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- Aon Consulting Submits Paper to Commission on USPS employee benefits-AON Consulting asserts Employee benefits, including paid leave, represent a very substantial portion of USPS’ total compensation paid to employees.-7/6/03
Below is the text version of a letter
submitted to the Postal Commission by NALC President William Young. The
complete PDF (997k) file can be found by clicking
Pay Comparability
(National Association of Letter Carriers and Professor James L. Medoff,
Harvard University) 
A Response to the Testimony of Thomas Rand to the President’s Commission on the United States Postal Service by the National Association of Letter Carriers
July 2, 2003
Mr. James A. Johnson and Mr. Harry J. Pearce Co-Chairs
President’s Commission on the U. S. Postal Service
1120 Vermont Avenue, NW Suite 971
Washington, D.C. 20005
Dear Mr. Johnson and Mr. Pearce:
I want to thank you for soliciting the response of James Medoff (to the testimony of Michael Wachter and posting it along with my cover letter of May 29, 2003 on your web site. Your willingness to consider both sides of the debate on pay comparability is much appreciated. In that spirit, I wish to submit the attached response to the testimony of Thomas Rand, who appeared before the Commission on May 28th in Washington, D.C. Like Dr. Wachter, Mr. Rand has been a management-side witness in postal interest arbitrations. As with wages, the Commission will be able to achieve a more complete understanding of the issue of benefit comparability and the enormous complexity of the issue by considering a broader range of evidence.
Before briefly drawing your attention to the key points in the attached, I would like to clear up a misconception about USPS benefits. The Postal Reorganization Act (PRA) does not forbid the Postal Service and its unions from negotiating over employee benefits. In fact, the PRA -- Title 39, Section 1005(f) -- contemplates “variations, additions, or substitutions” with respect to fringe benefits. The parties have voluntarily maintained their participation in most of the government-wide benefit programs while negotiating the details of coverage. For example, the parties have negotiated cost-sharing provisions for health benefit premiums since the early 1970s. Nevertheless, the parties realize, and the Commission should understand, a decision to withdraw from these government-wide benefit programs would adversely affect these programs and would prompt bi-partisan political opposition in Congress.
The attached response deals with Mr. Rand’s testimony in greater detail, but I wish to highlight a number of important points:
Rand’s conclusion that postal benefit costs dramatically exceed private sector benefit costs is erroneous because: (1) his analysis does not control for key factors such as firm size, industry and other relevant variables, and (2) the database he relies on, the Employer Costs for Employee Compensation series (ECEC) from the BLS grossly understates the actual benefit costs of private sector employers. It does this by including large numbers of small and medium size businesses (which are by definition not comparable to the Postal Service) that provide few if any fringe benefits typically provided by large employers like the Postal Service. The resulting average costs are misleadingly low due to the inclusion of employers with zero or limited benefit costs.
The ECEC series cited by Rand demonstrates the importance of controlling for industry. Although the series offers few industry breakdowns, it does include one for the Pubic Utilities and Communications (PUC) sector of the economy, which is made up of network industries that are fairly comparable to postal services. The data shows that benefit costs for blue collar workers in PUC industries stood at $9.94 per work hour in December 2002 -- a figure that is roughly comparable to the $10.17 figure for full-time postal employees. The PUC figure is 58% greater than the average figure for all full-time workers in private industry that Rand compared to postal benefit costs – even though it includes part-time workers (who often receive reduced benefits) and workers whose firms do not provide benefits. Postal benefits are comparable when a fair standard is used.
On retirement benefits, Rand suggested that private employers are increasingly adopting defined contribution plans but failed to make it clear that the federal government, which includes the USPS, has already done so. FERS, the plan for postal employees hired after 1984 which covers 70% of the postal workforce, has a large defined contribution component. Rand incorrectly asserted that both FERS and CSRS provide “unlimited protection against inflation.” In fact, FERS does not provide cost-of-living adjustments (COLAs) to early retirees (those retiring before 62) and typically pays less than the rate of inflation (CPI minus one percent). Although FERS and CSRS provide good pension benefits, including benefits for early retirees, many very large private companies do so as well.
On health benefits, Rand cited a Mercer study that shows private sector employees pay a much higher share of premiums than postal employees (31% vs. 16.5%). But there is no indication that the firms surveyed by Mercer are comparable to the USPS or that the workers covered are comparable to postal employees. Data on employer-provided health plans collected by the U.S. Department of Health and Human Resources shows that employees of large firms (those with 1,000 employees or more) pay an average of 18.4% for self-only coverage and 20.5% for family coverage. (The figures for such employees in the “utilities and transportation” sector are even lower: 10.5% and 14.4% respectively.)
Rand failed to address the benefits of truly comparable workers employed by other national delivery firms. If the Commission compares the benefits of full-time employees of the USPS with those of similar workers at United Parcel Service and Federal Express, it will conclude that postal benefits are comparable, not excessive.
I request that you post the attached response on your web site alongside the Medoff statement on pay comparability. I am confident that it will aid you and your colleagues as you grapple with the issues covered by your May 28th hearing. Thank you again for your time and consideration.
Sincerely,
William H. Young
President
cc: Members of the President’s Commission on the U.S. Postal Service
Executive Director Dennis Shea
Postal Service Benefit Costs:
A Response to the Testimony of Thomas Rand to the President’s Commission on the United States Postal Service by the National Association of Letter Carriers
By James Sauber and Amy O’Hara[1]
At its hearing on May 28, 2003, the President’s Commission on the United States Postal Service invited Thomas Rand, a long-time compensation consultant to (and arbitration witness for) the Postal Service, to make a presentation on postal employee benefit costs. Rand argued that USPS employees “realize a significant benefits premium compared to the private sector.” He stated that “the cost of benefits provided USPS employees exceeds the cost of benefits provided full-time employees in the private sector by 61 percent." (See page 2 of his testimony.) He went on to present selected evidence on USPS retirement and health benefits that purported to demonstrate their excessive cost. NALC strongly disagrees with Rand’s conclusions and submits this response to give the Commission a more complete understanding of the issue of postal employee benefits.
Overall Comparability
Rand’s claim of a 61% benefits premium results from a comparison of average USPS benefit costs to data on private sector benefit costs compiled by the Bureau of Labor Statistics (BLS) and published quarterly in its Employer Costs for Employee Compensation (ECEC) series. The ECEC series is a useful database, but it is inadequate for the task of measuring benefit comparability for a single enterprise like the USPS. Average benefit levels for full-time workers in the private sector as measured by the ECEC cannot serve as standards for determining comparability, particularly when these average levels are depressed due to the statistical inclusion of millions of workers employed by tens of thousands of small businesses that provide few (if any) benefits. Such businesses are clearly not comparable to the USPS and should not be included in the analysis.
A responsible analysis of USPS employee benefit levels would exclude small firms and companies that fail to offer many fringe benefits. It would also control for industry and other relevant factors. The ECEC series unfortunately precludes such an analysis. The ECEC does, however, offer data on industries that are highly comparable to the USPS – the Public Utilities and Communications (PUC) group of industries.
This group (which combines Standard Industrial Classification codes 48 and 49) is comprised of network industries that are comparable in that regard to postal services, including the electricity, gas, sanitary services and telecom sectors. The ECEC data for the PUC sector is provided in Table 16 of its quarterly release.[2] A breakout of that data provided on the next page shows that the cost of benefits per work hour in the Public Utility and Communications sector is much greater than the average cost for full-time private sector workers in general. Indeed, the average $9.39 per work hour cost of benefits in PUC industries is nearly 50% greater than the average private sector figure cited by Rand. If we focus on blue collar workers in the PUC sector, the average rises to $9.94 per work hour. At $10.17 per work hour, USPS benefit costs are roughly comparable to those paid to workers in PUC group of industries, even without controlling for firm size and other relevant factors. The benefit premium Rand alleges virtually disappears by simply adopting a more appropriate comparison group. It would diminish further if we limited our comparison to full-time PUC workers and disappear completely if we controlled for firm size.
Postal employee benefits are greater than average private sector benefits because large firms pay greater wages and benefits, as the work of Harvard’s James Medoff clearly shows. (See Medoff’s May 29, 2003 statement to the Commission.) This large employer effect is clear in Rand’s own presentation. Handout Page 4 presents data from the 2002 Hay Benefits report. The Hay report is based on a survey of medium and large employers. The 25% gap between the value of USPS and private sector benefits in this report is much smaller than the 61% premium suggested by the ECEC data in Rand’s presentation. Of course, Rand presented no evidence that the Hay survey involves companies that are “comparable” to the USPS and the survey suffers from the same flaw as the ECEC – average benefit levels derived from it are artificially reduced by including companies that do not provide the fringe benefits provided by the Postal Service (and other national delivery companies). Nevertheless, Handout 4 does demonstrate the so called size effect.
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Rand Testimony, Handout Page 3 Cost per Work Hour |
Alternative BLS Comparison Cost per Work Hour * |
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Benefit |
USPS Full-Time |
BLS- Full-time Private Workers |
Public Utilities & Communications |
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All workers |
Blue-collar |
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Retirement |
$2.55 |
$0.80 |
$1.27 |
$1.46 |
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|
|
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|
Health Care |
$2.52 |
$1.70 |
$2.64 |
$2.80 |
|
|
|
|
|
|
|
Paid Leave |
$3.70 |
$1.80 |
$3.33 |
$3.55 |
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|
|
|
|
|
|
Medicare/Social Security |
$1.40 |
$2.00 |
$2.06 |
$2.05 |
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|
|
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|
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Life Insurance |
$0.15 |
$0.12 |
$0.09 |
$0.08 |
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|
|
|
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Total Cost Per Work Hour |
$10.17 |
$6.30 |
$9.39 |
$9.94 |
|
Source: Rand testimony and unpublished data from the Bureau of Labor Statistics.* * In its published data on Public Utility and Communication workers, the BLS combines health and life insurance into an “insurance” category while Social Security and Medicare are combined with other legally required benefits. See Table 16 of the March 18, 2003 release of the ECEC series. NALC requested and received from the BLS unpublished and disaggregated data to present the data in the same way it is presented in Handout Page 3 of the Rand testimony. The unpublished data provided a further breakdown by white- and blue-collar employees. |
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Retirement benefits
As Rand testified, the Postal Service participates in two government-wide defined benefit plans, the Civil Service Retirement System (CSRS) and the Federal Employees Retirement System (FERS). What he did not make clear, however, is the key distinction between the two. Specifically, the FERS defined benefit is much less generous than the CSRS defined benefit as a matter of design since it supplements Social Security and a defined contribution plan (TSP). FERS was constructed to mirror so-called “three-legged” retirement plans offered by large employers in the private sector. In other words, Congress specifically designed FERS to be comparable to plans offered by large national employers as a matter of national public policy. As the nation’s second largest employer, the USPS would be expected to offer such a comparable plan.
Rand stated that both CSRS and FERS provided “unlimited protection against inflation.” While that statement is true for CSRS beneficiaries, it is misleading with respect to postal employees hired since 1984, the 70% of postal employees covered by FERS. Not only does FERS provide reduced cost-of-living adjustments (COLAs) that are indexed to the CPI minus one percent (as Rand acknowledged), but it also denies COLAs to retired workers until they turn 62 years old (a point Rand overlooked), up to seven years after they retire. This distinction is important since CSRS is being phased out in favor of FERS.
Rand went on to testify that only 51% of the firms included in the Hay Group 2002 Survey offered a defined benefit plan such as the FERS basic annuity plan. The implication was that defined contribution plans are the preferred option. However, the 2002 Hay Benefits Report indicates that among the category of largest firms (10,000 employees or more), 71 percent offered defined benefit plans. The Postal Service is a large employer and its employee compensation should be compared to that paid by other large employers. Moreover, it must be emphasized that FERS is made up of a modest defined benefit component and a defined contribution component. To the extent that defined contribution plans represent the wave of the future, FERS has led the way for nearly twenty years.
Finally, Rand testified that early retirement added 32% to the cost of FERS relative to all firms that offered defined benefit plans. However, this figure would be significantly reduced if the focus were placed on the largest employers. Again, according to the 2001 Hay Benefits Report, some 60% of the firms with at least 10,000 employees permitted workers to retire before the age of 65 without a reduction in benefits. (See page 10 of the 2002 Employee Benefit News Benefits Barometer produced by AdvancePCS.)
Health benefits
Rand’s testimony on health benefits addressed two issues: the comparability of active employee health benefits and the rising cost of retiree health coverage.
On the first issue, Rand cited a National Survey of Employer-Sponsored Health Plans in 2002 conducted by Mercer Human Resource Consulting to argue that postal employee health benefits are more generous and require a lower employee contribution than benefit plans in the private sector (16.5% vs. 31%). However, again, the Mercer survey covers firms with as few as 10 employees. It is clear that larger firms offer better benefits and pay a much higher percentage of premium costs compared to smaller firms. It is startling that Rand ignored this obvious factor. The USPS share of premium costs are certainly not out of line when compared to other large companies.
In 2000, the Agency for Healthcare Research and Quality[3] found that workers employed by firms with 1,000 or more employees paid an average of just 18.2% of total premium costs for self-only coverage and 20.5% for family coverage. For the industry most comparable to the Postal Service, utilities and transportation, the contribution rates were even lower, 10.5% and 14.4% respectively. These rates of employee contributions reported in government data are far below the 31% average from the Mercer survey cited by Rand and are very close to the 16.5% average paid by USPS employees.
With regard to retiree health coverage, Rand noted that the Postal Service is now spending nearly $1 billion per year on retiree health care costs – 1.5 percent of the Postal Service’s $65 billion operating budget. Rand observed that companies in the private sector are moving to reduce their coverage of retirees in a variety of ways. The plain fact of the matter is that a significant majority of large employers continue to provide retiree health insurance. The 2001 Hay Benefits Report indicated that 60% of employees who retired from firms with more than 10,000 employees have employer-provided coverage and 68% of early retirees from such firms retain coverage. As for cost-sharing, the Postal Service covers about 70% of the cost of retiree premiums. This is roughly comparable with the results of the Kaiser-Hewitt Retiree Health Survey (2002) which found that employers pay 60% of retiree premiums on average. This survey of large firms (those with at least 1,000 workers) notes that one-fifth of these employers still pay 100% of the premiums.
Following Rand’s testimony, many members of the Commission focused on the large unfunded liability of future retiree health benefits and raised the possibility of requiring the USPS to pre-fund these benefits. This would be unwise. Projecting future health benefit costs is nearly impossible and unlike pension benefits, future health benefits are not vested. As the Cost Accounting Standards Board of the Office and Management and Budget has observed in proposed regulations related to the retirement costs of federal contractors: “The Board remains concerned that the volatility of health care trends, coupled with the SFAS 106 emphasis on current market conditions, could create an unacceptable degree of uncertainty in the estimates of the liability for future post-retirement [health] benefits” and notes how this uncertainty could adversely affect pricing decisions in the future. (Federal Register, October 5, 2000, proposed changes to 48 CFR Part 9904, p. 59525)
Perhaps in view of this problem, the Financial Accounting Standards Board does not require private sector companies to pre-fund retiree health benefit liabilities and most companies do not do so. At a time when the Postal Service has finally escaped the burden of miscalculated pension liabilities with the passage of the CSRS funding reform legislation, it would be a disappointing irony to repeat the mistake with even more difficult-to-predict health care costs.
Mandating pre-funding would place the Postal Service at a competitive disadvantage with firms that provide alternatives to the mail and do not pre-fund such obligations. This may further divert volume from the mail stream and distort the competitive balance in areas of the market where the USPS provides a welcome alternative to market-dominant providers of express and parcel services.
Conclusion
NALC acknowledges that certain aspects of USPS benefits are generous in comparison with those found in the private sector. Like all other federal employees, postal employees do enjoy a higher number of paid holidays; most private sector workers do not get all ten federal holidays off with pay. And the postal retirement plans, which cover all federal employees, certainly provide good benefits. But most of the largest employers in the country provide superior paid leave benefits and solid pension benefits as well. NALC believes it is entirely appropriate for the federal government to reflect this fundamental reality.
As in the case with wages, the level of benefits paid to workers by other national delivery companies is the most appropriate basis for making judgments about benefit comparability. UPS and FedEx provide comprehensive pension and health care benefits as well as the full range of other fringe benefits provided by the USPS. Even a cursory review of benefits payable to delivery personnel employed by UPS and FedEx will demonstrate the comparability of letter carrier benefits.[4] The Rand testimony ignores the benefits payable to workers employed by truly comparable private sector firms such as FedEx and UPS. Thus, the evidence cited by Rand is both fundamentally flawed and strikingly incomplete.
Postal and federal employee benefits reflect historical judgments made over many decades by Congresses and administrations of a wide variety of political and ideological persuasions. If those judgments are to be revisited, it must be done on the basis of a far more searching approach than the one provided by Mr. Rand. Rand’s presentation and this response to it demonstrate the complexity of making fair judgments about the proper level of postal employee benefits. This is precisely why NALC believes that collective bargaining remains the most appropriate forum for making decisions about comparability.
[1] James Sauber is Research Director of the National Association of Letter Carriers (NALC) and may be reached at jsauber@nalc.org. Amy O’Hara is a Research Economist at NALC and may be reached at .
[2] See page 20 of the March 18, 2003 release of the BLS ECEC for December 2002 cited by Rand.
[3] 2000 Employer-Sponsored Health Insurance Data. Private-Sector Data by Firm Size, Industry Group, Ownership, Age of Firm, and Other Characteristics. November 2002. Agency for Healthcare Research and Quality, Department of Health and Human Services, Rockville, MD.
[4] See NALC Exhibits 98 and 99 of the 1995 Stark Interest Arbitration proceedings. Copies are available upon request.
source: Postal Commission website
Below is the text version of a letter
submitted to the Postal Commission by NALC President William Young. The
complete PDF (997k) file can be found by clicking
Pay Comparability
(National Association of Letter Carriers and Professor James L. Medoff,
Harvard University)
May 16, 2003
Mr. James A Johnson and Mr. Harry J. Pearce
Co-Chairs
President's Commission on the U.S. Postal Service
1120 Vermont Avenue, NW
Suite 971
Washington DC 20005
Dear Mr. Johnson and Mr. Pearce:
Thank you for giving me a second opportunity to testify before The President's Commission on the U.S. Postal Service on behalf of the National Association of Letter Carriers.
It is clear that you and your fellow Commissioners are taking your mandate to consider the future of the U.S. Postal Service very seriously. Candidly, I have been very impressed with the knowledge you have accumulated in such a short period of time, which has been reflected in the questions you and your colleagues have posed to me and to other witnesses. You are clearly doing everything you can to solicit and analyze as much information as possible in preparation for your recommendations, which could well determine the future viability of the Postal Service
After returning from Chicago hearing, I recalled a paper which I believe could be helpful to your efforts. The paper, which I have enclosed, is entitled "U.S. Postal Service Collective Bargaining: Is the Grass Greener on the Other Side of Interest Arbitration?" It was written by NALC Research Director James Sauber and was presented at the Tenth Conference on Postal and Delivery Economics held in Amsterdam, Germany in June 2002. This annual international conference is sponsored by the Rutgers University Center for Research in Regulated Industries and attracts academics, postal regulators, industry professionals and government officials from all over the world. The paper was among those selected for publication and is included in the volume Postal and Delivery Services: Delivering on Competition, edited by Michael Crew and Paul Kleindorfer and published in 2002 by Kluwer Academic Publishers
The paper provides a brief history of postal collective bargaining and shows how all the major postal stakeholders-rate-paying customers, federal taxpayers, postal managers and postal employees -have benefited from the use of interest arbitration. To be more specific, it demonstrates that since the parties first resorted to interest arbitration in 1978, real postage rates (adjusted for inflation) have declined even as taxpayer subsidies were phased out and postal employees shared modestly in the efficiency gains achieved by the Postal Service.
I ask that you share the paper with your colleagues on the Commission
If the National Association of Letter Carriers can be of further assistance, please do not hesitate to contact me, I wish you the best in your deliberations.
Sincerely,
The Postal Commission is analyzing the collective bargaining model- HTML version courtesy of Ninth Street Rag
William Young, NALC President Urges Postal Commission to 'Tread Lightly' on Changing Bargaining Structure-4/29/03