DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 34-95
TO	:	ALL STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	MARY ANN WYRSCH Director Unemployment Insurance Service
SUBJECT	:	Combined Wage Program (CWC)

1. Purpose. To provide policy direction and guidance to State Employment Security Agencies (SESAs) concerning the CWC program.

2. References. Section 3304(a)(9)(A), Internal Revenue Code of 1986; 20 CFR 616: ET Handbook No. 399.

3. Background. In consultation with the Employment and Training Administration (ETA), the Interstate Conference of Employment Security Agencies' (ICESAs') Interstate Benefit (IB) User Group (formerly, Interstate Benefit Committee) is reviewing issues concerning procedures and practices for handling claims under the Interstate Arrangement for Combining Employment and Wages (CWC Program). During the last committee term, in response to a request for information by the CWC Sub-Committee, States' Coordinators and CWC staff raised issues concerning unauthorized procedures that are the result of States' practices that have evolved over the years, including unauthorized form changes, and suggested certain regulatory changes.

   Regulations published at 20 CFR 616.8(f) require States to calculate the percentage of benefit charges to at least three decimal places, but allow percentages to be calculated beyond three decimal places. This has proved to be problematic in the reconciliation of charges on quarterly Statement of Benefits Paid to Combined Wage Claimants, Form IB-6.

   The Chairman of the ICESA Unemployment Insurance Committee and the Chairman of the IB User Group asked States to agree voluntarily to implement a procedure limiting the calculation of pro rata benefit charges for the quarterly Statement of Benefits Paid to Combined Wage Claimants, Form IB-6, to three decimal places and implement a reconciliation procedure that provides for a $1.00 plus or minus tolerance.

   This directive transmits the list of States that have agreed to all or part of the request and provides clarification of procedures. Other issues involving unauthorized form changes, variations in the manner that information is provided, and the potential automation of the Form IB-6 process, will be addressed after the IB User Group completes its deliberations and makes its suggestions to ETA.

4. CWC Billing and Reimbursement Policy Agreement.

   1. Effective immediately, the following States have agreed to adopt a policy to calculate CWC benefit charges to three decimal places and implement a reconciliation procedure that allows a $1.00 plus or minus tolerance in quarterly charge.

      Alabama	Missouri
      Alaska	Montana
      Arizona	Nebraska
      Arkansas	Nevada
      California	New Hampshire
      Colorado	New Jersey
      Connecticut	New Mexico
      Delaware	North Carolina
      District of Col.	North Dakota
      Florida	Ohio
      Georgia	Oklahoma
      Hawaii	Puerto Rico
      Idaho	Rhode Island
      Illinois	South Carolina
      Indiana	South Dakota
      Kansas	Tennessee
      Kentucky	Texas
      Louisiana	Utah
      Maine	Virginia
      Maryland	Washington
      Michigan	West Virginia
      Minnesota	Wisconsin
      Mississippi	Wyoming

      Note: Although all of these States have agreed to change calculations, the actual change will require programming to implement and will not occur simultaneously in all States.

   2. Effective immediately, the following States have agreed to implement a reconciliation procedure that allows a $1.00 plus or minus tolerance in quarterly charge.

      Iowa

      Oregon

      Pennsylvania

5. Issues and Procedures.

   1. Posting of Benefit Charges on the QuarterlY Statement of Benefits Paid to Combined Wage Claimants, Form IB-6. Some Paying States consolidate benefit charges for more than one benefit year when preparing the Form IB-6. This practice is inconsistent with the requirements for completing the Form IB-6 and also makes verification of charges during a benefit year impossible. Benefit Charges shown on the Form IB-6 are required to be posted separately for each claim from which they are paid indicating the appropriate benefit year ending date. Therefore, if benefits are paid to an individual with respect to different benefit years during a quarter, the charges must be posted separately. States that are combining such payments must discontinue the practice immediately.

   2. Using Wages from a Transferring State to Determine Entitlement on a Claim Other Than the One for Which They Were Transferred. When a paying State requests a transfer of wages for use in determining eligibility on a combined wage claim, the response is specific to the request which includes a specific effective date and involves a specific base period. If the effective date and/or the base period (in cases of use of an alternate base period) of the claim changes, the wages transferred in response to the original request must be returned to the transferring State and a new request sent with the claim's effective date or new base period.

      Under the automated wage transfer system, the claim identification data contained in the electronic Report on Determination of Combined-Wage Claim, TC-IB5, must match the corresponding data of the electronic wage transfer response, TCIB4.

      Note: Combined wage transfer rules also do not permit a State to request a transfer of wages that cover a period in excess of the single base period being used in the determination of the claim. States may not request a transfer of wages that cover both the basic and alternate base period in a single request. Alternate base period wages are to be requested only after the basic base period wages have been returned.

   3. Crediting Transferring State(s) for Benefit Charges Previously Reimbursed When Benefits are Determined to Have Been Overpaid to the Claimant and Recoverable. A determination that requires the claimant to reimburse the paying State previously paid benefits, either by cash or by offset of future benefits, establishes a recoverable overpayment. When such a determination is issued, the paying State shall credit each transferring State(s) with the full amount of all previously reimbursed benefit charges associated with the overpaid benefits. The paying State shall also discontinue requesting benefit reimbursement from the transferring State(s) for any outstanding charges relating to such benefits.

   4. Size of Type Used in Printing Statement of Benefits Paid to Combined-Wage Claimant, Form IB-6. The Form IB-6 is designed with nine specific columns to array information pertaining to benefits paid, to each CWC claimant during the reference quarter, that are reimbursable by the transferring State. The form is designed for landscape printing in 11" by 8 1/2" form size. The size of the print to be used when printing the form and posting information to the document have not been specified. Some States are using a print size that makes the information difficult to read. States are requested to use a minimum font size of 12 cpi.

   5. Paying States' Practice of Sending Notification to All States When Its Issuance of Statement of Benefits Paid to Combined-Wage Claimant, Form IB-6 will be late. In order for a quarterly Form IB-6 to be considered timely, it must be issued to the transferring State within 45 days of the end of the quarter during which the benefits were paid. Some States have implemented procedures of notifying all States when the Form IB-6 will not be sent immediately upon the end of the quarter even when the report will not be later than the 45 days allowed. Most States' coordinators find that such notifications serve little or no purpose and request that they be discontinued except when the Form IB-6 will not be sent during the time allowed.

6. Action Required. State Administrators are requested to ensure that the information in this directive is made available to all appropriate staff and that the CWC procedures as clarified are followed.

7. Inquiries. Questions concerning this letter should be addressed to the appropriate Regional Office.