DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 18-94
TO	:	ALL STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	MARY ANN WYRSCH Director Unemployment Insurance Service
SUBJECT	:	Procedures for Release of Unemployment Insurance Benefits Quality Control (BQC) Data

1. Purpose. To provide State Employment Security Agencies (SESAs) with guidelines for the annual release of Unemployment Insurance (UI) Benefits Quality Control (BQC) program data for Calendar Year (CY) 1993.

2. References. 20 CFR 602; Federal Register Notice, March 26, 1990, 54 FR 11112; UIPL 13-93, January 12, 1993; and Benefits Quality Control State Operations Handbook, ET Handbook No. 395.

3. Background. The final rule to establish the Unemployment Insurance Quality Control program is found at 20 CFR Part 602. Effective October 5, 1987, QC programs in the 50 States, the District of Columbia, and Puerto Rico have selected weekly random samples of UI benefit payments for investigation under the mandatory program.

   20 CFR 602.21(g) provides that each State shall:

   Release the results of the QC program at the same time each year, providing calendar year results using a standardized format to present the data as prescribed by the Department; States will have the opportunity to release this information prior to any release by the Department.

   The notice of procedures for the release of BQC data for the UI program was published in the Federal Register on March 26, 1990, at 54 FR 11112.

4. Date of Record. The Department has established close of business (c.o.b.) April 30, 1994, as the date of record for State databases for computation of the error rates for the Annual Report of BQC data for CY 1993. All information in the Annual Report will be based on CY 1993 BQC cases that have been signed off by the QC supervisor by c.o.b. April 30, 1994. States must not reopen any CY 1993 BQC cases after this date until they have reviewed the computations of the error rates and have reconciled any differences between the State and National databases. Any data analysis supporting the Annual Report must be run on the database as it exists at c.o.b. on April 30. If States make any further changes, their data and results will differ from the data and results of the National Office. These differences will then have to be reconciled.

5. Annual Report Software. The software which produces the Annual Report excludes Emergency Unemployment Compensation (EUC) program eligibility option cases, as described in UIPL 13-93, from the rates calculations. This software also excludes cases which do not meet the definition of the BQC population, for example, interstate or supplemental payments. These cases are coded "9" in data element c1. The software adjusts the population dollars paid to exclude any EUC and code "9" cases. The software uses new data elements h5 (total overpayment amount for the key week) and h6 (total underpayment amount for the key week). The CY 1993 rates released by the States and published in the Federal compendium is based on these factors. The footnote look-up table applies to the CY 1993 data. Any footnote referring to time lapse considers the reopen date if the reason for reopening is code "3" (the State on its own has recognized and error and has made the necessary corrections).

   The States may run the modified Annual Report software as soon as all cases are completed. The date of record is c.o.b. April 30, 1994. The National Office will produce an Annual Report for each State, based on the BQC cases closed as of c.o.b. April 30, 1994.

6. Annual Report Format. The Annual Report format is shown in Attachment 1. It is divided into three main sections.

   Quality Control Data

   Total Dollars Paid in Population - Total UI benefits paid to the population of UI claimants who comprise the sampling frames for all weeks in CY 1993 for which the State pulled a BQC sample, adjusted to exclude EUC program eligibility option cases and other UI payments that do not meet the definition of the BQC population.

   Sample Size - Total UI payments selected during CY 1993 (BQC batches 9301 through 9352) and completed (QC supervisor sign-off) by c.o.b. April 30, 1994, excluding EUC program eligibility and other cases that do not meet the BQC population definition. This is the number of BQC sample cases from which the rates and sampling errors (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.

   95% Confidence Interval - A confidence interval, expressed as +/- a percentage, will be 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 BQC sample.

   Footnotes

   The footnotes that will appear on State BQC Annual Reports to describe certain conditions that affect the data are described in Attachment 1, pages 2 and 3.

   No changes have been made to the footnotes for the CY 1993 Annual Report.

   Narrative

   States are invited to supply a narrative analysis that will accompany their Annual Report. The Department will include this narrative in the digest of States' Annual Reports that it will prepare (see section 10, below).

   The narrative may include, but is not limited to, a discussion of State laws and how they affect error rates, an explanation of circumstances that led to some degree of inaccuracy in the reported error rates, and proposed or actual corrective action strategies.

   State narratives must be received in the National Office no later than June 11, 1994. States not planning to submit a narrative should notify the National Office by June 11, 1994, that no narrative will be submitted. The procedures for preparing and transmitting the Annual Report narrative to the National Office are described in Attachment 3.

7. Supplemental Data. In order for the SESAs to interpret the data in the Annual Report and provide narrative explanations of the data, the Department recognizes the need for additional information on cause and responsibility. The software that produces the BQC Annual Report will also generate a separate report consisting of up to 16 responsibility categories and up to 6 cause categories. Responsibility and cause data will be reported as percentages of UI dollars overpaid. The format for this report is shown in Attachment 4.

   In order to provide States with the greatest flexibility in interpreting the data, all possible responsibility codes and broad cause categories can be generated. States can combine categories which contain few sample cases, where appropriate. No sampling errors will be computed because the publication of these percentage rates is not mandatory. States should be aware that many of these percentages are based on small numbers of BQC sample cases and may have relatively large sampling errors. The Department will publish such data in the technical appendix, along with additional analysis where appropriate.

8. Comment Period. BQC Annual Reports produced by the Department of Labor will be transmitted to each State on May 13, 1994. Each State should review its Annual Report and if there are any comments submit them to the National Office (Attn: TEUQS, Andy Spisak) by May 31, 1994. SESA comments will be discussed and reconciled by June 7, 1994.

9. Public Release by SESA. As stated in the Federal Register notice of March 26, 1990:

   Each State will release the required data annually through established channels for disseminating State performance data. In accordance with established State procedures, the data must be provided to those who normally receive performance/evaluation data and to anyone else who requests it. It is no longer necessary to publish a notice of availability.

   States must release their Annual Reports by June 30, 1994. If a State fails to release data in accordance with these procedures, the Department, in its annual review of State QC operations as specified in 20 CFR, Part 602, Section 602.31, will take appropriate action.

10. Federal Release of Data. The Department will announce the availability of QC program data for CY 1993 through a notice published in the Federal Register on or about July 29, 1994. The Department's publication will be a digest prefaced by background information on the Quality Control program, and a brief discussion of how the error rate estimates are computed. Readers will be discouraged from comparing results among States. Each State's section, including its Annual Report and narrative, will be displayed separately. State sections will be ordered alphabetically to discourage ranking and comparisons. The name of the State official designated by the State as its Annual Report contact will also be published.

    For CY 1993, the Department will continue the practice begun with CY 1989 data of publishing certain analytical information on aspects of the BQC findings.

    If the Department determines that a State has failed to follow the prescribed QC methodology -- in terms of sample selection, data collection methodology, or case completion timeliness -- to such an extent that the data are not reliable, the Department will publish an explanation of the major deficiency in lieu of an Annual Report for that State. Also in accordance with instructions in the Program and Budget Plan, ET Handbook No. 336 (2nd edition), States will be required to address these areas by submitting corrective action plans for the upcoming fiscal year.

11. Key Dates. The following is a summary of key dates for the public release of CY 1993 BQC data.

    2/7-4/30	States check databases and resolve any database problems.
    4/30	Date of record for State BQC databases for Annual Report purposes. Cases closed by supervisors after this date will NOT be included in the Annual Report. States should not reopen any CY 1993 cases to change the database after this date until their Annual Report is finalized and any analysis for the release of the data or the narrative is completed.
    4/30	Department of Labor electronically transmits the modified Annual Report software and footnote look-up table to each State's Sun computer.
    5/16	Department of Labor sends Annual Reports to the State Administrators over signature of Mary Ann Wyrsch, Director, UIS.
    5/16-5/31	States review Annual Reports and provide comments to Department of Labor.
    6/1-6/7	Department of Labor and States discuss and reconcile comments in collaboration with Department of Labor Regional Offices.
    6/11	States provide name of contact persons to Department of Labor ETA Regional Administrators. States provide narrative comments or notice of waiver of narrative comments to Department of Labor National Office.
    6/30	States release CY 1993 BQC Annual Report and send copy of the release to the appropriate Department of Labor Regional Administrator.
    7/14	States send copies of any press releases and/or newspaper articles relating to the Annual Report released by the SESA for CY 1993 to the appropriate Regional Administrator.
    7/29	Department of Labor publishes notice in the Federal Register announcing the availability of BQC data.

12. Action Required. State Administrators are requested to:

    1. provide copies of these guidelines to the appropriate staff and

    2. ensure that annual report narrative comments or notice of waiver of such comments is transmitted to the Department of Labor National Office.

    3. ensure that the following information is supplied to ETA Regional Administrators:

       (1) the name, location, and telephone number of a contact person to whom interested parties can write or call with questions or inquiries about the State's annual release of BQC data by June 11, 1994;

       (2) a copy of the State annual BQC data release by June 30, 1994; and

       (3) copies of any press releases and/or newspaper articles relating to the Annual Report released by the SESA for CY 1993 by July 14, 1994.

13. Inquiries. Questions should be directed to the appropriate Regional Office.

14. Attachments.

    (1) Annual Report Format and Footnotes;

    (2) State BQC Sample Selection by Batch for CY 1993;

    (3) Annual Report Narrative Format and Preparation; and

    (4) Format for BQC Annual Report Supplemental Data.