At NPF this year, the industry was promised that all the answers to their questions about Full-Service would be included in the final Federal Register ruling. This ruling was posted in April. While it clarified several important details, some questions remain unanswered. Let's take a deeper look.

What Hasn't Changed The Federal Register solidified the Postal Service's intent to require Full-Service preparation for automation rates starting January 26, 2014. These preparation and submission changes will be required for First-Class Mail, Standard and Periodicals letters, flats and cards, as well as Bound Printed Matter flats. Any mailer planning to delay implementation in hopes that this would all blow over should take note: there will be no delays. Here's a rundown of the requirements:

1. Intelligent Mail barcodes on mailpieces, trays, and sacks must be unique for a minimum of 45 days.
2. Intelligent Mail pallet placards, including a unique pallet barcode, are required when mail is prepared on pallets according to the DMM, used for drop-shipping or Customer Supplier Agreement (CSA) preparation.
3. Drop-ship appointments must be scheduled in advance using the FAST system.
4. Mailing documentation must be submitted electronically, using Mail.dat, Mail.XML or the Postal Wizard. Mailers must identify the by/for information and barcodes used in the mailing.
5. Mailers who use specialized preparation, like CSA, must use that preparation for all their mailings.

Mail will continue to be checked for mail content, piece design, and sortation during mail acceptance. If a problem is found during verification, mailers have the option to re-work the mail, or forego the automation discount to send the mail as-is.

Updates and Clarifications The only acceptable tray or sack label will be the new Intelligent Mail tray label (IMtb). This layout includes one 24-digit barcode.
The Postal Service listed its definition of mail owners and mailing agents. This has been a major source of contention between mail service providers (MSPs) and USPS. The by/for data is populated by Mailer IDs and Customer Registration IDs, and in addition to being confusing, MSPs have been hesitant to request MIDs and CRIDs for all their customers. USPS has defined a mail owner as "the business entity, organization or individual who makes business decisions regarding mailpiece content, directly benefits from the mailing, and ultimately pays for postage on the mailpiece directly or by way of a mailing agent." A mailing agent is basically anyone who facilitates a mailing on behalf of a mail owner. While the mail owner information is not required for mailings under 5,000 pieces, this is likely too small a target for most MSPs. Those who want a consistent workflow may wind up requesting and specifying the mail owner information on all mailings anyway.

While palletization rules have been around for several years, the regulations have been clarified. Mailers must prepare pallets with Intelligent Mail container barcodes (IMcb) according to DMM standards when:
· First-Class mailings have at least 48 linear feet of letter trays or 16 linear feet of flat tubs
· The mailer has a customer service agreement (CSA)
· The mailing is separated onto pallets or other containers by destination
· Standard Mail or Periodicals mailings have more than 500 pounds of bundles or sacks
· Standard Mail or Periodicals mailings have more than 72 linear feet of trays
· The mailer chooses to containerize the mailing under DMM 705.8.0

Of particular interest to MLOCR mailers, a new requirement states that Full-Service automation letters cannot be combined in the same tray with unbarcoded, POSTNET or IMb mail that doesn't include a delivery point.

Most importantly, the Federal Register filing outlined the verifications USPS will perform on mailings starting January 26. In addition to the checks performed on automation mailings today, acceptance personnel will verify that barcodes on pieces, trays and pallets are present and readable, and that electronic documentation was submitted. Supplementary checks will be performed on the electronic documentation itself, but any problems found will not penalize the mailer for the first half of 2014.

Remaining Questions
The definition of mail owner versus mailing agent is a step in the right direction, but still leaves several scenarios unaddressed. In some cases, the actual mail submitter will have no insight into who "directly benefits from the mailing" because of the many layers of pre-processing completed by other companies.
While the rules for palletization are clearer, cases of co-palletization and other mixed mailing scenarios weren't addressed.
Lastly, the ruling states that while no assessments for electronic verifications will be made until July 2014, it's implied that mailers will be on the hook for any deficiencies at that time. What those assessments will be has not been announced.

Even with these unknowns, getting started on Full-Service is crucial. With the fall mailing season right around the corner, there will be little time to get on board before these changes are mandated. Getting started now is the key to mailing success.