October 14, 2011 DRAFT
Benefit Year Earnings (BYE) 20% of BAM Improper Payments in 2010: Root Causes Identified: Agency Causes Too few BPC staff to adequately investigate and address cross-match hits Not taking full advantage of traditional cross match, NDNH, and jail roster data Lack of automation of cross-match activities Not using all contacts with claimants and employers as an opportunity to educate Claimant Causes Lack of understanding of reporting requirements (difference between net vs. gross earnings; when earned vs. when paid) Misrepresentation to agency of reported earnings 2
Benefit Year Earnings (BYE): Planned action(s) to address: Increase the number of integrity staff in new UI organization Targeted outbound call campaign to claimants who have reported wages explaining their responsibilities Revision of claimant communication tools (handbook, hold messages, call center scripts, IVR, etc.) Procurement of enhanced cross-match automation Use website to publicize fraud convictions and other consequences, i.e., time and monetary penalties Principal milestones: New UI organization goes into effect 11/01/2011 Targeted outbound call campaign to begin 12/2011 Updated communication tools by 12/2011 Cross-match RFP to be released by 11/30/2011 3
Separations (SEPs): 14% of BAM Improper Payments in 2010 Root Causes Identified: Agency Causes Incorrect separation determinations Inadequate fact-finding at the time of initial claim submission Insufficient number of staff to adequately adjudicate separation-related issues Claimant Causes Failure to report separations or inaccurate and/or incomplete reporting of separation information Employer Causes Non-timely submission of separation information or inadequate and/or incomplete reporting of separation information 4
Separations: Planned action(s) to address: Increase the number of adjudication staff in new CDLE-UI organization—now focusing on both timeliness and quality Provide refresher training for adjudicators Determine whether to provide fact-finding training to call center agents Use all communications with employers & claimants to stress the importance of timely submission of separation documents Principal milestones: New UI organization goes into effect 11/01/2011 Decision on role of call center in fact-finding, by 11/30/2011 5
Work Search Issues: 41% of BAM Improper Payments in 2010 Root Causes Identified: Agency Causes Lack of specificity in current regulations concerning work search, recordkeeping, and record retention requirements Lack of specificity in current claimant communications concerning work search, recordkeeping, and record retention requirements Treating all failures to respond to BAM questionnaire as work search improper payments Claimant Causes Lack of understanding of work search, recordkeeping, and record retention requirements 6
Work Search Issues : Planned actions to address: Develop new regulations to provide clarity and specifics on work search, recordkeeping, and record retention requirements Issue formal warning letter to claimants who fail to respond to BAM questionnaire instead of establishing improper payment due to W/S – continue to establish improper payment on failure to respond Claimants receiving formal warning letters will be subject to a higher frequency of audits Revise claimant communication tools (handbook, hold messages, call center scripts, etc.) Provide work search logs on line and reinstitute log in handbook for emphasis Principal milestones: New regulations in place by 1/2012 Updated communication tools by 12/2011 7
Strategies to Support Owning UI Integrity: Increase in the number of UI staff addressing improper payment-related issues Clear articulation of our goal to exceed national average in terms of improper payments—and timeline and milestones for achieving this goal Encourage staff from across the organization to “own” and report improper payments to BPC for investigation – additional staff in BPC will increase detection rates Develop processes that promote the sharing of information across the organization for performance improvement and lessons learned BAM results shared quarterly Appeals reversals shared with adjudicator Use data from BAM and appeals to identify training needs across the UI organization that will further reduce improper payments Involvement of staff from across CDLE in the Integrity Task Force and in implementing this action plan 8
Communications Strategies: To claimants Revised handbook with work search and earning logs Revised hold messages and IVR scripts (both work search and BYE) Targeted outbound call campaign to address BYE, Work Search issues Congratulations letters to claimants who appear on the NDNH To employers Auditors to communicate importance of submitting forms timely Use of quarterly Tax Newsletter to educate Explore use of outbound call reminders 9
Communications Strategies, Continued: To state UI staff Keep staff appraised of Integrity Task Force Activities Involve staff in UI Integrity process improvement activities To the public Rulemaking process to strengthen work search recordkeeping requirements Monthly UI Stakeholder Group meetings To state leaders (Governor, state legislature, etc.) Rulemaking process to strengthen work search recordkeeping requirements Monthly UI Stakeholder Group meetings Regular progress reporting to the Governor on activities related to improper payments responsive to Executive Order B
“Integrity: Own It!” Questions? State contact for follow-up: Brian Chesher: Phone: