April 29 2008 03:06 PM

The rules for Move Update are changing effective November 23, 2008, and the USPS is re-engaging its efforts to enforce Move Update Compliance. In the past, the USPSs efforts to evaluate a mailers compliance with the Move Update requirement were manually performed. However, this is soon to change.

The timing of the rule changes coincides with the postage rate increases effective May 12, 2008. Mailers will be using newly designed postage statements, and many of these new statements include a Move Update Method area, where the mailer must check off how they are complying with the Move Update requirement. Today, this requirement only applies to First-Class Mail and requires that the Move Update must be performed within the 185 days prior to submission of the mail to the USPS. However, effective November 23, Standard Class mailers of Letters, Flats and Parcels will also have to check one of those check boxes, and the frequency has been increased to 95 days prior to submission to the USPS. Checking the box on the postage statement certifies that the information on the form is accurate and subject to the language of the statements certification section.

While the Move Update requirement has existed for First Class Mail since July 1, 1997, it has been incorrectly interpreted and  misunderstood by many mailers. Details on the current requirement can be found on Postal Explorer (http://pe.usps.com) in DMM section 233.3.5. Also, publication 363 provides even more detailed information (http://www.usps.com/cpim/ftp/pubs/pub363.pdf).

Historically, the process of determining whether mailers were complying with the Move Update requirement was difficult. However, the USPS recently established processes to measure compliance for whatever Move Update method a mailer is employing. This includes an upgrade to their Merlin systems to verify whether the mail appears to be in compliance with Move Update requirements. As the mailing industry moves to the Intelligent Mail Barcode, it will allow the USPS to determine whether mailers are complying with the Move Update requirement even after the mailing has been made. That data will likely be used to trigger discussion with the mailer on their Move Update compliance procedures and whether improvements are required.

Under the current Move Update requirement for First-Class presort and automation discounts, Each address and associated occupant name used on the mail pieces in a mailing must be updated within 185 days before the mailing date, with one of the USPS-approved methods. 

Before the Mailing: For a marketing mailing from a rented mailing list, this is easy to understand. The list is acquired and run through a pre-mailing solution like NCOALink, which provides a change of the addresses of people who moved so mailing is printed with the new address. Transactional mailers that prepare transactional mail, such as invoices and statements, may have additional challenges. Large corporate mailing operations often have no control over the address data as its often contained in print image files generated by invoicing programs from other departments. A post-composition program can be used to get the name and addresses from the print image files, run CASS and NCOALink and return the corrected address and barcode information to the print image file before it is printed. However, in many cases, these corrections cannot make it back to the owners of these addresses to update the lists they came from. Over time, the ability to update the print image address expires, and future mailings cannot be delivered as addressed, resulting in an increase of UAA. That leads to the other point of confusion:

Update What? The address on the mail piece? The address in the database which created the mailing list? Both? Certainly the address on the piece must be updated with the new address prior to mailing. Whether the original mailing list must be updated would depend on which method you are using for Move Update compliance.  Lets briefly review the most common Move Update methods:

Address Change Service (ACS) supplies an electronic address change after a mailing. In most cases, the original mailing list is updated with the new address in order to have it appear on the next mailing. The requirement to update the list 185 days prior to the mailing requires mailing to a new address at non-automation rate the first time it is mailed if ACS is the only method of Move Update used. The logic is how could the address be updated within 185 days prior to a mailing if never mailed before? Any First-Class Mail discount can be claimed the second time the piece is mailed since the first mailing starts the clock of the ACS move update process.

FASTforward processing can be utilized for mail processed on MLOCR Equipment. This allows a new address to be sprayed on the mail piece at the time of machine sortation so it will always update the address on the mail piece. During the first 13 months that FASTforward can change an address, mailers would normally not update their address databases with changes supplied by the USPS because mailers were not directly made aware of the changes that were made by FASTforward (unless the FFMUNF process was utilized). Therefore, it is important to have additional processes in place to handle mail with moves effective between months 13 and 18, when mail will be returned with the new address on the mail piece. If you fail to update your original databases with the new addresses on those return mail pieces promptly, you may lose the ability to update the customer address as, after 18 months, the mail piece will be returned without the new address affixed.

NCOALink users must use the new address on the mail piece. NCOALink processes utilize either 18 or 48 months worth of change of address information. The user must apply the new address to their original list before the change of address disappears from the NCOALink database. With 18-month data, after 18 months, NCOALink  would no longer change that address, resulting in return mail that will not have a return address on it since the forwarding order has expired. You do have 18 months to electronically update the original database record. An additional benefit is that NCOALink will also flag records that the USPS knows the recipient has moved but for which there is no new address available. Mailers can use this information to suppress pieces from being mailed or trigger additional research.

Ancillary Service Endorsement Like with ACS, the mail owner will get mail returned with one of those yellow labels applied or get a postcard with the new address shown. The new
address must be used to update the customers address on future mailings within the required time frame (185 days right now) in order to be compliant. As noted with ACS, the other Post Mailing solution, the first mailing to utilize an Ancillary Service Endorsement does not meet the Move Update requirement (unless an additional pre-mailing solution is also utilized).

Alternative Method  What if you cannot change the address on the mail piece because your industry requires some kind of notification or verification? To stay in compliance, you would mark those addresses in your original database and put mail pieces for these addresses in a separate First-Class mailing that does not attempt to claim any presort or automation rates or apply for alternative Move Update process, as described in USPS Publication 363.

New requirements take effect November 23, 2008. However, since these requirements must be satisfied 95 days before the mailing takes place, Standard mailers must really implement this requirement on or after August 20, 2008 to ensure USPS compliance.

Lloyd Moss is the Director of Postal Affairs and Pre-sort, Pitney Bowes Group 1 Software. Please visit www.g1.com.