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Planning the FY 2015 state UI service plan
Summary ETA gave state unemployment agencies supplemental instructions for their FY 2015 State Quality Service Plans. The letter identifies national priorities, performance measures and corrective action requirements, along with deadlines and electronic submission instructions. Its attachments include the measures to address and planning templates. ETA now lists the advisory as Canceled.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 21-14
Date issued
August 5, 2014
Status
Withdrawn
ETA's advisory listing marks this letter Canceled as of 2026-10-24; its PDF prints an expiration date of December 31, 2015.
Status last verified October 24, 2026
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CLASSIFICATION
EMPLOYMENT AND TRAINING ADMINISTRATION Unemployment Insurance
ADVISORY SYSTEM CORRESPONDENCE SYMBOL
U.S. DEPARTMENT OF LABOR OUI/DPM
Washington, D.C. 20210 DATE
August 5, 2014
ADVISORY: UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 21-14
TO: STATE WORKFORCE AGENCIES
FROM: PORTIA WU /s/
Assistant Secretary
SUBJECT: Additional Planning Guidance for the Fiscal Year (FY) 2015 Unemployment
Insurance (UI) State Quality Service Plan (SQSP)
1. Purpose. To initiate the SQSP process, provide supplemental instructions, and define
additional requirements for the FY 2015 SQSP.
2. References.
• Section 303(a)(1) of the Social Security Act (SSA);
• 20 CFR Parts 640, 650, 652, and 660;
• Unemployment Insurance Program Letter (UIPL) No. 14-05, Changes to UI Performs,
and its Changes 1, 2, and 3;
• UIPL No. 22-05, Unemployment Insurance Data Validation (UI DV) Program Software
and Policy Guidance, and its Changes 1 and 2;
• UIPL No. 3-07, Use of National Directory of New Hires (NDNH) in Unemployment
Insurance (UI) Benefit Accuracy Measurement (BAM) Audits, and its Change 1;
• UIPL No. 12-08, Establishing an Acceptable Level of Performance (ALP) for the
Unemployment Insurance (UI) Reemployment Rate Measure;
• UIPL No. 3-10, Revisions to Employment and Training (ET) Handbook 336, 18th
Edition: “Unemployment Insurance (UI) State Quality Service Plan (SQSP) Planning
and Reporting Guidelines”;
• UIPL No. 22-10, Selecting and Monitoring At-Risk States for Continuous Improvement
and Compliance with First Payment Timeliness and First Level Appeals Promptness;
• UIPL No. 03-11, Implementation of the Effective Audit Measure;
• UIPL No. 19-11, National Effort to Reduce Improper Payments in the Unemployment
Insurance (UI) Program;
• UIPL No. 34-11, Performance Measure for Unemployment Insurance (UI) Integrity, and
its Change 1;
• UIPL No. 22-13, Additional Planning Guidance for the Fiscal Year (FY) 2014
Unemployment Insurance (UI) State Quality Service Plan (SQSP);
• UIPL No. 09-13, Integrity Performance Measures for Unemployment Insurance (UI);
RESCISSIONS EXPIRATION DATE
None December 31, 2015
• Employment and Training (ET) Handbook No. 336, 18th Edition, Unemployment
Insurance (UI) State Quality Service Plan (SQSP) Planning and Reporting Guidelines,
and its Change 3 (April 2014); and
• ET Handbook No. 395, 5th Edition, State Operations Handbook for the Unemployment
Insurance (UI) Benefit Accuracy Measurement (BAM) Program, (November 2009)
(http://wdr.doleta.gov/directives/attach/ETHandbook_395_Ch5.pdf).
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 UI program’s ability to reflect their joint commitment to performance
excellence and client-centered services. The SSA authorizes the Secretary of Labor to
provide funds to administer the UI program and governs the expenditure of those funds.
Therefore, the SQSP operationally serves as the grant document through which states receive
Federal UI Administrative Funding.
As part of UI Performs, which is 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. States must participate
in the 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.
ET Handbook No. 336 contains general instructions for the SQSP. This Handbook is
designed as a permanent instruction for the planning and budget process and provides states
with planning guidelines and instructions for reporting UI financial and staff year
information. Annually, the Employment and Training Administration (ETA) issues a UIPL
with additional planning guidance that supplements the Handbook and provides direction and
instructions specific to the upcoming FY. Change 3 of ET Handbook No. 336, issued in
April 2014, includes changes to various instructions and guidance to the SQSP process.
4. National Priorities. The SQSP process addresses current state service delivery
performance. It also aligns state procedures with national policies and priorities for paying
benefits accurately and timely and providing reemployment assistance.
Each year, after consulting with our stakeholders, ETA establishes national priorities for the
UI program. For FY 2015, ETA’s top priority continues to be the prevention, detection, and
recovery of improper payments. Additionally, ETA will continue to work to improve
program performance nationally; emphasize better service delivery for the UI program by
improving reemployment services to UI recipients; and improve the process for detecting
misclassified workers.
ETA provides the following national priorities for FY 2015 to help states develop their SQSP,
including the establishment of state-level priorities for the UI program. Several of the
priorities are ongoing from the previous year with one exception – a focus on building state
capacity to administer the UI program effectively.
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Improving State Capacity to Administer and Operate the UI Program Effectively
In the aftermath of the Great Recession, states are emerging with new challenges in
administering the UI program such as pent-up demand to make program improvements
and/or to implement new technology solutions; the need to downsize as workload diminishes;
backlogs that may still be in place due to high workloads; loss of key subject matter expertise
due to retirements; many new staff who are still in learning mode; and declining
performance. As states begin to look strategically at next steps in restoring program
accountability and integrity, we strongly encourage them to use the SQSP process of
developing plans to incorporate administrative capacity building strategies such as:
• Conducting business process analysis to identify opportunities for improving program
operations, and implementing recommendations from the analysis to improve
performance;
• Using Supplemental Budget Request opportunities to implement strategies most
likely to enhance state capacity;
• Reviewing staff training strategies to support succession planning and ongoing staff
development for new staff; and
• Taking advantage of technical assistance opportunities offered by the U.S.
Department of Labor (Department), and the Information Technology Support Center,
the UI Integrity Center of Excellence; and making use of the peer to peer information
and tools available through the UI Community of Practice.
The Department is eager to work with states to make the SQSP process a meaningful
management tool that becomes a strategic road map for states to improve program
administration and ensure quality service delivery.
Improving Prevention, Detection, and Recovery of UI Improper Payments
The President issued Executive Order 13520 on November 23, 2009, which articulates the
Administration’s focus on reducing improper payments government-wide. Under the criteria
established by the Office of Management and Budget (OMB), the UI program is considered a
“high priority” program. For the FY 2013 reporting period, UI was one of the top five
Federal programs based on the dollar amount of improper payments. In addition, the
Department’s Office of Inspector General has determined that the UI program is out of
compliance with the Improper Payment Elimination and Recovery Act (IPERA) of 2010
because the 2011, 2012 and 2013 improper payment rates do not meet IPERA reduction
targets and/or the criterion in IPERA that requires Federal agencies to report an improper
payment rate of less than 10 percent. The Department established the improper payment
reduction targets for the UI program with OMB approval. This is a critical issue given the
impact that improper payments have on state UI trust funds. Integrity efforts not only help
preserve these unemployment funds and control UI tax rates, but they also maintain the
public trust that the program is protected and operated as intended. As such, there will be a
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continued, intensified effort for ETA and the states to work collaboratively to aggressively
reduce improper payments.
Improving Program Performance Nationally
ETA has embarked on a multi-pronged strategy designed to significantly bolster program
accountability and facilitate performance improvement nationally. For FY 2015, ETA will
continue the following strategies to meet this objective:
• Provide high-emphasis technical assistance to support performance improvements for
“At-Risk” states (states with sustained poor performance);
• Continue to use the UI performance management system, UI Performs, which
includes core measures and Secretary’s Standards to monitor state performance; and
• Review and improve the SQSP process, including helping states to develop more
effective corrective action plans (CAPs) to help 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 UI Claimants
Reemployment of UI claimants remains a top priority for the entire workforce system,
including UI. The UI program is one of the required programs in the one-stop delivery
system under the WIA and must work collaboratively with workforce system programs to
fully connect UI claimants to the full range of reemployment services delivered through
American Job Centers, online, and through rapid response. Through initiatives such as
Reemployment and Eligibility Assessments and ETA’s more recent work with five pilot
states implementing strategies to achieve improved UI connectivity with the public
workforce system and improved reemployment service delivery strategies, states are
encouraged to continue to make progress in this area. ETA will focus significant technical
assistance resources this year to leverage the work of the five pilot states and to support the
next wave of states to implement enhanced reemployment strategies for UI claimants. ETA
will also continue to work with states that have Reemployment and Eligibility Assessment
grants to identify and share “best practices” and develop a more uniform national assessment
program. ETA is particularly interested in strategies that use data to better target
reemployment services and more quickly and precisely connect UI beneficiaries to job
opportunities and/or services that will speed their return to employment.
As states develop their SQSPs, they should consider including innovative and robust
reemployment strategies that are jointly developed in collaboration with workforce system
partners, including the WIA Adult and Dislocated Worker programs and the Wagner-Peyser
funded Employment Service program. These strategies may include:
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• Developing intake processes that produce a more complete profile on UI claimants so
that they can be targeted more efficiently with reemployment services and job
referrals;
• Connecting UI claimants as quickly as possible to the public labor exchange systems
so that they can start receiving job referrals immediately; and
• Using ongoing risk assessment to determine whether UI claimants are having a
difficult time finding a job and require additional services.
ETA recommends that UI program staff collaborate with these partners to ensure the
strategies reflect the agreement(s) made and are documented in each partner’s strategic plan.
Addressing Worker Misclassification
The President’s FY 2015 budget request includes a multi-agency initiative to dramatically
strengthen and coordinate Federal and state efforts to address employer misclassification of
workers. The goals are to:
• Improve Federal and state agency capacity to identify potential violators through
improved information sharing and targeted audits in high-risk industry sectors;
• Provide outreach to employers to educate them about proper worker classification
and, thereby, prevent misclassification;
• Increase statutory enforcement; and
• Enable the collection of payroll taxes previously lost due to misclassification.
As this Federal-state collaboration unfolds, ETA will make states aware of new opportunities
and strategies that may be available to address this problem.
The President’s FY 2015 budget request also includes $10 million for an initiative to increase
state capacity to address misclassification within the UI program. This request builds on the
$10 million appropriated for worker misclassification in FY 2014. This initiative would
provide 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,
establish a cross-state agency task force to target egregious employer schemes to avoid
taxation through misclassification, and develop education and outreach programs. States
should monitor their performance under the Effective Audit Measure to determine whether
they are effectively detecting and preventing worker misclassification. ETA will provide
states with additional guidance for this initiative when the FY 2015 budget is enacted.
States may deploy a wide array of other strategies in addition to these Federal strategies.
ETA encourages states to develop and implement state-driven strategies to address the
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misclassification of workers and to include those strategies in the state’s SQSP. ETA will
identify state “best practices” in this area and share them broadly.
Federal 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.
In recognition of the national priorities, attention continues to be focused on the following
GPRA goals for FY 2015, 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.
GPRA Strategic Goal 4: Secure retirement, health, and other employee benefits and,
for those working, provide income security.
GPRA Strategic Objective 4.1: Provide income support when work is impossible or
unavailable and facilitate return to work.
• Make Timely Benefit Payments
o Target: 87.5 percent of intrastate first payments for full weeks of unemployment
compensation will be made within 14/21 days from the week ending date of the
first compensable week.
• Detect Benefit Overpayments
o Target: Overpayments established will be at least 55.3 percent of the estimated
detectable, recoverable overpayments.
• Establish Tax Accounts Promptly
o Target: 89.0 percent of status determinations for new employers will be made
within 90 days of the end of the first quarter in which liability occurred.
• Facilitate the Reemployment of Claimants
o Target: No target has been set for FY 2015. In FY 2014, ETA established a
workgroup to develop a strategy for implementing a common integrated
reemployment measure that includes both UI and workforce system data. The
workgroup has identified the Labor Exchange Reporting System (LERS) as an
existing reporting mechanism capable of accomplishing this objective. Through
LERS, states and territories report on participant characteristics, services received,
and employment outcomes for participants enrolled in the Employment Service,
including participants that access the services through electronic means only. A
common integrated reemployment measure, the entered employment rate (EER),
is reported on the ETA 9002C report within LERS. Because Column C on that
report provides a breakout for Eligible Claimants, these data can be used to
compute an EER for UI claimants. ETA will continue to analyze this data in FYs
2014 and 2015 in order to develop a methodology for establishing national GPRA
measure and targets for implementation in FY 2016. Simultaneously, ETA will
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publish a Federal Register notice announcing and seeking comments on the
establishment of the EER as an official GPRA measure beginning in FY 2016.
5. SQSP Planning Guidance and Requirements. ET Handbook No. 336, 18th Edition,
Change 3, and this UIPL provide guidelines for the completion and submission of the SQSP
and should be used when preparing the SQSP for FY 2015.
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, CAPs and/or Narratives are expected whenever a state’s
performance does not meet established criteria for the SQSP measurement period (or
performance year) and remains uncorrected before the preparation of the SQSP. The
measurement period for the FY 2015 SQSP is April 1, 2013 – March 31, 2014, unless
otherwise indicated.
CAPs and Narratives addressing performance deficiencies are the components of the state’s
formal plan and schedule for improving performance; therefore, the causes of performance
shortfalls should be thoroughly analyzed before the development of the state’s 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 when due,” in
accordance with section 303(a)(1), SSA. To that end, ETA has identified persistently low
performing states as "At-Risk," requiring high emphasis for technical assistance and
monitoring. This collaborative process is expected to identify impediments to achieving
performance standards; action steps designed to improve performance; and technical
assistance strategies. The action strategies and technical assistance activities will become
part of the state’s SQSP CAP for those measures that have caused the state to be considered
“At-Risk.” ETA will notify states it selects to participate in the process.
States selected because of consistently significant low performance for the first payment and
appeals timeliness measures will work collaboratively with ETA to achieve performance
improvement. For a state to have the “At-Risk” designation removed, it must achieve six
months of meeting the standard and be likely to continue sustained improvement.
SQSP Assurances
By signing the SQSP Signature Page, a state certifies that it will comply with the assurances
listed in ET Handbook No. 336, 18th Edition, and that the state will institute plans or
measures to comply with the requirements for each of the assurances.
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, Section H, Assurances, states are expected to provide the dates that their
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Information Technology (IT) Contingency Plan, System Security Plan, and Risk Assessment
were implemented, tested, and reviewed/updated.
States must:
• 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 years.
If a state does not have 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 to meet these requirements in a CAP. 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 3.
6. SQSP Reform.
To ensure a viable SQSP and improve its quality, ETA is moving the states to a biennial
SQSP cycle beginning with the FY 2015 SQSP. This biennial SQSP process provides a 24-
month window for states to adequately plan and implement performance improvement
efforts. The new SQSP process provides for two types of submittals, i.e., a formal two-year
plan and an off-year SQSP Lite submissions.
States will submit budget worksheets and various assurances annually since funds for UI
operations are appropriated each year. These and other required documents related to the
Federal UI administrative funding process are to be submitted with both the Biennial SQSP
and the SQSP Lite.
SQSP Preparation and Submittal
SQSP Formal Submittal: The Biennial SQSP (the formal plan) consists of a complete SQSP
package. It must contain a transmittal letter, the State Plan Narrative, CAPs, the IAP, budget
worksheets/forms, assurances, organizational charts, a signature page, and other required
administrative documents as requested. For the two-year planning cycle, states must submit
quarterly targets and milestones for both years. A sample CAP format for the two-year
planning cycle is attached.
States may also develop extended multi-year CAPs so that efforts which must extend beyond
the two-year planning cycle 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 two-year SQSP planning cycle) but should provide
enough information to explain anticipated progress and results.
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SQSP Lite Submittal: The SQSP Lite submittal consists of items included in the state’s
request for Federal UI administrative funding, as well as ad hoc modifications to SQSPs.
Since states and ETA’s ROs will continue to review reported performance data, monitor
program performance, and initiate corrective actions when warranted, the SQSP Lite
submittal will require states to submit new CAPs and IAPs to describe, for example:
• Corrective actions the state will take based on findings made in RO performance
reviews; and
• New performance deficiencies identified in RO reviews of state performance data
during the most recent performance year.
States will be required to modify the State Plan Narrative, existing CAPs, and IAPs to
include, for example:
• Missed milestones; and
• New strategies for performance improvement.
SQSP Reform Implementation
Implementation for the new SQSP planning cycle will occur in a phased approach. Using the
FY 2015 SQSP as a baseline, one half of the states in each region will be assigned to Group 1
and will submit a complete SQSP package with two-year plans. Group 1 states will include
those states designated as High Priority and/or “At-Risk” and additional states to equate to
one half of the states from a given region. The remaining states will be assigned to Group 2
and will submit a complete SQSP package with one-year plans. Starting in FY 2016, all
states will be placed on a two-year plan cycle – that is, states that submitted an FY 2015
two-year SQSP will continue to submit two-year plans, and states that submitted an FY 2015
one-year plan will submit two-year plans. This means all states will submit two-year plans
going forward, but on alternating cycles. ROs will include submission requirements in their
annual instructions to the states in their regions.
An implementation timeline is as follows:
Implementation Timeline
FY 2015 FY 2016
Group 1 States Group 1 States
Formal SQSP Submittal SQSP Lite Submittal
On half of the states submit complete Submit abbreviated SQSP package, including
SQSP package with two-year plans. transmittal letter, budget worksheets/forms,
Signature Page, assurances, CAP/IAP
modifications, and new or modified organizational
charts.
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Also,
• New CAPs and IAPs for:
o On-site reviews that identifies a need for
corrective action
o New performance deficiencies identified
during PY 2015 (Apr 1, 2014 – Mar 31,
2015, unless otherwise indicated)
o Other identified deficiencies
• Modifications to existing CAPs and IAPs
for:
o Missed milestones
o New strategies for performance
improvement efforts
Group 2 States
Group 2 States
One half of states submit complete SQSP Formal SQSP Submittal
package with one-year plans
Submit complete SQSP package with two-year
plans
Additional descriptions of the formal SQSP submittal, SQSP Lite submittal, SQSP cycle
schedule, significant activities, and dates relating to the submittal and approval of the SQSP
are outlined in ET Handbook No. 336, 18th Edition.
States will continue to prepare and transmit an SQSP in accordance with the instructions in
ET Handbook No. 336. The primary change is that states will submit the formal SQSP once
every two years. The SQSP Lite submittal, as described above, will occur on the off-year of
the SQSP cycle. Regional and National Office staff and the state will routinely review
performance data to monitor program performance. This assessment will potentially lead to
corrective action for either the formal SQSP submittal or the SQSP Lite submittal. States
will continue to provide ROs with the status of corrective action efforts, no less than
quarterly.
7. SQSP Program Performance and Criteria for FY 2015.
Core Measures
Performance below the acceptable levels of performance (ALPs) is expected to be addressed
in a CAP unless otherwise indicated. Additional instructions for Core Measures are as
follows:
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• The Detection of Overpayments Measure.
This measure is the percentage of detectable/recoverable overpayments established for
recovery. States reporting an overpayment detection rate below 50 percent are expected
to address the deficiency in a CAP. Also, because states generally 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. States reporting ratios over 95
percent are expected to explain in the Narrative section the reasons for the higher-than-
expected ratios. If an overpayment rate above 95 percent is the result of improper
administration of BAM or Benefit Payment Control (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, 2014; the performance period for the BAM component is the
three-year period ending September 30, 2013.
• UI Integrity Measure - Benefit Year Earnings (BYE)
The UI Integrity Measure for BYE addresses the leading cause of UI improper payments
– claimants who return to work, fail to report earnings, and who continue to claim and
collect UI benefits. Performance will be measured by the state’s BYE overpayment rate,
estimated by the BAM survey, rather than the amount overpaid to control for year-to-year
changes in benefit outlays. Per UIPL No. 34-11, the ALP for the calendar year (CY)
2013 performance period is a 50 percent reduction in the state’s CY 2008 to CY 2010
baseline BYE rate. A state will meet the ALP if: 1) its BYE overpayment rate decreases
during the performance period by the percentage decrease specified for the period; or
2) its BYE overpayment rate decreases during the performance period and the rate is
below the national BYE overpayment rate by the target percentage decrease. States
failing to meet the ALP for the UI Integrity Measure for BYE will be expected to develop
a CAP as part of the FY 2015 SQSP. The CAP will address performance for CY 2013.
For the CY 2014 performance period, state ALPs have been set at a 25 percent reduction
from the state’s CY 2010 to CY 2012 baseline BYE rate. These performance targets were
established in UIPL No. 34-11, Change 1.
• Effective Audit Measure
The Effective Audit Measure, as noted in UIPL No. 03-11, 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
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among any of the four factors to attain the overall passing score of at least 7.0. States that
do not meet this measure will be expected to complete a CAP based on CY 2013 data.
• Improper Payments Measure
The Improper Payments Measure is defined as UI benefits overpaid and underpaid,
estimated from the results of the BAM survey of paid UI claims in the State UI,
Unemployment Compensation for Federal Employees (UCFE), and Unemployment
Compensation for Ex-Servicemembers (UCX) programs minus the amount of state UI,
UCFE, and UCX program overpayments recovered (reported on the ETA 227
Overpayment Detection and Recovery Report). This net amount is expressed as a
percentage of the amount of UI, UCFE, and UCX benefits paid.
In accordance with requirements in section 3(a)(3)(F), IPERA, the Department has
established an ALP of less than 10 percent for the improper payment measure. That is,
states must maintain a net improper payment rate of less than10 percent for covered
programs. This new ALP was applicable to the 2013 IPIA performance period (BAM
sampling weeks 201227 through 201326, which coincide with the period July 1, 2012, to
June 29, 2013). States failing to meet the ALP for the 2013 IPIA performance period will
be expected to develop a CAP as part of the FY 2015 SQSP.
The Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERIA)
requires agencies to include all identified improper payments in the reported estimate,
regardless of whether the improper payment in question has been or is being recovered.
The Department is in consultation with OMB regarding an alternative methodology for
estimating the improper payment rate. This measure will be revised for the 2014
performance period pending OMB approval of the new methodology.
• UI Overpayment Recovery Measure
Pursuant to Section 3(a)(3)(F) of IPERA and UIPL No. 09-13, the recovery rate is “the
amount of improper overpayments recovered divided by the amount of improper
overpayments identified.” To establish the ALP for the proposed measure, the
Department conducted an analysis of the UI payment, overpayment detection, and
recovery data and proposed to establish recovery targets of 55 percent for the 2013 IPIA
reporting period, and 58 percent for the 2014 IPIA reporting 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 the ETA 227 and ETA 227 Emergency
Unemployment Compensation (EUC) data for the IPIA period (July 1 to June 30 of the
IPIA reporting year). Pursuant to the UI Reports Handbook (ET Handbook No. 401, 4th
edition), the June quarter ETA 227 reports are due August 1st. The first measurement
period was July 1, 2012 to June 30, 2013. States failing to meet the ALP for the 2013
IPIA performance period will be expected to develop a CAP as part of the FY 2015
SQSP.
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Secretary’s Standards
Performance below the criteria for the Secretary’s Standards established in regulation at 20
CFR Parts 640 and 650 is expected to be addressed in a CAP.
UI Programs
• 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. 3-07 and UIPL No. 3-07, Change 1, must be addressed in a CAP
for FY 2015.
• BAM
State BAM operations or operational components that, based on the BAM Administrative
Determination, are not compliant with investigative and/or method and procedure
requirements established in ET Handbook No. 395, 5th Edition, must be addressed in a
CAP. This includes paid and denied claim population variances outside established
control limits.
• 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 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 was June 10, 2014. DV items that failed to pass
validation or that were not submitted are expected to be addressed in the state’s FY 2015
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, 2014 certification
window.
Any DV items due for Validation Year 2014 that do not pass--not submitted or submitted
with failing results--by the June 10, 2014, deadline, must be addressed in a CAP for FY
13
2015. This is a change from FY 2014, when a state that had submitted all items due
could address failed ones in a narrative.
ROs will monitor states every three years, on cycles coinciding with the DV validation
year. They will assess accuracy of the state’s DV results considered passing or not due as
of the time of the monitoring visit to verify that that the states are properly implementing
the DV program. DV items submitted as passing but which a monitoring review
determined to have failed will be addressed in the SQSP process according to the
following schedule:
The FY 2015 SQSP will include DV items failing after review in the VY 2013
and 2014 monitoring cycles (monitored by June 10, 2014); and
The FY 2016 SQSP will include DV items failing after review in the VY 2015
monitoring cycle (monitored between June 11, 2014 and June 10, 2015).
Based on the plan described, the DV monitoring schedule and the SQSP schedule should
align beginning with the FY 2015 SQSP.
• UI Program Integrity
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. For FY 2015, states are required to
report their planned activities to prevent, detect, reduce, and recover improper UI
payments in their Program Integrity Action Plan, which should be submitted as part of
their annual SQSP submission.
To update their Program Integrity Action Plan, states must analyze their BAM data to
identify the top root causes for improper payments and develop strategies that will be
effective in reducing or recovering improper payments. The most recent state data are
available at the Department’s Web site at http://www.dol.gov/dol/maps/map-ipia.htm.
ETA will continue to provide technical assistance to states to support their integrity
activities through webinars, individual state technical assistance, and in partnership with
the UI Integrity Center of Excellence. 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 NDNH and other
overpayment prevention tools for BPC.
The UI Program Integrity Action Plan and instructions are included as Attachment C.
14
Other UI Performance
States are expected to address the following performance deficiencies in the SQSP Narrative:
• 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 percent 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 in the SQSP Narrative.
Attachment A lists the performance criteria for the Core Measures, Secretary’s Standards and
other program requirements where CAPs and/or Narratives may be required if annual
performance is not acceptable.
8. Funding Period. The Department proposes appropriations language for obligation of FY 2015
UI allocations by states through December 31, 2015, with 90 additional days to liquidate the
obligations and complete the expenditure of funds. Under this proposed appropriations
language, states may obligate FY 2015 UI funds through September 30, 2017, if such
obligations are for automation acquisitions or competitive grants awarded to states for
improved operations; reemployment and eligibility assessments and improper payments; or
activities to address worker misclassification. Therefore, if Congress adopts the proposed
appropriations language, the end of the FY 2015 obligation period for regular state UI
administrative funds will be December 31, 2015, for all funds except automation acquisitions,
improved operations, reemployment and eligibility assessments, and improper payments or
misclassification activities, which have an obligation deadline of September 30, 2017. The
Department will notify state agencies if Congress adopts this language.
9. Data Availability. ROs will provide states with reports showing their performance
measured against the Core Measures, Secretary’s Standards and other information relevant to
the SQSP (e.g., reporting deficiencies).
10. Deadline for State SQSP Submittal. Each RO will set a deadline for states to submit their
SQSPs for FY 2015.
15
11. Electronic Submission of the SQSP. States must submit the SQSP electronically and
should contact their RO SQSP Coordinator 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 3) are available in PDF format and may be downloaded from
the OMB 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.
12. 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 3;
• Coordinate specifics, as appropriate, with the RO for electronic submission of the plan;
and
• Submit the FY 2015 SQSP by the dates specified to the appropriate RO.
13. Inquiries. Questions should be directed to the appropriate RO.
14. Attachments.
A. Measures/Programs to be addressed in the FY 2015 SQSP
B. Unemployment Insurance (UI) Program Integrity Action Plan
C. New Sample CAP format
16
Attachment A
Measures/Programs to be Addressed in the Fiscal Year (FY) 2015
State Quality Service Plan (SQSP)
Core Measures Measurement Period Criteria CAP Narrative
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 87% √
Nonmonetary Determination Time Apr 1, 2013 – Mar 31, 2014 80% √
Lapse (combined score)
Nonmonetary Determination Quality Apr 1, 2013 – Mar 31, 2014 75% √
– Nonseparations
Nonmonetary Determination Quality Apr 1, 2013 – Mar 31, 2014 75% √
– Separations
Detection of Overpayments BPC: Apr 1, 2011 – Mar 31, <50% √
2014; >95% √
BAM: Oct. 1, 2010 –
Sept. 30,2013
If the rate is a result of
improper administration of >95% √
BAM and/or BPC
Average Age of Pending Lower Apr 1, 2013 – Mar 31, 2014 30 days √
Authority Appeals
Average Age of Pending Higher Apr 1, 2013 – Mar 31, 2014 40 days √
Authority Appeals
Lower Authority Appeals Quality Apr 1, 2013 – Mar 31, 2014 80% √
New Employer Status Jan 1, 2013 – Dec 31, 2013 70% √
Determinations Time Lapse
Tax Quality (Part A: No more than Jan 1, 2013– Dec 31, 2013 ← √
3 tax functions failing Tax
Performance System (TPS) in a year)
Tax Quality (Part B: The same tax Jan 1, 2013 – Dec 31, 2013 ← √
function cannot fail for 3 consecutive
years)
Facilitate Reemployment 1st Payments: October 1, Varies by State
2012 to September 30, 2013
Reemployment: January 1, √
2013 to December 31, 2013
UI Integrity Measure – Benefit Year BAM batches 201301 to 50% reduction from √
Earnings (BYE) 201352 (Dec. 30, 2012 – State’s CY 2008 - CY
Dec 28, 2013) 2010 baseline BYE rate
Effective Audit Measure Jan 1, 2013 – Dec 31, 2013 Score >7;and exceed √
all 4 factors
Improper Payments Measure BAM: Batches 201227 to
201326 (July 1, 2012 to June < 10%
29, 2013) √
BPC: July 1, 2012 – June 30,
2013
UI Overpayment Recovery Measure July 1, 2012 – June 30, 2013 √
55%
Measures/Programs to be Addressed in the Fiscal Year (FY) 2015
State Quality Service Plan (SQSP) (cont’d)
Measurement Period Criteria CAP Narrative
Secretary’s Standards in
Regulation
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 87% √
(IntraState 14/21 Days)
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 93% √
(IntraState 35 Days)
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 70% √
(InterState 14/21 Days)
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 78% √
(InterState 35 Days)
Lower Authority Appeals (30 Days) Apr 1, 2013 – Mar 31, 2014 60% √
Lower Authority Appeals (45 Days) Apr 1, 2013 – Mar 31, 2014 80% √
UI Programs, etc. Measurement Period CAP Narrative
Data Validation Apr 1, 2013 – Mar 31, 2014
Results not submitted by June √
10, 2014
_________________________
Failing/incomplete submission Apr 1, 2013 – Mar 31, 2014 √
by June 10, 2014
Compliance with NDNH matching Status as of March 31, 2014 √
requirements for BAM
BAM operations not compliant with Jan 1, 2013 – Dec 31, 2013 √
investigative and /or method and
procedure requirements
Incorrect recording of the Issue Apr 1, 2013 – Mar 31, 2014 √
Detection Date and/or
Determination Date
TPS Sample Reviews Jan 1, 2013 – Dec 31, 2013 √
UI Program Integrity To be
addressed
in the UI
Integrity
Action Plan
2
Attachment B
Unemployment Insurance (UI) Program Integrity Action Plan
State: (Name of state) Federal Fiscal Year: (SQSP Planning Year)
Root Causes:
(List the top three root causes of improper payments in the state for the most recent IPIA period, and
percentage change for each cause compared to the prior year’s IPIA rate.
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.)
Strategies Actions/ Targets and Milestones Resources
This section should be
List the specific action
divided into target and
steps for each strategy Provide a description of the
milestones. Specific
List the strategies that that the state is taking. type of resources, e.g. human
milestones should be set
the state is taking to If a Plan is already in capital, technology and other
for each of the actions. It
address UI improper place, list continuing tools that have been designated
is suggested that the
payments. actions/activities first to address the state’s UI
milestones be set
and then any new improper payments.
quarterly under each
actions/activities.
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 IPERA, we are requiring State Workforce Agencies (SWAs) to report their
planned activities to prevent, detect, reduce, and recover improper UI payments in a UI 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 the recovery of
improper payments;
• Timeline, expected targets and measures;
• Type and source of resources dedicated to accomplish the action plan; and
• Outcomes from the previous year’s strategies to address root causes of improper
payments.
To help the SWAs plan, the Employment and Training Administration (ETA) will provide each
state with state-specific Benefit Accuracy Measurement (BAM) improper payment estimates,
with data and the annual trend for the top root causes of overpayments. SWAs are strongly
encouraged to implement new strategies to address root causes with negative trends in improper
payments.
Program Integrity Action Plan Specifics
The plan must identify the SWA officer(s) accountable for reducing improper payments,
summarize the SWA’s assessment of 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
agency’s 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 must use
the BAM improper payment estimates we provide to describe their strategies to prevent,
detect, and/or reduce each root cause. Additionally, the strategies must 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:
2
• 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 before 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) Implementing the State Information Data Exchange System (SIDES) designed to
improve the quality and timeliness of separation information;
(4) Reviewing state law, rules and regulations, business processes, and goals that are
concerned with employment service (ES) registration and aligning 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 enough information
during the initial claims process to register the claimant for services. This
information is transmitted to ES and the system shows an active registration.
(5) Using 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 between weekly certifications. 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-to-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;
3
(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 after the payment. These are actions that the
state controls and usually involve crossmatch activities such as:
(1) National Directory of New Hire Crossmatching – check crossmatch time
parameters and agency filters, and 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) No. 19-11, National Effort to Reduce Improper
Payments in the Unemployment Insurance (UI) Program;
(3) Wage Record Crossmatching – check the index calculation to ensure that it
reflects current earnings-disregard standards, run the wage record crossmatch for
nine 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 must specify the actions they plan to take to recover overpayments
and plans to improve the recovery of overpayments. (See UIPL No. 33-99,
4
Overpayment Recovery Technical Assistance Guide, available at
http://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=1788). Examples of this
would be:
(1) Redesign of the BPC overpayment recovery workflow process;
(2) Streamline administrative activities and/or automation of skip tracing and
collection notices to claimants;
(3) Implementation of the Federal Tax Offset Program (TOP) with the
Department of the Treasury; and
(4) Implementation of a state Income Tax Offset program.
B. Targets and Timeline. When designing strategies to address improper payments, agencies
must 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. ETA
encourages states to develop realistic multi-year initiatives.
C. Resource Allocation. The plan must include a description of the type of resources such as
human capital, technology and other tools that will be used to prevent, detect, reduce and
recover improper payments.
D. Outcomes from Last Year’s Strategies. Agencies must include a brief summary discussion of
the implementation outcomes from the previous year’s integrity strategic plan, noting
whether the strategy implementation was completed, indicating known results, and/or
discussing delays or barriers that prevented completion of the strategy implementation.
5
Attachment C
CORRECTIVE ACTION PLAN
Federal Fiscal Years: ___________ MEASURE/PROGRAM AREA:
State: _______________ (ex. FY 2015 – FY 2016) ______________________________________________________
(Use descriptors contained in Appendix III of the SQSP Handbook)
Projected Performance Levels:
Current Performance Level: _______
(as of 3/31 or most recent _________ ________ ________ ________ ________ ________ ________ ________
performance) (12/31/__) (3/31/__) (6/30/__) (9/31/__) (12/31/__) (3/31/__) (6/30/__) (9/30/__)
SUMMARY:
The Summary must provide:
A. The reason(s) for the deficiency;
B. A description of the actions/activities which will be undertaken to improve performance and;
C. If a plan was in place the previous fiscal year, an explanation of why the actions contained in that plan were not successful in improving performance, and
an explanation of why the actions now specified will be more successful; and
D. A brief description of plans for monitoring and assessing accomplishment of planned actions and for controlling quality after achieving performance goals.
If the desired improvement will not be accomplished by the end of the current fiscal years (the two consecutive fiscal years for which the plan is in effect), also
indicate the major actions remaining to be taken in subsequent fiscal years, and a projection as to when the performance goal will be achieved.
MILESTONES: (Number sequentially) Completion Date*
12/31 03/31 06/30 09/30 12/31 03/31 06/30 09/30
Milestones should be established for each core element of the state’s
corrective action plan and be of sufficient number and frequency to facilitate
state and regional plan oversight and assessment during the fiscal year(s). It
is anticipated that one or more milestones for each quarter would permit such
progress tracking and assessment during the fiscal year(s) through state and
regional follow-up schedules.
States also may wish to identify performance milestones that reflect the
performance level they anticipate will result from completion of planned
activities.
{} If continued, check box
* States should use a √ to indicate the quarter the milestone is expected to be completed.
Attachment 1 (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2014/UIPL_21-14_Attachment_A_Acc.pdf)
Attachment A
Measures/Programs to be Addressed in the Fiscal Year (FY) 2015
State Quality Service Plan (SQSP)
Core Measures Measurement Period Criteria CAP Narrative
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 87% √
Nonmonetary Determination Time Apr 1, 2013 – Mar 31, 2014 80% √
Lapse (combined score)
Nonmonetary Determination Quality Apr 1, 2013 – Mar 31, 2014 75% √
– Nonseparations
Nonmonetary Determination Quality Apr 1, 2013 – Mar 31, 2014 75% √
– Separations
Detection of Overpayments BPC: Apr 1, 2011 – Mar 31, <50% √
2014; >95% √
BAM: Oct. 1, 2010 –
Sept. 30,2013
If the rate is a result of
improper administration of >95% √
BAM and/or BPC
Average Age of Pending Lower Apr 1, 2013 – Mar 31, 2014 30 days √
Authority Appeals
Average Age of Pending Higher Apr 1, 2013 – Mar 31, 2014 40 days √
Authority Appeals
Lower Authority Appeals Quality Apr 1, 2013 – Mar 31, 2014 80% √
New Employer Status Jan 1, 2013 – Dec 31, 2013 70% √
Determinations Time Lapse
Tax Quality (Part A: No more than Jan 1, 2013– Dec 31, 2013 ← √
3 tax functions failing Tax
Performance System (TPS) in a year)
Tax Quality (Part B: The same tax Jan 1, 2013 – Dec 31, 2013 ← √
function cannot fail for 3 consecutive
years)
Facilitate Reemployment 1st Payments: October 1, Varies by State
2012 to September 30, 2013
Reemployment: January 1, √
2013 to December 31, 2013
UI Integrity Measure – Benefit Year BAM batches 201301 to 50% reduction from √
Earnings (BYE) 201352 (Dec. 30, 2012 – State’s CY 2008 - CY
Dec 28, 2013) 2010 baseline BYE rate
Effective Audit Measure Jan 1, 2013 – Dec 31, 2013 Score >7;and exceed √
all 4 factors
Improper Payments Measure BAM: Batches 201227 to
201326 (July 1, 2012 to June < 10%
29, 2013) √
BPC: July 1, 2012 – June 30,
2013
UI Overpayment Recovery Measure July 1, 2012 – June 30, 2013 √
55%
Measures/Programs to be Addressed in the Fiscal Year (FY) 2015
State Quality Service Plan (SQSP) (cont’d)
Measurement Period Criteria CAP Narrative
Secretary’s Standards in
Regulation
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 87% √
(IntraState 14/21 Days)
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 93% √
(IntraState 35 Days)
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 70% √
(InterState 14/21 Days)
First Payment Promptness Apr 1, 2013 – Mar 31, 2014 78% √
(InterState 35 Days)
Lower Authority Appeals (30 Days) Apr 1, 2013 – Mar 31, 2014 60% √
Lower Authority Appeals (45 Days) Apr 1, 2013 – Mar 31, 2014 80% √
UI Programs, etc. Measurement Period CAP Narrative
Data Validation Apr 1, 2013 – Mar 31, 2014
Results not submitted by June √
10, 2014
_________________________
Failing/incomplete submission Apr 1, 2013 – Mar 31, 2014 √
by June 10, 2014
Compliance with NDNH matching Status as of March 31, 2014 √
requirements for BAM
BAM operations not compliant with Jan 1, 2013 – Dec 31, 2013 √
investigative and /or method and
procedure requirements
Incorrect recording of the Issue Apr 1, 2013 – Mar 31, 2014 √
Detection Date and/or
Determination Date
TPS Sample Reviews Jan 1, 2013 – Dec 31, 2013 √
UI Program Integrity To be
addressed
in the UI
Integrity
Action Plan
2
Attachment 2 (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2014/UIPL_21-14_Attachment_B_Acc.pdf)
Attachment B
Unemployment Insurance (UI) Program Integrity Action Plan
State: (Name of state) Federal Fiscal Year: (SQSP Planning Year)
Root Causes:
(List the top three root causes of improper payments in the state for the most recent IPIA period, and
percentage change for each cause compared to the prior year’s IPIA rate.
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.)
Strategies Actions/ Targets and Milestones Resources
This section should be
List the specific action
divided into target and
steps for each strategy Provide a description of the
milestones. Specific
List the strategies that that the state is taking. type of resources, e.g. human
milestones should be set
the state is taking to If a Plan is already in capital, technology and other
for each of the actions. It
address UI improper place, list continuing tools that have been designated
is suggested that the
payments. actions/activities first to address the state’s UI
milestones be set
and then any new improper payments.
quarterly under each
actions/activities.
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 IPERA, we are requiring State Workforce Agencies (SWAs) to report their
planned activities to prevent, detect, reduce, and recover improper UI payments in a UI 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 the recovery of
improper payments;
• Timeline, expected targets and measures;
• Type and source of resources dedicated to accomplish the action plan; and
• Outcomes from the previous year’s strategies to address root causes of improper
payments.
To help the SWAs plan, the Employment and Training Administration (ETA) will provide each
state with state-specific Benefit Accuracy Measurement (BAM) improper payment estimates,
with data and the annual trend for the top root causes of overpayments. SWAs are strongly
encouraged to implement new strategies to address root causes with negative trends in improper
payments.
Program Integrity Action Plan Specifics
The plan must identify the SWA officer(s) accountable for reducing improper payments,
summarize the SWA’s assessment of 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
agency’s 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 must use
the BAM improper payment estimates we provide to describe their strategies to prevent,
detect, and/or reduce each root cause. Additionally, the strategies must 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:
2
• 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 before 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) Implementing the State Information Data Exchange System (SIDES) designed to
improve the quality and timeliness of separation information;
(4) Reviewing state law, rules and regulations, business processes, and goals that are
concerned with employment service (ES) registration and aligning 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 enough information
during the initial claims process to register the claimant for services. This
information is transmitted to ES and the system shows an active registration.
(5) Using 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 between weekly certifications. 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-to-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;
3
(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 after the payment. These are actions that the
state controls and usually involve crossmatch activities such as:
(1) National Directory of New Hire Crossmatching – check crossmatch time
parameters and agency filters, and 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) No. 19-11, National Effort to Reduce Improper
Payments in the Unemployment Insurance (UI) Program;
(3) Wage Record Crossmatching – check the index calculation to ensure that it
reflects current earnings-disregard standards, run the wage record crossmatch for
nine 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 must specify the actions they plan to take to recover overpayments
and plans to improve the recovery of overpayments. (See UIPL No. 33-99,
4
Overpayment Recovery Technical Assistance Guide, available at
http://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=1788). Examples of this
would be:
(1) Redesign of the BPC overpayment recovery workflow process;
(2) Streamline administrative activities and/or automation of skip tracing and
collection notices to claimants;
(3) Implementation of the Federal Tax Offset Program (TOP) with the
Department of the Treasury; and
(4) Implementation of a state Income Tax Offset program.
B. Targets and Timeline. When designing strategies to address improper payments, agencies
must 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. ETA
encourages states to develop realistic multi-year initiatives.
C. Resource Allocation. The plan must include a description of the type of resources such as
human capital, technology and other tools that will be used to prevent, detect, reduce and
recover improper payments.
D. Outcomes from Last Year’s Strategies. Agencies must include a brief summary discussion of
the implementation outcomes from the previous year’s integrity strategic plan, noting
whether the strategy implementation was completed, indicating known results, and/or
discussing delays or barriers that prevented completion of the strategy implementation.
5
Attachment 3 (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/UIPL/2014/UIPL_21-14_Attachment_C_Acc.pdf)
Attachment C
CORRECTIVE ACTION PLAN
Federal Fiscal Years: ___________ MEASURE/PROGRAM AREA:
State: _______________ (ex. FY 2015 – FY 2016) ______________________________________________________
(Use descriptors contained in Appendix III of the SQSP Handbook)
Projected Performance Levels:
Current Performance Level: _______
(as of 3/31 or most recent _________ ________ ________ ________ ________ ________ ________ ________
performance) (12/31/__) (3/31/__) (6/30/__) (9/31/__) (12/31/__) (3/31/__) (6/30/__) (9/30/__)
SUMMARY:
The Summary must provide:
A. The reason(s) for the deficiency;
B. A description of the actions/activities which will be undertaken to improve performance and;
C. If a plan was in place the previous fiscal year, an explanation of why the actions contained in that plan were not successful in improving performance, and
an explanation of why the actions now specified will be more successful; and
D. A brief description of plans for monitoring and assessing accomplishment of planned actions and for controlling quality after achieving performance goals.
If the desired improvement will not be accomplished by the end of the current fiscal years (the two consecutive fiscal years for which the plan is in effect), also
indicate the major actions remaining to be taken in subsequent fiscal years, and a projection as to when the performance goal will be achieved.
MILESTONES: (Number sequentially) Completion Date*
12/31 03/31 06/30 09/30 12/31 03/31 06/30 09/30
Milestones should be established for each core element of the state’s
corrective action plan and be of sufficient number and frequency to facilitate
state and regional plan oversight and assessment during the fiscal year(s). It
is anticipated that one or more milestones for each quarter would permit such
progress tracking and assessment during the fiscal year(s) through state and
regional follow-up schedules.
States also may wish to identify performance milestones that reflect the
performance level they anticipate will result from completion of planned
activities.
{} If continued, check box
* States should use a √ to indicate the quarter the milestone is expected to be completed.
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