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U.S. DEPARTMENT OF LABOR
Employment and Training Administration
Washington, D. C. 20210

CLASSIFICATION

UI

CORRESPONDENCE SYMBOL

TEUQS

ISSUE DATE

April 20, 1995

RESCISSIONS

None

EXPIRATION DATE

April 30, 1996

DIRECTIVE

:

UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 20-95

 

TO

:

ALL STATE EMPLOYMENT SECURITY AGENCIES

 

FROM

:

MARY ANN WYRSCH
Director
Unemployment Insurance Service

 

SUBJECT

:

Procedures for Release of Unemployment Insurance (UI) Benefits Quality Control (BQC) Data for Calendar Year (CY) 1994

  1. Purpose. To provide State Employment Security Agencies (SESAs) with guidelines for the annual release of UI BQC program data for CY 1994.

  2. References. 20 CFR 602; Federal Register Notice, March 26, 1990, 54 FR 11112; UIPL 13-93, January 12, 1993; and Benefits Quality Control State Operations Handbook, ET Handbook No. 395.

  3. Background. The final rule to establish the Unemployment Insurance Quality Control program is found at 20 CFR Part 602. Effective October 5, 1987, QC programs in the 50 States, the District of Columbia, and Puerto Rico have selected weekly random samples of UI benefit payments for investigation under the mandatory program.

    20 CFR 602.21(g) provides that each State shall:

    Release the results of the QC program at the same time each year, providing calendar year results using a standardized format to present the data as prescribed by the Department; States will have the opportunity to release this information prior to any release by the Department.

    The notice of procedures for the release of BQC data for the UI program was published in the Federal Register on March 26, 1990, at 54 FR 11112.

  4. Date of Record. The Department has established close of business (c.o.b.) April 30, 1995, as the date of record for State databases for computation of the error rates for the CY 1994 Annual Report of BQC data. All information in the Annual Report will be based on CY 1994 BQC cases that have been signed off by the QC supervisor by c.o.b. April 30, 1995. States must not reopen any CY 1994 BQC cases after this date until they have reviewed the computations of the error rates and have reconciled any differences between the State and National databases. Any data analysis supporting the Annual Report must be run on the database as it exists at c.o.b. on April 30. If States make any further changes, their data and results will differ from the data and results of the National Office. These differences will then have to be reconciled.

  5. Annual Report Software. As described in UIPL 13-93, the software which produces the Annual Report excludes Emergency Unemployment Compensation (EUC) program eligibility option cases from the rates calculations. It also excludes cases which do not meet the definition of the BQC population, for example, interstate or supplemental payments. These cases are coded "9" in data element c1. The software adjusts the population dollars paid to exclude any EUC and code "9" cases.

    The CY 1994 footnote look-up table can be found in Attachment 1, pages 2 and 3. For cases with a reopen code of "3" (the State has changed the data in a previously closed case), the reopen date is used in determining the appropriateness of footnotes concerning time lapse requirements.

    The States may run the Annual Report software as soon as all cases are completed. The National Office will produce an Annual Report for each State, based on the CY 1994 BQC cases as of c.o.b. April 30, 1995.

  6. Annual Report Format. The Annual Report format is shown in Attachment 1. It is divided into three main sections.

    Quality Control Data

    Footnotes

    The footnotes that will appear on State BQC Annual Reports to describe certain conditions that affect the data are described in Attachment 1, pages 2 and 3.

    Narrative

    States are invited to supply a narrative analysis that will accompany their Annual Report. The Department will include this narrative in the digest of State Annual Reports that it will prepare (see section 10, below).

    The narrative may include, but is not limited to, a discussion of State laws and how they affect error rates, an explanation of circumstances that led to some degree of inaccuracy in the reported error rates, and proposed or actual corrective action strategies.

    State narratives must be received in the National Office no later than June 9, 1995. States not planning to submit a narrative should notify the National Office by June 9, 1995, that no narrative will be submitted. The procedures for preparing and transmitting the Annual Report narrative to the National Office are described in Attachment 2.

  7. Supplemental Data. In order for the SESAs to interpret the data in the Annual Report and provide narrative explanations of the data, the Department recognizes the need for additional information on cause and responsibility. The software that produces the BQC Annual Report will also generate a separate report consisting of up to 16 responsibility categories and up to 6 cause categories. Responsibility and cause data will be reported as percentages of UI dollars overpaid. The format for this report is shown in Attachment 3.

    In order to provide States with the greatest flexibility in interpreting the data, all possible responsibility codes and broad cause categories can be generated. States can combine categories which contain few sample cases, where appropriate. No sampling errors will be computed because the publication of these percentage rates is not mandatory by the State. States should be aware that some of these percentages are based on small numbers of BQC sample cases and may have relatively large sampling errors. The Department may publish such data in the technical appendix, along with additional analysis where appropriate.

  8. Comment Period. BQC Annual Reports produced by the Department of Labor will be transmitted to each State on May 12, 1995. Each State should review its Annual Report and if there are any comments submit them to the National Office (Attn: TEUQS, Andy Spisak) by May 31, 1995. SESA comments will be discussed and reconciled by June 9, 1995.

  9. Public Release by SESA. As summarized from the Federal Register notice of March 26, 1990:

    Each State will release the required data annually through established channels for disseminating State performance data. In accordance with established State procedures, the data must be provided to those who normally receive performance/evaluation data and to anyone else who requests it. It is no longer necessary to publish a notice of availability.

    States must release their Annual Reports by June 30, 1995. If a State fails to release data in accordance with these procedures, the Department, in its annual review of State QC operations as specified in 20 CFR, Part 602, Section 602.31, will take appropriate action.

  10. Federal Release of Data. The Department will announce the availability of QC program data for CY 1994 through a notice published in the Federal Register on or about July 31, 1995. The Department's publication will be a digest prefaced by background information on the Quality Control program, and a brief discussion of how the error rate estimates are computed. Readers will be discouraged from comparing results among States. Each State's section, including its Annual Report and narrative, will be displayed separately. State sections will be ordered alphabetically to discourage ranking and comparisons. The name of the State official designated by the State as its Annual Report contact will also be published.

    For CY 1994, the Department will continue the practice begun with CY 1989 data of publishing certain analytical information on aspects of the BQC findings.

    If the Department determines that a State has failed to follow the prescribed QC methodology -- regarding sample selection, data collection methodology, or case completion timeliness -- to such an extent that the data are not reliable, the Department will publish an explanation of the major deficiency in lieu of an Annual Report for that State. Also in accordance with instructions in the Program and Budget Plan, ET Handbook No. 336 (11th edition, change 2), States will be required to address these areas by submitting corrective action plans for the upcoming fiscal year.

  11. Key Dates. The following is a summary of key dates for the public release of CY 1994 BQC data.

    4/30 States check BQC databases and resolve any database problems.
    4/21 States submit any request for waiver of time lapse requirements, along with supporting analysis, to appropriate Department of Labor ETA Regional Administrator.
    4/30 Date of record for State BQC databases for Annual Report purposes. Cases closed by supervisors after this date will NOT be included in the Annual Report. States should not reopen any CY 1994 cases to change the database after this date until their Annual Report is finalized and any analysis for the release of the data or the narrative is completed.
    4/30 Department of Labor electronically transmits the modified Annual Report software and footnote look-up table to each State's Sun computer.
    5/12 Department of Labor sends Annual Reports to the State Administrators over signature of Mary Ann Wyrsch, Director, UIS.
    5/15-5/31 States review Annual Reports, including footnotes, and provide comments to Department of Labor.
    6/1-6/9 Department of Labor and States discuss and reconcile comments in collaboration with Department of Labor Regional Offices.
    6/9 States provide name of contact persons to appropriate Department of Labor ETA Regional Administrator. States provide narratives or notice of waiver of narrative comments to Department of Labor National Office.
    6/30 States release CY 1994 BQC Annual Report and send copy of the release to the appropriate Department of Labor ETA Regional Administrator.
    7/14 States send copies of any press releases and/or newspaper articles relating to the Annual Report released by the SESA for CY 1994 to the appropriate Regional Administrator.
    7/31 Department of Labor publishes notice in the Federal Register announcing the availability of BQC data.

  12. Action Required. State Administrators are requested to:

    1. provide copies of these guidelines to the appropriate staff;

    2. ensure that annual report narrative comments or notice of waiver of such comments is transmitted to the Department of Labor National Office by c.o.b. June 9, 1995; and

    3. ensure that the following items are supplied to ETA Regional Administrators:

      (1) any request for a waiver of time lapse requirements by c.o.b. April 21, 1995;

      (2) the name, location, and telephone number of a contact person to whom interested parties can write or call with questions or inquiries about the State's annual release of BQC data by c.o.b. June 9, 1995;

      (3) a copy of the State annual BQC data release by June 30, 1995; and

      (4) copies of State releases of BQC data, any press releases and/or newspaper articles relating to the Annual Report released by the SESA for CY 1994 by July 14, 1995.

  13. Inquiries. Questions should be directed to the appropriate Regional Office.

  14. Attachments. (1) Annual Report Format and Footnotes; (2) Annual Report Narrative Format and Transmission; and (3) Format for BQC Annual Report Supplemental Data.