Latest Scoop on Move Update
SouthEastern Mailers Association Article - February 2003
by Robert B. Swick,
Vice President Data Services, Anchor Computer, Inc.
The most immediate item of interest (or concern if you are a First class mailer who
hasn’t been in compliance with the Move Update regulation) is that the compliance
element of Move Update is scheduled to roll out nationally in March.
The good news is that the extreme strictures of implementation experienced in the
southeast test areas will be not be the norm in the future, supposedly. The qualifier
added at the end is necessary since the review and auditing process is managed at each
of the 85 USPS field district offices, which adds that amount of human variability.
So, what is this kinder, gentler form of Move Update compliance? First class mailers
and their mail service providers must understand what it takes to be in compliance.
To start with, the Postal Service offers four (4) name and address update services:
- National Change of Address (NCOA)
- Fastforward®
- Letter Endorsements
- Address Change Service (ACS)
Any one or combination must be employed at least every six months.
"Employed" means incorporating the changes into your database.
Usually a forwarding order expired notice on
an undeliverable mail piece is the trigger for the USPS district office
auditors to check a company’s update process. If an approved procedure is in place,
that should end the investigation. However, if noncompliance is determined then the
mailer will be required to return the discounts received upfront for either the whole
mailing or a portion designated as not being in compliance. For example, if the mail
returns trace back to just one list where multiple lists were used then focus
will rest only on mail relating to that cited list.
A not so "kind and gentle" approach could be to (a) define the entire mailing to
be out of compliance and (b) extending the noncompliance to all mailings for up
to one year.
At this point it’s important to remember that postage discounts are given upfront
and in good faith for the list update (work share) effort accomplished by the
list owner. No work share no postage discount earned. So use of words like
"fine" and "penalty" are incorrect. Reimbursement of unearned postage discount is
what’s at stake.
The second development in the evolving world of Move Update is an initiative to
create an official Postal Service document that holds list owners responsible
for being in compliance with the regulation. Working in a similar manner as the
CASS certificate, this document will identify what method was used and when it
was last applied to the database. This directs ultimate responsibility on list
owners rather than mail service providers, an important distinction.
Another development may be forthcoming that relates to the planned expansion of the
Move Update regulation to Periodicals and Standard class mailers. It is possible that
the USPS will issue a second official announcement on expansion of the regulation.If
that happens the scheduled spring 2004 planned rollout may be delayed as much as another
twelve months. More is expected on this, perhaps on or before the April National Postal Forum.
The last item relating to Move Update is one of attitude.
Most look at this regulation as a cost of doing business. Frankly, that is a warped
viewpoint.It is far more correct to recognize and embrace the benefit of maintaining clean lists.
We owe our livelihoods to the direct mail medium, which is a bit ironic if we
aren’t doing everything in our power to see that it works as best as possible.
That means making our lists as deliverable as possible. Clean, deliverable lists
generate responses. Regardless of what mail class is used. Regardless of any Postal
regulation. Clean files should be "best practices" standard! For those buying
into position, the first couple of update notices presented should be
irrelevant.
Continued success in these challenging times.
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