UIPL_17-16_Acc.pdf

ETA Advisory File Text

CLASSIFICATION EMPLOYMENT AND TRAINING ADMINISTRATION Unemployment Insurance ADVISORY SYSTEM CORRESPONDENCE SYMBOL U.S. DEPARTMENT OF LABOR OUI DPM Washington D.C. 20210 DATE RESCISSIONS EXPIRATION DATE None Continuing ADVISORY UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. TO STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE UNEMPLOYMENT INSURANCE DIRECTORS FROM PORTIA WU Assistant Secretary SUBJECT Reengineering Unemployment Insurance UI Benefits Program Accountability Process High Priority Designation of States with Sustained Poor Performance 1. Purpose. To inform states regarding the new selection process for designating low performing states as High Priority and the process for removal from that designation. 2. References. Section 303 a 1 of the Social Security Act SSA Title 20 Code of Federal Regulations Parts 602-617 625 640 and 650 Unemployment Insurance Program Letter 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. 33-11 Identification of Improper Payment High Priority States for Unemployment Insurance UIPL No. 9-13 Change 1 Integrity Performance Measure for Unemployment Insurance UIPL No. 17-15 Additional Planning Guidance for the Fiscal Year FY 2016 Unemployment Insurance UI State Quality Service Plan SQSP Training and Employment Notice TEN No. 8-14 Reengineering Unemployment Insurance UI Benefits Program Accountability Process TEN No. 3 -15 Reengineering Unemployment Insurance UI Benefits Program Accountability Processes Update on Implementation Progress and State Impacts Employment and Training ET Handbook No. 301 5th Edition UI Performs Benefits Timeliness and Quality Nonmonetary Determinations Quality Review ET Handbook No. 382 3rd Edition Handbook for Measuring Unemployment Insurance Lower Authority Appeals Quality 2 ET Handbook No. 395 5th Edition Benefit Accuracy Measurement State Operations Handbook and ET Handbook No. 396 4TH Edition Unemployment Insurance Benefit Accuracy Measurement Monitoring Handbook. 3. Background. In April 2014 the Employment and Training Administration ETA initiated a project to reengineer UI benefit p rogram accountability processes. ETA realized that a change in the current benefit accountability processes was needed to address the evolving changes occurring in the UI program. The UI system has a complex array of accountability and performance measurement processes designed to ensure program integrity and quality. Over the years the UI program has changed and evolved and is now facing challenges such as aging information technology systems and increased operating costs to support these systems and staffing reductions due to continued funding co nstraints. TEN Nos. 08-14 and 0 3-15 outlined the new framework undertaken by ETA. As part of the new framework for UI benefit accountability processes ETA has developed a new process for identifying states that are considered to be High Priority and in need of more intensive technical assistance. For ov er five years ETA used two processes and designations that relate to st ates struggling with program performance and or program integrity issues. UIPL No. 22-10 describes the previous process of selecting and monitoring states designated as At-Risk for continuous improvement with First Payment Timeliness and First Level Appeals Promptness performance. UIPL No. 33-11 describes the previous process for selecting states with program integrity issues to be designated as High Priority. The goa l of both processes described in these two UIPLs was to provide enhanced monitoring and intensive technical assistance to the designated states in support of performance impr ovement. As discussed in more detail below the new reengineered framework envisions a single designation of High Priority for states with performance challenges. 4. The New High Priority Designation Framework. The new Hig h Priority Model integrates a variety of important program performance measures relating to UI benefit payment performance integrity and op erations. The methodology was developed to include integral parts of UI Performs core measures d ata validation results and program integrity-related data as explained in further detail below. The UI Performs Core Measures used in the model are currently documented here http www.ows.doleta.gov unemploy pdf Core Measures.pdf. The variables in the mode l primarily contain all core benefit measures three out of the four Core Performance Program Integrity measures one of the core appeals measures and one additional p rogram-integrity data item not used as a core measure. The model also takes into account state d ata v alidation results. The new High Priority Model consists of four data inputs that will be used to determine if a state will be designated as High Priority. The data inputs are 1 Benefits Appeals and Data 3 Validations Results 2 Program Integrity and Data Validation Results 3 State Self-Assessment Results and 4 ETA Regional National Office Input. A graphic depiction of the High Priority Model is provided in Attachment A. The High Priority Model compiles performance data from the states UI benefit payment operations using the following data inputs A. Benefits Appeals and Data Validation Results Module . This component includes the core benefit s and appeals m easures and data validation results. The following measures will be included as part of this module 1. Benefit Measures a First Payment Timeliness percent of all first payments made within 14 21 days after the week ending date of the first compensable week in the benefit year. First payments must be made within 14 days for states with a waiting week and 21 days for states without a waiting week. b Nonmonetary Determinations Time Lapse - Percent of nonmonetary determinations separations and nonseparations made within 21 days of the date of detection of any nonmonetary issue that had the potential to affect the claimant s benefit rights. c Nonmonetary Determination Quality Nonseparations - Percent of nonseparation determinations with quality scores equal to or greater than 95 points based on the evaluation results of quarterly samples selected from the universe of nonseparation determinations. d Nonmonetary Determination Quality Separations - Percent of separation determinations with quality scores equal to or greater than 95 points based on the evaluation results of quarterly samples selected from the universe of separation determinations. 2. Appeals Measures Average Age of Pending Lower Authority Appeals The sum of the ages in days from filing of all pending lower authority appeals divided by the number of lower authority appeals. 3. Data Validation Results Population corresponding with the following areas a First Payment Timeliness Benefit Population 4 b Nonmonetary Determinations Timeliness Benefit Population 5 c Separation Determinations Quality Benefit Item BTQ1 d Nonseparations Determination Quality Benefit Item BTQ2 e Lower Authority Appeals Timeliness Benefit Populations 8 and 10 B. Program Integrity and Data Valid ation Results Module. This module will include the following p ro gram integrity components 1. Integrity Measures 4 a Overpayment Detection Percent of detectable recoverable overpayments estimated by the Benefit Accuracy Measurement BAM survey that were actually established for recovery by the state. b Ove rpayment Recovery Percent of overpayments recovered of established overpayments that are not waived. c Improper Payments Percent of BAM estimated benefits overpaid plus BAM estimated benefits underpaid. 2. Integrity Data - Operational Rate Non-UI Performs Core Measure Pe rce nt of fraud and nonfraud overpayments that states are reasonably expected to detect and establish for recovery excluding work search employment service registration base period wage issues and miscellaneous causes such as benefits paid during a period of disqualification redeterminations and b ack pay awards of total benefit outlays. 3. Data Validation Results Population corresponding with the following areas a Overpayments Established Benefit Population 12 b Overpayment Recovery Benefit Population 13 C. State Self-Assessment Results Module. A new component of the reengineered UI benefit accountability processes is a state self-assessment tool that states will complete annually to identify and implement improved business processes. The results from the UI Benefits Program Operations State Self-Assessment will assist ETA in monitoring the states quality of operations and identify areas where improvement is needed. The self- assessment is completed by dedicated state staff state employee or contractor . The self- assessment consists of fifteen 15 functional areas see Attachment B . Th e state self- assessment tool was piloted with nine states California Colorado Connecticut Delaware Georgia Idaho Minnesota New Hampshire and Utah and the feedback received from the pilot states is being used to further refine the self-assessment questionnaires. ETA is in the process of developing an approach to incorporate the results from the state self-assessment into the High Priority state composite score. This will require a full year of state self-assessment data so the data from the state s self- assessment will not be part of ETA s High Priority designation process until Fiscal Year FY 2018 at the earliest. States will have an opportunity to provide comments on the self-assessment too l as part of the Office of Management and Budget s Paperwork Reduction Act clearance process which was announced in the Federal Register Notice https www.federalregister.gov articles 2016 06 30 2016-15467 agency-information- collection-activities-comment-request-unemployment-insurance-benefits-operations . D. ETA Regional National Office Input. ETA Regional National Office input is the last component used in determining which state s will be designated High Priority. Examples of this input include findings from prior program reviews Office of Inspector General or General Accounting Office audits awareness of significant changes to state policies IT systems or program leadership and other data and information available regarding the state s administration of the program. 5 5. High Priority Designation Process Selection as a High Priority State . The information from each of the modules described above will be part of the process for designating High Priority states. Attachment A outlines how the scores are computed for each module. The selected H igh Priority state s will be for mally notified by ETA with infor mation on the specific areas that caused their selection as High Priority. One of the key aspects of this new process is the on -site review with each High Priority state by a selec t e xpert review team. The expert team is made up of National Regional and State subject matter experts SMEs on the issue areas identified as needing improvement. State S ME s will be used only for providing technical assistance. The expert tea m will conduct the on -site review with the designated High Priority state . The on -site re view is designed to identify process improvements needed and provide enhanced technical assistance that will support implementation of those process improvements and result in improved program performance. The expert team may evaluate other areas if the data indicate potential problems in those areas that were not previously identified. At the end of the review states will be issued a formal Monitoring Report by the Region that will identify any findings areas of concern and best practices. Additionally b ased on the issues identified in the on-site review and action steps for process improvement states may be required to modify their State Quality Service Plan SQSP to either revise their existing corrective action plan CAP or add new CAP s as appropriate . 6. High Priority Designation Removal Process. The purpose of the High Priority Designation and its associated process es is to enable ETA to provide more enhanced monitoring and technical assistance to the state to allow the state to improve in those specific areas of concern without the detriment to other program areas. ETA will work collaboratively with the state to identify strategies and action steps that will enable the state to improve its performance in the areas identified during the on -site review. In order to have the High Priority designation removed a state must a Complete corrective actions resulting from the state s on-site review b Meet and sustain any Acceptable Level of Performance ALP for the core measures relate d to the areas of concerns during the initial designation process The High Priority designation will continue until the state meets the ALP standard s http www.ows.doleta.gov unemploy pdf Core Measures.pdf for six consecutive months The state can show that it is likely to continue to sustain the performance improvement and c Maintain performance in other program areas without any diminution of performance i.e. the improved performance in the identified performance areas must not negatively impact the performance in other measured areas. 7. Action Requested. State administrators and UI directors are requested to provide the above information to all appropriate state personnel. 6 8. Inquiries. Inquiries should be directed to your Regional Office. 9. Attachments. Attachment A High Priority Model Computing the Scores Attachment B The Operational Functions Chart