DIRECTIVE	:	UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 08-87, Change 4
TO	:	STATE EMPLOYMENT SECURITY AGENCIES
FROM	:	GRACE A. KILBANE Administrator Office of Workforce Security
SUBJECT	:	Answers to Questions and Comments Raised Concerning the Unemployment Insurance Benefit Accuracy Measurement (BAM) Program.

1. Purpose. To transmit information to the State Employment Security Agencies (SESAs) concerning coding of Job Service registration for BAM investigations.

2. Reference. ET Handbook No. 395; UIPL No. 8-87.

3. Background. Since the beginning of the BAM program, staff have had difficulty coding findings relating to Job Service registration. Some States require claimants to register with the Job Service to establish Unemployment Insurance (UI) eligibility, but appear to lack a clear operational definition of what constitutes Job Service registration, and clear procedures to administer the requirement. For example, the automated system in some States may deactivate a registration without the claimant's knowledge. Confusion results if by custom the State does not view such de-registration as a disqualifying issue, and the BAM investigators code the week as an improper payment. Telephone and electronic claims filing methods have also affected registration requirements. Some States consider UI claimants registered with Job Service upon completion of the UI initial claim form by telephone or other remote means; others require in-person Job Service interviews to be considered registered. In many cases, the introduction of remote claims filing methods coincided with restructuring of the way in which SESAs provide employment services to the public, such as, access to electronic jobs data bases and self-help training resources. State law and policy in some instances may not have been revised to reflect these new environments.

   Use of remote claims filing methods and/or change in Job Service registration behavior requires additional guidance on coding Job Service registration. Inconsistent interpretations by the States of their own Job Service registration policies and procedures sometimes lead to improper coding of BAM cases. The attached questions and answers are intended to promote uniformity in this area.

4. BAM Program Policy Concerning Job Service Registration. State written law, policy, and procedures govern whether claimants are required to be registered with the Job Service and what constitutes registration. BAM coding should be consistent with such law, policy, and procedures.

5. Recoding of BAM Data Fields. States should consider re-coding the BAM data collection instrument (DCI) data fields on a case-by-case basis for calendar year 2000 forward, in accordance with the interpretation reflected in the attached Questions and Answers. Any re-coding may impact the key week action code (h1), the dollar amounts in fields (h2) through (h6), and the following error issue (ei) codes:

   ei-1 - dollar amount of key week error

   ei-2 - key week action

   ei-3 - error cause (code 460)

   ei-4 - Error responsibility

   ei-5 - QC/BAM detection point (code 60)

   States must coordinate re-coding efforts through the Regional Offices. Cases may be re-opened using the Federal monitoring review code 5, in order to avoid adversely affecting time lapse.

6. Action Required. 

   1. Administrators are requested to share the attached information with appropriate staff.

   2. Ensure BAM staff have current, accurate information on State law, policy and procedures relative to UI claimant Job Service registration requirements; and

   3. Consider re-coding data fields as provided in 5. above if warranted to ensure accuracy of data.

7. Inquiries. Direct questions to your Regional Office.

8. Attachment. Copy of questions and answers.