Questions and answers on unemployment data validation

UIPL06-10acc.pdf (https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2010/UIPL06-10acc.pdf)

                                                       CLASSIFICATION
      EMPLOYMENT AND TRAINING ADMINISTRATION           Unemployment Insurance
                 ADVISORY SYSTEM                       CORRESPONDENCE SYMBOL
            U.S. DEPARTMENT OF LABOR                   OUI/DPM
               Washington, D.C. 20210                  DATE
                                                       January 5, 2010


ADVISORY:           UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 6-10

TO:                 STATE WORKFORCE AGENCIES

FROM:               JANE OATES /s/
                    Assistant Secretary

SUBJECT:            Unemployment Insurance (UI) Data Validation (DV) Program
                    Questions and Answers


1. Purpose. To respond to questions regarding the UI DV Program.

2. References. Unemployment Insurance Program Letter (UIPL) No. 03-04,
   “Unemployment Insurance Data Validation (UI DV) Program Status and Guidance;”
   UIPL No. 22-05, “Unemployment Insurance Data Validation (UI DV) Program
   Software and Policy Guidance;” UIPL No. 22-05, Change 1, “Unemployment
   Insurance Data Validation (UI DV) Program Activities During Validation Years (VY)
   2007 and VY 2008 and Policy Clarification;” UIPL No. 22-05, Change 2,
   “Unemployment Insurance Data Validation (UI DV) Program Activities During
   Validation Years (VY) 2008 and Beyond;” and ETA Handbook No. 361 (UI Benefits
   and UI Tax Data Validation Handbooks).

3. Background. UI DV is necessary to ensure that data reported by states and used by
   the Department to measure performance for administrative fund allocations,
   economic analysis, and other purposes are accurate and comparable across states.

   The operation of the UI DV program has changed significantly over the past few
   years. These changes include the issuance of several software releases, data extract
   and data transmission procedures, and the structure of the database that stores DV
   summary results. The Department has provided policy guidance in the documents
   cited in the References section. These changes and guidance have generated
   discussion in the states. The attachment to this advisory is a compilation of
   questions and answers provided as guidance to the states in the operation of the UI
   DV program.


 RESCISSIONS                                                  EXPIRATION DATE
 None                                                         January 5, 2011

                                        -2-



4. Action Requested. State Administrators are requested to distribute this guidance to
   appropriate staff.

5. Inquiries. Inquiries should be directed to the appropriate Regional Office.

6. Attachment. Attachment - Questions and Answers on Data Validation.

UIPL06-10a1.pdf (https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2010/UIPL06-10a1.pdf)

                                                                              Attachment



                  Questions and Answers on Data Validation


Benefits Questions

Weeks Claimed (Population 1)

   Pop 1-1   Question: In reference to population 1, how do we report a week filed (week
             claimed) that is initially monetarily ineligible, but two weeks later it is
             redetermined to be monetarily eligible? For example, how would we report the
             week filed on the ETA 5159 report for December 2008 if the same week is
             redetermined in January 2009? Would we amend the December 2008 ETA 5159
             report?

             Answer: Two things are important when reporting a week claimed: 1) is
             the claimant monetarily eligible or is the claimant’s monetary eligibility
             pending, and 2) did the claimant have excessive earnings for the week
             claimed. Monetarily eligible means that the claimant has received a
             sufficient monetary determination and has not exhausted benefits.
             Pending means that there was no final determination on the claimant’s
             monetary eligibility because the appeal period for an ineligible monetary
             determination had not expired, or a status determination to investigate
             unreported or covered wages is ongoing, or an appeal of an ineligible
             monetary determination had not been decided.

             The question implies that a monetary redetermination was pending while
             missing Base Period (BP) wages were being investigated. Under these
             circumstances the agency should continue to report every week for there
             are not excessive earnings as a week claimed until a final determination
             has been made that the claimant is monetarily ineligible. These are
             legitimately countable weeks claimed; whether the claimant is determined
             eligible or ineligible in January 2009 will not change the fact that the
             December 2008 report that counts such claimed weeks is correct and
             should not be amended. Additionally, in this latter scenario, the state
             would report a monetary determination on insufficient wages on its
             200804 ETA 218 report to reflect the monetary status at end of the quarter.

   Pop 1-2   Question: A situation occurs in certain states where an individual is claiming
             payments in a continued claim series when the status of the monetary
             determination is pending (i.e. monetary eligibility has not been finally
             determined). Should these weeks be counted as weeks claimed? A related issue is
             determining whether weeks claimed should be counted when a pending monetary



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             determination precludes a consideration about whether excessive earnings are
             being reported which would invalidate the “weeks claimed” count.

             Answer: Yes. If weeks are claimed while a monetary determination is
             pending, and for there are not excessive earnings, they should be reported
             as weeks claimed on the ETA 5159 Report. See answer to 1-1, above.
             However, in answer to the second question, if the monetary determination
             is made, and later in the same reporting period the earnings test deems
             some of the weeks ineligible due to excessive earnings, then those weeks
             initially considered “claimed” in the reporting period should be removed
             before submitting the report. If the weeks are determined not payable due
             to excessive earnings after the report has been transmitted to the National
             Office (NO), then a revised report for that period need not be submitted
             unless it results in a variance of greater then +/- 2%.

Final Payments (Population 2)

   Pop 2-1   Question: States with provisions for partial disqualification have encountered
             situations where the claimant received a final payment under a claim but the
             claimant had access only to a portion of the state’s maximum benefit entitlement
             based on the monetary determination. The claimant receives the maximum
             benefit payment to which he is entitled, but not the maximum which would have
             been available absent the disqualification. Should this final payment be classified
             as “final payment for maximum duration” on the ETA 218 Report?

             Answer: For purposes of the 218 Report (State UI claimants only),
             maximum duration is defined by the monetary determination. All
             claimants whose monetary determination entitles them to the state’s
             maximum duration would be reported on the 218 Report as qualifying for
             maximum potential duration [cell 28 (c28) and perhaps c6] before any
             reductions apply due to disqualifications or penalties.

             Claimants who only have access to a portion of their original monetary
             entitlement due to a penalty, and whose payments exhaust their reduced
             entitlement, should be reported on the 5159 (line 303 -26, -27, or -28) and
             on the 218 (lines 102 and 104, 8-14,19) as having received a final payment.
             The weeks of actual duration on the 218 report will reflect the reduced
             entitlement. When constructing the extract file for Final Payments, those
             claims for which entitlement was exhausted because the balance was
             reduced due to disqualification should have their Maximum Benefit
             Allowance (MBA) reduced by the amount of the disqualification to get the
             accurate actual weeks of duration.





                                                                                  Attachment

   Pop 2-2   Question: Reporting instructions refer to a final payment of zero as indicative of
             claim exhaustion. This presents difficulties when state policy allows for situations
             where a balance exists but is not available to the claimant because of a
             disqualification. How are final payments identified?

             Answer: Claim exhaustion, or the receipt of a final payment, is
             consistently defined in both the validation handbook and the ET Handbook
             401 definitions for the ETA 5159 and 218 Reports. State reporting
             procedures may use “final payment of zero” as a proxy for exhaustion; in
             this case the previous payment, which represented the remainder of
             benefits to which the claimant was entitled, would be the actual “final
             payment.” This must be harmonized with the common definition of final
             payment, which is “the last regular benefits a claimant receives in a
             benefit year because the claimant has no further entitlement to payment”
             (ET Handbook 401, page 1-5-5 (ETA 218).

   Pop 2-3   Question: In some cases the designation of “final payment” is determined based
             on claim status, and then additional wages are added to the claim resulting in an
             extension of the entitlement period (monetary redetermination). Is the count for
             original “final payment” valid?

             Answer: Yes, if the claim met all conditions for final payment at the time
             the designation was assigned and the additional credits are not added
             until a subsequent report period.

   Pop 2-4   Question: Can an adjustment payment be counted as a final payment?

             Answer: Yes. A final payment is the payment that exhausts the
             claimant’s benefit entitlement, and this payment can be an adjustment
             payment or a payment for the last week compensated.

Initial Claims (Population 3)

   Pop 3-1 Question: Some states use the “processing date” for new claims instead of the
            “claim-filed” date. Is this an issue?

             Answer: Yes. Handbook 401 specifies that claims are to be “counted as of
             the date…taken or received.” (see Handbook 401, page I-2-3). Depending
             on a state’s processes, certain types of claims, e.g., claims filed over the
             Internet, may not be processed when “taken or received.” In these
             instances, using the Processing date for the true “claim-filed” date will
             cause many claims to be counted in the wrong period. This is particularly
             problematic for the weekly ETA 539 report, which is a key economic



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          indicator. Because the 539 report’s definitions mirror those on the 5159
          (see Handbook 401, page I-1-7), a state must strive to count initial claims
          when actually filed for both the 5159 and 539 reports. In cases where
          process date follows the date received (or “filed”), and actual filed date is
          not available on its system, the state should do two things. First, develop
          an algorithm based on process date that yields the true filed date in all or
          most instances, and use that for both reporting and validation. For
          example, if new claims taken over the Internet are processed the next
          business day, the algorithm would calculate the date claim filed on the
          system as Processed Date minus one day and would appropriately
          account for weekends and holidays. Second, take steps to capture the
          actual filed date in its data system.

Pop 3-2   Question: A claim was filed on 1/23/09 with insufficient wages (no base period
          wages), but UCX wages were added on 2/16/09. When validating Field 6,
          “Program Type,” which is reported on the ETA 5159 report, would we use the
          information that would have been available as of the date the 5159 report was run
          for January 2009?

          Answer: No. Population 3 is used to simultaneously validate claims
          reported on the ETA 5159 report, and monetary determinations reported
          on the ETA 218 report. When validating the “Program Type” the 218
          report rule is followed, that is, you use the “Program Type” that is
          applicable at the end of the reporting period (quarter). In this case it is the
          status of the claim on 2/16/09, and the “Program Type” is UCX. If the
          claim were initially filed as State UI, and no UCX wages were added, it
          would be reported on the 218 as “Insufficient Wages” and on the 5159 as
          “State UI.” However, because UCX wages were added and no UI wages
          were found, when the Pop 3 record is built it would be considered a UCX
          claim, and it would not be reported on the 218 report, which includes only
          State UI monetaries. (If the claim initially had some UI wages, but they
          were insufficient to establish a benefit year, the claim would always be
          State UI even if it depended on the UCX wages to establish a BY. In such
          a case, the monetary would be reported on the ETA 218, with the final
          amount and duration based on the redetermination that included the UCX
          wages.)

Pop 3-3   Question: A claim was filed 1/23/09 which appeared to be a UCX-only claim.
          On 2/16/09, UCX wages were received, and a monetary determination was
          issued. On 2/18/09, the claimant contacted the agency and reported working for a
          UI base-period employer, and UI base-period employer wages were added to the
          claim on 2/24/09. Are we to validate Fields 9 “Sufficient/Insufficient/Combined





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          Wages”, 10 “WBA”, 11 “MBA,” 12 “Potential Weeks of Duration,” and 13
          “Potential Weeks of Maximum Duration,” based on the end of the quarter data?

          Answer: Yes, when the record for that transaction is built for the extract
          file, Fields 9 – 13 should be based on the end-of-quarter data.

Pop 3-4   Question: A claimant initially files an intrastate claim against “State A” via the
          internet. The claim is established as a monetarily ineligible (insufficient wage
          credits) “State A” claim, and a monetary determination is issued. Claimant
          contacts State “A” and advises that that all of his/her wages were actually earned
          in “State B.” The claimant subsequently files an Interstate-Agent claim against
          “State B,” and cancels the intrastate “State A” claim. How should this State “A”
          claim be reported?

          Answer: The Handbook 401 instructions for the 5159 report indicate that
          claims are to be counted “as of the date the claims are taken or received.”
          Based on the example, you would report only one new claim initial claim
          transaction in order to maintain a one-to-one relationship between initial
          claims filed (captured on the ETA 5159 report), and spells of
          unemployment (captured on the ETA 539 report). The Intrastate claim
          filed in State “A” would be cancelled because there were no wages earned
          in that state. Thus the claim filed against State “B” becomes an Interstate
          Claim filed From the Agent State. In the example, both the cancelled
          intrastate claim, and the Interstate-Agent claim represent the same spell of
          unemployment, of which only one should be reported. If both
          transactions occur in the same reporting period, the state would report
          only the Agent Claim. If the transactions span 2 separate reporting
          periods, then State A would have reported the Intrastate Regular UI claim
          in month 1 and a monetary determination with insufficient wages on the
          ETA 218 report. It would report the Interstate Filed from Agent state in
          month 2. Unless the variances are +/- 2%, no revisions to the ETA 5159
          report for period 1 would be necessary.

Pop 3-5   Question: Should an Interstate-Agent claim be reported, under Line 100, column
          2, on the ETA 218 report, as a claim with insufficient wage credits? For example,
          a claimant living in “State A” files a claim against the liable “State B.” “State
          A” does not establish a claim, and does not issue a monetary determination.

          Answer: No. The ETA 218 reporting instructions, on page I-5-4, of HB
          401, indicate: “1. Activities to be Reported...monetary determinations
          which were made during the reported period.” In the example, a
          monetary determination was not made; and “2. b. The liable state should
          submit data relating to interstate claims.” In the example, “State B” is the



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             liable state, which would report an Interstate Liable initial claim on the
             5159 report, and--if the claim is State UI--a monetary determination on the
             218. State A reports the Interstate Agent claim but has no monetary
             determination to report on the ETA 218.

   Pop 3-6   Question: What date do we use in determining whether the claim is intrastate or
             interstate (Field 7), if the status changes during the same month?

             Answer: For Field 7 “Intrastate/Interstate,” a validator should enter the
             final status of the claim in the state and use the date that claim was filed.
             For example, if Mr. Smith initially files an Intrastate claim against state A
             on June 10 but on June 15 decides to file an Interstate claim against state B
             in which he also worked because this would yield a higher WBA, the
             Intrastate claim would be cancelled. State A would report Smith’s claim
             as an Interstate Agent claim, filed on June 15.

   Pop 3-7   Question: UI Benefits Data Validation (DV) Handbook information regarding
             Population 3 indicates that the entry for the “MBA,” must be blank or 0. If
             “0000.00” is entered, will it be treated as a syntax error?

             Answer: No, the software will treat “0000.00” or “0” as = 0

   Pop 3-8   Question: Some states have provisions for claimants to draw benefits through the
             UI program while pursuing self-employment. How should these claims be
             counted?

             Answer: Self-employment claims should be reported on line 201 (13) of
             the 5159 report, and weeks and amounts compensated on lines 301 (20)
             and 302 (20), respectively. Records should be included in two extracts: 1)
             Population 3: Subpopulation 3.46, which is the number of self-
             employment claims (Appendix A, page A.17), and 2) Population 4:
             Subpopulation 4.43, which is the number of self-employment payments
             (Appendix A, page A.28).

Additional Claims (Population 3a)

   Pop 3a-1 Question: Can we use the employer identification (ID) number in the extract file
            for Population 3a instead of the employer name?

             Answer: Yes, either Employer Account Numbers (EAN) or employer
             name is acceptable in Field 10, Last employer.





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Payments (Population 4)

   Pop 4-1   Question: The reporting instructions for the ETA 9050, on page V-1-5, of HB
             401, related to “First Compensable Week,” indicate: “1) This will normally be the
             first week in the claims series in non-waiting week states and the second week in
             the claims series in waiting week states; 2) If two or more weeks of benefits at the
             beginning of the claims series are paid at the same time (whether by separate
             checks or by one check), then the earliest week-ending date in the benefit year is
             the starting date for measuring the timeliness of the first payment.” If a decision
             to deny benefits is appealed and upheld, will the first non-denied week be the first
             compensable week?

             Answer: No, in this case there will be no first compensable week. See
             Scenario 2 in the tables on pages V-1-6 and V-1-7 of Handbook 401
             instructions for the 9050 report. In those scenarios, the result for “Week 1
             denied, appealed and denial upheld on appeal” would be the same as
             “Week 1 denied, not appealed.” A denial of what would be the first
             compensable week in a benefit year does not cause the first compensable
             week to shift to the first non-denied week.

   Pop 4-2   Question: Appendix A of the UI Benefits DV Handbook labels the type of
             compensation for Subpopulations 4.46 and 4.47 as, “Weeks Compensated Not
             First Payments.” However, the Population 4 Record Layout gives the “Type of
             Compensation” labels as First Payment, Continued Payment, Adjustment, Self-
             Employment, and Prior Weeks Compensated. In the date record, should the label
             for a Continued CWC Payment be “Weeks Compensated not First Payments,” or
             “Continued Payments?” The footnote on page A.29 seems to indicate the use of
             the label, “Weeks Compensated not First Payments.”

             Answer: In building the record, states must use the labels provided in the
             Population 4 Record Layout; the DV software only accepts those values.
             Appendix A often uses a more inclusive term, but only for descriptive
             purposes. In this case, use “Continued Payments” for all weeks paid to a
             CWC clamant during the reporting quarter, whether paid before or after
             the CWC first payment was made.

   Pop 4-3   Question: If a UI benefit check is produced by a state, but it is cancelled before it
             is mailed to the claimant, should it be counted as a UI payment?

             Answer: No, since a cancelled check/payment would not have a mail
             date and it would not appear in a state’s accounting system as a payment,
             or debit against the claimant’s MBA.





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   Pop 4-4   Question: An adjustment payment covering a number of weeks, some of which
             were partial payments and some total, was made as a lump sum. How do we
             account for partial/total unemployment flags for the component adjustment
             payments?

             Answer: The state should break the adjustment payment down into its
             component weeks, and code the information for each week for which the
             payment adjustment was made.

   Pop 4-5   Question: A check was sent for a regular week of UI benefits on February 28,
             2008. No withholdings or reductions were made to the benefit check. The
             claimant exhausted benefits on May 5. This was flagged, and presumably
             reported as a final payment. On July 5, the check was cancelled as a “Stale-Dated
             check” (valid check never deposited). As a result, the claimant has a one-week
             available balance. Until the point when the check was cancelled, the payment on
             2/28 was counted as a week compensated. If the payment is cancelled, and the
             amount returned to the claimant’s balance, should it still be reported as a
             payment? Once the payment was cancelled would the week previously reported
             as a final payment still be reported as a final payment? Is this a moot point
             because all of the dates in question (check sent: 1st quarter, final pay: 2nd quarter,
             first check cancelled: 3rd quarter, benefit year ending (BYE): 4th quarter) are in
             different quarters (so the only reports affected would be those that include the
             cancel/stale date and the time the check was sent, such as an annual report)?

             Answer: Yes, the February 28 payment would be reported as a week
             compensated on the February 2008 ETA 5159 report and the payment on
             May 5 would be reported as a week compensated and as a final payment
             on the May 2008 ETA 5159 report and as a final payment on the 2nd
             quarter’s ETA 218 report because all these represented counts/amounts of
             payments actually made based on information accurate at the time. If a
             week’s entitlement is then restored to the claimant’s balance and another
             payment made in July, then that payment would be reported on the July
             2008 ETA 5159 as a week compensated and final payment, as a final
             payment on the 3rd quarter ETA 218 report. Thus, two final payments can
             be reported for one claim series, as long as they occur in different months
             (ETA 5159) or quarters (ETA 218).

Nonmonetary Determinations (Population 5)

   Pop 5-1   Question: Note #1 of the Population 5 Notes (page A.46) states: “For states that
             require a week to be claimed in order to count a nonmonetary determination, use
             the transaction date of the nonmonetary determination when the mail date
             precedes the week claimed date. For example, if a determination is mailed in
             December and the week is claimed in January, the state enters the transaction (or



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countable) date in January to signify that this nonmonetary determination is
countable for Federal reporting purposes.” We require a week claimed before a
nonmonetary determination (nonmon) can be counted. What is meant by the term
“Transaction date” and what date should be used in the Notice Date field of the
Pop 5 extract (Field 12)?

Answer: Since the mid-1990s, Federal reporting policy has not required
that a week be claimed for a nonmonetary determination to be counted.
However, some states have policies that specify that a nonmon may not be
issued (i.e., does not become effective) until the claimant claims a week of
benefits. The Department insists that reporting follow state policy and
that no nonmon in these states be counted until the state declares it
issuable. Thus, if it happens that such a state does prepare and issue a
nonmon before a week is claimed, reporting and time lapse calculations
must be based on the date the week is claimed (the “transaction date” in
Note 1.) That is the date the nonmon becomes effective in the state.

The note is intended to ensure that Population 5 extract records include
only issuable nonmonetary determinations, and that they are counted in
the right time period and their time lapse is based on the correct
transaction dates. The note indicates that the correct date in Field 12
(Notice Date) for a nonmon in a state that still requires a week to be
claimed is the later of (a) the date a week is claimed or (b) the issue date
on the determination (i.e. the date the determination notice is mailed or, if
no notice is required, the date payment is authorized, waiting week credit
is given, or an offset is applied). In the unlikely situation that the state
has dated the nonmon before it has become issuable, the nonmon record
must use the date of the appropriate week claimed (the transaction date)
in Field 12. If the week claimed date is no earlier than the issue date on the
determination —which is more likely--then use the issue date on the
determination in the Notice Date field because that is the date the nonmon
was both issued and became effective and is the official start date of the
state’s appeal period.

This procedure ensures that the validation counts will be correct; if the state
is systematically counting and reporting nonmons before their true issue
dates, they will fail RV. Any nonmon record examined during the DEV
process that contains a Notice Date that precedes the date of week claimed
must fail validation as it is issued (or at least dated) contrary to state
policy.





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   Pop 5-2   Question: We have some issues (approved training, for example) where we do not
             require a week to be claimed to count them. Page A.46, of the UI Benefits Data
             Validation Handbook, under “Population 5 Notes” states, “For states that require
             a week to be claimed in order to count nonmonetary determination, use the
             transaction date of the nonmonetary determination when the mail date precedes
             the week claimed date.” We infer that because we do not require a week claimed
             for these decisions that we should fill “first week affected” with the determination
             mailed date, is that correct?

             Answer: Yes. That would be acceptable. However, since the elimination
             of the ETA 9053 report, the First Week Affected (field 10) is now optional
             and it may also be left blank. Because a week claimed is not required for
             these transactions, the operative transaction date would be the date of the
             determination itself.

   Pop 5-3   Question: The time requirement for the issuance of non-monetary determinations
             (nonmons) is a key performance indicator. States have different methods of
             recording the dates used for this calculation. How can procedures be standardized
             to assure that states are in compliance?

             Answer: The UI benefits Population 5 record layout requires that dates be
             provided for issue “Detection date” (Field 11) and “Notice date” (Field
             12). These terms are defined in ET Handbook 401 and the UI Benefits
             Validation Handbook. The only exception to the general rule comes in
             states that require a week to be claimed before a nonmon can be counted.
             In such states, if the Notice Date precedes the date the week is claimed, the
             Week Claimed Date is used in Field 12 instead of the Notice Date. See
             Appendix A, Population 5, Note 1, p. A.46, where Week Claimed Date is
             called “transaction date.”)

Claims Filed (Populations 6 and 7)

   Pop 6-1   Question: The UI Benefits DV HB on page A.49 states, “If a state experiences
             delays in mailed appeals, it can use the received date rather than the postmark
             date to ensure all appeals are counted.” What we keep in the mainframe is the
             date the transaction was entered into the system (Entry Date). This field is used
             for the UI data validation extract file and for the monthly federal 5130 reporting.
             Are we in compliance with Step 32?

             Answer: No. Using Entry Date would not satisfy the requirements for
             Step 32. The Department rates agency appeals performance by basing
             time lapse or case aging on the date an appeal was actually filed because
             that is the time lapse experienced by the appellant. However, if the mail
             system typically produces long delays between the time an appeal is filed


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              and when it reaches the agency, the use of received date instead of filed
              date is allowed so that the agency is not penalized for uncontrollable delays
              and to ensure that appeals filed are properly counted. Entry date is not an
              acceptable proxy for received date because it can give a misleading
              impression of time lapse/case aging by eliminating time lags that are
              under the agency’s control. Therefore, states should use actual Filed Date
              when their mailed appeals are not typically affected by extended mail
              delays; if mail delays are a problem, they should use Received Date or the
              closest approximation to received date available from operational data
              and work to resolve delayed mail with the United States Postal Service.

Average Age of Pending Lower and Higher Authority Appeals (LAA/HAA)
(Populations 10 and 11)

   Pop 10-1 Question (HAA): In the extract file for March, 214 records were identified as
            errors because the “Docket Number/Unique ID” field was blank. This occurred
            because we have cases that were appealed in March, and prior months, but the
            docket numbers were not assigned until after April 1. Essentially, there is a filed
            date in our system (and the case is coded as a higher authority appeal), but the
            case does not have a docket number. Can we use the lower authority appeals
            docket number when a higher authority number has not been assigned?

              Answer: Yes, that is one of two ways to approach this. The Lower
              Authority docket number (preferably with a suffix such as -1 or –a to
              differentiate it clearly from the LAA appeal), or some other “dummy”
              docket number could be used to ensure that the “Docket Number Unique
              ID” field is populated; however, a crosswalk between the Higher
              Authority docket number, and the Lower Authority or “dummy”
              document number, should be assembled, and maintained to avoid any
              discrepancies during Data Element Validation (DEV). If that method is
              not chosen, the agency could wait until the docket numbers are assigned
              to build the extract file. In any case, however, the state must make sure
              that the date the docket number is assigned is not used as the file date, or
              time lapse and case aging will be skewed.

Overpayments Populations 12 (Established), 13 (Reconciliation) and 14 (Age of OPs)

   Pop 12-1 Question: On the ETA 227 report, under which cell in Section C,
            Recovery/Reconciliation, should credit card payments be included? Do credit
            card payments get included under “Cash” or “Other?”

              Answer: Credit card payments would be classified as “Cash,” in the same
              manner that personal check payments are treated.



                                                                                  Attachment



   Pop 12-2 Question: Benefit overpayments reported on the ETA 227 report should be
            included in the “dropped” category on the report when they are no longer in
            active status. How is it determined when overpayments should be categorized as
            “dropped”?

             Answer: For reporting purposes, overpayments should be classified as
             “D” (dropped) when the overpayment has been reported for nine or more
             quarters and was in active collection throughout the quarter prior to the
             report quarter but has been removed from active collection status during
             the report quarter. These criteria are only for reporting purposes, and do
             not affect how long state law or policy requires them to keep
             overpayments “on the books.” Validators must be clear on the state’s
             criteria for considering an overpayment in active collection status or
             dropped from active status, and ensure that is applied properly when
             conducting DEV.

Module 4 – Lower Authority Appeals Quality Sample

   Mod 4-1   Question: When validating Population 8, we discovered that our ETA 9054
             reported count was significantly lower than the universe count, which caused us
             to fail. After investigating, we determined that while the universe file count
             included issues that do not affect a claimant’s benefits, the ETA 9054 count did
             not include these issues. Handbook 401 instructions and definitions for the ETA
             9054 are identical to the ETA 5130, and page I-3-4, indicates, “If state procedures
             permits recourse to the appeals authorities by employers or employer
             representatives desiring to appeal a state agency decision which did not directly
             affect the benefit rights of a specific claimant or claimants, such appeals should be
             excluded from this report.” Additionally, the ETA 5130 instructions also apply
             to the ETA 9057 report. Should issues that do not affect a claimant’s benefits be
             included on the ETA 9054 report, and should they be included in the Module 4
             appeals quality sample?

             Answer: No. As noted in Handbook 401, page I-3-4, issues that do not
             affect a claimant’s benefits, should not be reported on the ETA 5130 (or
             the ETA 9054), and they should also be excluded from the universe for the
             ETA 9057 sample. Also excluded from those reports are hearings of
             Interstate appeals held by agent states (See Note, HB 401, p.1-3-4).





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Tax Questions

Active Employers (Population 1)

   Pop 1-1    (Active Employers) Question: The “number of liable quarters” is defined as
             “the number of consecutive quarters between the date the employer was activated
             or reactivated …..” This implies that the count of quarters should start over
             again when the account is reactivated. How is employer status established?

             Answer: An employer may be added to the state’s accounts, and be
             countable as an active employer, when the employer meets the state’s
             threshold of liability (based on paying a certain amount of wages). When
             this occurs the state will make a New Status Determination (validated on
             Population 3) and add the employer account to its list of liable employers
             (validated using Population 1). The criteria for the identification of active
             employers using the Tax Population 1 extract file, and for New Status
             determinations using the data in Tax Population 3, are displayed on pages
             A.15 and A. 20 of Appendix A in the UI Tax Data Validation Handbook.
             Both population extract files contain “reactivation process date” as a data
             element. That is the date when an employer account that had been
             previously inactivated or terminated was reestablished by paying enough
             wages to meet the state’s liability threshold. On the DV extract file, the
             count of the number of quarters for a reactivated employer will begin with
             the quarter of liability on which that reactivation is based. The number of
             quarters that a given employer has been in active status can be established
             using the Activation or Reactivation Date in combination with quarterly
             wage file extract data and the Liability Met Threshold date, although the
             Population 1 extract file only contains 8 quarters of wage data before the
             report quarter.

   Pop 1-2   Question: The count of new employers required for item 14 on the ETA 581
             report is susceptible to state-specific definitions and administrative procedures.
             Some states assign account numbers to potential employers before they actually
             establish payroll. The DV software rejects employers for whom no records
             indicating wages paid by that employer were submitted. How can the validation
             methodology be reconciled with state policy in this regard?

             Answer: National reporting standards were established to allow
             meaningful comparisons among all states. For this reason, the national
             reporting standards do not provide states the latitude to report data using
             state-specific definitions that are contrary to those established federally.
             States that do not use the DOL definition for determining subject
             employers will not reconcile with data validation requirements. ETA 581



                                                                               Attachment

             reporting instructions specify that potential employers who have not
             actually met a specific threshold or condition of liability contained in a
             state’s unemployment compensation law do not meet the definition of
             “employers” and should not be included in the count of new employers
             until wages-paid data indicate that they are “liable employers.” This rule
             was established as part of Handbook 401, Change 12. For employers that
             met the state’s liability threshold since 1/1/2003, the validation software
             checks to see that the activation processing date (Field 8 of Population 1) is
             not earlier than the Liability/Met Threshold Date (Field 5). In the case of
             employers that had been inactivated/terminated and then reactivated, it
             checks to see that the Reactivation Processing Date (Field 6) is not earlier
             than the Liability/Met Threshold Date.

   Pop 1-3   Question: Some states do not require reimbursable employers to report wages to
             the UI agency. Claims filed against these employers require that wage
             information be obtained by request. Because there is no record of wages paid
             during preceding quarters, the DV software does not identify these employers as
             “active.” How can this discrepancy be dealt with?

             Answer: One criterion for “active employer” status for data validation is
             evidence of wages paid. Every state should require all subject employers
             to report wages quarterly. (As of November 2009, only Massachusetts has
             not complied with this requirement.) All states can expect that the DV
             software will reject as errors validation extract records for employers that
             have not submitted quarterly wages and this may cause them to fail DV.
             States that do not require reimbursing employers to report wage records
             should describe the situation in the comments section of the summary
             report. Regional Office (RO) coordinators will review comments when
             deciding when to impose Corrective Action Plans (CAPs) in response to
             specific DV issues.

Report Filing Delinquency (Population 2)

   Pop 2-1   Question: Line 201, (8) and (11) on the ETA 581 Report require states to identify
             the number of employer accounts which have been “resolved” through obtaining a
             report, determining non-liability for taxes, or issuing an assessment. According
             to ETA 581 definitions, reports can only be resolved by assessments if
             assessments are “final.” State procedures vary considerably on this matter; some
             consider a report resolved when they issue an assessment that is legally binding,
             even though it is not a “final assessment” because the appeal period is not
             exhausted. Others only classify the account as “resolved” when the final
             assessment is issued. These different interpretations of when an account is
             resolved by assessment can affect how long it takes to resolve reports and thus




                                                                                Attachment

             distort the information provided in the “resolved reports” category of the ETA
             581 Report. How can this apparent distortion be avoided?

             Answer: ET Handbook 401 defines a Resolved Report as, “A contribution
             report which has been received or resolved by a final assessment of tax
             that is legally due and collectible or by a determination of non-liability.”
             Unfortunately, “legally due and collectible” and “final assessment” do not
             mean the same thing in all states. Many states consider an assessment
             “legally due and collectible” when it is issued; it becomes “final” only
             when the employer’s opportunity to appeal the formal legal notice of the
             amount of the unpaid contributions has expired. In deciding when a
             report is resolved for ETA 581 purposes, states should be guided by the
             two elements that normally make up a Final Assessment. These are: first,
             that the employer’s appeal period must have passed; and, second that the
             tax must be “legally due and collectible” and the state includes the
             estimated assessment in item 26 on line 401 of the ETA 581 report (and in
             the quarter assessed, in item 22 as well). States should therefore use the
             date on which the assessment has satisfied these two elements to indicate
             when a report is resolved.

Status Determinations (Population 3)

   Pop 3-1   Question: How do we count Successor status determinations in the following
             situations: Company A acquires Company B, and Company C; Company A is the
             Successor and Company’s B and C are the Predecessors. Should we build a
             successor record for both B and C?

             Answer: Yes, if Companies B and C are unique employers, and the
             successorship was determined to meet the state UC laws of succession
             separately, then there should be two distinct successor records.

Field Audits (Population 5)

   Pop 5-1   Question: Items 53 through 58 on the ETA 581 Report pertain to audit data for
             under- and over-reported wages and contributions. Should these amounts be
             “netted” with only the net results reported?

             Answer: No. The under- and over-reported amounts should be reported
             separately for each quarter. Reporting the amounts separately provides
             information about how accurately employers are reporting wage
             information.





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Module 5 – Wage Item Validation

   Mod 5-1   Question: If states put all magnetic media together as a single mode of
             transmission (compact disc, diskette, tape) should they be broken out for Wage
             Item Validation (WIV)?

             Answer: Yes, because the intention of Module 5 is to assess the accuracy
             with which a state counts wage items for each mode of entry it uses, so
             that it can improve the accuracy for any mode that is deficient.

   Mod 5-2   Question: If only one of the five modes used had an error percentage >2%, does
             the entire validation fail? Do we do WIV for all modes again next year, or just
             the mode that fails?

             Answer: WIV is treated the same as Report Validation (RV) for one of the
             populations, that is, if one group fails, then the entire population fails, and
             must be repeated the following year. The failure of one mode equals total
             failure for WIV.

   Mod 5-3   Question: What is a batch in terms of WIV? One state has 50 employers per
             batch, while in other states a batch is a day’s work of transactions.

             Answer: States typically batch wage and contribution reports received, by
             mode, into groups, to process them and to organize their accounting
             records. Depending on state procedures, a batch could contain 50 reports,
             100 reports, or an entire day’s processing. A day’s worth of Wage and
             Contribution reports could yield many batches, or only a single batch.
             Validators must select a batch for each mode that contains at least 150
             wage records in accordance with the sampling instructions in the Module
             5 guidance.

   Mod 5-4   Question: During WIV, if you have to do one mode more than once, how do you
             get that total of 150 records? Can the total for the second batch include other
             modes?

             Answer: In WIV, we have changed the approach to validating Wage
             Items from recounting a batch to recounting a sample of records. For each
             mode, you are asked to recount a sample of 150 wage records. Thus, for
             each mode, select a batch that contains at least 150 wage records; if none is
             readily available, select two or more batches. These will be recounted in
             two parts, a subsample of 50 records as a first-stage acceptance sample
             that will pass if the recount equals the number of wage items in your





                                                                                Attachment

            system, and the full sample of 150 records that will pass if the difference is
            six or fewer.

  Mod 5-5   Question: Can WIV be done at any time during the Validation Year (VY)?

            Answer: Yes, as long as it involves the validation of counts reported for
            the report periods that the VY (April 1 through March 31) comprises.
            Given the reporting lag for the ETA 581 report, that means the validation
            will probably apply to the 2nd, 3rd, or 4th calendar quarters so that results
            can be submitted by the June 10 deadline.

General Questions

  Gen 1-1   Question: The DV software automatically eliminates duplicate records when
            deriving counts for summary validation. The criteria used by the software to
            detect duplicate records sometimes result in the identification of records as being
            duplicate when, in fact, they are not. How can states cope with the situation
            when records are erroneously identified as duplicate and eliminated from the data
            set resulting in failure for a given population?

            Answer: The criteria built into the software consistently apply federal
            requirements. These identify “true” duplicate records in most states but
            are too simple to address all situations in all states. Instances exist where
            records appear to be duplicates when, under unique states’ procedures
            and processing conventions, they are legitimately reportable cases. Based
            on our discussions with state staff, it appears that such cases are relatively
            infrequent, and the ±2% validity standard will typically accommodate
            them. Thus, it did not seem advisable to introduce the additional
            complexity into the extract files and the software needed to determine
            they are legitimate claims. However, if the number of duplicates is large
            enough to cause a population to fail, states should manually check the
            transactions the software has identified as duplicates, determine which are
            “true” duplicates and eliminate them from the file, and note the number
            of legitimate, reportable transactions still identified as duplicates by the
            software in the comments field and explain why they are legitimately
            reportable cases. If it should happen that they exceed the ±2% threshold,
            the comments will serve both to explain why the state should have
            passed, the documentation for changing the Fail to Pass, and as a guide
            for the design of future versions in the software.

  Gen 1-2   Question: Are the optional (grey-highlighted) fields in Appendix A, the Report
            Validation Specifications, validated? It is my understanding that any entry in an
            optional (grey-highlighted) field is simply passed.



                                                                               Attachment



          Answer: If a field is optional, and the programmer left it blank, the
          validator should pass it. If a field is optional for every sub-population in
          the population, and the programmer has filled in a value, it is at the
          discretion of the validator to determine whether to automatically pass the
          field or not. It is preferable that the optional fields are reviewed for
          consistency; however, since they are not used for case assignment, they
          may be passed.

          If a field is optional for some subpopulations, but applicable for others,
          conduct a thorough DEV, since, in some instances an optional field is used
          for subpopulation assignment.

Gen 1-3   Question: Our reporting methodology involves building the DV population files
          first, and then using the extracted data for the ETA required reports. This is the
          reporting methodology that was outlined for us; is this still correct?

          Answer: The Department has no policy on this; it only requires states to
          assess the accuracy of selected key report items by using the Data
          Validation system. The Department recommends using the DV
          methodology as a basic guide to reporting because it systematically
          interprets reporting requirements. However, the DV program has some
          limitations: it does not validate every reportable item; and it does not
          necessarily perfectly classify all the elements that it validates.

Gen 1-4   Question: For data fields that appear in a number of populations such as WBA,
          MBA, Earnings, Intrastate/Interstate, are we to use the earliest information
          available, or the current information available at the time of reporting/validation?

          Answer: The best general guide for all fields is to use the value that is
          applicable to the transaction at the time that the ETA report is produced,
          i.e. following the reporting instructions on Handbook 401. For example,
          when validating the ETA 218, the WBA and MBA values should
          correspond to the last available information at end of the report quarter
          being validated. For the monthly ETA 5159, on the other hand, a claim is
          classified as Intrastate or Interstate according to how it was classified at
          the time the claim was taken and not to how it was classified at the end of
          the month. Earnings in Population 4 must be captured for each week in
          order to validate a partial payment correctly.

Gen 1-5   Question: Do we have to create extract files for programs other than Regular UI,
          such as Extended Benefits (EB), Extended Unemployment Compensation (EUC),
          Disaster Unemployment Assistance (DUA), etc?



                                                                             Attachment



          Answer: No. We only validate regular UI reports data and so no extract
          files need be built for reports specifically for temporary or episodic
          programs such as EB, DUA, EUC, etc.

Gen 1-6   Question: How must UI DV deficiencies be addressed through the State Quality
          Service Plan (SQSP)?

          Answer: Every spring, the SQSP Call Memo explains how unmet UI DV
          requirements must be addressed in the SQSP for the upcoming fiscal
          year. For example, for FY 2010, any DV items due for VY 2009 but not
          submitted must be addressed in a Corrective Action Plan (CAP), and a DV
          CAP must also be done if a state has a combination of non-submitted and
          submitted-but-failing items. If, however, a state submitted all DV items
          due for VY 2009 but some of them failed, it may address those that did not
          pass in the SQSP narrative. Both CAPs and narratives must explain the
          cause of the failure and the actions the state will take to correct the failure
          during the upcoming validation year 2010. Because requirements and
          how they must be addressed in the SQSP may change from year to year,
          validators must always consult the current SQSP Call Memo.

Gen 1-7   Question: Will states be allowed to conduct Workload Validation?

          Answer: No. UIPL 22-05, Change #2, indicates, “Beginning with VY 2009,
          Workload Validation is no longer an alternative to DV.”

Gen 1-8   Question: When reporting errors are found in the course of validation, how far
          back should reports be revised?

          Answer: It would be useful to revise reports as far back as can be done at
          reasonable cost so that analyses and projections which rely on this data
          will be accurate. Because actuarial projections--e.g., of the number of
          nonmonetary determinations used as workload items--are usually based
          on data over time (time series), accurate time series data help produce
          accurate projections. However, costs of making retroactive changes can
          often be high. Consult with Regional Office (RO) or NO staff regarding
          the importance of making retroactive changes to specific data series.

Gen 1-9   Question: How will DV results affect the interpretation of performance results
          and the size of administrative allocations?

          Answer: Policy regarding DV results will be used in the calculation of
          funding allocations and the calculation and interpretation of UI



                                                                             Attachment

           PERFORMS and GPRA performance measurements. The timeline for
           when the Department will begin using DV results for these purposes, is
           under development. This issue will be addressed in a subsequent
           advisory. Even in the absence of a formal connection between data
           validation and formal performance measurements and allocations, the
           importance of accurate reporting cannot be overemphasized, and states
           need to take all appropriate steps to ensure that the data used by
           policymakers and those responsible for oversight and management of the
           UI system are correct.

Gen 1-10 Question: States sometimes discover through the DV process that data gathered
         for a Federal report is incorrect or incomplete. Even if the state has a commitment
         to correcting the problem it has no way of preparing correct and/or complete
         report information until the problem is diagnosed and corrected. Should the state
         provide report data even if it knows that it is not correct?

           Answer: States should always report the best data available at the time. If
           the state knows that accuracy of the data is suspect, it must use the
           Comments section to alert the Department of this fact, and subsequently
           correct the data. Cells for which data are questionable should not be left
           blank. ET Handbook 401, 4th Edition, Introduction and General Reporting
           Instructions states, “For six regular-program workload reports (ETA 5159,
           ETA 5130, ETA 218, ETA 207, ETA 581, and ETA 586) any values not filled
           in will prevent the report from being transmitted to the National Office.
           Incomplete reports are not acceptable. For non-workload reports or for
           workload reports other than regular versions, cells not filled in are
           assumed to be zero and are automatically zero filled when left blank.”
           States need to undertaken appropriate analyses to determine the causes of
           any incorrect data as soon as data problems are discovered (e.g., through a
           failing data validation RV) and take steps to correct the reporting errors.
           This is particularly important for key data such as used in GPRA or UI
           Performs performance reports, or for workload.