DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 18-00
TO	:	STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	GRACE A. KILBANE Administrator Office of Workforce Security
SUBJECT	:	Procedures for Release of Unemployment Insurance (UI) Benefit Accuracy Measurement (BAM) Data for Calendar Year (CY) 1999

1.Purpose. To provide State Employment Security Agencies (SESA) with guidelines for the release of UI BAM program data for CY 1999.

2.References. 20 CFR 602; Federal Register Notice, September 3, 1987, 52 FR 33520; Unemployment Insurance Program Letter (UIPL) No. 13-93, January 12, 1993; UIPL No. 19-96, April 24, 1996; and Benefit Accuracy Measurement State Operations Handbook, ET Handbook No. 395.

3.Background. The final rule to establish the UI Benefit Accuracy Measurement program, formerly Benefits Quality Control (QC), is found at 20 CFR Part 602 (52 FR 33520). 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.

UIPL No. 19-96 announced the elimination of the requirement that States publicly release BAM program data. While the Department of Labor will continue to publish an annual compendium of all States' data, each State may determine whether to independently release its data to the public.

4.Federal Release of UI PERFORMS Data.BAM data are published as part of the UI PERFORMS Annual Report, which also includes data for the Benefits Timeliness and Quality (BTQ) and Tax Performance System (TPS) programs. UI PERFORMS is the Department of Labor's management system for promoting continuous improvement in the performance of the UI system.

The CY 1999 UI PERFORMS Annual Report will be posted on the ETA Office of Workforce Security (OWS) public Internet site, which is currently under development. The Department will announce the implementation date and Web address of the OWS site in a UIPL. The Department of Labor will distribute a limited number of the printed version of the UI PERFORMS Annual Report to SESA administrators. Additional copies of the printed version of the report can be obtained through the National Technical Information Service (NTIS) (Internet: www.ntis.gov). The Department of Labor will announce the availability of CY 1999 BAM program data and information on ordering the CY 1999 UI PERFORMS Annual Report from the NTIS in a notice published in the Federal Register on or before August 31, 2000.

The BAM section of the CY 1999 UI PERFORMS Annual Report will include background information on the BAM program and a brief discussion of how the payment accuracy rate estimates are computed. Readers will be discouraged from comparing results among States. Each State's BAM Annual Report will be displayed separately in alphabetical order to discourage ranking and comparisons. In addition to the States' Annual Reports, the Department of Labor may publish analytical information on CY 1999 BAM program findings.

If the Department of Labor determines that a State has failed to follow the prescribed BAM program methodology -- regarding sample selection, data collection methodology, or case completion timeliness -- to such an extent that the data are not reliable, the Department of Labor will publish an explanation of the major deficiency in lieu of a BAM Annual Report for that State. States will be required to address these areas by developing corrective action plans as part of the State Quality Service Plan (SQSP) process.

5.Narratives. States that wish to address issues related to data published in the CY 1999 UI PERFORMS Annual Report are urged to do so through the SQSP process. If a State concludes that the CY 1999 BAM data need to be addressed separately, the State can supply an optional narrative, which the Department of Labor will post on the OWS public Internet site, along with the CY 1999 BAM data. However, State narratives will not be included in the printed version of the UI PERFORMS CY 1999 Annual Report.

The narrative must be transmitted by electronic mail to Andrew Spisak at "tonight!andy" on the Sun SPARC computer system or to "aspisak@doleta.gov" on the Internet, and a copy of the narrative must be provided to the appropriate Regional Office. State narratives must be received in the National Office no later than June 9, 2000. States that decide not to submit a narrative do not need to notify the National Office that no narrative will be submitted. State narratives that are not submitted electronically or that are received after the June 9, 2000, deadline will not be included in the UI PERFORMS data posted on the OWS public Internet site.

Effective with the publication of the CY 2000 UI PERFORMS Annual Report, the Department of Labor will no longer post or publish State narratives. Since the elimination of the requirement that States publically release BAM data, few States in recent years have opted to submit narratives. States can address issues related to the BAM, BTQ, and TPS data published in the UI PERFORMS Annual Report through the SQSP process.

6.BAM Date of Record. The Department of Labor has established close of business (c.o.b.) April 29, 2000, as the date of record for State databases for computation of the CY 1999 BAM Annual Report payment accuracy rates. All information in the Annual Report will be based on CY 1999 BAM cases that have been signed off by the BAM program supervisor by c.o.b. April 29, 2000. Any data analysis supporting the Annual Report must be run on the database as it exists as of c.o.b. on April 29, 2000.

States must not reopen any CY 1999 BAM cases after this date until they have reviewed the computations of the payment accuracy rates and have reconciled any differences between the States' and Department of Labor's databases. If States make any subsequent changes, their data will differ from the Department of Labor's data, which can result in inconsistencies between the State and Department of Labor versions of the Annual Report. Any such differences must be reconciled before the Annual Report can be issued.

7.BAM Annual Report Software. As described in UIPL No. 13-93, the software which produces the BAM Annual Report excludes cases that do not meet the definition of the BAM population, for example, interstate or supplemental payments. These cases are coded "9" in the program code data element (c1 in the b_master table of the UI database). The BAM Annual Report software adjusts the amount of UI benefits paid to the population to exclude the amount paid that is represented by cases with program code value "9".

Prior to the date of record, the Department of Labor will transmit a footnote lookup table for the CY 1999 BAM Annual Report. States can run the Annual Report software as soon as all BAM cases are completed. The National Office will produce an Annual Report for each State, based on the CY 1999 BAM cases as of c.o.b. April 29, 2000.

8.BAM Annual Report Format, Definitions, and Supplemental Data. The BAM Annual Report format is displayed and the components of the Annual Report are defined in Attachment 1. In order for the SESAs to interpret the data in the BAM Annual Report, the software that produces the BAM Annual Report also generates a separate report consisting of up to 16 responsibility categories and up to 6 cause categories. Responsibility and cause data are reported as percentages of UI dollars overpaid. No sampling errors are computed for these percentages. States should be aware that some of these percentages are based on small numbers of BAM sample cases and may have relatively large sampling errors. States can combine categories which contain few sample cases, where appropriate. The format for this report is shown in Attachment 2.

If cause and responsibility percentages do not add up to 100 percent, States should check for cases in which the key week amount overpaid coded in data element h5 in the b_master table of the UI database does not equal the sum of dollars overpaid coded in data element ei1 for key week actions 10, 11, 12, 13, and 15 in the b_errisu table. The amount overpaid cannot exceedthe amount paid coded in data element f13 in the b_master table.

9.Comment Period. BAM Annual Reports produced by the Department of Labor will be mailed to each State by May 12, 2000. Each State should carefully review its Annual Report and submit any comments to the National Office, with a copy to the appropriate Regional Office, by June 2, 2000, to:

Andrew Spisak
U. S. Department of Labor
ETA / Office of Workforce Security
200 Constitution Avenue, NW
Room S-4522
Washington, DC 20210

Alternatively, States may submit comments by e-mail to aspisak@doleta.gov via the Internet or tonight!andy via the State's Sun computer e-mail utility or by fax to Andrew Spisak at 202-219-8506. National and Regional Office staffs will discuss and reconcile issues raised in the States' comments by June 9, 2000.

10.Public Release by SESA. Although States are no longer required to release their annual BAM program data, States should provide the data to interested parties upon request. States will provide the name, address, phone number, and e-mail address of the person(s) designated by the State as its BAM Annual Report contact to the Department of Labor (attention of Andrew Spisak, at the above address), by June 9, 2000. The name of the individual(s) designated by the State as its BAM Annual Report contact will be published in the Federal Register notice announcing the availability of BAM data in the UI PERFORMS Annual Report. States must continue to follow the reporting requirements described in section 12, regardless of their decision to release their data to the public.

11.Key Dates. The following is a summary of key dates for the public release of CY 1999 BAM data. These dates are the latest that the task or action must be completed.

4/21	States submit requests for waivers of BAM time lapse requirements, along with supporting analysis, to the appropriate Department of Labor ETA Regional Administrator.
4/28	The Department of Labor Regional Offices respond to States on the disposition of State requests for waivers of BAM time lapse requirements
4/29	The Department of Labor electronically transmits the footnote lookup table for the BAM Annual Report software to each State's Sun computer.
4/29	Each State checks its UI database to: 1) ensure that the BAM supervisor has signed off all cases which the BAM investigators have completed, and 2) reopen any case in order to update information or correct any data errors.
	Cases closed by supervisors after April 29, 2000, will not be included in the Annual Report. States should not reopen any CY 1999 cases to change the database after April 29, 2000, until their Annual Report is finalized.
5/12	Grace A. Kilbane, Administrator, OWS, sends the BAM Annual Reports to the State Administrators.
6/2	States review BAM Annual Reports, including footnotes, and provide comments to the National Office (to the attention of Andrew Spisak, as discussed in section 9), with copies to ETA Regional Administrators.
6/9	National and Regional Offices discuss SESA comments with the States and reconcile any differences between the States' and Department of Labor's databases.
6/9	States electronically transmit optional narratives to the National Office (to the attention of Andrew Spisak, as discussed in section 5), with copies to the ETA Regional Administrators.
6/9	States provide the National Office (to the attention of Andrew Spisak, as discussed in section 10) the name, address, phone number, and e-mail address of BAM Annual Report contact person (or persons), with copies to the ETA Regional Administrators.
8/31	Department of Labor publishes notice in the Federal Register announcing the availability of BAM data as part of the UI PERFORMS Annual Report.

12.Action Required. State Administrators are requested to:

a.provide copies of these guidelines to the appropriate staff;

b.ensure that any request for a waiver of time lapse requirements are sent to the ETA Regional Administrators by c.o.b. April 21, 2000;

c.ensure that any comments on the CY 1999 Annual Report data that require reconciliation of differences between the State's and Department of Labor's databases are sent to the Department of Labor's National Office and copies are sent to ETA Regional Administrators by June 2, 2000; and

d.ensure that the following items are sent to the Department of Labor's National Office and copies are sent to ETA Regional Administrators by June 9, 2000:

(1)optional narrative addressing issues in the CY 1999 BAM data; States that decide not to submit a narrative do not need to notify the National Office that no narrative will be submitted; and

(2)the name, address, telephone number, and e-mail address of the contact person(s) to whom interested parties may write or call with questions or inquiries about the State's BAM program data.

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

14.Attachments. (1) BAM Annual Report format, footnotes, and definitions; and (2) BAM Annual Report Supplemental Data format.