The USPS recently presented its 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 took 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 NCOALink® but still catches at least 70% of the moves no penalty will be assessed. A 7 cent per piece penalty will be levied against whatever 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 COAs 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 COAs 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.
Additional points: Adjudication will occur at the point of acceptance. Whichever 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 USPSs 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.
Critical Move Update error level tolerance...
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NCOA Link overview...
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Significant noncompliance
penalties starting January, 2010:
- Standard Mail: $.07 per piece entire mailing
- First Class
Mail: full rate no discounts
