BMEU full-service mailers have transitioned to participate in Seamless Parallel

On May 8, the U.S. Postal Service published a final notice in the Federal Register notifying the mailing community that required mailers that enter full-service mailings at a Business Mail Entry Unit (BMEU) to participate in Seamless Parallel by June 1. In addition, the Postal Service provides advance notice of its intent: To require all mailers with an authorized Detached Mail Unit to enroll in the Seamless Acceptance Program by May 1, 2021; and to verify all BMEU-entered full-service mailings using only automated sampling and verification processes beginning July 1, 2021.

By MAX PAXTON,
National Newspaper Association

‘Seamless Acceptance’ is a project by USPS to eliminate verification of each mailing by a postal clerk. In the traditional verification, each mailing was weighed and tested against the mailing statement submitted by the mailer. But USPS is looking to save the acceptance cost and instead just wants to measure samples of each mailing in a random process. Although Seamless might eliminate a postal clerk, it puts a greater burden on the mailer to be precise because variations that result in postage shortages will eventually carry penalties.
This means that if your newspaper is a Full Service ImB mailer, like it or not, your mailing will be enrolled in the Seamless Parallel program. Initially, there won’t be much of a change. You’ll continue to submit your Periodical postage statement, Form 3541, electronically using whatever software you currently use. Postage payments may be made by whatever method currently used, whether by deposit to your trust account at your local entry post office or electronically through the Electronic Payments System (EPS). The Business Mail Entry Unit (BMEU) clerk at your post office will continue to verify your mailing, checking weights, etc., just as before.
But, somewhere downstream, there will be a sampling process, and those mail piece characteristics will be verified and will appear in the dashboard of your Business Customer Gateway.
For many NNA-member mailers, Seamless Parallel and the follow-on Seamless Acceptance will only affect a portion of your mailing. It will not be used to verify DDU mail or mail entered at nearby post offices by Exceptional Dispatch. For most newspapers, it will only apply to papers mailed to out-of-county subscribers.
The controlling document that explains the entire streamlined mail acceptance policy of the USPS is called Publication 685. It was put out in 2018 and is available on the USPS website (https://bit.ly/3e5cu3I).
I have a number of questions about the implementation of Seamless Parallel for community newspapers, and by extension, full Seamless Acceptance.
Publication 685 says that to get onto Seamless Parallel, mailers should work with their BMEU clerks to begin the process. But, we’ve not heard anything from our entry post office about transitioning our mailing by the June 1 date, and my BMEU clerk wasn’t sure she knew what Seamless was. I don’t think this is a unique situation around the country.
On the other hand, we have heard of BMEU clerks contacting the local paper and declaring that the paper had to go Seamless — months before the Federal Register notice was published.
As I see it, the takeaway is that very little should change for you if you are pushed into Seamless Parallel until July 1, 2021, at the earliest, when the Register notice says all 90% Full Service mailings entered at a BMEU will have to be Seamless.
NNA has been concerned about a number of the provisions of this mandate. During the comment period on this rule, NNA expressed concerns about the downstream verification of piece weights, about the speed of adoption of this rule, about possible additional costs to mailers to comply with this rule, and about the future possible effect on newspapers that were not Full Service and were being manually verified by BMEU personnel.
USPS attempts to answer these questions in the supplementary information published with the Final Notice, and if you are concerned about the implementation of Seamlesss Acceptance, it could be worth a read. It can be found at https://bit.ly/2zR5Ak3.
The Postal Service says that the issue of concerns over downstream sampling is being addressed by a USPS Work Group. Tonda Rush and I have been participating in this Work Group, and frankly, we don’t think that the group understands how small-volume Periodicals mailers use the system. We’re not convinced that the Postal Service has addressed this issue. They have said that during the test period in which mailings were sampled that they have found very few that were off the stated weight. They also say that mail pieces will have some allowance of variation — about 3% — off that stated weight. Mailers will be given four strikes before any penalties will be assessed. And they say that Full Service mailers can see all instances of failed tests on their Mailer Scorecard in the BCG dashboard. About all we can advise is that you need to be watching, and we’ll continue to monitor the situation and report concerns as they occur to USPS management.
The Postal Service punted on the question of providing financial incentives in the form of rate discounts for implementing Seamless, saying that it was up to the Postal Rate Commission. With all that’s going on with Trump’s fight with USPS over package rates, incentives for Seamless are surely way down the PRC’s list.
The Postal Service has said that newspapers not now in Full Service ImB will continue to be entered and verified at the entry office by BMEU personnel and that they have no plans to require Full Service and, by extension, Seamless Acceptance. This could change, of course, and we’ll watch this.
We also can’t give a lot of guidance on how to work with your local BMEU at your entry post office to get onto the Parallel Seamless. It’s my assumption that the BMEU clerks will unilaterally make the changes needed on their end to make this happen, and the only notice you might get is to begin seeing entries on your Mailer Scorecard, but this is pure speculation. It might be worth a conversation with your BMEU.
Please keep NNA informed of any issues that crop up around the roll-out of the Parallel Seamless program. If we can learn of issues promptly, possibly we can get the Postal Service to address them before they become hardened into USPS policy.

Matt Paxton is NNA Postal Chair and a member of the Mailers Technical Advisory Committee for NNA, along with Brad Hill of Interlink and NNA's Tonda Rush.