Qualified Circulation

Discover the reporting requirements for education, public access and employee copies.

 



Household/Individual

Copies distributed to households for personal use by residents are eligible as qualified household/individual circulation. See AAM Rule C 103.3 Other Qualified Circulation.

If you serve digital editions to individuals for free, or paid for by a third party, please refer to the digital editions guide.

Qualification

Copies distributed to households for free, or paid for by a third party, are eligible as qualified household/individual circulation if the following requirements are met:

  • On the first day of delivery, a notice presents the recipient with dates (or term) and frequency of delivery and an option to decline delivery.
  • The opt-out option must include clear and simple instructions for the consumer.

In addition, for programs where delivery exceeds one year, the publication must contact each household annually to perform the following:

  • Confirm desire for continued delivery or offer choice to stop delivery. Contact may be via mail, email, telemarketing or robocall (automatic dialer).
  • Provide clear and simple instructions to stop delivery (opt-out) such as a phone call to the publication, direct mail response card, or in the case of robocalls, a push-button response.

Reporting

Copies distributed to households for free, or paid for by a third party, are classified as qualified household/individual circulation in AAM’s database and documents.

For the Audit

For the audit of qualified household/individual circulation, publishers must maintain records and make them available to the auditor. These records include, but are not limited to, the following:

  • Example of first delivery notice with term, frequency and opt-out instructions
  • Explanation and examples of the annual confirmation process
  • Route lists for each program

In addition, an attestation from the publisher must confirm the following:

  • Average number of copies claimed in the publisher’s statement period
  • Delivery was to valid residential addresses
  • Initial opt-out delivery notices were executed for all new recipients
  • If a delivery program exceeds one year, annual confirmation effort was made

Financial Transactions

AAM’s qualification review and audit processes do not govern or consider financial transactions related to qualified circulation. Payments received by third parties have no impact on the qualification or classification of the circulation.

If an individual orders and pays for a subscription, the circulation is eligible as paid individual subscriptions.

 

Education

Copies used by students in accredited classrooms as part of the curriculum are eligible as qualified education copies. See AAM Rule C 103.2 Education Programs.

If you serve digital editions as qualified education copies, please refer to the digital editions guide.

Copies available for pick up by university or college students are eligible as qualified public access copies.

Qualification

Copies used in accredited classrooms are eligible as qualified education copies if the following requirements are met:

  1. Request for newspapers and delivery must be to a school or educational facility with an accredited classroom setting for grades kindergarten and above.
  2. The newspapers will be used by students in the classroom as part of their curriculum.
  3. Affidavits are collected at least annually and after completion of the distribution. 
  4. The number of qualified education copies served to a classroom per day can’t exceed the number of students in the classroom (one copy may be added for the teacher).
  5. The total number of qualified education copies per school per day can’t exceed the number of students enrolled.

Reporting

Copies used by students in accredited classrooms as part of the curriculum are classified as qualified education copies in AAM’s database and documents.

For the Audit

For the audit of qualified education circulation, publishers must maintain records and make them available to the auditor. These records include, but are not limited to, the following:

  • Draw per school
  • Order forms
  • Affidavits

Affidavits

Affidavits are required for all (100 percent) of the classrooms. Programs for which affidavits are not received are not eligible for inclusion on AAM documents.

Affidavits must, at minimum, contain the following information:

  • Name and address of school
  • Statement to confirm the newspapers were ordered, received and used in the classroom as part of the curriculum
  • The quantity of copies and number of students in the classroom
  • Date(s) or date range copies were received
  • Name of teacher(s) who received the distribution (if completed by a principal)
  • Printed name, title and phone number of the person signing the affidavit
  • Signature and date

 Affidavits submitted electronically (via email and online) to the newspaper are acceptable.

  • All the information noted above is required.
  • Since a signature is not attainable electronically, the individual completing the form should include a statement confirming the information provided in the electronic affidavit is true and accurate. For example, “I agree the above information is complete and accurate.” It may be necessary to directly contact the teacher or school official to confirm the information contained in the affidavit.

It is up to each newspaper to develop their own affidavits and ensure they include the minimum content required by AAM.

Financial Transactions

AAM’s qualification review and audit processes does not govern or consider financial transactions related to qualified circulation. This includes sponsorship and fundraising efforts. Payments received by schools or third parties have no impact on the qualification or classification of the circulation.

 

FAQs about Qualifying Educational Copies

Students now consume news content in classrooms via print, digital replicas, tablet apps, smartphone apps and websites. Libraries are becoming media centers and librarians are serving as cross-platform media specialists.

As the educational environment evolves, Canadian newspapers should be aware of the rules and guidelines to qualify their educational programs for AAM. Here is a list of frequently asked questions and responses about qualifying educational copies.  More information is also available in AAM Rule C 103.2 Education Programs and the digital guide for education copies.

What are qualified education programs?

Educators use newspapers as a dynamic, informative teaching tools to bring real world examples to the subjects they teach. To actively engage students in this type of instruction, access to a newspaper’s content print or digital content is necessary. AAM rules and guidelines allow newspapers used in accredited classroom settings (K-12, college and home schools) to be claimed as qualified education copies.

What is the AAM audit process for qualified education programs?

The AAM audit process for qualified education copies confirms the following:

  • The newspaper content was available for use, either in print or digital format
  • The educational setting is an accredited classroom
  • Students engage with the newspaper in the classroom as part of the teacher’s lessons.
  • The quantity claimed is reasonable, meaning no more than one copy per student and one per teacher.

When a digital edition is used in the classroom, can the whole class or the whole school have the same username and password for access?

Yes. 

Can a principal, administrator, media specialist or librarian request the newspapers and complete the affidavits for all the teachers in the school?

Yes, but the newspaper is ultimately responsible for ensuring the teachers actively use the copies as part of the curriculum and the quantity claimed to AAM does not exceed the number of students and teachers. 

Are affidavits still necessary?

Yes, the affidavit should be signed by someone who knows that copies were available, actively used in the classroom by educators and the quantity did not exceed one per student and one per teacher. If one person orders and attests to a large volume of copies at one location, AAM staff may take additional efforts to ensure all requirements are met.

Are there any limits on education copies?

Copies claimed to AAM are limited to one per student and one per teacher. A classroom may receive print and have access to replica and nonreplica digital editions, but only one circulation unit may be claimed for each student and teacher.

Is a newspaper allowed to provide print copies or digital access to all students at a school, regardless if teachers are using them in the classroom? How are copies requested by the media center for general use classified?

If a school or media center requests copies for general use, they are eligible as qualified public access, not education copies.

  • For print, the total gross copies distributed are eligible for inclusion provided the quantity does not exceed one copy per student and faculty member.
  • For digital, each student or faculty member must have a unique identifier and only the net copies accessed by unique individuals, per issue, are eligible for inclusion.

Copies provided by the newspaper that are not requested or accepted by the receiving location are not eligible for AAM reporting purposes. 

 

Public Access

Copies available for use or pick-up by consumers in public locations are eligible as qualified public access copies.

See AAM Rule C 103.3 Other Qualified Circulation.

Qualification

Copies available for use or pick-up by consumers in public locations are eligible as qualified public access circulation if the following requirements are met:

  • Copies are intended for use by patrons or pick- up by consumers
  • Documentation is available to support the quantity of newspapers per issue distributed at each location.

Acceptable distribution venues include, but are not limited to, the following:

  • Retail outlets
  • Hospitals
  • Nursing homes
  • Restaurants
  • Medical offices
  • Barber shops/hair salons
  • Airlines
  • Other public locations

Reporting

Copies available for use or pick-up by consumers in public locations are classified as qualified public access copies in AAM’s database and documents.

For the Audit

For the audit of qualified public access circulation, publishers must maintain records and make them available to the auditor. These records include, but are not limited to, the following:

  • List of all distribution locations
  • Draw at each location
  • Contact information for management at each location

In addition, an attestation from the publisher must confirm the following:

  • Average number of copies claimed in the publisher’s statement period
  • Confirmation of delivery

Financial Transactions

AAM’s qualification review and audit processes do not govern or consider financial transactions related to qualified circulation. This includes sponsorship efforts. Payments received from third parties have no impact on the qualification or classification of the circulation.

 

Employee

Copies served to employees, retired employees, independent agents and correspondents are eligible as qualified employee copies.

See AAM Rule C 103.1 Employee, Correspondent and Agent Copies.

If you serve digital editions as qualified employee copies, please refer to the digital editions guide.

Qualification

Employee copies are eligible as qualified circulation if the following requirements are met:

  • Individual is an eligible recipient.
  • Copies are easily accessible to the recipients (made available for use or pick up in the normal work environment and delivered to retirees’ homes).
  • There is a limit of one copy per day, per recipient.
  • Copies distributed to individuals employed or contracted with more than one publication are only claimed as an employee copy for one publication.

Eligible recipients include the following:

  • Employees on the regular payroll (full or part-time) of the newspaper during the reporting period.
  • Employees of subsidiaries on the regular payroll who are actively engaged in the production or distribution of the newspaper.
  • Independent contractors (agents) currently involved in delivering the newspaper to subscribers.
  • Correspondents contributing at least one article per month that is printed in the newspaper.

Reporting

Copies served to eligible employees, retired employees, independent agents and correspondents are classified as qualified employee copies in AAM’s database and documents.

For the Audit

For the audit of qualified employee copies, publishers must maintain records that confirm the newspapers’ distribution and the active status of employment, retirement, contractor or correspondent. These records must be available to the auditor.

Financial Transactions

If an employee, retiree, correspondent or agent orders and pays a qualifying price for their own subscription out of their own pocket, the circulation is eligible as paid individual subscriptions.

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