Here's a fact you may not know about the month of May: In any calendar year, no other month starts on the same day of the week.
If you're a mailer, here is a fact that you do know about May: It is bringing two significant changes from the USPS.
The first change is the new postage rates that become effective on May 11. Mailers will remember that the December 2006 Postal Accountability and Enhancement Act changed the USPS rate setting process to its now annual schedule. The 2009 rate changes were announced in February and are available at www.usps.com/prices/pricechanges.htm.
As with past changes, the commercial postage rate schedules reflect incentives to encourage or discourage mailers from specific mail preparation methods (such as the 2007 change to shape-based postage rates), or to prepare mailers for future changes in mail processing (such as the elimination of destination delivery unit discounts). One new requirement will potentially affect all quick printers who are also mailers—flats must have a delivery point barcode to qualify for automation compatible postage rates. Other changes with less applicability include a test incentive program for saturation mailers, changes for standard mail parcels and non-flat machinable (NFM) mail, and changes for parcel post and parcel select.
When move update was expanded in November 2008 to include standard mail, the USPS granted a grace period, declaring it would not impose any penalties on standard mail found to be non-compliant. This changes on May 11 for both first class and standard mail.
First class mail. Only single-piece first class mail is exempt from move update requirements. Therefore, beginning May 11, the penalty for non-compliance will be reclassification of the mail piece to the single-piece rate, regardless of the rate originally claimed (presorted, automation, or carrier route). What this means is that an entire mailing could potentially be reclassified as single-piece and all postage discounts lost.
Standard mail. Non-compliant standard mail will be assessed an additional seven cents for the entire mailing.
The trigger-point for determining non-compliance is complicated. A sample of mail pieces will be scanned in MERLIN, converted to an electronic file, and processed by the USPS at the National Customer Service Center (NCSC) using the 18-month NCOALink product. A comparison of the number of addresses found and updated by the mailer to the number of addresses that should have been updated, as determined by NCOALink, will determine compliance. If there are more than five errors in the MERLIN sample, the mailing will be declared non-compliant, provided the percentage of addresses found by the mailer is less than an initial 70% threshold. If a mailing is declared non-compliant, the mailer can either re-work the mailing or pay the seven cents per piece surcharge.
The USPS has said that the penalty will not be due immediately (to give the mailer time to make the additional funds available) and that the mailer can use the regular MERLIN appeal process to challenge the determination of non-compliance. However—and this is an important clarification by the USPS—the penalty will be assessed on whoever signs the Statement of Mailing, regardless of who "owns" the mail.
USPS Form 6014
Before this clarification, most mailers were using PS Form 6014, Certification of Move Update Compliance, to transfer liability for move update compliance to the mail owner. However, in February 2009 the USPS announced that effectively immediately, it has discontinued use of PS Form 6014. Bulk mail acceptance clerks were told not to require or accept PS Form 6014 from mailers. According to the USPS, the form was originally developed at the request of the mailing industry by a Mailers Technical Advisory Council (MTAC) work group so that mail owners could provide verification of move update compliance to mail processors.
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.