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Fiscal year 2025 unemployment insurance State Quality Service Plans

Summary ETA told state unemployment insurance agencies how to prepare their fiscal year 2025 State Quality Service Plans and submit them by deadlines set by their regional offices. The letter covers performance and integrity priorities, required improvement plans, reporting and funding. Its printed expiration date was December 31, 2025, although ETA's advisory listing still labels it active.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 16-24
Date issued
July 22, 2024
Status
Unknown
ETA's advisory listing labels this letter Active, but the letter itself prints an expiration date of December 31, 2025. Its status is unclear.
Status last verified October 24, 2026

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

The current status of this document is unclear
ETA's advisory listing labels this letter Active, but the letter itself prints an expiration date of December 31, 2025. Its status is unclear. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 Unemployment Insurance
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OUI/DPM
             Washington, D.C. 20210                       DATE
                                                          July 22, 2024

ADVISORY:       UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 16-24

TO:             STATE WORKFORCE AGENCIES

FROM:           JOSÉ JAVIER RODRÍGUEZ
                Assistant Secretary

SUBJECT:        Additional Planning Guidance for the Fiscal Year (FY) 2025 Unemployment
                Insurance (UI) State Quality Service Plan (SQSP)

1. Purpose. To initiate the FY 2025 SQSP process and define additional requirements relevant
   to the FY.

2. Action Requested. The Employment and Training Administration (ETA) requests State
   Administrators to:

   •   Make this information available to appropriate staff;
   •   Prepare their state’s SQSP in accordance with planning and reporting instructions
       contained in Employment and Training (ET) Handbook No. 336, 18th Edition, Change 4
       (SQSP Handbook) and additional instructions in this Unemployment Insurance Program
       Letter (UIPL);
   •   Coordinate specifics, as appropriate, with the ETA Regional Office (RO) for electronic
       submission of the SQSP; and
   •   Submit the FY 2025 SQSP to the appropriate RO by the deadline set by the RO.

3. Summary and Background.

   A. Summary – The SQSP Handbook provides planning and reporting instructions for the
      SQSP process. This UIPL provides additional guidance relevant to the SQSP process for
      FY 2025, specifies dates applicable to the FY, outlines national priorities and Federal
      program emphasis, and identifies special planning requirements for the FY.

   B. Background – The SQSP is the state’s UI performance management and service plan. It
      represents an approach to the UI performance management and planning process that
      allows for an exchange of information between Federal and state partners to enhance the
      UI program’s ability to reflect their joint commitment to performance excellence and
      customer-centered services. As part of UI Performs, the comprehensive performance
      management system for the UI program, the SQSP is the principal vehicle that state UI
      programs use to plan, record, and manage improvement efforts as they strive for
      excellence in service. Title III of the Social Security Act (SSA) authorizes the Secretary

  RESCISSIONS                                              EXPIRATION DATE
  None                                                     December 31, 2025

       of Labor (Secretary) to provide funds to states to administer the UI program and governs
       the expenditure of those funds. The SQSP is a part of the process by which states receive
       Federal UI administrative grants.

       The SQSP Handbook contains general instructions for the SQSP. It is designed as a
       permanent guide for the planning and budget process and provides states with planning
       guidelines and instructions for reporting UI financial and staff year information. The
       SQSP Handbook notes that ETA will issue a SQSP UIPL each year with additional
       planning guidance that supplements the SQSP Handbook and provides direction and
       instructions specific to the upcoming FY. Though this additional planning guidance is
       like the guidance issued in previous years, there are changes relevant to the FY 2025
       SQSP; therefore, please review this guidance carefully.

       The SQSP Handbook is approved under the Office of Management and Budget (OMB)
       No. 1205-0132. The current approval expires on June 30, 2027.

       ***Note: Due to the sensitivity of information about integrity controls and certain other
       UI operational matters, states should not make their SQSP publicly available.
4. For FY 2025, ETA will continue to strive to make the SQSP process a meaningful
   management tool and a strategic road map to improve program administration, strengthen
   program integrity, and ensure quality service delivery. The SQSP process focuses on
   promoting state performance and integrity by aligning state UI administration and operations
   with national priorities, paying benefits accurately and timely, and connecting unemployment
   compensation (UC) claimants with needed reemployment services. This section highlights
   the major areas that states are to use in developing their FY 2025 SQSPs.

   A. National Priorities and Federal Program Emphasis

       National Priorities

       The Federal-state Unemployment insurance (UI) system, created by the Social Security
       Act of 1935 (SSA), is a social safety net for individuals who have lost employment for
       good cause or no fault of their own. It also helps to stabilize local and national economies
       during periods of labor market disruption by keeping funds circulating, and it keeps
       displaced workers attached to the labor market. As noted in the report, Building
       Resilience: A Plan for Transforming the Unemployment Insurance, “unemployment
       benefits supported over 53 million workers and kept 5.5 million people from falling into
       poverty,” during the COVID-19 pandemic.
       However, the COVID-19 pandemic exposed many challenges and areas in need of
       improvement in the UI system and also brought about new threats to the system. These
       challenges include administrative funding issues, that some workers are not covered by
       the UI program, the adequacy of weekly benefit amounts, and increased fraud risks
       brought about by attacks from sophisticated domestic and international criminal
       networks.


         The American Rescue Plan Act (ARPA), enacted in March of 2021, provided a one-time
         $2 billion investment in the UI system aimed at addressing the most significant
         operational and administrative challenges facing the program. Although this amount was
         reduced by $1 billion in the Fiscal Responsibility Act enacted on June 2, 2023, the goals
         for ARPA and system transformation remain the same. The ARPA goals are detecting
         and preventing fraud, promoting equitable access, and ensuring the timely payment of
         UC.
         The UI system currently is experiencing a “window of opportunity” as funding is
         available to make significant improvements to the system. Using most of the available
         ARPA funds, the Department of Labor (Department) has provided over $750 million in
         grants to states to address the goals set out in ARPA. In addition to these investments of
         funds, the nation is experiencing a stable labor market and very low UI claims volume.
         These conditions offer an opportunity to make substantial progress in completing many
         ARPA-related UI modernization projects that support UI transformation.
         The Department recognizes that states have been challenged with administrative funding
         levels and staff capacity including challenges in retention and hiring. However, for this
         year’s SQSP, the Department urges each state to focus its SQSP narrative on building a
         strategic plan and vision on how ARPA investments will support UI transformation in the
         state.
         When developing the FY 2025 SQSP, the Department suggests a state plan focus on
         strategies to:
             •    Rebuild and improve program performance and develop high-quality customer
                  services and experiences, including implementing ARPA-funded projects1
             •    Develop a multi-layered approach to addressing fraud, reducing improper
                  payments, and recovering established overpayments 2
             •    Ensure equitable access to UC3
             •    Strengthen reemployment and connections to suitable work4
             •    Build responsive and resilient state IT systems
             •    Ensure accurate and complete reporting of ETA required reports5
         The Department recommends reviewing the report, Building Resilience: A Plan for
         Transforming Unemployment Insurance, to inform state strategies.

         The Department also recommends identifying in the strategic plan the potential barriers
         and threats to success, as well as technical assistance needs. Successful implementation
         of these ARPA projects will ensure the UI system continues to fulfill the promise of the


1 Attachment II provides information and resources on this strategic area.
2 Attachment III provides information and resources on this strategic area.
3 Attachment IV provides information and resources on this strategic area.
4 Attachment V provides information and resources on this strategic area.
5 Attachment VI provides information and resources on this strategic area.


  Federal-state UI system and provide a social safety net for America’s workers. Thus, the
  Department encourages each state to develop its own UI transformation plan.

  Federal Program Emphasis

  The Government Performance and Results Act of 1993 (GPRA) requires a commitment
  from all Department programs to attain expressed goals and objectives. Achieving these
  objectives requires the combined efforts of the Federal and state partners. Like the
  national priorities, Federal program emphasis summarizes the primary areas in which the
  Federal partner will focus attention and resources for the planning cycle. The
  Department’s Strategic Plan and the Department’s annual performance budget form the
  basis for the Federal program emphasis.

  In FY 2025, ETA will continue to work with states to rebuild performance with attention
  on the GPRA goals below for FY 2025, with targets that the UI system, as a whole, is
  expected to meet. States should continue to strive to reach or exceed these GPRA goals
  and targets. States must describe in the SQSP Narrative the steps they will take to reach
  and/or exceed these GPRA goals and targets (see
  https://oui.doleta.gov/unemploy/docs/GPRA_Summary_Report.asp for the FY 2025
  GPRA goals and targets.

                   Goal                                         Target
   Percent of Intrastate Payments         87 percent of intrastate first payments for full
   Made Timely (Make Timely Benefit       weeks of UC will be made within 14/21 days
   Payments)                              from the week ending date of the first
                                          compensable week.
   Detection of Recoverable               Overpayments established at a rate that is at
   Overpayments (Detect Benefit           least 57.5 percent of the estimated detectable,
   Overpayments)                          recoverable overpayments.
   Percent of Employer Tax Liability      90 percent of status determinations for new
   Determinations Made Timely             employers will be made within 90 days of the
   (Establish Tax Accounts Promptly)      end of the first quarter in which liability
                                          occurred.


B. Program Performance

  The Department’s strategic approach to UI Performs is to focus efforts on improving the
  performance of states where performance is below minimum criteria while promoting
  overall excellence. To that end, states are expected to address performance that does not
  meet established performance levels for the SQSP measurement period.

  Corrective Action Plans (CAPs) are expected whenever a state’s performance is below
  established performance levels for the SQSP measurement period. The measurement
  period for the FY 2025 SQSP is April 1, 2023 – March 31, 2024, unless otherwise
  indicated (see Attachment I).



C. UI Performance Criteria

   Attachment I lists the Core Measures, Secretary’s Standards, and UI Programs, and the
   established performance levels where CAPs and/or Narratives may be expected if annual
   performance is below these established performance levels for the measurement period.

   i. Core Measures. Performance below the accepted level of performance (ALP) for
      Core Measures are expected to be addressed in a CAP unless otherwise indicated.

      Additional instructions for Core Measures are as follows:

      •   The Detection of Overpayments Measure. This measure is the percentage of
          detectable/recoverable overpayments estimated by the Benefit Accuracy
          Measurement (BAM) survey that was established for recovery through regular UI
          Benefit Payment Control (BPC) program operations. Any state reporting an
          overpayment detection rate below 50 percent is expected to address the deficiency
          in a CAP. In addition, because most states cannot cost-effectively detect and
          establish more than 90 percent of estimated overpayments, an upper limit of 95
          percent has been established for monitoring purposes. If an overpayment
          detection rate is above 95 percent and is found to be the result of improper
          administration of BAM or BPC activities or misreporting of data on the ETA 227
          (Overpayment Detection and Recovery Activities) report, the state is expected to
          submit a CAP (for BAM/Overpayment Detection or BPC/Overpayment Detection
          or address reporting 227 issues). (See UIPL No. 14-05, Change 1, Section 5.c.)
          The state should develop the CAP to ensure that the state is producing valid data
          for the Overpayment Detection Measure. The performance period for the BPC
          component is the three-year period ending March 31, 2024; the performance
          period for the BAM component is the three-year period ending September 30,
          2023.

      •   Effective Audit Measure. The Effective Audit Measure, as noted in UIPL No.
          03-11, is a blended measure of the following four factors: 1) Percentage of
          Contributory Employers Audited Annually; 2) Percentage of Total Wage Changed
          as a Result of Audit; 3) Percentage of Total Wages Audited; and 4) Average
          Number of Misclassifications Detected Per Audit. Each of the four factors has a
          minimum standard score that states are expected to meet to pass the Effective
          Audit Measure, as well as an overall combined score that is expected to be
          achieved. The measure also instructs each state to direct additional emphasis to
          the factor(s) that state personnel deem important to the state. An additional two
          points must be earned among any of the four factors to attain the overall passing
          score of at least 7.0. A CAP is expected for states that do not meet the measure
          based on calendar year 2023 data.

      •   Improper Payments Measure. The Improper Payments Measure is defined as UC
          overpaid plus UC underpaid divided by the total amount of UC paid. It is based
          on estimates from the results of the BAM survey of paid UC claims in the State
          UI, Unemployment Compensation for Federal Employees, and Unemployment

    Compensation for Ex-Servicemembers programs. The Payment Integrity
    Information Act (PIIA) of 2019, codified in 31 U.S.C. 3351 et seq., requires
    agencies to examine the risk of erroneous payments in all programs and activities
    they administer. PIIA also requires Federal programs to report an annual improper
    payment rate and include all identified improper payments in the reported
    estimate, regardless of whether the improper payment in question has been or is
    being recovered (see UIPL No. 09-13, Change 1 for ETA’s approved improper
    payment rate computation methodology). Corrective actions and IAP root causes
    for FY 2025 are based on ETA’s approved computation methodology. PIIA, in 31
    U.S.C. 3351(4), defines the term “improper payment” as:

         (A) …any payment that should not have been made or that was made in an
             incorrect amount, including an overpayment or underpayment, under a
             statutory, contractual, administrative, or other legally applicable
             requirement; and

         (B) includes—(i) any payment to an ineligible recipient; (ii) any payment
             for an ineligible good or service; (iii) any duplicate payment; (iv) any
             payment for a good or service not received, except for those payments
             where authorized by law; and (v) any payment that does not account
             for credit for applicable discounts.

    In accordance with the PIIA, under the compliance requirements in 31 U.S.C.
    3351(2), an ALP of less than 10 percent has been established for the improper
    payment measure. States are expected to maintain an improper payment rate of
    less than 10 percent for covered UI programs. This ALP is applicable to the 2023
    PIIA performance period (July 1, 2022 to June 30, 2023). A state failing to meet
    the ALP for the 2023 PIIA performance period will be expected to develop a CAP
    as part of the FY 2025 SQSP.

•   UI Overpayment Recovery Measure. As explained in UIPL No. 09-13, the
    recovery rate is “the amount of improper overpayments recovered divided by the
    amount of improper overpayments identified.” The ALP for the recovery rate
    measure is 68 percent for the 2023 PIIA performance period. The Department will
    compute future recovery targets based on the most recent recovery and other
    performance data available.

    The performance period will be based on data from the ETA 227, Overpayment
    Detection and Recovery Activity (Regular), and ETA 227, Overpayment
    Detection and Recovery Activity (Emergency Unemployment Compensation)
    (EUC), for the PIIA 2023 performance period (July 1, 2022 to June 30, 2023).
    Pursuant to the UI Reports Handbook (ET Handbook No. 401, 5th edition), the
    June quarter ETA 227 reports are due August 1 each year. A state failing to meet
    the ALP for the 2023 PIIA performance period will be expected to develop a CAP
    as part of the FY 2025 SQSP.



 ii.   Secretary’s Standards

       A state experiencing performance below the criteria for the Secretary’s Standards
       established in regulation at 20 CFR Parts 640 and 650 is required to address the
       performance issues in a CAP. The Secretary’s Standards are listed in Attachment I.

iii.   UI Programs

       States must address the following UI Programs as described below:

       •   State Directory of New Hires (SDNH)/National Directory of New Hires
           (NDNH)

           State BAM operations that, based on the BAM Administrative Determination, are
           not compliant with the NDNH matching requirements in ET Handbook No. 395,
           5th Edition, chapter VI, UIPL No. 03-07, and UIPL No. 03-07, Change 1, are
           expected to be addressed in a CAP for FY 2025.

       •   Benefit Accuracy Measurement (BAM)

           State BAM operations or operational components that are not compliant with
           investigative and/or “methods and procedures” requirements established in ET
           Handbook No. 395, 5th Edition, and through findings established through ET
           Handbook No. 396, 4th Edition monitoring reviews (based on the annual
           determination letter issued on or before May 1, 2024), are expected to be
           addressed in a CAP. This includes paid and denied claim population variances
           outside established control limits.

       •   Tax Performance System (TPS)

           To ensure that UI tax operations are in compliance with Federal reporting and
           oversight requirements, a state’s failure to conduct one or more TPS sample
           reviews will be subject to a CAP. Additionally, a tax function that is not sampled
           will be included in the number of total failing functions as measured by Tax
           Quality Part A (no more than three tax functions may fail TPS review) and Part B
           (a tax function cannot fail for three consecutive years). Exceptions include
           universes that are too small to support a sample (“S”), an Experience Rate sample
           that was not scheduled for review during the performance year (“E”), or the
           granting of a temporary waiver by the RO (“W”). Program Review Findings
           Charts should be noted accordingly.

       •   Data Validation (DV)

           The deadline for submitting DV results is June 10, 2024. DV items that fail to
           pass validation, or were due but not submitted, are expected to be addressed in the
           state’s FY 2025 SQSP. Non-submitted items also include failure to certify that the



          state instructions in the Module 3 for Benefits and Tax are up-to-date during the
          April 1 – June 10, 2024, certification window.

          Any DV items due for Validation Year 2024 that did not pass or were not
          submitted by the June 10, 2024, deadline are expected to be addressed in a CAP
          for FY 2025.

          ROs will monitor states every three years on cycles coinciding with the Data
          Validation Years. ROs will assess the accuracy of the states’ DV results
          considered passing or not due as of the time of the monitoring review to verify
          that the states are properly implementing the DV program. DV items submitted as
          passing but which a monitoring review determined to have failed also are
          expected to be addressed in the SQSP. All subsequent SQSP cycles will address
          items changed from pass to fail in the previous year’s monitoring review.

iv.   Other UI Performance

      States are expected to address the following performance deficiencies in the SQSP
      State Plan Narrative, unless otherwise indicated.

      •   Failure to meet reporting requirements for Federally-required reports.

      •   Invalid recording of the Issue Detection Date (IDD) and Determination Date
          (DD). The validity of the UI Performs nonmonetary determination timeliness
          measure depends on the accuracy of the state’s IDD and DD data. IDD and DD
          data are considered accurate if dates were correct in at least 95 percent of the
          nonmonetary determinations evaluated in the quarterly quality samples (obtained
          from the ETA 9056 report for the measurement period (see Attachment I). Since
          the accuracy of IDD and DD data is based on sample results, sampling variation
          will be taken into account in setting the percentage below which a state’s data will
          be considered inaccurate. States with invalid IDD or DD data are expected to
          address the steps they will take to record the IDD and DD correctly in the SQSP
          Narrative.

v.    Future Performance Requirements

      UIPL No. 07-21, published in FY 2021, announced, for states with RESEA programs,
      a new reemployment core measure: Reemployment rate in the 2nd Quarter after
      Program Exit for RESEA Participants. This core measure is designed to focus on
      RESEA program performance, given that the RESEA program is now permanently
      authorized within the context of the broader workforce development system. This
      measure aligns with the Workforce Innovation and Opportunity Act (WIOA) primary
      indicators of performance and will utilize data that states already report for the
      Employment Service program, and will assist ETA and states in assessing state
      performance related to the employment outcomes of RESEA participants.




      Performance data for FY 2020 and FY 2021 will be used to review state performance
      trends and to establish baseline state RESEA performance. States that do not meet
      performance criteria for both of these performance periods will not be expected to
      submit CAPs for FY 2025 SQSPs.

      UIPL No. 07-21 also announced two new program performance measures that are
      meant to assist states in managing reemployment performance, but these measures are
      not core measures and do not have associated ALPs.

D. UI Program Integrity and the IAP

   The purpose of the IAP is for the state to provide a comprehensive and detailed plan
   outlining the agency's UI integrity and antifraud strategies. States will use the IAP
   template (Word document) to develop their FY 2025 IAPs. The template provides states
   with a format that is conducive for developing a comprehensive, detailed, and actionable
   IAP, and offers flexibility to clearly articulate state integrity plans and antifraud
   strategies. States are expected to report their planned actions and activities to prevent,
   detect, reduce, and recover fraudulent and other UI improper payments in their IAPs,
   which are submitted each year as part of the annual SQSP submission.

   A critical part of fraud risk management includes evaluating outcomes using a risk-based
   approach and adapting activities to improve fraud risk management strategies. To
   effectively manage fraud risks, each state should develop and document an antifraud
   strategy that describes the state’s approach for addressing fraud risks.

   For FY 2025, ETA is highlighting the following specific topics that states must
   incorporate into the SQSP IAPs as part of the FY 2025 SQSP submission. States should
   use the IAP template as a guide to develop their IAPs and ensure all key IAP topics
   (outlined below) are addressed.

   • (Topic #1:) – Ensuring UI program integrity by assessing and evaluating fraud risks,
     and implementing and maintaining an array of sufficient controls to effectively
     mitigate the likelihood and impact of fraud, and reducing improper payments:

      o    State actions to evaluate UI fraud risks and implement and maintain sufficient
           controls to effectively prevent fraud and reduce improper payments, including
           state progress in developing the state’s own state-specific antifraud strategy.

      o    State use of tools, services, strategies, process improvements, and/or procedural
           changes adopted by the state to combat fraud, verify identities, and enhance
           recovery efforts. States must identify which tools, solutions, and service
           provider(s) are used in the state’s fraud management operations including, but
           not limited to, the following areas: data analysis, risk-based identity (ID)
           verification, fraud prevention and detection, and cybersecurity.

      o    State use of UI Integrity Center resources, with a particular focus on state
           connection to the Integrity Data Hub (IDH) and use of its datasets to cross-match


        UC claims and aid in the prevention and detection of fraud and improper
        payments (see Training and Employment Notice (TEN) No. 24-21).

    o   State use of required and recommended integrity controls and overpayment
        recovery activities as outlined in UIPL No. 11-23, including any additional
        effective cross-matching and overpayment recovery activities and identified best
        practices.

    o   State use and employer participation in the State Information Data Exchange
        System (SIDES) (see Section 5 of UIPL No. 19-16 and TEN No. 12-16).

•   (Topic #2) – State plans and actions to address the state's top three improper payment
    root causes in the PIIA 2023 performance period.

•   (Topic #3) – State coordination and collaboration with Department’s Office of
    Inspecter General (DOL-OIG) and other state and Federal law enforcement agencies
    to investigate and prosecute UI fraud and recover overpayments. The response should
    also include information on the state’s plans to continue providing all confidential UC
    information to DOL-OIG for purposes of both investigating fraud and performing
    audits.

•   (Topic #4) – State plans to strengthen program integrity in UI tax operations,
    including current activities and plans to identify and prevent worker misclassification,
    State Unemployment Tax Act Dumping, fictitious employer schemes, and
    development/use of effective employer audit strategies (i.e., use of remote audits).

•   (Topic #5) – State plans and actions to strengthen internal security and ensure that all
    appropriate internal controls and processes are in place and are adequate to assess
    internal risks and threats, ensure program integrity, and minimize program
    vulnerabilities (see UIPL No. 14-17).

•   (Topic #6) – State plans and actions to evaluate the effectiveness and equity of fraud
    prevention and detection, ID verification, and improper payment reduction activities.
    The state should include strategies to ensure that processes used to detect and prevent
    fraud are effective, and do not limit the ability for a legitimate claimant to apply for
    and, if eligible, receive UC. States implementing or using facial recognition
    technology in their ID proofing processes must also report findings from bias testing
    and provide updates on efforts to mitigate biases or barriers in this section of the IAP.

•   (Topic #7) – State plans and actions to mitigate negative consequences for victims of
    UI ID fraud, including ensuring simplified processes to remove the victim’s liability
    for overpayments resulting from ID fraud.

•   (Topic #8) – If the state has not provided complete and accurate overpayment
    reporting on the ETA 227 series of reports (Overpayment Detection and Recovery
    Activities), and the ETA 902P report (Pandemic Unemployment Assistance


        Activities), the state must provide information on plans for improvement, including
        timeframes and milestones, for addressing the issue and ensuring complete, accurate,
        and timely reporting in FY 2025.

    States are required to provide a six-month update to the IAP, covering the first two
    quarters of the FY (October – March) when submitting the SQSP quarterly update for the
    quarter ending March 31. The purpose of the six-month update is for a state to provide a
    progress report on the integrity and antifraud strategies outlined in the IAP. The update
    must include details on any new strategies, solutions, and/or activities; changes to
    existing strategies; planning or strategy delays and/or challenges in implementing the
    IAP; positive outcomes (e.g., progress toward the achievement of objectives); and
    identified successes.

    ETA will continue to provide technical assistance to states to support their integrity
    activities through guidance, webinars, individual state technical assistance, and in
    partnership with the many available resources to support states with strengthening UI
    program integrity (see Section 12 of this UIPL for UI Technical Assistance Resources).

E. Planning Requirements for FY 2025

  i.    SQSP Submittal Cycle

        The SQSP process provides a 24-month window for states to adequately plan and
        implement performance improvement efforts. The process provides for two types of
        submittals: a Formal two-year (Biennial) plan, and an Alternate Year plan.
        Descriptions of the Biennial and Alternate Year SQSP submittals, significant
        activities, and dates relating to the submittal and approval of the SQSP are outlined in
        the SQSP Handbook and this UIPL. This year (FY 2025), all states will submit a
        Biennial SQSP.

 ii.    SQSP Preparation

        States must use the Excel CAP Workbook to develop their CAPs for the SQSP
        submissions. States must also use the Excel CAP Workbook for reporting updates to
        specific CAP milestones and CAP performance each quarter. States must also use the
        IAP template to develop the IAP and provide IAP updates. The ROs will provide
        states with the Excel Workbook and IAP template with specific instructions relevant
        to this Biennial SQSP submittal.

 iii.   SQSP Assurances and Approval

        By signing the SQSP Signature Page, a state certifies that it will comply with the
        assurances listed in ET Handbook No. 336, 18th Edition, Change 4, and will institute
        plans or measures to comply with the requirements for each of the assurances.





       •   Assurance of Disaster Unemployment Assistance (DUA)

           Each state must assure that it will conduct annual training for DUA staff and
           develop and maintain a Standard Operating Procedures manual for DUA. States
           are encouraged to use the DUA training modules available on the NASWA
           learning platform at https://www.naswa.org/learning.

           Each state must:

       •   Indicate that it has conducted training and provide the date(s) of the training; and

       •   Indicate that it has developed and/or maintained DUA Standard Operating
           Procedures for use during a major disaster declaration.

           States may contact the RO for a copy of a DUA Standard Operating Procedure
           template. ROs will also obtain an initial copy from each state for the
           Department’s record. See TEN No. 13-21 for additional information.

F. Waiving Recovery of Overpayments, where Appropriate. As states are resolving
   backlogs, they may identify situations where individuals received benefits to which they
   were not entitled, and establish an overpayment in each such instance. As noted in UIPL
   No. 20-21, Change 1, seeking recovery of overpayments from individuals who did not
   commit fraud and were without fault in receiving the overpayment, especially in light of
   the economic effects of the pandemic, creates an extraordinary hardship on working
   families. The authority to waive recovery of overpayments under the regular UI program
   is a matter of state law. When establishing overpayments under the temporary
   Coronavirus Aid, Relief, and Economic Security (CARES) Act UI programs, the
   Department strongly encourages states to exercise the authority to waive recovery when
   both conditions set forth in the CARES Act, as amended, are satisfied: (1) payment was
   done without fault on the part of the individual; and (2) repayment would be contrary to
   equity and good conscience. States are reminded that to consider a waiver of the recovery
   of an overpayment, the state must first establish an overpayment, and under no
   circumstances may a state waive recovery activities for a fraudulent overpayment.

   Within the context of the CARES Act UI programs, states are permitted to use blanket
   waivers under the seven scenarios described in Attachment I to UIPL No. 20-21, Change

    1. These approved blanket waiver scenarios permit a state, under the limited authorized
   circumstances, to process the waiver of recovery for individual overpayments that do not
   require additional fact-finding or submission of individual requests. These scenarios also
   permit the state to process the waiver of recovery for multiple overpayments meeting one
   of the approved scenarios simultaneously based on a single set of facts. If overpayments
   covered by the seven approved scenarios were processed individually, it could result in
   the same amount of overpayments not being recovered (i.e., recovery still being waived),
   but at a greater cost and inefficiency to the state because of the workload generated from
   processing individual waivers. Overpayments occurring outside of the scope of the
   approved scenarios may still be considered for waiving repayment on an individual case-



   by-case basis to ensure the two conditions described in the preceding paragraph are
   satisfied.

G. Coordination with DOL-OIG. States are reminded of their obligation to report alleged
   or suspected UI fraud to the DOL-OIG as outlined in UIPL No. 04-17, Change 1. States
   must refer allegations which they reasonably believe constitute UC fraud, waste, abuse,
   mismanagement, or misconduct to the DOL-OIG. States are also required to disclose
   confidential UC information related to the CARES Act, as amended, to the DOL-OIG for
   the purpose of UC fraud investigations and audits for the entire pandemic relief period
   (see UIPL No. 04-17, Change 1). Additionally, TEN No. 05-22 reminded states of the
   DOL-OIG’s authority under the Inspector General Act and strongly encouraged states to
   comply with data requests made by DOL-OIG. Furthermore, as a condition of receiving
   funding announced in UIPL No. 22-21, participating states are required to disclose all
   confidential UC information to DOL-OIG for purposes of both investigating fraud and
   performing audits through weeks of unemployment ending before December 31, 2023.

   States are also strongly encouraged to report suspected UI fraud to IDH by creating fraud
   alerts and submitting all suspicious claims data for cross-matching. Providing suspicious
   claims data to IDH gives each state the ability to analyze state claims data against known
   suspicious activity in other states, which offers a mechanism to quickly identify potential
   fraud across the UI system. States needing assistance with IDH, or to learn more about
   how IDH can help states’ fraud prevention and detection efforts, can reach out to the IDH
   Team at [email protected] for more information.

H. WIOA Combined State Plans. WIOA provides the option for states to submit a
   Combined State Plan that includes program plans for mandatory one-stop partners and
   other programs. Given that the UI program is a mandatory one-stop partner under WIOA,
   states have the option of including the UI program as part of the Combined State Plan.
   However, each state must participate in the UI Performs SQSP process whether or not the
   state decides to include the UI program as part of its Combined State Plan.

   If a state chooses to submit a WIOA Combined State Plans with UI as a required partner,
   the state must incorporate SQSP into the Combined State Plan via the WIOA State Plan
   Portal at https://wioaplans.ed.gov/. Those states must incorporate only the allowable
   documents of the FY 2025 SQSP into the Combined State Plan upon ETA’s approval of
   the SQSP, but no later than October 31, 2024.

   Because of the sensitive nature of some SQSP documents, only the following SQSP
   documents are allowed to be included in the WIOA Combined State Plan:

   •   Transmittal Letter
   •   A list of CAPs (the Biennial SQSP Overview Page from the SQSP CAPs and
       Quarterly Reporting Workbook)
   •   Budget Worksheets/Forms
   •   Organization Chart
   •   SQSP Signature Page



I. UI Technical Assistance Resources. The following resources provide states with
   information and support for UI program activities.

   •   ETA’s Regional Offices. ETA’s ROs are available to provide states with ongoing
       technical assistance regarding UI program administration and operations, integrity
       strategies, and to connect states with resources supported and funded by the
       Department. States are encouraged to work closely with ROs in developing the SQSP
       and IAP, and any needed CAPS.

   •   UI Integrity Center. In FY 2012, ETA created the UI Integrity Center of Excellence
       (UI Integrity Center) to support the needs of the fifty-three State Workforce Agencies
       in implementing strategies to ensure program integrity to prevent, detect, and recover
       improper payments, and to reduce fraud in the UI programs. The NASWA Center for
       Employment Security Education and Research, Inc. (CESER) operates the UI
       Integrity Center through a cooperative agreement with ETA.

   •   Office of Unemployment Insurance Modernization (OUIM). OUIM, located
       within the Department’s Office of the Secretary, has developed resources to assist
       states with equitable practices that reduce claimant errors which contribute to
       improper payments. States can visit OUIM’s reference site where promising practices
       and reference materials related to IT modernization and updates from Department-
       sponsored engagements are housed. The reference site is located at
       https://www.dol.gov/agencies/eta/ui-modernization.

   •   UI Information Technology Support Center (UI ITSC). ETA created UI ITSC in
       1994 through a cooperative agreement with the State of Maryland to develop products
       and services and to support state UI agencies in the use of IT for efficient
       administration of the UI program. Since 2009, NASWA CESER has operated the UI
       ITSC. The UI ITSC’s activities involve providing information, technical assistance,
       products, and services to states or state consortia in support of the modernization of
       IT systems used to administer the UI program. For more information on UI ITSC visit
       http://www.itsc.org.

   •   DOL-OIG. ETA recommends states build a strong partnership with DOL-OIG.
       States are encouraged to collaborate with their respective ROs and DOL-OIG to share
       fraud trends and analysis, discuss recommendations and effective strategies for
       responding to emerging fraud schemes, receive updates on prosecution efforts, and
       facilitate sharing of UI fraud and integrity-related challenges and best practices
       among states.

J. Funding Period. The Department’s proposed FY 2025 appropriation language for State
   UI and Employment Service Operations allows for obligation of UI allocations by states
   through December 31, 2025, with 90 additional days to liquidate the obligations and
   complete the expenditure of funds. Under this proposed language (which mirrors the
   language of recent-year appropriation acts), states would be able to obligate FY 2025 UI
   funds through September 30, 2027, if such obligations are for automation, competitive


       grants awarded to states for improved operations, or for conducting in-person
       reemployment and eligibility assessments and improper payment reviews, and providing
       reemployment services and referrals to training, as appropriate. The grant management
       resources and information including grant terms and conditions are available at
       https://www.doleta.gov/grants/resources.cfm. Please note that FY 2025 grant terms and
       conditions are not available at this time. This information will be provided through ROs
       at a later date and also posted at the webpage indicated above.

   K. Data Availability. ROs will provide states with data showing their performance
      measured against the Core Measures, Secretary’s Standards, and other information
      relevant to the SQSP (e.g., reporting deficiencies).

   L. SQSP Submittal Deadlines. Each RO will set a date and inform states of the deadline to
      submit their SQSPs for FY 2025.

   M. Electronic Submission of the SQSP. States must submit the SQSPs electronically and
      should contact their respective RO SQSP Coordinators before submittal to coordinate
      specific details. Standard forms required as part of the budget reporting process (Chapter II
      of ET Handbook No. 336, 18th Edition, Change 4) are available in PDF and may be
      downloaded from the OMB website at: grants.gov/forms/forms-repository/sf-424-family.

       States may submit the SQSP Signature Page electronically if the state law permits. States
       that do not submit the signature page electronically (which includes by fax or scan) must
       submit the signature page by mail by the deadline set by the RO.

5. Inquiries. Please direct inquiries to the appropriate ETA RO.

6. References.

   •   Social Security Act (SSA), sections 303(a)(1) and 306 (42 U.S.C. 503(a)(1) and 506);
   •   Government Performance and Results Act (GPRA) of 1993, Pub. L. 103-62, as amended
       by GPRA Modernization Act of 2010, Pub. L. 111-352;
   •   Payment Integrity Information Act of 2019 (PIIA), Pub. L. 116-117;
   •   Workforce Innovation and Opportunity Act (WIOA), Pub. L. 113-128, 29 USC 3101 note
       and Title I;
   •   Wagner-Peyser Act, 29 U.S.C. Sec. 49 et seq., as amended by Title III of WIOA;
   •   Trade Act of 1974, Pub. L. 93-618, as amended;
   •   Bipartisan Budget Act of 2013, Pub. L. 113-67;
   •   Bipartisan Budget Act of 2018, Pub. L. 115-123;
   •   Departments of Labor, Health and Human Services, and Education, and Related Agencies
       Appropriations Act, 2020, Pub. L. 116-94;
   •   Consolidated Appropriations Act, 2021, including Division N, Title II, Subtitle A, the
       Continued Assistance for Unemployed Workers Act of 2020;
   •   American Rescue Plan Act of 2021, Pub. L. 117-2;
   •   Executive Order 13985 of January 20, 2021; 86 FR 7009, page 7009-7013;



•   20 CFR Parts 601, 640, 650, 652, and 660;
•   2 CFR Part 200, Subpart F, The Uniform Administrative Requirements, Cost Principles,
    and Audit Requirements for Federal Awards at 2 CFR Parts 200 and 2900;
•   Appendix C to Office of Management and Budget (OMB) Circular A123, Requirements
    for Payment Integrity Improvement;
•   UIPL No. 08-24, Fiscal Year (FY) 2024 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment
    (RESEA) Grants, issued February 21, 2024,
    https://www.dol.gov/agencies/eta/advisories/uipl-08-24;
•   UIPL No. 08-24, Change 1, Corrected Attachment I to Unemployment Insurance
    Program Letter (UIPL) No. 08-24, issued March 22, 2024,
    https://www.dol.gov/agencies/eta/advisories/uipl-08-24-change-1;
•   UIPL No. 01-24, Equitable Access in the Unemployment Insurance (UI) Program, issued
    November 8, 2023, https://www.dol.gov/agencies/eta/advisories/uipl-01-24;
•   UIPL No. 11-23, Change 1, Announcing an Extension of Period of Time that Funding
    will be Available to Cover Transaction Costs and Announcing the Establishment of a
    Deadline for States to Enter into Data Sharing Agreements (DSAs) for the National
    Identity Verification Offering (NIDVO) Established in Unemployment Insurance
    Program Letter (UIPL) No. 11-23, issued April 29, 2024,
    https://www.dol.gov/agencies/eta/advisories/uipl-11-23-change-1;
•   UIPL No. 11-23, Announcement of Grant Opportunities and National Identity (ID)
    Verification Offering under the American Rescue Plan Act (ARPA), issued July 13, 2023,
    https://www.dol.gov/agencies/eta/advisories/uipl-11-23;
•   UIPL No. 02-23, Fiscal Year (FY) 2023 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment
    (RESEA) Grants, issued February 23, 2023,
    https://www.dol.gov/agencies/eta/advisories/uipl-no-02-23;
•   UIPL No. 10-22, Fiscal Year (FY) 2022 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment
    (RESEA) Grants, issued January 21, 2022,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9998;
•   UIPL No. 02-22, Change 2, Extension of Time for States to Express Interest in the Grant
    Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No. 02-22,
    to Support States Following a Consultative Assessment for Fraud Detection and
    Prevention, Promoting Equitable Access, and Ensuring the Timely Payment of Benefits,
    including Backlog Reduction, for all Unemployment Compensation (UC) Programs,
    issued September 19, 2022, https://www.dol.gov/agencies/eta/advisories/uipl-02-22-
    change-2;
•   UIPL No. 02-22, Change 1, Extension of Time for States to Express Interest in the Grant
    Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No. 2-22 to
    Support States Following a Consultative Assessment for Fraud Detection and Prevention,
    Promoting Equitable Access, and Ensuring the Timely Payment of Benefits, including
    Backlog Reduction, for all Unemployment Compensation (UC) Programs, issued
    February 16, 2022, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8539;




•   UIPL No. 02-22, Grant Opportunity to Support States Following a Consultative
    Assessment for Fraud Detection and Prevention, Promoting Equitable Access, and
    Ensuring the Timely Payment of Benefits, including Backlog Reduction, for all
    Unemployment Compensation (UC) Programs, issued November 2, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6683;
•   UIPL No. 01-22, Announcing the Availability of an Incarceration Data Exchange and
    Instructions to Access the Data Exchange between the Unemployment Insurance (UI)
    Interstate Connection Network (ICON) and the Social Security Administration (SSA)
    Prisoner Update Processing System (PUPS), issued October 29, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4115;
•   UIPL No. 23-21, Grant Opportunity for Promoting Equitable Access to Unemployment
    Compensation (UC) Programs, issued August 17, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7400;
•   UIPL No. 22-21, Change 2, Additional American Rescue Plan Act (ARPA) Funding and
    Support for States to Strengthen Unemployment Insurance (UI) Program Integrity,
    including Identity (ID) Verification, Fraud Prevention and Detection, and Overpayment
    Recovery Efforts in All Unemployment Compensation (UC) Programs and Required and
    Strongly Recommended Strategies, Tools, and Services for UI Fraud Risk Mitigation and
    Improper Payment Reduction, issued April 27, 2023,
    https://www.dol.gov/agencies/eta/advisories/uipl-22-21-change-2;
    https://www.dol.gov/agencies/eta/advisories/uipl-22-21-change-2
•   UIPL No. 22-21, Grant Opportunity to Support States with Fraud Detection and
    Prevention, Including Identity Verification and Overpayment Recovery Activities, in All
    Unemployment Compensation (UC) Programs, issued August 11, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?docn=4240;
•   UIPL No. 20-21, Change 1, Additional State Instructions for Processing Waivers of
    Recovery of Overpayments under the Coronavirus Aid, Relief, and Economic Security
    (CARES) Act, as Amended, issued February 7, 2022,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8527;
•   UIPL No. 20-21, State Instructions for Assessing Fraud Penalties and Processing
    Overpayment Waivers under the Coronavirus Aid, Relief, and Economic Security
    (CARES) Act, as Amended, issued May 5, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6830;
•   UIPL No. 13-21, Fiscal Year (FY) 2021 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessments
    (RESEA) Grants, issued January 19, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6686;
•   UIPL No. 07-21, Performance Measures for Reemployment Services and Eligibility
    Assessments (RESEA) and Unemployment Insurance (UI) participants, issued December
    17, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3854;
•   UIPL No. 28-20, Change 2, Additional Funding to Assist with Strengthening Fraud
    Detection and Prevention Efforts and the Recovery of Overpayments in the Pandemic
    Unemployment Assistance (PUA) and Pandemic Emergency Unemployment
    Compensation (PEUC) Programs, as well as Guidance on Processes for Combatting
    Identity Fraud, issued August 11, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?docn=7207;


•   UIPL No. 28-20, Change 1, Additional Funding for Identity Verification or Verification
    of Pandemic Unemployment Assistance (PUA) Claimants and Funding to Assist with
    Efforts to Prevent and Detect Fraud and Identity Theft as well as Recover Fraud
    Overpayments in the PUA and Pandemic Emergency Unemployment Compensation
    (PEUC) Programs, issued January 15, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9897;
•   UIPL No. 28-20, Addressing Fraud in the Unemployment Insurance (UI) System and
    Providing States with Funding to Assist with Efforts to Prevent and Detect Fraud and
    Identity Theft and Recover Fraud Overpayments in the Pandemic Unemployment
    Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC)
    Programs, issued August 31, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8044;
•   UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program and
    the UI Programs Authorized by the Coronavirus Aid, Relief, and Economic Security
    (CARES) Act of 2020 – Federal Pandemic Unemployment Compensation (FPUC),
    Pandemic Unemployment Assistance (PUA), and Pandemic Emergency Unemployment
    Compensation (PEUC) Programs, issued May 11, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4621;
•   UIPL No. 22-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 –
    Short-Time Compensation (STC) Program Grants, issued May 10, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6220;
•   UIPL No. 09-20, Unemployment Insurance (UI) State Quality Service Plan (SQSP)
    Submittal Schedule, issued February 6, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7801;
•   UIPL No. 08-20, Fiscal Year (FY) 2020 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessments
    (RESEA) Grants, issued January 30, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4214;
•   UIPL No. 13-19, National Directory of New Hires (NDNH) and State Directory of New
    Hires (SDNH) Guidance and Best Practices, issued June 7, 2019,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5373;
•   UIPL No. 07-19, Fiscal Year (FY) 2019 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment
    (RESEA) Grants, issued January 11, 2019,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8397;
•   UIPL No. 18-17, Unemployment Insurance Benefits Operations Self-Assessment Tool,
    issued July 28, 2017, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9282;
•   UIPL No. 14-17, States' Responsibilities for Internal Security in the Unemployment
    Insurance Program, issued March 23, 2017,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5496;
•   UIPL No. 04-17, Change 1, Requirement for States to Refer Allegations of
    Unemployment Compensation (UC) Fraud, Waste, Abuse, Mismanagement, or
    Misconduct to the Department of Labor's (Department) Office of Inspector General's
    (DOL-OIG) and to Disclose Information Related to the Coronavirus Aid, Relief, and
    Economic Security (CARES) Act to DOL-OIG for Purposes of UC Fraud Investigation



    and Audits, issued August 3, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5817;
•   UIPL No. 03-17, Change 1, Fiscal Year (FY) 2017 Unemployment Insurance (UI)
    Reemployment Services and Eligibility Assessment (RESEA) Grants, issued September
    22, 2017, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6557;
•   UIPL No. 03-17, Fiscal Year (FY)2017 Unemployment Insurance (UI) Reemployment
    Services and Eligibility Assessment (RESEA) Grant, issued December 8, 2016,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5218;
•   UIPL No. 19-16, Unemployment Insurance (UI) Supplemental Funding Opportunity for
    Improved Operations, issued August 2, 2016,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6982;
•   UIPL No. 17-16, Reengineering Unemployment Insurance (UI) Benefits Program
    Accountability Process: High Priority Designation of States with Sustained Poor
    Performance, issued July 13, 2016,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3910;
•   UIPL No. 02-16, Change 1, State Responsibilities for Ensuring Access to Unemployment
    Insurance Benefits, Services, and Information, issued May 11, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5491;
•   UIPL No. 02-16, State Responsibilities for Ensuring Access to Unemployment Insurance
    Benefits, issued October 1, 2015,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4233;
•   UIPL No. 01-16, Change 1, Federal Requirements to Protect Claimant Rights in State
    Unemployment Compensation Overpayment Prevention and Recovery Procedures –
    Questions and Answers, issued January 13, 2017,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7706;
•   UIPL No. 01-16, Federal Requirements to Protect Individual Rights in State
    Unemployment Compensation Overpayment Prevention and Recovery Procedures, issued
    October 1, 2015, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5763;
•   UIPL No. 17-14, Revised Employment and Training (ET) Handbook No. 336, 18th
    Edition: “Unemployment Insurance (UI) State Quality Service Plan (SQSP) Planning
    and Reporting Guidelines”, issued July 7, 2014,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9690;
•   UIPL No, 09-13, Change 1, Integrity Performance Measure for Unemployment
    Insurance, issued January 27, 2015,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7422;
•   UIPL No. 09-13, Integrity Performance Measures for Unemployment Insurance (UI),
    issued January 29, 2013, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8922;
•   UIPL No. 05-13, Work Search and Overpayment Offset Provisions Added to Permanent
    Federal Unemployment Compensation Law by Title II, Subtitle A of the Middle Class Tax
    Relief and Job Creation Act of 2012, issued January 10, 2013,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3698;
•   UIPL No. 08-12, Change 1, Consolidation of the Employment and Training
    Administration (ETA) 9000 and ETA 227 Reports, issued July 27, 2015,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9079;




•   UIPL No. 08-12, Consolidation of the Employment and Training Administration (ETA)
    9000 and ETA 227 Reports, issued January 11, 2012,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3311;
•   UIPL No. 03-11, Implementation of the Effective Audit Measure, issued December 30,
    2010, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2971;
•   UIPL No. 22-10, Selecting and Monitoring At-Risk States for Continuous Improvement
    and Compliance with First Payment Timeliness and First Level Appeals Promptness,
    issued April 23, 2010, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2890;
•   UIPL No. 03-07, Change 1, Use of National Directory of New Hires (NDNH) in
    Unemployment Insurance (UI) Benefit Accuracy Measurement (BAM) Audits, issued
    February 27, 2008, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2597;
•   UIPL No. 03-07, Use of National Directory of New Hires (NDNH) in Unemployment
    Insurance (UI) Benefit Accuracy Measurement (BAM) Audits, issued October 31, 2006,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2280;
•   UIPL No. 22-05, Change 2, Unemployment Insurance Data Validation (UI DV) Program
    Activities during Validation Years (VY) 2008 and Beyond, issued March 14, 2008,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2611;
•   UIPL No. 22-05, Change 1, Unemployment Insurance Data Validation (UI DV) Program
    Activities During Validation Years (VY) 2007 and 2008 and Policy Clarification, issued
    July 21, 2006, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2245;
•   UIPL No. 22-05, Unemployment Insurance Data Validation (UI DV) Program Software
    and Policy Guidance, issued April 28, 2005,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2074;
•   UIPL No. 14-05, Change 3, Acceptable Levels of Performance (ALP) Criteria for
    Appeals Case Aging Measures and Nonmonetary Determination Quality Review, issued
    April 16, 2008, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2625;
•   UIPL No. 14-05, Change 2, Performance Criteria for Appeals Case Aging Measures and
    the Starting Date for Measuring Nonmonetary Determinations Time Lapse, issued
    December 13, 2006, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2287;
•   UIPL No. 14-05, Change 1, Performance Criterion for the Overpayment Detection
    Measure; Clarification of Appeals Timeliness Measures; and Implementation of Tax
    Quality Measure Corrective Action Plans (CAPs), issued October 12, 2005,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2157;
•   UIPL No. 14-05, Changes to UI Performs, issued February 18, 2005,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=1683;
•   TEGL No. 11-23, Fiscal Year (FY) 2024 Funding Allotments and Operating Guidance
    for Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment
    (RESEA) Grants, issued February 21, 2024,
    https://www.dol.gov/agencies/eta/advisories/tegl-11-23;
•   TEGL No. 11-23, Change 1, Corrected Attachment I to Training and Employment
    Guidance Letter (TEGL) No. 11-23, issued March 22, 2024,
    https://www.dol.gov/agencies/eta/advisories/tegl-11-23-change-1;
•   TEGL No. 08-22, Fiscal Year (FY) 2023 Funding Allotments and Operating Guidance
    for Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment



    (RESEA) Grants, issued February 23, 2023,
    https://www.dol.gov/agencies/eta/advisories/tegl-08-22;
•   TEGL No. 05-21, Fiscal Year (FY) 2022 Funding Allotments and Operating Guidance
    for Unemployment Insurance (UI) Reemployment Services and Eligibility Assessment
    (RESEA) Grants, issued January 21, 2022,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3134;
•   TEN No. 28-23, Announcement of a New Data Sharing Partnership Between the U.S.
    Department of Treasury’s (Treasury) Bureau of the Fiscal Service (Fiscal Service) and
    the National Association of State Workforce Agencies’ (NASWA) Unemployment
    Insurance (UI) Integrity Center to provide State UI Agencies Access to Do Not Pay
    Working System (DNP) Data Sources and Services through the UI Integrity Data Hub
    (IDH), issued May 2, 2024, https://www.dol.gov/agencies/eta/advisories/ten-28-23;
•   TEN No. 06-23, Announcing “Fundamentals of Equitable Access in Unemployment
    Insurance (UI)” Online Training, issued September 1, 2023,
    https://www.dol.gov/agencies/eta/advisories/ten-06-23;
•   TEN No. 26-22, Availability of the Unemployment Insurance (UI) Equitable Access
    Toolkit, issued May 12, 2023, https://www.dol.gov/agencies/eta/advisories/ten-26-22;
•   TEN No. 05-22, Authority of the U.S. Department of Labor’s (Department) Office of
    Inspector General (DOL-OIG) to Receive Confidential Unemployment Compensation
    (UC) Data, issued September 15, 2022,
    https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-05-22;
•   TEN No. 24-21, Encouragement for States to Use the Integrity Data Hub (IDH)
    available through the Unemployment Insurance (UI) Integrity Center, issued May 5,
    2022, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8412;
•   TEN No. 15-21, Announcing the National Association of State Workforce Agencies
    (NASWA) Unemployment Insurance (UI) Integrity Center’s Behavioral Insights Toolkit,
    issued November 17, 2021, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6799;
•   TEN No. 13-21, State Quality Service Plan Assurances Required for Disaster
    Unemployment Assistance, issued October 19, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5710;
•   TEN No. 17-19, Model Unemployment Insurance State Work Search Legislation, issued
    February 10, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4227;
•   TEN No. 12-16, Unemployment Insurance (UI) State Information Data Exchange System
    (SIDES), issued September 27, 2016,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8026;
•   TEN No. 03-15, Reengineering Unemployment Insurance (UI) Benefits Program
    Accountability Processes: Update on Implementation Progress and State Impacts, issued
    July 27, 2015, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6837;
•   TEN No. 08-14, Reengineering Unemployment Insurance (UI) Benefits Program
    Accountability Processes, issued September 2, 2014,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4692;
•   ET Handbook No. 336, Unemployment Insurance (UI) State Quality Service Plan (SQSP)
    Planning and Reporting Guidelines, 18th Edition, Change 4 (March 2019), Employment
    and Training (ET) Handbook No. 336, 18th Edition, Change 4;




   •   ET Handbook No. 361, Unemployment Insurance Data Validation Handbook, Tax
       (October 2022), UNEMPLOYMENT INSURANCE (doleta.gov);
   •   ET Handbook No. 395, Benefit Accuracy Measurement State Operations Handbook, 5th
       Edition (November 2009), Employment and Training (ET) Handbook No. 395, 5th
       Edition;
   •   ET Handbook No. 396, Unemployment Insurance Benefit Accuracy Measurement
       Monitoring Handbook, 4th Edition (November 2009), Employment and Training (ET)
       Handbook No. 396, 4th Edition; and
   •   ET Handbook No. 401, 5th Edition, UI Report Handbook No. 401 (July 2017),
       Employment and Training (ET) Handbook No. 401, 5th Edition.

7. Attachments.

   •   Attachment I: Measures/Programs to be Addressed in the Fiscal Year (FY) 2025 State
       Quality Service Plan (SQSP)

   •   Attachment II: Additional Information and Resources to Rebuild and Improve Program
       Performance and Develop High Quality Customer Services and Experiences, including
       Implementing ARPA-funded Projects

   •   Attachment III: Additional Information and Resources to Develop a Multi-layered
       Approach to Addressing Fraud, Reducing Improper Payments and Recovering
       Established Overpayments

   •   Attachment IV: Additional Information and Resources to Ensure Equitable Access to the
       UI Program

   •   Attachment V: Additional Information and Resources to Strengthen Reemployment
       and Connections to Suitable Work

   •   Attachment VI: Additional Information and Resources to Ensure Accurate and Complete
       Reporting of ETA Required Reports





                                                                                             Attachment I

                       Measures/Programs to be Addressed in the Fiscal Year (FY) 2025
                                     State Quality Service Plan (SQSP)


                                                                                                 FY 2025
       Core Measures                  Measurement Period                   Criteria
                                                                                               Requirement

First Payment Promptness           Apr 1, 2023 – Mar 31, 2024                87%                   CAP
Nonmonetary Determination          Apr 1, 2023 – Mar 31, 2024              80%
                                                                                                   CAP
Time Lapse                                                            (combined score)
Nonmonetary Determination          Apr 1, 2023 – Mar 31, 2024
                                                                             75%                   CAP
Quality – Nonseparations
Nonmonetary Determination          Apr 1, 2023 – Mar 31, 2024
                                                                             75%                   CAP
Quality – Separations
                                   BPC
                                                                             50%                   CAP
                                   Apr 1, 2020 – Mar 31, 2023

                                   BAM                                       95%                 Narrative
Detection of Overpayments
                                   Oct. 1, 2020 – Sep. 30, 2023
                                   If rate over 95% is a result of
                                   improper administration of                95%                   CAP
                                   BAM and/or BPC
Average Age of Pending Lower       Apr 1, 2023 – Mar 31, 2024
                                                                           30 days                 CAP
Authority Appeals
Average Age of Pending Higher Apr 1, 2023 – Mar 31, 2024
                                                                           40 days                 CAP
Authority Appeals
Lower Authority Appeals       Apr 1, 2023 – Mar 31, 2024
                                                                             80%                   CAP
Quality
New Employer Status
                              Jan 1, 2023 – Dec 31, 2023                     70%                   CAP
Determinations Time Lapse
                              Jan 1, 2023 – Dec 31, 2023              No more than 3 tax
                                                                     functions failing Tax
Tax Quality – Part A                                                                               CAP
                                                                     Performance System
                                                                        (TPS) in a year
                                   Jan 1, 2023 – Dec 31, 2023            The same tax
                                                                      function cannot fail
Tax Quality – Part B                                                                               CAP
                                                                       for 3 consecutive
                                                                              years
                                   Jan 1, 2023 – Dec 31, 2023          Score >7 and pass
Effective Audit Measure                                                                            CAP
                                                                          all 4 factors
                                   BAM batches 202227
Improper Payments Measure                                                   < 10%                  CAP
                                   through 202326
UI Overpayment Recovery
                                   Jul 1, 2022 – Jun 30, 2023                68%                   CAP
Measure





   Secretary’s Standards in                                                        FY 2025
                                      Measurement Period           Criteria      Requirement
          Regulation
First Payment Promptness           Apr 1, 2023 – Mar 31, 2024
                                                                     87%            CAP
(Intrastate 14/21 Days)
First Payment Promptness           Apr 1, 2023 – Mar 31, 2024
                                                                     93%            CAP
(Intrastate 35 Days)
First Payment Promptness           Apr 1, 2023 – Mar 31, 2024
                                                                     70%            CAP
(Interstate 14/21 Days)
First Payment Promptness           Apr 1, 2023 – Mar 31, 2024
                                                                     78%            CAP
(Interstate 35 Days)
Lower Authority Appeals (30        Apr 1, 2023 – Mar 31, 2024
                                                                     60%            CAP
Days)
Lower Authority Appeals (45        Apr 1, 2023 – Mar 31, 2024
                                                                     80%            CAP
Days)


                                                                                   FY 2025
      UI Programs, etc.               Measurement Period           Criteria      Requirement

                                                                   Results not
                                                                  submitted by      CAP
                                                                 June 10, 2024
Data Validation –Populations &
                               Apr 1, 2023 – Mar 31, 2024            Failing/
Modules (Benefits and Tax)
                                                                   incomplete
                                                                                    CAP
                                                                 submission by
                                                                 June 10, 2024
Compliance with NDNH
matching requirements for          Status as of March 31, 2024                      CAP
BAM
BAM operations not compliant
with investigative and/or
                                   Based on the annual
method and procedure
                                   determination letter issued                      CAP
requirements including
                                   on or before May 1, 2024
construction of valid samples
and sample populations
Incorrect recording of the Issue
Detection Date and/or              Apr 1, 2023 – Mar 31, 2024                     Narrative
Determination Date

TPS Sample Reviews                 Jan 1, 2023 – Dec 31, 2023                       CAP

Reporting Deficiencies                                                            Narrative

UI Program Integrity                                                                IAP





                                                                                            Attachment II


    Additional Information and Resources to Rebuild and Improve Program Performance
                                           and
                  Develop High Quality Customer Service and Experiences,
                      including Implementing ARPA-funded Projects


The unprecedented claims workload during the peak of the COVID-19 pandemic significantly impacted
states’ capacity to administer and operate their UI programs. Many states continue to struggle with
administrative and operational challenges resulting in performance and customer service issues in the
aftermath of the pandemic and its longer-term impact on the UI program. These challenges include but
are not limited to: changes in state program leadership; aging technology systems and/or implementing
new technology solutions; managing the loss of key subject matter expertise due to staff retirements and
turnover; hiring new staff, requiring ongoing staff training and increased supervision; loss of contracted
staff support; combatting an increase in fraud activities; and the need to improve overall program
performance.

Using funding made available under ARPA, the U.S. Department of Labor (Department) has awarded
about $783 million in grants to states to support UI modernization. These grants include funding to
implement state-specific recommendations produced by engagements from the Department’s “Tiger
Teams” (multi-disciplinary teams of experts established by the Department to analyze state UI systems
and process challenges) engagements; to pursue projects to enhance equitable access to the UI program;
and to support program integrity activities.

While significant progress has been made across the nation in improving timeliness of benefit payments,
states continue to struggle to meet the acceptable level of performance for timeliness in first payments,
adjudication and appeals. In preparation of the FY 2025 SQSP, states should examine strategies and
processes with the goal of quickly reducing the level of backlogs. States are encouraged to leverage
resources on the use of plain language (https://www.dol.gov/agencies/eta/ui-modernization/use-plain-
language) and behavioral insights (See TEN 15-21) to improve service delivery in the UI program. As
part of the FY 2025 SQSP process, states must, in the State Plan Narrative, describe their plans to
address any pending adjudication and appeals backlogs and to improve timely delivery of benefits. If a
state has an ARPA -funded grant that will impact processes to improve timeliness, the state is
encouraged to include the strategy(ies) it is pursuing using these grant funds in their FY 2025 SQSPs.

In developing their FY 2025 SQSPs, states are strongly encouraged to incorporate administrative
performance improvement strategies such as:

•   Projects funded through ARPA grants to improve equitable access to the UI program as detailed in
    UIPL No. 23-21 and leverage the strategies states are pursuing through the ARPA-funded grants to
    support implementation of state-specific Tiger Team recommendations (as detailed in UIPLs No.
    02-22 and 02-22, Change 2 and 11-23).

•   Conducting business process analyses in key areas to identify opportunities and recommendations
    for improving program operations, integrity, and performance, and implementing the
    recommendations.




•   Reviewing service delivery processes to ensure that current web-based, telephone-based, and other
    remote UI services provide and promote alternative mechanisms for individuals experiencing
    barriers to access, such as a disability or limited English proficiency (see UIPLs No. 01-24, 02-16
    and 02-16, Change 1).

•   Reviewing staff training strategies to support succession planning and ongoing staff development;
    and using online training modules available through the National Association of State Workforce
    Agencies’ (NASWA’s) learning management platform at https://www.naswa.org/learning.

•   Incorporating lessons learned from the COVID-19 pandemic, including the significant increase in
    UC claims and implementation of the temporary Coronavirus Aid, Relief, and Economic Security
    (CARES) Act UI programs, such as managing rapid changes in staffing, implementing call center
    expansions, and innovations to manage customer flow, and technology solutions to increase capacity
    and detect and prevent fraud and other improper payments.

•   Using technical assistance opportunities offered by ETA, the Department’s Office of Unemployment
    Insurance Modernization (OUIM), the Department’s Office of the Chief Information Officer
    (OCIO), UI Information Technology Support Center (ITSC), and the UI Integrity Center, as well as
    the many resources available through the UI Community of Practice (CoP) on WorkforceGPS at
    https://www.workforcegps.org/. Also, states are encouraged to review information and resources
    available on the Department’s UI Modernization resource page at
    https://www.dol.gov/agencies/eta/ui-modernization.





                                                                                          Attachment III



         Additional Information and Resources to Develop a Multi-layered Approach
                  to Addressing Fraud, Reducing Improper Payments and
                          Recovering Established Overpayments


To effectively combat fraud and improper payments in the UI program, states must use a variety of
controls and strategies. As a greater level of organized criminal elements have embarked on fraudulently
obtaining UC payments, no one approach is sufficient on its own to adequately prevent and detect fraud
and resulting improper payments. This Attachment offers an overview of various tools, strategies, and
process improvements that states should consider as part of their fraud and improper payment plan,
including enhanced and robust use of IDH and the SIDES.

Intercepting fraud as early as possible minimizes its impact on the UI system. Fraud detection operations
and procedures, coupled with using a risk-based approach to determine which claims are subject to
evidence-based ID verification, are critical to ensuring payment is made timely and only to individuals
entitled to receive UC. The Department continues to strongly encourage states to adopt multiple
strategies and techniques to validate UC claims; detect and share suspicious claim attributes among
states; consider a range of other available tools and resources when combating fraud; conducting risk-
based ID verification; and ensure program integrity. In addition, states should work collaboratively with
law enforcement agencies to assist in investigative efforts.

Overpayment recovery is critical to protect both state unemployment funds and Federal funds in the
Federal unemployment trust fund and must be given the same priority as overpayment prevention and
detection. ETA strongly encourages states to work proactively and collaboratively with Federal law
enforcement to streamline forfeiture and seizure efforts and with banks and financial institutions to
facilitate the rapid return/recovery of improperly paid UC.

ETA has provided states significant additional funding to support states with fraud prevention and
detection, ID verification, and overpayment recovery activities in the CARES Act UI programs and
regular UI programs (see UIPLs No. 28-20; 28-20, Change 1; 28-20, Change 2; 28-20, Change 4; 22-21;
02-22; and 11-23).

State Use of the National Identity Verification (ID) Offering

The UI program integrity focus includes ID verification; fraud prevention and detection; fraud risk
mitigation; improper payment reduction; the recovery of overpayments; the prevention of
underpayments; the timely and accurate payment of benefits; the timely and accurate establishment of
employer accounts, the timely and accurate collection of employer contributions, and ensuring equitable
access in all UI programs. ETA’s efforts to improve integrity in the UI programs include providing
guidance, technical assistance, resources, and funding to support states in combatting fraud;
strengthening ID verification; reducing improper payments; recovering overpayments; assessing and





addressing fraud risks; protecting victims of ID fraud; modernizing state UI systems; and evaluating data
to ensure effectiveness and equity in fraud prevention and detection efforts.

UIPL No. 11-23 announced an opportunity for states to participate in a National ID Verification
Offering (NIDVO) for both online and in-person ID verification services. That UIPL informed that over
the next two (2) years, subject to the availability of funding and necessary agreements being in place, the
Department will use ARPA funds to make available to states the government-operated ID verification
systems developed by the U.S. General Services Administration to verify identities online through
Login.gov, and by the U.S. Postal Service (USPS) to verify identities in person at participating USPS
retail locations nationwide. That UIPL also informed that the Department will cover the transaction
costs for ID verification for participating states during this process.

UIPL No. 11-23, Change 1 announced the expansion of the period that the Department will cover
transaction costs for ID verification for participating states for at least the later of two years after the
date the state deploys NIDVO, or two years after the date of issuance of UIPL No. 11-23, Change 1,
subject to both the availability of funding and all applicable agreements being executed. In addition, the
Department established a deadline for states regarding participation in NIDVO and having transaction
costs covered by the Department. States must have entered into a data sharing agreement with the
Department by June 28, 2024.

State Use of UI Integrity Center Resources

The UI Integrity Center, established and funded by the Department and operated by NASWA’s CESER,
assists states in their efforts to prevent, detect, and recover improper and fraudulent payments, and
improve UI program integrity by developing and promoting innovative program strategies. The UI
Integrity Center is a unique and extremely valuable resource available at no cost to states, and ETA
strongly encourages states to access its services and resources on a regular and ongoing basis to inform
and support state integrity strategies, strengthen fraud prevention and detection, enhance fraud
management operations, and improve overpayment recovery efforts. Below are important UI Integrity
Center services and resources that states should connect to and build into the IAP as part of the SQSP.

•   Integrity Data Hub – is a secure, robust, centralized, multi-state data system that allows participating
    states to cross-match, compare, and analyze UC claims data against a variety of datasets for
    enhanced prevention and detection of improper payments and fraud in UI programs (see TEN No.
    24-21). On May 2, 2024, the Department announced a new data sharing partnership between U.S.
    Treasury’s Bureau of Fiscal Service and NASWA’s UI Integrity Center to make Treasury’s Do Not
    Pay Working System data sources and services available to IDH to further support states in
    preventing and detecting improper payments and strengthening UI program integrity. See TEN No.
    28-23.

•   State Services – supports states in assessing business processes and provides recommendations for
    adoption of effective strategies for combatting fraud, reducing a state’s improper payment rate,
    enhancing overpayment recovery, and improving UI program integrity.





•   UI Integrity Knowledge Exchange Library (Library) – provides an online, searchable, knowledge-
    sharing platform with a repository containing thousands of UI technical resources to strengthen UI
    program integrity.

•   Behavioral Insights (BI) – is a UI Integrity Center effort that brings together practices from the field
    of behavioral science to promote UI integrity and reduce UI improper payments by applying
    observations about human behavior to strategies that can improve decision-making and program
    outcomes. NASWA’s BI Toolkit provides states with a collection of resources, articles, templates,
    and how-to information to help state UI agencies apply the learnings of BI to address program
    compliance challenges and improve UI program integrity (see TEN No. 15-21).

•   UI National Integrity Academy (Academy) – provides no-cost interrelated certificates that offer
    program integrity trainings for state staff via online, eLearning modules and Virtual Instructor Led
    Training. The Academy’s Learning Management System provides states with access to self-paced,
    on-demand training available at any time and a searchable online catalog with over 120 lessons
    available for state UI staff in the areas of Program Leadership, UI Operations Integrity, Fraud
    Investigations, Tax Integrity, Data Analysis, and Behavioral Insights.

Increased State and Employer Use of SIDES

State implementation and employers’ use of SIDES should be an integral part of a state’s integrity
strategy (see TEN No. 12-16 and information available at https://www.naswa.org/uisides). SIDES is
composed of Web Services for third-party administrators (TPAs) and large employers, and E-Response
for smaller employers. States should view SIDES as a critical part of UI integrity efforts and are
encouraged to connect to all SIDES exchanges and build SIDES into the IAP as part of the SQSP.

The SIDES Separation Information Exchange supports timely and accurate information from employers
and TPAs, which aids in reducing separation errors. As set out in UIPL No. 19-16, ETA has
expectations for the overall state usage of SIDES (Web Services and E-Response) with a goal for states
to receive employer responses through SIDES Web Services and SIDES E-Response for at least 50
percent of all UC initial claims processed, and, separately, a goal of at least 35 percent of all UC initial
claims processed through the SIDES E-Response. ETA encourages states to increase employer usage of
SIDES for separation exchanges by pursuing the following strategies:

•   Each state should strive to have all TPAs operating within the state to be live and using Web
    Services.

•   States that have been successful in obtaining greater employer use have SIDES as the default method
    of exchanging information, unless employers “opt-out” of this approach. These states have also used
    SIDES as the only electronic response system and have not used parallel/dual systems.

•   States that have been successful in obtaining greater employer use have a single sign-on for SIDES
    and the state’s employer portal. The NASWA SIDES Team can provide technical assistance to states
    on implementing a single sign-on option if the state is not currently using a single sign-on for
    employers.



•   States also should consider efforts to promote SIDES E-Response and to encourage employers who
    do not use TPAs to use SIDES, especially those employers who are frequent users of the UI
    program. In marketing SIDES, states are encouraged to use resources like the SIDES toolkit found at
    http://sidesitk.naswa.org/sides.

States should also consider strategies to address fictitious employer fraud schemes, such as early
detection through employer registration fraud risk scoring for newly established employer accounts, and
potentially looking at focused audits for blocked claims.

In addition, states should monitor their performance under the Effective Audit Measure to determine
whether they are effectively detecting and preventing worker misclassification (see UIPL No. 03-11).
States may deploy a wide array of strategies to address worker misclassification. ETA encourages states
to develop and implement strategies to address the misclassification of workers and to include those
strategies in the states’ SQSPs. ETA will continue to identify state “best-promising practices” in this
area and share them broadly.

States should consider using the other valuable SIDES exchanges, if they are not already doing so.
These additional exchanges include:

•   Monetary & Potential Charges Exchange – advises the employer/TPA of the wages used to calculate
    potential UC payable to the claimant and advises the employer of the potential charges applied to the
    employer’s state unemployment taxes if UC is paid, and the employer is found liable.

•   Additional Fact-Finding Exchange – permits electronic transmission of unique questions and
    responses between the state and the employer/TPA.

•   Determinations & Decisions Exchange – permits the state to electronically transmit a non-monetary
    determination or an appeals decision to an employer/TPA, and permits the employer/TPA to
    electronically respond, if necessary, with an appeal of a non-monetary determination or appeal of a
    lower-level appeal decision using the standard national format.

•   Earnings Verification Exchange – electronically sends wage verification requests to employers
    through a state-specific employer portal and is recommended if a state does not have an automated
    web-based system for requesting employers to verify earnings.

•   Benefit Charges Exchange – advises the employer/TPA of the amount of benefits charged to the
    employer for determining the employer’s state unemployment taxes based on the claimant’s
    eligibility and account liability.

Fraud Risks Profile

The Department has aligned its UI fraud risk management activities with the U.S. General
Accountability Office’s (GAO’s) Fraud Risk Framework by documenting a UI Fraud Risk Profile which
identifies inherent fraud risks and assesses the likelihood and impact of fraud risks to the UI program.
The Department determined the UI program has a “low” fraud risk tolerance, acknowledging that fraud
risks can be mitigated, but cannot be eliminated. ETA continues to evaluate the suitability of existing



fraud controls and assesses and updates its antifraud and improper payment reduction strategies through
a robust and dynamic UI Integrity Strategic Plan,1 which continuously evolves and includes innovative
strategies and antifraud controls to combat emerging fraud threats and address the highest residual risks
identified in the UI Fraud Risk Profile. ETA is also investing in developing new and enhancing existing
tools, datasets, and resources, and making them available to aid states in more quickly identifying
potential improper payments and fraud.

Since the UI program is a Federal-state partnership, which means both the Department and state UI
agencies are responsible for ensuring UI program integrity. Therefore, states should also evaluate UI
fraud risks and implement and maintain sufficient controls to effectively prevent fraud and reduce
improper payments. GAO’s Framework for Managing Fraud Risks in Federal Programs highlights the
key elements of an antifraud strategy.2 In developing an antifraud strategy, states should establish roles
and responsibilities of those involved in fraud risk management activities. The antifraud strategy should
describe existing fraud control activities as well as any new control activities a program may adopt to
address residual fraud risks.




    The public version of the UI Integrity Strategic Plan is found at https://oui.doleta.gov/unemploy/integrity_plan.asp.
 See A Framework for Managing Fraud Risks in Federal Programs at https://www.gao.gov/assets/gao-15-593sp.pdf, Table 4,
page 19.




                                                                                    Attachment IV


                       Additional Information and Resources to Ensure
                             Equitable Access to the UI Program



A top priority of the Department is ensuring equitable and meaningful access to the UI program.
Section 303(a)(1), SSA, includes a requirement that a state’s methods of administration include
insuring full payment of UC “when due." The Department interprets this to include a
requirement of equity so that individuals have sufficient access to the program so that eligibility
can be determined, and UC payments can be made, “when due.” Promoting equitable access in
state UI programs is also one of the enumerated purposes for which funding set out in Section
9032 of ARPA may be used.

On January 20, 2021, the President issued Executive Order (EO) 13985 concerning advancing
racial equity and support for underserved communities. This EO articulates the importance of
advancing equity for all, including people of color and others who have been historically
underserved, marginalized, and adversely affected by persistent poverty and inequality. This
includes, low wage workers, Black and Hispanic/Latino workers, individuals with disabilities,
and individuals with limited English proficiency. Advancing equity requires a systematic
approach to embedding fairness in decision-making processes and eliminating barriers to access.
Public programs must be designed to serve all individuals. For this reason, the Federal
Government should, consistent with applicable law, allocate resources to address the historic
failure to invest sufficiently, justly, and equally in underserved communities, as well as
individuals from those communities. State UI agencies must ensure that use of technologies and
systems for administering UI programs and providing services do not create barriers (e.g.,
procedural, technological, or informational) that may prevent individuals from accessing UC,
such as by denying a reasonable opportunity to establish eligibility.

In November 2023, ETA issued UIPL No. 01-24, which provides clarity around the
Department’s use of the terms “access” and “equitable access,” and further describes how
program integrity is impacted by efforts to ensure equitable access to the UI program. This UIPL
informs states of ways that equitable access can be evaluated and enhanced, including through
technical assistance and tools from various Department initiatives and state-based partnerships.
States are encouraged to examine any available claimant demographic data to help inform
strategies to enhance outreach and education about the UI program to underserved communities.
Each state should also explore strategies to improve the state’s UI program recipiency rate. In
addition, states should focus on UI functions and activities that ensure equitable access to these
programs. UIPLs No. 02-16 and 02-16, Change 1, outline the requirements that states must meet
to ensure access to the UI program, and ensure timely payments are made to eligible individuals.

States are encouraged to use the UI Equity Toolkit as a resource concerning equitable access to
the UI program. See TEN No. 26-22.





In September 2023, ETA announced the availability of the first online training module
concerning equitable access and the UI program. TEN No. 06-23 details the launch of the new
“Fundamentals of Equitable Access in UI” training lesson, which is self-paced and can be
accessed via NASWA’s learning management website (https://www.naswa.org/learning). ETA,
in collaboration with NASWA, has created this online training to address challenges and possible
solutions to help ensure equitable access to UI programs. Additional training modules are
currently in development. ETA strongly encourages state to have all UI program staff and
support staff participate in this online training.

States should discuss how they are improving their UI programs to reduce or eliminate barriers
to access and any equity issues across the claimants’ journeys. This could include but it is not
limited to discussing the state’s approach to:

o Simplifying communications using plain language and behavioral insights (referenced
  above);

o Enhancing language access and translation and interpretation services;

o Engaging claimant-focused community organizations to provide feedback on pain points,
  education campaigns, and cultural competency;

o Creating feedback loops across the states’ diverse communities and claimants;

o Developing and utilizing demographic, geographic, and industry data across the claimant
  journey to discover and fix pain points across populations;

o Improving in-person and phone services;

o Improving online accessibility and usability across computer and phone devices; and

o Improving educational content available in both in-person and electronic means.

States that received ARPA-funded equity grants as announced in UIPL No. 23-21 are
encouraged to include the equity strategies they are pursing using these grant funds in their FY
2025 SQSPs.





                                                                                     Attachment V


                     Additional Information and Resources to Strengthen
                      Reemployment and Connections to Suitable Work



Reemployment Services and Eligibility Assessments (RESEA) for individualized reemployment
services

The reemployment of UC claimants remains a top priority for the entire workforce system. The
UI program supports reemployment through a variety of targeted strategies, and RESEA
provides a dedicated funding stream for states to provide individualized reemployment services
and referrals to other workforce partners. RESEA, a voluntary program for states, is codified in
Section 306, SSA. Recognizing RESEA as a permanent workforce partner, states with RESEA
programs have been directed to prioritize strategies that support the expansion and sustainability
of the program, such as permanent staffing, expanded eligibility, and increased service-delivery.
UIPL No. 08-24 and 08-24, Change 1, and Training and Employment Guidance Letter (TEGL)
No. 11-23 and 11-23, Change 1 provide the FY 2024 RESEA operating guidance. States recently
updated their WIOA state plans, which should reference the integration of RESEA into their
broader workforce system and reemployment strategies.

States are permitted to reference their RESEA and WIOA state plans in the SQSP rather than
replicate these strategies and approaches. States should also discuss in their SQSPs how their
RESEA strategies support reducing improper payments, including the review of claimant
eligibility, and providing services that help them comply with work search requirements.

STC as a lay-off aversion program

The STC program (known also as “worksharing” or “shared work”) is a lay-off aversion program
in which an employer, under a state-approved plan, reduces the work hours for a group of
workers, and these workers in turn receive reduced UC payments for the weeks in which they
worked reduced hours. States that received grants as described in UIPL No. 22-20 to implement
or improve their STC programs, or to promote participation in STC programs, are encouraged to
include the strategies they are pursuing using these grant funds in their FY 2025 SQSPs. The
Department also encourages the use of STC to support workers and employers.

Robust Work Search Activities

Section 303(a)(12), SSA, requires, as a condition of a state receiving a UI administrative grant,
that state law include a work search requirement as a condition of UC eligibility. Each state
defines acceptable work search activities through its laws and policies, which vary across the
states.

TEN No. 17-19 provides states with model work search legislation focused on proactively
referring claimants to suitable work, establishing a comprehensive definition of acceptable work
search activities that focuses on rapid reemployment, and providing fair notice and
documentation requirements. It is a best practice for states to have a fully integrated workforce
system that focuses its collective efforts on assisting claimants to return to suitable work as
quickly as possible. The following items reflect work search strategies that states should
consider:

o Requiring work search activities that embrace a wide array of activities that support
  reemployment in today’s labor market and include receiving services through American Job
  Centers;

o Supporting claimant compliance with required work search activities through a
  reemployment service delivery design that includes developing clear, plain language work
  search requirements that: 1) ensure claimants understand work search requirements (both
  acceptable activities and documentation requirements); 2) ensure claimants understand the
  consequences of failing to comply with these requirements; and 3) provide assistance in
  developing a reemployment plan that meets the requirements, including through customer-
  friendly technology applications that facilitate claimants carrying out tasks that meet work
  search requirements;

o Encouraging states to proactively identify and refer claimants to suitable job openings from
  public and private job banks, and ensure that claimants accept employment in suitable work
  when offered;

o Developing and facilitating continuous review of completed work search activities to verify
  claimant compliance;

o Documenting these activities through the state’s case management system or other
  information technology (IT) systems that support documentation requirements; and

o Providing case management services through American Job Center career counselors, which
  include following up with claimants and employers on the results of job referrals to inform
  future job referrals and/or the need for additional reemployment services for the claimant.
There are additional strategies states should consider in developing their work search
requirements and designing reemployment service delivery strategies that support a claimant’s
ability to comply with a state’s work search requirements and help to mitigate improper
payments to claimants who fail to meet this eligibility requirement. States are strongly
encouraged to implement these additional strategies to address work search errors and
incorporate those strategies into the Integrity Action Plan (IAP) as part of the SQSP.

o Designing the state RESEA program to support the development of an individual
  reemployment plan that can help each claimant effectively plan work search activities, and
  making such services available virtually to support a broader reach;

o Encouraging RESEA and other career and reemployment service providers to take
  advantage of the My Reemployment Plan tools that are designed to support development of
  individualized reemployment plans and connect claimants to effective reemployment
  resources (see Pathways to Reemployment); and

o Reinforcing the requirement to complete work search activities throughout the claims cycle
  through the use of plain language to explain the requirements and use of behavioral


messaging in electronic communications, either in an online technology application or
through emails or texts, to “nudge” claimants to comply with work search requirements.





                                                                                   Attachment VI


                     Additional Information and Resources to Ensure
                Accurate and Complete Reporting of ETA Required Reports


The impact of the pandemic on the UI system has resulted in some states experiencing technical
challenges leading to untimely filing and/or inaccurate reporting of the ETA required reports.
The states’ SQSP Narrative is required to include actions planned to address this issue and
ensure appropriate reporting in FY 2025. States are also required to correct any inaccuracies in
previously transmitted reports to ensure accurate data is reported.

Additionally, states with inaccurate and/or incomplete reporting on all ETA 227 series of reports
(Overpayment Detection and Recovery Activities), and the 902P report (Pandemic
Unemployment Assistance) must report their plans to correct the reporting issues in the IAP,
specifically regarding Section C. Overpayment Activity and Administration (all activity EXCEPT
for Identity Theft) and Section D. Overpayment Activity Related to Identity (ID) Theft.

States must also continue to ensure accurate financial transaction information is reported on the
ETA 2112 Financial Transaction Summary Report. Ongoing activity associated with the various
CARES Act programs must be reported on the appropriate lines of the ETA 2112 report and
recoveries must be broken out by relevant program. Prior reports should be revised to ensure
accuracy including cases where comingled recoveries may have been reported under lines not
associated with a specific program.

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