DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 37-91
TO	:	ALL STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	DONALD J. KULICK Administrator for Regional Management
SUBJECT	:	Guidelines for Unemployment Insurance (UI) Quality Control (QC) Program Improvement (PI) Studies

1. Purpose. To provide revised and expanded guidance to State employment security agencies (SESAs) on the development and conduct of special studies that may facilitate UI program improvement actions.

2. References. UIPL 29-86 (April 18, 1986); and FM 11-90, (October 27, 1989).

3. Background. The Employment and Training Administration (ETA) has always encouraged the States to develop innovative and cost effective methods for obtaining and using benefits QC (BQC) data. The QC regulation at 20 CFR 602.21 (b) -- following the consensus agreement -- provides a degree of flexibility in the use of BQC resources for basic study activity. In December 1987 the Department issued a directive (UIPL 9-88) to the SESAs confirming their option to divert QC staff resources, for an approved period, to conduct program improvement (PI) studies, with a corresponding reduction in the QC weekly samples during the study period. The directive stressed that such reductions in QC sampling were exceptional and temporary, and that diversion of QC investigative staff for a variety of special studies should be approved in advance.

   UIPL 33-89 offered broadened guidelines to encourage SESAs to study a wide range of UI program issues and problems. Since its issuance, a large number of States have conducted PI studies. The quality level of these studies varied significantly. That experience is the basis of a number of modifications and refinements of existing PI study policy and procedures incorporated in this program letter. These changes are intended to enhance the general quality of PI study proposals submitted for approval, and to improve the processing of approvals of both SESA proposals and requests for study extensions by the Regional and National Offices (RO and NO).

4. Policy. This directive reiterates the ETA policy of encouraging and aiding SESAs to undertake short-term research projects and program studies as a means of translating general findings of QC case investigations into practical UI program improvements and error reductions. Such efforts may involve UI data analysis beyond the capabilities of the QC analyst and other available UI staff, or take the form of gathering new, supplemental data that could serve to inform management policy and process decisions.

   No approval is required when the State maintains its required QC sample size and funds the project from available resources. Advance approval from the NO is required if a State plans to fund a study by reducing its required annual QC sample, and deploys QC staff in this study effort. No State may reduce its QC sample size below 400 cases per year.

   1. Required Standards.  Standards for SESA PI study proposals should reflect primarily the needs of SESA decisionmakers. Areas of study may include development and testing, but not implementation or operation of ongoing UI activities. Therefore, QC staff cannot be diverted from QC functions to work on regular UI program implementation or operational activity.

      During the past three years, SESAs have submitted program improvement proposals which varied widely in content and quality. This variance may have been the result of broadly written guidelines. It is now appropriate to more specifically define the basic content requirements for study proposals.

      (1)  Problem Addressed - What is the specific problem or UI program facet that is proposed for PI study? What aspects of this situation have SESA staff identified through QC verification data? Indicated the findings that SESA staff have made through analysis of QC data (and other UI data) that suggest the need for further study before SESA management can consider potential program improvement actions.

      (2)  Objectives and Methodology - What are the study objectives? What does the SESA expect to learn from the study? Describe the methodology to be followed. Explain how this study approach will provide additional information needed by UI management.

      (3)  Results Expected - What results are anticipated? How will the results of the study be presented to UI principals? How does the SESA anticipate translating this information into decisions that may lead to UI program improvement?

      (4)  Projected Study Resources - How many QC staff and other UI resources will be needed to conduct the program improvement study? Be sure to identify QC positions the SESA plans to dedicate to the study and indicate the size (number of cases) of the reduction in QC weekly sampling requested during the study period.

      Work Plan - What is the projected time period for: (a) implementation of the PI study, and (b) preparation of a final study report? Present a study work plan that specifies: (a) QC staff hours and time (in weeks) required for completing major tasks or segments of the study, and (b) QC staff time, if any, needed for preparation of the final report. Indicate the: (a) anticipated study start date, (b) study completion date, and (c) planned date for completing the final report.

      In short, by responding to the several questions and issues presented above, the SESA should be able to communicate clearly the following essential information in each study proposal offered:

      • the problem or issue to be studied,

      • the objectives of the study,

      • the methodology to be followed,

      • the results and outcomes expected and how to use these findings for program refinement,

      • UI resources (including QC staff) to be used in completing the study and the final report, and the schedule for completion of the study and the final report.

      In the preparation of PI study proposals, SESA staff may find it useful to organize its material following an outline which details the basic study elements and information that are required in this directive. An example of such a proposal outline or checklist is presented in the attachment.

      If a study proposal fails to meet the five established requirements, the RO will return it to the SESA for completion, and for subsequent resubmission to the RO. No PI study involving QC sample reduction should be launched prior to NO approval. The NO will not approve such studies retroactively.

   2. Final Report - At the conclusion of the QC program improvement study, the SESA should prepare a final report assessing the outcomes of the study. An adequate study report will cover the following elements:

      (1)  the focus and scope of the study, i.e., the problem, goals and objectives of the proposed study;

      (2)  the methodology pursued and an assessment of whether or not the study objectives were met by this approach.

      (3)  a brief description of study implementation and the outcomes (expected, unexpected) of the effort;

      (4)  a statement of the principal findings (positive or negative) and the potential usefulness of these results for prompting UI program improvements; and

      (5)  recommendations for UI management consideration. Describe any benefits that may have resulted already from the study.

      The SESA should forward four copies of each study report to the appropriate RO. (It is desirable that, whenever feasible, the SESA send final reports of completed studies to the Region along with new and subsequent study proposals that are submitted for approval.)

5. Approval Procedures for Study Proposals. SESAs wishing to employ QC resources in UI program improvement studies will prepare proposals for submittal to their respective Regions, following the guidance and requirements of this directive. Since approvals of QC staff diversions are directly related to the Fiscal Year (FY), it is highly desirable that State proposals be planned and submitted to the Regions on a FY basis. (Several SESAs, particularly those using the Quality Improvement Project study model, have developed PI study proposals that coincide with the FY budget cycle.)

   SESAs are encouraged to seek assistance from the Regions, when needed, in developing suitable study work plans for inclusion in a request for QC staff diversion. The following steps are intended to expedite the review and approval of PI study proposals by the RO and NO.

   1. The SESA should submit a complete study proposal to the RO two months prior to the planned start date of the proposed study. This timing is particularly important in situations in which a SESA is hopeful of securing approval for additional studies to be launched following one or more current studies then nearing completion.

   2. The SESA should indicate the completion date of the final report and specify QC resources needed, if any, and the schedule of sample reduction requested for completion of the report.

   3. Regional staff will review the proposal and, if it meets the requirements stipulated in Section 4. a. above, send it along with the RO's evaluation and recommendations to the NO for review and approval. This review will be completed by the Region in three weeks or less.

   The NO decisions will be provided to the Region within the remaining five weeks.

6. Requests for Study Extensions. The NO policy continues to allow the diversion of SESA QC staff, with accompanying sample reductions, to accomplish UI program improvement as long as the State is engaged in activities likely to produce positive results. The policy is as follows:

   1. States that complete their PI studies in a timely manner may submit a new proposal at any time, in accordance with policy and procedures spelled out in this directive. In the interim they must return to investigating their respective full weekly sampling allocations.

   2. A State that has not completed one or more studies in the approved study period may request an extension of the period of QC staff diversion and sample reduction.

   The written request should be submitted to the appropriate RO as soon as it becomes clear that the study in question will not be completed as originally approved. At a minimum, such extension requests should be forwarded to the RO at least 45 days prior to the expiration of the initial approved studyperiod. For projects approved on Fiscal Year basis, this means submission of requests on or before August 15.

   The SESA request for extension should include the following information: (a) explanation for the extension request; (b) a supplemental work plan which details the number of QC staff and the number of weeks required for completion of both the study and the final study report, and (c) proposed RO assistance, if needed.

   The RO will forward the request to the NO, with its recommendation, 30 days prior to the end date of the ongoing study period, so that the NO is able to review the request and send a response to the Region before expiration of the initial approval period. If there is a delay beyond the initial study expiration date in approval of such an extension request, the State must return to its regular weekly sample level until approval has been confirmed.

7. Action Required. SESA administrators are requested to provide this information to appropriate SESA staff.

8. Inquiries. Questions should be directed to the appropriate RO.

9. Attachment. Minimum Proposal ElementsRequirements.

Attachment -- UIPL No. 37-91

Minimum Proposal ElementsRequirements

(Address each item)

1. Problem Identification

   (1)  Statement of Problem

   (2)  BQC data pointing to the problem

   (3)  Other pertinent UI data analyses

2. Objectives and Methodology

   (1)  Study objectives

   (2)  Expected insights from the study

   (3)  Methodologystudy approach

   (4)  Potential value of study for UI management

3. Potential Results

   (1)  Results expected

   (2)  Presentation of findings to management

   (3)  Likely program improvement actions

4. Study Resources

   (1)  Staff requirements

   (2)  QC sample reduction needed

5. Work Plan

   (1)  Schedule of key activities

   (2)  Deployment of QC staff

   (3)  Study completion date; final report date