In July 2014, the Postal Service and the American Postal Workers Union entered into a Memorandum of Understanding (MOU) regarding custodial workhours. The MOU dictated that custodians receive additional compensation when certain facilities fail to use 90 percent of their calculated annual custodial workhours. These hours are based on facility size and designated cleaning frequencies. As of the end of fiscal year (FY) 2018, there were 8,955 facilities subject to this MOU, including processing and distribution centers, post offices, stations, and branches.

Postal Service Maintenance Series Handbook MS-47 and Transmittal Letter 5 detail the process for calculating a facility’s annual custodial workhours, which are documented on Line H of Postal Service Form 4852, Workload Analysis and Summary. At fiscal year-end, facility management performs a reconciliation by comparing total actual custodial workhours shown in Labor Distribution Code (LDC) 38 to 90 percent of calculated annual custodial workhours shown on Line H of PS Form 4852 to determine compliance with the MOU requirement. Facilities that do not comply with the requirement are required to compensate custodians at the overtime rate via the grievance process.

Our objective was to assess compliance with the custodial workhour requirement to use 90 percent of calculated annual custodial workhours. The scope included custodial workhours for FYs 2015 through 2018 for the facilities subject to the MOU.

What the OIG Found

Facility management did not consistently meet the MOU requirement to use 90 percent of annual custodial workhours at all applicable facilities. Specifically, between FYs 2015 and 2018, 584 of 8,955 facilities (7 percent) did not meet this MOU requirement. Collectively, this equated to 791 MOU-related grievances, 7,949 grievance payments, 5,568 impacted employees, and $19.9 million in compensation paid at the overtime rate. Additionally, as of September 2018, there were another 409 open MOU-related grievances currently in the grievance process pending resolution, with some grievances being open since January 2015.

Conversely, 6,933 of 8,955 facilities (77 percent) exceeded 100 percent of calculated annual custodial workhours during the same period. In addition, management did not always ensure the accuracy of workhours reported in LDC 38, which represents custodial workhours. To assess accuracy, based on a statistical sample of 8,417 of 133,217 total workhours, which represented 5,509 workhours charged by custodians and 2,908 workhours charged by non-custodial employees:

  • Custodians charged 24 percent (1,311 of 5,509) of workhours, or 28,802 workhours projected over the universe, to incorrect LDCs.
  • Non-custodial employees incorrectly charged 46 percent (1,350 of 2,908) of workhours, or 5,663 workhours projected over the universe, to LDC 38.

Staffing challenges were a primary factor contributing to facilities not meeting the MOU requirement, including vacancies, long-term leave usage, inability to augment custodial work with temporary employees, and custodians doing non-custodial work.

By not meeting the MOU requirement for FYs 2017 and 2018, we determined the Postal Service incurred questioned costs of $8.4 million annually. Going forward, the Postal Service risks incurring another $16.1 million annually in costs for FYs 2019 through 2022, if failure to meet the MOU requirement continues.

Finally, when workhours are not charged to the appropriate LDC base operation, management cannot obtain an accurate account of effort required/incurred for specific tasks. In this instance, inaccurate reporting of LDC 38 could have a significant impact on a facility’s compliance with the MOU requirement.

What the OIG Recommended

We recommended management develop a strategy to address hiring and staffing challenges for custodial positions at facilities subject to the MOU and implement an oversight mechanism to hold managers accountable to the existing policy to periodically assess the accuracy of workhours charged to LDC 38 in the Time and Attendance Collection System.

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Audit Resolution - Recommendation 1

OIG Response

Comments (12)

  • anon

    Bout to slap my office with a Line H grievance. I’m constantly sent out to run express, level 7 mm clocks in using custodial rings. No OT allowed no matter what, even if I’m the only custodian for the day at an office with 140 routes. It doesn’t help that one of my coworkers has two separate cases for fmla, they call in at least 1-2 times a week. The CTC cleaning program also gutted the custodial work force. We used to have 6 custodians, now because of ctc we’re allowed 2.6 custodians. Wow, nice job usps. Nice job.

    Oct 17, 2020
  • anon

    We have custodial that works 10 hour work week. Are they allowed 10 minute break at all a day?

    Sep 26, 2020
  • anon

    I'm a custodian in Memphis,Tennessee where I have learned to just cover my station with this covid 19. I sanitize as much as possible on the inside but have been almost begging for a pressure washer to wash down the outside of the building for spiderwebs,spiders, wasps nests dirt,grime and saw a tick on the outside garbage can today. Need someone to understand that I need help in getting a power pressure washer to get the building cleaned.

    Jul 14, 2020
  • anon

    Unable to trust anyone from supervisior to our craft director. Craft director works with management. We're are to complete tour 1 routes. Yet we have no tour 1, no jobs up for tour 1. Craft director just marks it off as done. Now we are being told drive time is included in cleaning routes??? Receive threating text at 3:45 a.m. from craft director because of line H which supervisor does nothing about. ..we just can't staff properly they have to turn it into a game. Like my supervisor said to us. "We are the enemie and can't be trusted"

    Mar 10, 2020
  • anon

    I am a custodian in my home office but I am on detail and my detail extension was refused due to custodial hours in my home office. I was told by an individual in management, hours were not being transferred when PSE's were cleaning in my absence. I read thru the agreement and on pg. 13 it mentions that custodial hours when the custodian is on detail can be charged to a maintenance operation. Is this an accurate statement? Can an office do this. I need to know before my detail ends. I emailed the POOM and got a very rude reply in response. In 26 yrs I have never filed a grievance and I'm looking for guidance on how I should proceed.

    Mar 05, 2020
  • anon

    Can custodians operate chainsaws without the proper training or Safety equipment

    Feb 19, 2020
  • anon

    Maybe. Power equipment like that falls under level 7 pay though. So find out what clock ring you need to get that pay while you operate that equipment.

    Oct 17, 2020
  • anon

    We at DVD/ PEDC had not received any monies as per 2016,2017,2018 or 2019. How it is that NDC custodians had awarded monies for this memorando of understanding and not us at DVD

    Jan 24, 2020
  • anon

    In our station line H has turned management against us as if we are at war. We have been told we are the enemy and can't be trusted. At the end of every schedule is all routes will be completed no exceptions. We are short handed. The time given for routes are not right. We have had no safety talks for over a year. Running from station to station 30 mins here to 8 mins at another no time to clean just for line H hours. Is this what it has come down to .

    Jan 16, 2020
  • anon

    We have worked excessive hours of OT to make ctc hours. How can that make for proper staffing. Now. Tour 3 is given tour 2 work and a lot of our OT is cut. Is that right. Tour 2 is given tour 1 work when we have no tour 1???

    Dec 05, 2019
  • anon

    For line H reasons we have to do tour 1 routes yet we have no tour 1

    Nov 13, 2019
  • anon

    The problem is not 2014 MOU compliance but rather the entire CTC, MS-47 Tl-5 approach. The primary objective from Area and District level management was reduction in cleaning hours as a whole. What I have experienced is a minimalist approach to MS-47 staffing levels which has created a vacuum that needs addressed. I have yet to meet a Postmaster who actually had a say in developing their own staffing package. District came and measured and a few weeks later we have a new 4852. The staffing across the board was the minimal frequency the MS-47 would allow, despite what the office actually needed or local management required. For instance our District has been pushing RCE compliance. The route for policing trash outside has been reduced to only once a week. The MS-47 gives a range between 1 and 6 times a week. When we complained about this, we were told Area will only allow once a week. It is problems like this that encourage management to "adjust the frequencies" in order to keep the building presentable. With the MOU, frequencies cannot be adjusted without causing a shortage of Line H hours, as many are finding out. Many offices have used their custodians to perform needed work that has never been custodial work, such as changing a flat tire, installing a jump seat, transporting mail to another facility, fixing a lock that had been changed incorrectly or possibly some minor repairs around the building. Often with the terrible Facilities Maintenace program, FSSP, you may be waiting months for a simple repair. Naturally it may be an easy temptation to just have your custodian perform the work. The point I'm making is that Station Managers and Postmasters were never given a chance to curtail CTC to their own needs. Offices are told what work in the supplemental work category would be permitted and what would not be permitted. This has created a vacuum in not being able to utilize your personnal in a manner that best supports your local operation. My point is proven by the Line H grievances that are filed annually. My suggestion is to work with Area and District Maintenance Managment to better support APO offices in developing a staffing package that will not hurt at the end of the year. Simply put, work that is performed needs to be staffed. Better oversight on LDC 38 hours is needed I agree, but I believe this is only a bandaid on a fatal wound. In my opinion, better developed and more accurate staffing packages are the answer. Thank you for your interest in this subject.

    Nov 03, 2019