Mailing & Fulfillment — ‘Move Update’ Moves ForwardMay 2008 By Mary Ann Bennett
Unnoticed by most is an approaching issue that will have a much greater impact on the direct mail industry than either rate increase or the IMB.
USPS requirements for Move Updating of address lists for First Class Mail claiming presort rates will be expanded to include Standard Mail effective November 23, 2008. Also, the Postal Service is increasing the minimum frequency of Move Update processing from 185 calendar days to 95 days prior to the date of mailing.
Why Enforce Move Update Requirements?
Today, if you mail at First Class rates to a non-current address, your mail will be determined as undeliverable as addressed (UAA) and:
o USPS regulations state that every piece of UAA mail must be processed until a final disposition is made.
o In fiscal year 2004, the Postal Service handled 9.7 billion pieces of UAA mail at a cost of $1.85 billion.
In simpler terms, the USPS is happy to let you claim presort discounts on your First Class mailings--they just want to make sure that you're mailing to the recipient's current address. If they have moved, you have updated your database with the new information. This saves the USPS from incurring the significant expense associated with forwarding the mail, or returning it to the sender. Your claiming of postage discounts goes hand-in-hand with proving to the USPS you have done the work to meet its requirement.
Following are key steps to take.
Step 1: Know the Requirement
Currently, addresses on all Presorted First Class Mail must be updated within 185 days before the mailing date with a Postal Service-approved method:
o Address Change Service (ACS);
o National Change of Address Linkage System (NCOALink);
o FASTforward MLOCR processes if used each time before mail entry;
o Mailer Move Update Process Certification and USPS-approved alternative methods for mailers with legitimate restrictions on incorporating USPS-supplied change-of-address information into their mailing lists (see section on 99 Percent Accuracy); or
o Appropriate ancillary service endorsement.
Step 2: Identify Your Level of Exposure
You and your staff know your clients. You know whether or not they mail claiming First Class Presort discounts and how frequently.
o Who controls or is responsible for the database maintenance?
o If your customers perform their own database maintenance, how do they handle address change notifications?
o Is your mailing permit number being used by your client?
o Your signature is on the mailing statement, which alone "certifies" that the addresses in this mailing have met the entire Move Update standard. Chances are you will probably fight a losing battle and be held liable if you cannot present the "supporting documentation." Thus, penalties and fines may be assessed.
o Review your clients one at a time and rank their "risk" levels and your potential exposure.
Step 3: Educate Internal Staff and Be Prepared for Pushback
Particularly those who can never say "no" to a customer.
o Assure that your salespeople and CSRs are aware of the risks associated with telling a client he can mail First Class using your permit, etc.
o Your CSRs have to ask the questions and check on the status of the addresses in the list.
o Do you have "current" Move Update documentation in-house?
o Does the customer have it, so it can be provided upon request?
Those questions are just as important as checking on how much postage needs to be in the account. You may actually have to forego claiming the presort discounts if you know that you're mailing for a client that is very high risk.
99 Percent Accuracy
The USPS has developed a process for those customers who proclaim their lists are accurate and up-to-date. The 99 Percent Test is a computer-based process that performs USPS ZIP+4 coding and change of address processing utilizing the customer's file as input.
The test can be accomplished by submitting the files directly to the USPS for processing, or the USPS can bring the 99 percent process onsite for your customers to process the files.
The sole purpose of this agreement and the 99 Percent Test is to determine that 1 percent or less of the addresses have a change of address on file and to identify addresses that do not have a ZIP+4 code. For more information, visit http://ribbs.usps.gov/MUProcessGuide.pdf.
Give your clients the information, so they can check it out themselves. This will preclude their tendency to want to "shoot the messenger." Now, if you haven't discussed this with your client in the past, you can explain that even though the requirement has been in existence for some time now, the Postal Service has not been aggressively enforcing it.
Step 4: Research the Capabilities of Your Presort Software
Many presort software packages on the market today have numerous database maintenance features included with their presort capabilities. Most also have capabilities that are specific to the approved Move Update methods. For example, the package you currently use may have:
o The ability to search/find records in a list for updating;
o The ability to print Ancillary Service Endorsements directly on a mailpiece; and
o Compression/Formatting features for ease of file transfer.
Step 5: Research Costs Associated with Each Move Update Method
There are charges specific to each Move Update method and the range can be dramatic. This can be well worth the research time and effort.
o ACS may be the answer for some clients.
o NCOALink may be perfect for others.
o Use Ancillary Service Endorsements as a last resort, but make absolutely sure you know the specifics of using these endorsements and their associated fees.
Step 6: Communicate With Your Clients
Inform them of the Move Update requirements. Do you maintain their lists? If so, agree on who is responsible for keeping the addresses "current." Along those same lines, make absolutely sure there is a clear understanding of the terms list maintenance, computer processing, list processing, etc.
Your customers may assume that, since their mailer performs DPV ZIP+4 encoding and postal presorting to their data, address updating is included under that general term of "computer work."
Since potential penalties (Revenue Deficiency Assessments) can be significant, consider exactly who needs to be aware of the monetary ramifications. For example, the signature of the marketing manager who is authorized to sign for amounts up to $5,000 may be worthless in the event of a $10,000 fine.
Special note: Problems arise with uneven enforcement of these Move Update requirements by the USPS across the country. Revenue Deficiency Assessments can be in the millions of dollars, but they typically run in the tens of thousands. If your mailing is found to be non-compliant, USPS officials can retroactively take away all presort discounts you have claimed on your First Class mail in the previous 12 months.
Unfortunately, there is no hard and fast rules on these assessments. Worse yet, neither the USPS nor the recipient of a financial penalty make public announcements, so these fines remain clouded in rumor, myth and legend.
Some believe the USPS hasn't made a great deal of noise concerning this issue because they are only making changes to requirements that have been in place for more than a decade (July 1997). If you have been Move Update compliant all this time, then you have little to be concerned about.
These changes will present real revenue-generating opportunities because of the USPS mandate for you to perform data maintenance work for your clients at an increased frequency.
However, if you are among the many that have been uninformed and, subsequently, non-compliant, these changes could be difficult for your company and your clients to navigate.
Start today by charting a course to be Move Update compliant. Gain and share new knowledge, and proceed with confidence into this exciting time of progress for our industry.PI
About the Author
Mary Ann Bennett is president and CEO of The Bennett Group. For additional information, e-mail her at firstname.lastname@example.org or call (585) 424-2702.