U.S. DEPARTMENT OF LABOR
Employment and Training Administration
Washington, D. C. 20210
April 24, 1996
April 30, 1997
UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 19-96
ALL STATE EMPLOYMENT SECURITY AGENCIES
MARY ANN WYRSCH
Procedures for Release of Unemployment Insurance (UI) Benefit Accuracy Measurement (BAM) (formerly Benefits Quality Control (BQC)) Data for Calendar Year (CY) 1995
Purpose. To provide State Employment Security Agencies (SESAs) with guidelines for the annual release of UI BAM program data for CY 1995.
References. 20 CFR 602; Federal Register Notice, September 3, 1987, 52 FR 33520; 20 CFR 602; Federal Register Notice, March 26, 1990, 54 FR 11112; UIPL 13-93, January 12, 1993; UIPL 41-95, August 21, 1995; and Benefits Quality Control State Operations Handbook, ET Handbook No. 395.
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.
Beginning in 1993, a team of senior State Employment Security Agency (SESA) managers and Unemployment Insurance Service (UIS) staff known as the Performance Enhancement Workgroup (PEWG) developed the outlines of a comprehensive new closed-loop system for helping ensure continuous improvement in UI operational performance. UIPL 41-95, issued August 21, 1995, described this new system, called UI Performs, and solicited comments from SESAs. The UI Performs design is now being refined in light of SESAs' responses to UIPL 41-95. The new system will be phased in over 3-4 years as the various components are completed.
When complete and fully operational, UI Performs will comprise a renewed affirmation of long-standing principles for Federal-State cooperation; a redesigned process for operational planning and the execution of improvement activities; various mechanisms to ensure that performance in key areas at least exceeds certain minimum levels; and the redesign of many performance measurements plus the regular validation of key performance measures. The measures were selected to enable the UI system's success to be judged by how well it serves its ultimate customers--claimants and employers. Most of the data used to construct existing and new UI Performs measures are already in State databases; UI Performs should not appreciably increase overall measurement effort.
The measurement redesign aspect embraces the results of three initiatives which predated UI Performs: Revenue Quality Control, which developed new measures for tax performance to replace those previously gathered under the Quality Appraisal (QA) system; the Performance Measurement Review (PMR) project, which updated QA benefit payment timeliness and quality measures; and data validation. The team designing UI Performs also proposed changes in the Benefits Quality Control (BQC) system for measuring benefit payment accuracy, including the assessment of the accuracy of decisions to deny eligibility.
Two proposals for changing BQC have already been accepted: the name change to Benefit Accuracy Measurement (BAM) and dropping the requirement that States publicly release their data. Under 20 CFR 602.21 (g) and 602.22, the Department has determined that public release of data by the States is no longer considered necessary for the proper and efficient administration of State law. Therefore, the Department will no longer require States to publicly release the data. While the Department will continue to publish an annual compendium of all States' data, each State will determine whether they will independently make a public release of their data. Whether data are publicly released or not, States must continue to follow the reporting requirements described below.
Date of Record. The Department has established close of business (c.o.b.) April 29, 1996, as the date of record for State data bases for computation of the error rates for the CY 1995 Annual Report of BAM data. All information in the Annual Report will be based on CY 1995 BAM cases that have been signed off by the QC supervisor by c.o.b. April 29, 1996. States must not reopen any CY 1995 BAM 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 29. 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.
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 BAM 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. In CY 1995, there were no EUC cases in any State database.
An explanation of the CY 1995 footnotes 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 computing the time lapse and 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 1995 BAM cases as of c.o.b. April 29, 1996.
Annual Report Format. The Annual Report format is shown in Attachment 1. It is divided into three main sections.
Quality Control Data
Total Dollars Paid in Population
Total UI benefits paid to the population of UI claimants who comprise the sampling frames for all weeks in CY 1995 for which the State pulled a BAM sample, adjusted to exclude EUC program eligibility option cases and other UI payments that do not meet the definition of the BAM population.
Total UI payments selected during CY 1995 (BAM batches 9501 through 9552) and completed (supervisor sign-off) c.o.b. April 29, 1996, excluding cases that do not meet the BAM population definition. This is the number of BAM sample cases from which the rates and sampling errors (confidence intervals) are estimated.
The weighted ratio estimate of total dollars properly paid to total dollars paid expressed as a percentage.
The weighted ratio estimate of total dollars overpaid to total dollars paid expressed as a percentage.
The weighted ratio estimate of total dollars underpaid to total dollars paid expressed as a percentage.
95 percent Confidence Interval
A confidence interval, expressed as +/- a percentage, will be constructed for each of the three estimated rates. The actual rate is expected to lie within 95 percent of the intervals constructed from repeated samples of the same size and selected in the same manner as the BAM sample.
The footnotes that will appear on State BAM Annual Reports to describe certain conditions that affect the data are described in Attachment 1, pages 2 and 3.
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 10, 1996. States not planning to submit a narrative should notify the National Office by June 10, 1996, 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.
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 BAM 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. States can combine categories which contain few sample cases, where appropriate. No sampling errors will be computed. States should be aware that some of these percentages are based on small numbers of BAM sample cases and may have relatively large sampling errors.
If cause and responsibility percentages do not add up to 100 percent, States should check for cases in which the key week amount overpaid coded in data element h5 does not equal the sum of dollars overpaid coded in data element "ei1" for key week actions 10, 11, 12, 13, and 15. The amount overpaid cannot exceed the amount paid coded in data element f13.
The Department may publish this and other data in the technical appendix along with additional analysis, where appropriate. The format for this report is shown in Attachment 3.
Comment Period. BAM Annual Reports produced by the Department of Labor will be transmitted to each State on May 10, 1996. Each State should review its Annual Report and if there are any comments submit them to the National Office (Attn: TEUQS, Andy Spisak) with a copy to the Regional Office by May 31, 1996. SESA comments will be discussed and reconciled by June 10, 1996.
Public Release by SESA. As discussed above, States are no longer required to release their annual data. The Department, however, will continue to release a compendium of all States' data. States should provide the data to interested parties upon request.
Federal Release of Data. The Department will announce the availability of BAM program data for CY 1995 through a notice published in the Federal Register on or about July 31, 1996. The Department's publication will be a digest prefaced by background information on the Benefit Accuracy Measurement 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 1995, the Department will continue the practice begun with CY 1989 data of publishing certain analytical information on aspects of the BAM findings.
If the Department determines that a State has failed to follow the prescribed 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.
Key Dates. The following is a summary of key dates for the public release of CY 1995 BAM data.
|4/19||States submit any request for waiver of time lapse requirements, along with supporting analysis, to the appropriate Department of Labor ETA Regional Administrator.|
|by 4/29||States check BAM databases and resolve any database problems.|
|4/29||Date of record for State BAM databases, for CY 1995 Annual Report purposes. Cases closed by supervisors after this date will NOT be included in the Annual Report. States should not reopen any CY 1995 cases to change the database after this date until their Annual Report is finalized.|
|4/29||Department of Labor electronically transmits the modified Annual Report software and footnote look-up table to each State's Sun computer.|
|5/10||Department of Labor sends Annual Reports to the State Administrators over signature of Mary Ann Wyrsch, Director, UIS.|
|5/13-5/31||States review Annual Reports, including footnotes, and provide comments via their Regional Office by 5/31 to Department of Labor National Office.|
|6/3-6/10||Department of Labor and States discuss and reconcile comments in collaboration with Department of Labor Regional Offices.|
|6/10||States provide name, address, and phone number 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 via the Regional Office.|
|7/31||Department of Labor publishes notice in the Federal Register announcing the availability of BAM data.|
Action Required. State Administrators are requested to:
provide copies of these guidelines to the appropriate staff;
ensure that Annual Report narrative comments or notice of waiver of such comments is transmitted to the Department of Labor National Office via the Regional Office by c.o.b. June 10, 1996; and
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 19, 1996; and
(2) the name, location, and telephone number of a contact person to whom interested parties may write or call with questions or inquiries about the State's BAM data by c.o.b. June 10, 1996.
Inquiries. Questions should be directed to the appropriate Regional Office.
(1) Annual Report Format and Footnotes;
(2) Annual Report Narrative Format and Transmission; and
(3) Format for BAM Annual Report Supplemental Data.