oversight

Audit of the National Rural Letter Carriers' Association as Sponsor and Administrator for the Rural Carrier Benefit Plan Alexandria, Virginia

Published by the Office of Personnel Management, Office of Inspector General on 2016-02-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

        U.S. OFFICE OF PERSONNEL MANAGEMENT
           OFFICE OF THE INSPECTOR GENERAL
                    OFFICE OF AUDITS




                Final Audit Report
                                 AUDIT OF
                   THE NATIONAL RURAL LETTER CARRIERS’
                               ASSOCIATION
                  AS SPONSOR AND ADMINISTRATOR FOR THE
                        RURAL CARRIER BENEFIT PLAN
                           ALEXANDRIA, VIRGINIA

                                            Report Number 1B-38-00-15-057
                                                   February 26, 2016

                                                             -- CAUTION --
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data that is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.
             EXECUTIVE SUMMARY 

         Audit of the National Rural Letter Carriers’ Association as Sponsor and Administrator
                                   for the Rural Carrier Benefit Plan
Report No. 1B-38-00-15-057                                                                       February 26, 2016



Why did we conduct the audit?             What did we find?

We conducted this audit to obtain         We questioned $11,903 in administrative expenses and applicable
reasonable assurance that the National    lost investment income (LII). NRLCA agreed with all of the
Rural Letter Carriers’ Association        questioned amounts.
(NRLCA), as sponsor and
administrator for the Rural Carrier       Our monetary findings included the following for administrative
Benefit Plan, is complying with the       expenses:
provisions of the Federal Employees
Health Benefits Act and regulations          $5,262 in net overcharges for self-disclosed cost adjustments;
that are included, by reference, in the
Federal Employees Health Benefits            $3,933 for unallowable and/or unallocable expenses;
Program (FEHBP) contract. The
objective of our audit was to                $1,410 for excessive benefit plan brochure printing costs in
determine whether NRLCA charged               2012; and,
administrative expenses to the
FEHBP that were actual, allowable,           $1,298 for applicable LII on the questioned overcharges.
necessary, and reasonable expenses
incurred in accordance with the terms     We verified that NRLCA has returned all of the questioned
of the contract and applicable            amounts to the FEHBP.
regulations.

What did we audit?

Our audit covered NRLCA’s
administrative expenses from 2010
through 2014 as reported in the
Annual Accounting Statements.




 _______________________
 Michael R. Esser
 Assistant Inspector General
 for Audits
                                                        i
                 ABBREVIATIONS

CFR        Code of Federal Regulations
Contract   Contract CS 1073
Coventry   Coventry Health Care, Inc.
FAR        Federal Acquisition Regulations
FEHB       Federal Employees Health Benefits
FEHBAR     Federal Employees Health Benefits Acquisition Regulations
FEHBP      Federal Employees Health Benefits Program
LII        Lost Investment Income
NRLCA      National Rural Letter Carriers’ Association
OIG        Office of the Inspector General
OPM        Office of Personnel Management
Plan       Rural Carrier Benefit Plan




                                  ii
IV. MAJOR CONTRIBUTORS TO THIS REPORT
          TABLE OF CONTENTS

                                                                                                                          Page
          EXECUTIVE SUMMARY ........................................................................................... i 


          ABBREVIATIONS ...................................................................................................... ii 


  I.	     BACKGROUND ...........................................................................................................1 


  II.	    OBJECTIVE, SCOPE, AND METHODOLOGY .........................................................3 


  III.	   AUDIT FINDINGS AND RECOMMENDATIONS ....................................................5 


          A. ADMINISTRATIVE EXPENSES...........................................................................5 


               1. Self-Disclosed Cost Adjustments ......................................................................5 

               2. Unallowable and/or Unallocable Expenses .......................................................7 

               3. Benefit Plan Brochures ......................................................................................9 


  IV.	    MAJOR CONTRIBUTORS TO THIS REPORT........................................................11 


  V.	     SCHEDULE A - QUESTIONED CHARGES

          APPENDIX (National Rural Letter Carriers’ Association Draft Report Response,
          dated January 14, 2016)

          REPORT FRAUD, WASTE, AND MISMANAGEMENT
IV. MAJOR CONTRIBUTORS
            I. BACKGROUND
                       TO THIS REPORT

This final audit report details the findings, conclusions, and recommendations resulting from our
audit of the Federal Employees Health Benefits Program (FEHBP) operations at the National
Rural Letter Carriers’ Association (NRLCA), as sponsor and administrator for the Rural Carrier
Benefit Plan (Plan). NRLCA is located in Alexandria, Virginia.

The audit was performed by the Office of Personnel Management’s (OPM) Office of the
Inspector General (OIG), as established by the Inspector General Act of 1978, as amended.

The FEHBP was established by the Federal Employees Health Benefits (FEHB) Act (Public Law
86-382), enacted on September 28, 1959. The FEHBP was created to provide health insurance
benefits for federal employees, annuitants, and dependents. OPM’s Healthcare and Insurance
Office has overall responsibility for administration of the FEHBP. The provisions of the FEHB
Act are implemented by OPM through regulations, which are codified in Title 5, Chapter 1, Part
890 of the Code of Federal Regulations (CFR). Health insurance coverage is made available
through contracts with various health insurance carriers.

The Plan is a fee-for-service experience-rated employee organization plan offering health care
benefits to eligible enrollees and their families. Plan enrollment is open to eligible active and
retired rural letter carriers of the United States Postal Service. To enroll in the Plan, you must
already be, or must immediately become, a member of the NRLCA.

The NRLCA is the sponsor and administrator of the Plan, operating under Contract CS 1073
(contract) to provide a health benefits plan authorized by the FEHB Act. NRLCA’s activities
include overall administrative management of the Plan, determining eligibility for the Plan, and
administering the general day-to-day operations of the Plan. The NRLCA has the following
contractual arrangements with affiliates of Coventry Health Care, Inc. (Coventry), an Aetna, Inc.
company:

      First Health Life and Health Insurance Company and Cambridge Life Insurance
       Company to underwrite the Plan;
      Claims Administration Corporation to perform administrative functions; and
      Coventry Health Care National Accounts, Inc. and Coventry’s health plans to provide
       health care provider network services.

In 2013, Coventry merged with Aetna, Inc. The merger did not affect the contractual agreements
with NRLCA.




                                                  1                           Report No. 1B-38-00-15-057
The contract with OPM is experience-rated. Thus, the costs of providing benefits in the prior
year, including underwritten gains and losses which have been carried forward, are reflected in
current and future years’ premium rates. In addition, the contract provides that in the event of
termination, unexpected program funds revert to the FEHBP Trust Fund. In recognition of these
provisions, the contract requires an accounting of program funds be submitted at the end of each
contract year. The accounting is made on a statement of operations known as the Annual
Accounting Statement.

Compliance with laws and regulations applicable to the FEHBP is the responsibility of
NRLCA’s management. Also, management of NRLCA is responsible for establishing and
maintaining a system of internal controls.

There were no findings from our previous audit of NRLCA (Report No. 1B-38-00-04-023, dated
July 19, 2004) for contract years 2000 through 2002.

The results of this audit were provided to NRLCA in written audit inquiries; were discussed with
NRLCA officials throughout the audit and at an exit conference on November 19, 2015; and
were presented in a draft report, dated December 16, 2015. NRLCA’s comments offered in
response to the draft report were considered in preparing our final report and are included as an
Appendix to this report.




                                                2                          Report No. 1B-38-00-15-057
IV.
II. OBJECTIVE,
    MAJOR CONTRIBUTORS
               SCOPE, AND TO
                          METHODOLOGY
                             THIS REPORT

 OBJECTIVE

 The objective of our audit was to determine whether NRLCA charged administrative expenses to
 the FEHBP that were actual, allowable, necessary, and reasonable expenses incurred in
 accordance with the terms of the contract and applicable regulations.

 SCOPE

 We conducted our performance audit in accordance with generally accepted government auditing
 standards. Those standards require that we plan and perform the audit to obtain sufficient and
 appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
 audit objective. We believe that the evidence obtained provides a reasonable basis for our
 findings and conclusions based on our audit objective.

 We reviewed the Plan’s Annual Accounting Statements as they pertain to NRLCA’s
 administrative expenses for contract years 2010 through 2014.1 During this period, NRLCA
 charged approximately $9.2 million in administrative expenses to the FEHBP.


                                               NRLCA
                                    Administrative Expense Charges
                               $5
                  $ Millions




                               $4
                               $3
                               $2
                               $1
                               $0
                                      2010   2011     2012     2013      2014
                                             Contract Years


 In planning and conducting our audit, we obtained an understanding of NRLCA’s internal
 control structure to help determine the nature, timing, and extent of our auditing procedures.
 This was determined to be the most effective approach to select areas of audit. For those areas
 selected, we primarily relied on substantive tests of transactions and not tests of controls. Based
 on our testing, we did not identify any significant matters involving NRLCA’s internal control

 1
   The significant increase in NRLCA’s administrative expense charges for 2014 is due to the Affordable Care Act
 fees and vendor cost containment expenses.


                                                         3                               Report No. 1B-38-00-15-057
structure and its operations. However, since our audit would not necessarily disclose all
significant matters in the internal control structure, we do not express an opinion on the
NRLCA’s system of internal controls taken as a whole.

We also conducted tests to determine whether NRLCA had complied with the contract, the
applicable procurement regulations (i.e., Federal Acquisition Regulations (FAR) and Federal
Employees Health Benefits Acquisition Regulations (FEHBAR), as appropriate), and the laws
and regulations governing the FEHBP. The results of our tests indicate that, with respect to the
items tested, NRLCA did not comply with all provisions of the contract and federal procurement
regulations. Exceptions noted in the areas reviewed are set forth in detail in the "Audit Findings
and Recommendations" section of this audit report. With respect to the items not tested, nothing
came to our attention that caused us to believe that NRLCA had not complied, in all material
respects, with those provisions.

In conducting our audit, we relied to varying degrees on computer-generated data provided by
NRLCA. Due to time constraints, we did not verify the reliability of the data generated by the
various information systems involved. However, while utilizing the computer-generated data
during our audit, nothing came to our attention to cause us to doubt its reliability. We believe
that the data was sufficient to achieve our audit objective.

The audit was performed at NRLCA’s office in Alexandria, Virginia from September 14, 2015
through September 18, 2015. Audit fieldwork was also performed at our office in Cranberry
Township, Pennsylvania through November 19, 2015.

METHODOLOGY

We obtained an understanding of the internal controls over NRLCA’s cost accounting system by
inquiry of NRLCA officials. For contract years 2010 through 2014, we also judgmentally
reviewed NRLCA’s administrative expenses that were charged to the FEHBP. Specifically, we
reviewed the administrative expenses relating to the NRLCA expense accounts, certain Coventry
accounts, cost adjustments, and benefit plan brochures.2 We used the FEHBP contract, the FAR,
and the FEHBAR to determine the allowability, allocability, and reasonableness of charges.


2
  NRLCA allocated administrative expenses of $9,201,892 to the FEHBP from 22 NRLCA expense accounts
(including cost adjustments) and 3 Coventry accounts (i.e., vendor cost containment; taxes, licenses, and fees; and
outside services) for contract years 2010 through 2014. From this universe, we selected and reviewed a judgmental
sample of 14 NRLCA accounts, which totaled $5,744,863 in expenses allocated and charged to the FEHBP. We
selected these accounts based on high dollar amounts, trend analysis, and our nomenclature review. For the
Coventry accounts, we judgmentally selected the two years with the highest total charges and then selected the two
highest dollar Coventry accounts, totaling $2,228,002, from these years. Additionally, we judgmentally selected and
reviewed the highest dollar cost adjustment (a credit adjustment of $100,184 in 2011) during the audit scope. The
results of these sample selections were not projected to the universe of administrative expenses.


                                                        4                                Report No. 1B-38-00-15-057
  IV. AUDIT
III.   MAJORFINDINGS
             CONTRIBUTORS  TO THIS REPORT
                     AND RECOMMENDATIONS

  A. ADMINISTRATIVE EXPENSES

    1. Self-Disclosed Cost Adjustments                                                      $6,255

       During our audit fieldwork phase, NRLCA self-disclosed net overcharges of $5,262 to
       the FEHBP for various administrative expenses that were incurred from 2010 through
       2014. Specifically, NRLCA overcharged the FEHBP $20,998 and undercharged the
       FEHBP $15,736 for these various administrative expenses. As a result, NRLCA returned
       $6,255 to the FEHBP, consisting of $5,262 for net administrative expense overcharges
       and $993 for applicable lost investment income (LII) on the overcharges.

       Contract CS 1073, Part III, section 3.2 (b)(1) states, “The Carrier may charge a cost to the
       contract for a contract term if the cost is actual, allowable, allocable, and reasonable.”

       48 CFR 31.201-4 states, “A cost is allocable if it is assignable or chargeable to one or
       more cost objectives on the basis of relative benefits received or other equitable
       relationship. Subject to the foregoing, a cost is allocable to a Government contract if it-
           a) Is incurred specifically for the contract;
           b) Benefits both the contract and other work, and can be distributed to them in
               reasonable proportion to the benefits received; or
           c) Is necessary to the overall operation of the business, although a direct relationship
               to any particular cost objective cannot be shown.”

       Regarding reportable monetary findings, Contract CS 1073, Part III, section 3.16 (a),
       states, “Audit findings . . . in the scope of an OIG audit are reportable as questioned
       charges unless the Carrier provides documentation supporting that the findings were
       already identified and corrected (i.e., administrative expense overcharges . . . were
       already . . . returned to the FEHBP) prior to audit notification.”

       FAR 52.232-17(a) states, “all amounts that become payable by the Contractor . . . shall
       bear simple interest from the date due . . . The interest rate shall be the interest rate
       established by the Secretary of the Treasury as provided in 41 U.S.C 7109, which is
       applicable to the period in which the amount becomes due, as provided in paragraph (e)
       of this clause, and then at the rate applicable for each six-month period as fixed by the
       Secretary until the amount is paid.”

       While we were conducting our review of NRLCA’s administrative expenses, NRLCA
       self-disclosed to us that various expenses were over and/or undercharged to the FEHBP


                                                5                            Report No. 1B-38-00-15-057
from 2010 through 2014. The following summarizes the exceptions noted by NRLCA
that require cost adjustments:

   $5,598 in overcharges for “Disallowed Interest”;

   $5,522 in net overcharges for the “Elimination of Redundant Computer Allocation
    Charges” ($6,119 in overcharges and $597 in undercharges);

   $2,337 in net overcharges due to a “Difference in General Ledger Balances” ($4,024
    in overcharges and $1,687 in undercharges);

   $2,029 in overcharges for a “Correction in Health Premiums”;

   $905 in overcharges due to the “Elimination of Regular Pages in the Convention
    Issue of Magazine”; and,

   $11,129 in net undercharges due to the “Over/Under Stated Real Estate and/or
    Property Taxes” ($2,323 in overcharges and $13,452 in undercharges).

                                In total, NRLCA net overcharged the FEHBP $5,262 for
                                various administrative expenses that were incurred from
   NRLCA self-disclosed
                                2010 through 2014 (i.e., $20,998 in overcharges and
     net overcharges of
                                $15,736 in undercharges). We reviewed and agreed with
 $5,262 to the FEHBP for
                                NRLCA’s self-disclosed cost adjustments for these
    2010 through 2014.
                                various expenses. As a result of this finding, NRLCA
                                returned $6,255 to the FEHBP in September and October
2015, consisting of $5,262 for net administrative expense overcharges and $993 for
applicable LII on the overcharges. NRLCA returned these questioned amounts to the
FEHBP after receiving our audit notification letter (dated May 21, 2015).

NRLCA Response: 


NRLCA agrees with this finding.


OIG Comment:

We verified that NRLCA returned $6,255 to the FEHBP, consisting of $5,262 for net
overcharges and $993 for applicable LII on the overcharges.




                                        6                          Report No. 1B-38-00-15-057
   Recommendation 1

   We recommend that the contracting officer disallow $5,262 in administrative expenses
   that were net overcharged to the FEHBP from 2010 through 2014. However, since we
   verified that NRLCA returned these net overcharges of $5,262 to the FEHBP, no further
   action is required for this questioned amount.

   Recommendation 2

   We recommend that the contracting officer require NRLCA to return $993 to the FEHBP
   for LII on the questioned overcharges. However, since we verified that NRLCA returned
   $993 to the FEHBP for the questioned LII, no further action is required for this LII
   amount.

2. Unallowable and/or Unallocable Expenses                                               $4,238

   From 2009 through 2014, NRLCA charged unallowable and/or unallocable expenses of
   $3,933 to the FEHBP. As a result of this finding, NRLCA returned $4,238 to the
   FEHBP, consisting of $3,933 for the questioned expenses and $305 for applicable LII on
   these overcharges.

   As previously cited from Contract CS 1073, costs charged to the FEHBP must be actual,
   allowable, allocable, and reasonable.

   48 CFR 31.205-13(a) states, “Aggregate costs incurred on activities designed to improve
   working conditions, employer-employee relations, employee morale, and employee
   performance (less income generated by these activities) are allowable, except as limited
   by paragraphs (b), (c), and (d) of this subsection. Some examples of allowable activities
   are house publications, health clinics, wellness/fitness centers, employee counseling
   services, and food and dormitory services, which include operating or furnishing facilities
   for cafeterias, dining rooms, canteens, lunch wagons, vending machines, living
   accommodations, or similar types of services for the contractor's employees at or near the
   contractor's facilities.”

   48 CFR 31.205-14 states, “Costs of amusement, diversions, social activities, and any
   directly associated costs such as tickets to shows or sports events, meals, lodging, rentals,
   transportation, and gratuities are unallowable. Costs made specifically unallowable under
   this cost principle are not allowable under any other cost principle. Costs of membership
   in social, dining, or country clubs or other organizations having the same purposes are




                                             7                           Report No. 1B-38-00-15-057
also unallowable, regardless of whether the cost is reported as taxable income to the
employees.”

48 CFR 31.205-51 states, “Costs of alcoholic beverages are unallowable.”

FAR 52.232-17(a) states, “all amounts that become payable by the Contractor . . . shall
bear simple interest from the date due . . . The interest rate shall be the interest rate
established by the Secretary of the Treasury as provided in 41 U.S.C 7109, which is
applicable to the period in which the amount becomes due, as provided in paragraph (e)
of this clause, and then at the rate applicable for each six-month period as fixed by the
Secretary until the amount is paid.”

For the period 2010 through 2014, NRLCA allocated administrative expenses of
$6,033,251 to the FEHBP from 22 NRLCA expense accounts. From this universe, we
selected a judgmental sample of 14 accounts to review, which totaled $5,744,863 in
expenses allocated to the FEHBP. We selected these accounts based on high dollar
amounts, trend analysis, and our nomenclature review. While conducting our review, we
also selected an additional account that potentially contained unallowable expenses and
expanded our audit scope to include potential questionable items in this account for 2009.
We reviewed the expenses from these accounts for allowability, allocability, and
reasonableness.

                               Based on our review, we determined that NRLCA
    NRLCA charged              allocated and charged unallowable and/or unallocable
   unallowable and/or          expenses to the FEHBP for holiday parties and airline club
 unallocable expenses of       memberships incurred from 2009 through 2014.
  $3,933 to the FEHBP          Specifically, NRLCA allocated and charged $2,823 to the
 for holiday parties and       FEHBP for holiday parties. These parties were not
       airline club            employee morale events, but instead social events that
      memberships.             incurred expenses for items such as ice sculptures,
                               expensive food, and alcoholic beverages that are strictly
unallowable. NRLCA also allocated and charged $1,110 to the FEHBP for airline club
memberships. These club memberships provide NRLCA employees with perks and
amenities, such as the “Delta Sky Club” that offers complimentary cocktails, health food
options, and free Wi-Fi. In our opinion, airline club memberships provide no real benefit
to the FEHBP. As a result of this finding, NRLCA returned $4,238 to the FEHBP in
November 2015, consisting of $3,933 for the questioned unallowable and/or unallocable
expenses and $305 for applicable LII on these overcharges.




                                         8                           Report No. 1B-38-00-15-057
   NRLCA Response:

   NRLCA agrees with this finding.

   OIG Comment:

   We verified that NRLCA returned $4,238 to the FEHBP, consisting of $3,933 for the
   questioned unallowable and/or unallocable expenses and $305 for applicable LII.

   Recommendation 3

   We recommend that the contracting officer disallow $3,933 for unallowable and/or
   unallocable expenses charged to the FEHBP from 2009 through 2014. However, since
   we verified that NRLCA returned $3,933 to the FEHBP for these questioned charges, no
   further action is required for this amount.

   Recommendation 4

   We recommend that the contracting officer require NRLCA to return $305 to the FEHBP
   for LII on the questioned unallowable and/or unallocable expenses. However, since we
   verified that NRLCA returned $305 to the FEHBP for the questioned LII, no further
   action is required for this LII amount.

3. Benefit Plan Brochures                                                                    $1,410

   NRLCA printed an excessive amount of benefit plan brochures in 2012. As a result of
   this finding, NRLCA returned $1,410 to the FEHBP in October 2015 for the excess
   printing costs.

   48 CFR 31.201-3 (a) states, "A cost is reasonable if, in its nature and amount, it does not
   exceed that which would be incurred by a prudent person in the conduct of competitive
   business. . . . If an initial review of the facts results in a challenge of a specific cost by the
   contracting officer or the contracting officer's representative, the burden of proof shall be
   upon the contractor to establish that such cost is reasonable."

   In addition, the OPM contracting office provides guidance to the Carriers as to how many
   brochures are allowed to be printed. OPM determines the quantity of the brochures that
   NRLCA may charge to the FEHBP for each contract year. Any brochures that are
   printed over the approved quantity are not chargeable to the contract.




                                               9                             Report No. 1B-38-00-15-057
                                 For the period 2010 through 2014, NRLCA charged the
 NRLCA overcharged the           FEHBP $992,251 for the printing and mailing of benefit
  FEHBP $1,410 for the           plan brochures. Based on our review of these charges, we
   excessive printing of         found that NRLCA printed an excessive amount of benefit
  benefit plan brochures         plan brochures in 2012. Although the contracting officer
          in 2012.               only approved the printing of 87,421 benefit plan
                                 brochures in 2012, NRLCA printed 90,000 brochures. As
stated above, the cost to print benefit plan brochures over the amount approved by the
contracting officer is not chargeable to the contract. Therefore, the $1,410 cost of
printing the additional 2,579 brochures in 2012 is an unallowable charge to the FEHBP.
(Note: Since NRLCA did not mail out these additional benefit plan brochures, there were
no additional mailing costs to question. Also, we did not question LII for this finding
since the LII amount is immaterial.)

NRLCA Response:

NRLCA agrees with this finding.

OIG Comment:

We verified that NRLCA returned $1,410 to the FEHBP for the excess printing costs.

Recommendation 5

We recommend that the contracting officer disallow $1,410 for the excessive printing of
benefit plan brochures in 2012. However, since we verified that NRLCA returned $1,410
to the FEHBP for the questioned overcharge, no further action is required for this
amount.




                                       10                          Report No. 1B-38-00-15-057
IV. MAJOR CONTRIBUTORS TO THIS REPORT

    Experience-Rated Audits Group

                   , Lead Auditor

                  , Auditor

                  , Auditor




                     , Chief                  


                , Senior Team Leader 

 

 

 
 
 
 
                                                   
 




                                         11           Report No. 1B-38-00-15-057
                                                                                V. SCHEDULEA



                                                       ATIO AL RURAL LETTER CARRJE RS' ASSOCIATION
                                           AS SPONSOR A ND ADMll'IISTRATOR F OR THE RURAL CARRIER BENEFIT PLAN
                                                                    AL.EX NORIA, VffiGINlA

                                                                           Q UESTIONED CHARGES

                  AUDIT FINDINGS                               2009            2010           2011           2012           2013            2014           2015        T OTAL

A. ADMINISTRATIVE EXPE SES

    1. Self-Disclosed Cost A djustments•                              $0          ($491)          $540         $1,794           ($361)        $4,549           $223       $6,255

    2 . U nallowable and/or   nallocable Expenses"                 1,210          1,228              516            85             284             873            42       4,238

    3 . Benefit Plan Brochures                                         0              0                0         1,410               0               0             0       1,410

TOTAL Q UESTJO ED CHARGES                                 I      $1,210           $737          $1,056         $3,289            ($77)        $5,422           $ 265     $ 11 ,903


• We included lost investm ent incom e (LII) within audit findings A1 ($993) and A2 ($305). T h er efore, no additional LII is applicable for these a udit findings.




                                                                                                                                                         Report No. 1B-38-00-15-057
APPENDIX





            Report No. 1B-38-00-15-057
Furthennore, the NRLCA feels that the draft audit report sensationalizes some of the findings by
both incorporating them in summary text boxes and underlining the text in the body of the report.
We request that the emphasis (underlining) be removed from the final report.

                                            Sincerely,




                                             eanette Dwyer
                                            President
                                            National Rural Letter Cru1·iers' Association


Cc:




                                                                                     Report No. 1B-38-00-15-057
                                                                                                                       



                                       Report Fraud, Waste, and 

                                           Mismanagement 

                                                   Fraud, waste, and mismanagement in
                                                Government concerns everyone: Office of
                                                    the Inspector General staff, agency
                                                 employees, and the general public. We
                                               actively solicit allegations of any inefficient
                                                     and wasteful practices, fraud, and
                                                mismanagement related to OPM programs
                                               and operations. You can report allegations
                                                           to us in several ways:


                          By Internet:              http://www.opm.gov/our-inspector-general/hotline-to-
                                                    report-fraud-waste-or-abuse


                           By Phone:                Toll Free Number:                              (877) 499-7295
                                                    Washington Metro Area:                         (202) 606-2423


                             By Mail:               Office of the Inspector General
                                                    U.S. Office of Personnel Management
                                                    1900 E Street, NW
                                                    Room 6400
                                                    Washington, DC 20415-1100
                       
                                                                                                                       
                                                                                                                       




                                                             -- CAUTION --
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data that is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.

                                                                                                                Report No. 1B-38-00-15-057