Priority Mail: Move Update Penalties Ahead

Ten years after move update became a requirement for first class mail and 14 months after the requirement was extended to standard mail, the USPS has reached the end of the phase-in period. Beginning next month—January 4, 2010 is the exact date—the USPS will begin assessing penalties for mail that does not comply with move update requirements.

The requirements, which took effect on July 1, 1997 for first class presort mail and November 23, 2008 for standard mail, mandate that all mail must have been processed using an accepted move update method within 95 days of the mail entry date or lose the postage discount. There are four options available to meet the requirement; three are used after mail is entered, while one is used pre-mailing:

• ACS (address change service) is an automated way for mailers to receive change of address (COA) information directly from the USPS. ACS is post-mailing.
• ASE (ancillary service endorsement) is wording added to the front of the mail piece that tells the USPS what to do with the mail piece if it is undeliverable as addressed. ASE is post-mailing.
• FASTforward is also an automated system of permanent COA records that relocating customers have filed with the USPS. FASTforward is post-mailing.
• NCOALink is a method for identifying COA information prior to mailing.

Most quick printers who are mailers are using NCOA processing or ASE.

If assessed, the penalty for non-compliance will be substantial: seven cents per piece, applied to the entire mailing for standard mail, and the single-piece rate for the entire mailing for first class mail (which is about seven cents for a first class letter weighing up to one ounce). The penalty was approved by the Postal Regulatory Commission (PRC) in February 2009.

In November 2008 when move update was extended to standard mail (and the interval between move update verification shortened from 180 to 95 days), the USPS warned that it would allow no grace period for first class presort mail since the requirement had been in effect for more than 10 years, but that a grace period would be in effect for standard mail. To help mailers during the grace period, the USPS began providing feedback on move update compliance to mailers in April 2009. At that time, the verification process used live samples from the mailing, though this was intended to be temporary. The permanent verification process, called performance-based verification, will use MERLIN machines and become part of mail piece evaluation at acceptance. (A list of the locations where MERLIN machines are being used for performance-based verification is available at http://ribbs.usps.gov/index.cfm?page=moveupdate).

Here’s how performance-based verification will work: at the time of mail acceptance, address deficiencies (CASS and DPV failures) and move update will be checked against USPS databases in near real time. If fewer than five errors are found during verification, or if 70% of the change-of-address records have been updated, then the USPS will not assess a penalty. (The USPS intends to evaluate the minimum passing score of 70% every few months and to raise the score as quality improves.) If, however, more than 30% of the addresses that should have been updated were not updated, then the mailing will be deemed non-compliant and a penalty will be assessed. Mailers will have the option to pay the additional postage or withdraw the mailing.

Move Update and Customer Management
The penalty for move update non-compliance essentially removes the postage discount for first class presorted mail, and represents about a 30% penalty assessment for standard mail. As mentioned, the mailer (or mailing agent, which is what we are when we allow customers to use our permit) will have only two choices if a penalty is assessed: to pay the additional postage or remove the mail from entry.