DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 38-96
TO	:	ALL STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	MARY ANN WYRSCH Director Unemployment Insurance Service
SUBJECT	:	The Impact of Remote Claimstaking on Reporting and Use of Unemployment Compensation Claims Data and the Required Changes to the Interstate Statistical Data Exchange.

1. Purpose. To advise State Employment Security Agencies (SESAs) of decisions with regard to issues and concerns associated with remote claimstaking as they impact the reporting and use of claims data and the Interstate Statistical Data Exchange.

2. References. ET Handbook Nos. 392 and 401; UIPL 35-95; and the ICON User Guide.

3. Background. The number of initial unemployment compensation (UC) claims and the number of weeks claimed for UC are important national, State and local economic measures. On a weekly basis, the Unemployment Insurance Service (UIS) uses state reports on these measures to issue an aggregate report that is reflective of overall filing for and collection of unemployment benefits.

   This aggregate report contains two sets of claims counts. The first set, based on data from the ETA 538 Report, is "advance' data gathered from the most recent week. It reflects data on initial UI claims and weeks claimed. The initial claims numbers in the 538, or "advance" report are based on intrastate initials plus interstate agent claims. The weeks claimed number in the "advance" number in based on intrastate weeks and interstate liable claims paid by a state.

   The second set of data reported weekly is based on the ETA 539 report, and contains information for the week prior to the advance week. The initial claims data on this report mirrors that of the 538 report in that it contains intrastate initials and interstate agent claims. However, the weeks claims data in this report is the sum of intrastate weeks claimed plus interstate agent weeks claimed. These data are considered more accurate since the week's lapse time has allowed for the collection of information on agent weeks claimed. This latter information is gathered from a data exchange procedures available through the Interstate Connection (ICON) system known as the Interstate Statistical Data Exchange. The data from the ETA 539 report is used to determine the Insured Unemployment Rate (IUR) for each state and to determine the national IUR. This data also forms the basis for other key unemployment reports.

   In addition to the data exchange referenced above, States also exchange information under separate arrangements with contiguous or nearby states on commuter claims. The determination of which claimants are commuters is left to individual states to outline in agreements authorized under the Interstate Benefit Payment Plan, (IBPP), and the description of commuter claims is found in the Interstate Benefits (IB) Handbook. Generally, commuter claims are considered those filed by persons who worked, and would continue to seek work in one state, while living in another state. These claimants would be expected to file through intrastate procedures in the state in which they work. The data exchange on these claimants becomes necessary for purposes of Bureau of Labor Statistics (BLS) Local Area Unemployment Statistics (LAUS) data collection. The LAUS program which is used to develop the Total Unemployment Rate (TUR) for most jurisdictions, and for compiling other unemployment data, is based on the residence of the unemployed person, not where the claim is filed. BLS has developed methodologies for use by States in computing residence based unemployment data, which uses both the interstate agent claims data, and number of claims filed by commuters. This residence based unemployment data is used for a variety of purposes, among them funding allocations formulas, determination of eligibility for Federal aid, and economic development programs.

   As can be seen from the above description, a variety of procedures have been developed to exchange data among states on initial and weekly UI claims filings to meet the needs for IUR and TUR counts. As States move to implement remote/ telephone initial claimstaking for intrastate and interstate claims, issues arise on how to handle distinctions between intrastate and interstate claims, and how to handle the exchange of information among states in this new environment.

   To address these issues, a workgroup was convened by the Interstate Conference of Employment Security Agencies (ICESA), composed of representatives from the ICESA UI, Labor Market Information (LMI) and IB Committees, the BLS and the Unemployment Insurance Service (UIS). The goal of this group was to develop revised procedures for handling commuter and interstate claims data, and to address a systematic method for exchanging data between states.

   The policies and procedures contained in this directive reflect the discussion and understandings reached by the above referenced workgroup. It is being issued at this time to provide states with guidance about new data exchange procedures that need to be operative as states begin to more extensively implement remote/telephone claims systems.

4. Data Exchange for Commuter Claims. As noted above, most states have developed agreements under the IBPP on the procedures for identification, processing, and exchanging data on commuter claims. This directive does not change the nature of those individual agreements, nor does it change BLS guidance to states on how to utilize commuter claim data in aggregating residence based unemployment data. However, it has been determined that it would benefit all states to add the processes for exchange of commuter initial claims and weeks claimed data to the Interstate Statistical Data Exchange on the ICON system. Subsequent sections of this directive will address the procedures.

5. Statistical Data.

   1. State and Local FIPS Coding. Currently, the agent (residence) State provides to the liable State the claimant's residence State, county and local FIPS, or applicable codes, with respect to the claimant's address as part of the initial claims process. When the liable State takes the initial claim directly, the liable State will have to provide either the claimant's residence State, county and city/town FIPS codes or the claimant's full address in the report of an initial claim and week claimed. The FIPS publications provide most information. However, they do not contain the codes used by the New England States for local areas. If the liable State maintains both a mailing and residence address in an electronically accessible file, both addresses will be included in the data record. If the liable State maintains only a mailing address in an electronically accessible file, but determines that the mailing address is not the claimants residence address, the FIPS codes provided will be based on the residence address. The mailing address will be assumed to be the residence address if no conflicting residence FIPS codes or address is provided.

   2. Initial Claims and Weeks Claimed Data Identification. Each State must implement a procedure to identify and distinguish between intrastate claims filed by commuters and interstate claims (claims filed through or from an agent State) for benefit determination purposes, including the application of Federal law with respect to the Interstate Arrangement for Combining Employment and Wages, Unemployment Compensation for Ex-Servicemembers wage assignment and Extended Benefit eligibility (Refer to UIPL 35-95, Change 1, soon to be released). The identification/distinction between intrastate commuter claims and interstate claims will also be used in providing for the appropriate exchange of data between States and the use of data. The liable State can identify interstate claims by continuing to maintain a distinct office number in the record claim record. This will automatically distinguish them from commuter claims as the commuter claim record will show a non-resident address for an intrastate claim. All intrastate claims filed by non-residents are assumed to be claims filed by commuters. The liable State will also have to distinguish between interstate initial claims it takes by telephone and those filed through an agent State in order to extract and transmit initial claims information pertaining to only the initial claims taken under the liable State's remote claimstaking procedures during the report week. This distinction can be accomplished by showing only a State of residence FIPS code in the record. All claims on file that were filed through an agent State will have agent State FIPS codes in the liable record as provided by the agent State.

      Commuter claim data will be coded on the data record to provide for proper sorting by LMIBS and so that the residence State will be able to distinguish between interstate and commuter claimant detail data it receives for proper reporting and use. The coding of the data can be accomplished by electronically coding all intrastate claims with out-of-State addresses as commuters.

      Agent States may wish to create an agent State record from the initial claims data received from the liable State for interstate claims. These records could be used for reemployment assistance, IUR and reporting purposes.

   3. Data Exchange. The IB Committee has identified the data elements that will be exchanged between States to support remote initial claimstaking. The identified data elements (See Attachment A) have been provided to LMIBS for the development of the revised data exchange record and for development and distribution of revised procedures and guidelines to the SESAs. LMIBS has prepared a software application summary and flow chart and an estimated time line for distribution of the new programs to the States (See Attachment C.).

      Each State, whether or not it is implementing telephone claims, will need to install the new programs and take the other necessary actions to be prepared to receive initial claims and store data about its residents who have filed interstate claims directly with other States.

      (1) Liable States Taking Interstate Initial Claims By Telephone. Each State that takes interstate liable claims by telephone will send a report of each such claim, identified by residence State FIPS in the appropriate data field, to the LMIBS ICON HUB weekly. The initial claims data exchange will only include initial claims taken by the liable State. It will not include initial claims taken by the agent State.

      (2) Interstate Weeks Claimed Data. Weeks claimed data will be exchanged with respect to all interstate claims filed from a State whether directly with the liable State (via remote electronic procedures or mail) or through the agent State. Data pertaining to claims that have different agent and residence State codes maintained on file will identify both codes in the appropriate fields.

      (3) Commuter Weeks Claimed Data. At the end of the report week that includes the 12th of the month, each State will transmit weeks claimed data with respect to each intrastate claim filed by a commuter, to the State of residence under the same procedures as apply to interstate claims except that the field designated for the "Commuter Identification Code" will also be completed.

   4. Distribution of Data. Records will be sorted using agent and residence FIPS codes by the LMIBS ICON HUB. This will provide for all interstate initial claims and weeks claimed data and commuter weeks claimed to be delivered to the appropriate State as summary reports and detail data records.

      Interstate initial claims and weeks claimed summary reports will be available for pick-up (as a print file) from the LMIBS ICON HUB in a summary report by program (regular, extended, additional and Federal extension) and entitlement program (UI, UCFE, UCX), using the same format as is currently used for weeks claimed data, on each Wednesday morning.

      Commuter weeks claimed summary reports will only be reported for the report week that includes the 12th of the month and will be included in the print file from the LMIBS ICON HUB on the Wednesday morning following the week including the 12th of the month.

      The detail data will also be available for pick-up on Wednesday morning as a data file. The detail data file will include all records destined for the agent/residence State, including all interstate initial claims and weeks claimed and commuter weeks claimed.

      Recognizing that States will be implementing the new record format at different times during this transition period, the following procedures will be in place.

      During the transition period, two detail data files will be available to those States that are using the current 80 character record format to transmit weeks claimed data. Weeks claimed data from other States will be formatted to the old format for delivery to the States that have not implemented the new format. However, because initial claims detail data and the claimant's address will only be available in the new record format, the new detail data file of records in the new format will also be available to those States. In order to receive the new detail data file, States will have to install the de-block programs that are provided by LMIBS. States that have implemented the new record format will receive all the data in one file in the new format regardless of the format used by the sending State.

6. Preliminary Weekly Initial and Continued Claims Report, ETA 538. The advance weekly initial and continued claims report allows the Department to gather and report national data for a particular week during the following week. Quick release of these data are necessary since they represent leading economic indicators and the information benefits public policy makers and the public. The distribution of data among States via ICON cannot be scheduled to provide initial claims data to the agent State in time to meet the ETA 538 reporting requirements. Therefore, since on a national basis, the number of agent and liable interstate initial claims are conceptually the same, intrastate initial claims filed for the reference week and liable interstate initial claims received/taken as liable State will be reported. States will be notified of the effective date of this change at a later date.

7. Action Required. SESA administrators are requested to: (1) provide a copy of this directive to all appropriate staff, including Labor Market Information Directors; (2) ensure that prompt action is taken by the State upon receipt of the necessary programs and information from the LMIBS HUB, including necessary programming, to ensure that the data exchange requirements as set forth herein are met prior to participation in liable interstate remote initial claimstaking as a liable or agent State; (3) ensure that the claims data is properly used in compliance with all Federal reporting requirements.

8. Inquiries. Direct any questions to the appropriate Regional Office.

Click herefor Attachment A -- LIABLE/AGENT DATA TRANSFER RECORD

Click herefor Attachment B -- DATA FLOW CHARTS

Click herefor Attachment C -- INTERSTATE DATA EXCHANGE SYSTEM LIABLE/AGENT DATA TRANSFER (LADT) APPLICATION SUMMARY FLOW CHART