DIRECTIVE	:	GENERAL ADMINISTRATION LETTER NO. 04-97, Change 1
TO	:	ALL STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	DAVID HENSON Director Office of Regional Management
SUBJECT	:	Reporting of Data on the Emergency Unemployment Compensation Program for the ETA-227 Report

1. Purpose. To change instructions issued by General Administration Letter (GAL) 4-97 regarding the cessation of reporting data on the Emergency Unemployment Compensation (EUC) Program for the ETA-227 Report. Without this change, performance measures for Benefit Payment Control (BPC) will be adversely affected.

2. Reference. GAL 12-92 with changes 1-6; GAL 4-97; Public Laws 102-164, 102-182, 102-244, 102-318, 103-6, and 103-152.

3. Background. The EUC program ended on February 5, 1994, with no benefits payable for weeks of unemployment after April 30, 1994. GAL 12-92, with Changes 1-6, provided the implementing instructions for EUC based upon Public Law 102-164 and its several amendments: Public Laws 102-182, 102-244, 102-318, 103-6, and 103-152. GAL 12-92 instructed State Employment Security Agencies (SESAs) to report EUC activity, on separate reports including the ETA-227, for four full quarters after the last payable week of the program. Thus, reporting of EUC activity should have been discontinued after June 30, 1995, for most required reports. However, a significant number of SESAs continued submitting EUC Reports beyond the June 30, 1995, cutoff.

   Subsequently, GAL 4-97 was issued to restate the instructions to discontinue reporting. Despite this reiteration, many SESAs continued to submit separate ETA-227 Reports for EUC through December 31, 1998, at which time the National Office prevented any further electronic reporting of EUC data by removing the data entry screens for EUC.

   Additionally, GAL 4-97 directed SESAs to combine any residual EUC data with that of the regular program reports with a comment made of this in the "remarks" section of the reports.

   This last instruction regarding combining EUC data with regular program data has been reconsidered. For most reports, there is little or no impact on the data because EUC activity has ceased. However, this is not true for the ETA-227 Report, where outstanding EUC overpayments still exist. If not corrected, adherence to these instructions will have an adverse impact on the records for the ETA-227 reporting system and the performance measures derived from them by distorting the ratio of overpayment collections to overpayment establishments.

4. Revised Instructions. The proper instructions for the cessation of reporting EUC data were those outlined in GAL 12-92. The pertinent points for the reporting and treatment of EUC overpayments are summarized as follows:

   • Make active collection efforts, including offset, to recover EUC overpayments during the three-year period subsequent to the overpayment.

   • During the second three-year period subsequent to an overpayment:

   • Remove EUC overpayments from the accounting records.

   • Retain administrative records of the overpayments.

   • Although offset is no longer permitted, overpayments recovered by other means should be credited to the administrative records.

   • Write off the EUC overpayment record after the second three-year period subsequent to the overpayments.

   • Report EUC activity for four full quarters after the last payable week of the EUC program.

   Thus, EUC data should never be combined with the data from the regular programs for the ETA-227 Report.

5. Action Required. SESA Administrators are requested to review their records to determine whether the ETA-227 Reports for the regular program contain any EUC data. No further action is necessary if the ETA-227 Reports for the regular program do not contain EUC data. However, if the ETA-227 Reports for the regular program contain EUC data, submit revised ETA-227 Reports (for the regular program only) excluding those data.

6. Inquiries. Please direct inquiries to the appropriate Regional Office.