The USPS recently presented it’s most recent and, as far as we can tell, final position on Move Update Compliance and adjudication. Effective January 4, 2010 penalties for non-compliance of the move update rules put in place on November 23, 2008 will begin to take effect. Using Performance Based Verification (PBV) a sample will be taken from the mailing and run through MERLIN. MERLIN will be lifting names and addresses and transmitting that data to the NCSC in Memphis checking for change-of-addresses (COA) that have occurred between 95 days and 18 months.
The current tolerance is 70%, so if the mailer misses six or more COA but still catches at least 70% of the moves no penalty will be assessed. A 7 cent per piece penalty will be levied against what ever portion of the mailing does not meet the 70% threshold.
For example, consider a 200,000 piece mailing, with a sample size of 2,000 pieces run through MERLIN.
If the NCSC determines there are 20 COA’s that have occurred in the sample and the mailer corrected 14 (70%) of them, there is no penalty assessed.
If however the mailer only corrected 10 COA’s there would be a 50% failure rate. A 7 cent per piece penalty would be levied against 20% of the entire mailing (50% less 30% threshold) 40,000 pieces would be penalized .07 or $2,800 or the mailing could be “re-worked.”
- Adjudication will occur at the point of acceptance
- Which ever party signs the postage statement will be held accountable.
- Returns with no new address provided still count against the tolerance and should have been removed from the list.
While this is a softening of the USPS’s original position that a 7 cent per piece penalty would be levied across the entire mailing, officials are warning that the 70% threshold will be reviewed and expected to increase. Additionally, repeated failures of the testing may result in harsher penalties, so simply paying the penalty at acceptance is not an acceptable model for compliance to the Move Update requirement