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Move Update assessments have been initiated. Starting January 4, 2010, the new assessment charge of $0.07 per piece on the applicable noncompliance percentage of either a First-Class or Standard Mail mailing claiming automation rates went into in effect. The February 1st Domestic Mail Manual spells out the new requirements as approved by the Postal Regulatory Commission.
Specifically, mailers that claim presorted or automation prices for First-Class Mail, or claim any Standard Mail prices, must identify on the postage statement which Move Update method was used to ensure that the mailing meets the Move Update standard. Additionally, on each postage statement, mailers or their agents must also affix their signatures to certify that the mailing presented for acceptance qualifies for the prices claimed. If a mailer does not identify a Move Update method and certify compliance, then the Postal Service can reject the mailing, unless the mailer agrees to pay the First-Class Mail single-piece price. This is a very costly action.
To recap, the Move Update standard requires that a mailer participate in an approved Move Update process (such as NCOALINK, Address Change Service of all varieties, etc), and use the change of address information received through the approved Move Update process to correct the mailing addresses for the mailing.
Recently, however, the Postal Inspection Service has been checking mail owners to be certain that “moves” captured are effected in their mailing database, not just the mailing file. This has been a longstanding requirement for First-Class Mail presort and automation prices. Prior to November 2008, however, the frequency with which a mailer was required to participate in the Move Update process and make the requisite address changes was within the 185 days immediately preceding the date of mailing. In November 2008, this frequency was reduced to 95 days immediately preceding the date of mailing. The Move Update standard, including the 95 day frequency, was extended to include all Standard Mail in November 2008.
What is interesting is that Move Update testing performed by the USPS indicates that Standard Mailings tend to be more in compliance than First-Class mailings.
Move Update Nuts & Bolts
Capturing Move Information – According to the USPS, the Move Update standard is designed to help assure that mail reaches its intended recipients in a timely manner. It is also intended to reduce the number of mail pieces that require forwarding, return, or disposal as waste, thus reducing Postal Service costs. The problem is that the percentage of movers that fill out and file change of address (COA) forms has dropped from a high of 78% to just 53% today. Additional methods for capturing move information, therefore, need to be adopted if the Move Update standard is to work effectively.
Compliance Testing – To test compliance, the USPS developed new procedures known as Performance Based Verification (PBV). Introduced Spring 2009, PBV allows the Postal Service to sample mailings during the acceptance process and compare mail piece addresses within the sample against the change of address information in the National Change of Address (NCOA) database. MERLIN is used during mail detection where the address records are scanned and captured and sent to Memphis for validation and comparison to the NCOA database. The ratio of the number of failed COAs – addresses that should have been updated per Postal Service records – to the number of actual COAs (all changed addresses for addresses in the mailing) is calculated. If this ratio for the sample is sufficiently high (30 or more percent), the mailing is subject to an additional postage charge known as the Move Update assessment charge. Mailers are offered the option of taking the mailing back and reworking it to avoid the Move Update assessment charge. Mailers need to note that if questionable records are removed from the mailing, the presort requirements might not be met. It is also entirely possible for the mailing to be current and the sample chosen to have an inordinate number of uncaptured moves, such as for Puerto Rico where matching may be particularly difficult due to postal address standards. This would be an isolated area of problems and not represent the entire mailing.
A provision for multi-client mailings is also included for the first year after implementation. A mailer submitting a combined multi-client mailing that fails the Move Update verification may have additional postage attributed to individual clients, given certain conditions described in detail on the ribbs.usps.gov website. If the conditions are met, the Move Update Assessment Charge of $0.07 could apply to a different number of pieces, thus affecting the overall assessment charge for the mailing.
The PBV process does not establish compliance or noncompliance with the Move Update standard. It is merely a tool that the Postal Service uses to test mailings. It is designed to facilitate the acceptance of mail in the event that the PBV Move Update process determines that a sample of the mailing has failed above a given tolerance.
Mailers who believe the Move Update assessment charge has been applied to their mailing(s) in error may appeal to the Pricing and Classification Service Center in New York City.
The percentage of a mailing paying the additional charge is based on the percentage of failed sample pieces above the tolerance. Each assessed piece pays an additional $0.07. As examples, with a tolerance of 30 percent exempted from the charge: