Home Delivery Paid

Ensure your newspaper's paid subscriptions count as paid circulation.

 

A subscription is defined as the purchase of more than a single issue. Subscriptions purchased by individual customers for personal use are eligible as paid home delivery if the purchase price is at least one cent, net of considerations. See AAM Rule C 1.1 Paid Circulation Defined.

It is the publisher’s responsibility to ensure their home-delivery promotions are executed in compliance with all AAM rules and guidelines. Upon request, AAM’s audit department will provide a confidential review of clients’ programs. If you are developing an initiative that is not addressed in this guide or you have additional questions, please contact AAM.

 

Note: While AAM Rule C 1.1 Paid Circulation Defined is the primary rule defining paid circulation, it is not the only rule to consider when developing home-delivery promotions. Rules also govern premiums, combination sales, frequency conversions, etc. Therefore, a newspaper must consider all rules applicable to the program being developed.

 



Apartment Programs

Subscriptions included with apartment rentals are eligible as paid home delivery if the following requirements are met.

  • A lease addendum presents the subscription in a clear and conspicuous manner to include the term, frequency and amount of monthly rent allocated to its purchase.
  • The dollar amount allocated to the subscription is at least one cent, net of considerations. See AAM Rule C 1.1 Paid Circulation Defined.
  • The tenant is expressly asked to accept or decline the subscription (yes and no response options).
  • If the subscription is declined, the addendum clearly informs the tenant that rent is reduced by the subscription value.
  • The tenant presentation excludes any reference to the subscription as being free, no additional cost, complimentary or other synonymous language. Copies presented or implied as free are only eligible as verified public access circulation.

Example:

Lease Addendum
A 7-day subscription to the Illinois Today is included with your monthly rent of $900 (a $5.00 value per month). Would you like to receive this subscription?
___Yes ___No
If you do not wish to receive the subscription, you will receive a refund of $5.00 each month.
_______________
Signature of Tenant
August 15, 20XX
Date

 

Charitable Donations

When solicitations indicate that a charitable donation is included in the purchase price, the subscriptions are eligible as paid home delivery if the following requirements are met:

  • The donation amount and name of charity are clearly identified.
  • The subscription purchase price is at least one cent plus the full value of the donation.
  • See AAM Rules C 1.1 Paid Circulation Defined and C 5.7 Subscriptions Involving Charitable Donations.

 

Combination Sales

When two or more different priced publications are sold together (newspapers or periodicals), the circulation is eligible as paid home delivery if the following requirements are met:

  • The selling price of the combination package is at least one cent per subscription, net of considerations. See also AAM Rule C 1.1 Paid Circulation Defined.
  • Subscriptions to each publication in the combination package are generally available for sale separately in the marketplace. See AAM Rule C 5.3 Combination Sales.
  • None of the publications are stated or implied as free, no additional cost, no extra charge, complimentary or other synonymous language.

For eligibility as paid home delivery, the solicitation for combination sales may be presented in either of the following ways:

  • Promote only the sale of the combination package. If the solicitation promotes only the combination package, the purchase price offered must be a minimum of one cent per publication, net of considerations.
  • Promote the combination package as well as a subscription to one or both of the publications individually (optional). If the solicitation presents one or both of the publications individually, in addition to the combination, the individual purchase prices must be at least one cent less than the combo price.
     

 

Note: AAM Rule C 5.1 Premiums Defined stipulates that priced publications (newspapers or periodicals) are not permitted to be positioned as premiums (free gifts). Rather, the rule governing combination sales applies.

 

Examples:

Buy a one-year, 7-day subscription to both The Gazette and The Journal for the low price of only $100!

___ Sign me up for a one-year subscription to The Gazette and The Journal for only $100!

or

Buy a one-year, 7-day subscription to The Gazette (7-day) and to Best Ever Magazine (12 issues) for the low price of only $100!

___ Sign me up for a one-year subscription to The Gazette (7-day) and Best Ever Magazine (12 issues) for only $100!

 

Contests

If a consumer is entered into a contest, directly resulting from a subscription purchase, qualification of the subscription is not impacted. The subscription is eligible as paid home delivery provided the solicitation complies with all other AAM rules and guidelines.  

Technically, if the winner of the contest is a subscriber, the individual received a premium. If, over the audit period, the number of winners is minimal, the impact to paid circulation is immaterial. Therefore, we consider it to have no impact on subscription qualification.

No disclosure of these contests is required. See AAM Rule C 5.5 Contests and Coupons.

 

Paid Subscriptions Using the Word “Free”

If part of a subscription term is promoted as free, the entire term of service is eligible as paid home delivery if the following requirements are met:

  • Promotional materials state the subscription term and frequency.
  • The purchase price is at least one cent, net of considerations.
  • Contract portion of the offer states the full-delivery term and purchase price of the subscription. See AAM Rule C 1.1 Paid Circulation Defined, section (d).

The contract portion of the solicitation is:

  • The direct mail piece where the consumer actually chooses the purchase option (i.e. by checking a box).
  • The order page on the Internet (or shopping cart summary).
  • The point of verbal agreement in a telemarketing script or inbound call.

If part of a term is presented as free in easy pay offers, the promotional material must contain language that implies value to the free term. For example, if it solicits “Choose Easy Pay and get the first 4 weeks free,” then paid value is implied by stating, “That’s the first 8 weeks for the price of 4.”

Copies presented or implied as free without the contractual statement of full term and price are only eligible as qualified home delivery – targeted circulation.

Examples:

Buy or renew a Monday - Sunday subscription to The Gazette today at regular prices and get up to three extra months absolutely FREE!

Yes! Sign me up for or renew my 7-day subscription today!

_____ 1 month for $10 plus 1 month free - that's 2 months for the price of 1.
_____ 3 months for $30 plus 1 month free - that's 4 months for the price of 3.
_____ 6 months for $60 plus 2 months free - that's 8 months for the price of 6.
_____ 1 year for $100 plus 3 months free - that's 15 months for the price of 12.

 

Sign up for Easy Pay today and get your first month subscription to The Gazette absolutely FREE!

That's right, the first month is on us !

Yes! Sign me up for Easy Pay today and get one month completely free!

That's your first two months for the price of one.
_____ 7-day ($9.00 per month)
_____ 6-day ($7.00 per month)
_____ Weekend only ($5.00 per month)
_____ Sunday only ($4.00 per month)

 

Frequency Changes (Upgrades)

Copies served to paid subscribers, resulting from a frequency change, may be eligible as paid home delivery. There are three ways the frequency change may occur:

  • Frequency Conversion (“Forced”) – Elimination of Frequency Ordered
  • Frequency Upgrade (“Opt-Out”) – Publisher’s Discretion
  • Subscriber’s Choice

If digital editions are used for a frequency change, please refer to paid subscriptions, bundled sales and AAM Rule C 5.10 Subscriptions Involving Digital Editions.

Frequency Conversion (“Forced”) – Elimination of Frequency Ordered

When newspapers eliminate a frequency and, as a result, must change or upgrade subscribers to a new frequency, all copies served for the new frequency are eligible as paid home delivery if the following requirements are met:

  • The discontinued frequency isn’t promoted within 30 days before elimination or reinstated for six months.
  • Effected subscribers are notified in writing prior to the change. The notice must contain the effective date, new frequency and reason for change. The notice may be a wrap, letter, post-it, postcard or similar item affixed to the top of the subscriber's newspaper or sent via mail. A notice printed in the price box of the newspaper is not sufficient.
  • All days are presented as "included with the current paid subscription." If any days of the week are presented or implied as free, the copies served on those days are only eligible as qualified home delivery – targeted circulation.
  • See Rule C 5.13 Subscription Offer Based on Acceptance Unless Declined. Section(a)

Frequency Upgrade (“Opt-Out”) - Publisher’s Discretion

When publishers choose to upgrade a subscriber’s frequency, without eliminating the one ordered by the subscriber, all copies served for the new frequency are eligible as paid home delivery if the following requirements are met:

  • Effected subscribers are notified in writing prior to the change. The notice must contain the effective date of the change, the new frequency, and instructions on how to opt-out of the upgraded service. The notice may be a wrap, letter, post-it, postcard or similar item affixed to the top of the subscriber's newspaper or sent via mail. A notice printed in the price box of the newspaper is not sufficient.
  • The opt-out instructions are clear and simple.
  • All days are presented as "included with the current paid subscription."  If any days of the week are presented or implied as free, the copies served on those days are only eligible as qualified home delivery – targeted.
  • Minimum service must be 12 weeks. 

Subscriber’s Choice

When publishers offer subscribers the voluntary opportunity to expand their frequency, all copies served for the new frequency are eligible as paid home delivery if the following requirements are met

  • The subscriber opts in to receive the new frequency.
  • All days are presented as "included with the current paid subscription."  If any days of the week are presented or implied as free, the copies served on those days are only eligible as qualified home delivery – targeted circulation.

 

Multiple Subscriptions

When multiple subscriptions to the same newspaper are sold together, all subscriptions are eligible as paid home delivery if the following requirements are met:

  • Promotional materials state the subscription term, frequency and quantity of subscriptions.
  • The purchase price is at least one cent, net of considerations, per subscription. See AAM Rule C 1.1 Paid Circulation Defined.
  • The consumer is presented with the option to purchase only a single subscription.
    • The price of the single subscription is lower than the bundled price by at least one cent (per subscription removed from the sale).
    • See AAM Rule C 5.3 Combination Sales, section (b) (2).
  • None of the subscriptions are stated or implied as free, no additional cost, complimentary or other synonymous language. Copies presented or implied as free are only eligible as qualified home delivery – targeted circulation.

The requirements above also apply to gift subscriptions. Gift subscriptions are purchased by individuals as a normal expression of friendship. See AAM Rules C 3.5 Gift Subscriptions and C 3.6 Gift Subscriptions Not Recognized as Paid Circulation.

If digital subscriptions are included in the sale, please refer to bundled sales and AAM Rule C 5.10 Subscriptions Involving Digital Editions.

Examples:

No more sharing!

Buy two, one-year, seven-day subscriptions for the low price of only $100!

_____ Yes! I'd like to buy a one-year, 7-day subscription for only $100.
_____ Sounds like a great offer, but I would only like to buy one subscription for $99.99.

 

No more sharing!

Buy a one-year, seven-day subscription for the low price of only $99.98!

_____ Yes! I'd like to buy a one-year, 7-day subscription for only $99.98.
_____ Yes! Send me a second subscription for only a penny more.

 

Premiums

Premiums are anything offered as gifts to individuals for purchasing a subscription. This includes free items and discounts.

Subscriptions sold with premiums (gifts) are eligible as paid home delivery if the following requirements are met:

  • Promotional materials state the subscription term and frequency.
  • The purchase price is at least one cent, plus the full value of the premium. See AAM Rule C 5.2 Premiums with Subscriptions/Single Copy Sales.
    • The full value of the premium is considered to be the highest of either the stated value (value stated on the promotional material), retail value (price it would cost a consumer to buy the item in the public marketplace) or cost to the publisher (cost to obtain or produce the item).
    • In some cases, an item may not be sold to the public and the promotional materials will not state a value. In those cases, the cost to the publisher would be used to determine the premium value. However, if more than one value exists, the highest value is the AAM premium value.
    • If the item is a discount card with infinite value (percent off or dollars off), it must be sold to nonsubscribers to establish a retail value.

The following items are not considered premiums per AAM Rule C 5.1 Premium Defined:

  • Publications (newspapers and periodicals) published four or more times per year. In these cases combination sales apply.
  • Part of a subscription term. See section on the word free used for paid circulation.
  • Free or discounted access to archives or back content.
  • Free or discounted access to online content or digital editions from the same editorial home page of the publication.
  • Anything sent free by mail with a subscription offer or sample merchandise that can be ordered and received regardless if a subscription is purchased.
  • Items offered to current paid subscribers as an inducement to convert to payment method for a future subscription.
     

 

Note: For Easy Pay offers, the circulation is eligible as paid after the subscriber completes enough debit or credit card payments to cover the minimum of one cent for the term delivered, plus the full value of the premium.

 

Examples:

Subscribe to one year of The Gazette at regular price and get a Great Buy gift card worth up to $100!

YES, sign me up or renew my 7-day subscription today!
_____ 3 months @ $35.00 - get a $30 gift card.
_____ 6 months @ $65.00 - get a $60 gift card.
_____ 1 year @ $105.00 - get a $100 gift card.

 

Subscribe to The Gazette for seven days a week and if you choose Easy Pay, get a $10 Great Buy gift card!

YES, sign me up for a one-year, 7-day subscription for $100!
_____ check enclosed
_____ Bill me
_____ Charge my credit card # _________________
_____ Easy Pay: I understand my debit or credit card will be billed monthly at $8.33 per month and will continue until I cancel the subscription. Please send me the $10 gift card!

 

Subscribe to The Gazette for seven days a week at the great price of only $100!

AND if you enroll in Easy Pay today, we will give you a $10 gift card to PC City!

YES, sign me up for a one-year, 7-day subscription today for $100 and send me my $10 gift card!
_____ Check enclosed
_____ Bill me
_____ Charge my credit card # _____________________

( ) Yes, also sign me up for Easy Pay upon expiration of my one-year subscription. I understand my debit or credit card will be billed monthly at $8.33 per month and will continue until a cancel the subscription. And for signing up for Easy Pay today, I will get a $10 PC City gift card!

 

Previous Sunday

When a copy of the most recent Sunday issue is offered with new subscriptions, this additional Sunday is eligible as paid home delivery if the following requirements are met:

  • The new subscriber takes affirmative action to accept the previous Sunday issue (opt-in).
  • The previous Sunday is presented as included with the subscription price. Copies presented or implied as free are only eligible as verified public access circulation.

Example:

Subscribe to 3 months of the Illinois Today today!

Yes, sign me up for my three-month subscription today!
_____ 7-day (Mon.-Sun.) $30
_____ 6-day (Mon.-Sat.) $24
_____ Weekend only (Fri., Sat., and Sun.) $18
_____ Sunday only $15

( ) Yes, please deliver last week's Sunday paper included with the cost of my subscription!

 

Subscriptions Sold with Other Services

Subscriptions included with the sale of other services such as cable television, Internet, or phone service, are eligible as paid home delivery if the following requirements are met:

  • The consumer takes affirmative action (opt-in) to accept the subscription.
  • The same offer presents the service for purchase without the subscription.
  • The cost of the other service on its own is less than the package cost. The difference is at least one cent, net of considerations. See AAM Rule C 1.1 Paid Circulation Defined.
  • The invoice, receipt, or billing statement for the other service itemizes a qualifying price for the subscription separate from the cost of the other service. See AAM’s Policy on Sales with Other Services.
  • Copies presented or implied as free are only eligible as qualified home delivery - targeted circulation.

Example:

Sign up for Direct Digital Cable Today!

Sign up for Direct Digital Cable today for only $29.99 per month and get a 7-day Illinois Today subscription for only an additional penny per month. That's $30 for both cable and the newspaper!

 

Contract for Direct Digital Cable

_____ Yes! I want to add a 7-day subscription to Illinois Today for only an additional 1¢ per month.

 

Monthly Billing Statement for Direct Digital Cable Service (portion)

Cable.....$29.99
Illinois Today Subscription.....$00.01
Taxes, Fees, etc......$ 5.00
Total Due.....$35.00

 

Subscriber Loyalty Programs

Subscriber reward programs designed to promote brand loyalty are exempt from AAM premium rules if the following requirements are met:

  • Subscriber enrollment is required. Automatic enrollment is not sufficient.
  • Rewards are either merchandise or points redeemable for merchandise.
    • Cannot include access to paid print or electronic subscriptions of other publications.
    • Rewards cannot be converted to cash or accepted as payment for a subscription to the newspaper.
  • Rewards provided to a new subscriber in the first 90 days of their term may not exceed the price they paid for the subscription.
  • Varying levels of membership and specific criteria for each is acceptable (i.e. gold, silver and platinum).
  • See AAM Rule C 5.1 Premium Defined, section (a) (9).

If a loyalty program does not meet the above requirements, the program is subject to all premium rules. Therefore, all subscribers receiving the loyalty program must pay at least one cent, plus the full premium value. The price at which the membership is sold to nonsubscribers is considered the premium value.

 

Note: Loyalty programs commonly include, but are not limited to, additional news content, VIP ticket access, discounts to local retailers, etc.

 

Subscriptions Purchased with Award Points

Subscriptions purchased with award points, in lieu of cash, are acceptable as paid home delivery if the following requirements defining the reward program are met:

  • Subscriber enrolls. Automatic enrollment is not sufficient.
  • Points are earned from specific incremental actions communicated to and performed by the consumer. The volume of points earned for each activity must be clearly communicated.
  • The program provides an initial award of no more than 35 percent of the points needed to obtain the least expensive product or service in the program.
  • A consumer’s account status is accessible on a regular basis. If points expire, sufficient time to accumulate and redeem points for the highest valued item is given.
  • Accrued points are available for future redemption.
    • All items offered have a stated value in points or dollars.
    • At least 20 percent of all items offered for the redemption of points are nonpublication items. At least half of all the nonpublication items must be commercially available.
    • The value of each commercially available item is equal to or greater than the average value of all publications available.
  • Each point has a monetary value.
    • The product value divided by the assigned point value equals the per-point value.
    • The point value is consistent for all award items.
  • The subscription purchase price, when converted to dollars, is at least one cent, net of considerations. See AAM Rule C 1.1 Paid Circulation Defined. To calculate the subscription purchase price, multiply the per-point value established for the program by the number of points redeemed.
  • See AAM Rule C 5.9 Subscriptions Purchased with Award Points.
     

 

Note: Commonly known award point programs include, but are not limited to, frequent flyer and credit card point programs.

 

For the Audit

An example of each promotion used in the audit period must be retained for review by AAM. See AAM Rule B 1.1 File Copies, Subscription Promotion Offers.

This includes, but is not limited to:

  • Direct mail pieces
  • Order forms
  • Telemarketing scripts
  • Radio scripts (or recordings of radio advertisements)
  • Television scripts and storyboards (or recordings of television advertisements)
  • Print outs of website pages
  • Point-of-purchase materials (signs, posters, etc.)
  • Advertising campaigns (run of press and free standing inserts)

Newspapers should be able to identify the internal promotional code assigned for each specific and unique promotion and obtain a production report for each one.

The auditor may also evaluate the financial relationships between the newspaper and its home-delivery contractors such as wholesale rates, credits and debits issued and collection procedures. Access to the records of any agents and subscribers is required. These records may include, but are not limited to copies of invoices, draw sheets, collection reports, debit and credit memos, payments, and bank deposits.

It is imperative to the efficiency of the audit that the publication responds in a timely manner to all auditor requests for documentation.

Previous Article
Newspaper Prototype Reports
Newspaper Prototype Reports

View samples of newspaper quarterly data reports and CMRs.

Next Article
Digital Subscriptions
Digital Subscriptions

Follow this guide to ensure your digital subscriptions are eligible as AAM circulation units.

Do you have questions or want to learn more?

Contact AAM