GSA Policy Advisory:

 

Guidelines for Federal Agencies

On Converting to Commercial Payment Systems for Postage

 

 

I.  Introduction

 

On June 6, 2002, GSA published a regulation that requires all Executive agencies and all Congressional agencies (except Congress and the Architect of the Capitol) move away from the Official Mail Accounting System (OMAS).  Instead, the regulation requires the agencies to begin paying the United States Postal Service (USPS) using commercial payment processes, effective December 31, 2003.  The specific citation is Federal Management Regulation, 41 CFR 102-192.55(c).

 

The regulation establishes only one other firm requirement with regard to payment and accounting for mail.  Agencies are required to ensure that mail costs are identified at the program level (See Appendix A for a definition and discussion of “program level”).  Everything else in this document is a recommendation; that is, you are free to reach the two requirements stated in the regulation as you see fit.

 

This GSA Policy Advisory provides guidance to federal agencies on moving toward commercial payment processes for mail.  It is intended for use primarily by federal:

 

·        Mail managers;

·        Managers of programs that generate mail;

·        Budget analysts; and

·        Financial managers.

 

 

II.   Contents

 

      The guidance in this Policy Advisory is provided as a series of Appendices.  The Appendices are:

 

A.     Recommendations for Managing Postage Costs and Outgoing Mail Operations.

B.     Critical Steps in Converting to Commercial Payment for Postage.

C.    Using Commercial Permits to Pay for Mail that is Printed and/or Mail by a Contractor, Especially through the U.S. Government Printing Office.

D.    Background of the OMAS/Commercial Payments Initiative.

 

      GSA wrote this Policy Advisory, with extensive input from the USPS, the Department of the Treasury, and mail managers from many federal agencies.  GSA is issuing this Policy Advisory as part of its responsibilities to the federal mail management community under the Federal Records Act (44 U.S.C 2904).

 

 

III.  Conclusion

 

GSA recognizes that the transition to commercial payment for postage will be more complicated for some agencies than for others.  We firmly believe that it will benefit the taxpayers in the long run.  When Federal line managers pay for postage the same way that private sector organizations do, and account for postage costs through their standard accounting and budget processes, they are able to:

 

·        Track postage costs in real time;

·        Measure performance;

·        Identify opportunities to save money before they spend it;

·        Use commercial mail service vendors who are locked out by OMAS;

·        Identify instances of potential fraud;

·        Streamline operations and improve productivity; and

·        Increase their ability to react quickly to problems.

 

 

 

 

 

/s/ G. Martin Wagner____________

G. Martin Wagner

Associate Administrator

Office of Governmentwide Policy

 

 

Appendix A

 

Recommendations for Managing Postage Costs

And Outgoing Mail Operations

 

 

Recommendation 1:  Give financial incentives to program managers to manage postage costs aggressively.

 

      The regulation requires agencies to ensure that mail costs are identified at the program level, but it leaves the definition of “program level” to the individual agency.

 

      Giving program managers financial incentives means defining “program level” so that the program manager who controls the decision to place substantial volumes of material in the mail is the same person who has specific budget authority for postage, controls obligation of funds for postage, and accounts for those funds.  This is consistent with the way spending is controlled in the federal government for equipment, furniture, travel, supplies, etc.

 

      The concept of “program level” has been a source of confusion for many people.  The objective is to give direct control over postage funds to any manager who spends enough on postage that it will be cost-beneficial to do this.  In most agencies, this does not mean that all program managers at a given level will have their own postage budgets.  Rather, the mail and finance experts need to develop a clear and comprehensive picture of which programs, at various levels, actually generate significant volumes of mail.  Next, they need to take an honest look at the one-time costs and the ongoing costs of assigning mail budgets to program managers and of keeping track of mail costs at the program level.  Only when you have all of this information can the conversion committee single out the programs that should have their own separate budgets and, thereby, have control over their own postage.

 

      On the issue of “program level,” we should also note that most advanced commercial enterprises keep track of almost all postage by program.  Where postage meters are shared, they use automated systems to keep track of which part of the organization generated each mail piece.

 

      Most federal agencies classify obligations by allowance area (activity, project, function, or organization) and object class for adequate review of financial operations.  Since there is no object class specifically assigned for postage, GSA suggests that you set up a separate sub-object class for postage; probably the best place for this is under Object Class 22.  This will allow you to further identify the type of expenditure and budget for postage during your budget preparation process.

 

Recommendation 2: Identify and adopt best practices such as meter optimization, CAPS accounts, worksharing, and ACH payments.

 

This conversion from OMAS to commercial payment gives you an opportunity to reinvent your outgoing mail processes.

 

 First, many federal agencies have postage meters that have postage volumes too low to make them cost-efficient.  Options such as regular stamps and PC postage are much better solutions for many federal facilities (PC postage allows the user to purchase and print postage with a stand-alone desktop computer).  Where postage meters are the right answer, the commercial payments initiative creates an opportunity to make changes in the number of meters, the types of meters, and where they are located.

 

      Second, the Postal Service provides incentives in their rate structures for mailers who do a good job of preparing the mail.  Best practices under this category including careful mailing list preparation, careful mail piece design, barcoding, presorting, and consolidating mail to obtain or enhance discounts.

 

      Third, for permit mail, this initiative makes it possible for federal agencies to use the Postal Service’s Centralized Account Processing System (CAPS).  Commercial payment processes require that postage be purchased before it is used.  Under the CAPS system, any number of commercial mailing permits may be funded from one, central account.  GSA recommends that each program manager who controls a significant number of mailing permits should establish a separate CAPS account.  For more information about CAPS, go to:

 

http://caps.usps.gov/capsover.asp

 

For information about the USPS PostalOne! Program, which will shortly roll up the CAPS system into an advanced, Internet-based program, go to:

 

http://www.usps.com/postalone/faqs.htm

 

      Please note that the postage meter companies will be able to honor requests for postage only if sufficient funds have already been made available through a banking process, and local post offices will be able to accept permit mail only if CAPS shows that sufficient funds are available (or if money is sent directly to the local post office).  Clearly, under the commercial payments model, program managers must obligate funds in a timely manner to ensure mailings are not delayed.  Careful, timely planning is critical.

 

 

Recommendation 3:  Develop or use a financial accountability system that separately tracks all mail costs to the program area.

 

      One critical element in establishing accountability for postage is to track spending.  As with the budgeting and obligation, each agency must make a separate cost-benefit analysis and develop a tracking system that makes sense for them.  The best solution for many agencies will be to use data from the existing finance system, once it has been modified to accept obligations for postage expenses.

 

      The tracking system should provide:

 

 

      The mail regulation states that the system should:  “Show allocations for postage and all other mail costs (e.g., payments to service providers, mail center personnel costs, mail center overhead, etc.) separate from all other administrative expenses.”  This is, of course, the goal of full cost accounting, which is the standard that all federal accounting systems seek to achieve.  GSA recognizes that agencies will reach this goal in steps.  The first step, for mail operations, is to track postage expenses.

 

Once you have a tracking system for postage, you will be able to reconcile statements from the USPS and bills from all other service providers with internal financial data. This is a key step in assigning accountability, because it allows managers to review and manage their expenditures in a timely manner.

 

      The regulation also states that the system should:  “Allow mail centers to establish systems to charge their customers for postage; and identify and charge mail costs that are part of printing contracts to the program level.”  This is one more important step in identifying postage expenses.

     

      Agencies have expressed concern that conversion to commercial payment processes will take away the management information that OMAS has provided.  However, the postage meter companies and the USPS CAPS system all provide management information.  Commercial mailers find the information from the meter companies and CAPS to be entirely sufficient for their management needs.  GSA believes that, in sum, this data will be more detailed and more useful than the data now available from OMAS.

 

 

Recommendation 4:  Use performance measures.

 

      The President’s Management Agenda emphasizes use of performance measures for federal programs.  The Government Performance and Results Act does so as well, and, across the full range of GSA’s governmentwide policy programs, we work with federal agencies to develop and use performance measures in their administrative functions.

 

      Large commercial mailers use a wide range of performance measures in their incoming and outgoing mail programs, and most of these are useful or adaptable to federal mail operations.  A few examples for outgoing mail are:

 

·        Savings generated by worksharing;

·        Reduction in “undeliverable as addressed” mail;

·        Percentage of payments for postage made electronically;

·        Ratio of express mail to first class mail;

·        Percentage of spoiled postage; and

·        Customer satisfaction.

 

      As you develop your plan to convert to commercial payment processes, we strongly recommend that you develop performance measures in two areas – tracking the success of your outgoing mail program, and tracking the success of your conversion process.

 

      We provide additional suggested performance measures at http://www.gsa.gov/mailpolicy.

 

 

 

Appendix B

 

Critical Steps in

Converting to Commercial Payment for Postage

 

1.  Establish a Conversion Committee

 

A.     Recruit experts from budget, contracting, finance, information technology, mail operations, printing, major agency programs, resource management, the USPS account manager, USPS corporate treasury, and vendor representatives.

B.     Develop a detailed plan.

 

2.  Inventory Current Situation (for your entire organization, nationwide)

           

A.     Locate and count:

 

·        Penalty meters and locations;

·        Penalty permits;

·        Penalty business reply mail (BRM) permits and locations;

·        Penalty merchandise return service (MRS) permits and locations; and

·        Existing commercial meters and permits, if any.

 

B.     Determine the annual volume, by location, of:

 

·        Penalty postage stamps;

·        Meter postage; and

·        Permit postage.

 

C.    Identify:

 

·        Repetitive large mailings; and

·        Use of business reply mail, certified mail, express mail, and other USPS services that are used regularly.

 

3.  Accounting, Budget, and Finance

 

A.     Determine the new organizational levels and locations for budgeting and postage payment (i.e., the “program level” discussed in the regulation and under Recommendation 1 in Appendix A).

B.     Develop budgets for those programs and locations.

C.    Establish and communicate obligating procedures for requesting payment to USPS.

D.    Allocate funds to those levels and locations.

E.     Establish a process for converting obligations to bank transactions (Please see the Treasury Financial Management Bulletin entitled “Federal Agency Postage Payments to the United States Postal Service” for specific payment procedures).

F.     Establish and communicate procedures to track and account for postage.

G.    Authorize credit card usage for purchases from the USPS.

 

4.  Postage Meter Conversion

 

A.     Work with the meter companies to determine the number of meters needed, appropriate locations, limits on dollar amounts, limits on how often postage should be added, and your desired conversion date(s).

B.  Identify locations where stamps and/or PC postage would be more cost-beneficial.

C.    Obtain lockbox account numbers from the USPS.

D.    Establish a Computerized Meter Resetting Service (CMRS) account for each group of meters that will be funded as a unit.

E.     Transmit money to the trust account(s) before conversion takes place (Credit will be given through the OMAS account for postage remaining on the penalty meters when they are checked out of service.  The money cannot be transferred directly to the commercial meter.  Instead, the credit will go to the manager of the OMAS account.  Mail managers should work with agency finance personnel to arrange for the OMAS credit to be returned to the budget for the appropriate part of the agency).

F.     Check commercial meters into service.

G.    Verify that the new meter is a commercial meter.  Commercial meter imprints may not say “Penalty for Private Use $300” – that is reserved for the Official Mail Accounting System.  Instead, they should say simply, “Official Business.”  You may add the name of the agency or other information if you wish.

H.     Check penalty meters out of service.  Do not check any penalty meter out of service until the commercial meter is operational and tested.  Be sure to record the date the penalty meter is checked out of service and the amount of postage remaining on it.

I.         Ensure that OMAS receives credit for unused penalty postage.

 

5.  CAPS Accounts (See Appendix A for a detailed discussion of CAPS)

 

A.     Establish and fund CAPS accounts as needed.  Please note that you will need to establish one permit account at a local post office before you can establish a CAPS account. (Please see the Treasury Financial Management Bulletin entitled “Federal Agency Postage Payments to the United States Postal Service” for specific payment procedures).

B.     Link permits, BRM, Periodicals, and Express Mail corporate accounts to CAPS.

 

6.  Permit Conversion

 

A.     Apply and pay for prepaid permits at needed post offices.  An initial fee of $150 must be paid at the post office when a commercial permit is first obtained.  This must be renewed for each local post office annually, but, if the permit is linked to a CAPS account, the renewal fees may be paid via the CAPS account.  This eliminates the need to pay the renewal fee at the local post office. 

B.     Establish and fund trust accounts as needed.  A trust fund is required at every post office where a permit will be used, if that post office is not linked to a CAPS account (Please see the Treasury Financial Management Bulletin entitled “Federal Agency Postage Payments to the United States Postal Service” for specific payment procedures). 

C.    Print stationery items with prepaid permit numbers as needed (e.g. envelopes, labels, etc…).  As with meters, commercial permit stationery for federal agencies may not say “Penalty for Private Use $300.”  Instead, it should say “Official Business Only.”

D.    Ask USPS to close the G permit in OMAS.

 

Note:  Today, there are 2,600 post offices that are automated to accept permit mailings through the CAPS system.  These are the larger post offices, so a large majority of federal mail will be inducted there.  For permits at the non-CAPS post offices, you will need a local permit.

 

Early in calendar year 2004, the CAPS system will be folded into a new USPS system called PostalOne!  Initially, the same 2,600 local post offices will be able to accept bulk mail under PostalOne!  If you find yourself needing to present bulk mail at a post office that is not linked to PostalOne!, we recommend that you ask the postmaster to consider linking to PostalOne!  Experience has shown that most postmasters will be happy to do so when the opportunity for additional business at their post office is presented to them.

 

7.  Penalty Business Reply Mail (BRM) Conversion

 

A.     Apply and pay for prepaid BRM permit(s).  You need only one BRM permit nationwide, though you may wish to establish more for internal accounting or finance purposes.

B.     Arrange for post offices to accept mail that carries the penalty BRM permit but charge it to the commercial permit.

C.    Print items with prepaid BRM permit information as needed.  Coordinate the design of new BRM pieces with USPS’ mail design specialist to ensure they are correct prior to printing the pieces.

D.    Destroy unused stocks of penalty BRM items.

 

Note:  There are essentially three levels of BRM processing and payment:

1.      The simplest form relies on a BRM permit plus the standard per-piece fee, which is $.60 per piece.  The agency pays the fee directly to the local post office when they pick up the mail.

2.      The next step up involves establishing a pre-paid trust account from which payment for BRM mail is drawn.  The account costs $475 per year, and the per-piece rate is $.10.  Simple math shows that this arrangement makes sense only if the agency receives at least 950 BRM pieces per year.

3.      The third level requires the mailer to make sure that all BRM pieces meet USPS automation compatibility requirements (mail piece design, barcoding, etc.).  The annual fees are much higher, but the per-piece fees are lower, so this makes sense for high-volume BRM users.

For more information on BRM, see Sections S922 and E150 of the USPS Domestic Mail Manual.

 

8.  Periodicals Permit Conversion

 

A.     Apply and pay for prepaid periodicals permits at the local post offices where periodicals will be presented for mailing.

B.     Ask USPS to close penalty periodical permits in OMAS.

 

9.  Penalty Express Mail Conversion

 

A.     Apply for and fund express mail corporate accounts as needed.

B.     Ask USPS to close penalty express account in OMAS.

 

10.  Penalty Postage Stamps Conversion

 

A.     Establish a cut off date for ordering more penalty stamps.

B.     Ask USPS to close your penalty stamp account in OMAS.

C.    Use penalty stamp inventory before prepaid stamps.  The USPS does not issue refunds for unused penalty stamps or exchange them for prepaid stamps.  Penalty stamps do not have an expiration date.  The postage on a mail piece may be paid by a combination of penalty and prepaid stamps.

D.    Purchase prepaid stamps.  Postage stamps normally may not be purchased from a trust account.  Credit cards are the most convenient payment method.

 

11.  Merchandise Return Service (MRS) Conversion

 

A.     Establish prepaid MRS permits and trust accounts at needed post offices.

B.     Arrange for post offices to accept mail that carries the penalty MRS permit but charge it to the prepaid permit.

C.    Ask USPS to close MRS in OMAS.

 

12.    PC-Based Postage

 

Establish PC based postage accounts with vendors as needed.

 

13.  Stop printing stationery items with the penalty statement.

 

14.  Close out OMAS Accounts.

 

15.  Communications

 

All finance managers, budget managers, program managers, and mail managers in your agency will need to know the new commercial process before this conversion is completed.  It is critical, therefore, that all internal communications about the new commercial payment process be timely, clear, consistent, and factual.  Every commercial payment process plan should specify the program managers and agency finance officials who will coordinate all mailings. Commercial payment plans should also ensure that:

 

·        All available information is communicated in a timely manner;

·        Everyone is sending the same message; and

·        Messages are crafted so that all personnel can easily understand the information.

 

16.  Training 

 

Education and awareness are the essential ingredients to preparedness.  Program managers and mail center employees must know what to do before mailing with the USPS.  Effective training will develop a culture of commercial processes.  Every commercial process plan should discuss how new and current mail center workers will be trained and how they will rehearse various plans and scenarios.

 

17.  Transition.

 

It is very unlikely that all of the meters or permits in a large agency can be converted from penalty mail to commercial processes on a single, specific date. 

 

A.     Meters.

 

Meter conversion requires a technician from the meter supplier company to physically replace the meter head.  If your agency has a small number of meters, all in one location and all provided by one supplier, you may be able to arrange for their conversion on a single date that you and the meter supplier agree on.  However, if you have a large number of meters, multiple locations, and/or multiple suppliers, you almost certainly will not be able to select a single date on which all of them will be converted. 

 

This has two practical consequences.  First, you will have to make separate arrangements with each meter supplier to convert the meters for each of your locations.  Second, since most meters will not be converted on the same date, your agency will need to make OMAS payments and commercial payments at the same time.  That is, you will need to continue making sufficient payments to the Postal Service for penalty mail while, at the same time, paying into Postal Service commercial trust accounts for the meters that have been converted or will soon be converted.  For a large agency, this process of balancing penalty mail funds and commercial postage funds will probably extend over a period of several months.

 

B.    Permits (bulk mail, business reply, etc.)

 

Today, most federal agencies using OMAS have a single permit or a small number of them.  Under the commercial payments model, agencies will probably find that they need a significant number of permit imprint and BRM accounts, because each “program level” should have its own BRM permit and its own CAPS account.  As with meters, it is unlikely that a large agency can establish all of the needed permits and put them into use on a single, specific date.  Therefore, as with meters, it will be necessary to maintain payments to the Postal Service at a reduced level for penalty mail while, at the same time, ensuring that permit trust accounts have funds sufficient to support commercial permit mailings.  For a large agency, this process also will probably extend over a period of several months.

 

C.  Stationery

 

You probably have a supply of stationery pre-printed with your G-permit number.  If so, you should select a date for converting your permits that minimizes the amount of remaining stationery.  If you wish, you may convert to commercial permits and still use G-permit stationery, but only if you make arrangement in advance with the Postal Service to do this.

 

18.    Reports and data

 

Most OMAS users rely on the OMAS reports to tell them how much money they have spent on postage.  Obviously, once you have converted to commercial payments, you will no longer receive these reports.  Ideally, your agency’s finance system will provide detailed reports, but in most agencies this ideal is some years away from realization.

 

In the meantime, the meter suppliers are fully prepared to supply detailed reports on usage, and they are able to compile your agency’s data in many different ways to meet your needs.  For permit mail, the CAPS system offers a range of on-line reports, and the new PostalOne! System, which will take over all of the CAPS functions in the next year, will offer a much broader range of on-line reporting and analysis capabilities.

 

In sum, the reports available under the commercial payment model will provide more data and greater analytic possibilities than OMAS.

 
Appendix C

 

Using Commercial Permits to Pay for Mail that is Printed and/or Mailed by a Contractor, Especially through the

U.S. Government Printing Office

 

Currently, the Government Printing Office (GPO) will write a printing contract that includes mailing using your G-permit, their permit, or a contractor’s permit.  They provide these options to expedite the process and make the mailing of your print job flow easily. 

 

·        When the postage is paid for through a GPO permit or the contractor’s permit, the cost will be included in the invoice that the GPO sends to you, and it will include GPO’s surcharge on both the printing and postage cost. 

·        When the postage is paid using your G-permit number, the cost appears on your OMAS statement.

 

Under the commercial payments model, the same options are still available.  You may use a commercial permit established by your agency, a commercial permit obtained by the GPO, or the contractor’s permit.  As before, if you use the GPO permit or the contractor’s permit, the cost will appear on GPO’s invoice.  However, if you use your own commercial permit, you must ensure that:

 

1.      Your agency has a permit at the local post office where the mail will be presented;

2.      You have provided sufficient funds to that post office to cover the cost of that mailing; or

3.      You have sufficient funds in your USPS Centralized Account Processing System (CAPS) account to cover the cost of that mailing.  If you are using CAPS to pay for the mailing, you must also ensure that the permit at the local post office where the mail will be presented is linked to your CAPS account.

 

In order to ensure full cost accounting, we recommend you give the GPO your commercial permit number.  This will ensure you are able to identify the actual postage costs separate from the printing costs.  The first time you do business with a particular contractor, you will have to work with them to establish a commercial permit for your agency at the post office where they routinely present bulk mail.

 

However, for small print/mail jobs, it may be easier to use either a GPO commercial permit or the contractor’s permit.  If you do, you must make sure that the contract requires the contractor to show the postage cost separate from the printing cost.

 

Here are a few additional considerations:

 

·        All of the information in this appendix applies whether you are using the GPO or another federal procurement office to obtain your printing.

·        You can print the permit imprint indicia onto a label that you will apply to your mail piece. This is a smart choice if you are not printing your own envelopes.

·        If you use a presort bureau, you may be able to use their permit number and save on the Permit Imprint application fee and annual mailing fee.

·        You can print a large quantity of mail pieces with your Permit Imprint Indicia in advance and mail small quantities as you need; then, you pay only for postage as it is used. 

·        If you will be mailing from more than one Post Office, you can use a "company imprint," which omits address information while including your company name; this way you can use a single design for your Permit Imprint Indicia.
Appendix D

 

Background of the OMAS/Commercial Payments Initiative

 

Two fundamental management goals stand behind this requirement to convert to commercial payment processes.  The first is using financial incentives to point federal managers toward better management of postage.  In federal agencies that use OMAS, a fundamental disconnect exists among allocation, obligation, and payment.  Mail budgets are prepared, and mail payments are made, only at the headquarters level.  The program officials who make the practical decisions to put material into the mail have no responsibility for budget allocation, obligation, or reconciliation.

 

The result of this disconnect, as we see it, is a failure to assign incentives and accountability where they belong.  We certainly applaud the efforts in many agencies to identify postage expenditures by program and to monitor and control those expenditures.  However, this work occurs after the fact.  We strongly believe that the program manager who controls the decision to place material into the mail should be the person controlling that expenditure, and that he or she should do it before putting material into the mail.  This, in our view, is the only way to ensure accountability.

 

The second management goal is bringing commercial business practices into the federal government.  Government-unique systems are inherently inefficient, and OMAS is certainly no exception.  Throughout the universe of federal finance, in concert with the President’s Management Agenda, the government is moving toward commercial processes that emphasize full cost realization and accountability. Clean financial statements, closing accounts quickly at the end of fiscal years, cost accounting, prompt payment, and so on are all part of this movement.  The initiative to convert postage to commercial payment is another small part of this.

 

The General Services Administration has discussed moving to commercial payment with Federal financial experts, mail industry consultants, and the Office of Management and Budget.  Virtually every one of these experts agrees that giving program managers information about, and responsibility for, the money they spend on mail is critical to improved management and cost control.  We have also studied the experience of the five Federal agencies (most notably the Department of Defense) that have converted all or part of their postage to commercial payment processes, and their experience confirms the potential value of this initiative.

 

Shortly after publication of the mail management regulation, the Treasury Department asked the Postal Service and GSA to find a way to keep the money inside the Treasury.  GSA assembled an interagency team and worked for a full year on different approaches to accomplish this.  The team's conclusions were (1) meeting this requirement would require that the Postal Service build a new, government-unique system, which they would then have to maintain along with OMAS; and (2) it would not be cost-beneficial to do this.  Therefore, we will not be constructing a new Interagency Payment and Collection System (IPAC) process for postage.

 

Executives from the Treasury, Postal Service, and GSA met in June 2003 to develop an alternate solution.  They assumed that most of the large, centrally managed federal mail programs are, for the part, applying cost-effective measures while using OMAS.  They also agreed that making program-level officials accountable for postage remains a valuable objective.

 

Therefore, the Treasury, Postal Service, and GSA have agreed that about ten large, centrally managed federal mail programs will continue to use the Official Mail Accounting System for the foreseeable future.  These programs spend approximately $625 million per year on postage.

 

All other federal mail programs are still expected to convert to commercial payment processes for postage.  The programs that will be converting spend approximately $100 million on postage, joining the programs already converted that spend about $200 million per year on postage.

 

Agencies have expressed concern about the cost of exchanging postage meters, and, more broadly, the cost-benefit relationship for the entire process of converting to commercial payment processes.  GSA recognizes that certain costs are associated with this initiative, primarily exchanging the heads on penalty meters, programming agency finance systems, and training agency personnel.  We see this as an opportunity for the agencies to review meter types and locations and to develop internal systems to track postage costs.  We also know that the meter companies will actively compete on any solicitation to replace large numbers of meters.  We firmly believe that, in the long run, this initiative will produce savings much larger than the up-front costs.