Postal Q&A: Paid obits as ad matter; incorrect address corrections

Here are more questions and answers from inquiries to the National Newspaper Association Postal Hotline in recent weeks.

Q: How does the Post Office look at obits on a Postal Report from our papers? We have both paid obits and basic death notices with only a surcharge, so how does the post office know the difference as they audit?

A: Paid content, whether in the form of editorial matter or otherwise, must be counted as advertising. The post office may not know the difference, but the rule covers all paid content. Here is the complete set of rules for advertising from DMM 207.4.12.1, with pertinent sentence in italics:
“Advertising includes:
A. All material for the publication of which a valuable consideration is paid, accepted, or promised, that calls attention to something to get people to buy it, sell it, seek it, or support it.
B. Reading matter or other material for the publication of which an advertising price is charged.
C. Articles, items, and notices in the form of reading matter inserted by custom or understanding that textual matter is to be inserted for the advertiser or the advertiser’s products in the publication in which a display advertisement appears.
D. A newspaper’s or periodical’s advertisement of its own services or issues, or any other business of the publisher, whether in display advertising or reading matter.”

Q: I would like to see a copy of last year’s Statement of Ownership for a newspaper. Their office is reluctant to share. Any ideas on how to get such?

A: Post Office of entry is obligated to provide this under the Freedom of Information Act. But it could charge a reasonable copying fee. Other than that, a copy might be obtained from public library via last October’s issues, if run according to law. If the post office refuses, NNA can help you appeal to the postal Pricing & Classification Service Center in New York City. You may so advise the postmaster if necessary.
Lynne Lance, chief operating officer and membership director of NNA, also advised that because most state press associations collect this information from newspapers for dues and/or advertising information, they might provide it because it is a public record.

Q: I wanted to follow suit of some of the national newspapers by using a weekend dateline that includes both Saturday and Sunday. It is out in the newsstand all weekend until the next publishing date. Do you think this is going to cause me problems with our post office as to our publishing dates?

A: No. You can feel free to use the dual days, or even Friday-Sunday as some tri-weeklies do, so long as you are not changing the frequency. A frequency change or number of publishing days per year change must be reported on PS Form 3510. The current fee is $80.

Q: Can a gift subscription donated to charity to be resold be counted as paid or must it be complimentary?

A: Yes, so long as “the recipient charity keeps records and gets those records back to the publisher, then it is considered paid if sold above nominal. That way the recipient charity is acting as an agent. If they don’t want to do that, then they are considered samples copies,” according to Chuck Tricamo, manager of the Pricing and Classification Service Center of U.S. Postal Service in New York City. Nominal prices are those sold for at least 30 percent or more of the basic price per term.

Q: I have gotten two manual address correction system notices (yellow sticker, PS Form 3579) from an out-of-town subscriber, and after checking with him, I learned that his address is correct.

A: This is an age-old problem, often thought to be the result of substitute or new carriers on the route who don’t yet know the scheme for customers on the route. They simply mark a periodical as undeliverable and generate a notice (although they take forever through the manual system).
That’s made worse by higher turnover in a full-employment economy. To prove that thesis, one of our members recently got this response from a proactive postmaster at their original-entry office that they shared with me, along with some excellent customer service including a credit:
“I checked with (the receiving post office), and apparently this was because of a problem employee that has since been removed. The carrier on the route is aware of the issue, and there shouldn’t be any more problems getting this delivered moving forward. To compensate, I will give you the next one free of charge since it was because of our collective mistake.”
This is a good time to remind NNA members that one of the major advantages of converting to Full Service Intelligent Mail Barcoding is the free electronic ACS. We plan to offer more on that subject in an upcoming issue. 
© Max Heath 2018, National Newspaper Association.