State conversion from penalty mail to commercial postage

Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2006/TEGL04-06_508.pdf

CLASSIFICATION
      EMPLOYMENT AND TRAINING ADMINISTRATION       UI
                 ADVISORY SYSTEM
              U. S. Department of Labor            CORRESPONDENCE SYMBOL
               Washington, D.C. 20210              OWS/DUIO

                                                   DATE
                                                   August 15, 2006

ADVISORY: TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 4-06

TO:              STATE WORKFORCE AGENCIES
                 STATE WORKFORCE LIAISONS
                 ONE STOP CENTER SYSTEM LEADS

FROM:            EMILY STOVER DeROCCO /s/
                 Assistant Secretary

SUBJECT:         Plans to Phase out Penalty Mail Costs for “Employment Security”
                 Programs and Availability of Supplemental Budget Funds for Conversion
                 to Commercial Mail Methods

1. Purpose. To inform state workforce agencies (SWAs) of the Employment and Training
   Administration’s (ETA’s) intention to eliminate its authority to pay the U.S. Postal Service
   (USPS) directly for “employment security” postage costs beginning Fiscal Year (FY) 2008.
   These plans include the following:

   •    Phasing out ETA payment to the United States Postal Service (USPS) for state agency
        penalty mail and postal management costs beginning in Fiscal Year (FY) 2007 for states
        volunteering to be early implementers; beginning in FY 2008, all states will assume
        responsibility for paying their own postage costs as well as any postal management
        services currently provided to states through the Unemployment Insurance (UI)
        Supplemental Budget Request (SBR) process;
   •    Implementing new procedures to fund UI, Foreign Labor Certification (FLC), Trade
        Adjustment Assistance (TAA), and Work Opportunity Tax Credit (WOTC) postage
        beginning with FY 2008;
   •    Implementing new procedures to fund Wagner-Peyser (WP) and Workforce Information
        Grants (WIGs) beginning with Program Year (PY) 2008;
   •    Providing guidance on the payment of postage costs for programs conducted by SWAs in
        cooperation with the Bureau of Labor Statistics (BLS) and Veterans Employment and
        Training Service (VETS);
   •    Providing information on technical assistance available to states in converting from the
        (penalty mail) Official Mail Accounting System (OMAS) to commercial mail to improve
        general mail practices; and

   •   Soliciting UI SBRs from states for the purpose of implementing commercial mail
       programs and improving postage management.

2. References. General Administration Letter No. 6-89, Employment Security Mail; 39 U.S.C.
   3202(a) (1) (E); Section 3.3 of the USPS Domestic Mail Manual; State Unemployment
   Insurance and Employment Service Operations Appropriations Language; Unemployment
   Insurance Program Letter (UIPL) No. 15-04; and ET Handbook No. 336, 18th Edition, State
   Quality Service Plan Planning and Reporting Guidelines.

3. Background. Under USPS requirements established in October 1993, states implemented
   direct accountability methods (meters, stamps, and permit numbers) for postal management
   systems that are in use today. This was the first time ETA had actual cost information for
   state postage costs. This information, which is discussed in-depth in Attachment 1, showed
   that postage costs vary widely among states.

   In FYs 1998 and 1999, ETA established a federal/state postage workgroup to review states’
   postage costs. The workgroup discussed various strategies and potential formulas for
   allocating postage resources to states and queried states on their mailing practices and
   postage costs. The results of the National Association of State Workforce Agencies
   (NASWA)/ETA work group’s efforts informed this initiative.

4. Impetus for Change. Some states have been implementing new operating policies and
   procedures that should reduce postage costs, such as use of debit cards for paying benefits
   and direct deposit of benefits, electronic transmission of separation requests, Interactive
   Voice Response Systems to process weekly claim certifications and provide claim
   information, Internet tax registration, etc. As these new procedures are being planned and/or
   implemented, states have requested that they be permitted to “reinvest” the resulting postage
   savings in their program operations. While it is desirable to reward states that become more
   efficient, the current arrangements for financing SWAs’ postage where the Department of
   Labor (DOL) pays USPS directly for SWA postage costs have not allowed ETA to approve
   these requests. In addition, the current arrangement does not provide states with financial
   incentives to make improvements.

5. Changes Necessary to Convert from OMAS to Commercial Mail. In FY 1994, states
   converted to direct mail accountability, which involved the installation of postage meters and
   the use of permits, stamps, and Business Reply Mail (BRM). Therefore, the biggest change
   involved in converting to commercial methods of payment is that, unlike the payment
   method used under OMAS where DOL pays USPS directly for SWA postage costs, states
   will need to ensure that funds are on deposit with the USPS for all payment methods
   (permits, meters, BRM, etc.) prior to mailing.

   States will need to make arrangements with their local postal representative or local postal
   business service network and their meter manufacturer/vendor to initiate the following
   changes:

   a) Permit Mail – Typically, permit mail (G-12) is used for large mass mailings where the
      content is the same. Currently, states have one G-12 mailing permit, and the fee is billed
      through OMAS. States will need to submit an application to their local post office for a
      state agency mailing permit and pay the permit fee. Funds must be on deposit prior to
      mailing when using permit mail. There is a one-time permit fee of $160 per local
      facility. There is an additional $160 annual mailing fee per site for those states that will
      be using the First Class mail presorting programs to obtain postage discounts.

   b) Business Reply Mail – Currently, states have one BRM permit, and the fee is billed
      through OMAS. States will need to submit a BRM permit application for each mailing
      site that a state agency wishes to receive BRM. Unlike the current BRM, funds must be
      on deposit prior to mailing when using BRM permit mail. There is an annual BRM
      permit and renewal fee of $160 per unique permit number. States can save money by
      obtaining only one BRM permit and allowing all locations in the state to use the same
      number. Additionally, each location using the BRM permit will pay postage plus a per
      piece handling fee. Since the handling fee is determined on volume, states are
      encouraged to consult with their local post office to select the best option.

   c) Metered Mail – Most states currently use penalty meters and the postage costs are billed
      through OMAS. When converting to commercial mail, states will need to contact their
      meter vendor. The vendor will need to change the meter heads on the meter from OMAS
      to commercial. The cost of conversion is dependent upon the vendor selected. In some
      cases, meters may need to be replaced with digital meters to keep current with postal
      requirements. Unlike penalty mail and the OMAS, funds must be on deposit prior to
      mailing when using metered mail.

       A more detailed explanation is provided in Guidelines for State Agencies to Convert
       From “Official Mail Accounting System” (OMAS) To Commercial Payment
       Systems for Postage, which may be found on the Office of Workforce Security’s
       Web site at : www.ows.doleta.gov under “Quick Links” Postage Initiative.

6. New Postage Funding Arrangements.

   A. Unemployment Insurance postage funding processes

   •   Base Allocation Process

       The method for developing state specific target amounts for UI postage expenses uses
       projected base weeks claimed and subject employer workloads to determine each state’s
       share of total postage funds. This method is identical to the one used to generate the state
       specific amounts withheld from the base allocations for Federal payments to the USPS
       which have been attached for informational purposes only to previous years’ state UI
       administrative planning targets.

•   Above-Base Process

    The determination of above-base postage funding will be based exclusively on weeks
    claimed workload that was not included in the base allocation; subject employer activity
    is funded 100 percent in base. The regular UI base weeks claimed workload issued with
    the state UI administrative planning targets is a fiscal year total that must be converted to
    a quarterly equivalent base weeks claimed. The quarterly regular UI base weeks claimed
    will be subtracted from the actual regular UI weeks claimed as reported on the UI-3, and
    any weeks claimed in excess of the base weeks claimed will be considered above base
    workload. Trade and additional benefits weeks claimed will be added to regular UI
    above base weeks, and the resulting total will be multiplied by a unit cost (estimated to
    be 23 cents in FY 2007) for postage. The product will be the postage above base
    funding.

B. Wagner-Peyser postage funding process

ETA will provide $18 million that has been withheld from the WP national appropriation for
postage costs directly to the states. The distribution will be based on each state's share of the
total WP appropriation according to the statutory formula allocation. This methodology is
identical to the one used to generate the state specific amounts for Federal payments to the
USPS in the past.

C. Bureau of Labor Statistics Cooperative Agreements funding process

BLS will provide postage funding to SWAs directly. BLS will inform SWAs of the process
it will use separately.

D. Jobs for Veterans’ State Grants funding process

VETS will provide the $1.5 million, previously transferred to ETA for postage, directly to
the states based upon each state’s share of the total Jobs for Veterans’ State Grant formula
funding. A state’s postage allocation will consist of approximately one percent of its
statutory formula allocation, and VETS will inform State Workforce Agencies of the
allocation process in a Veterans’ Program Letter (VPL).

E. Miscellaneous ETA Workforce Grants and Programs

The FLC, TAA, WIG, and WOTC programs have been assessed a percentage of their
national appropriation for postage costs. In PY 2006/FY 2006, the percentage was 2.9
percent or $2.0 million. Upon converting to commercial mail, these programs will no longer
be assessed for postage, and the funds will be included in state grants.

7. Postal Supplemental Budget Request Process. The postal SBR process used to reimburse
   states for their use of vendors to bundle their UI mail to obtain discounts will be eliminated
   in FY 2007 for early implementers and in FY 2008 for all other states, and states will be
   expected to pay these costs out of their annual postage allocation.

8. Technical Assistance. All states should begin consulting with their local post office, which
   can provide assistance on contacting local postal representatives or their local postal business
   service network. These USPS representatives can provide technical assistance on what
   permit application forms to fill out and how to achieve the maximum postage discounts.
   States should also consult with their local meter manufacturer vendor who can guide them
   through the meter conversion process.

   States are encouraged to utilize www.USPS.com to find additional resources and guides to
   improve mail management programs. Additionally, the National Postal Forum is a national
   event that provides opportunities for state mail managers to attend seminars and workshops
   on the latest innovations in mail management. The Forum provides the opportunity for state
   mail managers to obtain information on operating efficient mail operations and to obtain
   information from experts and their colleagues in other states. Information regarding
   registration costs, dates, etc., can be found on www.USPS.com.

9. Early Implementers. ETA encourages states to assume responsibility for their postage and
   mail management costs beginning as early as October 1, 2006, on a voluntary basis. In doing
   so, the state agrees to convert to commercial mail prior to the conversion date. ETA will no
   longer reimburse USPS for early implementing states’ FY 2007 penalty mail costs thereafter,
   and if USPS presents a postage bill on behalf of the state account, the amount billed will be
   recouped from the state.

   States may opt to convert effective at the beginning of a quarter. In a case where a state
   converts after the first quarter of FY 2007, its UI postage allocation will be adjusted
   according to its historical weeks claimed pattern, and its WP, FLC, TAA, WIG, and WOTC
   postage allocation will be 25 percent for each quarter remaining in the year.

   BLS and VETS will provide instructions to states on how BLS cooperative agreements and
   VETS funded programs will be provided postage funds.

   A state that wishes to implement before FY 2008 should notify Dale Ziegler, Deputy
   Administrator, Office of Workforce Security, 200 Constitution Ave. N.W., Room S-4231,
   Washington, D.C. 20210, indicating its intention to implement early and provide the date it
   will make the conversion. Questions may be directed to Mr. Ziegler at 202-693-2942 or
   [email protected].

10. Timeline.

   •   ETA will provide all states with UI, FLC, TAA, WOTC postage allocations and cease
       paying the USPS for state UI postage costs, including VETS, beginning October 1, 2007,
       at which time states will pay the USPS directly.
   •   To accommodate FY implementation, ETA will provide all states with partial WP and
       WIG postage allocations in PY 2007 (covering 9 months beginning October 2007) and
       cease paying the USPS for state WP and WIG postage beginning October 2007, at which
       time states will pay the USPS directly. Full WP and WIG postage allocations will be
       provided beginning in PY 2008.
   •   States wishing to be early implementers may convert to commercial mail beginning
       October 1, 2006, and ETA will provide participating states with a postage allocation as
       described above. BLS and VETS will provide information for early implementers
       separately.

11. Proper Use of Postage Resources. State administrators should refer to General
    Administration Letter No. 6-89 for information on the proper use of postage funds.

12. UI Supplemental Budget Requests for FY 2006. Up to $50,000 per state is available in FY
    2006 for use by states to make the changes noted in item #5 above to convert to commercial
    mail during FY 2007. These funds are also available to assess UI mailing operations,
    explore opportunities and available technologies to improve efficiency and reduce mailing
    costs, and install or modify systems or equipment to decrease mailing expenditures. See
    Attachment II for UI SBR instructions. SBRs are due to the National Office no later than
    September 15, 2006.

13. Action Required. State administrators and liaisons are requested to distribute this advisory
    to appropriate staff.

14. Inquiries. State administrators should contact their ETA regional office and DVET/VETS
    Regional Administrators as appropriate.

15. Attachments.
    Attachment I - Penalty Mail Fact Sheet
    Attachment II - Outline for FY 2006 Supplemental Budget Request for Penalty Mail
    Conversion and Postal Management Improvements
    Attachment III - FY 2007 Preliminary Postage Allocations
    Attachment IV – 3-Year Analysis – Average UI Work Load/Postage Costs

Attachment: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2006/TEGL04-06_Att1.pdf

Attachment I

                                          PENALTY MAIL
                                           FACT SHEET

Penalty mail allows for reimbursement of states’ postage costs “after the fact,” which the
Department of Labor (DOL) pays directly to the United States Postal Service (USPS). The
authorized users include the following programs/organizations:

       Unemployment Insurance (UI), Wagner-Peyser (WP), Foreign Labor Certification (FLC),
       Disaster Unemployment Assistance (DUA), Bureau of Labor Statistics (BLS)
       Cooperative Agreement, Trade Adjustment Assistance (TAA), Work Opportunity Tax
       Credit (WOTC), and the Disabled Veterans’ Outreach and Local Veterans Employment
       programs (Veterans Programs).

The legal authority to use penalty mail is found at 39 U.S.C. 3202(a)(1)(E):

       “[T]he United States Employment Service and the system of employment offices
       operated by it in conformity with the provisions of sections 49-49c, 49d, 49e-49k of Title
       29 [Wagner-Peyser Act], and all state employment systems which receive funds
       appropriated under authority of these sections” are authorized to use penalty mail.

Section 3.3 of the USPS Domestic Mail Manual interprets the penalty authority privilege granted
to the “United States Employment Service” in 39 U.S.C. as encompassing “Employment
Security Offices,” which provides the authority to other DOL users and functions, e.g., UI – All
mail prepared under 7.0, 8.0, 9.0, and 11.0 (sections in the manual) by state employment security
offices is accepted without prepayment of postage and fees.

Additionally, the appropriations act provides DOL with the authority to pay the USPS directly
for state postage costs. Since states do not pay their postage directly, their individual postage
costs are essentially invisible. Thus, there is little incentive for states to aggressively manage
their costs.

How the Current System Works

   •   DOL subtracts funds from state UI administration, WP, Foreign Labor Certification
       (FLC), Trade Adjustment Assistance (TAA), Workforce Information Grants (WIG),
       Work Opportunity Tax Credit (WOTC) appropriations to cover state postage costs before
       annual allocations are provided to the states. These funds are held by ETA, which pays
       monthly postage charges to the USPS for the states’ employment security postage.
   •   ETA bills BLS for actual costs, and charges Veterans’ programs an estimated amount.
   •   A few states use vendors to bundle their mail to obtain discounts and are reimbursed for
       their postage costs through supplemental budget requests.

States’ Postage Experience

Actual postage costs vary from state to state and are primarily influenced by UI claim workloads,
WP usage, and state efficiency. Historically, postage costs have been approximately 4-5 percent
of the appropriations, but vary depending upon the state of the economy. In the case of UI,
recent postage costs have ranged from $76 million in FY 2000 to $142 million in FY 2004.
Little information is available on actual WP, FLC, TAA, WIG, and WOTC postage costs; the
USPS does not collect program specific information, and the ETA Office of Financial and
Administrative Management (OFAM) has charged these programs approximately $20 million
per year over the past five years for postage costs based upon estimation.

ETA reviewed UI postage expenditures for FY 2003, FY 2004 and FY 2005 (Attachment V)
using Weeks Claimed and 4 times Subject Employers as a proxy for workload to assess state
postal expenses and expressed the result as a postal workload index (PWI). The review revealed
that in FY 2005 the average PWI was 0.62 and the median 0.66, ranging from a low of 0.42 to a
high of 1.69. In FY 2003, the median was 0.70 and the range was 0.46 to 1.63. The wide range
results from differing state practices in postal management, including the use of available
discounts to reduce overall costs.

On several occasions, ETA has encouraged improvements in state postage handling with varying
degrees of success. In FY 2005, ETA provided a $50,000 SBR opportunity for states to study
and examine mailing operations, explore opportunities to improve efficiency and reduce mailing
costs and to implement available technology to decrease state mailing expenditures in
anticipation of this change; only 30 states requested funds. Previously, in FY 1992, ETA
provided funding ($11.5 million) for states to purchase postal equipment to improve efficiencies
and reduce costs; as a result, many states now participate in complicated postal discount rate
programs (e.g., presorting, bar-coding etc.) and have reduced their postage costs. For example, a
39 cent letter can be mailed at the automated presorted three digit rate of 30.8 cents per piece or
a 21 percent cost saving. Today, some states continue to use mail discount programs. A few
states even use commercial mail practices wherein ETA pays the costs through SBRs.

Attachment: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2006/TEGL04-06_Att2.pdf

Attachment II

   OUTLINE FOR FY 2006 SUPPLEMENTAL BUDGET REQUEST FOR PENALTY
     MAIL CONVERSION AND POSTAL MANAGEMENT IMPROVEMENTS

Up to $50,000 per state is available in FY 2006 unemployment insurance (UI) funds for use by
states to pay for the costs of converting to commercial mail and to improve efficiency and
reduce mailing costs, and install or modify systems or equipment to decrease mailing
expenditures.

Description of the Project:

Provide a brief description of the proposed use of the SBR funds converting from OMAS to
commercial mail and/or making improvements to the state’s UI postal management system. The
description should explain the activities that the SWA will undertake and should substantiate the
proposed project costs.

Instructions: Refer to Handbook No. 336 for instructions in completing supplemental budget
requests.

Costs:

Cost expenditures must match those on the SF 424A. Provide brief explanations of the cost
breakouts for staff, equipment, other expenditures, etc., for each project and sub-project.

Hardware, Software, Telecommunications Equipment, Contracted Services

Item              Number Requested       Cost Per Item        Total Cost

____________________________________________________

Staff (This format is used for SWA staff and/or for contract staff)

Position Title    # Hours            Cost Per Hour        Total

____________________________________________________

Identify other expenditures and include cost estimates.

_____________________________________________________

State Contact: Provide name, telephone number and email address of the individual who can
answer any questions relating to this proposal.

Amount of Funding Request for this Project: SBR funds may be used for one-time costs
only and may not be used for ongoing costs, such as maintenance of software and
hardware, or ongoing communications costs.

Staff costs are allowable only for staff not previously funded by the state's base grant.
Costs for training and related travel expenses are allowable for base staff but salaries and
benefits are not allowable for base staff attending training unless the state incurs
additional expenses such as backfilling the staff position during the time that the
employee attends training. Above base AS&T and NPS staff year costs must be based on
the state PS and PB rate approved for the current year's UI grant.

Examples of how SBR funds may be used include the following:

       •   Converting OMAS meters to commercial meters, and payment of Permit Mail and
           Business Reply Mail (BRM) fees (see #5 in TEGL 4-06).
       •   Conducting a cost-benefit analysis of using contract services that will allow states to
           take advantage of presorting and automation discounts offered by the Postal Service
           to reduce postage costs.
       •   Replacing/updating mailing equipment to improve efficiency and reduce costs (for
           states that manage their own mail operation).
       •   Assessing current mailing processes to identify areas where additional efficiencies
           may be derived, including reviewing what is mailed and to whom it is being mailed,
           and, where applicable, reducing unnecessary redundancies in mailing.
       •   Modifying benefit or tax systems to ensure the most efficient print streams are used.

Any funds that are not used for automation acquisition expenditures must be obligated by
December 31, 2006, and liquidated within 90 days of that date. Funds used for automation
acquisition expenditures are available for obligation through September 30, 2008, and
liquidated within 90 days of that date.

Due Date: SBR proposals must be received in the national office no later than September 15, 2006.

Send these SBRs and the required documents to the attention of: U. S. Department of
Labor, Office of Workforce Security, ATTN: Jagruti Patel, 200 Constitution Avenue, NW,
Room S-4231, Washington, D.C. 20210. A copy should be provided to the appropriate
Regional Administrator. The state should ensure that the following is provided:

       •   Original and two copies of each SBR proposal with supporting documentation.
       •   Completed forms SF 424 (revised 10-2005), 424a and 424b as required in ET
           Handbook 336, 18th Edition.

Attachment: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2006/TEGL04-06_Att3.pdf

Attachment III

                        FY 2007 Preliminary Postage Allocations

                                       FY 2007
                       FY 2007 UI      Estimated     PY 2006 Wagner-   FY 2007/PY 2006
                       Base Postage   Above Base      Peyser Postage     Total Postage   FY 2005 Actual
                        Allocation    Earnings (1)      Allocation      Allocation (2)   Postage Paid (3)

Total                   103,513,037      4,585,000        18,000,000       126,098,037       123,741,514

Alabama                   1,051,374         44,515           245,492         1,341,381         1,223,680
Alaska                      508,335         25,488           195,669           729,492           590,861
Arizona                   1,206,372         48,822           306,939         1,562,133         1,407,640
Arkansas                  1,001,662         45,647           148,567         1,195,876         1,465,289
California               15,694,789        696,536         2,076,603        18,467,928        12,782,756
Colorado                  1,235,365         44,797           282,169         1,562,331         2,145,948
Connecticut               1,431,172         64,090           198,486         1,693,748         1,622,107
Delaware                    309,616         13,078            50,277           372,971           298,598
District of Columbia        302,595         12,364            71,335           386,294           374,149
Florida                   4,230,359        159,197           891,781         5,281,337         4,742,672
Georgia                   2,241,778         91,347           513,140         2,846,265         2,237,976
Hawaii                      325,380         13,239            68,288           406,907           508,881
Idaho                       547,135         22,947           163,027           733,109           645,839
Illinois                  4,855,959        223,886           756,896         5,836,741         5,312,806
Indiana                   1,912,423         86,229           362,249         2,360,901         3,032,186
Iowa                        928,605         40,564           177,281         1,146,450           972,909
Kansas                      751,621         30,722           163,467           945,810         1,257,803
Kentucky                  1,236,986         55,384           235,037         1,527,407         1,183,508
Louisiana                 1,118,746         46,952           259,444         1,425,142         1,838,112
Maine                       444,783         18,202            96,950           559,935           752,079
Maryland                  1,476,676         59,902           312,253         1,848,831         2,112,243
Massachusetts             2,939,014        134,061           378,379         3,451,454         3,846,220
Michigan                  4,410,183        210,824           623,680         5,244,687         6,210,767
Minnesota                 1,962,294         88,133           311,264         2,361,691         2,340,818
Mississippi                 732,948         32,092           175,387           940,427         1,083,003
Missouri                  1,924,576         85,256           342,172         2,352,004         2,561,113
Montana                     350,507         13,824           133,226           497,557           515,808
Nebraska                    538,729         22,522           160,112           721,363           789,960
Nevada                      796,456         35,425           125,929           957,810           852,994
New Hampshire               301,724         10,441            74,288           386,453           387,935
New Jersey                4,309,181        198,345           486,859         4,994,385         4,326,782
New Mexico                  465,520         19,050           149,503           634,073           660,358
New York                  7,569,202        344,073         1,079,169         8,992,444         8,358,530
North Carolina            2,687,378        119,568           492,338         3,299,284         3,073,079
North Dakota                180,284          6,938           135,664           322,886           271,255
Ohio                      3,644,742        165,684           687,745         4,498,171         5,317,368
Oklahoma                    786,818         31,404           186,664         1,004,886         1,084,818
Oregon                    1,608,003         72,356           231,181         1,911,540         2,549,486

Pennsylvania                    6,462,652        313,603              705,868           7,482,123         6,818,470
Puerto Rico                     1,586,699         78,853              224,046           1,889,598         1,088,619
Rhode Island                      462,285         20,386               62,789             545,460           555,163
South Carolina                  1,339,961         59,219              255,641           1,654,821         1,753,409
South Dakota                      160,944          5,124              125,385             291,453           333,881
Tennessee                       1,586,579         70,680              331,584           1,988,843         2,162,310
Texas                           5,198,921        223,386            1,277,588           6,699,895         6,306,769
Utah                              525,266         19,083              214,845             759,194         1,639,737
Vermont                           273,325         11,774               58,737             343,836           393,419
Virgin Islands                     30,508            975               35,455              66,938            42,044
Virginia                        1,605,801         60,835              389,282           2,055,918         2,097,982
Washington                      2,739,750        121,170              383,228           3,244,148         4,605,508
West Virginia                     562,209         25,405              143,515             731,129           874,601
Wisconsin                       2,800,535        135,077              337,421           3,273,033         4,041,989
Wyoming                           158,312          5,526               97,280             261,118           289,275
Guam                                    0              0                8,423               8,423                 0

                 (1) Above base postage is estimated based on FY 2007 President’s budget assumptions. Above base
                     weeks claimed were assumed to be realized in the same proportion as base weeks claimed.
                 (2) Does not include $2.0 million for FLC, WIG, and WOTC.
                 (3) Adjusted for amount paid by VETS

Attachment: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2006/TEGL04-06_Att4.pdf

Attachment IV

                     3-Year Analysis – Average UI Work Load/Postage Costs

                 Subject Employers    Base & Above      Total Work     Actual UI Postage    Postage/Workload
                        X4            Weeks Claimed       Items            Paid (1)           Index (PWI)I

Total                   27,937,323        163,965,394    191,902,717        122,507,213                  0.64

Alaska                       66,344           896,399        962,743             386,426                 0.40
California                4,055,272        25,197,132     29,252,404          13,677,523                 0.47
Delaware                    104,815           498,475        603,290             284,008                 0.47
Illinois                  1,121,289         8,699,369      9,820,659           4,680,539                 0.48
Georgia                     801,260         3,204,815      4,006,075           1,949,075                 0.49
New Jersey                1,134,029         6,902,186      8,036,215           4,063,996                 0.51
Kentucky                    355,167         1,851,924      2,207,091           1,122,794                 0.51
Rhode Island                133,544           761,399        894,943             472,163                 0.53
Iowa                        275,477         1,446,363      1,721,840             908,708                 0.53
Idaho                       163,055           828,806        991,861             564,342                 0.57
Arizona                     442,264         2,004,173      2,446,437           1,417,469                 0.58
Texas                     1,584,640         8,585,585     10,170,225           5,979,737                 0.59
Nevada                      195,141         1,198,353      1,393,494             831,233                 0.60
Montana                     126,761           444,473        571,234             344,338                 0.60
Florida                   1,665,620         5,506,664      7,172,284           4,335,134                 0.60
New Mexico                  169,788           713,244        883,032             534,118                 0.60
Pennsylvania              1,084,319        10,318,167     11,402,485           6,987,478                 0.61
North Dakota                 74,633           204,399        279,032             171,851                 0.62
New York                  1,903,211        11,656,664     13,559,875           8,376,578                 0.62
Alabama                     345,828         1,715,347      2,061,175           1,291,814                 0.63
New Hampshire               156,955           411,340        568,294             356,807                 0.63
Louisiana                   381,189         1,859,379      2,240,568           1,436,977                 0.64
North Carolina              722,699         4,900,338      5,623,037           3,613,846                 0.64
Minnesota                   532,800         2,896,577      3,429,377           2,207,943                 0.64
South Carolina              359,837         2,237,927      2,597,764           1,752,000                 0.67
Michigan                    859,713         7,777,429      8,637,142           5,924,568                 0.69
Virginia                    676,448         2,282,042      2,958,490           2,031,124                 0.69
Oklahoma                    301,555         1,198,496      1,500,051           1,031,974                 0.69
Nebraska                    181,493           731,274        912,767             631,153                 0.69
Indiana                     502,599         3,067,829      3,570,428           2,484,234                 0.70
Missouri                    522,380         3,260,932      3,783,312           2,651,006                 0.70
Kansas                      271,271         1,412,751      1,684,022           1,181,975                 0.70
Tennessee                   440,405         2,661,377      3,101,783           2,272,728                 0.73
Massachusetts               700,909         5,308,642      6,009,551           4,436,854                 0.74
Wyoming                      78,417           196,996        275,414             204,528                 0.74
Mississippi                 216,189         1,192,701      1,408,891           1,046,631                 0.74
Connecticut                 387,411         2,572,449      2,959,860           2,262,254                 0.76
Ohio                        933,657         6,070,788      7,004,445           5,448,172                 0.78
South Dakota                 92,076           175,152        267,228             211,225                 0.79
Arkansas                    244,389         1,661,437      1,905,826           1,514,284                 0.79
Maryland                    538,829         2,104,189      2,643,018           2,121,206                 0.80
Oregon                      405,551         3,348,382      3,753,933           3,111,122                 0.83

Hawaii                       116,061            470,067            586,129     496,920   0.85
Maine                        158,467            619,716            778,183     670,312   0.86
Vermont                       84,161            403,675            487,837     420,219   0.86
Colorado                     577,085          1,811,146          2,388,231   2,079,934   0.87
West Virginia                150,915            829,332            980,247     909,869   0.93
Wisconsin                    492,273          4,290,065          4,782,338   4,449,888   0.93
Washington                   822,569          4,791,216          5,613,786   5,452,896   0.97
Utah                         226,560            787,811          1,014,371   1,715,240   1.69

Note: DC, PR and VI not included due to incomplete data
      (1) Does not include WP, VETS, Trade or BLS postage paid