NLRB's Own Auditor: The Staffing Numbers It Gave Congress Were Wrong
Summary
A National Labor Relations Board Inspector General audit found that the spreadsheet formula the agency uses to decide how many caseworkers each of its 26 regional offices gets does not meet federal budgeting standards and lacks basic internal controls -- and that the resulting staffing figures NLRB reported to Congress in its own budget justification were themselves inaccurate. Over nine years of an appropriation frozen at the exact same $274,224,000, Regional Office staff fell 35% while every other part of the agency grew, and the payroll cost per case rose 36%.
Nine years, the exact same number
NLRB's annual appropriation was $274,224,000 for FY2014 and $274,224,000 for FY2022 -- and every year in between. Deflating that figure for inflation, the OIG calculated⧉ that the FY2022 appropriation was worth $40.1 million less, in FY2014 real dollars, than its face value. Framed the other way, NLRB would have needed roughly $47 million more in FY2022 -- about 17% more than it actually got -- just to preserve FY2014's real spending power. The Division of Operations-Management's written response didn't dispute any of it: it "wholeheartedly agrees" the flat appropriation amounted to real cuts, and that the agency should have been funded at least $321.2 million in FY2022 to keep pace.
View data as table
| Enacted appropriation, every year FY2014-FY2022 | 274,224,000 | the identical dollar figure enacted nine years straight |
|---|---|---|
| FY2022 appropriation, in FY2014 real dollars | 234,100,000 | same $274.224M, deflated for inflation |
| What FY2022 needed to match FY2014 buying power | 321,200,000 | OIG estimate; DOM agreed it should have been at least this much |
Field offices shrank. Everywhere else grew.
The compared agency staffing at the start and end of the level-funding period. Regional Office FTEs -- the caseworkers, supervisors, and administrative staff who actually process unfair-labor-practice charges and union representation petitions -- fell from 1,087 to 709, a 35% drop. Every other position at the agency, mostly headquarters, grew 2%, from 481 to 491. Agency-wide, that nets out to a 23% overall staffing decline concentrated almost entirely in the field. Regional payroll and benefits expenses fell 8.46% over the period; every other category of payroll and benefits expense rose 28.56%. The Division of Operations-Management's own written response offers context, not a rebuttal: it points to a formalized headquarters branch, an expanded Ethics Office, a new E-Litigation Branch, and centralized decision-writing and compliance work, all of which moved positions out of the field count and into headquarters -- plus a FY2018 early-retirement program that, the division says, hit Field staff harder than headquarters.
View data as table
| Regional Offices | -35% | 1,087 -> 709 FTE, a loss of 378 |
|---|---|---|
| All other positions (incl. headquarters) | 2% | 481 -> 491 FTE, a gain of 10 |
| Agency-wide | -23% | 1,568 -> 1,200 FTE, a loss of 368 |
One consequence of that imbalance: even though headquarters and other non-Regional positions grew only 2% in raw headcount, their share of the agency's total staffing rose from roughly 30.7% of all FTEs in FY2014 to roughly 40.9% by FY2022 -- because the Regional cuts were so much steeper than any headquarters growth. Regional Office FTEs also fell more than three times as fast as Regional case intake did over the same period: a 35% staffing decline against an 11% caseload decline.
Fewer cases, higher cost per case
The math shows up in the price. Regional payroll and benefits expenses per rose from $127,423 in FY2014 to $173,163 in FY2022 -- up $45,739, or 36% -- even as the Regional caseworker corps shrank 33% and Regional case intake fell 11%, from 23,100 cases to 20,512. The 's own year-by-year figures for Regional payroll and benefits cost per case received show the number climbing well above its FY2014 level of $5,885.70, peaking at $7,485.12 in FY2021 (a pandemic-depressed low in case volume), and still sitting at $6,067.77 in FY2022 -- above where it started nine years earlier, even as the raw headcount doing the work kept shrinking.
View data as table
| FY2014 | 5,885.7 | 23,100 cases received |
|---|---|---|
| FY2018 | 6,255.9 | 20,954 cases received |
| FY2021 (period peak) | 7,485.1 | 16,720 cases received -- pandemic-era low |
| FY2022 | 6,067.8 | 20,512 cases received |
The formula had errors -- and so did what NLRB told Congress
The didn't just flag the methodology; it found the spreadsheet implementing it was broken. Three regions had formula errors traced to cells manually copied from one to another: Region 14's calculation referenced the wrong data entirely; Region 16's overstated its case intake by pulling in FY2022 numbers for a FY2018 calculation and left out R cases altogether; Region 27's borrowed case data from a different region. Separately, comparing the division's staffing spreadsheet to actual payroll records from the Office of Human Resources, the found mismatches in nine more regions -- board-agent and supervisor counts off by as much as 2.5 -- which it attributed to the division maintaining staffing data by hand instead of pulling from the agency's own payroll system.
Applying GAO's Standards for Internal Control in the Federal Government⧉, the found the staffing-calculation process failed standard after standard: no documented risk analysis, no control activities, no reliable internal data source, no quality-information processing. The sharpest finding sits in how that data leaves the building: NLRB's Budget Branch relies on the division's Field Office calculation to report Requested, Enacted, and Actual figures to Congress' Committee on Appropriations in its annual budget justification. The 's conclusion: "We found that information reported was inaccurate because we found errors in the Field Office calculation and the Field Office calculation methodology."
The Division of Operations-Management agreed with three of the 's four recommendations -- it says it had already found and fixed the three formula errors by the time the audit closed, and committed to building a formal internal-control process by the end of the first quarter of FY2025. It disagreed with the recommendation to reconsider the underlying formula itself, defending the 45-cases-per-Board-Agent standard as the product of years of experience and a stated consensus among regional directors, and noting that case intake had begun climbing again by FY2022 and FY2023 alongside new field hiring surges.
- NLRB's appropriation was $274,224,000 in FY2014 and $274,224,000 in FY2022 -- the identical figure for nine straight years. Inflation-adjusted, the calculated that eroded roughly $40-47 million in real spending power.
- Regional Office FTEs fell 35% (1,087 to 709) while every other agency position grew 2% (481 to 491) -- headquarters' share of total agency staffing rose from about 31% to about 41% as a result.
- Regional payroll and benefits cost per rose 36% ($127,423 to $173,163) even as the Regional workforce shrank 33% and case intake fell 11%.
- The found spreadsheet formula errors in 3 regions and staffing-vs-payroll data mismatches in 9 more, tracing both to a manual process with no data-quality checks.
- The 's sharpest finding: the figures NLRB reported to Congress' Committee on Appropriations in its own budget justification were inaccurate, as a direct consequence of the formula and data errors.
- NLRB's Division of Operations-Management agreed to fix the process (three of four recommendations) but rejected the recommendation to reconsider the underlying 45-cases-per-Board-Agent formula itself.
Figures are drawn from the NLRB Office of Inspector General's audit, Performance Based Staffing (-AMR-102-24-02, issued March 22, 2024), read in full via direct PDF fetch from nlrb.gov -- the 's own domain -- including the Division of Operations-Management's full written response, attached as Appendix B. A blind adversarial verifier, working from the primary document alone with no access to this draft, independently checked every itemized fact; see verification.json.
The -vs-caseload ratio, the real-funding-gap share of the base appropriation, and the headquarters share-of-total- shift are this outlet's own arithmetic on the source document's own directly-stated numbers (methods and caveats in analysis.json); none of the three appears pre-computed in the source. Every finding in the underlying report is attributed to an office (the Division of Operations-Management, the Budget Branch, the Office of the Chief Financial Officer, individual Regions by number) or a role, never to a named person as a wrongdoer -- the division's written response is signed by its Associate General Counsel in an official capacity, not cited here as an individual finding.
Sources(2) ▾
- National Labor Relations Board, Office of Inspector General, Performance Based Staffing (OIG-AMR-102-24-02) (2024-03-22) — NLRB-'s own performance audit is the sole source for: the FY2014-FY2022 Field Office -allocation methodology and its finding that the methodology does not meet Circular A-11 requirements on any of seven applicable criteria; the finding that the Division of Operations-Management's -calculation process lacks an appropriate system of internal controls under 's Standards for Internal Control in the Federal Government (Appendix A); the flat $274,224,000 appropriation for FY2014-FY2022 and its inflation-adjusted erosion; the Regional Office vs. all-other trend data; the Regional payroll-and-benefits-per- and per-case-received figures; the three Regions (14, 16, 27) with spreadsheet formula errors and the nine Regions where the Division of Operations-Management's staffing data did not match Office of Human Resources payroll data; the finding that information NLRB reported to the House and Senate Appropriations Committees in its annual budget justification was inaccurate as a result; the COVID-19 case-intake adjustment methodology; the four recommendations; and the Division of Operations-Management's full written response (Appendix B), including its disagreement with Recommendation 2 and its explanation for headquarters staffing growth. nlrb.gov · original document
- National Labor Relations Board, Office of Inspector General, Inspector General Hotline (2026-07-20) — Used only to source the CTA hotline contact (cta.json). nlrb.gov · original document
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The National Labor Relations Board's Office of Inspector General⧉ audited the formula the agency's Division of Operations-Management uses to decide how many caseworkers each of NLRB's 26 regional offices needs. The 's conclusion: the methodology does not meet Governmentwide ( Circular A-11) budgeting standards, and the process behind it lacks an appropriate system of internal controls. Over the nine fiscal years the audit examined -- FY2014 through FY2022, during which NLRB's appropriation stayed at the identical $274,224,000 every single year -- Regional Office staff fell 35% while the rest of the agency grew, and the found that the staffing figures NLRB reported to Congress' Committee on Appropriations were, as a direct result, inaccurate.