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Benefit Accuracy Measurement changes during the pandemic
Summary ETA directed states to modify Benefit Accuracy Measurement software and case handling in response to increased unemployment claims and the temporary Federal Pandemic Unemployment Compensation program. It addresses sample selection, population counts and investigations, with detailed questions and answers in the attachments. State UI program integrity staff were the intended readers.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 25-20
Date issued
June 15, 2020
Status
Active
ETA’s listing marks this letter Active, and its PDF prints “Rescissions: None” and “Expiration Date: Continuing.” Its operating changes address temporary pandemic program workloads.
Status last verified October 24, 2026
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About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
EMPLOYMENT AND TRAINING ADMINISTRATION Unemployment Insurance
ADVISORY SYSTEM CORRESPONDENCE SYMBOL
U.S. DEPARTMENT OF LABOR
OUI/DPM
DATE
Washington, D.C. 20210
June 15, 2020
ADVISORY: UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 25-20
TO: STATE WORKFORCE AGENCIES
FROM: JOHN PALLASCH
Assistant Secretary
SUBJECT: Benefit Accuracy Measurement (BAM) Program Operations in
Response to the Coronavirus Disease of 2019 (COVID-19) Pandemic
1. Purpose. The purpose of this Unemployment Insurance Program Letter (UIPL) is to
provide guidance to State Workforce Agencies on changes in the operation of the BAM
program, including BAM sample selection and case management applications, as a result of
issues arising from the COVID-19 pandemic. These COVID-19-related issues include the
unprecedented increases in Unemployment Insurance (UI) program workloads and the new
Unemployment Compensation (UC) programs created in the Coronavirus Aid, Relief, and
Economic Security (CARES) Act (Public Law 116-136), including the Federal Pandemic
Unemployment Compensation (FPUC) program, which provides a federal payment of $600
in addition to the state Weekly Benefit Amount (WBA).
2. Action Requested. The U.S. Department of Labor’s (Department) Employment and Training
Administration (ETA) requests that State Workforce Administrators provide the information in
this UIPL and its attachments to the appropriate program staff in order to guide the state in
reprogramming and modifying the BAM software applications to ensure the continued proper
operation of the BAM program.
3. Summary and Background.
a. Summary – This UIPL provides guidance to states on the operation of the BAM
program, including: 1) required modifications of the BAM software application due to
increases in UI claims workload and the enactment of the FPUC program; 2) required
revisions to existing BAM sample selection, population count, and case management
software applications; and 3) answers to questions received regarding BAM program
operations.
b. Background – On March 27, 2020, the President signed into law the CARES Act, which
includes the Relief for Workers Affected by Coronavirus Act set out in Title II, Subtitle
A. The CARES Act was designed to respond to the economic effects of the COVID-19
pandemic. Section 2104 of the CARES Act authorizes the temporary FPUC program,
providing eligible individuals with $600 per week in addition to the WBA received from
RESCISSIONS EXPIRATION DATE
None Continuing
designated UC programs.
States play a fundamental role in ensuring the integrity of the UI program. In the midst
of current extraordinary workloads, it remains vital that states continue to operate their
programs, both new and existing, in conformity and compliance with federal laws and
guidance and promote program integrity. The BAM program is one of the most
important tools to measure UI payment integrity. The large increase in UI workloads
and the additional provisions of the CARES Act present unique challenges to the
accurate and timely reporting of BAM data. This UIPL describes the changes that are
required in the BAM sample selection, population counts, and case management
software applications.
4. Changes in the BAM Program. The BAM program is an integrity assessment tool.
Representative samples of UI payments and disqualifying ineligibility determinations are drawn
and comprehensively investigated to determine whether they were properly administered to
claimants and whether these claimants were paid the proper amounts, or appropriately denied.
Based on the errors identified and information gathered, states can develop and implement
corrective actions to ensure accurate administration of state law, rules, and procedures.
See BAM State Operations Handbook (ET Handbook No. 395, 5th edition (ET Handbook 395))
for additional details about BAM program administration. Questions and Answers related to
BAM program operations are provided in Attachment IV of this UIPL.
a. BAM Sample Selection and Population Counts. The state selects weekly samples of
BAM paid weeks and monetary, separation, and nonseparation denials using either a
Common Business-Oriented Language (COBOL) program provided by the Department or a
software application developed by the state that complies with the Department’s
specifications in the ET Handbook 395. With the large increase in UC claims as a result of
the COVID-19 pandemic, several data elements in the current software cannot
accommodate the population workload counts or the paid benefit amounts that states must
report.
The State UI Transaction file includes all records that meet the definition for inclusion in
one of the four BAM populations (paid benefits, monetary denials, separation denials, and
non-separation denials). The weekly sfsum.dat file consists of aggregate sample and
population data for the four BAM populations. This data includes selected characteristics
that are used to conduct statistical tests of sample validity. The weekly rec1.dat file consists
of claimant data obtained from the state database for cases selected for the four BAM
populations. See Chapter III of ET Handbook 395 for additional information on the State
UI Transaction file, sfsum.dat file, and rec1.dat file.
The UI Transaction file, sfsum.dat file, and rec1.dat files are interdependent and so an error
in any of these files creates an issue for administration of the entire BAM program. The
BAM COBOL program can accommodate only six digits for all population fields and nine
digits for the population amount of benefits paid in the sfsum.dat file. Therefore, states
where the number of weeks paid exceeds 999,999 or the amount of payments exceeds
$999,999,999 should temporarily suspend the BAM sampling process until changes to the
sfsum.dat, rec1.dat, and BAM case management software have been completed. States
should retain each week’s UI Transaction file so that these samples and population counts
2
can be reconstructed retroactively when changes to the software application have been
completed.
States with workload counts that can be accommodated by the existing sfsum.dat file (that
is, UI weeks paid less than or equal to 999,999 and UC payments less than or equal to
$999,999,999) should continue to enter UC payment amounts based on ONLY the state
WBA (i.e., not include the $600 FPUC) in the following files:
Max Pay field (positions 57 to 59) of the COBOL Control Record (or the equivalent in a
State-developed program);
Amount Paid to Claimant (Item #13) in the UI Transaction file;
Amount of Offset Applied (Item #14) in the UI Transaction file;
Amount of Intercept or Withholding (Item #15) in the UI Transaction file;
Total Amount Paid to Claimant (Item #21) in the UI Transaction file;
WBA (Before Investigation) (Item #29) in the rec1.dat file; and
Amount Paid and/or Offset (Item #62) in the rec1.dat file.
Required Changes to the BAM Files
Every state must make the following changes to either the BAM COBOL program or the
state-developed Sample Selection and Population Count software by BAM Batch 202027
(i.e., the week ending July 4, 2020). The Department will revise and deploy the BAM case
management software applications (Case Conversion, Update Cases, Reopen Cases, and
Environment Settings) in June 2020.
i. UI Transaction file:
States must make the following changes to the UI Transaction file. The following
data elements will increase from three positions to four positions:
Item No. Name
13 Amount Paid to Claimant
14 Amount Offset
15 Amount of Intercept
Total Amount "Paid"
21
Sum of items 13, 14, and 15
The UI Transaction file specifications are provided in Attachment I of this UIPL.
ii. sfsum.dat file:
States must make the following changes to the sfsum.dat file.
o Increase all population fields from six positions to seven positions.
o Increase the Amount of Population UI Benefits Paid from nine positions to ten
positions.
3
The sfsum.dat file specifications are provided in Attachment II of this UIPL.
iii. rec1.dat file:
States must make the following change to the rec1.dat file.
WBA (Before Investigation) (Item #29) will increase from 3 positions to 4
positions.
The rec1.dat specifications are provided in Attachment III of this UIPL.
iv. Control Record:
The BAM COBOL sample selection and population count programs require a
Control Record. The purpose of the file is to specify the batch from which the BAM
paid, monetary, separation, and nonseparation samples are selected, the sample sizes
and random start numbers for these samples, the beginning and ending dates of the
requested batch, and the maximum WBA in the state, including dependents’
allowances (referred to as Max Pay in the file). The record format of the Control
Record is included in Chapter III of the ET Handbook 395.
States using the existing COBOL programs must modify the Control Record to
increase the Max Pay field from three to four positions (positions 57 to 60). States
that have developed their own BAM sample selection and population count
programs will have to ensure the same functionality as the Control Record.
Whether a state modifies the BAM COBOL program or a program developed by the
state that is the functional equivalent of the BAM COBOL program, the state must
ensure that the modified sfsum.dat and rec1.dat files conform to the specifications
required in this UIPL. Specifically, each state must ensure that each record in the
files consists of 80-character lines. Positions 1 through 79 of each line must contain
data or spaces (HEX ‘20’, Octal ‘040’, for example). Position 80 on each line must
be coded with a line feed (for example, ASCII - 10, HEX ‘0A’, EBCDIC 25, or
Octal ‘012’).
b. BAM Data Elements. Data from each case sampled for BAM are entered into a database
on the state’s Unemployment Insurance Database System (Sun Server). The data are
obtained both from existing records and from case investigations. See Chapter IV of ET
Handbook 395. The following section describes specific data elements that must be
updated to accommodate the large increase in UI workload. Additionally, the Department
will modify the BAM Case Conversion, Update Cases, Reopen Cases, and Environment
Settings software with a planned release in June 2020.
States must reopen completed BAM cases to revise data as a result of the release of the
revised software (for example, entering the FPUC amount or improper payments that
exceed $999) will reopen these cases using Reopen Code ‘9’. Case completion timeliness
will not be recalculated.
4
i. For sampled UC payments where FPUC was paid to the claimant for that week,
states must enter the amount of this supplemental federal payment in data element
d7. This data element is currently defined as Tax Rate for Last Employer. As of the
release of the BAM revised software associated with this UIPL, states should stop
collecting the tax rate information for the d7 element. The data element will be
redefined as:
(d7) Federal Supplemental Payment
Definition: Enter the amount of any federal supplemental payment associated
with the UI claim (for example, FPUC dollars) that are paid to the claimant
for the Key Week (KW), whether paid in a single payment or as a separate
payment for the KW sampled. Enter whole dollar amount of the federal
supplemental payment.
Format: money (4,0)
ii. Other changes to data elements in the BAM database are summarized in the
following tables.
Data Elements in b_master Data Elements in b_master
as Currently defined as of May 2020: as Revised in June 2020:
Element Data Item Element Data Item
Name Type Name Name Type Name
e9 money(3,0) WBA Before e9 money(4,0) WBA Before
e10 money(3,0) WBA After e10 money(4,0) WBA After
Amount Should Have Amount Should
h2 money(3,0) h2 money(4,0)
Been Paid Have Been Paid
h3 <=$50,000 Total Amount OP h3 <=$99,999 Total Amount OP
h5 money(3,0) Tot KW OP h5 money(4,0) Tot KW OP
h6 money(3,0) Tot KW UP h6 money(4,0) Tot KW UP
Data Element in b_errisu Data Elements in b_master
as Currently defined in May 2020: as Revised in June 2020:
Column Type Name Column Type Name
ei1 money(3,0) Amount of KW Error ei1 money(4,0) Amount of KW Error
Data Elements in b_dca_master Data Elements in b_dca_master
as Currently defined in May 2020: as Revised in June 2020:
Element Data Item Element Data Item
Name Type Name Name Type Name
Wbabef money(3,0) WBA Before wbabef money(4,0) WBA Before
Wbaaft money(3,0) WBA After wbaaft money(4,0) WBA After
5. Inquiries. Please direct questions to the appropriate Regional Office.
5
6. References.
Section 2104 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L.
116-136), including Title II Subtitle A, Relief for Workers Affected by Coronavirus Act;
The Families First Coronavirus Act, (Public Law 116-127), specifically Division D, the
Emergency Unemployment Insurance Stabilization and Access Act of 2020;
20 C.F.R. Part 602, Quality Control in the Federal-State Unemployment Insurance System;
UIPL No, 10-20, Unemployment Compensation (UC) for Individuals Affected by the
Coronavirus Disease 2019 (COVID-19), issued March 12, 2020,
https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8893;
UIPL No. 13-20, Families First Coronavirus Response Act, Division D Emergency
Unemployment Insurance Stabilization and Access Act of 2020, issued March 22, 2020,
https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8634;
UIPL No. 13-20, Change 1, Families First Coronavirus Response Act, Division D Emergency
Unemployment Insurance Stabilization and Access Act of 2020, issued May 4, 2020,
https://wdr.doleta.gov/directives/corr_doc.cfm?docn=5374;
UIPL No. 15-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 –
Federal Pandemic Unemployment Compensation (FPUC) Program Operating, Financial,
and Reporting Instructions, issued April 4, 2020,
https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9297;
UIPL No. 15-20, Change 1, Coronavirus Aid, Relief, and Economic Security (CARES) Act
of 2020 - Federal Pandemic Unemployment Compensation (FPUC) Program Reporting
Instructions and Questions and Answers, issued May 9, 2020,
https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3946; and
Employment and Training (ET) Handbook No. 395, 5th Edition, Benefit Accuracy
Measurement State Operations Handbook (November 2009).
7. Attachments.
Attachment I: UI Transaction file
Attachment II: sfsum.dat file
Attachment III: rec1.dat file
Attachment IV: BAM Program Operation Questions and Answers
6
Attachment I to UIPL No. 25-20
UI Transaction File
Field
Item # Name Positions Formats
Length
1 State I.D. 2 1-2 FIPS Code
2 Batch # 6 3-8 YYYYWW
3 Social Security # 9 9-17 Actual #
4 Claim Date 8 18-25 MMDDYYYY
5 Transaction Date 8 26-33 MMDDYYYY
6 Sample Select. Ind. 1 34 1 or 2
7 Transaction Type 1 35 1 to 4
8 Gender 1 36 1, 2 or 8
9 Date of Birth 6 37-42 MMYYYY or 010001
10 Ethnicity 1 43 1 to 5 or 8
11 Program Type 1 44 1 to 9
12 UI Duration 1 45 1 to 5
13 Amount Paid to Claimant 4 46-49 Whole Dollars
14 Amount Offset 4 50-53 Whole Dollars
15 Amount of Intercept 4 54-57 Whole Dollars
16 Claim Type 2 58-59 00-04, 11-15
17 Filing Status 1 60 1 to 3
18 Workshare Pct. 2 61-62 00 to 99
19 Run Date 8 63-70 MMDDYYYY
20 Adjustment Ind. 1 71 1 or 2
Total Amount "Paid"
21 4 72-75 Whole Dollars
Sum of items 13, 14, and 15
Zero-filled; can be used
--- Filler 5 76-80
by state for edit codes
I-1
Attachment II to UIPL No. 25-20
sfsum.dat File
Record Format for sfsum.dat file
(All Fields are Numeric)
Item # Name Field Size Positions
1 Batch 6 1-6
21 Sample Type 1 7
3 Sample Size 2 8-9
4 Population Size 7 10-16
52 Random Start # 6 17-22
3
6 Skip Interval 6 23-28
7 Initial Case Selected 6 29-34
8 Sample – Male 2 35-36
9 Population – Male 7 37-43
10 Sample – Female 2 44-45
11 Population – Female 7 46-52
12 Sample – Gender Missing 2 53-54
13 Population – Gender Missing 7 55-61
14 Sample – White 2 62-63
15 Population – White 7 64-70
16 Sample – Non-white 2 71-72
17 Population – Non-white 7 73-79
18 Sample – Ethnicity Missing 2 80-81
19 Population – Ethnicity Missing 7 82-88
20 Sample – Age < 25 2 89-90
21 Population – Age < 25 7 91-97
22 Sample – Age 25-34 2 98-99
23 Population – Age 25-34 7 100-106
24 Sample – Age 35-44 2 107-108
25 Population – Age 35-44 7 109-115
26 Sample – Age 45-64 2 116-117
27 Population – Age 45-64 7 118-124
28 Sample – Age 65+ 2 125-126
29 Population – Age 65+ 7 127-133
30 Sample – Age Missing 2 134-135
31 Population – Age Missing 7 136-142
II-1
Attachment II to UIPL No. 25-20
324 Sample – UI Program 2 143-144
334 Population – UI Program 7 145-151
345 Sample – UCFE/UCX 2 152-153
355 Population – UCFE/UCX 7 154-160
36 Sample – Program Missing 2 161-162
37 Population – Program Missing 7 163-169
386 Sample - <= $50 Paid 2 170-171
396 Population - <= $50 Paid 7 172-178
6
40 Sample - $51-100 Paid 2 179-180
416 Population - $51-100 Paid 7 181-187
426 Sample - $101-150 Paid 2 188-189
436 Population - $101-150 Paid 7 190-196
6
44 Sample - $151-200 Paid 2 197-198
456 Population - $151-200 Paid 7 199-205
466 Sample -> $200 Paid 2 206-207
476 Population -> $200 Paid 7 208-214
6
48 Sample – Amount Paid Missing 2 215-216
496 Population - Amount Paid Missing 7 217-223
506 Sample – Amount Paid 5 224-228
516 Population – Amount Paid 10 229-238
6,7
52 Sample – Amount Paid Variance 8 239-246
536,7 Population – Amount Paid Variance 8 247-254
__________________________
1
The first records are UI paid claims (sample type = 1), followed by monetary denials (sample
type =2), separation denials (sample type = 3), and nonseparation denials (sample type =4).
2
Reported with six digits, implied decimal (.xxxxxx).
3
Reported with one implied decimal (xxxx.xx).
4
UI program codes include regular UI, UI-UCFE, UI-UCX or UI-UCFE-UCX (program type
codes 1, 2, 3, and 4 in the UI transaction file).
5
Program codes include UCFE and/or UCX only (program type codes 5, 6 and 7 in the UI
transaction file).
6
For the monetary, separation, and non-separation denials, this item must equal zero.
7
Reported with three implied decimal places (xxxxx.xxx).
II-2
Attachment III to UIPL No. 25-20
Rec1.dat File
Record Format for rec1.dat file
Item Field
Name Positions Formats/Codes1
Flag
# Size
1 Social Security # 9 1-9 9-digit SSN (state use only)
2 State ID 2 10-11 2-digit FIPS Code
3 Batch Number 6 12-17 YYYYWW
Claim Date (Week Ending or Effective
8 18-25
4 Date) MMDDYYYY
5 Local Office Number 4 26-29 State-assigned #
6 U.S. Citizen 1 30 1 to 3 or Blank
7 Education 2 31-32 00 to 12, 14 to 16, 20 or Blank
8 2 Voc/Tech Training 1 33 1 to 3 or Blank
9 2 In Training 2 34-35 00, 11 to 14, 21 to 24 or Blank
3-digit major and minor O*NET
10 2 Occupation Code (Last Employer) 3 36-38
code or Blank
11 Date of Birth 8 39-46 MMDDYYYY or Blank
12 Gender 1 47 1, 2 or Blank
13 Ethnicity Classification 1 48 1 to 6, 9 or Blank
14 Program Code 1 49 1 to 8 or Blank
15 Combined Wage 1 50 1 to 6 or Blank
16 Benefit Yr. Beginning 8 51-58 MMDDYYYY or Blank
17 Initial Claim Filing Method 1 59 1 to 6 or Blank
18 2 # Prior Nonsep Issues 2 60-61 2 digits or Blank
19 2 # Prior Nonsep Issues (Disqualifying) 2 62-63 2 digits or Blank
20 Reason for Separation (Before Investigation) 2 64-65 10 to 69 or Blank
21 Date of Separation (Before Investigation) 8 66-73 MMDDYYYY or Blank
22 2 Recall Status (Before Investigation) 1 74 0, 1, 2 or Blank
NAICS code (first 4 digits) or
NAICS Last Employer 4 75-78
23 2 Blank
# Base Period Employers (Before
24 2 79-80 2 digits or Blank
Investigation)
25 Base Period Wages (Before Investigation) 6 81-86 6 digits (whole dollars) or Blank
NAICS code (first 4 digits) or
26 2 NAICS Primary Base Period Employer 4 87-90
Blank
27 High Quarter Wages (Before Investigation) 5 91-95 5 digits (whole dollars) or Blank
# Weeks Worked in BP (Before
3 96-98
28 Investigation) 3 digits or Blank
29 WBA (Before Investigation) 4 99-102 4 digits (whole dollars) or Blank
III-1
Attachment III to UIPL No. 25-20
30 MBA (Before Invest.) 5 103-107 5 digits (whole dollars) or Blank
31 Monetary Redeterm. (Before Investigation) 1 108 1, 2 or Blank
Remaining Balance (As of week paid or 5 digits (whole dollars) or Blank
32 5 109-113
denial) determination)
# Dependents Claimed (Before
2 114-115
33 Investigation) 2 digits, 00 or Blank
Dependents Allowance (Before
3 116-118
34 Investigation) 3 digits (whole dollars) or Blank
35 2 First CWE Date 8 119-126 MMDDYYYY or Blank
36 2 Date of First Payment 8 127-134 MMDDYYYY or Blank
37 2 Key Week Cert. Method 1 135 1 to 3 or Blank
38 3 Filing Method Week Claimed/Paid 1 136 1 to 6 or Blank
39 (Relocated to Item # 62) 3 137-139 Blank
40 (Relocated to Item # 63) 3 140-142 Blank
41 (Relocated to Item # 64) 3 143-145 Blank
42 (Relocated to Item # 65) 3 146-148 Blank
43 (Relocated to Item # 66) 3 149-151 Blank
44 2 Required to Seek Work 1 152 1 to 5 or Blank
45 2 ES Registration Required 1 153 1 to 4 or Blank
46 2 Actively/Currently Registered w/ ES 1 154 1 to 4 or Blank
47 2 Reason ES Reg. Deferred 1 155 1 to 6 or Blank
48 2 # of ES Referrals 2 156-157 2 digits or Blank
49 2 Union Referral Status 1 158 0 to 3 or Blank
50 5 Union Service 1 159 0 to 3 or Blank
51 5 Union Assistance Requested 1 160 0 to 4 or Blank
52 5 Claimant Union Assisted 1 161 0, 1, 2 or Blank
53 5 Monetary Denial Reason 2 162-163 00 thru 59 or Blank
54 5 Nonmonetary-Nonseparation Denial Reason 2 164-165 00 thru 79 or Blank
55 5 Claim Type 1 166 0 to 5
56 5 Initial Determination Appealed6 1 167 0 to 3 or Blank
57 5 Result of Initial Determination Appeal6 1 168 0 to 6 or Blank
58 5 Sample Type 1 169 1 to 4
59 Ethnicity 1 170 0, 1 or Blank
60 5 Separation Issue No. 2 171-172 0 to 99, -2 or Blank
61 5 Nonseparation Issue No. 2 173-174 0 to 99, -2 or Blank
62 4 Amount Paid and/or Offset 5 175-179 5 digits (whole dollars) or Blank
63 Total Earnings (Before Investigation) 4 180-183 4 digits (whole dollars) or Blank
64 Earnings Deduction (Before Investigation) 4 184-187 4 digits (whole dollars) or Blank
III-2
Attachment III to UIPL No. 25-20
Other Deductible Income (Before
65 6 188-193 6 digits (whole dollars) or Blank
Investigation)
66 Other Deduction (Before Investigation) 5 194-198 5 digits (whole dollars) or Blank
1 Unless otherwise noted, refer to ET Handbook No. 395 Chapter IV for paid claims, and Chapter VIII for
denied claims for data element codes.
Flags
2 Required for UI paid claims cases only; optional for denial cases.
3 Required for UI paid claims cases and any denial decision when a week was claimed; leave blank for denial
decisions if no week was claimed.
4 Required for UI paid claims cases. For denial cases, leave blank if there is no payment associated with the denial
determination. Otherwise, enter the amount paid, offset, intercepted, withheld or deducted for the weeks affected
by denial determination.
5 Data element added for denied claims.
6 Appeal status at time case was selected for sample; data element can be updated if status changes before case is
closed.
III-3
Attachment IV to UIPL No. 25-20
BAM Program Operation Questions and Answers
A. FPUC Payments
1. Question: If the BAM unit finds the Key Week (KW) is totally overpaid (that is, (h2)
Amount That Claimant Should Have Been Paid is $0 for regular UC and element (ei2)
=10, 11, or 12) after investigation due to earnings or failure to meet other eligibility
requirements, is the claimant still eligible for FPUC for the KW?
Answer: No. The claimant must be eligible for at least $1 of underlying state benefits
for the KW to be eligible to receive the FPUC payment for that week (see UIPL No.
15-20 Change 1, Attachment, Section A. Issuing Payments Q&As). If the amount due
to the claimant for regular UC is zero dollars, the BAM unit must ensure the agency
also addresses the FPUC dollars for the period of denial. This should be addressed in
the case summary and recorded appropriately in element (h3). Note that FPUC is not
treated as deductible income.
If the BAM unit is reviewing a denied claim and finds that the claimant is eligible for
at least $1 of underlying benefits, then the FPUC payment is also due for the weeks
affected by the denial. This information should be resolved by the BAM unit or
referred to the appropriate department to ensure payment is made when it is due.
2. Question: How should FPUC payments be handled within the BAM program?
Answer: FPUC dollars are from a temporary federally-funded program and must be
excluded from the BAM population. Therefore, elements (e9) Weekly Benefit
Amount Before Investigation, (e10) Weekly Benefit Amount After Investigation, (f13)
Original Amount Paid and/or Offset for Key Week, (h2) Amount That Claimant
Should Have Been Paid, (h5) Total Overpayment Amount for the Key Week, (h6)
Total Underpayment Amount for the Key Week, and (ei1) Dollar Amount of Key
Week Error will exclude the amount of FPUC dollars paid. Similarly, the coding for
improper denials which result in payment will exclude the FPUC dollars paid.
However, FPUC dollars paid must be recorded into elements (h3) Total Whole $
Amount of Overpayments (include Key Week) and (h4) Total Whole $ Amount of
Underpayments (include Key Week). The case summary should include a brief
statement on FPUC dollars paid.
Effective with the release of the revised BAM software by the Department announced in
this UIPL, the state must enter the FPUC dollar amount in the newly-defined element
(d7) Federal Supplemental Payment, described in section 4.b.i. of this UIPL. For any
cases that include FPUC payments that a state has already closed (e.g., generally all cases
with a key week on or after week-ending April 4, 2020), the state must reopen and update
the record using Reopen Code ‘9’. As stated in this UIPL, BAM units will no longer
record the tax rate in the BAM PCA investigation.
IV-1
Attachment IV to UIPL No. 25-20
3. Question: Should the amount of FPUC dollars paid be included in the comparison
tables (b_comparison) elements (cm3) Sample Dollars Paid and element (cm4)
Population Dollars Paid?
Answer: No. FPUC dollars are from a temporary federally-funded program and
should be excluded from the BAM population and sample. Pursuant to UIPL No. 15-
20, Attachment I, the FPUC amount paid is also excluded from the ETA 5159 report
(i.e., ar5159).
The BAM sfsum file must exclude these FPUC dollars in these positions:
506 Sample – Amount Paid 5 202-206
516 Population – Amount Paid 9 207-215
These fields are used in calculating the weighted dollars paid for estimates.
Additionally, the rec1.dat file should exclude the FPUC amount from DCI elements
prepopulated. For example, it may prepopulate elements (e9), (e11), and (f13) (etc.).
29 WBA (Before Investigation) 4 99-102 4 digits (whole dollars) or Blank
30 MBA (Before Invest.) 5 103-107 5 digits (whole dollars) or Blank
62 Amount Paid and/or Offset 5 175-179 5 digits (whole dollars) or Blank
If the record includes FPUC dollars in any of these fields, then the BAM unit must update
such elements using the appropriate BAM application.
B. PEUC and PUA Claims in BAM
4. Question: Should UC claims filed for the sole purpose of checking eligibility for
Pandemic Emergency Unemployment Compensation (PEUC), Pandemic
Unemployment Assistance (PUA), Extended Benefits (EB), and Trade Readjustment
Allowances (TRA) be included in the BAM samples?
Answer: No. UC claims filed for the sole purpose of checking eligibility for PEUC,
PUA, EB, and TRA should not be included in the BAM samples.
5. Question: Are PEUC and PUA claims excluded from the BAM samples? How should
PEUC/PUA claims be handled if selected in the BAM sample?
Answer: Yes. All paid and denied PEUC and PUA claims will be excluded from the
BAM Paid Claims Accuracy (PCA) and Denied Claims Accuracy (DCA) sampling
frames. This is consistent with the policy followed for previous temporary programs.
Per the instructions in ET Handbook 395, Chapter III, the State UI Transaction file,
Program Type (Data Element 11) must be coded “8” (Other) and Unemployment
Duration Code (Data Element 12) must be coded “5” (Other federal extended benefits
program).
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Attachment IV to UIPL No. 25-20
If a PEUC or a PUA claim is selected for the BAM sample (PCA or DCA) because it
was not properly coded in the State UI Transaction file, it must be coded as such: PCA
data element (c1) Program Code equals “8” or DCA data element (22) Program Code
equals “8”. Such cases will not be investigated by the BAM unit and the BAM
supervisor will not sign-off on them. The BAM unit must sample additional cases in
subsequent batches to compensate for the number of PCA and DCA sample cases
deleted due to improper coding of a PEUC or PUA claims in the State UI Transaction
file.
C. Impacts following Temporary BAM Suspension
6. Question: My state received approval from the Department to suspend the BAM
program for Batch Range 202014 through 202026 so that BAM investigators could
help process initial claims and adjudication in Operations. Now that the BAM
investigator has returned to the BAM unit, what should happen if he or she is assigned
one of the cases he or she processed while helping in Operations?
Answer: Any case that an individual BAM investigator handled while helping in
Operations should be assigned to another BAM staff member to complete the
investigation.
7. Question: My state received approval from the Department to suspend BAM
investigations for the quarter-ending June 30, 2020. How does this suspension affect
the minimum annual sampling number of cases?
Answer: If the state received approval from the Department to temporarily suspend
BAM investigations, the state is not be expected to make-up cases for the period to
which the suspension applies. The minimum annual sampling requirement is reduced
by the total number of cases that would have been sampled during the period that the
approved temporary suspension covered.
8. Question: My state received approval from the Department to suspend BAM
investigations for the quarter-ending June 30, 2020. How does this suspension affect
the timeliness performance measures?
Answer: The state is expected to complete sampled PCA cases, Batch 201927 through
Batch 202013, no later than September 30, 2020. Additionally, BAM units must
complete outstanding open (Batch range 201927 through 202013) DCA cases by
October 28, 2020. If the state experiences any timeliness issues in completing BAM
cases, the Department will consider the circumstances, including the approved BAM
suspension, when determining the state’s corrective action as part of the State Quality
Service Plan activities.
D. Work Search Verifications
9. Question: Given the economic effects of COVID-19, my state is having challenges in
receiving responses to requests for information when conducting work search
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Attachment IV to UIPL No. 25-20
verifications. In some cases, the businesses are closed. In many others, checking to
see if someone applied for work in prior weeks is not a priority for the business. Is
there a possibility of modifying the verification requirement for the current time?
Answer: An employer statement that providing the information is not a priority is not
the same as the employer indicating no information will be provided. The BAM unit
must make an exhaustive attempt to obtain information from an employer listed as a
contact. If the employer responds that the entity does not have the information or
does not know whether the claimant made a contact, then the investigator has met the
exhaustive attempt requirement and the contact should be coded as unverifiable. If
the business is closed, then the investigation could conclude the contact is
unverifiable once the exhaustive attempt has been made.
10. Question: My state allowed for permissible flexibilities in determining whether an
individual met the able to work and available to work requirements during periods of
the pandemic. The state also modified and suspended the work search requirements.
How should a BAM investigator account for these temporary policy changes?
Answer: Section 4102(b) of the Families First Coronavirus Act, specifically Division
D, the Emergency Unemployment Insurance Stabilization and Access Act of 2020
(EUISAA) (Public Law 116-127), provides states with emergency temporary
flexibility to modify or suspend the work search requirement in response to the spread
of COVID-19. See UIPL Nos. 10-20, 13-20, and 13-20 Change 1 for additional
details. If the state chooses to exercise such flexibility regarding work search, the
BAM unit should apply the law and policies in effect in the state during the temporary
emergency in evaluating able, available and work search compliance. If the
claimant’s satisfaction of the work search requirement is established under such a
provision, the case file must have a copy of the emergency declaration or applicable
official policy (See ET Handbook 395 Chapter VI, p. VI-4) as supporting
documentation for the determination made as a result of the BAM investigation.
However, if the key week was paid prior to the start of or after the lapse of state’s
emergency temporary modification, then the investigation must enforce established
law during the period of payment and follow normal BAM investigative procedures.
(See UIPL No. 13-20, Change 1, Attachment 1, Q&A #8).
IV-4
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