Can the USPS Free Delivery Confirmation Service be Used in Lieu of Certified Mail as a USPS Record of Proof of Delivery?

Recently I have had several firms ask me if they could use USPS Form 152 instead of the more costly Certified Mail most commonly used to provide proof of receipt. The short answer is no.

USPS regulations state (USPS.Gov):
"Do you need to verify when your parcel was delivered or that a delivery attempt was made? Use Delivery Confirmation service.

Delivery Confirmation™ service lets you find out the date and time your First-Class Mail parcel, Priority Mail item, or Package Services parcel was delivered or, if delivery was attempted but not successful, the date and time of the delivery attempt.

This is all you need to do:

• Complete PS Form 152.
• Affix the barcoded label to your First-Class Mail parcel, Priority Mail item, or Package Services (Parcel Post®, Media Mail®, Library Mail, or Bound Printed Matter) parcel.
• Have your PS Form 152 receipt postmarked for proof the item was mailed."

This service does not apply to First Class letters

At this writing, (April 2015) the cost of Certified Mail service is $3.30 per item Certified. The basic cost of a First Class letter is .49. Therefore, the total cost (before considering any pre-sort discounts which might be available) to mail a one ounce Certified Mail letter is $3.79. The minimum cost to mail a First Class parcel is $5.05. So technically this service would be available but the cost would be about one-third more than using Certified Mail. Additionally, a signed receipt for a Certified mail item has long been recognized in legal venues as valid proof of notice. While a case that PS Form 152 also provides such proof can certainly be proposed, it is unclear what advantage any mailer would have by availing themselves of the more expensive similar service.