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

CLASSIFICATION

UI

CORRESPONDENCE SYMBOL

TEUDPR

ISSUE DATE

April 24, 1997

RESCISSIONS

None

EXPIRATION DATE

April 30, 1998

DIRECTIVE

:

UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 25-97

 

TO

:

ALL STATE EMPLOYMENT SECURITY AGENCIES

 

FROM

:

GRACE A. KILBANE
Director
Unemployment Insurance Service

 

SUBJECT

:

Procedures for Release of Unemployment Insurance (UI) Benefit Accuracy (BAM) Data for Calendar Year (CY) 1996

  1. Purpose. To provide SESAs with guidelines for the annual release of UI BAM program data for CY 1996.

  2. 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; and Benefits Quality Control State Operations Handbook, ET Handbook No. 395.

  3. Background. The final rule to establish the Unemployment Insurance Quality Control (QC) 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 Benefit Quality Control (BQC) data for the UI program was published in the Federal Register on March 26, 1990, at 54 FR 11112.

    As part of an overall review of the BQC program, the Performance Enhancement Workgroup (PEWG) agreed to several changes in the BQC program, including changing the name of the program to Benefit Accuracy Measurement. Following another recommendation of the PEWG, States are no longer required 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.

  4. Date of Record. The Department has established close of business (c.o.b.) April 30, 1997, as the date of record for State databases for computation of the error rates for the CY 1996 Annual Report of BAM data. All information in the Annual Report will be based on CY 1996 BAM cases that have been signed off by the QC supervisor by c.o.b. April 30, 1997. States must not reopen any CY 1996 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 30. If States make any further changes, their data and results will differ from the data and results of the National Office (NO). 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 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 code "9" cases.

    An explanation of the CY 1996 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 NO will produce an Annual Report for each State, based on the CY 1996 BAM cases as of c.o.b. April 30, 1997.

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

    Benefit Accuracy 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 1996 for which the State pulled a BAM sample, adjusted to exclude other UI payments that do not meet the definition of the BAM population.

    • Sample Size

      Total UI payments selected during CY 1996 (BAM batches 9601 through 9652) and completed (supervisor sign-off) by c.o.b. April 30, 1997, 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.

    • Proper Payments

      The weighted ratio estimate of total dollars properly paid to total dollars paid expressed as a percentage.

    • Overpayments

      The weighted ratio estimate of total dollars overpaid to total dollars paid expressed as a percentage.

    • Underpayments

      The weighted ratio estimate of total dollars underpaid to total dollars paid expressed as a percentage.

    • 95% 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% of the intervals constructed from repeated samples of the same size and selected in the same manner as the BAM sample.

      Footnotes

      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.

      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 NO no later than June 9, 1997. States not planning to submit a narrative should notify the NO by June 9, 1997, that no narrative will be submitted. The procedures for preparing and transmitting the Annual Report narrative to the NO 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 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%, 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.

  8. Comment Period. BAM Annual Reports produced by the Department of Labor will be transmitted to each State on May 9, 1997. Each State should review its Annual Report and if there are any comments submit them to the NO (Attn: TEUDPR, Andy Spisak) with a copy to the Regional Office (RO) by May 30, 1997. SESA comments will be discussed and reconciled with the States through the RO by June 9, 1997.

  9. Public Release by SESA. As discussed above, States are no longer required to release their annual data. The Department of Labor (Department), however, will continue to release a compendium of all States' data. States should provide the data to interested parties upon request.

  10. Federal Release of Data. The Department will announce the availability of BAM program data for CY 1996 through a notice published in the Federal Register on or about July 31, 1997. The Department's publication will be a digest prefaced by background information on the BAM 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 1996, 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.

  11. Key Dates. The following is a summary of key dates for the public release of CY 1996 BAM data.

    4/25 States submit any request for waiver of time lapse requirements, along with supporting analysis, tothe appropriate Department of Labor ETA Regional Administrator.
    by 4/30 States check BAM databases and resolve any database problems.
    by 4/30 Department of Labor electronically transmits the modified Annual Report software and footnote look-up table to each State's Sun computer.
    4/30 Date of record for State BAM databases, for CY 1996 Annual Report purposes. Cases closed by supervisors after this date will NOT be included in the Annual Report. States should not reopen any CY 1996 cases to change the database after this date until their Annual Report is finalized.
    5/9 Department of Labor sends Annual Reports to the State Administrators over signature of Grace A. Kilbane, Director, UIS.
    5/12-5/30 States review Annual Reports, including footnotes, provide comments to the NO, with copies to Regional Administrators.
    6/2-6/9 Regional Offices facilitate the discussion of State Agency comments and the reconciliation of any differences.
    6/9 States provide name, address, and phone number of contact persons to appropriate Department of Labor ETA Regional Administrator. States provide electronically to the NO, with a hard copy to the Regional Administrators, narratives or notification that a narrative will not be submitted.
    7/31 Department of Labor publishes notice in the Federal Register announcing the availability of BAM data.

  12. Action Required. State Administrators are requested to:

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

      b.  ensure that Annual Report narrative comments or notice of waiver of such comments is transmitted to the Department of Labor NO via the RO by c.o.b. June 9, 1997; and

      c.  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 25, 1997; 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 9, 1997.

  13. Inquiries. Questions should be directed to the appropriate RO.

  14. Attachments. 

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