Employers and States Working Together to Improve the UI Program National UI Directors’ Conference & IT/Legal Issues Forum October 3-6, 2016, New Orleans
Understand the successes Session Takeaways Understand the successes Understand the challenges Understand the importance Consider best practices
Successes
Committed resources to support UI Integrity, employer compliance, and states’ UI program needs Dedicated UC Government Relations team NASWA affiliate member UWC, Inc. member AUTO member Investment in technology and data solutions SIDES CaseBuilder UI Cross Match
SIDES Currently Live in 45 Jurisdictions DC DE PR RI VI WA WA OR CA NV HI AZ NM TX OK AR LA FL GA AL MS ID MT WY UT CO ND SD NE KS MN WI MI MO IL IN OH NY PA NC SC KY TN WV VA ME ME MT ND VT OR MN NH ID WI NY MA SD DC DE PR RI VI WY MI CT PA IA NV NE OH NJ IN MD IL UT CA CO WV VA KS KY MO NC TN AZ NM OK AR SC AL AK TX MS GA LA FL Already live ( 40 States) Live by YE 2016 (9 States) Not Participating (4 States *MA added) State Information Data Exchange (SIDES) EFX is ready to begin testing with states as soon as they are available Need additional states to utilize the Monetary Determination file to expand use of Separation file (base period notices)
CaseBuilder is improving employer compliance and impacting UI Integrity 3,800 clients 125,000 live unique users 67% of activity handled through CaseBuilder
challenges
Challenges State UI System Modernization/Online Systems Lack of collaboration with stakeholders Lack of advance communication to employers/TPAs No advance notice of UI form revisions No phased-in rollout Little or no testing prior to “go live” No “Plan B” Agency mandated use of online system
Challenges UI “Integrity Law” The problem Wide variation in laws and regulations Wide variation in processes among state agencies Lack of communication in how state UI agencies will administer Timely (respond on or prior to the deadline) Adequate (answer all of the questions) Compliant (avoid pattern of failure & loss of charge relief) 2 or 2% Pattern of Failure: defined by many states as the greater of two or more instances or two percent or more of claims within the prior year.
Arkansas, Texas, New York, North Carolina 51% of claims in preceding calendar quarter or 3 if total is ≥ 5 “Adequate” defined by statute 3 or more instances No timeframe in the statute – once an occurrence is issued, it does not expire Pattern of failure” not defined 2% or more of total claims in the prior calendar year “Adequate” not defined by statute
SSN Challenges Redaction or elimination of SSN on Employer/TPA- facing communications Impacts accuracy and efficiency Not limited to documents; some UI agencies no longer providing full SSN on rebuttal calls 28 jurisdictions currently truncate at least 1 UI document
Opportunities
Best Practices – UI System Modernization Communicate Advise employer and TPA community of your objectives before RFP Notify well in advance: Let TPAs and employers know what is changing and what impact the new system may have on them Include Solicit feedback from stakeholders via UIAC or topic-specific meetings Conduct trial data-runs, partnering with TPA or employer with a database that can challenge your system Avoid roll-out of end to end system all at once Educate Offer new system training to employers/TPA s via webinars Establish an employer/TPA “Hotline” number or e-mail address Post information, updates and FAQ’s on website Publish updates in your employer UI newsletter
Best Practices UI Integrity SSN General Clearly define “adequate” Clearly define the time period (if “pattern” is included in regulation) Ex: Calendar year, rolling 12 months from occurrence, previous 12 months…. Communicate which forms are considered a “request” Consult with other state UI agencies, TPAs, and employers SSN Provide full SSN on all employer-facing documents General Have a TPA liaison Publish an Employer UI Newsletter Create an Employer UI Advisory Committee
Questions or Thoughts?? Lori Roberts lori.roberts@equifax.com 614-658-3102