1.
Purpose. To provide State Workforce
Agencies (SWAs) with guidelines and key dates for the release of UI BAM paid
and denied claims data for CY 2003 and to inform the states that the Department
of Labor (DOL) will publish BAM program data in the CY 2003 UI Performs Annual
Report.
2.
References. 20 CFR 602; Unemployment
Insurance Program Letter (UIPL) No. 19-96; UIPL No. 19-03; and Benefit Accuracy
Measurement State Operations Handbook, ET Handbook
No. 395, 3rd ed.
3.
Background. DOL will publish a compendium
of all states' CY 2003 BAM paid and denied claims data as part of the UI Performs
Annual Report. UI Performs is DOL's performance measurement system for UI. Although
UIPL No. 19-96 announced the elimination of the requirement in 20 CFR 602.21(g)
that states release BAM program data publicly, states may choose to release
their BAM data to the public independent of the federal release.
4.
Federal
Release of UI Performs Data. The CY 2003 UI Performs Annual Report will include background
information on the BAM program, a brief discussion of how the accuracy rate
estimates are computed, national summary data, state paid claims annual reports,
and state Denied Claims Accuracy (DCA) rates for monetary, separation, and
nonseparation determinations. Although DOL no longer publishes BAM program
narratives submitted by SWAs as part of the UI Performs Annual Report, states
may provide explanatory information related to any UI program data published
in the UI Performs Annual Report through the State Quality Service Plan (SQSP)
process.
DOL will also publish a CY 2003 BAM analytical report
separate from the UI Performs Annual Report. This report will include:
-
additional
integrity measures for UI paid claims, including the fraud overpayment rate,
agency responsibility overpayment rate, and the BAM operational rate, which is
a component of the Government Performance and Results Act UI overpayment
detection measure;
-
data on the
cause, responsibility, and prior agency action for erroneous UI payments and
improper denials;
-
causes of the
largest increases and decreases in state UI overpayment rates from CY 2002 to
2003;
-
average amount
of error per overpayment error and per workload measure for overpayments
attributable to monetary, separation, and nonseparation issues; and
-
a list of
individuals designated by the states as points of contact for public inquiries
about BAM data.
Both the CY 2003 UI Performs Annual Report and the CY 2003
BAM analytical report will be posted on the Employment and Training
Administration (ETA) Web site: http://workforcesecurity.doleta.gov.
DOL will also announce the availability of these reports on the Web site.
If a state fails to follow the BAM methodology regarding
sample selection, data collection, or case completion timeliness prescribed in
ET Handbook No. 395 to such an extent that the data are not reliable, DOL will
publish an explanation of the major deficiencies in lieu of BAM program data
for that state. States must address these deficiencies through corrective
action plans as part of the SQSP process.
5.
BAM Date of
Record. Chapter
VI of ET Handbook No. 395 requires that "a minimum of 98 percent of cases for
the year must be completed within 120 days of the ending date of the Calendar
Year." Close of business (c.o.b.) April 29, the 120th day of CY 2004, is the
date of record for state databases for computation of the CY 2003 BAM paid
claims Annual Report and DCA rates. All BAM paid and denied claims accuracy
rates published in the UI Performs Annual Report and the BAM analytical report
will be based on CY 2003 BAM paid and denied claims cases that have been signed
off by the BAM program supervisor by c.o.b. April 29, 2004.
Changes to the state's database subsequent to the date of
record can result in inconsistencies with DOL's database that must be
reconciled before the BAM program data can be published. States must not
reopen any CY 2003 BAM cases after April 29, 2004, until they have reviewed the BAM
program data transmitted to them by DOL and have confirmed that these data
agree with the BAM paid and denied claims accuracy data produced by the state's
database. Procedures for resolving differences between DOL and state BAM
program data are discussed in section 8.
6.
BAM Annual
Report Software. States may run the BAM paid claims Annual Report software as soon as they
complete all CY 2003 BAM paid claims cases. The National Office will produce a
paid claims' Annual Report for each state, based on the CY 2003 BAM cases as of
c.o.b. April 29, 2004. The BAM Annual Report software
excludes cases that do not meet the definition of the BAM paid claims
population (for example, supplemental payments or payments made for Temporary
Extended Unemployment Compensation (TEUC) claims) and adjusts the amount of UI
benefits paid to the population to exclude the amounts paid that are
represented by these excluded cases. Prior to the date of record, DOL will
transmit a footnote lookup table for the CY 2003 BAM paid claims Annual Report.
The BAM DCA software on the state Sun
computer systems does not currently include programs that allow states to
produce DCA rates reports. DOL plans to install DCA error rates reports
software on the state Sun computers during CY 2004; however, these programs may
not be available by the April
29, 2004, date of
record. In CY 2003, the National Office distributed an Informix ACE report
program that produces DCA rates to all BAM
supervisors and state Sun system administrators. States are encouraged to use
this program to produce DCA rates and compare them with the rates DOL transmits
to them for comment prior to publication. States can verify DCA case
completion and timeliness with the DCA Case Completion and Timelapse Report,
which was installed on state Sun systems in CY 2003.
BAM DCA rates exclude sample cases that do not meet the
definition of the DCA population (for example, monetary redeterminations, nonmonetary
determinations that are not reportable on the ETA 207 and 9052 reports, and
denied TEUC claims). DCA rates also exclude two types of cases for which there
is no denial issue to investigate: 1) cases in which monetary eligibility was
established upon receipt of Combined Wage Claims, Unemployment Compensation for
Federal Employees, and/or Unemployment Compensation for Ex-service Members wage
credits within the two-week sampling lag (Action Code Flag “0”); and 2) claims
withdrawn by the claimant (Action Code Flag “8”). The software that the
National Office uses to produce the DCA rates adjusts the DCA populations to
exclude the determinations represented by these excluded cases.
7.
BAM Report
Formats, Definitions, and Footnotes. A facsimile of the BAM paid claims Annual Report, a
prototype DCA rates report, report definitions, and report footnotes were
published in Attachments 1, 2, and 3 of UIPL 19-03. States should refer to
these materials to prepare and evaluate their CY 2003 BAM reports, substituting
all references to CY 2002 dates and batches with the dates in this UIPL.
8.
Comment
Period. DOL will
mail BAM paid and denied claims accuracy rates to each state by May 7, 2004. Each state should carefully
review the paid claims Annual Report produced by DOL to verify that it agrees
with the Annual Report produced from the state's BAM database. States can
check the DCA data by running the Informix ACE DCA rates reports.
States should report any discrepancies or submit questions
concerning the BAM paid and denied claims data or footnotes to the National
Office, with a copy to the appropriate Regional Administrator, by May 28, 2004, to Andrew Spisak by e-mail (Spisak.Andrew@dol.gov), fax
(202-693-3975), or mail:
Andrew Spisak
U. S. Department of Labor
ETA / Office of Workforce Security
200 Constitution Avenue, NW
Room S-4522
Washington, DC 20210
National and Regional Office staff will address and
reconcile issues raised by the states by June 4, 2004.
9.
Key Dates. The following key dates for the
public release of CY 2003 BAM data are the latest that the task or
action must be completed.
4/16/04 States submit requests for waivers of BAM paid
and denied claims time lapse requirements, along with supporting analysis, to
the appropriate ETA Regional Administrator.
4/23/04 Regional Offices respond to states on the
disposition of state requests for waivers of BAM time lapse requirements.
4/29/04 The National Office electronically transmits
the footnote lookup table for the BAM paid claims Annual Report software to
each state's Sun computer.
4/29/04 Each state checks its
UI database to: 1) ensure that the BAM supervisor has signed off all BAM paid
and denied claims cases which the 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, 2004,
will not be included in the paid claims Annual Report or DCA rates.
States must not reopen any CY 2003 cases after April 29, 2004, until they have reviewed the BAM
program data transmitted by the National Office and verified the data against
their state database or reconciled any differences with DOL.
5/7/04 The National Office sends the CY 2003 BAM
program data to the state administrators.
5/28/04 States review BAM paid
and denied claims accuracy rate data and footnotes, and report any
discrepancies or submit questions concerning the BAM data or footnotes to the
National Office (to the attention of Andrew Spisak, as discussed in section 8),
with copies to the appropriate ETA Regional Administrator.
6/4/04 National and Regional Office staff address
issues raised by the states and reconcile any differences in state and DOL BAM
program data.
6/4/04 States provide the
National Office the name, address, telephone number, and e-mail address of the
contact person (or persons) for public inquiries concerning BAM paid and denied
claims data. This information should be sent to the attention of Andrew Spisak
at the address, e-mail address, or fax provided in section 8, with copies to
the appropriate ETA Regional Administrator.
8/27/04 DOL publishes the CY 2003 BAM data on the ETA Web site.
10.
Action. State Administrators
are requested to:
a.
provide copies
of these guidelines to the appropriate staff;
b.
send any
request for a waiver of time lapse requirements to the appropriate ETA Regional
Administrator by c.o.b. April
16, 2004;
c.
ensure that
any issues related to CY 2003 BAM paid or denied claims data or footnotes that
require reconciliation of differences between the state's and DOL's BAM program
data are sent to the National Office and that copies are sent to the
appropriate ETA Regional Administrator by May 28, 2004; and
d.
ensure that
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 are sent to the National Office and
copies are sent to the appropriate ETA Regional Administrator by June 4, 2004.
11. Inquiries. Questions
should be directed to the appropriate Regional Office.