommendation when NMB provides evidence it has established such a procedure.
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| National Mediation Board | The NMB Board should establish procedures for regularly updating its agency-wide training policy. (Recommendation 2) |
NMB agreed with this recommendation. On April 1, 2026, NMB reported that the agency continues to support employee training and professional development opportunities for all levels of staff and that training and development is discussed during employees' quarterly performance reviews. NMB reported that its training policy is still applicable; however, it is currently under revision to incorporate recent OPM training guidance and requirements. While NMB stated that its training policy is still applicable, in 2024 we reported that the policy had not been updated since 2013 and was no longer aligned with the agency's organizational structure. Revisions to its training policy underway as of April 2026 may bring this policy into better alignment with NMB's current structure, however, the agency did not indicate that it has established any procedures to regularly update its agency-wide training policy. We will close this recommendation when NMB provides evidence that it has established such a policy.
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| National Mediation Board | The NMB Board should provide officials who are assigned essential additional roles with sufficient training and information, including position descriptions, necessary to understand and carry out the full scope of their responsibilities. (Recommendation 3) |
NMB agreed with this recommendation. On April 1, 2026, NMB reported that it is in the process of updating position descriptions for Departmental Directors with ancillary duties or roles. NMB stated that it hopes to have these descriptions updated by June 1, 2026. We will close this recommendation when NMB completes this process and provides examples of these updated position descriptions.
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| National Mediation Board | The NMB Board should develop procedures to ensure it has all necessary personnel policies in place and that they are regularly reviewed and updated to meet the needs of the agency and comply with federal requirements. (Recommendation 4) |
NMB agreed with and implemented this recommendation. On March 31, 2026, the NBM Chairman issued a memorandum to NMB Directors outlining the agency's policy for reviewing, and updating as necessary, policies and directives. This memorandum included a requirement that agency policies are reviewed annually in January during the Congressional Budget Justification preparation and in June during the planning phase of the for the agency's financial audit. The memorandum describes the parties responsible for reviewing and updating various types of policies and responsibilities for finalizing and approving policy updates.
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