In recent months, many have seen articles and announcements that the U.S. Postal Service is implementing new strategies to control operational costs. And, along with these new strategies, it is enforcing some old mandates that have been around for a number of years. One mandate that has become a vortex of recent activity is Move Update Compliance. Stepped up or re-instated enforcement was to come in March, then April and then May. In April at the National Postal Forum in New Orleans, there were the rumors of NCOA exclusive licensees disappearing in 2004, FASTforward meeting its demise in 2005, the formation of NCOAlink, and a new Postal Service form (PS 6014) was published. Currently, it is very difficult to find definitive information on any of these issues. Yes, there is a new form; however, its use may or may not be mandatory. Yes, there is talk about NCOAlink; however, getting high ranking Postal Service officials at the National Customer Support Center in Memphis to provide real program details is nearly impossible. There is a possibility that the issue of NCOA licensees ceasing to exist in 2004 may be heading in the direction of legal action. Given that all of these issues seem to be perpetually swirling around the bowl, for the time being, mailers simply need to be vigilant and prepared prepared to, at the very least, be able to meet the current Move Update Requirement. 

 

Why Enforce Move Update Requirements?

If you mail at First-Class rates to an address that is not current mail will be determined as undeliverable as addressed (UAA) and:

  • Current regulations state that every piece of UAA mail must be processed until a final disposition is made

  • The Postal Service is forwarding approximately two billion mailpieces per year, returning approximately 1.3 billion mailpieces to senders

  • Average additional cost of 20.9. is incurred by the Postal Service for forwarding, 58.6. if the mailpiece must be returned to sender

     

    Steps to Take

    Step 1 Know the Requirement

    Domestic Mail Manual E130.3.3   Address Quality

    The mailer's signature on the postage statement certifies that this standard has been met.

    Addresses on all Presorted First-Class Mail must be updated within 180 days before the mailing date with a Postal Service-approved method:

  • Address Change Service (ACS)

  • National Change of Address (NCOA)

  • FASTforward

  • Appropriate ancillary service endorsement F010

     

    Domestic Mail Manual E110.5.0

    Basic Standards Documentation

    A postage statement, completed and signed by the mailer, using the correct Postal Service form or an approved facsimile, must be submitted with each mailing except for single-piece First-Class Mail or single-piece Priority Mail mailings in which the correct postage is affixed to each piece. Supporting documentation might be required by the standards for the rate claimed or the postage payment method used.

     

    Your Signature Says It All

    Be aware that Postal Service Revenue Assurance can assess penalties (hold you liable) for your signature only. Effective with the new postage statements of June 2002, your signature on a postage statement claiming First-Class Presort Discounts certifies:

  • The Postal Service Move Update standard has been met

  • You have used an approved methods of updating addresses

  • You have incorporated those additional addresses into your database

     

    Postage Statements prior to June '02 required you to indicate the Move Update method used. The standard has not gone away just because the methods no longer appear on the form! Now, your signature alone certifies that you have met the entire Move Update standard.

     

    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.

  • Who controls or is responsible for the database maintenance?

  • If your clients perform their own database maintenance, how do they handle address change notifications?

  • Is your mailing permit number being used by your client?

  • 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" and penalties and fines that may be assessed.

  • Review your clients one at a time and rank their "risk" levels and your potential exposure.

     

    Step 3 Educate Internal Staff

    Particularly those who can never say no to a customer.

  • Assure that your salespeople and your CSRs are aware of the risks associated with telling a client he can mail First Class using your permit, etc.

  • Your CSRs have to ask the questions and check on the status of the addresses in the list.

  • Do you have "current" Move Update documentation in-house?

  • Does the client have it so it can be provided if 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 you are mailing for a client that is very high risk.

     

    If you start this process of educating your staff now, asking the Move Update questions will be as common place as ZIP+4 encoding your client's data is today.

     

    Step 4 Research Capabilities of Your Presort Software

    Many presort software packages on the market today have numerous database maintenance features included with their presort capabilities. They may also have capabilities that are specific to the approved Move Update methods. For example, the package you currently use may have:

  • The ability to print the ACS Participant Code

  • The ability to search/find records in a list for updating

  • The ability to print Ancillary Service Endorsements directly on a mailpiece

  • Compression/formatting features for ease of file transferral

     

    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.

  • ACS may be the answer for some clients.

  • NCOA may be perfect for others.

  • You may even find that you can justify the current expense of FASTforward.

     

    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 term(s) list maintenance, computer processing, list processing, etc. Your customers may assume that, since their mailer performs ZIP+4 encoding and postal presorting to their data, address updating is included under that general term of "computer work." 

     

    If they do their own database maintenance, inform them of the specific work they need to perform with relation to Move Update.

  • What Move Update method are they using?

  • Do they have documentation to support their method?

  • Do they use Ancillary Service Endorsements?

     

    Since potential penalties can be significant, you need to 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.

     

    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 7 Develop a Mini Strategic Plan

    Build a plan for your mailing business that specifically addresses the issue of Move Update Compliance.

  • Identify your strengths, weaknesses and opportunities.

  • Build and follow through with action plans.

  • Structure a mission statement that will focus your company on making Move Update Compliance a mutually beneficial undertaking for your internal and external customers. 

     

    Mailers need to keep a watchful eye on the entire issue of Move Update Compliance. There will be many changes made in the coming months. Hopefully, the changes that occur will result in some real opportunities for the mailing industry. However, without copious, consistent communication and education on Move Update issues and consistent enforcement of the requirements, the mailing industry will remain uncertain as to how to proceed into the future.

     

    Mary Ann Bennett is the president and CEO of The Bennett Group. For additional information, please contact her by e-mail at maryann@the-bennett-group.com or by phone at 585-820-5457.

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