Reducing UAA Must Focus on New Movers
In a recent post, I addressed the issue of undeliverable as addressed (UAA) mail, and how brands, businesses and other mailers lose more than $1 billion a year by not getting their mail addressed properly. It's a solvable problem.
Both the USPS and the DMA have made public commitments to reduce UAA as an industry goal, both of which would help marketers and their bottom lines. Progress toward UAA reduction, however, has not been uniform.
Recently, Charley Howard, who is the vice president of postal affairs at Harte-Hanks (disclosure: Harte-Hanks is a client), discussed this concern in a monthly e-newsletter he writes for the company called Postology. Charley wrote about UAA, and explained why UAA reduction goals have been slow to materialize. One of the key reasons has nothing to do with mailers, and everything to do with mail recipients: Too few Americans are filling out National Change of Address (NCOA) forms as they had previously. In fact, less than 50 percent are now doing so, and its ramifications on UAA volume are profound.
Frankly, mailers must supplement their use of NCOA with proprietary change-of-address/new move data from commercially available sources in the private sector. There's just no way around this. However, by taking advantage of such services (as all direct mailers should), there is a risk that the USPS, ironically, will penalize the mailer. Charley explains the paradox here, used with permission:
USPS New Moves Source Is not Enough
"In addition to ... postal-approved methods for Move Updates being applied to mailing files, there are those in the industry that additionally supplement postal moves with a Proprietary Change of Address (PCOA) service offering (for example, Harte-Hanks offers such a service). The sources of this move data tend to come from utility, telecommunication and publishing companies. In recent years, PCOA has developed into a near necessity because of the diminishing numbers of people who fill out the USPS Change of Address form.
When NCOALINK started in late 1986, more than 90 percent of all moves were captured. Today the use of COA cards has fallen to less than 50percent of moves. How can the USPS ever hope to reach its goal of cutting UAA mail by 50percent if its own source for Move Update data has fallen below half of all moves? Forcing mailers to go outside the Postal Service to attempt to obtain the balance of the moves contains some postage risk, however.
During Mail Acceptance, mail samplings are run through the MERLIN detection machine. The scanned records are passed by the USPS's COA data to test for Move Update compliance of 90%. There is a chance of failure through the use of proprietary sourced moves. Here is an example. Say a grown child leaves home to go to college or to get a job and an apartment. The child files the COA with the USPS. Assume 9 months later the child returns home for whatever reason and no COA is filed. The USPS COA has the first move but not the second. The mail owner, using a PCOA, has obtained the second move back to the original address and is using it in the current mailing. MERLIN would show this as a failure because the move the USPS has on record is not reflected in the mailing. The service provider would have to fight this ruling to prove that it has the more current data.
The real problem here is that the USPS's own COA data is inadequate to achieve the desired results. It is inadequate to even validate the thoroughness of Move Update compliance. The USPS needs to recognize that along with less use of the mail by younger generations, comes little to no use of COA as a stand-alone product. Therefore the USPS needs to supplement its own data with outside sourced data to become the sole repository of moves, once again. The USPS needs to invest in better data to save more in the end - and only then can UAA be reduced in line with Postal Service management goals."
This opinion in its entirety reflects Charley's view—and not necessarily my own or that of Harte-Hanks. But, I do believe that using PCOA should be recognized in some fashion by USPS, so mailers can be rewarded for keeping their mail off the UAA track and in the recipients' hands. Putting the onus on the mailer to explain how its list is more up to date than the USPS's on change-of-address concerns seems to be a burden that does not reflect today's list hygiene realities. Either USPS should incorporate PCOA sources in MERLIN, or it should provide some sort of seal of approval on what private sector sources are already doing to help mail reach the intended recipient. Let me know your points of view in your comments here.