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Understanding Changes to the Debt Collection Process
By Al Lum
NAPS DDF provider, Labor Relations Admin Group, LLC
In late 2019 to early 2020, the Postal Service began implementing changes to procedures for handling debts the agency claimed were owed by nonbargaining-unit employees. The latest edition of the Employee and Labor Relations Manual (ELM) 49, September 2020, reflects the changes.
Overall, debt-collection procedures remain the same. You first are issued a letter of debt determination (LODD), which is followed by the Notice of Involuntary Administrative Salary Offset Under the Debt Collection Act. The LODD has been revised; the changes are outlined in ELM 49, Section 452.2, “Voluntary Repayment Procedures.”
Previously, when an employee received an LODD, they were given several options to respond. Those included a request for reconsideration of the debt, a request for records supporting the Postal Service claim for the debt and, if the employee did not contest the debt, repayment options.
The two significant changes are eliminating the request for reconsideration and, now, the LODD and Notice of Involuntary Administrative Salary Offset are issued from the Office of Accounting Services (USPS Disbursing Office, Eagan, MN). Your manager no longer issues the letter or notices.
In the revised LODD, there no longer is language stipulating an employee can request records on which the postal official relied to determine the debt. However, the employee can request postal records (see ELM 49, 452.241).
The LODD states you should make payment within 15 days from receipt of the letter, otherwise, “the debt may be considered delinquent and subject to collection under the Debt Collection Act and its associated regulations.” This language is very intimidating. However, the agency cannot begin the process of collecting the debt until you are issued the Notice of Involuntary Administrative Salary Offset.
Once an employee receives the Notice of Involuntary Administrative Salary Offset, I, as your DDF provider, have 15 calendar days from the day of receipt to file the petition to the judicial office. If you have requested records and still are waiting for a response, I still have to file the petition within the 15 calendar days. Otherwise, it would be untimely.
Stay well, be safe.