DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 03-01
TO	:	ALL STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	GRACE A. KILBANE Administrator Office of Workforce Security
SUBJECT	:	Unemployment Insurance Data Validation (UIDV) Program Update and Implementation Plans

1. Purpose. To give the status of UIDV implementation, announce the current planning target date for beginning implementation, invite States to participate in UIDV, and provide instructions for performing validation activities.

2. Background. In March 1999, ETA Regional Offices and SESAs received the Final Evaluation Report for A Pilot Study of Data Validation Techniques for Unemployment Insurance. In brief, the pilot test showed that States could implement the system with reasonable effort when key ADP and program staff cooperate, and that the validation system worked as designed to discover reporting errors and validate data. While implementation on average required the commitment of approximately two staff years, the maintenance of the system after implementation was estimated to be much smaller, about 0.8 staff years for tax and benefits combined. It is thought that experience and further automation can reduce both the implementation and continuing staffing requirements.

   Since May 1999, SESAs and Regions have operated validation activities with the understanding that the replacement of Workload Validation (WV) by the UIDV system would be delayed to enable States to concentrate scarce programming resources on ensuring that UI systems were Year 2000-compliant. States were to continue to perform WV according to the existing WV cycle. If they preferred, they could instead implement the UIDV system using the draft UIDV handbooks. The new WV/UIDV contractor, Sparhawk Group, Inc., would provide technical assistance with either WV operations or UIDV implementation as needed. Authorization to require operation of the WV system will expire on December 31, 2000.

3. Workload Validation and Data Validation Compared.. Both validation systems are based on the same underlying validation concepts. That is, they intend for States to:

   1. Independently reconstruct the reported counts to assess whether their report-generating routines are counting accurately, and

   2. Evaluate samples of the underlying items to assess whether they are counting what the Federal reports intend to be counted.

   WV and UIDV differ radically in how they look at the UI data in the validation process. Workload Validation makes the individual report element--the building blocks of the workload measures--the focus of validation. (To validate its 10 workload measures, WV validates 29 elements on four reports.) The Data Validation methodology goes below the report element level to the more basic concept of a transaction (or, in the case of tax and other report elements, dollars or entities on hand). Transactions are the building blocks of report elements. UIDV sees the universe of UI report elements on 47 UI reports as various combinations of a much smaller number of basic, mutually exclusive transactions such as various categories of initial claims, first payments, and nonmonetary determinations. By validating the underlying transactions and checking how they are combined, UIDV efficiently reviews a much larger number of report elements. Three major differences between WV and UIDV are as follows:

   Dimension	Workload Validation	Data Validation
   Scope	Validates 29 data elements on four reports	Designed to validate just under one half the elements on the 47 UI required reports
   Handbook Concept	One generic WV handbook. States interpret and apply its requirements to their specific situations. Result: interpretations can vary	53 State-specific benefits and 53 tax Handbooks, containing specific programming guidelines and validation steps based on the State's own management information system
   Degree of Automation	Contains many manual operations	Very highly automated with automated test routines and built-in spreadsheets

4. Implementation Steps for the Mandatory Program. Within the next two months, ETA will begin the paperwork clearance process by issuing a preclearance notice with a 60-day comment period. This will signal the Department's intent to seek the Office of Management and Budget's authorization under the Paperwork Reduction Act of 1995 to collect validation information under the UIDV program. The preclearance notice will be followed by the formal paperwork clearance package.

   Upon receiving OMB's approval-expected about April 1, 2001--training sessions on the new system will begin during April-May 2001.

   We envision that transition to UIDV will take approximately 18 months, during which time the Department will request authorization to require some States to continue to use the old WV program. States ready to begin implementing UIDV in calendar year 2001 will use it as their validation system and be waived from any WV requirements. States which will not be ready to begin implementing UIDV before January 2002 and which need to validate certain workload data will use WV to validate those data until they begin implementing UIDV. To prepare for implementation, the Department is developing simpler software for updating the handbooks and will work to obtain updated State database references, so that the handbooks distributed by Spring 2001 are current.

   Some additional States may wish to implement UIDV earlier. This is strongly encouraged. It will provide the Department with additional information on how best to prepare and support States for implementation. Early implementing States will receive more individualized preparation as well as an early start and a waiver from WV. The Department will arrange implementation training and technical assistance for early implementers through its support contract with Sparhawk Group. We will also need information early in calendar year 2001 on States' readiness to implement UIDV as input for a training and implementation schedule. States should also designate a UIDV Coordinator, and provide the designee's name, telephone number and e-mail address to the Regional UIDV Coordinator.

5. Interim Steps To Promote Data Validity. The increased emphasis on performance accountability (e.g., UI PERFORMS, Government Performance and Results Act, Chief Financial Officers Act, Workforce Investment Act) and the expected revisions in the methodology used to formulate and allocate UI administrative resources continue to elevate the importance of data validity. Thus, during the transition to UIDV, it is important that States pay the greatest possible attention to data quality and steps that can be taken to improve it. These include:

   1. Regularly reviewing reports data, noting possible misreported elements, and taking appropriate corrective action;

   2. If not already done, completing scheduled FY 2000 WV activities and reporting results by December 31, 2000;

   3. Seeking the assistance of Sparhawk Group with technical questions on WV activities in progress. Sparhawk may be contacted by e-mail at DV@SparhawkGroup.com and;

   4. Communicating any interest in early implementation of UIDV to the appropriate Regional staff as the first step to arranging the necessary training and technical assistance for starting the implementation process.

6. Action Required. SESA Administrators are requested to:

   1. Distribute this directive to appropriate staff ;

   2. Communicate interest in early implementation and submit the name, phone number and e-mail address of the UI Data Validation Coordinator to the appropriate Regional Office;

   3. If required to conduct WV in FY 2000, complete validations and report results to the appropriate Regional Office by December 31; and

   4. Ensure that staff take appropriate steps to ensure data validity (outlined in item 5 above) to prepare for UIDV implementation.

7. Inquiries. Please refer any questions to the appropriate Regional Office.