Preliminary Comments on the IMb Full Service Federal Register Notice

without comments

“No assessments will be made as a result of any additional full service electronic verification until July 1, 2014.”

Now the threat becomes real, with a date attached to it.  Full Service Assessments (aka Penalties as a Revenue Stream) are levied AFTER the mail has long since left the position of the mailer.  With no details besides the USPS reporting to verify the validity of these assessments, mailers are going to be stuck.  The Microstrategy reports are difficult to navigate and decipher, and in some cases the results are questionable.  A lot of improvement would need to take place in order for the industry to have any confidence in that they are being penalized accurately and fairly.

“Should a mailing fail the existing verifications, the mailer may choose to have the disqualified mailing returned for re-work or pay the additional postage to mail at a non-automation price.”

This is huge.  Right now, if a Full Service IMb mailing has issues, it can be downgraded to Basic IMb and still receive automation prices.  This all-or-nothing approach has more to do with the USPS’ inability to increase IMb Full Service participation short of mandating it.  If Full Service was so great, mailers would not need a mandate to comply to, they would have complied voluntarily.  Add on the additional expense of having a mailing returned when an issue isn’t caught until well downstream.  By not including a Basic automation option for downgrading to, the penalty is huge.

IF the USPS incurs costs by having to process pieces manually vs on automation equipment, I can totally understand a penalty.  This all-or-nothing fail, however, in most cases will NOT force the USPS to process manually, not incur costs.  It’s akin to police ticket blitzes to increase revenue.  Tell it to the judge, who happens, in this case, to also be the policing force.
“The Postal Service is working with the mailing industry to resolve the current technical issues preventing the upload of eDoc for all full-service automation mailings prior to January 26, 2014.”

“The Postal Service is working with the mailing industry to resolve the current technical issues for MLOCR bundled-based flats prior to January 26, 2014.”

Please note – there are numerous current (and some old) technical issues.  Many of these issues have been worked on for a very long time, setting a date to have them fixed by doesn’t make it so.

Written by Lisa.Bowes

April 15th, 2013 at 10:01 am

Posted in USPS

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