UIPL 01-26 (complete document).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 December 2 2025 RESC ISSIONS None EXPIRATION DATE June 30 2026 ADVISORY TO UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 01-26 STATE WORKFORCE AGENCIES FROM LORI FRAZIER BEARDEN Acting Assistant Secretary SUBJECT Payment Integrity Information Act PIIA of 2019 Reporting Year 2025 Procedures for the Completion of Unemployment Insurance UI Benefit Accuracy Measurement BAM Data 1.Purpose. To provide State Workforce Agencies SWAs guidelines and key dates for the completion of the 2025 UI BAM paid and denied claims sample cases. 2.Action Requested. The U.S. Department of Labor Department Employment and Training Administration ETA requests that SWA Administrators a.Provide copies of these guidelines to the appropriate staff. b.Ensure that ETA Regional Office are 1 Notified by November 24 2025 of any issues that require the reconciliation of the SWA s and ETA s BAM data and 2 Provided the point of contact information for the SWA s BAM published data by January 12 2026. 3.Summary and Background. a.Summary This Unemployment Insurance Program Letter UIPL provides guidelines and key dates for the completion of the 2025 representative sample cases of UI payments and denials and the publication of 2025 BAM data. ETA issues these annual guidelines as set out in Employment and Training ET Handbook No. 395 5 th Edition Office of Management and Budget OMB approval number 1205-0245 . b.Background The BAM program is a tool for assessing the accuracy of a sample of paid and denied claims in three major UI programs regular State UI Unemployment Compensation for Federal Employees and Unemployment Compensation for Ex- Servicemembers. SWAs select weekly random samples of paid and denied claims. Independent state BAM investigators audit these paid and denied claims to determine whether UI benefits were properly paid or properly denied. The data gathered through 2 the BAM program is used to assess the accuracy of UI payments and estimate the UI Improper Payment Rate as required by Federal Law. This information is also critical in assisting states to develop and implement plans to improve accurate administration of state law rules and procedures. Each year ETA publishes a UIPL that provides dates for annual case completion verification of data contained in the national database and an explanation of data footnotes for the current reporting year. 4. Guidelines and Key Dates. a. Completion of PIIA 2025 BAM Cases. The PIIA requires ETA to provide information on improper payments in the UI program including the improper payment estimate in the Department s Annual Financial Report to OMB. 1 To accomplish this mandate ETA establishes the PIIA reporting year for the BAM program which includes payment accuracy estimates for the period beginning in July and continuing through June of the following year BAM batch range YYYY27 through YYYY 1 26 . ETA established standards that states complete a minimum 95 percent of sampled cases within 90 days of the week ending date of the batch and complete 98 percent of sampled cases within 120 days of the ending date of the above annual reporting period. 2 This July-to-June reporting period provides the most recent BAM data available to meet the PIIA reporting schedule requirements for the fiscal year. b. Transmittal of PIIA 2025 Data. For PIIA 2025 the reporting period is from July 1 2024 to June 30 2025 batches 202427 through 202526 . The published BAM data will be based on PIIA 2025 BAM sampled paid and denied claims cases that the state BAM supervisor has closed and submitted to the Department by the date of record for PIIA 2025 of COB November 21 2025 . Changes to a SWA s database after the date of record can result in inconsistencies with the ETA database. A SWA must not close or reopen any PIIA 2025 BAM cases after November 21 2025 until the SWA has confirmed that the BAM paid claims and denied claims data produced by its databases are accurate. By December 1 2025 ETA will produce and transmit to each SWA paid and denied claims accuracy data using the BAM Paid Claims Annual Report Denied Claims Error Rates Report and Improper Denials Rates Report based on the PIIA 2025 BAM cases that were submitted by the SWA as of COB November 21 2025. SWAs are also required to run their own BAM Paid Claims Annual Report Denied Claims Error Rates 1 Payment Integrity Information Act of 2019 PIIA Pub. L. 116-117 2 Employment and Training ET Handbook No. 395 5 th Edition Benefit Accuracy Measurement State Operations Handbook November 2009 https www.dol.gov sites dolgov files ETA handbooks 2009 ETHandbook 395 Ch5 acc.pdf page VI-11 3 Report and Improper Denials Rates Report software so the results can be compared with ETA s rates and report footnotes. By December 12 2025 SWAs should report any discrepancies or submit questions concerning the BAM paid and denied claims data and footnotes to ETA. Please send comments electronically to UI-BAM dol.gov with a copy to the appropriate ETA Regional Office. Samples of these reports report definitions and report footnotes are available in Attachments I and II. ETA staff will address and reconcile issues raised by the SWAs by December 19 2025. 5. Key Dates. The following key dates are the latest dates for completing the task or action 6 30 2025 11 21 2025 This date represents the end of the PIIA 2025 reporting year and is comprised of batches 202427 through 202526. By this date SWAs must have selected the minimum number of valid cases to meet annual sample allocation requirements i.e. 360 or 480 paid claim cases and 150 of each of the three types of denied claims 3 . SWAs must complete at least 98 percent of the valid cases sampled in PIIA 2025 by November 21 2025. Each SWA checks its UI database to ensure 1 the BAM supervisor has signed off on all BAM paid and denied claims cases that investigators have completed and 2 reopened cases have been updated and data errors corrected by this date. Cases closed by supervisors after COB November 21 2025 will not be included in the Paid Claims Accuracy PIIA Report or the Denied Claim Accuracy Error Rates and Improper Denials Rates Reports. SWAs must not reopen any PIIA 2025 cases after November 21 2025 until they review the BAM data transmitted by ETA and verify the data against their SWA database to reconcile any differences with ETA. For BAM paid claims data BAM should compare the highlighted BAM sample and dollars paid in Attachment I. 12 3 2025 SWAs submit requests for waivers of BAM Paid and Denied claims timeliness requirements along with supporting documentation to the appropriate ETA Regional Office. Generally waivers are granted only for catastrophic events i.e. occurrence by natural causes that could not have been prevented by the exercise of foresight or caution . 3 Annual BAM paid claims sample sizes have been set at 360 cases in the ten smallest states and 480 in all other states. State size is based on the average Unemployment Insurance UI weeks compensated during the five most recent years. 4 12 3 2025 ETA transmits the PIIA 2025 BAM data to the SWAs BAM supervisors. 12 12 2025 SWAs review BAM paid and denied claims accuracy data and footnotes and report any discrepancies or submit questions about the BAM data or footnotes electronically to UI-BAM dol.gov with a copy to the appropriate ETA Regional Office. 12 19 2025 ETA staff members address issues raised by the SWAs and reconcile any differences between SWA and ETA BAM data. 1 12 2026 SWAs provide the point of contact information for the person s responsible for public inquiries about BAM paid and denied claims data. SWAs should send this information electronically to UI- BAM dol.gov with a copy to the appropriate ETA Regional Office. 6. Inquiries. Please direct inquiries to the appropriate ETA Regional Office. 7. References. Payment Integrity Information Act of 2019 PIIA Pub. L. 116-117 31 U.S.C. 3515 Financial statements of agencies 20 C.F.R. Part 602 Quality Control in the Federal-State Unemployment Insurance System UIPL No. 09-13 Change 1 Integrity Performance Measure for Unemployment issued on January 27 2015 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter-no- 09-13-change-1 UIPL No. 16-24 Additional Planning Guidance for the Fiscal Year FY 2025 Unemployment Insurance UI State Quality Service Plan SQSP issued on July 22 2024 https www.dol.gov agencies eta advisories uipl-no-16-24 UIPL No. 11-24 Procedures for the Completion and Publication of Unemployment Insurance UI Benefit Accuracy Measurement BAM Data for Payment Integrity Information Act PIIA Reporting Year 2024 issued on May 3 2024 https www.dol.gov agencies eta advisories uipl-11-24 Employment and Training ET Handbook No. 395 5 th Edition Benefit Accuracy Measurement State Operations Handbook November 2009 https www.dol.gov sites dolgov files ETA handbooks 2009 ETHandbook 395 Ch5 ac c.pdf and Office of Management and Budget OMB Circular No. A-123 Appendix C Requirements for Payment Integrity Improvement March 5 2021 . https fiscal.treasury.gov files dnp OMB M-15-02.pdf 5 8. Attachments. Attachment I Benefit Accuracy Measurement BAM Paid Claims Accuracy Sample Annual Report Report Definitions and Report Footnotes Attachment II Benefit Accuracy Measurement BAM Denied Claims Accuracy Sample Error Rates Report and Improper Denials Rates Report Report Definitions and Report Footnotes Attachment I I-1 Benefit Accuracy Measurement BAM Paid Claims Accuracy Sample Annual Report STATE ZZ Batch Range 202427 - 202526 Total Dollars Paid in Population 221 830 728 Sample Size 383 Percentage Of Dollars 95 Confidence Interval - Proper Payments 88.1 3.5 Overpayments 11.6 3.5 Total 100.0 Underpayments 0.3 0.2 Percentages apply to less than a complete year of UI payments the State did not pull a sample for three 3 week s . The State completed 83.7 of the cases within 90 days. The Quality Control QC program standard is 95 completed within 90 days. 15.9 of the sample cases were not completed when this report was prepared. This exceeded the QC program requirement that no more than 2 of the cases for the year remain incomplete. Attachment I I-2 Benefit Accuracy Measurement BAM Paid Claims Accuracy Sample Annual Report Supplemental Data STATE ZZ Batch Range 202427 - 202526 Responsibility for Overpayments Percent of Dollars Overpaid Claimant Only 51.6 Agency Only 15.6 Claimant Agency 10.6 Claimant Employer 10.5 Employer Only 8.6 Claimant Employer Agency 2.1 Claimant Other 1.7 Employer Agency 1.0 Other Only 0.0 Employer Other 0.0 Agency Other 0.0 Claimant Employer Other 0.0 Claimant Agency Other 0.0 Employer Agency Other 0.0 Claimant Employer Agency Other 0.0 Responsibility Not Specified 0.0 Attachment I I-3 Cause for Overpayments Percent of Dollars Overpaid Benefit Year Earnings Issues 39.1 Eligibility Issues Excluding Work Search 25.7 Separation Issues 20.5 Base Period Wage Issues 7.4 Other Issues 5.9 Work Search Issues 2.9 N O T E The percentages for the responsibilities or cause do not sum to 100 percent. You should check field h5 to verify that all cases have been coded correctly within your specified batch range. If cause and responsibility percentages do not add up to 100 percent states should check for cases in which the key week amount overpaid underpaid coded in data element h5 in the b master table of the UI database or does not equal the sum of dollars overpaid underpaid coded in data element ei1 for key week actions 10 11 12 13 and 15 in the b errisu table. The amount overpaid cannot exceed the amount paid coded in data element f13 in the b master table. Attachment I I-4 Benefit Accuracy Measurement BAM Paid Claims Accuracy Report Definitions Total Dollars Paid in Population Total UI benefits paid to the population of UI claimants who constitute the sampling frames for all weeks in PIIA 2025 from which the State pulled a BAM sample adjusted to exclude UI payments that do not meet the definition of the BAM population for example supplemental payments or payments made for Emergency Unemployment Compensation claims . These excluded cases are coded 8 temporary emergency or 9 deleted Record e.g. TAA DUA Workshare SEA in the program code data element c1 in the b master table of the UI database. Sample Size Total number of UI payments selected during PIIA 2025 BAM batches 202427 through 202526 and completed supervisor sign-off by COB October 28 2025 excluding cases that do not meet the BAM population definition. This is the number of BAM sample cases from which the payment accuracy rates and confidence intervals are estimated. Proper Payments The weighted ratio estimate of total dollars properly paid to total dollars paid expressed as a percentage. Overpayments The weighted ratio estimate of total dollars overpaid to total dollars paid expressed as a percentage. Underpayments The weighted ratio estimate of total dollars underpaid to total dollars paid expressed as a percentage. Weighting Procedures UI benefits properly paid overpaid and underpaid for each batch with at least two completed paid claims cases are weighted by the batch population adjusted to exclude cases that do not meet the BAM definition program code 8 or 9 . The accuracy rates are the ratios of these weighted benefits summed for all batches. Batches with only one completed case are merged to ensure that each batch has a minimum of two completed cases. Attachment I I-5 95 Percent Confidence Interval A confidence interval expressed as - x percentage points is constructed for each of the three estimated rates. The actual rate is expected to lie within 95 percent of the intervals constructed from repeated samples of the same size and selected in the same manner as the BAM sample. Attachment I I-6 Benefit Accuracy Measurement BAM Paid Claims Accuracy Report Footnotes Footnote 1 Claimants failing to conduct required work search were given formal warnings and no overpayment was established. The proper payment rate would be lower and the overpayment rate would be higher if these cases were counted as erroneous payments. Condition Any PIIA 2025 BAM case with key week action code 14 in field ei2 of the b errisu table of the UI database. Footnote 2 Percentages apply to less than a complete year of UI payments due to the State not pulling a sample for x weeks. Condition There is no record in the b comparison table of the UI database for one or more BAM batches 202427 through 202526. Note If the State requested and received permission from ETA to suspend BAM sampling temporarily due to a catastrophic event or another approved reason the footnote will reflect that ETA concurred with the suspension. Footnote 3 The State selected samples that were below the minimum prescribed levels for x weeks. Condition State selected one or more BAM weekly samples below the minimum level prescribed in Benefit Accuracy Measurement State Operations Handbook ET Handbook No. 395 5 th Edition chapter VI p. 11. Sampled cases that fail to meet the BAM population definition are counted toward meeting the minimum weekly sample. The minimum weekly and quarterly samples based on current annual sample allocations are Sample Annual Allocation Normal Weekly Minimum Weekly Normal Quarterly Minimum Quarterly Paid Claims 360 7 5 90 81 Paid Claims 480 9 6 120 108 Denials 150 450 3 2 37-38 32 Allocation for the ten smallest states in terms of UI workload. 150 cases each of monetary separation and non-separation denials will be selected each year for a total of 450 Denied Claims Accuracy cases. Attachment I I-7 Note If a state requested and received permission from ETA to reduce BAM sample sizes temporarily due to workload contingencies the footnote will reflect that ETA concurred with the reduction. Footnote 4 Percentages based on data collection procedures that were not completely in accordance with the program methodology prescribed in ET Handbook No. 395 5 th Edition. Condition ETA staff continuously monitors state performance with respect to the BAM administrative requirements established in ET Handbook 395 5 th Edition for example minimum sample sizes population variances case completion percentages and timeliness and quality of the BAM audits . According to UIPL No. 16-24 p. 7 states must address BAM program performance deficiencies in a Corrective Action Plan as a part of the State Quality Service Plan. Footnote 5 The state completed x percent of the cases within 90 days. The program standard is 95 percent completed within 90 days. Condition State failed to meet case completion objectives established in ET Handbook No. 395 5 th Edition Benefit Accuracy Measurement State Operations Handbook chapter VI p. 11. Cases not meeting the BAM population definition are not counted in calculating state time lapse rates. Footnote 6 X percent of the sample cases were not completed when this report was prepared. This exceeded the program requirement that no more than two 2 percent of the cases for the year remain incomplete. Condition The percentage is based on the number of BAM cases that were not completed no supervisor sign-off by COB October 28 2025 divided by the number of valid cases selected for BAM weekly samples during PIIA 2025 BAM batches 202427 through 202526 . Cases that do not meet the BAM population definition are not counted in calculating state case completion rates. Footnote 7 The annual sample for state is x cases below the allocated annual sample for the state. The precision of the data might be reduced due to the failure to sample at the prescribed level. Attachment I I-8 Condition The state s annual sample selection is below its allocated annual sample. Cases that do not meet the BAM population definition are not counted toward meeting the annual sample allocation. Note If a state requested and received permission from ETA to reduce BAM sample sizes temporarily due to workload contingencies the footnote will reflect that ETA concurred with the reduction. Footnote 8 The population from which the BAM sample was selected did not include all of the UI benefits paid. This limits the degree to which inferences about the population can be made from BAM data. Condition The dollars paid in the BAM population for PIIA 2025 vary from the dollars paid reported in the state s ETA 5159 Claims and Payment Activities reports by more than the statistical control limit. Attachment II II-1 Benefit Accuracy Measurement BAM Denied Claims Accuracy Sample Error Rates Report State ZZ Report Date 9 30 2025 Batch Range 202427 202526 Denial Type Population Cases Completed Monetary 24 260 127 Separation 29 674 129 Nonseparation 63 255 131 Denial Type Total Errors Improper Denial Adjusted Improper Denial Overpayment Proper Denial Monetary 12.01 12.01 11.00 0.00 0.00 Separation 2.61 0.76 0.76 0.00 1.86 Nonseparation 14.08 11.06 10.42 0.00 3.02 Excludes cases not meeting DCA definition for inclusion in population withdrawn claims and claims for which monetary eligibility was established upon receipt of combined wage claim CWC unemployment compensation for federal employees UCFE and or unemployment compensation for ex-servicemembers UCX wage credits. Adjusted rate excludes erroneous denials that were corrected by agency or reversed on appeal prior to DCA case completion. Properly denied but for wrong reason or section of the law. The state completed 74.47 percent of the Monetary denials sample cases within 90 days. The program standard is 85 percent completed within 90 days. The state completed 76.60 percent of the Separation denials sample cases within 90 days. The program standard is 85 percent completed within 90 days. The state completed 88.65 percent of the Nonseparation denials sample cases within 90 days. The program standard is 85 percent completed within 90 days. - Estimated rates apply to less than the total population of Monetary denials due to the state not pulling a sample for four 4 week s . - Estimated rates apply to less than the total population of Separation denials due to the state not pulling a sample for four 4 week s . - Estimated rates apply to less than the total population of Nonseparation denials due to the state not pulling a sample for four 4 week s . Attachment II II-2 Benefit Accuracy Measurement BAM Denied Claims Accuracy Sample Improper Denials Rates Report State ZZ Report Date 9 30 2025 Batch Range 202427 202526 Denial Type Population Cases Completed Monetary 24 304 128 Separation 29 674 131 Nonseparation 63 255 132 Denial Type Improper Denial 95 C.I - Adjusted Improper Denial 95 C.I - Monetary 11.55 5.95 10.55 5.78 Separation 0.76 1.48 0.76 1.48 Nonseparation 11.78 5.92 11.14 5.78 Excludes cases not meeting DCA definition for inclusion in population withdrawn claims and claims for which monetary eligibility was established upon receipt of CWC UCFE and or UCX wage credits. Adjusted rate excludes erroneous denials that were corrected by agency or reversed on appeal prior to DCA case completion. Note 95 C.I. is the 95 percent confidence interval for the estimated rate. The interval is the range between the rate minus the value in the 95 C.I. column and the rate plus the value in the 95 C.I. column. For example the interval for 10.0 - 2.5 is 7.5 to 12.5 . The true rate is expected to lie within 95 percent of the intervals constructed from repeated samples of the same size and selected in the same manner as the BAM DCA sample. Estimated rates apply to less than the total population of Monetary denials due to the state not pulling a sample for four 4 week s . Estimated rates apply to less than the total population of Separation denials due to the state not pulling a sample for four 4 week s . Estimated rates apply to less than the total population of Nonseparation denials due to the state not pulling a sample for four 4 week s . Attachment II II-3 Benefit Accuracy Measurement BAM Denied Claims Accuracy Report Definitions Population The number of denial determinations that constitute the sampling frames for all weeks in PIIA 2025 for which the state pulled a BAM DCA sample adjusted to exclude agency actions that do not meet the definition of the BAM DCA population for example monetary redeterminations nonmonetary determinations that are not reportable on the ETA 207 and 9052 reports and denied emergency unemployment compensation EUC claims . These excluded cases are coded 8 EUC or 9 all other excluded records in the Program code data element in the b dca master table of the UI database. The software also adjusts the DCA populations to exclude two types of cases for which there is no denial issue to investigate 1 cases in which monetary eligibility was established upon receipt of Combined Wage Claims Alternative Base Period Claims Unemployment Compensation for Federal Employees and or Unemployment Compensation for Ex-service members wage credits within the two-week sampling lag Action Code Flag 0 and 2 claims withdrawn by the claimant Action Code Flag 8 . Sample Size Total DCA cases selected during PIIA 2025 BAM batches 202427 through 202526 and completed supervisor sign-off by COB October 28 2025 excluding cases that do not meet the BAM DCA population definition. This is the number of BAM DCA sample cases from which the accuracy rates are estimated. Improper Denial Rate The weighted proportion of denied claims for which the DCA investigation concluded that the claimant should have been eligible for UI benefits or was underpaid UI benefits Error Issue Action Code 20 21 22 or 23 expressed as a percentage. Adjusted Improper Denial Rate Improper Denial Rate excluding cases in which erroneous denials were corrected by the agency Prior Agency Action 20 to 29 or eligibility was established through appeal Results of Appeal of Initial Determination 1 or 3 prior to DCA case completion. Overpayment Rate The weighted proportion of denied claims for which the DCA investigation concluded that the claimant should have been ineligible for UI or should have received a lower benefit amount for weeks that had been paid Error Issue Action Code 10 11 12 13 14 15 or 16 expressed as a percentage. Attachment II II-4 Proper Denial Rate The weighted proportion of denied claims for which the DCA investigation concluded that the claimant was properly denied but for the wrong or different reason section of the law Error Issue Action Code 30 expressed as a percentage. Weighting Procedures Accuracy rates are computed separately for each batch with at least two completed DCA cases and weighted by the batch population adjusted to exclude cases that do not meet the BAM DCA definition Program code 8 or 9 or cases with Action Codes 0 monetary eligibility established upon receipt of CWC UCFE and or UCX wage credits or 8 withdrawn claims . The accuracy rate equals the sum of the products of the batch rates and weights. Batches with only one completed case are merged to ensure that each batch has a minimum of two completed cases. 95 Percent Confidence Interval A confidence interval expressed as - x percentage points is constructed for each of the estimated accuracy rates. The actual rate is expected to lie within 95 percent of the intervals constructed from repeated samples of the same size and selected in the same manner as the BAM sample. Attachment II II-5 Benefit Accuracy Measurement BAM Denied Claims Accuracy Report Footnotes Footnote 1 Estimated rates apply to less than the total population of sample type denials due to the state not pulling a sample for x weeks. Condition There is no record in the b dca comparison table of the UI database for one or more batches specified in the batch range for sample type y where b dca comparison samptype 2 monetary 3 separation or 4 nonseparation . Footnote 2 Estimated rates for sample type denials are based on data collection procedures that were not completely in accordance with the program methodology prescribed in ET Handbook No. 395 5 th edition. Condition Based on program monitoring conducted by ETA s national and regional offices this footnote will be generated from a footnote look-up table for each sample type 2 monetary 3 separation or 4 nonseparation . Footnote 3 The state completed x percent of the sample type denials sample cases within 90 days. The program standard is 85 percent completed within 90 days. Condition The percentage for sample type y where b dca master.samptype 2 monetary 3 separation or 4 nonseparation will be calculated using the same method used in the BAM DCA Case Completion and Time Lapse report. Cases not meeting the BAM DCA population definition b dca master.program 8 or 9 or withdrawn claims b dca master.actflag 8 are not counted in calculating state time lapse rates. Footnote 4 x percent of the sample type denials sample cases were not completed when this report was prepared. This exceeds the program requirement that no more than two 2 percent of the cases for the year are incomplete 120 days after the end of the PIIA reporting year. Condition The percentage is based on the number of BAM DCA cases that were not completed b dca master.supcomp is NULL by COB October 28 YYYY 1 divided by the number of valid cases selected for BAM DCA weekly samples during PIIA YYYY BAM batches YYYY27 through YYYY 1 26 . Cases that do not meet the BAM DCA population definition b dca master.program 8 or 9 or withdrawn claims b dca master.actflag 8 are not counted in calculating state case completion rates. A percentage will be calculated for each Attachment II II-6 sample type y where b dca master.samptype 2 monetary 3 separation or 4 nonseparation . This footnote will be generated only if the user specifies an annual report when the user specifies the batch range YYYY27 through YYYY 1 26 . Footnote 5 The annual sample of sample type denials is x cases below the allocated annual sample of 150 BAM DCA cases per year. The precision of the data might be reduced due to the failure to sample at the prescribed level. Condition The state s annual sample selection is eight 8 or more cases below its allocated annual sample of 150 cases. Cases that do not meet the BAM population definition b dca master.program 8 or 9 are not counted toward meeting the annual sample allocation. This footnote will be generated from a footnote look-up table for each sample type 2 monetary 3 separation or 4 nonseparation . This footnote will be generated only if the user specifies an annual report when the user specifies the batch range YYYY27 through YYYY 1 26 . Footnote 6 The sampling frames from which the sample type denials samples were selected may not include all of the determinations that meet the definition for inclusion in the DCA population or may include records that do not meet the DCA population definition. This limits the degree to which inferences about the population can be made from BAM DCA data. Condition The size of the DCA population for PIIA 2025 varies by more than the statistical control limit from the benchmark population. The benchmark populations are Monetary Percent of determinations denied in ETA 218 report times number of new initial claims intrastate and interstate liable plus transitional claims in ETA 5159 report. Separation Percent of determinations denied in ETA 207 report times number of separations in ETA 9052 report. Nonseparation Percent of determinations denied in ETA 207 report times number of nonseparations in ETA 9052 report. This footnote will be generated from a footnote look-up table for each sample type 2 monetary 3 separation or 4 nonseparation . This footnote will be generated only if the user specifies an annual report when the user specifies the batch range YYYY27 through YYYY 1 26 .