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Panoptic Enterprises' FEDERAL CONTRACTS DISPATCH

DATE: August 26, 2003

SUBJECT: Federal Management Regulation (FMR); Mail Management

SOURCE: Federal Register, September 29, 2003, Vol. 68, No. 188, page 56111

AGENCIES: Office of Governmentwide Policy, General Services Administration (GSA)

ACTION: Interim Rule

SYNOPSIS: GSA is amending FMR 102-192.50, What must all agencies do to manage their mail effectively and efficiently?, to extend, from October 1, 2003, to December 31, 2003, the deadline for agencies to convert to commercial payment to the United States Postal Service instead of the Official Mail Accounting System (OMAS).

EDITOR'S NOTE: For more on the interim rule that established the deadline being extended, see the June 6, 2002, FEDERAL CONTRACTS DISPATCH "Federal Management Regulation (FMR); Mail Management."

The FMR is Chapter 102 of Title 41 of the CFR. The FMR is available at http://www.gsa.gov/Portal/gsa/ep/programView.do?pageTypeId=8199&ooid=10625&programPage=%2Fep%2Fprogram%2FgsaDocument.jsp&programId=9654&channelId=-13342#Chapter%20102:%20Federal%20Management%20Regulation.

DATES: The effective date of this interim rule is September 29, 2003. Comments on the interim rule must be submitted on or before November 28, 2003.

ADDRESSES: Comments should be submitted to General Services Administration, Regulatory Secretariat (MVA), 1800 F Street, NW, Room 4035, ATTN: Laurie Duarte, Washington, DC 20405; or by e-mail to: fmrcase.2003-102-1@gsa.gov. Cite "FMR Amendment 2003-2, FMR Case 2003-102-1" in all correspondence related to this interim rule.

FOR FURTHER INFORMATION CONTACT: Henry Maury, Office of Governmentwide Policy, Mail Communications Policy Division (MTM), 202-208-7928.

SUPPLEMENTAL INFORMATION: Section 2 of the Federal Records Management Amendments of 1976 (Public Law 94-575) directs GSA to provide guidance and assistance to federal agencies on records management, including the processing of mail by federal agencies.

On June 6, 2002, GSA issued an interim rule that established FMR Part 102-192, Mail Management, for this guidance (previously, GSA had provided its guidance in Federal Property Management Regulations (FPMR) Part 101-9, Federal Mail Management). FMR 102-192.50(c) contained the following:

"Beginning October 1, 2003, all payments to the United States Postal Service must be made using commercial payment processes, not OMAS [Official Mail Accounting System]." (EDITOR'S NOTE: FMR 102-192.35, What definitions apply to this part?, says "Official Mail Accounting System (OMAS) is the Postal Service's government-unique system used to track postage used by most federal agencies. OMAS is used in conjunction with each agency's online payment and accounting system (OPAC) account at the Treasury.")

The Department of Defense had successfully used this approach to make program managers accountable for mail expenditures, and DOD had experienced dramatic reductions in postage costs. GSA believed requiring this same approach would lead to similar benefits among the civilian agencies.

Shortly after GSA issued the interim rule, the Treasury Department asked GSA to reconsider its position. Treasury pointed out that commercial postage payment mechanisms use arrangements with commercial banks to replenish the postage balances maintained in the postage meters that agencies would be using. Because of the commercial fees involved, as well as the negative impact on the overall federal cash management position, Treasury asked GSA to work with the Postal Service to find a way to keep the money inside the Treasury -- that is, to have the agencies continue making payments through the Interagency Payment and Collection System (IPAC), which is how OMAS payments are made today.

GSA assembled an interagency team and worked for a year on different approaches to accomplish this. The team concluded that to satisfy Treasury's request and keep most of the money inside the government, a small number of high-volume, centrally managed federal mail programs will have to continue to use the OMAS/IPAC process for the foreseeable future.

However, GSA states in the introduction to this interim rule that it is "still committed to implementing a more accountable system for making postage payments throughout the federal government and believe that commercial postage payment processes provide the quickest and simplest way of doing this. Since the negotiation process with the Treasury, the Postal Service, and GSA has taken so long, we are extending the deadline for converting to commercial postage payment processes to December 31, 2003." GSA is doing this by substituting "December 31,2003" for "October 1, 2003" in FMR 102-192.50(c).

GSA also states in the introduction to the interim rule that "any agency planning to continue using the OMAS/IPAC system beyond December 31, 2003, will have to request a deviation. This requirement applies to agencies planning to use OMAS/IPAC indefinitely and agencies planning to convert to commercial payments after December 31, 2003. All deviation requests will be required to include a discussion of how the agency has implemented, or plans to implement, an accountable system for making postage payments. Deviation requests that do not address the agency's intentions to install such an accountable system will not be approved. Detailed information on the expected nature and level of detail of such discussions will be included in the guidance on preparing deviation requests. This guidance will be issued by e-mail and Internet publication. The web site is http://www.gsa.gov/mailpolicy."

FOR FURTHER INFORMATION CONTACT: Panoptic Enterprises at 703-451-5953 or by e-mail to Panoptic@FedGovContracts.com.

Copyright 2003 by Panoptic Enterprises. All Rights Reserved.

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