UIPL_21-17_Acc.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION Unemployment Insurance CORRESPONDENCE SYMBOL OUI DPM DATE RESCISSIONS None EXPIRATION DATE December 31 2018 ADVISORY UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. TO STATE WORKFORCE AGENCIES FROM BYRON ZUIDEMA Deputy Assistant Secretary SUBJECT Additional Planning Guidance for the Fiscal Year FY 2018 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 201 8 SQSP. 2. References. Section 303 a 1 of the Social Security Act SSA Government Performance and Results Act GPRA of 1993 Pub. L. 103-62 as amended by GPRA Modernization on Act of 2010 Pub . L. 111-352 Improper Payments Elimination and Recovery Act of 2010 IPERA Pub. L. 111-204 31 U.S.C. 3301 note and 3321 note Improper Payments Elimination and Recovery Improvement Act of 2012 IPERIA Pub. L. 112-248 Section 103 of the Workforce Innovation and Opportunity Act WIOA Pub . L. 113 - 128 20 CFR Parts 601 640 650 652 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. 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 2 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 and Change 2 UIPL No. 09 -13 Integrity Performance Measures for Unemployment Insurance UI and its Change 1 UIPL No. 17 -14 Revised Employment and Training ET Handbook No. 336 18 th Edition Unemployment Insurance UI State Quality Service Plan SQSP Planning and Reporting Guidelines UIPL No. 13 -15 Fiscal Year FY 2015 Unemployment Insurance UI Reemployment Services and Eligibility Assessment RESEA Grants UIPL No. 07-16 Fiscal Year FY 2016 Unemployment Insurance UI Reemployment Services and Eligibility Assessment RESEA Grants UIPL No . 17 -16 Reengineering Unemployment Insurance UI Benefits Program Accountability Process High Priority Des ignation of States with Sustained Poor Performance UIPL No. 03 -17 Fiscal Year FY 2017 Unemployment Insurance UI Reemployment Services and Eligibility Assessment RESEA Grant Workforce Innovation and Opportunity Act Notice of Proposed Rulemaking Pr oposed Rules 80 Fed . Reg . 20573 -20687 April 16 2015 Training and Employment Notice TEN No. 08 -14 Reengineering Unemployment Insurance UI Benefits Program Accountability Processes TEN No. 03 -15 Reengineering Unemployment Insurance UI Benefits Program Accountability Processes Update on Implementation Progress and State Impacts ET Handbook No. 336 Unemployment Insurance UI State Quality Service Plan SQSP Planning and Reporting Guidelines 18 th Edition Change 3 April 2014 ET Handbook No. 395 State Operations Handbook for the Unemployment Insurance UI Benefit Accuracy Measurement BAM Program 5th Edition November 2009 and ET Handbook No. 401 4 th Edition UI Reports Handbook No. 401 . 3. Background . The SQSP is the state s UI per formance management and service plan. It 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. As part of UI Performs the comprehensive performance management system for the UI program the SQSP is the principal vehicle that state UI programs use to plan record and manage improve ment efforts as they strive for excellence in service. The SSA authorizes the Secretary of Labor to provide funds to administer the UI program and govern s the expenditure of those funds. Therefore t he SQSP is the part of the process by which states r eceive Federal UI administrative grants. ET Handbook No. 336 contains general instructions for the SQSP See UIPL No. 03-10 . Th is Handbook is designed as a permanent instruction for the planning and budget 3 process and provides states with planning guide lines and instructions for reporting UI financial and staff year information. ET Handbook No 336 is approved under OMB No. 1205 -0132 . The Handbook provides that t he Employment and Training Administration ETA in the U.S. Department of Labor Departme nt will issue an SQSP UIPL each year with additional planning guidance that supplements the Handbook and provides direction and instructions specific to the upcoming FY. 4. National Priorities . The SQSP process focuses on promoting state performance and integrity aligning state UI administration and operations with national policies paying benefits accurately and timely and connecting UI claimants with needed reemployment services. Each year after consulting with our stakeholders ETA establishes na tional priorities for the UI program. For FY 201 8 ETA s top priorities include a continued focus on the prevention detection and recovery of improper payments improved program performance implementation of the WIOA provisions that relate to the UI pr ogram and robust and innovative reemployment service delivery strategies for UI claimants to speed their return to work . ETA provides the following national priorities for FY 201 8 to help states develop their SQSP . State s should also establish additiona l state -level priorities for the ir UI program. Improving State Capacity to Administer and Operate the UI Program Effectively The UI program acts as an important economic stabilizer when areas experience contractions in their labor markets. It is also a critical safety net for eligible American workers who are unemployed and are able to work available to work and actively seeking work. States continu e to struggle with administrative and operational challenges including changes in program leadership in many states the need to make program improvements to aging technology systems and or to implement new technology solutions the need to reduce staffing levels as workload s and funding decline the loss of key subject matter expertise due to retirements new staff who are still learning the program and overall challenges to improv ing program performance. In develop ing their SQSPs states are strongly encourage d to incorporate administrative capacity -building strategies such as Conducting a business p rocess 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 to enhance state capacity by usi ng information technology to improve staff productivity implement new tools and strategies to reduce improper payments and improve program performance 4 Reviewing staff training strategies to support succession planning and ongoing staff development for n ew staff and Using technical assistance opportunities offered by the Department the UI Information Technology Support Center ITSC and the UI Integrity Center of Excellence as well as the peer -to-peer communication platforms and other information sha ring tools available through the UI Community of Practice CoP . ETA is eager to work with states to make the SQSP process a meaningful management tool to be used by states as a strategic road map to improve program administration and ensure quality servi ce delivery. Improving Prevention Detection and Recovery of UI Improper Payments ETA recognizes that states have made improv ing program integrity a major priority in recent years. Nevertheless the UI program has not met the targets in the Improper Pa yment Elimination and Recovery Act IPERA of 2010. The UI program has been out of compliance since 2012. This is a critical issue given the adverse impact that improper payments have on state UI trust funds. Integrity efforts not only help preserve the se 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 continued effort for ETA and the states to work collaboratively to aggressively reduce improper payments. ETA expect s states to continue to implement national integrity strategies that focus on the largest root causes where states have the greatest likelihood of being able to prevent improper payments including Failure of claimants t o comply with state work search requirements Work Search Payments to individuals who continue to claim benefits after they have returned to work Benefit Year Earnings and Failure of employers or their third -party administrators to provide timely and adequate information on the reason for an individual s separation from employment Separation . ETA encourages states to use the resources of the UI Integrity Center operated by the National Association of State Workforce Agencies. The UI Integrity Center continues to develop new products and should be considered a technical assistance resource for states in addressing integrity related matters. Among its offerings to states the Center compiles best practices for state operation of Benefit Payment Contro l BPC functions develops training modules for state integrity staff and responds to individual state s requests for assistance with integrity operations. When identifying potential strategies to address improper payments states are also encouraged to seek out the Integrity tab on 5 the UI CoP on the WorkforceGPS website which is populated with best practices by the Integrity Center see https ui.workforcegps.org . States should continuously assess whethe r there are other state -specific strategies that will improve their capacity to address the root causes of the state s improper payments and include those strategies in the Integrity Action Plan IAP which is a key component of the SQSP submission. For example states should review their current law s regulations policies procedures and practices that may have the unintended consequence of creating improper payments. Improving Program Performance Nationally ETA has embarked on a multi -pronged strate gy designed to significantly bolster program accountability and facilitate performance improvement nationally. For FY 201 8 ETA will continue the following strategies to meet this objective Continue to provide intensive technical assistance to support p erformance improvements for 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 Implement improvements to the SQSP process as part of a broader effort to reengineer UI benefit accountability processes for the program as a whole. State s will also be expected to implement and use the new UI Benefits Operations State Self -Assessment Tool which will focus on review ing benefit operations in the various functional and program areas. The state s should use the tools and the results of its review to identify and address areas needing improvement in their operations. More information will be provided as this new tool is rolled out to the states. 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 . Workforce Innovation and Opportunity Act WIOA The enactment of WIOA on July 22 2014 has a number of impacts for the UI program including but not limited to provisions related to the requirements for mandatory one - stop partners which includes UI th e type of UI career services that must be provided in one -stop centers and amendments to the Wagner -Peyser Act that speak to the types of employment services that should be available to UI claimants. WIOA seeks to modernize the workforce system to provid e comprehensive integrated and streamlined services which requires linking and aligning the different one -stop partners. 6 As a mandatory one -stop partner the UI program continues to be a vital program within the workforce system and UI claimants cont inue to be critical customers for the system. As such UI state agencies play an important role in the implementation of WIOA and must work collaboratively with other workforce system partners to fully connect UI claimants to the full range of reemploymen t services delivered through the American Job Centers AJCs on -line systems and through the states rapid response programs. States are strongly encouraged as they develop their SQSPs to address implementation of the WIOA provisions as they relate to the operations of the UI program which include Integrating the delivery of services to UI claimants Ensuring meaningful assistance to UI claimants is provided in the AJCs and Partnering with the Wagner -Peyser Act -funded Employment Service ES prog ram to ensure employment services are available to UI claimants. Reemployment of UI Claimants Reemployment of UI claimants remains a top priority for the entire workforce system including UI and as stated above is reinforced with the enactment of WI OA. In FY 2015 ETA made important changes to the Reemployment and Eligibility Assessment s REA program now called the Reemployment Services and Eligibility Assessment s RESEA program. Funding for this program may now be used for the delivery of caree r services in addition to conducting eligibility assessments . With RESEAs there is a focus on targeting claimants that are most likely to exhaust their UI benefits and recipients of Unemployment Compensation for Ex -Servicemembers UCX benefits . The goa l is to provide these populations with a range of services to facilitate enrollment in other workforce programs given they are more likely to have more barriers to reemployment. For more information on the RESEA program please see UIPL No. 13 -15 https wdr.doleta.gov directives corr doc.cfm DOCN 4482 UIPL No. 07 -16 https wdr.doleta.gov directives corr do c.cfm DOCN 6312 and UIPL No. 03 -17 https s wdr.doleta.gov directives corr doc.cfm DOCN 5218 . As states develop their SQSPs they should consider including innovative and robus t reemployment strategies that are jointly developed in collaboration with workforce system partners including but not limited to the WIOA Adult and Dislocated Worker programs the Wagner -Peyser Act -funded ES program and the Trade Adjustment Assistance program. ETA recommends that UI program staff collaborate with these partners to ensure the strategies reflect the agreement s made as part of the WIOA state planning process and as part of the local WIOA Memorandum of Understanding process . 7 Strate gies to consider include Developing integrated registration processes that produce a more complete profile of UI claimants so that AJCs may better serve them by more efficiently targeting reemployment services and job referrals Connecting UI and UCX claimants as quickly as possible to the public labor exchange systems so that they may start receiving job referrals immediately and consider periodically pushing jobs to claimants throughout the claim cycle Integrating information technology systems to support improved reemployment service delivery and Using ongoing assessments to determine whether UI and UCX claimants are having a difficult time finding a job and need additional services. This may include periodic reviews and adjustments to the st ate s worker profiling model to ensure it is still properly identifying claimants most likely to exhaust and be in need of reemployment services. Improving Data Validation and Federal Reporting Data Validation DV is a systematic procedure for assessin g the accuracy of UI reports required by ETA and is a critical part of guaranteeing the integrity of the UI program as a whole. DV informs several essential government functions including performance assessment budget formulation and economic management . By ensuring states are reporting accurate counts and storing key data points correctly the performance and workload of a state UI program is more accurate . The Department uses UI DV results to evaluate the accuracy of the data states report on selecte d UI required reports. Accurately reported data are essential for properly assessing state performance for ensuring that states are treated equitably when administrative funds are distributed and for providing a basis for many statistical research analy ses. Because performance measures are intended to guide and assist states in improving their performance and service to their ultimate customers workers and employers states also have an interest in ensuring that the data from reports upon which these measures are based are correct. The DV system includes detailed guidance to state programmers for correctly constructing various report elements. This not only ensures they will construct the DV extract files accurately but also will simplify their ta sks when new tax or benefit system software is installed. Addressing Worker Misclassification States should monitor their performance under the Effective Audit Measure See UIPL No. 03 -11 https wdr.doleta.gov directives corr doc.cfm DOCN 2971 to determine whether they are effectively detecting and preventing worker misclassification. 8 States may deploy a wide array of strategies to address worker misclassification. ETA encour ages states to develop and implement state -driven strategies to address the misclassification of workers and to include those strategies in the state s SQSP. ETA will continue to identify state best practices in this area and share them broadly. The UI CoP provides states the ability to review and select best practices from other states that they can implement to address the issue of worker misclassification. Government Performance and Results Act GPRA UI Performance Measures Federal Emphasis The Government Performance and Results Act of 1993 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 t he national priorities attention continues to be focused on the following GPRA goals for FY 201 8 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. See https oui.doleta.gov unemploy docs GPRA Summary Report.asp for the FY 2018 GPRA goals and targets. Percent of Intrastate Payments Made Timely Make Timely Benefit Payments o Targe t 87. 0 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. Detection of Recoverable Overpayments Detect Benefit Overpayments o Tar get Overpayments established will be at least 61 .9 percent of the estimated detectable recoverable overpayments. Percent of Employer Tax Liability Determinations Made Timely Establis h Tax Accounts Promptly o Target 89.0 percent of status determinat ions for new employers will be made within 90 days of the end of the first quarter in which liability occurred. UI Re -employment Rate . A measure of the reemployment rate at the second quarter after exit for all UI claimants registered with the Wagner -Peys er Act - funded ES system includes all participants receiving UI benefits regardless of whether or not they came into the program employed an example of which would be a claimant with part -time employment and earnings below the state s earning allowance . The data for the implementation of this UI measure will require new reporting by the states. The new data collection process began in November 9 2016 with first reports to ETA due in July 2017. A target will be implemented upon availability of adequate d ata to conduct analysis and to establish an annual national target for this measure. ETA expects to establish a national target for this measure in FY 2019. 5. WIOA Combined State Plans . WIOA provides the option for states to include program plans for mand atory one -stop partner s and other programs to submit a Combined Plan. Given that the UI program is a mandatory one -stop partner states have the option of including the UI program as part of the WIOA Combined State Plan. However each state must particip ate in the UI Performs SQSP process whether or not the state decides to include UI as part of its WIOA Combined State Plan. States electing to include UI in a Combined Plan must incorporate the SQSP in its entirety into the Combine d Plan through the Co mbined State Plan process. Subsequent SQSPs are to be incorporated into the Combined Plan upon approval of the SQSP but no later than October 31 2017. For the states that choose to include UI in a Combined Plan these states must cut -and - paste the SQ SP documents into the WIOA State Plan Portal. However the Portal has limitations and not all approved SQSP documents can be incorporated into the Portal. Below are specific instructions for including SQSP documents into the Portal a Transmittal Lette r The Portal does not support Adobe Portable Document Format PDF therefore states including UI in a Combined Plan must include the unsigned M icro soft Word version of the transmittal letter into the Portal. States are to add a note at the end of this section in the Portal that the signed copy of the transmittal letter is maintained with the state agency and the RO . b SQSP Narrative Corrective Action Plans CAPs and IAP The CAP and Quarterly Reporting Workbook documents are Excel documents with mu ltiple rows in a single column which is not supported by the Portal . Therefore states including UI in a Combined Plan must use the M icrosoft Word version of the CAP IAP and Narrative forms. c Budget Worksheets Forms The Portal does not support Adob e PDF therefore states including UI in a Combined Plan must add a note at the end of the section that includes information from the SF 424 the title description funding total project start and end date and the name of the authorizing representative . The note also must include a state ment that the signed copy of the SF 424 and other appropriate budget - related forms are maintained with the state agency and the RO . d Organization Chart These charts are to be converted to M icrosoft Word and cut - and -paste d into the Portal. If the state cannot convert the chart into M icrosoft Word 10 format the state must add a note at the end of this section in the Portal that the Organization Chart is maintained with the state agency and the RO . e SQSP Signature Page The Portal does not support Adobe PDF format therefore states including UI in a Combined Plan must include the unsigned version of the Signature Page. The approving official s name must be typed on the form that is submitted into the Portal. States mus t include a note at the end of this section in the portal that the signed copy of the SQSP Signature Page is maintained with the state agency and the RO . Note Since the Portal has limitations and does not support PDF documents signed signature pages cannot be loaded . Therefore a ll approved signed SQSP documents must also reside in the RO 6. UI Program Performance and Criteria for FY 201 8. The attachment lists the performance criteria for the Core Measures Secretary s Standards and other program requirements where CAPs and or Narratives may be expected if annual performance is not acceptable. A. Core Measures . Performance below the ALPs for Core Measures is expected to be addressed in a CAP unless otherwise indicated. Core Measures are listed in Attachment A. Additional instructions for Core Measures are as follows UI Re -employment Rate . A measure of the reemployment rate at the second quarter after exit for all UI claimants registered with the Wagner -Peyser system includes all participants r eceiving UI benefits regardless of whether or not they came into the program employed. The data for the implementation of this UI measure will require new reporting by the states. The new data collection process began in November 2016 with first report s to ETA due in July 2017. A target will be implemented upon availability of adequate data to conduct analysis and to establish an annual national target for this measure. ETA expects to establish a national target for this measure in FY 2019. The De tec tion 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 mostly 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 Na rrative 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 BPC activities or misreporting of data on the ETA 227 Overpayment Detection and Recovery Activitie s report the state is 11 expected to submit a CAP for BAM Overpayment Detection or BPC Overpayment Detection . The CAP is to be designed to produce valid data for the Overpayment Detection Measure. The performance period for the BPC component is the thre e-year period ending March 31 2017 the performance period for the BAM component is the three -year period ending September 30 2016. UI Integrity Measure - Benefit Year Earnings BYE . This measure has been discontinued . ETA is currently developing a management information measure Average Amount of UI Overpayment AUO that will assist states in capturing and analyzing their overpayments levels. More information regarding the AUO will be provided in future guidance. Effective Audit Measure . The Effective Audit Measure as noted in UIPL No. 03 -11 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 N umber of Misclassifications Detected Per Audit . Each of the four factors has a minimum standard score that states must attain to pass the Effective Audit Measure as well as an overall combined score that must be met. The measure also requires states to direct additional emphasis to the factor s that they deem important to their state. An additional two points must be earned among any of the four factors to attain the overall passing score of at least 7.0. States that do not meet this measure will be e xpected to develop a CAP based on CY 2016 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 Comp ensation for Federal Employees UCFE and Unemployment Compensation for Ex -Service members UCX programs. Before the enactment of IPERIA ETA used a methodology which subtracted UI overpayment recoveries for the computation of the estimated improper payment rate. However 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. ETA s revised methodology consistent with IPERIA no longer nets out recoveries for the computation of the improper payment rate. Please refer to UIPL No. 09 -13 Change 1 for a detailed discussion on the changed methodology. In accordance with requirements in section 3 a 3 F IPERA an ALP of l ess than 10 percent has been established for the improper payment measure. That is states must maintain an improper payment rate of less than 10 percent for covered programs. This ALP is applicable to the 2016 Improper Payments Information Act IPIA pe rformance period Ju ne 28 2015 to June 25 2016 . States failing to 12 meet the ALP for the 2016 IPIA performance period will be expected to develop a CAP as part of the FY 2018 SQSP. UI Overpayment Recovery Measure . As explained in UIPL No. 09 -13 the recovery rate is the amount of improper overpayments recovered divided by the amount of improper overpayments identified. The ALP for the recovery rate measure is 68 percent for the 2016 IPIA performance period. The Department will compute future recov ery targets based on the most recent recovery and other performance data available. The performance period will be based on data from the ETA 227 Overpayment Detection and Recovery Activity Regular and ETA 227 Overpayment Detection and Recovery Activ ity Emergency Unemployment Compensation EUC for the IPIA period July 1 2015 to June 30 2016 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. States failing to meet the ALP for the 2016 IPIA performance period will be expected to develop a CAP as part of the FY 2018 SQSP. B. 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. Secretary s Standards are listed in the a ttachment. C. UI Programs The following UI Programs must be addressed as described below National Directory of New Hires NDNH State BAM operations tha t 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. 03-07 and UIPL No. 03-07 Change 1 must be addressed in a CAP for FY 2018 . Benefit Accuracy Measurement 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 and throu gh findings established through ET Handbook No. 396 4th Edition monitoring reviews based on the annual determination letter issued May 1 2017 must be addressed in a CAP . This includes paid and denied claim population variances outside established con trol limits. 13 Tax Performance System TPS To ensure that UI tax operations are in compliance with Federal reporting and oversight requirements failure to conduct one or more TPS sample reviews will be subject to a CAP. Additionally a tax function tha t 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 u niverses 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 acc ordingly. Data Validation DV The deadline for submitting DV results is June 10 2017 . DV items that fail to pass validation or that are due but not submitted are expected to be addressed in the state s FY 2018 SQSP. Non -submitted items include fai lures to certify that Module 3 of the DV Benefits and Tax Handbooks are up -to-date during the April 1 June 10 2017 certification window. Any DV items due for Validation Year VY 2017 that do not pass or are not submitted by the June 10 2017 deadlin e must be addresse d in a CAP for FY 2018 . ROs will monitor states every three years on cycles coinciding with the DV validation year. They will ass ess the accuracy of the state s DV results considered passing or not due as of the time of the monitoring review to verify that the states are properly implementing the DV program. DV items submitted as passing but which a monitoring review determined to have failed must also be addressed in the SQSP. The FY 2018 SQSP CAP will include DV items failing after review in the VY 2017 monitoring cycle monitored between June 11 2016 and June 10 2017 . All subsequent SQSP cycles will address items changed from pass to fail in the previous year s monitoring review. UI Program Integrity States are required to report their planned activities to prevent detect reduce and recover improper UI payments in their IAP which should be submitted as part of their SQSP submission. States should convene their previously established cross - functional integrity task force to update their IAP . S tates 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 Depa rtment s Web site at https www.dol.gov general maps data . 14 ETA will continue to provide technical assistance to states to support their integrity activities through webinars individual state technica l assistance and in partnership with the UI Integrity Center. States are strongly encouraged to review and consider the use of the Integrity Center s products and tools as part of their own state -specific work search strategies. These products and tools are posted on the Integrity tab at https ui.workforcegps.org . In addition ETA will work with states to expand participation in the Treasury Offset Program for the recovery of overpayments to implement a nd use 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 format and instructions for the UI Program Integrity Act ion Plan are in ET Handbook 336 18 th Edition Appendix I. D. Other UI Performance States are expected to address the following performance deficiencies in the SQSP Narrative unless otherwise indicated Failure to conduct required program reviews Defi ciencies 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 measur e 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 addre ss the steps they will take to record the IDD and DD correctly in the SQSP Narrative. 7. SQSP Planning Guidance and Requirements . ET Handbook No. 336 18 th Edition Change 3 and this UIPL provide guidelines for the completion and submission of the SQSP for FY 201 8. 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 and remains uncorrected before the preparation of the SQSP. 15 The measurement period for the FY 201 8 SQSP is April 1 201 6 March 31 201 7 unless otherwis e indicated see attachment . CAPs and Narratives addressing performance deficiencies are components of the state s formal plan and schedule for improving performance therefore the cause s of performance shortfalls should be thoroughly analyzed before the development of the state s SQSP . A. SQSP Submittal The SQSP process provides a 24 -month window for states to adequately plan and implement performance improvement efforts. The process provides for two types of submittals a Formal two -year biennial plan and an Alternate year plan. 1 SQSP Formal Submittal The Formal submittal consists of a complete SQSP package. It must contain a transmittal letter the State Plan Narrative CAPs the IAP budget worksheets forms assurances organizational char ts 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. States may also develop extended multi -year CAPs so that efforts that m ust 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 plan ning cycle but should provide enough information to explain anticipated progress and results. 2 SQSP Alternate Year Submittal The SQSP Alternate year submittal consists of items included in the state s request for Federal UI administrative funding as we ll as modifications to SQSPs. It must contain at the least a transmittal letter budget worksheets organizational chart if changed SQSP Signature Page CAPs for new performance deficiencies and required modifications to existing CAPs. Since state s and ROs will continue to review reported performance data monitor program performance and initiate corrective actions when warranted the SQSP Alternate year submittal will require states to submit new CAPs 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 informed by their RO if modifications are r equired to the State Plan Narrative existing CAPs and IAPs to include for example 16 Missed milestones and New strategies for performance improvement. Budget worksheets and various assurances will continue to be submitted annually since funds for UI o perations are appropriated each FY. These and other required documents related to the Federal UI administrative funding process are to be submitted with both the Formal biennial SQSP and the Alternate year submittal s. Additional descriptions of the Form al and Alternat e year submittal SQSP cycle schedule significant activities and dates relating to the submittal and approval of the SQSP are outlined in ET Handbook No. 336 18 th Edition Change 3 . B. SQSP Preparation States must use t he Excel CAP Workboo k to develop their CAPs and IAPs for the SQSP submissions . States must use the CAP Workbook also for reporting updates to the specific milestones and performance each quarter. The RO will provide states with the Excel Workbook and specific instructions at the beginning of each SQSP planning cycle. C. The At -Risk Process ETA had previously identified persistently low performing states as At -Risk since FY 2011 because of consistently significant low performance for the first payment and appeals time liness measures . States that have been identified as At -Risk in previous years will continue to work collaboratively with ETA to achieve performance improvement. The action strategies and technical assistance activities are to be included in the state s SQSP CAP for those measures that have caused the state to be designated At -Risk. The At -Risk designation will continue until each of the remaining state s designated as At -Risk meet s the ALP for the identified performance measure for six consecut ive months and is likely to continue to sustain this performance improvement. These states will also continue to receive enhanced technical assistance as needed. The ROs must schedule and conduct quarterly status calls with each At -Risk state to dis cuss the state s progress in implementing the activities and strategies identified in the SQSP and the state s progress towards achieving the performance standards. D. High Priority States As part of the reengineering of its program oversight and accou ntability processes ETA developed a new process for identifying states that are considered to be High Priority and in need of more intensive technical assistance. Please refer to TEN Nos. 08-14 and 3-15 for details. The High Priority model is designed to take a variety of important program performance measures relating to UI benefit payment performance integrity and operations and to produce a score for each state. The methodology was developed to 17 include integral parts of UI Performs core measures DV results and program integrity - related data . The selected High Priority state s will be formally notified by ETA with information on the specific focus areas that caused their selection under this initiative. One of the key aspects of this proces s is an on -site review with each High Priority state by a select expert team of program specialists . The expert team will include National Regional and state subject matter experts on the issue areas identified as needing improvement. ETA will work c ollaboratively with each state to identify strategies and action steps to enable the state to improve its performance in the areas identified by the on -site review. The High Priority designation framework and process are outlined in UIPL No. 17 -16 . The High Priority designation will continue until the state completes corrective actions resulting from the state s on -site review meets the standards for the core measures related to the areas of concerns during the initial designation process for six conse cutive months and is likely to continue to sustain this performance improvement and maintains performance in other program areas without any diminution of performance. ROs must schedule and conduct quarterly status calls with each High Priority state t o discuss the state s progress in implementing the activities and strategies identified during the on -site review and in the state s SQSP . The quarterly calls will include the High Priority state the RO and the National Office. E. SQSP Assurances By sig ning the SQSP Signature Page a state certifies that it will comply with the assurances listed in ET Handbook No. 336 18 th Edition and institute plans or measures to comply with the requirements for each of the assurances. States will continue to provi de information for the Assurance of Contingency Planning and the Assurance of Automated Information Systems Security . In the State Plan Narrative Section H states are expected to provide the dates that their Information Technology IT Contingency Plan System Security Plan and Risk Assessment were implemented tested and reviewed updated. States must 1 Review and if necessary update and test its IT Contingency Plan annually 2 Review and or update its System Security Plan annually and 3 Con duct a Risk Assessment once every three years. If a state does not have an IT Contingency Plan System Security Plan and Risk Assessment procedures in place or if these documents are incomplete then the state is expected to address the actions it plan s to take to meet these requirements in a CAP . 18 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 18 th Edition Change 3. 8. Funding Period . The Department s p roposed FY 201 8 appropriation language allows for obligation of UI allocations by states through December 31 201 8 with 90 additional days to liquidate the obligations and complete the expenditure of funds. Under this proposed language states would be a ble to obligate FY 201 8 UI funds through September 30 20 20 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 and states would be able to obligate FY 201 8 UI funds through September 30 202 3 if such obligations are for automation acquisitions being carried out through a consortia of states. Therefore if Congress adopts the p roposed FY 201 8 appropriations language the end of the obligation period for regular state UI administrative funds will be December 31 201 8 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 20 20 . ETA will notify state agencies if Congress adopts this language. 9. Data Availability . The ROs will provide states with data showing their perfo rmance 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 201 8. States electing to include UI in a Combined Plan must incorporate the SQSP into the Combined Plan upon approval of the SQSP but no later than October 31 2017. 11. Electronic Submission of the SQSP . States must submit the SQSP electronically and sh ould 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 and may be downloaded f rom the OMB W eb 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 sub mit the signature page electronically which includes by fax or scan must submit the signature page by mail by the deadline set by the RO. 12. Action Requested . State Administrators are requested to Make this information available to appropriate sta ff Prepare their SQSPs in accordance with instructions in this UIPL and the planning and reporting instructions contained in ET Handbook No. 336 18 th Edition Change 3 19 Coordinate specifics as appropriate with the RO for electronic submission of the plan and Submit the FY 201 8 SQSP to the appropriate RO by the deadline set by that RO . 13. Inquiries . Questions should be directed to the appropriate RO. 14. Attachment . Measures Programs to be addressed in the F iscal Year FY 201 8 State Quality Service Plan SQSP