Our objective was to assess the Postal Service’s management of its employees’ use of novel coronavirus disease (COVID-19) leave under the Families First Coronavirus Response Act (FFCRA).
In March 2020, the president declared COVID-19 pandemic to be a national emergency and signed the FFCRA into law, creating two new types of leave:
- Up to 80 hours of emergency paid sick leave for specific qualifying reasons.
- Public health emergency leave, which amended the Family Medical Leave Act (FMLA) to allow employees to take up to 12 weeks of leave for an additional qualifying reason related to the closure of a child’s school or place of care.
The FFCRA was effective from April 1 through December 31, 2020. Any leave taken prior to April 1, 2020, remained subject to Postal Service rules in place at that time. The legislation was intended to ensure that workers were not forced to choose between their paychecks and public health measures. On April 7 and May 22, 2020, the U.S. Office of Personnel Management (OPM) released employee leave provisions of the FFCRA.
Although the FFCRA expired on December 31, 2020, the Postal Service continued to allow liberal leave usage for employees who had a sickness related to COVID‑19. On March 11, 2021, the American Rescue Plan Act was signed into law. This Act is similar to the FFCRA in that it created a new type of leave. Effective March 12, 2021, and continuing through September 30, 2021, the American Rescue Plan Act provides employees with up to 600 hours of paid leave. The OPM issued guidance on using the new leave authority on April 29, 2021.
The Postal Service faced significant unforeseen and uncontrollable challenges due to the COVID‑19 pandemic, including higher package volumes, employee absenteeism, employee safety, and unanticipated expenses.
Since reporting its first confirmed COVID‑19 case in February 2020, the Postal Service took several quick, decisive actions focused on employee safety, including:
- Creating the COVID‑19 Command Response Team at Postal Service Headquarters.
- Providing personal protective equipment, enhancing daily procedures, and updating the layout and operations of facilities to mitigate the risk of employees contracting or spreading COVID‑19.
- Creating a centralized website for employees with COVID‑19 instructions and guidance.
- Developing agreements with the unions for additional paid leave for some non-career employees.
While we recognize the challenges facing the Postal Service during the pandemic, we identified three areas of improvement for future implementation of leave administration because of the Postal Service’s management of COVID‑19 leave under FFCRA.
First, facility managers did not always maintain a completed Postal Service (PS) Form 3971, Request for Notification of Absence, or the additional required documentation to support emergency paid sick leave and expanded FMLA. We found 185 of 192 (96 percent) randomly sampled employees were either missing documentation or documentation was not properly completed.
The 185 employees accounted for over $900,000 in unsupported COVID‑19 leave costs.
COVID‑19 pandemic challenges prevented Postal Service facility managers from consistently following the procedures regarding the authorization of employees using COVID‑19-related leave. By not having appropriate supporting documentation to substantiate that employees were on authorized leave, we estimated the Postal Service’s unsupported COVID‑19 leave costs nationwide totaled $12.4 million.
Second, the Postal Service responded to the FFCRA by providing guidance to its supervisors and configuring the payroll systems to ensure employees were paid properly. However, the Postal Service was not always able to accurately track the rural carriers’ COVID‑19 administrative time because the payroll system was limited in the number of leave codes available within the administrative leave category.
Third, the Postal Service was not always able to monitor FFCRA leave limits. Employees who used COVID‑19-related leave did not always comply with FFCRA guidelines. There were nearly 12,000 instances of employees who exceeded COVID‑19-related leave limits. Specifically, the Postal Service identified and made over 8,300 payroll adjustments for employees who exceeded COVID‑19‑related leave limits. We found nearly 3,600 additional employees who still needed payroll adjustments because they exceeded leave limits.
Although the Postal Service began automating payroll system controls in July 2020, it did not fully implement controls until September 2020, nearly five months after the FFCRA was effective. Instead, facility supervisors were instructed to manually review FFCRA employee leave limits.
COVID‑19 and the corresponding FFCRA were unexpected and unusual occurrences. However, with the American Rescue Plan Act and potential for future legislation related to COVID‑19, or with the occurrence of other unexpected or unusual events, it is critical for the Postal Service to ensure consistent communication on the importance of policy requirements and system flexibility to prevent the same or similar issues from reoccurring.
We recommended management:
- Reiterate to managers and supervisors at all levels the importance of policy requirements to manage and document leave, including pandemic‑related leave.
- Modify the system to allow for all employees to digitally complete PS Form 3971.
- Modify the payroll systems or develop another methodology for accurate recording of administrative leave for rural carriers.
- Reiterate Postal Service policy to all employees for consistent, nationwide application for monitoring leave to not exceed allowable leave limits.