U.S. DEPARTMENT OF LABOR
Employment and Training Administration
Washington, D. C. 20210
February 26, 1996
February 28, 1997
UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 10-96
ALL STATE EMPLOYMENT SECURITY AGENCIES
MARY ANN WYRSCH
Implementation of New Time Lapse and Quality Measures for Unemployment Insurance (UI) Benefits Operations
Purpose. To issue the new time lapse and quality measures for UI benefits operations to be implemented as a part of UI Performs as described in Unemployment Insurance Program Letter (UIPL) No. 41-95; to provide a schedule of actions that will occur during implementation of the new measures; and to convey a summary of the comments on the Performance Measurement Review (PMR) Interim Evaluation Report. (See Attachments.)
References. Federal Register Notice (FRN) Vol. 54, No. 12; FRN Vol. 57, No. 126; FRN Vol. 60, No. 11; UIPL No. 10-89; UIPL No. 13-91; UIPL No. 30-92; UIPL No. 13-95; and UIPL No. 41-95.
Background. Beginning in 1993, a team of senior State Employment Security Agency (SESA) managers and Unemployment Insurance Service (UIS) staff known as the Performance Enhancement Work Group (PEWG), developed the outlines of a comprehensive new closed-loop system to help ensure continuous improvement in UI operations performance. This new system, called UI Performs, is described in UIPL No. 41-95, issued August 21, 1995. The UI Performs design is now being refined in the light of responses to UIPL No. 41-95; the system will be phased in over 3-4 years as the various components are completed.
When complete and fully operational, UI Performs will comprise a renewed affirmation of long-standing principles for Federal-State cooperation; a redesigned process for operational planning and the execution of improvement activities; various mechanisms to ensure that performance in key areas at least exceeds certain minimum levels; and the redesign of many performance measurements plus the regular validation of key performance measures. The measures were selected to enable the UI system's success to be judged by how well it serves its ultimate customers - claimants and employers. Most of the data used to construct existing and new UI Performs measures are already in State databases; UI Performs should not appreciably increase measurement effort overall.
The measurement redesign aspect embraces the results of three initiatives which predated UI Performs: Revenue Quality Control (RQC), which developed new measures for tax performance to replace those previously gathered under the Quality Appraisal (QA) system; the PMR project, which updated the QA benefits time lapse and quality measures; and data validation. The team designing UI Performs also proposed substantial changes in the Benefits Quality Control (BQC) system for measuring benefit payment accuracy, including the assessment of the accuracy of decisions to deny eligibility.
This UIPL implements the new benefits time lapse and quality measures of UI Performs, which resulted from the PMR project.
PMR Project. The Department of Labor (DOL) initiated the PMR project in 1988 to examine, evaluate and improve performance measurement in UIS oversight of SESAs. (FRN Vol 54, No. 12; UIPL No. 10-89; and UIPL No. 13-91.) Eligible UI claimants are entitled to receive benefit payments in a timely manner. Claimants also have a right to expeditious consideration of eligibility issues and to fair hearings.
QA, the current performance measurement system for benefits time lapse and quality, as well as certain revenue and cash management measures, had not been subjected to in-depth review since its inception in the mid-1970s. Yet, changing technologies and increasing use of automated systems had transformed the delivery of UI services to the public. At the same time, DOL recognized a need to integrate QA with other components of its oversight system.
PMR was designed for completion in three phases. Phase I consisted of the analysis of existing benefits time lapse and quality measures to determine their legislative basis and to identify gaps or overlaps in measurement areas, the development of new or revised measures, and the design for a field test of selected measures.
With the involvement of State and Federal UI representatives, the project defined time lapse measures and quality measures covering benefit payments, nonmonetary determinations, lower authority appeals, and the Combined Wage Claim (CWC) program. Some of the measures added program categories and reporting intervals to existing reports; some of the measures looked at UI service areas which had not formerly been measured. (FRN Vol. 57, No. 126, which published UIPL No. 30-92 for the general public.)
In Phase II, six States successfully conducted a 15-month field test of reporting data for the proposed PMR measures from July 1993 through September 1994.
A report entitled "Interim Evaluation Report," dated December 5, 1994, contained an analysis of the field test data. It was distributed as an attachment to UIPL No. 13-95, which was published in the Federal Register as Vol. 60, No. 11. The report showed that the new benefits time lapse and quality measures and the software developed for analysis of results could yield meaningful and statistically valid information in a cost-effective manner, with the exception of the CWC quality measures.
This Interim Report showed that five of the six field test States were able to produce the data for the performance measures with little difficulty. This was the result of the fact that the measures were selected with the consideration that most of the required data points for the promptness measures would already be resident in the State claims files, and would require development of minimal new local office procedures. In some of the States the entire reporting change was accomplished in the data processing unit and was transparent to the rest of the agency. The field test State that experienced the most difficulty was in the midst of an automated system change and was not, during the field test period, able to produce nonmonetary time lapse data; it did produce data for the other measures. The nonmonetary promptness measure using detection date as a starting point was not field tested, but was included at the recommendation of the PEWG after completion of the field test. This measure will require some States to change procedures to add detection date to the claimant record.
States were invited to review and comment on the Interim Report. All the comments received regarding the measures were considered in the development of final implementation plans. Attachment B summarizes the comments to UIPL No. 13-95 and DOL responses to them.
The "Final Evaluation Report" has been completed and is available upon request from the National Office.
Phase III encompasses nationwide implementation of the new benefits time lapse and quality measures of UI Performs.
Changes in Benefit Measures. The new benefits time lapse and quality measures are described in Attachment A. In summary, the changes are:
• first payment time lapse will continue to be measured and reported monthly, but at additional intervals;
• time lapse measures for continued payments, partial payments for both first and continued payments, and workshare payments for both first and continued payments are new and will be measured monthly;
• the time lapse measure for nonmonetary determinations that is currently measured annually from sample data will be measured monthly from universe data;
• time lapse for implementing nonmonetary determinations is a new measurement and will be measured quarterly;
• the existing quarterly measurement of wage transfer, billing and reimbursement time lapse will remain the same, with expanded intervals;
• the existing monthly measurement of lower authority appeals time lapse will remain the same, with expanded intervals;
• time lapse associated with lower authority appeals case aging is new and will be measured monthly;
• time lapse for implementing appeals decisions is a new measure and will be measured quarterly;
• the existing monthly measurement of higher authority appeals time lapse will remain the same; and
• time lapse associated with higher authority appeals case aging is new and will be measured monthly.
• the quality measure of nonmonetary determinations that is currently measured and reported annually will be measured quarterly under UI Performs; the data source will be samples drawn from the nonmonetary determination time lapse universe; and
• the quality measure of lower authority appeals that is currently measured and reported annually will be measured quarterly; the data source will be samples drawn from the lower authority appeals time lapse universe.
The definitions for reporting requirements in ET Handbook No. 401 still apply, with the following exceptions. The population for the measurement of first payment time lapse has been changed to include partial and part-total payments. The definition of nonmonetary determinations has been changed and will result in the inclusion of formerly noncountable determinations. Whether or not a week is claimed, a nonmonetary determination must meet the following criteria to be valid:
(1) An issue was detected which had the potential to affect the claimant's past, present, or future benefit rights; and
(2) A determination of eligibility was made.
Attachment C lists the measures, their reporting frequency, and their data sources and whether they are new or exist in the current performance appraisal system.
Implementation. States should plan to submit their first time lapse reports under UI Performs for the month ending July 31, 1996, by August 20, 1996. These reports include all monthly time lapse reports and lower and higher authority appeals case aging reports.
The quarter ending September 30, 1996, will furnish the universes for the first quality samples for nonmonetary determinations and lower authority appeals. All quarterly quality review data should be data entered by November 20, 1996. The implementation time lapse reports will be calculated from dates recorded during the quality review process.
These instructions will be reissued in a slightly different format as a part of ET Handbook 401, UI Reports Handbook. Attachment A presents the reporting requirements in the format used since the end of the first phase of the project. States should begin necessary programming changes using these instructions and not wait for the changes to Handbook 401, since the reporting requirements will be the same.
Other issues associated with implementation which States should be aware of include:
QA. QA currently provides the annual results of State performance. UIS will publish a report on the current benefit measures for the last time based on results compiled in May 1996. After that date, the PMR-developed measures will replace the benefits time lapse and quality measures administered under QA. UIS will publish a report on State performance using available data reported under the new benefits measures in 1997. It is a goal of the UIS that reporting of results under the new measures will be combined with other results in a new comprehensive report. The relationship of this new report to corrective action planning is still under analysis in the UIS. Planning and reporting issues will be presented in greater detail in a later directive.
Tripartite Quality Reviews of Nonmonetary Determinations; Lower Authority Appeals Review. UIS will implement a tripartite review of nonmonetary determinations to reduce nonsampling error and to increase consistency among reviewers. SESA staff will review quarterly samples. If possible, the host State will be joined by a visiting State reviewer or a regional representative. The two reviewers will score each sample case independently. When two reviewers agree as to whether a case passes or fails, the case data can be entered into the database. When the two reviewers do not agree, a third reviewer will score the case and make the final ruling. The host State will have another State in the Region participate with reviews, with Regional Office staff also participating, whenever possible. However, during some quarters, a State may accomplish its review exclusively with its own staff or with the help of another State reviewing records sent by mail. Regional Office staff will participate at least one quarter annually.
For lower authority appeals, SESA staff will review quarterly samples and enter the case data into the database. To reduce nonsampling error, annually, the National Office will invite SESA staff to participate in reviews as is currently done for QA.
UIS will provide new handbooks for nonmonetary determinations quality review and lower authority appeals quality review in July 1996 and will hold training sessions in August and September 1996.
Performance Measurement Tiers. Attachment A lists the new benefits time lapse and quality measures with designations as Tier I or Tier II. These designations are recommended under UI Performs and are described in UIPL No. 41-95.
Data collection under the new measures may reveal a need for revisions to current national performance standards, but review of national performance standards can begin only after States begin to report data under the new measures. When sufficient data are available for performance analysis, UIS will ask State program administrators to contribute to discussions regarding benchmarking.
In the interim, the existing Secretary's Standards relating to first payment and lower authority appeals time lapse used in conjunction with the analysis of QA results, will continue to apply. In addition, for Tier I measures, because the new measures are substantially the same as the QA measures, the existing Desired Levels of Achievement (DLAs) that apply to current measures under QA will continue in the interim. However, because of the increased statistical rigor and more inclusive universes used in reporting nonmonetary determinations time lapse and quality measures, performance in those areas may differ significantly from prior performance in some States, and during the interim reporting period, UIS will make allowances in the analysis of results.
Tier II measures, while important indicators of program performance, will not be benchmarked with national performance standards.
Schedule of Actions. The following events are expected to occur during implementation of the new benefits time lapse and quality measures.
|July 1996||New handbooks issued for nonmonetary determinations and lower authority appeals quality review.|
|July 1, 1996||States begin data collection for the new measures.|
|Aug 20, 1996||Data for all monthly reports to be entered into the electronic reporting system.|
|Aug-Sept 1996||Training sessions in quality review of nonmonetary determinations and in quality review for lower authority appeals.|
|Sept 30, 1996||End of first quarter to be sampled for nonmonetary determinations and lower authority appeals quality. As soon as possible after Oct 1, draw the samples for quality review.|
|Oct 15, 1996||Deadline for entry of "skeleton fields" for nonmonetary determination and lower authority appeals quality samples, so that edits can be run to check the validity of the samples.|
|Nov 20, 1996||Deadline for quality evaluation data for the sampled nonmonetary determinations and lower authority appeals to be entered into UIDB. Hereafter, quality data will be due the 20th day of the second month following the end of each quarter.|
OMB Approval. These reporting requirements are approved by the Office of Management and Budget according to the Paperwork Reduction Act of 1980. OMB Approval No. 1205-0359, Expiration Date: September 30, 1998.
Action Required. SESA Administrators are requested to:
Provide copies of this UIPL and Attachments to appropriate staff.
Implement the necessary changes in State automated systems to report as required by the schedule above.
Direct any questions to the appropriate Regional Office.
Attachment A - "UI PERFORMS: Time Lapse and Quality Measures for Unemployment Insurance Benefits Operations"
Attachment B - Comments on Performance Measurement Review Interim Evaluation Report
Attachment C - Table: Unemployment Insurance Performance Measures