FY 2012 state unemployment quality service plans

UIPL21-11ACC.pdf (https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2011/UIPL21-11ACC.pdf)

                                                           CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION
               ADVISORY SYSTEM                             CORRESPONDENCE SYMBOL
                                                           OUI/DPM
          U.S. DEPARTMENT OF LABOR
                                                           DATE
             Washington, D.C. 20210                        June 23, 2011



ADVISORY:          UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 21-11

TO:                STATE WORKFORCE AGENCIES

FROM:              JANE OATES /s/
                   Assistant Secretary

SUBJECT:           Additional Planning Guidance for the Fiscal Year (FY) 2012 Unemployment
                   Insurance (UI) State Quality Service Plan (SQSP)

1. Purpose. To initiate the process, provide supplemental instructions, and define additional
requirements for the FY 2012 SQSP.

2. References. Section 303(a)(1) of the Social Security Act; 20 CFR Parts 640, 650, 652, and
660; Workforce Investment Act Final Rule; Unemployment Insurance Program Letter (UIPL)
No. 19-11; UIPL No. 3-10; UIPL No. 12-08; UIPL No. 3-07; UIPL No. 3-07, Change 1; UIPL
No. 22-05; UIPL No. 22-05, Changes 1 and 2; UIPL No. 14-05; UIPL No. 14-05, Changes 1, 2,
and 3; UIPL No. 03-11; and ET Handbook No. 336, 18th Edition, Change 2 (December 2009).

3. Background. The SQSP 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 ability of the program to reflect their joint commitment to performance excellence
and client-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.
Additionally, it is the grant document through which states receive federal UI administrative
funding. ET Handbook No. 336, 18th Edition, contains general instructions for the SQSP. The
Handbook is designed as a permanent instruction for the annual planning and budget process and
provides states with planning guidelines and instructions for reporting UI financial and staff year
information. Annually, additional planning guidance is issued that supplements the Handbook
and provides direction and instructions specific to the upcoming FY.

States must participate in the annual UI Performs SQSP process whether or not they opt to
include the UI program as part of their Strategic Unified State Plan submitted under Section 501
of the Workforce Investment Act (WIA) of 1998.




 RESCISSIONS                                              EXPIRATION DATE
 None                                                     June 23, 2012

4. National Direction. The SQSP process addresses current state performance related to service
delivery. It also aligns state procedures for consistency with national policies and priorities
relating to accurately and timely paying benefits, and providing reemployment assistance.

Each year, after consulting with its stakeholders, the Department of Labor (Department)
establishes national priorities for the UI program. For FY 2012, the Department’s top priority is
the prevention, detection, and recovery of improper payments. Additionally, the Department
will continue to work to improve program performance nationally; to emphasize better service
delivery for the UI program by improving reemployment services to UI recipients; and to
improve the process for detecting misclassified workers.

The following national priorities are provided for FY 2012 to assist states in the development of
their SQSP, including the establishment of state-level priorities for the UI program. States are
required to submit the UI Program Integrity Action Plan to address their state’s UI improper
payments and are strongly encouraged to address the other national priorities in their SQSPs.

Improved Prevention, Detection, and Recovery of UI Improper Payments

President Barack Obama issued Executive Order 13520 on November 20, 2009, which
articulates the Administration’s focus on reducing improper payments government-wide. The UI
program is one of the top four federal programs with a high dollar amount of improper payments
and is, therefore, considered a “high priority” program. In addition, the UI program as a whole
is considered out of compliance pursuant to the Improper Payment Elimination and Recovery
Act (IPERA) of 2010 due to having an improper payment rate exceeding 10 percent. This is a
critical issue given the impact that improper payments have on the UI trust funds. Integrity
efforts not only help to preserve the UI trust funds and control UI tax rates, but these efforts also
maintain the public trust that the program is protected and operated as intended. As such, there
will be an intensified effort for the Employment and Training Administration (ETA) and the
states to work collaboratively to aggressively reduce improper payments.

As part of the submission of the FY 2012 SQSP, states are required to develop a Program
Integrity Action Plan. States are to analyze their Benefit Accuracy Measurement (BAM) data to
identify the top root causes for improper payments and develop strategies that will be effective in
reducing or recovering improper payments. ETA will be providing significant technical
assistance to states to support their integrity activities. In addition, ETA will work with states to
expand participation in the Treasury Offset Program for the recovery of overpayments, to
implement the State Information Data Exchange System for obtaining timely and complete
separation information, and to more effectively use the National Directory of New Hires and
other overpayment prevention tools for Benefit Payment Control (BPC). The format for the
Program Integrity Action Plan and instructions are included in Attachment C.

Improving Program Performance Nationally

ETA has embarked on a multi-pronged strategy designed to significantly bolster program
accountability and facilitate performance improvement nationally. Strategies to meet this
objective include:


      Partnering with the National Association of State Workforce Agencies in a federal/state
       collaborative effort to develop and implement action strategies and technical assistance to
       support states in improving UI program accountability and performance. This
       partnership focuses on helping states to better utilize data and use business process
       analysis and reengineering tools to improve administration and performance outcomes
       and to benchmark “best practices” for state UI benefit administration. A task group is
       currently validating the mechanism that will be used to gather state best practices;

      Providing high-emphasis technical assistance to support performance improvements for
       “at-risk” states (states with sustained and extremely poor performance);

      Continuing to utilize the UI performance management system, UI Performs, which
       includes core measures and Secretary’s Standards; and

      Reviewing and improving the annual SQSP process, including assisting states with
       developing more effective corrective action plans that truly help states meet or exceed
       performance targets.

As states develop their SQSPs, they should consider including strategies that will significantly
enhance program accountability and performance improvement and seek technical assistance
through ETA’s Regional Offices (ROs).

Reemployment of Unemployment Insurance Claimants

ETA will be focusing significant technical assistance resources to support states’ service
delivery to UI claimants in FY 2012. The goal is to ensure that UI claimants have access to the
full continuum of workforce services through One-Stop Career Centers, both virtual and in-
person, and through Rapid Response activities. ETA will be working more intensively with
states that have Reemployment and Eligibility Assessment grants to identify and share “best
practices” and to develop a more uniform national assessment program. ETA is also
collaborating with state and local delivery partners to improve the integration of UI and
workforce programs with the goal of improving employment outcomes for UI claimants.

As states develop their SQSPs, they should consider including innovative and robust
reemployment strategies that are developed in collaboration with the workforce system partners
in their state who are responsible for the WIA Adult and Dislocated Worker programs and
Wagner-Peyser funded employment services. These collaborative reemployment strategies
should be reflected in the partner agencies’ strategic plans.

Addressing Worker Misclassification

The President’s FY 2012 Budget includes a multi-agency initiative to dramatically strengthen
and coordinate federal and state efforts to address employer misclassification of workers. The
goal is to improve federal and state agency capacity to identify potential violators through
improved information sharing and targeted audits in high-risk industry sectors; to provide


outreach to employers to educate them regarding worker classification and, therefore, prevent
misclassification; to increase statutory enforcement, where appropriate; and, to enable the
collection of payroll taxes previously lost due to misclassification. As this federal collaboration
unfolds, ETA will make states aware of new opportunities and strategies that may be available to
address this problem.

The President’s budget also includes $26,900,000 for two new initiatives to increase state
capacity to address misclassification within the UI program. The first initiative provides for
competitive grants for states to increase their data sharing activities with the Internal Revenue
Service and other federal and state agencies; to implement targeted audit strategies; to establish a
cross-state agency task force to target egregious employer schemes to avoid taxation through
misclassification; and, to develop education and outreach programs. The second initiative would
pilot a high performance award program designed as an incentive for states to improve
misclassification efforts. ETA will provide states with additional guidance for these two
initiatives when the FY 2012 budget is enacted.

States may deploy a wide array of other strategies in addition to these federal strategies. States
are encouraged to move forward to develop and implement state-driven strategies to address
misclassification of workers and to include those strategies in the state’s SQSP. ETA will
capture state “best practices” in this area and share them broadly.

5. Strategic Goals and Outcome Measures. The five-year Department Strategic Plan forms the
basis for the federal emphasis for FY 2012. Required by Congress under the Government
Performance and Results Act of 1993 (GPRA), the Strategic Plan is an integral part of the budget
process and requires a commitment from all Department programs to attain expressed goals and
outcomes. Achieving these outcomes requires the combined efforts of the federal and state
partners.

The UI program and outcome goals, shown below, support the Department’s strategic vision of
“Good Jobs for Everyone.”

Program Goal: Secure health benefits and, for those working, provide income security.
Outcome Goal 4.2.: Ensure income support when work is impossible or unavailable.

This year, ETA is focusing significant technical assistance resources to support states’ service
delivery to UI claimants. The focus is to ensure that UI claimants have access to the full
continuum of services beginning with their claim for UI benefits by providing access to the full
range of workforce services delivered through One-Stop Career Centers and Rapid Response
activities. States are expected to describe in the SQSP Narrative the steps they will take to better
connect the UI claimant with the workforce system.

FY 2012 GPRA Goals and Targets

In recognition of ETA priorities, attention is focused on the following GPRA goals for FY 2012,
with targets that the system as a whole is expected to meet. States should continue to strive to
reach or exceed these GPRA goals and targets in FY 2012:


      Make Timely Benefit Payments
       o Target: 85.7% of intrastate first payments for full weeks of unemployment will be
         made within 14/21 days from the week ending date of the first compensable week.

      Facilitate the Reemployment of Claimant
       o Target: 56.4% of UI claimants will be reemployed by the end of the first quarter
          after the quarter in which they received their first payment.

      Detect Benefit Overpayments
       o Target: Overpayments established will be at least 52.3% of the estimated detectable,
          recoverable overpayments.

      Establish Tax Accounts Promptly
       o Target: 86.9% of status determinations for new employers will be made within 90
          days of the end of the first quarter in which liability occurred.

6. Program Performance. The Department’s strategic approach to UI Performs is to focus
efforts on raising the performance of states where performance is below minimum criteria, while
promoting overall excellence. Corrective action plans (CAPs) are expected whenever a state’s
performance does not meet established criteria for the SQSP measurement period (or performance
year) and remains uncorrected prior to the preparation of the SQSP. The measurement period for
the FY 2012 SQSP is April 1, 2010 – March 31, 2011, unless otherwise indicated.

Multi-year CAPs continue to be an option for states so that efforts which must extend beyond a
FY due to their size, scope, or complexity can be realistically portrayed. Out-year portions of
such multi-year plans do not need to provide quarterly targets or milestones (as required for the
SQSP year) but should provide sufficient information to explain anticipated progress and results.

7. SQSP Performance Criteria. CAPs are expected for:

      Performance below the acceptable levels of performance (ALPs) for Core Measures.
       There is an exception for the 2012 SQSP for the First Payment Promptness Measure. If
       performance for this measure is less than 87% but not lower than the GPRA national
       target of 85.7% of intrastate first payments for full weeks of unemployment within 14/21
       days from the week ending date of the first compensable week, then the performance for
       this measure may be addressed in the SQSP Narrative. If the performance is below
       85.7%, a CAP is necessary to address the deficiency.

      Performance below the criteria for the Secretary’s Standards established in regulation at
       20 CFR Parts 640 and 650. There is an exception for the 2012 SQSP for the First
       Payment Promptness (IntraState 14/21 Days) standard. If performance for this standard
       is less than 87% but not lower than the GPRA national target of 85.7% of intrastate first
       payments for full weeks of unemployment within 14/21 days from the week ending date
       of the first compensable week, then the performance for this standard may be addressed


       in the SQSP Narrative. If the performance is below 85.7%, a CAP is necessary to
       address the deficiency.

      The Detection of Overpayments Measure is the percent of detectable/recoverable
       overpayments established for recovery. States reporting an overpayment detection rate
       below 50% are expected to address the deficiency in a CAP. Also, because states
       generally cannot cost-effectively detect and establish more than 80%-90% of estimated
       overpayments, an upper limit of 95% has been established for monitoring purposes.
       States reporting ratios over 95% are expected to explain in the Narrative section the
       reasons for the higher-than-expected ratios. If an overpayment rate above 95% is 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). The
       CAP should be designed to produce valid data for the Overpayment Detection Measure.
       The performance period for the BPC component is the three-year period ending March 31,
       2011; the performance period for the BAM component is the three-year period ending
       September 30, 2010.

      State BAM operations that, based on the BAM Administrative Determination, are not
       compliant with the National Directory of New Hires matching requirements in ET
       Handbook 395, 5th Edition, chapter VI, UIPL 3-07 and UIPL 3-07, Change 1, effective
       for BAM paid claims sample cases beginning with batch 200801.

States are expected to address all other performance deficiencies in the SQSP Narrative. These
include:

      Failure to conduct required program reviews;

      Deficiencies identified during required program reviews;

      Failure to meet reporting requirements; and

      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% of the nonmonetary determinations evaluated in the
       quarterly quality samples (obtained from the ETA 9056 report). 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.

Attachment A lists the performance criteria for the Core Measures, Secretary’s Standards and
other program requirements where CAPs or Narratives may be required if annual performance is
not acceptable. Attachment B lists the final state-specific ALPs for the UI Reemployment
measure.


8. Additional SQSP Performance Criteria and Guidance.

UI Program Integrity

The IPERA requires agencies to ensure that their managers and accountable officers (including
the agency head), programs, and, where applicable, states and localities, are held accountable for
reducing improper payments. Beginning with the FY 2012 SQSP, State Workforce Agencies are
required to report their planned activities to prevent, detect, reduce, and recover improper UI
payments as part of their SQSP submission. The UI Program Integrity Action Plan and
instructions are included in Attachment C.

Data Validation (DV)

The deadline for submitting DV results is June 10, 2012. Failures, incomplete submissions
and/or non-submitted materials for DV are expected to be addressed in the state’s FY 2012
SQSP. Non-submitted items include failures to certify that Module 3 of the DV Benefits and
Tax Handbooks are up to date during the April 1 – June 10 certification window.

      If a state had DV items due for validation year (VY) 2011 and submitted all the items,
       but did not pass all items, it may address those that did not pass in the SQSP Narrative,
       explaining the cause of the failure and the actions the state will take to correct the failure
       during FY 2012.

      Any DV items due for VY 2011, but not submitted by the June 10, 2011, deadline, must
       be addressed in a CAP for FY 2012.

      If a state has a combination of non-submitted and submitted-but-failing items in FY
       2011, the state must do a DV CAP encompassing both the non-submitted and the
       submitted-but-failing items. In this case, the submitted-but-failing items may not be
       addressed in the Narrative.

Tax Performance System

To ensure that UI tax operations are also in compliance with federal reporting and oversight
requirements, failure to conduct one or more Tax Performance System (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 3 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.





Effective Audit Measure

The Effective Audit Measure is a new UI Performs Core Measure. It is a blended measure of the
following four factors: 1) Percent of Contributory Employers Audited Annually, 2) Percent of
Total Wage Change From Audit, 3) Percent 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 must attain to pass the Effective Audit Measure as well as an overall combined score
that must be met. The measure also requires states to direct additional emphasis to the factor(s)
that they deem important to their 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. Beginning with the FY 2015
SQSP, states that do not meet this measure will be required to complete a CAP based on the
2013 calendar year data. A CAP is not required with the FY 2012 SQSP submission.

9. Planning Requirements and Guidance for FY 2012. ET Handbook 336, 18th Edition,
Change 2 and this UIPL provide guidelines for the completion and submittal of the SQSP and
should be used when preparing the FY 2012 state plans.

CAPs and Narrative addressing performance deficiencies are the components of the state’s formal
plan and schedule for improving performance. A thorough analysis to identify the cause of
performance shortfalls should be performed prior to the development of the state’s plan. UI
programs and processes are interrelated; processes in one area may impact state processes in other
areas. Actions to improve or correct a measure should not impact other program areas. The
SQSP Handbook provides formats for the completion of the SQSP.

"At-Risk" Process

ETA’s goal is to ensure that states are implementing “methods of administration” reasonably
calculated to ensure full payment of unemployment compensation benefits “when due” in
accordance with federal law. To that end, ETA has identified persistently low performing states
as "at-risk" and requiring high emphasis for technical assistance and monitoring. States selected
because of consistently significant low performance for the first payment and appeals timeliness
measures have been notified by ETA.

SQSP Assurances

By signing the SQSP Signature Page, a state certifies that it will comply with the assurance listed
in ET Handbook 336, 18th Edition, Change 2, and that the state will institute plans or measures to
comply with the requirements.

States will continue to provide information for Assurances H, ‘Assurance of Contingency
Planning’ and J, ‘Assurance of Automated Information Systems Security’. In the State Plan
Narrative Outline, Section H, “Assurances,” states are expected to provide the dates that their
Information Technology (IT) Contingency Plan, System Security Plan, and Risk Assessment
were implemented, tested, and reviewed/updated.




States are expected to:

      Review and/or update, and test the IT Contingency Plan annually;

      Review and/or update the System Security Plan annually; and

      Conduct a Risk Assessment once every three (3) years.

If a state does not have an IT Contingency Plan, System Security Plan, and Risk Assessment
procedures in place or if these documents are incomplete, then the state is expected to address
the actions it plans to take in the SQSP Narrative. These plans and procedures must meet the
minimum controls listed in the Chapter I, Section VII-H and Section VII-J of the ET
Handbook No. 336, 18th Edition, Change 2.

10. Funding Period. The proposed appropriation language provides for obligation of FY
2012 UI allocations by states through December 31, 2012, with 90 additional days to liquidate
the obligations and complete the expenditure of funds. However, states may obligate FY 2012
UI funds through September 30, 2014, if such obligations are for automation acquisitions.
Therefore, the end of the FY 2012 obligation period is December 31, 2012, for all funds
except automation acquisitions, which have an obligation deadline of September 30, 2014.

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

12. Deadline for State SQSP Submittal. Each RO will set a deadline for states to submit their
SQSPs for FY 2012.

13. Electronic Submission of the SQSP. States are required to submit the SQSP electronically
and should contact their RO SQSP Coordinator prior to 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 2) are available in PDF format and may be downloaded from the Office
of Management and Budget Web site at:
http://apply07.grants.gov/apply/FormLinks?family=15. States may submit the SQSP
signature page electronically if the state law permits. States that do not submit an electronic
signature page must submit the signature page via fax, scan or mail by the deadline set by the RO.

14. Action Requested. State Administrators are requested to:

      Make this information available to appropriate staff;

      Prepare their SQSPs in accordance with instructions in this UIPL and the planning and
       reporting instructions contained in ET Handbook No. 336, 18th Edition, Change 2;

      Coordinate specifics, as appropriate, with the RO for electronic submission of the plan;



       and

      Submit the FY 2012 SQSP by the dates specified to the appropriate RO.

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

16. Attachment(s).

A. Measures/Programs to be addressed in the FY 2012 SQSP.
B. Final State-specific ALPs for UI Reemployment.
C. UI Program Integrity Action Plan Template and Instructions

UIPL21-11ATT-A.pdf (https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2011/UIPL21-11ATT-A.pdf)

                                                                                                                           Attachment A
                                    Measures/Programs to be Addressed in the FY 2012 SQSP

 Core Measures                                     Measurement Period                                 Criteria                  CAP             Narrative
 First Payment Promptness*                         Apr 1, 2010 – Mar 31, 2011                        87%                           √                 √
 Nonmonetary Determination Time                    Apr 1, 2010 – Mar 31, 2011                        80%                           √
 Lapse                                                                                          (combined score)
 Nonmonetary Determination Quality                 Apr 1, 2010 – Mar 31, 2011                        75%                           √

    - Nonseparations
 Nonmonetary Determination Quality                 Apr 1, 2010 – Mar 31, 2011                           75%                        √
    - Separations
 Detection of Overpayments                         BPC: Apr 1, 2008 – Mar 31,                          <50%                        √
                                                   2011;                                               >95%                                          √
                                                   BAM: Oct. 1, 2007 –
                                                   Sept. 30,2010

                                                   If the rate is a result of
                                                   improper administration of                          >95%                        √
                                                   BAM and/or BPC
 Average Age of Pending Lower                      Apr 1, 2010 – Mar 31, 2011                         30 days                      √
 Authority Appeals
 Average Age of Pending Higher                     Apr 1, 2010 – Mar 31, 2011                         40 days                      √
 Authority Appeals
 Lower Authority Appeals Quality                   Apr 1, 2010 – Mar 31, 2011                           80%                        √
 New Employer Status                               Apr 1, 2010 – Mar 31, 2011                           70%                        √
 Determinations Time Lapse
 Effective Audit Measure***                        Jan 1,2010 – Dec 31, 2010                Score >7;and exceed all              No
                                                                                                   4 factors                    CAP
                                                                                                                                until
                                                                                                                                 FY
                                                                                                                                2015
 Tax Quality (Part A: No more than      Jan 1, 2010– Dec 31, 2010                                                                √
 3 tax functions failing TPS in a year)
 Tax Quality (Part B: The same tax      Jan 1, 2010 – Dec 31, 2010                                                                √
 function cannot fail for 3 consecutive
 years)
 TPS Sample Reviews**                   Apr 1, 2010 – Mar 31, 2011                                                                 √
 Facilitate Reemployment                1st Payments: October 1,                                 Varies by State                   √
                                        2009 to September 30, 2010                             See Attached Table
                                        Reemployment: January 1,
                                        2010 to December 31, 2010
*Performance below 87%, but no lower than 85.7% may be addressed in the Narrative for the 2012 SQSP only. CAPs are required for performance
below 85.7% for the 2012 SQSP.

** To ensure compliance with federal oversight and reporting requirements, a CAP will also be required if a state does not conduct one or more of the 13
TPS sample reviews during the performance period. Tax functions that could not be sampled because the sample universe was invalid/corrupt (the
sample contained less than 53 valid cases) will be counted as a failure. A CAP is not required if a state identifies a universe that is too small to support a
valid sample, or the Experience Rate sample, which is examined once every four years, is not required. States can also request a temporary waiver from
the Regional Office under certain circumstances. For example, a waiver may be granted if IT modernization efforts have temporarily affected a TPS
universe.

***The Effective Audit Measure will be implemented with the FY 2015 SQSP. States will be expected to submit a CAP if their performance for the 2013
calendar year does not meet the ALP. A description of the Measure is in UIPL 3-11.

                                              Measurement Period                     Criteria             CAP          Narrative
 Secretary’s Standards in Regulation
 First Payment Promptness                Apr 1, 2010 – Mar 31, 2011                   87%                   √              √
 (IntraState 14/21 Days) *
 First Payment Promptness                Apr 1, 2010 – Mar 31, 2011                   93%                   √
 (IntraState 35 Days)
 First Payment Promptness                Apr 1, 2010 – Mar 31, 2011                   70%                   √
 (InterState 14/21 Days)
 First Payment Promptness                Apr 1, 2010 – Mar 31, 2011                   78%                   √
 (InterState 35 Days)
 Lower Authority Appeals (30 Days)       Apr 1, 2010 – Mar 31, 2011                   60%                   √
 Lower Authority Appeals (45 Days)       Apr 1, 2010 – Mar 31, 2011                   80%                   √

             Programs                       Measurement Period                                            CAP         Narrative
 Data Validation                          Apr 1, 2010 – Mar 31, 2011
     Results not submitted by                                                                              √
        June 10, 2011
    _________________________
     Failing/incomplete                  Apr 1, 2010 – Mar 31, 2011                                                       √
        submission by June 10,
        2011
 Compliance with National                Status as of March 31, 2011                                        √
 Directory of New Hires matching
 requirements for BAM
 Incorrect recording of the Issue         Apr 1, 2010 – Mar 31, 2011                                                       √
 Detection Date and/or
 Determination Date
*Performance below 87%, but no lower than 85.7% may be addressed in the Narrative for the 2012 SQSP only. CAPs are required for
performance below 85.7% for the 2012 SQSP.

UIPL21-11ATT-B.pdf (https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2011/UIPL21-11ATT-B.pdf)

                                                                   Attachment B

 UI Reemployment Preliminary Acceptable Levels of Performance (ALPs)
           Reemployment During 4 Quarters Ending 12/31/2010

        CY TUR        %                   Reemployment
State     (%)      Nonexempt     ALP        CY2010            Difference
AK          8.0%       67.1%        57%          55.4%               -1.6%
AL          9.5%       69.6%        54%          57.1%                3.1%
AR          7.9%       90.4%        50%          62.8%               12.8%
AZ         10.0%       87.8%        49%          50.8%                1.8%
CA         12.4%       86.9%        44%          51.6%                7.6%
CO          8.9%       82.9%        50%          46.7%               -3.3%
CT          9.1%       91.7%        47%          55.8%                8.8%
DC          9.9%       98.3%        47%          46.5%               -0.5%
DE          8.5%       74.2%        53%          58.4%                5.4%
FL         11.5%       94.0%        44%          43.1%               -0.9%
GA         10.2%       75.1%        50%          52.8%                2.8%
HI          6.6%       54.8%        62%          61.2%               -0.8%
IA          6.1%       43.8%        65%          64.3%               -0.7%
ID          9.3%       58.3%        57%          77.2%               20.2%
IL         10.3%       72.0%        50%          54.2%                4.2%
IN         10.2%       62.6%        53%          57.9%                4.9%
KS          7.0%       73.3%        56%          54.7%               -1.3%
KY         10.5%       61.9%        53%          63.5%               10.5%
LA          7.5%       90.8%        50%          53.0%                3.0%
MA          8.5%       88.9%        50%          55.3%                5.3%
MD          7.5%       86.4%        52%          53.8%                1.8%
ME          7.9%       97.3%        50%          55.8%                5.8%
MI         12.5%       65.4%        50%          64.3%               14.3%
MN          7.3%       61.4%        57%          68.3%              11.3%*
MO          9.6%       87.2%        49%          56.9%                7.9%
MS         10.4%       99.7%        46%          55.7%                9.7%
MT          7.2%       38.0%        63%          66.7%                3.7%
NC         10.6%       79.4%       50%           49.2%               -0.8%
ND          3.9%       33.0%        69%          74.6%                5.6%
NE          4.7%       65.7%       62%           57.7%               -4.3%
NH          6.1%       88.0%        53%          50.4%               -2.6%
NJ          9.5%       81.9%        49%          53.4%                4.4%
NM          8.4%       91.0%        49%          35.5%              -13.5%
NV         14.9%       71.7%        44%          49.0%                5.0%
NY          8.6%       80.9%        50%          52.8%                2.8%
OH         10.1%       86.9%        47%          51.1%                4.1%
OK          7.1%       88.4%        52%          46.5%               -5.5%
OR         10.8%       69.6%        53%          60.6%                7.6%
PA          8.7%       48.0%        62%          65.5%                3.5%
PR         16.1%       88.6%       41%           27.8%              -13.2%
RI         11.6%       68.5%        51%          52.6%                1.6%
SC         11.2%       90.1%        44%          52.3%                8.3%
SD          4.8%       61.6%        62%          66.0%                4.0%
TN          9.7%       68.0%        54%          56.2%                2.2%
TX          8.2%       93.0%        49%          52.8%                3.8%

UT            7.7%        85.9%         52%           55.8%    3.8%
VA            6.9%        89.4%         53%           54.6%    1.6%
VI            8.1%       100.0%         49%           52.9%    3.9%
VT            6.2%        55.6%         62%           64.4%    2.4%
WA            9.6%        77.6%         51%           58.9%    7.9%
WI            8.3%        45.9%         62%           54.4%   -7.6%
WV            9.1%        57.2%         57%           63.7%    6.7%
WY            7.0%        68.7%         59%           65.2%    6.2%

Note: States failing to attain ALP are highlighted.

* Based on estimated data due to missing reports.
Total Unemployment Rates (TUR) are for CY 2010
% nonexempt for year ending 9/30/2010.
% reemployed for year ending 12/31/2010.

UIPL21-11ATT-C.pdf (https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2011/UIPL21-11ATT-C.pdf)

                                                                          Attachment C
                       Unemployment Insurance Program Integrity Action Plan

State: (Name of state)                               Federal Fiscal Year: (SQSP Planning Year)

Root Causes:
(List top three of the root causes in the state.)




Accountable Agency Official(s): (List the person accountable for reducing UI improper payments)


Summary: (Provide a summary of the plan that the state has designed. The summary should
include outreach efforts planned by the agency to inform all UI and workforce staff, and
employers of the strategic plan to ensure everyone understands the importance of maintaining
program integrity.)




                                                      Targets and
Strategies                     Actions                                              Resources
                                                      Milestones



                                                 This section should be
                                                 divided into target and    Provide a description of the
                                                 milestones. Specific       type resource e.g. human
List the strategies      List the specific
                                                 milestones should be       capital, technology and
that the state is        action steps for each
                                                 set for each of the        other tools that have been
taking to address UI     strategy that the
                                                 actions. It is suggested   designated to address the
improper payments.       state is taking.
                                                 that the milestones be     state’s UI improper
                                                 set quarterly under        payments.
                                                 each target.

           Unemployment Insurance (UI) Program Integrity Action Plan
Background

On July 22, 2010, the Improper Payments Elimination and Recovery Act (IPERA) of 2010 (P.L.
111-204) was enacted. IPERA requires federal agencies and entities receiving federal funding to
ensure that their managers and accountable officers (including the agency head), programs, and,
where applicable, states and localities, are held accountable for reducing improper payments.

To implement the requirements of IPERA, the Department is requiring State Workforce
Agencies (SWAs) to report their planned activities to prevent, detect, reduce, and recover
improper UI payments as the Unemployment Insurance Program Integrity Action Plan. A
recommended template for the plan has been developed and is included. The action plan should
provide:

          Strategies and associated actions to reduce root causes, including recovery of these
           improper payments;
          Timeline, expected targets and measures; and
          Type and source of resources dedicated to accomplish the action plan.

To assist the SWAs in planning, the U.S. Department of Labor (Department) will provide each
with state-specific Benefit Accuracy Measurement (BAM) improper payment estimates, and data
regarding the top root causes of overpayments.

Program Integrity Action Plan Specifics

The plan must identify the SWA officer(s) accountable for reducing improper payments,
summarize the SWA’s assessment regarding whether it has the internal controls, human capital,
and information systems and other infrastructure needed to reduce improper payments to
minimal cost-effective levels, and identify any statutory or regulatory barriers which may limit
the agencies’ corrective actions in reducing improper payments. Additionally, the plan must
discuss the root causes of improper payments and present the state’s strategies to address these
causes.

A. Strategies to address Root Causes and Recovery of Improper Payments. The SWA shall use
   the BAM improper payment estimates provided by the Department to develop and describe
   their strategies to prevent, detect, and/ or reduce each root cause. Additionally, the strategies
   will include actions to improve the recovery of these improper payments.

   To determine the root causes for improper payments, each SWA needs to conduct an analysis
   of improper payments by reviewing:

          Cause and responsible party,
          Cause and prior actions by the agency, employer and claimant, and
          Cause and BAM error detection points.

   Other analysis may include SWA staffing issues, technology tools used, etc.

i) Prevention. Prevention activities are by definition proactive. These are actions
   performed prior to payment issuance to assure that the payment is accurate when
   made. Examples of this type of activity include:

   (1) Expanding the methods for communicating Benefit Rights and Responsibility
       Information (BRI), reviewing information layout and reading level, and testing
       claimant understanding;

   (2) Training employers and claimants on separation information requirements;
   (3) Implementation of the State Information Data Exchange System (SIDES)
       designed to improve the quality and timeliness of separation information;

   (4) Review of state law, rules and regulations, business processes, and goals that are
       concerned with employment service (ES) registration and align these elements to
       eliminate overpayments. Several business models exist which may help to
       eliminate ES Registration errors. Two of the most successful are outlined below:

       (a) Claimant responsible for ES registration – SWA stops payment if the claimant
           is not registered within 14 days of the initial claim. Weeks claimed or
           additional claims automatically maintain registration as active.
       (b) Agency responsible for ES registration – SWA collects sufficient information
           during the initial claims process to register the claimant for services. This
           information is transmitted to Employment Services and the system shows an
           active registration;

   (5) Use of Systematic Alien Verification for Entitlement (SAVE) and Social Security
       Administration Crossmatching;

   (6) Working with a consortium of states, improve the continued claims taking process
       (Interactive Voice Response (IVR) and Internet) design and flow logic to better
       detect changes in employment status (earnings to none) within and between
       weekly certifications to prevent payments when separations issues occur. To
       prevent benefit year earnings reporting errors, SWAs should ensure that the IVR
       or internet process clearly focuses first on employment status and then earnings in
       its series of questions asked -- for example, “Did you work during the week of
       mm/dd/yyyy?, How many hours did you work? How much do you earn per
       hour?”

   (7) Focusing on the claimant’s return to work date and earnings verification. If a
       claimant does not report work or hours after the return work date, create a call-in
       reporting requirement where the claimant has claimed a week after the return to
       work date and has not reported earnings;

   (8) Staff evaluation and training (such as an Expanded Benefit Timeliness and
       Quality adjudication evaluation program and issue training); and

   (9) Assuring standardized fact-finding questions are used and completed for each
       issue type.

ii) Detection. Detection activities occur subsequent to payment. These are actions that
    the state controls and usually involves crossmatch activities such as:

   (1) National Directory of New Hire Crossmatching – check crossmatch time
       parameters, agency filters, use mandatory call-ins if a week is claimed and no
       earnings are reported;

   (2) Implement the recommended operating procedures for Crossmatching Activity:
       National and State Directories of New Hires as outlined in the Unemployment
       Insurance Program Letter (UIPL) 19-11, National Effort to Reduce Improper
       Payments in the Unemployment Insurance (UI) Program;

   (3) Wage Benefit Crossmatching – check the pindex calculation to ensure that it
       reflects current earnings disregard standards, run the wage benefit crossmatch for
       9 consecutive weeks after the end of a quarter to distribute workload and detect
       issues as soon as information is available;

   (4) Implementation of SIDES to improve the quality and timeliness of separation and
       benefit year earnings information and to receive employer reported information in
       electronic format so earnings comparisons can be completed by the computer
       instead of Benefit Payment Control (BPC) personnel;

   (5) Use of data mining to detect such disqualifying issues as multiple claimants at
       single address or phone number; and

   (6) Use of predictive analysis to identify claims at high risk for overpayments.

iii) Reduction. Reduction activities are those actions which reduce the amount overpaid
     or the number of weeks overpaid and involve activities such as:

   (1) Redesign of BPC workflow to reduce administrative activities;

   (2) Using call-in and/or automated “required to report” notices (mail, IVR, email, and
       Internet) to raise BPC earnings issues quickly;

   (3) Use of weighting strategies to prioritize detection workload; and

   (4) Automating certain overpayment establishment decisions, where the business
       process only requires earning adjustment notices.

iv) Recovery. SWAs will specify the actions they plan to take to recover overpayments
    and plans to improve the recovery of overpayments. (See Unemployment Insurance
    Program Letter 33-99 “Overpayment Recovery Technical Assistance Guide”
    http://www.oui.doleta.gov/dmstree/uipl/uipl99/3399att/3399toc.htm). Examples of
    this would be:

       (1) Redesign of the BPC overpayment recovery workflow process;

               (2) Reduction of administrative activities and/or automation of skip tracing and
                   billing notices;

               (3) Implementation of the federal Tax Offset Program (TOP) with the U.S.
                   Department of the Treasury; and

               (4) Implementation of a state Tax Offset Program.

B. Targets and Timeline. When compiling its strategies to address improper payments, agencies
   shall set targets for future improper payment levels and a timeline when the proposed
   strategies will be completed and within which the expected targets will be reached. States
   are encouraged to develop realistic multiyear initiatives.

C. Resource Allocation: The plan shall include a description of the type of resources such as
   human capital, technology and other tools used to prevent, detect, reduce and recover
   improper payments.

D. High Impact States: ETA has collaborated with eleven states (CA, NY, NJ, NC, OH, MI,
   WI, FL, TX, IL, and PA) that have the greatest ability to impact and lower the UI improper
   payment rate to aggressively identify and implement strategies to bring down the UI
   improper payment rate and to provide leadership nationally to address this issue. A key
   centerpiece of the collaboration is that each state will form a cross-functional UI improper
   payment task force to both work on state specific strategies and to collaborate across states to
   share best practices. As part of this initiative, each of these eleven states is expected to
   develop and implement a state-specific strategic plan to bring down the state’s improper
   payment rate as quickly as feasible. For the FY 2012 submission of the UI Program Integrity
   Action Plan, these states may attach their state-specific strategic plan to this document
   including any additional information requested on the template above.