In an order issued July 2, the Postal Regulatory Commission opened a rulemaking to evaluate the Postal Service’s service performance measurement system.
As is reported regularly in Mailers Hub News, the current system does not measure service on a significant portion of the mailstream. In PQII/FY2024 (January-March), for example, only 63.81% of First-Class Mail (all commercial rate), 72.37% of Marketing Mail (mostly destination-entered), 51.60% of Periodicals (mostly outside-county), and 23.44% of Package Services (only Bound Printed Matter flats) was in measurement. Most of the remainder was excluded from measurement for one of fifteen reasons prescribed by the USPS. In its order, the PRC stated:
“By law, the Postal Service is required to maintain an objective external system for measuring service performance with respect to its Market Dominant mail products, unless the Commission approves the use of an internal measurement system. Prior to 2018, the Postal Service relied on an external measurement system for First-Class Mail single-piece letters and flats, and a hybrid external/internal measurement system for letters and flats entered in bulk. In 2018, the Commission provided approval for the Postal Service to begin replacing these former systems with an internal measurement system known as the Internal Service Performance Measurement (SPM) System.
“From a design perspective, SPM was intended to produce accurate, reliable, and representative results. When the Commission initially approved the use of SPM, the Commission noted several ongoing issues that were unresolved, but that the Postal Service was in the process of improving. The Commission’s expectation at that time was that the data on which the system relies would consistently improve in quality and quantity. However, this has not proven to be the case. The volume of mail in measurement has, in fact, stagnated. Across several dockets, commenters have described a growing divide between the service performance results reported by the Postal Service and the actual experience of mailers. These concerns have been exacerbated by recent operational changes by the Postal Service which raise questions as to whether the current operational environment is sufficiently analogous to the operational environment for which SPM was designed. In its FY 2023 Annual Compliance Determination, the Commission expressed its intention to conduct an evaluation of the accuracy and reliability of SPM and the data generated by it.
“In light of the foregoing, the Commission is opening this docket to address concerns that service performance results as reported by SPM may not accurately represent customer experience for the country as a whole. The Commission intends to review SPM to gain an understanding as to whether the design and implementation of SPM continues to produce accurate, reliable, and representative results in the current operating environment, as the law requires. If this review reveals that SPM is not producing accurate, reliable, and representative results, then the Commission’s intent is to identify changes to SPM’s design and implementation that would bring it into alignment with legal requirements. If such changes are not feasible, then the Commission will have to consider whether it is necessary to return to external service performance measurement. … “… [T]he service performance results produced by SPM are an amalgamation of granular and siloed evaluations of performance for the individual segments of mail collection (First Mile), mail processing (Processing Duration), and mail delivery (Last Mile). Given recent changes in operations and mail mix, the Commission has concerns about the continued validity of the design and implementation of each of these three systems, as well as how the systems function collectively as a whole.”
Twenty of the order’s 53 pages were used to detail the commission’s concerns with the current system, including:
- “the continued validity of a specific aspect of the design of First Mile sampling, which is that the current system was designed to exclude from direct sampling all mail that is entered at customer mailboxes, rather than collection boxes or retail facilities”;
- “the percentage of eligible mail that is excluded from measurement; the persistent causes of exclusion that are attributable to the Postal Service’s operations and data systems; and the lack of information on mail that is processed outside the automation mailstream”;
- “the reported explanation for why billions of pieces of First-Class Mail Presort letters and flats and USPS Marketing Mail have been excluded from measurement”;
- “the Postal Service has made little progress in addressing the issues surrounding reasons for exclusion from measurement”;
- “the possibility of non-sampling error caused by the intentional exclusion of mail that is not processed in the automation mailstream”;
- “when the “Start-the-Clock” event occurs for purposes of Processing Duration measurement”;
- “a seeming disconnect between the number of delivery points selected for inclusion in Last Mile sampling and the number of delivery points with sample responses that were deemed valid”;
- the possibility of non-robust measurement results due to the Last Mile Sample size and the possibility of bias due to the considerable number of delivery points that are excluded from it”;
- “the continued exclusion of all mail that does not have a last processing operation scan to establish a timeline for the Last Mile”;
- “how the segments collectively interact to produce an end-to-end measurement of service performance”; and
- “the possibility that the reported end-to-end measurements could be biased towards mail volume with characteristics that make it disproportionately likely to receive better service.”
The commission noted that comments – due September 11 – can address any matter “within the scope of this proceeding,” and it offered “specific topics on which it would particularly appreciate comment”:
- Is SPM in its current state producing accurate, reliable, and/or representative measurements of the Postal Service’s service performance? If not, what specific aspect of SPM’s design and/or implementation is causing service performance measurement to be inaccurate, unreliable, and/or unrepresentative?
- Are there modifications that could be made to SPM in its current state that would result in it being more accurate, reliable, and/or representative?
- Are there alternative measurement systems (either external or internal) that would be more accurate, reliable, and/or representative than SPM?
Given ratepayers’ interest in USPS service, and the gap between what the agency claims and what’s reported by external entities that measure performance independently, the PRC’s attention to the USPS service performance measurement process is both timely and welcomed. That’s likely less true for the Postal Service itself; under Postmaster General Louis DeJoy, it’s become more important to spin information into favorable publicity than to objectively state the facts.
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