[Federal Register Volume 66, Number 62 (Friday, March 30, 2001)]
[Notices]
[Pages 17443-17446]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 01-7909]


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DEPARTMENT OF LABOR

Employment and Training Administration


Proposed Collection; Comment Request

ACTION: Notice and request for comments.

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SUMMARY: The Department of Labor (DOL), as part of its continuing 
effort to reduce paperwork and respondent burden, conducts a 
preclearance consultation program to provide the general public and 
Federal agencies with an opportunity to comment on proposed and/or 
continuing collections of information in accordance with the Paperwork 
Reduction Act of 1995 (PRA95) (44 U.S.C. 3506(c)(2)(A)). This program 
helps to ensure that the requested data can be provided in the desired 
format, the reporting burden (time and financial resources) is 
minimized, the collection instruments are clearly understood, and the 
impact of collection requirements on respondents can be properly 
assessed. Currently, the Employment and Training Administration (ETA) 
is soliciting comments about the proposed new collection of information 
on the validity or correctness of certain Unemployment Insurance (UI) 
data that States now provide to ETA in monthly, quarterly or annual 
reports. Some of these data are used to calculate performance measures 
or to allocate the funds used for program administration. ETA is 
seeking Office of Management and Budget (OMB) approval under the PRA95 
to establish a UI Data Validation (UIDV) program to replace the 
existing Workload Validation (WV) program. The WV program, for which 
authority expired on 12/31/2000, validated--checked the accuracy of--a 
small number of reported data elements that are used to determine the 
allocation of funds appropriated for UI program administration. Under 
the more comprehensive UIDV program, States would validate about half 
the data they now report, including all the workload items. The UIDV 
system would increase the validation reporting burden. A copy of the 
proposed information collection request (ICR) can be obtained by 
contacting the office listed below in the addresses section of this 
notice.

DATES: Written comments must be submitted to the office listed in the 
ADDRESSES section below on or before May 29, 2001.

ADDRESSES: All comments about this proposed collection of information 
should be addressed to: Burman Skrable, Office of Workforce Security, 
Employment and Training Administration, U.S. Department of Labor, Room 
S-4231, 200 Constitution Avenue, NW., Washington, DC 20210. Telephone: 
202-693-3197 (this is not a toll-free number); fax: 202-693-3229; e-
mail: [email protected].

SUPPLEMENTARY INFORMATION:

I. Background

    Section 303(a)(6) of the Social Security Act specifies that the 
Secretary

[[Page 17444]]

of Labor will not certify State UI programs to receive administrative 
grants unless the State's law includes provisions for--

    Making of such reports. * * * as the Secretary of Labor may from 
time to time require, and compliance with such provisions as the 
Secretary may from time to time find necessary to assure the 
correctness and verification of such reports.

    Since the mid-1970s, all State Employment Security Agencies have 
been required to check the validity of certain data elements they 
submit on four required UI reports. The Department uses these data in a 
formula for determining each State's share of funds appropriated for 
the administration of the State's UI program. These elements are all 
aggregate counts of the number of times the State performs certain 
activities, or counts of such items as employers subject to UI taxes.
    Validation and the UI System. Validity means that the counts the 
State submits on its reports are correct accumulations of elements 
which conform to the Federal reporting definitions. State staff, 
following the instructions in ET Handbook No. 361, perform this WV 
process; Department of Labor Regional staff, assisted by a technical 
support contractor, audit the State's validations. The validation has 
two dimensions: quantity and quality. The quantity validation consists 
of comparing a reported count for a selected period with a 
reconstructed validation count; it passes if there is no more than a 2% 
difference between the two. In the quality validation, samples of each 
element are checked against primary agency records to ensure that the 
proper activities are being counted according to Federal reporting 
definitions. To pass, a sample may contain no more than 5% invalid 
elements. The WV process is repeated every three years if all 
validations pass; any failure requires a revalidation of failed 
elements the following year.
    Starting in the 1980s and continuing through the 1990s, the General 
Accounting Office and the Department's Office of Inspector General have 
criticized ETA for not validating all elements it requires States to 
report as program managers and policy officials at all levels rely upon 
such elements in making decisions affecting program design, funding and 
operations. More recently, the Government Performance and Results Act 
(GPRA) emphasizes that agencies need to ensure the validity of all data 
on which they base their strategic planning decisions and performance 
determinations. Commonly, agencies' GPRA displays indicate how they 
validate, or propose to validate, their performance data.
    In the 1990s DOL asked Mathematica Policy Research, Inc., to 
develop a more automated validation approach in conjunction with its 
management of the field test of new benefits timeliness and quality 
measures. When the field test showed the methodology to be sound, it 
was extended to key UI tax performance data.
    The new UIDV system has one feature in common with the WV system, 
but also some important differences:
     In common with WV, UIDV does quantitative validation by 
independently reconstructing reported counts, and qualitative 
validation by checking samples against primary agency records;
     The major differences are:

--WV starts with workload items, identifies each item the report 
elements comprise, and validates the report elements. In contrast, UIDV 
starts with the report elements to be validated. It first identifies 
the broad groups (``populations'') of underlying elementary 
transactions on which those report elements are based (e.g., initial 
claims), then devises mutually exclusive subgroups (``subpopulations'') 
which relate to the report elements.
--UIDV uses State-specific handbooks (one for benefits, another for 
tax) instead of one generic handbook. The UIDV handbooks' instructions 
for programmers and validators are specific to a State's own management 
information system. Thus, Federal reporting requirements are mapped to 
the related data element on each individual State's data system.
--UIDV is more highly automated and efforts are being made to automate 
its operations further to increase efficiency;
--UIDV's scope of validation is more extensive. It validates 
approximately half of the elements on the 47 required UI reports, 
versus WV's validation of only 29 data elements on four reports. UIDV 
validates all workload elements, including most of the data used to 
construct the Tier I UI performance measures (See Unemployment 
Insurance Program Letter 37-99, July 1, 1999, published as Federal 
Register Notice 64 FRN 38088 (July 14, 1999)).

    UIDV Pilot Test. Three States pilot tested the UIDV system between 
November 1997 and October 1998. Two States undertook validation of all 
benefit and tax report elements in the UIDV handbooks; the other State 
validated all benefits elements but only validated one (Field Audit) of 
the five tax populations. Pilot States and associated ETA Regional 
Office staff received preparatory training before starting and 
technical assistance throughout the pilot from a support contractor.
    In brief, the pilot test showed:
     States could generally implement the UIDV system with a 
reasonable but sustained level of effort.
     The UIDV system worked as designed to discover reporting 
errors.
     States do make reporting errors which need detecting and 
fixing.
     The reporting problems can be fixed.
     The average staff requirements from the pilot test were 
about 2200 hours to complete Benefits Validation and about 2300 hours 
for Tax Validation, or 2.2-2.5 staff years for both, of which 
programming time was about 77% or 1.8 staff years. The contractor's 
evaluation report estimated that the continuing validation cost will be 
about 35% of initial, or about 0.8 staff years for tax and benefits 
validation combined. Very little of this is programmer time.
    Although DOL has based the burden estimates below on the pilot 
program experience, it believes the estimates represent an upper limit 
for the true burden. The pilot was conducted while States were 
addressing Y2K concerns, which caused turnover among programmer staff 
and a lack of availability or intermittent availability of senior 
programmers for the pilot. The Department is also working to develop 
additional automation for the UIDV processes which will reduce initial 
programming time below the pilot test estimate.

II. Review Focus

    DOL is particularly interested in comments which:
     Evaluate whether the proposed collection of information is 
necessary for the proper performance of the functions of the agency, 
especially whether the information will have practical utility;
     Evaluate the accuracy of the agency's estimate of the 
burden of the proposed collection of information, including the 
validity of the methodology and assumptions used;
     Discuss how to enhance the quality, utility, and clarity 
of the information to be collected; and
     Suggest how to minimize the burden of the collection of 
information on those who are to respond, including through the use of 
appropriate automated, electronic, mechanical, or other technological 
collection

[[Page 17445]]

techniques or other forms of information technology (e.g., permitting 
electronic submission of responses).

III. Current Actions

    The Department proposes the following plan for implementing and 
operating the UIDV system:
     Mandatory implementation will begin around July 2001; 
States have been encouraged by Unemployment Insurance Program Letter 
No. 03-01 to implement the UIDV program voluntarily before then.
     States that are not ready to begin implementation in 2001 
will be required to validate all or some of the 11 workload items using 
the WV methodology if WV procedures would have called for validation.
     UIDV will initially retain the 3-year cycle for validation 
and the validation standards applied under WV (2% for 
quantity, 5% for quality). The following criteria, taken from WV, will 
also be used to determine when deviation from the cycle will be 
required: (1) A change in Federal reporting requirements; or (2) 
failure of the previous validation test; or (3) a major change in the 
State's computerized data system. In each of these cases, validation 
would be required the following fiscal year. Once into the continuing 
cycle, States decide when to conduct validation during a year.
     Beginning with the FY 2004 State Quality Service Plan 
(SQSP) cycle, States will be required to include validation findings in 
the SQSP. They will be required to develop a corrective action plan for 
failure to complete a validation or if the same report element 
repeatedly fails validation.
    Resources: States are expected to provide resources for UIDV from 
their UI administrative grant. Since the WV program was begun in the 
late 1970s, each State's grant has included one staff year for WV 
activities. The estimates below, based on estimates provided by the 
pilot evaluation contractor, indicate that average UIDV staffing 
requirements for continuing operations will be less than one staff 
year.
    ADP Support: To reduce programming costs, the Department is 
developing additional software intended to limit State programming 
requirements to preparing the extract programs for the data elements to 
be validated. The additional software provided by the Department should 
cut the programming demand on States during implementation, which 
averaged 1.8 staff years in the pilot test, in half.
    Data Recording and Reports: States will record the results of their 
investigations on spreadsheet software prepared as an accompaniment to 
their handbooks. Initially, the spreadsheets can be transmitted by e-
mail or regular mail to the Department. Eventually, the results will be 
submitted the same as other reports. The results will be stored in a 
database in the National Office in Washington, D.C., and compiled in an 
annual validation accuracy report.
    Training: DOL will begin conducting UIDV training for State staff 
in the Summer of 2001. Several sessions, perhaps on a regional basis, 
are envisioned. Experience to date suggests that small training 
sessions are most effective. States that elect to implement UIDV 
voluntarily may receive individual training. The Department's technical 
support contractor, Sparhawk Group, Inc., assisted by staff from 
Mathematica Policy Research, will conduct the training along with 
Department staff, and will provide continuing technical assistance 
during implementation. DOL will issue a directive containing details on 
the times, locations, and content of the training in advance of the 
sessions.
    Type of Review: New .
    Agency: Employment and Training Administration.
    Title: Unemployment Insurance Data Validation Program.
    OMB Number: 1205-0NEW.
    Recordkeeping: States are required to follow their State laws 
regarding public record retention in retaining validation results.
    Affected Public: State Governmental entities.
    Reference: Handbook 361.
    Total Respondents: 53.
    Frequency: Complete validation every third year; annually to 
revalidate failed data, when there are changes in Federal reporting 
requirements or when State data systems undergo major changes. Table 
below assumes that one third of States must validate 10% of elements in 
each of two ``off years.''
    Total Responses: 53 (Average in a year: 29.7).
    Estimated Time Per Response: 1,600 hours for a full validation, 
conducted every third year (based on pilot program. Off-year burden 
will depend on number of elements needing re-validation.)
    Total Burden Hours: 30,187 Hours.
    Total Burden Cost (capital/startup): 121,792 hours, $3,524,660 
(2,768 hours, $80,106 per each of 44 States).
    Total Burden Cost (operating/maintaining): $873,612 ($29,414 per 
State).

                                                  Calculation of Annual Burden and Capital/Startup Cost
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                                                                             Hours per                                                      Average per
                                          Frequency         Respondents      response       Total hours    Rate in $/hr       Total $         State $
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                                                              Calculation of Annual Burden
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Full Validation...................  Every 3rd year......              53           1,600          84,800           28.94       2,454,112          46,304
Partial Validation................  2 off years.........              36             160           5,760           28.94         166,694           4,630
3-Year Total......................  NA..................              NA              NA          90,560           28.94       2,620,806  ..............
Ann. Avg..........................  ....................            29.7           1,016          30,187           28.94         873,602          29,414
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                                                           Calculation of Capital/Startup Cost
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States Implement..................  One Time............              44           4,500         121,792           28.94       3,524,660          80,106
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[[Page 17446]]

    Comments submitted in response to this request will be summarized 
and/or included in the request for OMB approval of the information 
collection request; they will also become a matter of public record.

    Signed in Washington, DC on March 16, 2001.
Grace A. Kilbane,
Administrator, Office of Workforce Security.
[FR Doc. 01-7909 Filed 3-29-01; 8:45 am]
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