General Services Administration Regulatory Secretariat (MVRS) Office of Governmentwide Policy 1800 F Street, NW Washington, DC 20405

The head of the agency or a designated official signs the request. For mail deviation requests, the designated official should be someone with nationwide responsibility for the entire agency's mail.

FMR 102.192.50(c) Went into effect October 1, 2003. All agencies should have a deviation on file with Mail Management Policy. When your agency determines the transition to commercial payment for postage is extremely complicated, file a deviation within notification of 102.192. If you have not converted to the commercial payment process and we have not granted you a deviation, GSA's Mail Management Policy Team will be happy to meet with you to discuss any concerns you may have.

Federal Management Regulation, 41 CFR 102-2, Subpart A, Regulation System. The specifics on deviations are in 102-2.60 through 102-2.110.

Mail deviations are only granted for a maximum of two years. Hopefully, most agencies that are converting to commercial payment processes will not need that much time.

Regardless of whether your agency or part of your agency is planning to convert to commercial payment processes or to continue using the Official Mail Accounting System for the foreseeable future, your request must include:

• Citation of the specific Federal Management Regulation provision from which you wish to deviate, which for the commercial payments requirement in the mail regulation is 41 CFR 102-192.50(c);
• Point of contact at your agency;
  • A rationale for the request;
  • A proposed timeframe for the deviation;
  • A statement of whether you are converting to commercial payment processes or not (If only parts of your agency are converting, then identify the parts of the agency that are and are not converting);
  • A discussion of the results that you expect to achieve; and
  • A discussion of how you have implemented, or plan to implement, an accountable system for making postage payments.

For agencies or parts of agencies planning to convert to commercial payment processes, your deviation request must also include a plan, with milestone dates, showing the steps the agency will take to prepare for, implement, and follow up on the conversion.

The Mail Management Regulation requires that all agencies "Ensure that mail costs are identified at the program level." The objective of this requirement, as well as the requirement to use commercial payment processes, is to make the "cost-causer" responsible for the expense. That is, the program official who causes postage to be used should have a separate postage budget and should have to pay for the postage from those funds.

You should, of course, only push the budget and payment responsibility down to a reasonable level. How far down you do will depend on the complexity and sophistication of your budget and finance processes and how much each program spends on mail.

The objective in identifying mail costs at the program level is to make the person in charge of each program accountable for the postage that they incur. In agencies using OMAS, this can only be done indirectly, because the actual funds are obligated at the agency level. Even in these agencies, however, we expect the deviation request to discuss how program managers are made aware of, and responsible for, the postage that they incur.

If the agency does not already have a process for making program officials accountable for postage, then your deviation request should discuss the agency's plans to identify mail costs at the program level and make program managers accountable for those costs.

To develop a rationale, a timeframe, and a plan, you will need a fairly detailed analysis of meter locations and volumes, permit usage, what your agency mails, and who within the agency generates large volumes of mail. To the extent that you develop this information, providing it as part of the deviation request will help us analyze the request. If information like this is not currently available, then your request should include your plan to develop it.

We would also urge you to discuss quantifiable measures that you will use to track progress in implementing and using your accountable system. Implementation measures might include percent of meters converted, percent of postage assigned to specific program officials, etc. The GSA mail policy website, http://www.gsa.gov/mailpolicy, provides a list of performance measures for mail operations and management.

Yes. For example, let's say that all of your bureaus except one expect to be able to convert by December 31, 2003, but one bureau needs more time. Your deviation request would then reflect this situation. Please note that the agency's designated official, not by someone in the bureau, must sign the request.

Most cabinet agencies consist of dozens of bureaus and smaller organizations. Even so, each cabinet agency should submit only one deviation request. On the other hand, if you wish to present your agency's plans in two or more requests, that also will be acceptable.

Yes. Your follow-up analysis should provide information that may include, but should not be limited to, specific actions taken or not taken as a result of the deviation, outcomes, impacts, anticipated versus actual results, and the advantages and disadvantages of taking an alternative course of action. We will modify the annual report format to include this information and, for most deviations, the annual report will meet the requirement for follow-up analysis. If your agency is not required to report (because you spend less than $1 million per year on postage), then your implementation plan should include milestones for follow-up analysis.

GSA's Mail Policy Team will be happy to consult informally with any agency and/or to review draft deviation requests in advance of formal submission. Please call (202) 501-6245 or send a message to federal.mail@gsa.gov.