Section B

Recovery Program

Overview

Introduction Information in this section is provided to assist SESAs with recovery planning. SESAs are encouraged to develop goals and performance measures as recovery programs are enhanced to meet the needs of today's business environment.
Definition of term An aggressive, proactive approach to recovery is defined as actions taken by the SESA to recover overpaid UI benefits.
In this section The following topics will be discussed in this section.
Topic Page
Introduction 2
Organizational Structure 4
Statutory Authority 5
Statute of Limitations 6
Fraud Penalties 8
Cost of Recovery 10
Data Gathering 11
Waiver 15
Write-Off 16
Collection Cycle 19
Recovery Processes and Tools 22
Skip-Tracing 26
Summary of Guidelines 28
Introduction
Introduction In the past, recovery programs were often developed around a specific method, such as civil action, prosecution, and benefit offset. To be competitive with private industry today, a SESA must:

  • Have access to a wide range of methods that are not unnecessarily limited or restricted in usage.

    • Develop and implement an aggressive, proactive approach to recovery.

      • Use technology to their advantage by automating labor intensive manual processes.

Components of a recovery program No single method, tool, technique, or automated system can ensure the recovery of all overpaid UI benefits. To be effective, the following components are essential:

  • Statutes that provide access to a full range of recovery methods, tools, and techniques.

    • Adequate funding to support an aggressive, proactive approach to recovery.

      • Collection strategies balanced between proactive and passive recovery methods.

        • Training to build skills in customer service and collection techniques.

          • Automation of collection activities.

            • Data to measure program and performance effectiveness.

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Time is critical to recovery Labor intensive or cumbersome procedures and processes can delay initiating aggressive recovery activities. Time is a critical factor in the recovery of overpaid benefits. Studies have found that the potential for recovering debts is:

  • 75 percent for debts outstanding for 90 days.

    • 58 percent for debts outstanding for 180 days.

      • 10 percent or less for debts over one year old.

        Delays in the recovery process can increase the potential need to find debtors who may have relocated.

Administrative support Administrative support sets the tone for an effective recovery program. If the administration does not provide adequate support, the importance of recovery can fade into the background and recovery efforts are reduced to maintenance activities. An aggressive, proactive recovery program should be supported by:

  • Recognizing the importance of an effective recovery program.

    • Establishing a high priority for benefit recovery.

      • Ensuring adequate resources are available.

Recovery planning Statutes to support the recovery of overpaid UI benefits vary extensively from state to state. Some SESAs have found the fifty-five percent desired level of achievement to be nearly impossible to attain. Recovery planning can benefit collection organizations by identifying:

  • A baseline collection goal.

    • Performance measures.

      • Deficiencies in collection statues that require legislative changes.

        • Appropriate staffing level needed to reach the baseline collection goal.

Organizational Structure
Introduction Organizational structure and the entity responsible for recovery of overpaid benefits vary among the SESAs. Recovery activities can be:

  • Centralized, decentralized, or partially centralized.

    • Within or outside BPC organizations.

      • Integrated with or separated from employer tax collections.

Potential for impact on recovery Based on organizational structure and available resources, collection staff could be required to process workload other than overpayment recovery.
If overpayment recovery is... the collector is often responsible for one or more of the following:
assigned to BPC organizations à detection,

  • fact-finding,

    • overpayment establishment,

      • prosecution, and/or

        • overpayment recovery.

combined with tax collections à tax collections and/or

  • overpayment recovery.

partially centralized and partially decentralized à fact-finding,

  • prosecution, and/or

    • overpayment recovery.

No specific guidelines While no specific guidelines are recommended, SESAs should ensure that recovery is not impacted by the diversion of collection staff to other BPC activities. It is important to provide opportunities for aggressive, proactive recovery activities.

Statutory Authority
Introduction Some SESAs have statutes that hinder the recovery of overpaid benefits. Statutes that unnecessarily limit or restrict use of recovery methods can prevent a SESA from meeting or exceeding the desired level of achievement for overpayment recovery.
Examples of statutes This table provides examples of statutes that can impact an efficient and/or successful recovery program.
Statutes can... Examples
hinder recovery. à Limit offset of state tax refunds to a narrow window period or to only fraud overpayments.

  • Require prosecution prior to taking action.

create labor intensive processes. à Provide authority to offset state tax refunds yet create a prolonged, duplicative verification process prior to completing the transaction.

  • Require SESA representation at court proceedings during the civil action process.

restrict use of methods. à Restrict civil action to only fraud overpayments.

  • Limit recovery to offset of UI benefits, state tax refunds, lottery winnings, and/or other offset programs.

    • Limit offset of state tax refunds to the year the overpayment is scheduled for write-off or to only fraud overpayments.

Guideline It is recommended that SESAs pursue legislation that does not unnecessarily limit or restrict recovery efforts used to recover overpaid UI benefits.

Statute of Limitations
Introduction Recovery periods among the SESAs range from two years to unlimited. The responsibility of an individual to repay overpaid benefits should be limited to a reasonable period of time. Currently, the statutes of limitation for recovery vary from state to state, depending upon the type of overpayment, fraud or non-fraud, and the recovery method.
Suggested statute of limitations for recovery There is evidence to support a conclusion that recovery potential decreases significantly as time passes. The suggested statute of limitations for recovery should be:

  • three years to pursue active recovery and

    • an additional two to seven years to pursue recovery through passive methods, such as offsets or outsourcing to private collection agencies.

Active recovery period During the three-year recovery period, in addition to offsetting UI benefits and/or state tax refunds, debts should be aggressively pursued to attempt recovery by:

  • Personally contacting the debtor.

    • Taking civil action to effect recovery through levies, liens, and wage garnishments.

      • Outsourcing the debt to a private collection agency when it is considered not cost-effective for SESA staff to pursue.

Note: Variances in statutory authority may limit the SESA's ability to pursue recovery through the use of these methods.

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Passive recovery period Debts should be retained for an additional two to seven years to pursue recovery through passive methods that include:

  • Offset of state tax refunds.

    • Offset of UI benefits.

      • Other offset programs.

Note: More aggressive recovery activities should be considered during this time period if the potential for recovery improves.
Guidelines It is recommended that SESAs pursue legislation that:

  • Supports a recovery period between a minimum of three years and a maximum of ten years.

    • Does not unnecessarily restrict or limit the use of a particular method during the recovery period.

Fraud Penalties
Introduction All SESAs have statutes that assess penalties when fraud is involved in the overpayment of UI benefits. These penalties can be limited to administrative penalties only or a combination of administrative and monetary penalties.
Administrative penalty All SESAs assess administrative penalties (1) when fraud is involved in the overpayment of UI benefits. This penalty can be:

  • Disqualification for a specific number of weeks.

    Example: Claimant is eligible to receive benefits and continues to certify; however, benefits are not paid for disqualification weeks.

    • Disqualification for a period of time, e.g., cancellation of claim.

      • Reduction in claim benefits.

Note: Some statutes provide for the assessment of stiffer penalties for repeat offenders.
Monetary penalties Some SESAs also assess a monetary penalty that ranges from 10 percent to 300 percent of the overpaid amount.

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Penalty Versus No Penalty This chart compares 1995 fraud overpayment establishment and recovery dollars, as a percentage of benefits paid, between SESAs that do and do not assess a penalty. (2)
Analysis: It appears that more emphasis is placed on detecting, establishing, and recovering fraud overpayments when a penalty is assessed.
Guidelines It is recommended that SESAs:

  • Study the administrative penalty process to determine effectiveness and/or impact on the recovery of overpaid benefits.

    • Consider legislation to support a progressive monetary penalty when fraudulent activities result in an overpayment of benefits, e.g., 50 percent for first occurrence, 75 percent for second, 100 percent for third.

Cost of Recovery
Introduction A proactive approach to recovery can be enhanced by:

  • Funding to support aggressive collection activities.

    • Alternatives for developing win-win solutions.

Costs transferred to the debtor Private sector entities commonly shift the cost of recovery to the debtor through fees, such as late payment or collection fees. This practice could enhance recovery programs by:

  • Providing the collector with negotiation tools to support win-win solutions.

    • Encouraging debtor compliance with agreements.

      • Providing an additional source of funding to support the recovery process.

Practices common to collection organizations Practices common to collection organizations in both the private and public sector are:

  • Charging interest on unpaid balances.

    • Adding the cost of recovery to unpaid balances after a specific period of time.

      • Assessing a fee to establish a monthly installment payment plan and/or to re-establish a payment plan when the debtor defaults.

        • Charging a fee when payments are untimely.

Interest used as a negotiating tool Recovery of interest can add to the SESA's workload; however, some SESAs have the authority to use interest as a negotiating tool. Interest is not applied if:

  • Payment in full is received within six months.

    • Debtors establish a repayment plan and make all payments timely.

Guideline It is recommended that SESAs pursue the enactment of statutes that support shifting the cost of recovery to the debtor.

Data Gathering
Introduction Data is needed to make effective management decisions, measure program effectiveness, and identify opportunities for improvement.
Measuring effectiveness To measure the effectiveness of a recovery program, specific data is needed, such as:

  • How much does it cost to recover one dollar?

    • How many dollars were recovered as a result of a specific activity?

Example: 1976 Study on Cost Effectiveness:

According to the 1978 Resource Handbook on Overpayment Recovery, New Jersey compiled detailed data on the cost effectiveness of its recovery operations. In fiscal year 1977, its personnel cost for BPC positions was $2.05 million, or an average of $13,254 for each of their 154 positions. Recoveries for all programs during the same period totaled $5.5 million. Thus, for every dollar in administrative costs, New Jersey recovered $2.68. (3)

In late 1976, New Jersey established a small but identifiable section to concentrate on cash recoveries where normal efforts had been unsuccessful. Detailed figures were maintained to compare the cost of operating the section to recoveries attributable solely to the efforts of collection staff assigned to the section. It was found that dollars recovered per dollar of cost was:

1976 1977 1978
$3.63 $15.98 $17.48

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Data is needed to answer questions Study or statistical information is needed to support improvements to overpayment recovery. Although some SESAs have recognized the need for data, they are still in the process of developing data requirements.

Data is needed to answer questions such as:

  • What is the most effective method to use?

    • What does it cost to recover one dollar of overpaid benefits?

      • At what point does it cease to be productive to continue collection activities?

        • How long should billing statements be sent when the debtor fails to respond?

          • Are there patterns that identify more productive opportunities for recovery? (Example: After a period of weeks, months, or years, an increase in recovery potential is noted due to changing circumstances for the debtor.)

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Allocate data back to establishment time period When data is allocated back to the time period in which the overpayment was established, the information can be used to identify:

  • The most productive and cost-effective methods.

    • Weaknesses in recovery programs.

      For any given year, it is important for SESA management to know dollar amounts and/or percentage of establishment that were:

      • Written off as uncollectible,

        • Transferred to Allowance for Doubtful Accounts, or

          • Recovered as a result of:

            • Voluntary restitution, i.e., dollars received in response to a collection document prior to collector action.

              • Collector action, i.e., dollars recovered due to personal contact or other collector initiated activity.

                • Passive recovery methods, i.e., dollars recovered via offset programs.

Focus on outputs rather than inputs Performance measurements can be an effective management tool when focus is on outputs rather than inputs. An example of an output would be dollars recovered as a result of outgoing telephone calls, while an input would be the number of telephone calls placed.

The rules for developing and applying this technique are:

  • Measure only what you can control, e.g., dollars recovered as a result of the collector's action.

    • Compare your results to the best in the industry, public or private sector.

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Measuring program effectiveness It is suggested that SESAs:

  • Capture statistical data on the cost of their recovery programs.

    • Allocate dollars recovered, written off, or transferred to Allowance for Doubtful Accounts back to the period in which the overpayment was established.

      • Measure program effectiveness by dollars recovered as a direct result of collector action.

        • Use data to focus recovery activities on more productive, cost-effective methods.

          • Periodically compare dollars recovered to cost of recovery.

Waiver
Introduction Ideally, granting a waiver, when justified, should have little or no effect on the total amount recovered over a period of time. Although a number of SESAs have recognized that overpayments should be waived under specified conditions; other SESAs have no such provision. When waiver is denied, the SESA is required to provide appeal rights.
Typical statute provisions The typical statute provides that an overpayment will be waived only if:

  • The overpayment was not due to fraud, misrepresentation or willful non-disclosure by the claimant,

    • The overpayment was received without fault by the claimant, and

      • Recovery of the overpayment would be against equity and good conscience.

Advantages of waiver provisions A waiver provision:

  • Relieves the claimant of the obligation to repay an overpayment, in specified situations, where recovery would impose an extraordinary hardship on the claimant.

    • Permits the SESA to direct its resources and efforts to recovering other overpayments where it appears clear the claimant has both a legal and moral obligation to repay.

Guidelines It is recommended that SESAs:

  • Request legislation, if state law does not already provide for waiver, to waive repayment under specific circumstances.

    • Develop written guidelines to ensure that the waiver provision is administered equitably.

      • Periodically evaluate the number and amounts of waived overpayments to measure the effectiveness of the agency's prevention methods and techniques.

Write-Off
Introduction Based on statutory authority and criteria established by individual SESAs, some overpayments are determined to be uncollectible due to:

  • Statute of limitations for recovery.

    • Write-off criteria.

      • Waiver of repayment.

1997 ETA 227 statistics This table contains ETA 227 (4) statistical data for calendar year 1997. (Dollars shown in millions.)
Category Fraud Non-fraud Total
Cash Recovery $93.1 $73.6 $166.7
Offset Recovery $33.9 $74.1 $108.0
Write-Off $36.8 $81.4 $118.2
Waived -0- $19.5 $19.5
Allowance for Doubtful Accounts (5) $1,010.1 $1,363.1 $2,373.2
Collectible $629.6 $456.6 $1,086.2
Analysis: Although there is not a correlation between the year of establishment and dollars recovered or written off, these statistics appear to indicate:

  • A reliance on recovery through offset for non-fraud overpayments.

    • Debts determined uncollectible are retained in the Allowance for Doubtful accounts indefinitely.

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Know when to quit Knowing when to quit is an important facet of a successful recovery program. Recovery efforts cost money. As soon as an account is identified as uncollectible, recovery activities should be discontinued.
Benefits to writing off uncollectible overpayments Prolonged retention of uncollectible overpayments may reduce effectiveness of recovery programs by focusing collection activities away from more collectible debts. The benefits to writing off or removing uncollectible cases from active files are:

  • Reduction in administrative costs.

    • Concentration of efforts on collectible overpayments.

Factors to consider for write-off SESAs are encouraged to develop write-off criteria that will remove uncollectible debts from accounts receivable. Factors to consider include:

  • Claimant deceased.

    • Bankruptcy.

      • Lengthy incarceration.

        • Permanent and total disability.

          • Cost effectiveness of recovery.

            • Payment activity.

Benefits of periodic reviews It is suggested that SESAs periodically review debts written off. Although no official standard has been established, in the private sector, a write-off of bad debt exceeding 15 percent denotes a danger point. Periodic reviews provide an opportunity to:

  • Identify process improvements that will ensure collection activities are conducted timely and in accordance with SESA policies.

    • Evaluate the effectiveness of SESA recovery programs.

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Guidelines It is recommended that SESAs:

  • Pursue legislation to support writing off overpayments when identified as uncollectible.

    • Periodically review overpayments written off to measure the effectiveness of the agency's recovery program.

      • Periodically review debts transferred to the Allowance for Doubtful Accounts to ensure uncollectible debt is not retained indefinitely.

Collection Cycle
Introduction The longer an overpayment remains uncollected, the more difficult it becomes to recover the money. Collection activities should intensify throughout the collection cycle.
Step 1 Since every contact with the debtor is an opportunity to recover the debt, the first recovery attempt can be when the fact-finding process is initiated or concluded. Recovery efforts can consist of:

  • A simple statement, such as "Please do not send cash through the mail," on the predetermination notice to advise that payment is anticipated. Another example is a statement that advises claimants that an overpayment may be established and they should be prepared to repay the overpaid benefits.

    • A request for payment in full when the fact-finding interview is concluded.

Note: Variances in statutory authority may limit the SESA's ability to pursue recovery prior to the establishment of the overpayment.
Step 2 In addition to providing specific information about the reason for the overpayment and the right to appeal the decision, the overpayment notice should provide:

  • Clear, concise information about how to repay the debt.

    • The date when payment is anticipated.

      • A monthly repayment amount and repayment agreement to be completed and returned by the debtor if the debt cannot be paid in full within 30 days.

        • A payment coupon/stub and return envelope.

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Step 3 Voluntary and involuntary collection activities should be initiated as soon as allowed by statute. These activities include:

  • Mailing a demand for payment letter to all debtors who have not paid the debt in full or made repayment arrangements.

    • Initiating the processes that provide for recovery through offset programs such as UI benefits and state tax refunds. Offset recovery activities should continue until the overpayment is paid in full, the debt is written off as uncollectible, or the statute of limitations has expired.

Step 4 Debts should be prioritized by an automated collectibility profiling process. (6)
Step 5 Debts should be referred for collector action based on established criteria, e.g., when debtors do not respond to the demand letter within ten days, personal contact should be made to request payment.
Step 6 The collectibility of the debt should be evaluated to determine the next action. Some of the options available to the collector are:

  • Suspend collector activities for a specific period of time for re-evaluation or follow-up.

    • Route for skip-tracing.

      • Initiate legal remedies, such as civil action or prosecution.

        • Refer the debt to a private collection agency.

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Step 7 When all recovery efforts are exhausted, the debt should be reviewed to determine potential for:

  • Transfer to the Allowance for Doubtful Accounts.

    • Write-off as uncollectible.

Guidelines It is recommended that SESAs:

  • Initiate aggressive recovery activities as soon as allowed by statute.

    • Develop procedures to ensure collection activities intensify throughout the collection cycle.

      • Periodically review and evaluate the collection cycle to ensure debtors are not avoiding repayment by delaying the collection process.

        • Strive for win-win solutions that result in the collection of the debt in a timely manner while maintaining the goodwill of the debtor.

          • Establish clearly defined parameters for collection attempts.

Recovery Processes and Tools
Introduction Processes and tools commonly used in the private sector can enhance SESA recovery programs. They are a critical component of an effective recovery program. Options available for SESA consideration in developing win-win solutions include the authority to:

  • Assess and/or waive repayment of certain types of fees.

    • Report default or delinquent debts to credit reporting bureaus.

      • Negotiate the repayment amount with the debtor, i.e., offer in compromise.

        • Accept payment in a variety of different ways, i.e., credit cards, debit cards, electronic funds transfers, or check-by-telephone.

Examples of negotiable fees Examples of negotiable fees include:

  • Interest.

    • Late payment.

      • Establishment of an installment payment plan.

        • Re-establishment of a payment plan when the debtor defaults on the original agreement.

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Credit bureau reporting State statutes govern the release of information to credit bureaus. Reporting delinquent and/or untimely installment payments to credit reporting bureaus is a practice common to the private sector. If debtors are aware that failure to repay debts or abide by repayment agreements can and will affect their credit rating, recovery methods could be more effective. SESAs may want to consider broadening their statutes to provide for the use of this recovery tool.
Note: In some instances, a lien on real and/or personal property may be just as effective as credit bureau reporting. Additional research may be needed to determine the impact of continually updating credit bureau records.
Offer in compromise Since the overall goal of any collection program is to recover the dollars as quickly as possible, there is a definite place for an offer in compromise process in any collection strategy. When recovery could take years, it may be more cost effective for the SESA to accept a lower repayment amount based upon a lump sum settlement within a specific number of days.

An offer in compromise process requires the development of stringent criteria and must be closely monitored by management. The offer in compromise should include an option for the amount conditionally forgiven to become due and payable should the debtor be overpaid benefits again within a specific period of time.

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Check information by telephone Off-the-shelf software is currently available to provide capability for accepting check information by telephone. The information is entered on an automated system that can print the check at a bank designated by the agency. The check is then deposited into the agency's account the same day. This technology eliminates the "check's in the mail" response to requests for payment.
Credit and/or debit cards Although accepting credit card payments can reduce dollars recovered by the amount of the vendor fee, the SESA should have the capability to accept credit card payments. While transferring debt to credit cards is not suggested, this provides another repayment option for the debtor.
Electronic funds transfer Many businesses are encouraging customers and debtors to select the option of making payments through an electronic funds transfer process. Potential benefits to SESAs include:

  • Timely follow-up on delinquent payments.

    • Reduction in resources expended to monitor the status of installment accounts.

      • Reduction in processing time for handling incoming mail.

        • Additional revenue from interest on deposits for the period of time the payment was previously in the mail.

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Guidelines It is recommended that SESAs:

  • Pursue legislation to:

    • Report delinquent and/or untimely installment payments to credit reporting bureaus.

      • Support the assessment and/or waiver of repayment of fees that can be used to develop win-win solutions.

        • Develop an offer in compromise process.

          • Accept repayment of overpaid UI benefits via credit cards, debit cards and/or electronic funds transfers.

            • Explore feasibility of purchasing software that provides for taking check information by telephone.

Skip-Tracing
Introduction Skip-tracing is the process of attempting to locate someone. When a debtor skips, he or she generally moves without leaving a forwarding address. The need to locate debtors who have moved from their last known address can delay the recovery process until the debtor is located.
Common skip-tracing sources Skip-tracing sources common to most SESAs are:

  • SESAs database.

    • Claimnet locator.

      • Employment history.

        • Utility companies.

          • Other state and federal public agencies, such as the United States Postal Service or state taxing and debt collection agencies.

            • Law enforcement organizations.

              • Telephone and/or CD ROM directories.

                • Credit bureaus.

                  • New hire data.

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Another tool for skip-tracing With the advent of the Internet, more and more information is becoming readily available. The Internet is a tremendous resource, with virtually unlimited potential. While some skip-tracing capability is available free of charge, access to the largest and most up-to-date national databases are available for a fee. Examples of the types of information available are:

  • Addresses.

    • Telephone numbers.

      • Names and telephone numbers of neighbors.

        • Bankruptcy.

          • Property searches that provide information on owners, sale dates, sale amounts, etc.

            • Reverse telephone directories.

              • Motor vehicle and drivers license information.

                • Informal networking.

Guidelines It is recommended that SESAs:

  • Consider feasibility of using the Internet as another skip-tracing tool.

    • Periodically evaluate recovery of skip-tracing cases to determine cost-effectiveness and impact on resources available to pursue recovery of overpaid benefits.

      • Consider outsourcing recovery to private collection agencies when debtors have moved to another state.

Summary of Guidelines
Introduction Recovery program guidelines are provided for SESA consideration to enhance the recovery of overpaid UI benefits.
Organizational structure While no specific guidelines are recommended, SESAs should ensure that recovery is not impacted by the diversion of collection staff to other BPC activities. It is important to provide opportunities for aggressive, proactive recovery activities.
Statutory authority It is recommended that SESAs pursue legislation that does not unnecessarily limit or restrict recovery efforts used to recover overpaid UI benefits.
Statute of limitations It is recommended that SESAs pursue legislation that:

  • Supports a recovery period between three and ten years.

    • Does not unnecessarily restrict or limit the use of a particular method during the recovery period.

Fraud penalties It is recommended that SESAs:

  • Study the administrative penalty process to determine effectiveness and/or impact on the recovery of overpaid benefits.

    • Consider legislation to support a progressive monetary penalty when fraudulent activities result in an overpayment of benefits, e.g., 50 percent for first occurrence, 75 percent for second, 100 percent for third.

Cost of recovery It is recommended that SESAs pursue the enactment of statutes that support shifting the cost of recovery to the debtor.

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Summary of Guidelines continued
Waiver It is recommended that SESAs:

  • Request legislation, if state law does not already provide for waiver, to waive repayment under specific circumstances.

    • Develop written guidelines to ensure that the waiver provision is administered equitably.

      • Periodically evaluate the number and amounts of waived overpayments to measure the effectiveness of the agency's prevention methods and techniques.

Write-Off It is recommended that SESAs:

  • Pursue legislation to support writing off overpayments when identified as uncollectible.

    • Periodically review overpayments written off to measure the effectiveness of the agency's recovery program.

      • Periodically review debts transferred to the Allowance for Doubtful Accounts to ensure uncollectible debt is not retained indefinitely.

Collection cycle It is recommended that SESAs:

  • Initiate aggressive recovery activities as soon as allowed by statute.

    • Develop procedures to ensure collection activities intensify throughout the collection cycle.

      • Periodically review and evaluate the collection cycle to ensure debtors are not avoiding repayment by delaying the collection process.

        • Strive for win-win solutions that result in the collection of the debt in a timely manner while maintaining the goodwill of the debtor.

          • Establish clearly defined parameters for collection attempts.

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Summary of Guidelines continued
Recovery processes and tools It is recommended that SESAs:

  • Pursue legislation to:

    • Report delinquent and/or untimely installment payments to credit reporting bureaus.

      • Support the assessment and/or waiver of repayment of fees that can be used to develop win-win solutions.

        • Develop an offer in compromise process.

          • Accept repayment of overpaid UI benefits via credit cards, debit cards and/or electronic funds transfers.

            • Explore feasibility of purchasing software that provides for taking check information by telephone.

Skip-tracing It is recommended that SESAs:

  • Consider feasibility of using the Internet as another skip-tracing tool.

    • Periodically evaluate recovery of skip-tracing cases to determine cost-effectiveness and impact on resources available to pursue recovery of overpaid benefits.

      • Consider outsourcing recovery to private collection agencies when debtors have moved to another state.

Footnotes:

1. For additional information on administrative penalties, see Attachment C, Table 1.

2. For additional information on penalties assessed by the SESAs, see Attachment C, Table 2.

3. Information is not available to identify the number of BPC positions expended through recovery efforts. BPC positions may include detection, establishment, investigation, and recovery activities.

4. The 1997 ETA 227 report contains a compilation of statistical data for fifty SESAs.

5. This is the amount identified by the SESA, based on historical records, that is estimated to be uncollectible. The estimate must be reasonable and supported by factual data.

6. For additional information on collectibility profiling, see Section F, Automation.