Live From CM: USPS Faces Challenges Over Circulation Auditing

A publishing industry group is actively combating U.S. Postal Service challenges to controlled circulation figures, filing a challenge on behalf of one magazine this month and working with an advisory group to review current guidelines.

Controlled circulation business-to-business publications petitioning for readership verification are first audited by the USPS. Magazines that generate part of their circulation from Internet and telephone channels are increasingly having their subscriber figures questioned by the United States postal service. Ongoing controlled circulation magazines are rarely audited by the USPS.

American Business Media, a trade magazine organization, has filed a challenge on behalf of one magazine whose circulation claims were rejected, according to David Straus, counsel for American Business Media.

At least four magazines that rely on reader questionnaires, as opposed to subscription fees, have had part of their circulation claims rejected by the postal service.

The sticking point comes when the questionnaires are conducted over the telephone or the Internet. Postal officials feel that such records are harder to confirm than subscriber bounce-back cards, Straus said.

The USPS will not accept tape recordings of qualification calls or forms filled in on Web sites as records of verified subscribers. The postal service does allow circulation verification organizations such as the Audit Bureau of Circulations or BPA Inc. to conduct follow-up qualification contact efforts to readers coming in through these channels.

In the cases Straus has monitored, roughly half of a sample of the individuals so qualified could not be contacted. Of those that could, another half (on average) did not recall requesting the magazines. As a result, the USPS has invalidated a significant portion of controlled circulation records generated through phone calls or Web sites.

“I don’t believe that there is massive fraud: I think there is a breakdown in the [auditing] process,” Straus said.

At least one publication has failed to reach its stated circulation goals because of this, Straus said. The publication, which he declined to name, received a revocation letter from one of the rates and classification service centers. Straus filed an appeal to postal headquarters earlier this month.

No date has been set for a ruling on the appeal.

Straus also serves on the Periodicals Advisory Group, a group of 20 people that periodically meet to discuss magazine-related issues with postal executives. Within the past week, the PAG presented the post office with a proposal discussing remedies for the qualification question. To date, the USPS has not offered any comment on the proposal.

According to Straus, Sen. Joseph I. Lieberman (D-CT) has also written to the post office on behalf of American Business Media. Straus did not make the contents of Lieberman’s letter public.