UIPL_18_16_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 August 1 2016 RESCISSIONS EXPIRATION DATE None December 31 2017 ADVISORY UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 18-16 TO STATE WORKFORCE AGENCIES F ROM PORTIA WU s Assistant Secretary S UBJECT Additional Planning Guidance for the Fiscal Year FY 201 7 Unemployment Insurance UI State Quality Service Plan SQSP 1. P urpose. To initiate the SQSP process provide supplemental instructions and define additional requirements for the FY 201 7 SQSP. 2. Re ferences. S ection 303 a 1 of the Social Security Act SSA Gove rnment Performance and Results Act of 1993 GPRA Pub. L. 103 -62 as amended by Pub. L. 111-352 GPRA Modernization Act of 2010 I mproper Payments Elimination and Recovery Act of 2010 IPERA Pub. L. 111-204 31 U.S.C. 3301 note and 3321 note W orkforce Innovation and Opportunity Act WIOA Pub. L. 105-220 Title I S ection 103 of the Workforce Innovation and Opportunity Act Pub . L. 113-128 July 22 2014 20 CF R Parts 640 650 652 and 660 Une mployment Insurance Program Letter UIPL No. 14-05 Changes to UI Performs and its Changes 1 2 and 3 U IPL No. 22-05 Unemployment Insurance Data Validation UI DV Program Software and Policy Guidance and its Changes 1 and 2 U IPL No. 3-07 Use of National Directory of New Hires NDNH in Unemployment Insurance UI Benefit Accuracy Measurement BAM Audits and its Change 1 U IPL No. 12-08 Establishing an Acceptable Level of Performance ALP for the Unemployment Insurance UI Reemployment Rate Measure U IPL No. 22-10 Selecting and Monitoring At-Risk States for Continuous Improvement and Compliance with First Payment Timeliness and First Level Appeals Promptness U IPL No. 03-11 Implementation of the Effective Audit Measure U IPL No. 19-11 National Effort to Reduce Improper Payments in the Unemployment Insurance UI Program 2 UIPL No. 34-11 Performance Measure for Unemployment Insurance UI Integrity and its Change 1 and Change 2 U IPL No. 09-13 Integrity Performance Measures for Unemployment Insurance UI and its Change 1 U IPL No. 17-14 Revised Employment and Training ET Handbook No. 336 18th Edition Unemployment Insurance UI State Quality Service Plan SQSP Planning and Reporting Guidelines U IPL No. 13-15 Fiscal Year FY 2015 Unemployment Insurance UI Reemployment Services and Eligibility Assessment RESEA Grants U IPL No . 07-16 Fiscal Year FY 2016 Unemployment Insurance UI Reemployment Services and Eligibility Assessment RESEA Grants U IPL No . 17-16 Reengineering Unemployment Insurance UI Benefits Program Accountability Process High Priority Designation of States with Sustained Poor Performance W orkforce Innovation and Opportunity Act Notice of Proposed Rulemaking Proposed Rules 80 Fed. Reg. 20687-21150 April 16 2015 Tr aining and Employment Notice TEN No. 08-14 Reengineering Unemployment Insurance UI Benefits Program Accountability Processes TEN No. 29-14 Announcing the release of the Workforce Innovation and Opportunity Act WIOA Notices of Proposed Rulemaking NPRMs on Federal Register PublicInspection TEN No. 03 -15 Reengineering Unemployment Insurance UI Benefits Program Accountability Processes Update on Implementation Progress and State Impacts ET H andbook No. 336 Unemployment Insurance UI State Quality Service Plan SQSP Planning and Reporting Guidelines 18th Edition Change 3 April 2014 ET H andbook No. 395 State Operations Handbook for the Unemployment Insurance UI Benefit Accuracy Measurement BAM Program 5th Edition November 2009 and ET H andbook No. 401 4th Edition UI Reports Handbook No. 401.3. B ackground. The SQSP is the state s UI performance management and service plan. Itrepresents 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 a nd 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 improvement efforts as they strive for excellence in service.The SSA authorizes the Secretary of Labor to provide funds to administer the UI program a nd governs the expenditure of those funds. Therefore the SQSP is the part of the process by which states receive Federal UI administrative grants. ET H andbook No. 336 contains general instructions for the SQSP See UIPL No. 3-10 . This Handbook is designed as a permanent instruction for the planning and budget process and provides states with planning guidelines and instructions for reporting UI financial and staff year information. The Employment and Training Administration ETA in the U.S. Department of Labor Department issues this annual SQSP UIPL with additional planning 3 guidance that supplements the Handbook and provides direction and instructions specific to the upcoming FY. 4. National Priorities. In addition to focusing on state performance and integrity the SQSP process also focuses on aligning state UI administration and operations with national policies and priorities for paying benefits accurately and timely and providing reemployment services. Each year after consulting with our stakeholders ETA establishes national priorities for the UI program. For FY 2017 ETA s top priorities include a continued focus on the prevention detection and recovery of improper payments improved program performance WIOA provisions that relate to the UI program robust and innovative reemployment service delivery strategies for UI claimants to speed their return to work and strategies to improve detection of misclassified workers. ETA provides the following national priorities for FY 2017 to help states develop their SQSP including the establishment of state-level priorities for the UI program. Improving State Capacity to Administer and Operate the UI Program Effectively The UI program continues to be a critical safety net for eligible American workers who are unemployed and are able to work available to work and actively seeking work. States are continuing to struggle with administrative and operational challenges including those that were a result of the Great Recession. An example of those challenges include new program leadership in many states a greater demand to make program improvements and or to implement new technology solutions the need to reduce staffing levels as workload diminishes loss of key subject matter expertise due to retirements many new staff who are still learning the program and struggles to improve program performance. As states continue to develop and implement new strategies to improve program accountability and integrity we strongly encourage states to develop their SQSPs to incorporate administrative capacity-building strategies such as Conducting a business process analysis to identify opportunities for improving program operations and implementing recommendations from the analysis to improve performance Using Supplemental Budget Request opportunities to implement strategies most likely to enhance state capacity by using information technology to improve staff productivity implement new tools and strategies to reduce improper payments and improve program performance Reviewing staff training strategies to support succession planning and ongoing staff development for new 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 4 the peer- to-peer communication platforms and other information sharing 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 used by states as a strategic road map to improve program administration and ensure quality service delivery. Improving Prevention Detection and Recovery of UI Improper Payments Despite the aggressive efforts states have made to improve program integrity over the last six years the UI program remains out of compliance with the Improper Payment Elimination and Recovery Act IPERA of 2010 as a result of having an improper payment rate that exceeds 10 percent nationally. 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 these unemployment funds and control UI tax rates but they also maintain the public trust that the program is protected and operated as intended. As such there will be a continued intensified effort for ETA and the states to work collaboratively to aggressively reduce improper payments. ETA will continue to work with states to actively improve prevention detection and recovery of improper payments. ETA is expecting states to continue to implement national integrity strategies that focus on the largest national root causes including Payments to individuals who continue to claim benefits after they have returned to work Benefit Year Earnings 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 and Failure of claimants to comply with the state s work search requirements Work Search . Additionally states should continuously assess whether 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. Improving Program Performance Nationally ETA has embarked on a multi-pronged strategy designed to significantly bolster program accountability and facilitate performance improvement nationally. For FY 2017 ETA will continue the following strategies to meet this objective Continue to provide intensive technical assistance to support performance 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 5 Implement improvements to the SQSP process as part of a broader effort to reengineer UI benefit accountability processes for the program as a whole. As state s 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 of which UI is one the type of UI career services that must be provided in one-stop centers and new language in 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 provide comprehensive integrated and streamlined services which requires linking and aligning the different one-stop partners. As a mandatory one-stop partner the UI program continues to be a vital program within the workforce system and UI claimants continue 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 workforce system programs to fully connect UI claimants to the full range of reemployment services delivered through the American Job Centers AJCs on- li ne 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 it relates to the operations of the UI program. 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 WIOA. In FY 2015 ETA made important changes to the Reemployment and Eligibility Assessment REA program now called the Reemployment Services and Eligibility Assessment RESEA program. Funding for this program may now be used for the delivery of reemployment services. In addition there is a new focus on targeting those claimants that are most likely to exhaust their benefits and recipients of Unemployment Compensation for Ex- Servicemembers UCX . The goal is to provide more intensive reemployment services to these populations given they are more likely to have more barriers to reemployment. For more information on the RESEA program please see UIPL No. 13-15 http wdr.doleta.gov directives corr doc.cfm DOCN 4482 and UIPL No. 07-16 http wdr.doleta.gov directives corr doc.cfm DOCN 6312 . As states develop their SQSPs they should consider including innovative and robust reemployment strategies that are jointly developed in collaboration with workforce system partners including but not limited to the WIOA Adult and Dislocated Worker programs the 6 Wagner-Peyser funded Employment Service program and the Trade Adjustment Assistance program. These strategies may include Developing intake processes that produce a more complete profile on UI claimants so that AJCs may serve them by more efficiently targeting reemployment services and job referrals Connecting UI claimants as quickly as possible to the public labor exchange systems so that they may start receiving job referrals immediately Integrating information technology systems to support improved reemployment service delivery and Using ongoing risk assessments to determine whether UI claimants are having a difficult time finding a job and need additional services. ETA recommends that UI program staff collaborate with these partners to ensure the strategies reflect the agreement s made and are documented in each partner s strategic plan. Addressing Worker Misclassification States should monitor their performance under the Effective Audit Measure See UIPL No. 03-11 http wdr.doleta.gov directives corr doc.cfm DOCN 2971 to determine whether they are effectively detecting and preventing worker misclassification. States may deploy a wide array of strategies to address worker misclassification. ETA encourages 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 the 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 UI Performance Measures Federal Emphasis The Government Performance and Results Act of 1993 GPRA requires a commitment from all Department programs to attain expressed goals and objectives. Achieving these objectives requires the combined efforts of the Federal and state partners. In recognition of the national priorities attention continues to be focused on the following GPRA goals for FY 2017 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 link below for the GPRA goals for FY 2017 http www.oui.doleta.gov unemploy docs GPRA Summary Report.asp. 7 Strategic Goal 4 Secure retirement health and other employee benefits and for those working provide income security. Strategic Objective 4.1 Provide income support when work is impossible or unavailable and facilitate return to work. Make Timely Benefit Payments o Target 87.0 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. Detect Benefit Overpayments o Target Overpayments established will be at least 61.4 percent of the estimated detectable recoverable overpayments. Establish Tax Accounts Promptly o Target 88.0 percent of status determinations for new employers will be made within 90 days of the end of the first quarter in which liability occurred. Employment Rate at Second Quarter After Exit The employment rate at the second quarter after exit for all UI claimants registered with the Wagner-Peyser system includes all participants regardless of whether or not they came into the program employed. The data for the implementation of the WIOA measure will require new reporting by the states. The new reporting is expected to begin in July 2016 with first reports due in November 2016. 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. 5. Impact of WIOA on the SQSP Process. A key goal for the UI program is to help ensure that claimants are able to successfully return to work. As such the SQSP must reflect coordination with other WIOA programs to ensure a coordinated effort and integrated service delivery. The coordination must be described in the State Plan Narrative portion of the SQSP. WIOA provides the option for states to include program plans for mandatory one-stop partner 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 beginning with the FY 2016 SQSP. However it should be noted that each state must participate in the UI Performs SQSP process whether or not the state decides to include UI as part of its WIOA Combined State Plan. The WIOA state plans were due by April 1 2016. States electing to include UI in a Combined Plan were to have incorporated the SQSP in its entirety into the Combined Plan through the Combined State Plan process. Subsequent SQSPs are to be incorporated into the Combined Plan upon approval of the SQSP. ETA has provided technical assistance on 8 WIOA state planning processes and will continue to provide assistance and guidance as necessary. To include the SQSP states must cut-and-paste the SQSP 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 1. Transmittal Letter The Portal does not support Adobe Portable Document Format PDF therefore states must include the unsigned Micro 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. 2. SQSP Narrative CAPs and IAP The CAP and Quarterly Reporting Workbook documents are Excel documents with multiple rows in a single column which is not supported by the Portal. Therefore states must use the Microsoft Word version of the CAP IAP and Narrative forms. 3. Budget Worksheets Forms The Portal does not support Adobe PDF therefore states are to 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 is to include a statement that the signed copy of the SF 424 and other appropriate budget-related forms are maintained with the state agency and the RO. 4. Organization Chart These charts are to be converted to Microsoft Word and cut-and pasted into the Portal. If the state cannot convert the chart into Microsoft Word format the state is to 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. 5. SQSP Signature Page The Portal does not support Adobe PDF format therefore states must include the unsigned version of the Signature Page. The approving official s name is to be typed on the form that is submitted into the Portal. States are to 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 All approved signed SQSP documents must also reside in the RO. 6. SQSP Planning Guidance and Requirements. ET Handbook No. 336 18 th Edition Chang e 3 and this UIPL provide guidelines for the completion and submission of the SQSP for FY 201 7. 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 9 excellence. To that end Corrective Action Plans CAPs and or Narratives are expected whenever a state s performance does not meet established criteria for the SQSP measurement period see Attachment A and remains uncorrected before the preparation of the SQSP. The measurement period for the FY 201 7 SQSP is April 1 201 5 March 31 201 6 unless otherwise indicated. CAPs and Narratives addressing performance deficiencies are components of the state s formal plan and schedule for improving performance therefore the causes of performance shortfalls should be thoroughly analyzed before the development of the state s SQSP. SQSP Preparation and 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 formerly called SQSP L ite . SQSP Biennial Submittal The Biennial SQSP consists of a complete SQSP package. It must contain a transmittal letter the State Plan Narrative CAPs the IAP budget worksheets forms assurances organizational charts a signature page and other required administrative documents as requested. For the two-year planning cycle states must submit quarterly targets and milestones for both years. A sample CAP format for the two-year planning cycle is in ET Handbook No. 336 18 th Edition Change 3. States may also develop extended multi-year CAPs so that efforts that must extend beyond the two-year planning cycle due to their size scope or complexity can be realistically portrayed. Out-year portions of such multi-year plans do not need to provide quarterly targets or milestones as required for the two-year SQSP planning cycle but should provide enough information to explain anticipated progress and results. 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 SQSP Signature Page CAPs for new performance deficiencies and required modifications to existing CAPs. Since states 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 regional office reviews of state performance data during the most recent performance year. Additionally states will be informed by their RO if modifications are required to the State Plan Narrative existing CAPs and IAPs to include for example 10 Missed milestones and New strategies for performance improvement. Budget worksheets and various assurances will continue to be submitted annually since funds for UI operations are appropriated each FY. These and other required documents related to the Federal UI administrative funding process are to be submitted with both the Biennial SQSP and the alternate year submittal. Additional descriptions of the formal SQSP submittal SQSP Alternatate 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 18th Edition Change 3. The At-Risk Process Old Proces s ETA s goal is to ensure that states are implementing methods of administration reasonably calculated to ensure full payment of unemployment compensation when due in accordance with section 303 a 1 SSA. To that end ETA had previously ident ified persistently low performing states as At-Risk requiring greater technical assistance and monitoring from the regional and National offices. This collaborative process between ETA and these states is expected to identify impediments to achieving performance standards action steps designed to improve performance and technical assistance strategies. The action strategies and technical assistance activities are to be included in the state s SQSP CAP for those measures that have caused the state to be designated At-Risk. States that have been identified as At-Risk in previous years because of consistently significant low performance for the first payment and appeals timeliness measures will continue to work collaboratively with ETA to achieve performance improvement. The At- Risk designation will continue until the state meets the standard for six consecutive months and is likely to continue to sustain this performance improvement. These states will also c ontinue to receive enhanced technical assistance as needed. High Priority States New Process As part of the reengineering of its program oversight and 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. Please refer to TEN Nos. 8-14 and 3 -15 for details. The new 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 include integral parts of UI Performs core measures data validation 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 new process 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 11 state subject matter experts on the issue areas identified as needing improvement. ETA will work collaboratively 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 new High Priority designation framework and process are outlined in UIPL No. 17 -16. SQSP Assurances By signing the SQSP Signature Page a state certifies that it will comply with the assurances listed in ET Handbook No. 336 18th Edition and institute plans or measures to comply with the requirements for each of the assurances. States will continue to provide information for Assurances H Assurance of Contingency Planning and J Assurance of Automated Information Systems Security. In the State Plan Narrative Section H 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 Review and or update and test the its IT Contingency Plan annually Review and or update its System Security Plan annually and Conduct 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 plans to take to meet these requirements in a CAP. These plans and procedures must meet the minimum controls listed in the Chapter I Section VII-H and Section VII-J of the ET Handbook No. 336 18th Edition Change 3. 7 . UI Program Performance and Criteria for FY 201 7. Core Measures Performance below the ALPs for Core Measures is expected to be addressed in a CAP unless otherwise indicated. Additional instructions for Core Measures are as follows Employment Rate OMB 1205-0521 ETA expects to establish an ALP for this measure in FY 2019. The data for the implementation of the WIOA measure will require new reporting by the states. The new reporting is due to start in July 2016 with first reports expected in November 2016. This measure will be implemented upon availability of adequate data in order to establish the ALP. 12 The Detection of Overpayments Measure. This me asure is the percentage of detectable recoverable overpayments established for recovery. States reporting an overpayment detection rate below 50 percent are expected to address the deficiency in a CAP. Also because states generally cannot cost-effectively detect and establish more than 90 percent of estimated overpayments an upper limit of 95 percent has been established for monitoring purposes. States reporting ratios over 95 percent are expected to explain in the Narrative section the reasons for the higher-than- expected ratios. If an overpayment rate above 95 percent is the result of improper administration of BAM or Benefit Payment Control BPC activities or misreporting of data on the ETA 227 Overpayment Detection and Recovery Activities report the state is expected to submit a CAP for BAM Overpayment Detection or BPC Overpayment Detection . The CAP should be designed to produce valid data for the Overpayment Detection Measure. The performance period for the BPC component is the three-year period ending March 31 201 6 the performance period for the BAM component is the three-year period ending September 30 201 5. UI Integrity Measure - Benefit Year Earnings BYE The UI Integrity Measure for BYE errors addresses a leading cause of UI improper payments individuals who continue to claim benefits after returning to work. Performance will be measured by the state s BYE overpayment rate estimated by the BAM survey rather than the amount overpaid to control for year-to-year changes in benefit outlays. Per UIPL No. 34-11 Change 2 the ALP for the calendar year CY 2015 performance period is a 25 percent reduction in the state s CY 201 2 to CY 2014 baseline BYE rate. A state will meet the ALP if 1 its BYE overpayment rate decreases during the performance period by the percentage decrease specified for the period or 2 its BYE overpayment rate decreases during the performance period and the rate is below the national BYE overpayment rate by the target percentage decrease. States failing to meet the ALP for the UI Integrity Measure for BYE will be expected to develop a CAP as part of the FY 2017 SQSP. The CAP will address performance for CY 2015 . 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 Number of Misclassifications Detected Per Audit. Each of the four factors has a minimum standard score that states must attain to pass the Effective Audit Measure as well as an overall combined score that must be met. The measure also requires states to direct additional emphasis to the factor s that they deem important to their state. An additional two points must be earned among any of the four factors to attain the overall passing score of at least 7.0. States that do not meet this measure will be expected to develop a CAP based on CY 2015 data. 13 Improper Payments Measure The Improper Payments Measure is defined as UI benefits overpaid and underpaid estimated from the results of the BAM survey of paid UI claims in the State UI Unemployment Compensation for Federal Employees UCFE and Unemployment Compensation for Ex-Servicemembers UCX programs. During the past years ETA used a methodology which subtracted UI overpayment recoveries for the computation of the estimated improper payment rate. The Improper Payments Elimination and Recovery Improvement Act of 2012 IPERIA requires agencies to include all identified improper payments in the reported estimate regardless of whether the improper payment in question has been or is being recovered. ETA s revised methodology no longer nets out recoveries for the computation of the improper payment rate . Please refer to UIPL No. 0 9-13 Change 1 for a detailed discussion on the new methodology. This new methodology for the computation of the improper payment rate will become effective for the states with the FY 2017 SQSP cycle. In accordance with requirements in section 3 a 3 F IPERA an ALP of less 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 2015 IPIA performance period July 1 2014 to June 30 201 5 . States failing to meet the ALP for the 2015 IPIA performance period will be expected to dev elop a CAP as part of the FY 2017 SQSP. UI Overpayment Recovery Measure Pursuant to Section 3 a 3 F of IPERA and UIPL No. 09-13 the recovery rate is the amount of improper overpayments recovered divided by the amount of improper overpayments identified. The ALP for the recovery rate measure is 65 percent for the 201 5 IPIA performance period. The Department will compute future recovery targets based on the most recent recovery and other performance data available. The performance period will be based on data from the ETA 227 Overpayment Detection and Recovery Activity Regular and ETA 227 Overpayment Detection and Recovery Activity Emergency Unemployment Compensation EUC for the IPIA period July 1 to June 30 of the IPIA reporting year . Pursuant to the UI Reports Handbook ET Handbook No. 401 4th edition the June quarter ETA 227 reports are due August 1st. States failing to meet the ALP for the 2015 IPIA performance period will be expected to develop a CAP as part of the FY 2017 SQSP. 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. 14 UI Programs National Directory of New Hires NDNH State BAM operations that based on the BAM Administrative Determination are not compliant with the NDNH matching requirements in ET Handbook No. 395 5th Edition chapter VI UIPL No. 3-07 and UIPL No. 3 -07 Change 1 must be addressed in a CAP for FY 2017 . 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 must be addressed in a CAP. This includes paid and denied claim population variances outside established control limits. 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 that is not sampled will be included in the number of total failing functions as measured by Tax Quality Part A no more than three tax functions may fail TPS review and Part B a tax function cannot fail for three consecutive years . Exceptions include universes that are too small to support a sample S an Experience Rate sample that was not scheduled for review during the performance year E or the granting of a temporary waiver by the RO W . Program Review Findings Charts should be noted accordingly. Data Validation DV The deadline for submitting DV results was June 10 201 6. DV items that fail to pass validation or that are due but not submitted are expected to be addressed in the state s FY 201 7 SQSP. Non-submitted items include failures to certify that Module 3 of the DV Benefits and Tax Handbooks are up-to-date during the April 1 June 10 2016 certification window. Any DV items due for Validation Year VY 2016 that do not pass or are not submitted by the June 10 201 6 deadline must be addressed in a CAP for FY 2017 . ROs will monitor states every three years on cycles coinciding with the DV validation year. They will assess 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. 15 The FY 2017 SQSP CAP will include DV items failing after review in the VY 2016 monitoring cycle monitored between June 11 201 5 and June 10 201 6 . All subsequent SQSP cycles will address items changed from pass to fail in the previous year s monitoring review. UI Program Integrity I PERA requires agencies to ensure that their managers and accountable officers including the agency head programs and where applicable states and localities are held accountable for reducing improper payments. States are required to report their planned activities to prevent detect reduce and recover improper UI payments in their Program Integrity Action Plan which should be submitted as part of their annual SQSP submission. To update their Program Integrity Action Plan states must analyze their BAM data to identify the top root causes for improper payments and develop strategies that will be effective in reducing or recovering improper payments. The most recent state data are available at the Department s Web site at http www.dol.gov dol maps map- ipia.htm. ETA will continue to provide technical assistance to states to support their integrity activities through webinars individual state technical assistance and in partnership with the UI Integrity Center of Excellence. In addition ETA will work with states to expand participation in the Treasury Offset Program for the recovery of overpayments to implement and 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 Action Plan are in ET Ha ndbook 336 18th Edition Appendix I. 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 Deficiencies identified during required program reviews Failure to meet reporting requirements and Invalid recording of the Issue Detection Date IDD and Determination Date DD . The validity of the UI Performs nonmonetary determination timeliness measure depends on the accuracy of the state s IDD and DD data. IDD and DD data are considered accurate if dates were correct in at least 95 percent of the nonmonetary determinations evaluated in the quarterly quality samples obtained from the ETA 9056 report . Since the accuracy of IDD and DD data is based on sample results sampling variation will be taken into 16 account in setting the percentage below which a state s data will be considered inaccurate. States with invalid IDD or DD data are expected to address the steps they will take to record the IDD and DD correctly in the SQSP Narrative. The Attachment lists the performance criteria for the Core Measures Secretary s Standards and other program requirements where CAPs and or Narratives may be required if annual performance is not acceptable. 8 . Funding Period. The Department s proposed FY 2017 appropriation language allows for obligation of UI allocations by states through December 31 2017 with 90 additional days to liquidate the obligations and complete the expenditure of funds. Under this proposed language states would be able to obligate FY 2017 UI funds through September 30 2019 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 2017 UI funds through September 30 2022 if such obligations are for automation acquisitions being carried out through a consortia of states. Therefore if Congress adopts the proposed FY 2017 appropriations language the end of the obligation period for regular state UI administrative funds will be December 31 2017 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 2019 . ETA will notify state agencies if Congress adopts this language. 9 . Data Availability. ROs will provide states with data showing their performance measured against the Core Measures Secretary s Standards and other information relevant to the SQSP e.g. reporting deficiencies . 1 0. Deadline for State SQSP Submittal . Each RO will set a deadline for states to submit their SQSPs for FY 2017 . 1 1. Electronic Submission of the SQSP. States must submit the SQSP electronically and should contact their RO SQSP Coordinator before submittal to coordinate specific details. Standard forms required as part of the budget reporting process Chapter II of ET Handbook No. 336 18th Edition Change 3 are available in PDF and may be downloaded from the OMB Web site at http apply07.grants.gov apply FormLinks family 15. States may submit the SQSP signature page electronically if the state law permits. States that do not submit the signature page electronically must submit the signature page by mail by the deadline set by the RO. 1 2. Action Requested. State Administrators are requested to Make this information available to appropriate staff Prepare their SQSPs in accordance with instructions in this UIPL and the planning and reporting instructions contained in ET Handbook No. 336 18th Edition Change 3 17 Coordinate specifics as appropriate with the RO for electronic submission of the plan and Submit the FY 201 7 SQSP to the appropriate RO by the deadline set by that RO. 1 3. Inquiries. Qu estions should be directed to the appropriate RO. 1 4. Attachment. Attachment A - Measures Programs to be addressed in the Fiscal Year FY 201 7 State Quality Service Plan SQSP