What this means for mailers is that the USPS has clearly stated that liability for move update compliance cannot be transferred from mail preparers to mail owners. The USPS position is that compliance with move update is just like any other verification procedure such as presort or barcode errors. The mail preparer has responsibility for compliance and can either take the mail back and rework or pay extra postage.
Liability for Move Update Compliance
The discontinuance of PS Form 6014 leaves mailing service providers at considerable risk for address quality errors, even when the mailer has no control at all over mail list compilation (such as a list provided by a broker or list compiler) or hygiene (such as a list maintained by a customer). This is a different situation than mail preparation, where the mailer does indeed have strict control over education, training, and operational performance of workers engaged in mail processing for postage discounts.
Understandably, the mailing industry has objected to this policy of holding mail preparers accountable for address quality, maintaining that it is unfair to penalize mailers for work done—or not done—by others. Two industry organizations, the Association of Postal Commerce (POSTCOM) and the National Postal Policy Council (NPPC), have presented comments before the Postal Regulatory Commission (PRC), which has the power to disapprove either the penalty or the method of testing compliance or both.
Minimizing the Risk for Move Update Compliance
With the stakes so high for non-compliance, mailers need to be formulating a strategy to minimize the risk associated with address quality. Some possibilities include:
- National Change of Address processing within 95 days of a mailing. Though it is not known whether evidence of timely National Change of Address (NCOA) processing will help in a finding of non-compliance with move update requirements, in theory NCOA processing should reduce the number of addresses that potentially could be found in the MERLIN sample.
- Exclude problem addresses from the mailing. Removing CASS (Coding Accuracy and Support System) and DPV (delivery point validation) failures from the mailing will improve the address quality of the list. If they must be mailed, CASS and DPV failures can be sent at the single-piece rate.
- Use the exceptional address format. When the target recipient for a mailing is not an individual but a residential or commercial building, adding "Or Current Resident" or "Or Current Occupant" as a secondary address line will eliminate the address from the requirement for move update.
- Make customers aware of the penalties for non-compliance and ask for indemnification. Developing a clear explanation for customers of address quality, including list hygiene and move update, is the first step in helping customers understand the importance of mail list hygiene. Building on this, mailers can request their customers to indemnify them against penalties for non-compliance in cases where customers are maintaining their own mail lists.
Nancy DeDiemar is the president of Printing Resources of Southern California, a quick print shop in Upland, CA, offering printing, copying, electronic prepress, and mailing services. Nancy is the co-publisher of Printips (www.printips.com), a newsletter subscription service for printers. Contact her at Nancy@printingresources.com.