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PRIORITY MAIL More Considerations for Full Service IMb The time to weigh your options is before the January 2014 deadline. By Nancy DeDiemar s the January 26, 2014 deadline grows ever closer for implementing full service Intelligent Mail Barcode (IMb) to qualify for automation-based postage discounts, printers who provide mailing services are realizing it may take a substantial investment in hardware, software, internal production control, staff training, and customer management to be effective in the full service IMb environment. To help mailers with the transition, many industry vendors, particularly those who sell software, are offering readiness analysis, training, implementation assistance, and other information—much of it free or at minimal cost. A Tech Credit Update Earlier this year the USPS announced its intention to offer an incentive program to help mailers with the costs of transition to full service IMb. Called the Full Service Technology Credit (often referred to as tech credit), the program required permission from the Postal Regulatory Commission (PRC). On April 16, 2013 the USPS filed a request with the PRC to approve the tech credit promotion. Several industry organizations (representing mailing service providers, newspapers, and major mailers) and big mailers (Valpak, Time Inc., and Conde Nast) submitted comments to which the USPS replied. In its ruling, published June 10, 2013, the PRC found that none of the commenters objected to the concept of an incentive for mailers to convert to full service IMb, but that many objected to one or more provisions of the current USPS proposal. The objections mainly centered on whether the tech credit, as proposed by the USPS, was fair. The commenters noted that two groups would not benefit at all from the tech credit—mailers who were early adopters of full service IMb (because they have already incurred their costs) and small mailers (those with fewer than 32 QUICK PRINTING / August 2013 125,000 pieces of qualifying mail volume) because they were not offered the tech credit. A second fairness argument was related to the cost of the tech credit incentive, estimated by the USPS to be $61.6 million. In the filing, the USPS requested authority to adjust the annual price caps (the mechanism by which postage rates are raised) to recover the $61.6 million. The PRC disallowed this provi- sion, which in practice would have had all mailers contributing to the recapture of the tech credit costs (in the form of increased postage rates), not just those who had benefited from it. The tech credit promotion had been set to run June 1, 2013 to May 31, 2014. On June 24, the USPS announced that will not proceed with the promotion due to the PRC's decision not to allow the price cap treatment and the USPS' financial condition. More Decisions for Full Service IMb One source of contention between the USPS and mailing service providers for full service IMb has been the definition of mail owner and mailing agent, both of which are embedded in the IMb—Mailer ID or MID for the mailing agent, and Customer Registration ID or CRID for the mail owner. Understandably, mailers have been reluctant to request MIDs and CRIDs for all their customers without knowing exactly how the USPS intends to use the information. The USPS definition of a mail owner is "the business entity, organization, or individual who makes business decisions regarding mail piece content, directly benefits from the mailing, and ultimately pays for postage on the mail piece directly or by way of a mailing agent." A mailing agent is anyone who facilitates a mailing on behalf of the owner. The USPS does not require mail owner identification for mailings of fewer than 5,000 pieces. While this is a benefit for mailers processing small mailings, it brings up a production control issue for mailers who have a mix of over- and under-5,000 piece mailing jobs. Essentially, it creates two kinds of mailings—those that require a CRID and those that do not. Rather than develop two sets of procedures, the mailing service provider might find it easier to use a CRID on every mailing, which means obtaining a CRID for every customer. Another decision needs to be made for move update. Full service IMb adds a fifth ancillary service endorsement for mail undeliverable as addressed (UAA). Electronic Service Requested printed on the mail piece tells the letter carrier that the specific disposition of the UAA mail piece—address service, change service, forwarding service, return service, or temporary return service—will be found within the IMb. Mailing service providers will likely need a scanner or (continued on page 39) w w w. M y P R I N T R e s o u r c e . c o m