References: Unemployment Insurance Program Letter (UIPL) No. 7-92, "Eagle Pass Task Force - Recommended Actions for Deterring and Detecting Fraud Activity in the Unemployment Insurance (UI) Program." Background: The validity of UI claims filed by claimants who use a third party to assist in filing has long been a concern of Federal and State UI administrators. Increased attention was focused on this concern in the early 1990's by the results of the Texas Employment Commission (TEC), the Office of Inspector General (OIG) and the Employment and Training Administration (ETA) investigation of a third party fraud scheme in Eagle Pass, Texas. A similar third party fraud scheme was subsequently uncovered in the Roma/McAllen, Texas, area. The Dallas OIG, with the cooperation of ETA and the SESAs, has successfully pursued prosecution and conviction of several individuals involved in these fraud schemes. Additional information concerning these operations can be found in UIPL No. 7-92. Further investigations have uncovered a total of fourteen third party fraud schemes along the Texas/Mexico border to date. These investigations disclosed that the third party filed weeks claimed on behalf of claimants, certified to false work search contacts, and perhaps falsified answers to other eligibility questions in the claimants' absence. The third party also forged the claimants' signatures and cashed UI benefit checks. The majority of the claimants identified during the third party investigations were filing interstate claims. These claims involved a total of thirty-three States, although most of the claims involved the States of California and Texas. Normally, after claimants file an interstate initial claim through an agent State local office, they correspond directly with the liable State by mail or telephone and only report again to the agent State local office if directed to report for eligibility review interview (ERI) purposes by the liable State. UIPL No. 7-92 indicated the actions that had been initiated in response to the Eagle Pass fraud scheme which included the establishment of a Task Force to look into the issues involved in the scheme with the goal of identifying lessons to be learned for the prevention of such occurrences in the future. Also included in UIPL No. 7-92 were numerous Task Force recommendations for SESA administrators to consider for use in their own systems and procedures for deterrence and detection of fraud activity. In addition to States taking specific actions to attempt to address the potential of fraud in the individual claims associated with cases in the Eagle Pass and Roma/McAllen fraud schemes, other significant activities that have been initiated since the issuance of UIPL No. 7-92 include: - In September 1993, UIS signed a Cooperative Agreement with the State of California to conduct a study to develop a prototype third party fraud profile system. The profile system will be directed toward early detection of potential third party UI benefit fraud. - A claimant benefit rights interview video and an informational booklet have been produced in both English and Spanish for use with interstate claimants in response to one of the Task Force's recommendations. UIPL No. 21-94, announcing the development of these materials and making them available to each of the States, was issued in April 1994. - A comprehensive Benefit Payment Control (BPC) Technical Assistance Guide (TAG) containing guidance on fraud detection and prevention was developed through a Cooperative Agreement between UIS and the State of Maryland. During 1994, three training sessions were held for State BPC staff in conjunction with the issuance of the BPC TAG to all States. - ETA Regional Offices hosted Regional and Multi-Regional BPC Conferences which have included information regarding third party fraud activity as well as other types of fraud activity. Additionally, State agency officials from California and Texas and ETA and OIG officials from the Regional and National Offices have met on several occasions to discuss efforts toward detection and deterrence of third party fraud. During one of these meetings, it was agreed that in- depth ERIs and investigations could be conducted to assess the cost effectiveness of these actions in addressing the problems of third party fraud. TEC developed and submitted a proposal, with input from ETA and OIG officials, to provide an analysis of third party involvement in the UI process and related integrity issues and to attempt to quantify the detection/deterrence effect of in-depth ERIs and investigations. This project was approved by ETA. Project Objectives: This project will extend for a 3-year period from October 1, 1994 through September 30, 1997, to allow for sufficient annual workload cycles to be able to accurately evaluate the effectiveness and determine the cost of the in-depth ERIs and investigations. The objectives of the project include: - Ascertaining the nature of third party involvement and the factors contributing to their use in the UI process. - Measuring the impact of increased investigative efforts and claimant interviews on third party fraud incidence. - Estimating the cost effectiveness of in-depth ERIs and investigations in detection and deterrence of improper payments. - Documenting the types of issues resulting in disqualifications and/or overpayments (e.g., able and available issues, and/or work search issues). - Developing recommendations for procedures designed to detect and deter third party fraud. - Ascertaining how agent and liable States may better coordinate efforts in detecting and deterring third party fraud. Project Design: Six local offices will be selected based on an analysis of claimant addresses, historical significance in prior investigations, and other local area characteristics and demographics. Three local offices will be "test" offices and three will be "control" offices. In each of these local offices, the project population will be: a. All claimants who are utilizing a single address used by multiple claimants as determined by a review of Texas files; and b. Any claimants with prior third party involvement who have active claims with Texas addresses associated with the six selected local offices. In the three "test" offices, such intrastate and interstate claimants will be called in for in-depth ERIs and all potential issues detected will be investigated. To ensure that all "test" offices are asking claimants the same questions, TEC will develop a comprehensive questionnaire. This questionnaire will provide for obtaining specific information such as residence address, labor market area attachment, work search activities, intervening/casual employment, etc. Fact-finding results from the ERIs and investigations will be provided to the appropriate TEC adjudication unit or liable State for determination and appropriate action. In the three "control" offices, ERIs for intrastate and interstate claimants will continue to be scheduled and conducted based on current policy and procedures. Comparable data will be accumulated at all phases to compare activity and results in the "test" and "control" offices. TEC Activities: TEC will perform all the following activities under this project: a. Utilize the Interstate Benefit Rights Interview (BRI) in the agent State claims process. b. Identify project population, e.g., multiple claimants utilizing a single address, OIG list of claimants with prior third party involvement. c. Call in all selected claimants in the "test" offices for in-depth ERIs that will focus on able and available issues, such as labor market attachment, work search, method(s) of seeking work, and other potential issues. d. Thoroughly investigate all potential issues identified including: (1) visiting, inspecting, or investigating single addresses used by multiple claimants and/or contacting third parties, as appropriate. (2) establishing contact sources for information at utility companies, law enforcement authorities, postal service, and State and Federal Courts, as needed. e. Refer potential issues and investigative results to appropriate adjudication units (TEC or liable State). f. Conduct special supplemental interviews/ investigations as requested by adjudication or prosecution units and/or liable States. g. Coordinate assistance from DOL-OIG regarding fraud cases as appropriate. h. Document the cost of conducting the in-depth ERIs and investigations (e.g., staff time, travel dollars, etc.). i. Collect and compile project data with respect to "test" and "control" offices for reporting purposes. j. Request liable States to provide information pertaining to the disposition of each case investigated and referred by TEC. k. Develop a follow-up form for use by liable States to provide the requested information on the disposition of each case to TEC. Data Analysis and Reports: Efforts are being made to ensure that data captured with respect to the "test" and "control" offices will provide sufficient information to address the project objectives so that meaningful conclusions can be reached and fraud detection and deterrent procedures for the UI system can be recommended. The identification of all data collection elements has not been completed. However, some of the information that will be compiled and separately arrayed by interstate and intrastate program for analysis with respect to claimants and third parties in the "test" and "control" offices is as follows: Claimant Information - Number of identified claimants; - Characteristics of claimants filing from suspect addresses-- - Occupation - Age - Sex - Mailing address - Residence address (if available) - Distance of residence from labor market area - Work history - Claim history; - Number of ERIs scheduled, conducted and results; - Number of claimant investigations conducted; - Number of determinations (fraud/non-fraud); - Amount of fraudulent and non-fraudulent overpayments established; - Number of claimants living outside the local labor market area while filing a UI claim; - Number of claimants working while filing a UI claim; - Number of claimants identified in prior investigations; - Number of claimants referred for prosecution; - Number of claimants convicted; and - Number of claimants prosecuted under Federal mail fraud statutes. Third Party Information - Number of third party interviews/contacts conducted; - Number of third party fraud investigations initiated; - Number of third party cases referred for criminal prosecution; - Number of third parties convicted; - Number of third parties referred to OIG for prosecution; and - Number of third parties contacted/investigated that were involved in prior OIG investigations. Liable State Assistance: As mentioned above, this project will be on-going through September 30, 1997. Each State, therefore, is requested to designate a contact person to coordinate interstate communications for this project during this period. Although TEC and the Dallas OIG will identify potential claimant fraud cases involving interstate and third parties and will be able to collect information regarding the issue, this project will be successful only with each liable State's assistance and cooperation. The TEC Project Director, Mr. Ken Helm, will be sending a letter to all SESAS informing them of the selected local offices and providing additional information regarding the project. Mr. Ken Helm will also be transmitting to SESAs a State specific OIG list of Social Security Numbers (SSNs) and addresses utilized by claimants with prior third party involvement. SESAs will be requested to conduct file searches of the information on the list against their active claim files in order to identify any active claims with Texas zip code addresses associated with the selected local offices. This will allow TEC to include in the project population, claimants with prior third party involvement who are not in TEC's agent State files but who are in an active claim filing status. To attempt to facilitate the use of the OIG information lists, these lists are being made available on floppy disks using Lotus spreadsheets. SESAs can use the OIG lists for their own integrity related purposes as they may deem appropriate. OIG Assistance Available: The Dallas OIG has agreed to work with TEC and the Dallas ETA Regional Office in order to ensure a comprehensive approach. The Dallas OIG will assist TEC in investigating the interstate cases and in preparing cases for prosecution. In addition, in order to assist liable States in prosecuting cases related to these interstate and third party cases, the Dallas OIG has agreed to assist liable States by providing testimony as to the OIG investigation of the third party, including evidence obtained. In some cases, as appropriate, the OIG will pursue Federal prosecution via the mail fraud statutes. Action Required: SESA Administrators are requested to: a. Ensure all appropriate SESA staff are aware of and familiar with the material in this UIPL and UIPL No. 7-92. b. Designate a contact person to coordinate interstate communications for this project and provide the name, telephone number, and address by December 30, 1994, to: Texas Employment Commission Kenneth Helm, Director Benefit Payment Control Department 101 East 15th Street Travis Building, Suite 200 Austin, Texas 78731 Phone Number - (512) 502-3701 Fax Number - (512) 502-3704 c. Establish a means to provide follow-up data to TEC pertaining to the disposition of each case referred by TEC utilizing the form which TEC develops. Information requested will include: - Disposition of issue. - Determination (fraud/non-fraud). - Overpayment (fraud/non-fraud). - Amount of overpayment. - Prosecution pursued. - Results of prosecution. d. Provide TEC with the PS/NPS cost of providing the follow-up information requested.

References: Section 3304(a)(9)(B) of the Internal Revenue Code, as amended; 20 CFR 616; ET Handbook No. 399; UIPL No. 55-89; and UIPL No. 11-91. Background: To address the need for prompt communication of wage transfer requests and responses for claims filed under the Interstate Arrangement for Combining Employment and Wages, a software package to telecommunicate the requests and responses using the INTERNET was distributed in September 1989. States were previously requested in UIPL No. 55-89 to be operational on the TC-IB4 application as of April 2, 1990. The TC-IB4 application was subsequently updated to address additional needs, identified by the States, and re-released in August 1990. The Report on the Determination of a Combined Wage Claim, Form IB- 5 (TC-IB5), is an integral part of the combined wage program. This report is used by a paying State to advise a transferring State of its potential benefit liability and to advise a transferring State when wages are returned and need to be restored to the wage file and made available. It is extremely important to use this report to return wages immediately so that they may be available for use for a substitute claim that may result from a combined wage claim cancellation or ineligibility. It is also important that States process the incoming TC-IB5s before incoming initial claims (TC- IB1s) to prevent the substitute initial claim from resulting in an ineligible monetary determination because the wages have not been restored. This application was distributed in December 1990, and SESAs were requested to implement the new automated procedure by April 1, 1991. Before and after the distribution of the TC-IB4 and TC-IB5 applications, several meetings were held with State representatives to explain the requirements, provide assistance and answer any installation questions. Additionally, SESAs were and continue to be allocated special funding for data processing support of the automation necessary to telecommunicate data under the interstate and combined wage program procedures. During the past year, all States have been contacted by the Regional Offices and offered on- site assistance. Yet some SESAs have not requested assistance and have not installed the required applications necessary to telecommunicate the data. SESAs' failure to telecommunicate the required data is having an adverse affect on all other States as they must continue to maintain a manual system in order to handle requests and responses to and from such States. Requirement for Conformity and Compliance: Section 3304(a)(9)(B) of the Federal Unemployment Tax Act requires States to participate in any combined wage claim arrangement approved by the Secretary of Labor (in consultation with the State agencies). 20 CFR 616.13, in pertinent part, implements this arrangement by providing that: Each State agency will cooperate with every other State agency by implementing such rules, regulations, and procedures as may be prescribed for the operation of this [combined wage] arrangement. Effective April 5, 1993, electronic data communication, as described in Section 5, is the prescribed procedure for handling wage transfer requests and responses, and reports on the determination of combined wage claims. Action Required: State Administrators are requested to take the necessary actions to ensure that effective April 5, 1993: a. all requests for wage transfers are sent and received via INTERNET; b. all responses to wage transfer requests are sent and received via INTERNET; c. all reports on the disposition of transferred wages (IB- 5) are sent and received via INTERNET; and d. the use of hard copy forms for these purposes are discontinued.

References: UIPL No. 16-94 (3/15/94), UIPL No. 31-94 (6/24/94), UIPL No. 32-94 (6/24/94), UIPL No.42-94 (8/16/94), ET Handbook No. 401. 2nd Edition, Change 5 (10/11/94). Background: The RQC staff compiles questions and issues that arise during Regional and National Office (NO) monitoring trips, and from other sources in order to develop a generic set of answers to those questions believed to be of universal interest to the State staff implementing RQC. Revised 581: The 581 report has been revised and approved by the Office of Management and Budget (OMB) to accommodate planned changes in data elements for accounts receivable and to include the proper data elements for RQC Computed Measures. Instructions for completing the revised 581 were issued in ET Handbook No. 401, 2nd Edition, Change 5, October 11, 1994. The revised form will become effective with the report for the quarter ending March 31, 1995, due in the NO on May 20, 1995. State Employment Security Agency staff have raised additional questions concerning changes on the revised form. Answers to 581 questions are now included in this third group of Q&A's dated November 1994. Questions and Answers: The Q&As are arranged by categories of the 581 report and by each major RQC tax function. Numbering of the questions in each section is continuous. This format provides the necessary flexibility to allow periodic Q&A updates to be inserted in the appropriate section. There may be some overlap between 581 and RQC Computed Measures questions. Effective with this compilation, questions relating to interpretation of Computed Measures data elements have been included in the appropriate 581 category and questions relating to calculation are included in the appropriate Computed Measures tax function. Action Required: The SESA Administrators are requested to provide the attached Q&As to the SESA Tax staff, the agency organizational unit responsible for the accuracy and completion of the 581, RQC Reviewers and appropriate DP staff. Five copies are attached for your convenience.

References: The EUC Act of 1991, Public Law 102-164, as amended; GAL No. 4-92 and Changes 1-4 as consolidated in GAL 12-92; UIPL No. 9-92 and Changes 1-4; the Federal-State Extended Unemployment Compensation Act of 1970, as amended; 20 CFR Part 615; 20 CFR Part 616; ET Handbook 392; ET Handbook 399; ET Handbook 401; Section 5100, Part V, Employment Security Manual and UIPL No. 6-92. Background: Many questions have been received from States about options available to claimants under Public Law 102-318. This change to the program letter provides to all States answers that have been given to individual State questions. Action Required: State Administrators are requested to make a copy of this UIPL available to all appropriate staff.

References: TEGL No. 3-94. Background: TEGL No. 3-94 was transmitted to all State JTPA liaisons, State Employment Security Agency (SESA) Administrators, and State Worker Adjustment liaisons. It is being retransmitted to all SESA administrators to ensure that the UI components in each SESA are informed of the contents so that they can coordinate their efforts to implement the WP/RS system. Action Required: SESA Administrators are requested to provide this information to all UI staff participating in WP/RS.

Reference: GAL 12-92 (September 11, 1992) Background: The amendments to the EUC program (effective July 3, 1992) included a provision that affects the work of QC -- the election provision. Under this provision, a claimant eligible for both regular Unemployment Insurance (UI) and EUC must be allowed to elect which benefit to receive. Although there is a general precedent for the election provision with Combined Wage Claims, this is the first instance of a program eligibility option for an extended benefits program and regular benefits. A further aspect is the "retroactive" provision. The election was effective for weeks after July 3, 1992. However, States have varied in how quickly they have implemented the requirements. Claimants must be offered the opportunity to elect EUC for weeks after July 3, 1992 already paid as regular UI or UCFE/UCX, etc., if they have the program eligibility option. The program eligibility option feature of the amendments requires the States to offer some claimants an election of EUC vs regular benefits more than once. At the end of the benefit year of a claimant who elects to defer the receipt of regular benefits to receive EUC, the claimant again has an election to postpone establishing a new benefit year to receive EUC on the most recently expired benefit year. The amendments affect the QC program as follows: I. The QC population includes regular benefit payments; it excludes all extended benefit-type payments, interstate, DUA, and TAA. The retroactive election provision makes this universe conceptually ambiguous. States are deleting retroactive EUC elections from the ET 5-159 report after the fact and unless adjusted the QC Population will diverge from the 5-159 figures. II. The election provision introduces two potential sources of payment error into the UI program. A. After the EUC amendments have been implemented, States can make mistakes by handling the election provisions incorrectly. For example, a claimant elects EUC but the State pays regular benefits. B. During the period between July 3, 1992 and the date of implementation of the EUC amendments, States will have made regular benefit payments to claimants that have the program eligibility option which were correctly included in the QC population. Some payments will appear in QC samples where the claimants were entitled to have been offered, and upon election receive, EUC payments. By the time QC investigates them, some may have been paid as EUC "retroactive" claims; QC may determine that others should have been paid as EUC claims or that an election should have been offered. Although the original payment decisions that put the payments in the QC sample were correct at the time they were made, some or all could be considered QC overpayments. This situation is complicated by the lack of an implementation period in the EUC amendments to define when retroactive payments are or are not timely. The total number of such payments depends on (a) the number of claimants with a program eligibility option in the State; (b) the speed with which the State implemented the new law; (c) the election decision made by the claimant. Policy: UI payments which subsequently become EUC payments will not be considered improper payments for QC purposes. Such cases need to be investigated and identified so that the QC population can be adjusted. The policy includes the following: a. Investigate all cases in the QC sample following standard QC procedures and code any UI errors. b. Identify ("flag") all program eligibility option cases for key weeks after July 3, 1992 and code them appropriately. This will be done by changing the Program Code. Most of the cases will be in the "retroactive" period, but some may also occur after full implementation. c. Additions will be made to the QC software to flag the sampled cases and a method will be devised to adjust the QC population. d. Program eligibility option cases in which the claimant elected regular benefits will remain in the QC population/sample. e. The only situation where the case will remain in the sample is one in which the regular monetary determination was in error: i.e.; the claimant should have exhausted in an earlier week but will receive EUC due to the additional EUC benefits. These are UI overpayments due to monetary determination errors, not related to implementation or operation of EUC. f. No EUC-related mistake will be counted as an error for QC purposes. Because the EUC program eligibility option cases are removed from the sample, they will not affect calculations of timeliness. Because they have been investigated fully for regular benefit eligibility, however, they will be counted toward meeting sample allocation requirements. g. The "flagged" cases will remain in the QC database for analysis: They may help explain any dramatic changes in a State's error rate from 1991 to 1992, if the program eligibility option cases prove to be significantly more or less error-prone in regard to regular program eligibility. Procedures: States must continue to fully investigate all cases in the QC sample and ascertain whether they met regular benefit eligibility criteria. States are required to: (a) review completed cases and structure current investigations to identify program eligibility option cases; (b) establish and maintain a list of affected cases for future coding. a. Identifying a Program Eligibility Option Payment. There are three basic classes of EUC program eligibility option cases that must be identified. (1) After presentation of the option by the agency, the claimant retroactively elected to substitute an EUC payment for the regular program payment. (2) Upon the presentation of the option by the QC Investigator (QCI) in the course of the QC verification (this could occur either for "retroactive" or post- implementation cases), the claimant elected EUC. (3) After review of completed QC cases, the QCI determines that the case had been or should have been transferred to EUC. Below is a selection of potential situations with coding instructions: 1. Payment made originally under regular program before State implementation of EUC. During the "implementation" period, State offered EUC, which claimant elected. QC investigation uncovered no regular benefits issues. CODING: Identify as EUC payment, for deletion from QC sample. 2. Payment made originally under regular program before State implementation of EUC. During the "implementation" period, State offered EUC, which claimant elected. QC investigation revealed that the regular payment was improper. CODING: Identify as EUC payment, for deletion from QC sample. 3. Regular benefit payment made before State implementation of EUC. During the "implementation" period, State offered EUC, which claimant rejected. QC investigation uncovered no regular payment issues. CODING: Regular payment. 4. Regular benefit payment made before State implementation of EUC. During the "implementation" period, State offered EUC, which claimant rejected. QC investigation uncovered that a regular payment was improper. CODING: Regular payment. 5. Regular benefit payment made after State implementation of EUC. QC investigation uncovered no regular payment issues; also determined claimant was EUC-eligible, but that State either failed to offer EUC election to claimant, or presented it incorrectly, so that EUC was not elected. Upon presentation by QCI, EUC is elected by claimant. CODING: Identify as EUC payment, for deletion from sample. 6. Regular benefit payment made after State implementation of EUC. QC investigation determines that original payment was improper; also determined claimant was EUC-eligible but that State either failed to offer EUC election to claimant, or presented it incorrectly, so that EUC was not elected. Upon presentation by QCI, EUC is elected by claimant. CODING: Identify as EUC payment, for deletion from sample. 7. Regular benefit payment made after State implementation of EUC. QC investigation uncovered no regular payment issues; also determined claimant was EUC-eligible, but that State either failed to offer EUC election to claimant, or presented it incorrectly, so that EUC was not elected. Upon presentation by QCI, EUC is not elected by claimant. CODING: Regular payment. 8. Regular benefit payment made after State implementation of EUC. QC investigation determines that original payment was improper; also determined claimant was EUC-eligible but that State either failed to offer EUC election to claimant, or presented it incorrectly, so that EUC was not elected. Upon presentation by QCI, EUC is not elected by claimant. CODING: Regular payment. 9. Regular benefit payment made after State implementation of EUC. During the QC investigation, it was determined that (a) the regular monetary determination was in error and that the claimant should have exhausted regular benefit eligibility before the Key Week; and (b) claimant was EUC-eligible. Claimant elected EUC either as result of either SESA or QCI offer. CODING: Regular UI payment error. 10. Regular benefit payment made and the QC investigation was completed before State implementation of EUC. During the "implementation" period, State offered EUC, which claimant elected. QC investigation uncovered no regular benefit issues. CODING: Identify as EUC payment, for deletion from QC sample. 11. Regular benefit payment made and the QC investigation was completed after State implementation of EUC. QC review determined claimant was EUC-eligible, but that State either failed to offer EUC election to claimant, or presented it incorrectly, so that EUC was not elected. Upon presentation by QCI, EUC is elected by claimant. CODING: Identify as EUC payment, for deletion from sample. b. Listing of Cases, Coding, Reporting. States are to develop and maintain a list of affected cases for additional coding at a later date. The first release following introduction of the new QC software will contain instructions for coding QC cases impacted by the EUC program. At this point, it is intended that this will involve reopening the case and changing the PROGRAM TYPE to a new code created to embrace EUC. Edits will be changed so that cases with the EUC code are (a) included in case counts for allocation purposes; (b) excluded from timeliness calculations; (c) dropped from the QC sample and thus excluded from the QC annual report; and (d) excluded from other major reports. These cases will be available for analysis. Action Required: State Administrators should provide this information to the appropriate State staff and ensure that: a. All cases in the QC sample that have a program eligibility option are identified; and b. A list of all identified cases is established and maintained for future data entry.

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References: Chapter IV, ET Handbook No. 384, Second Edition, 20 CFR 614.12 and 5 U.S.C. 8521(a)(2). Instructions: State Employment Security Agencies (SESAs) shall use the attached schedule to determine Federal military wages for UCX "first claims" filed beginning with the first day of the first week which begins after April 1, 1995, pursuant to 20 CFR 614.12. SESAs will continue to use the existing schedule for UCX "first claims" filed before the effective date of the attached revised schedule. As provided by 20 CFR 614.12(d), the attached schedule shall be published as a notice in the Federal Register. Action Required: Administrators should provide the above instructions and the attached revised schedule to appropriate staff.

References: Chapter V, Section 5, and Chapter XI, Section 1, ET Handbook No. 391. Instruction: SESAs should provide copies of the attached Federal pay schedules to appropriate staff members engaged in UCFE claims activities. Action Required: SESAs should follow the above instructions and provide the attached revised Federal pay schedule to appropriate staff.