Unemployment Insurance Program

Overview: State Priorities and Strategic Direction to Ensure Continuous Improvement.

• Cross Functional Areas: The last 12 months have brought much change to Indiana’s UI Program. During the fall of 2018, new leadership embarked upon two major projects focused on improving UI Benefits staff retention (which is discussed further in the UI Benefits section below) and overall efficiencies of the Quality, Policy, Integrity and Training (QPIT) Unit. The National Association of State Workforce Agencies (NASWA) Integrity Center visited Indiana in October of 2018. Additionally, Indiana launched enhancements to the Employer Self-Service (ESS) in Uplink in March of 2019 (discussed further in the UI Tax section below). 

The results of the QPIT efficiency review resulted in the following:

• Reinstated an overall UI Training Unit: This effort brings all UI Trainers to one team. 
• Created separate UI Internal Quality Unit: This effort focuses on providing coaching and feedback directly to staff in all UI areas.
• Created a UI Performance Unit: This effort brings all staff responsible for UI reporting to one team, streamlining data validation efforts and allowing time and focus for data integrity projects.
• Created UI Special Projects position: This effort brought forth a single point of contact to coordinate projects that span across functional areas, such as implementing the NASWA Integrity Center recommendations. 

As noted above, the NASWA Integrity Center was invited to Indiana to review specific areas of the Indiana UI system. This visit resulted in a better understanding of the current processes for new leadership, areas for growth and where efficiencies may be gained, and a formal report and recommendations from the NASWA team. Coordinating analysis and implementation of the recommendations from the NASWA report has been assigned to the UI Special Projects position mentioned above. In addition to the NASWA Integrity Center visit, Indiana is in the final stages of finalizing an MOU with the NASWA Integrity Data Hub. 

Complementing the NAWSA team, Indiana also completed all 15 of the UI Self-Assessments. There was one internal finding and resolution (discussed further in Section 2 below). In addition to the self-assessments, Indiana added a new process to the TPS review. As reviewers are examining processes and systems during the TPS review, they are documenting notable efforts and best practices, as well as overall process and system challenges. This effort will allow leadership to recognize staff for positive practices, as well as identify areas of improvements. 

• UI Benefits: Historically, Indiana was overly optimistic about the ability to bring both quality and timeliness of benefits processing into core measurement standards. Meeting both of these standards in FY 2019 and 2020 remains a significant challenge. Over the past few years, the Indiana Department of Workforce Development (DWD) launched several initiatives in the UI Benefits program to improve performance in the areas of quality, timeliness, and first payment promptness.  Quality improvement strategies have succeeded, with the agency achieving 79% separation quality and 85% nonseparation quality in the second quarter of CY2019. The focus on quality determinations has resulted in a struggle with nonmonetary determination timeliness and first pay promptness.

1. Training and Staffing: Indiana has struggled with negative UI Benefits staff turnover during the last several years. Although adjudicators received a salary increase in 2017, this one action did not decrease or slow the rate of turnover. New leadership of the UI division took a different approach to resolving this issue. Several roundtable conversations were held during September and October of 2018 with UI Benefits frontline adjudicators, adjudicator supervisors, Benefits Timeliness and Quality (BTQ) staff, and UI leadership. These roundtables were held to understand directly from the staff their thoughts on what is and is not going well and what is preventing adjudicators from staying. From this feedback, several policy changes have occurred in efforts to increase staff retention. Some examples include: adjusting the vacation policy to allow for an increase of staff who could be off, especially during holidays, while maintaining appropriate coverage; reinstating a flex-time policy; and piloting telework for both adjudicators and contact center staff. UI Leadership again worked with the State Personnel Department (SPD) to review the classification and salary range for adjudication work.  Conversations this time focused on the complexity of the work and the skillset needed to accurately complete adjudication work. DWD strongly encouraged SPD staff shadow adjudicators and not solely review job descriptions to understand the work. As a result, SPD created a new classification specifically for adjudicators, Claims Investigators. The new classification is tiered to allow for upward economic mobility and succession planning.  Claims Investigator Trainees have a higher starting salary and will receive a salary increase when they are able to pass the Working Test period. DWD is monitoring the impact of this reclassification as well as all the other changes on staff retention.

During the roundtable discussions, staff voiced wanting additional time with the Quality Manager for feedback, both positive and negative, and coaching from supervisors. The next task in the overall adjudication retention project is to revamp the internal quality review process. Historically, this process mimicked BTQ, though BTQ staff split their time between reviews and training. In PY2019, BTQ staffed reviewed 7,000 issues and held four 12-week training sessions. Feedback on quality pulls were minimal, occasionally only a sentence.  Adjudicators voiced needing and wanting more quality feedback. Revamping the benefits internal quality process is ongoing with implementation beginning in fourth quarter of 2019.  DWD will monitor the impact of the new process on Benefit, BTQ, and Benefits Accuracy Measurement (BAM) metrics.

Indiana has continued its adjudication training program, though a review of the current 12-week training began in the fourth quarter of 2019.  Any changes will be implemented throughout 2020. Indiana continues to hold monthly adjudication quality meetings, where members of the BAM, BTQ, and Adjudication Training Units meet with adjudication supervisors, the Director of Benefits, and the Associate Chief UI Officer to identify quality issues and training needs. Monthly refresher training lectures for adjudication staff, as well as ad hoc updates, are offered on unique issues as they arise.

2. Prevention, Detection, and Recovery of Improper Payments: Indiana has continued to make the prevention and detection of improper payments a priority by focusing on claimant messaging and work search initiatives. New administration, along with NASWA Integrity Center recommendations, have initiated efforts to provide claimants with understandable and easy-to-locate information. When the new claimant intake system was launched in 2017, it was designed with improper payment prevention in mind. This included many warnings and sign-offs about what not to do when filing a claim and weekly certification. After a few years of usage, however, it was determined that there was insufficient claimant education about what they should be doing. This has led to claimant confusion and simply guessing what they should be entering when filing a claim and weekly certification. This can lead to improper payments.

In early 2019, Indiana released a website (unemployment.in.gov) to explain and facilitate the UI process for the constituent. This website is used by both claimants and employers with the most sought after links provided on this page. Currently in progress are videos to walk through filing a weekly certification and a separate video about how to correctly report earnings. Also provided to claimants in 2019 was a work search log in a fillable PDF format. Indiana requires claimants keep a log of their weekly work search activities but has never provided the claimants with a form to utilize. The link to the log is available in multiple locations and is used weekly by claimants. The work search question page on the weekly certification was modified to help claimants better understand the work search requirements for the week. The previous question was modified to more clearly state the requirements. More information regarding work search projects is included in the section, WIOA and Reemployment.

As mentioned above, during the Self-Assessment process, Indiana found that the work done by the Benefit Payment Control (BPC) unit performing fraud and new hire investigations were limiting the scope of their work. This was implemented during the aftermath of the Recession when their workload was extremely high. Although necessary at the time, this process has since been recognized as insufficient for prevention, detection, and recovery of improper payments. The BPC unit has since updated their procedures and has lifted the previously imposed restrictions on the limits of their investigations.

In FY 2016, the agency implemented State Information Data Exchange System (SIDES), SIDES Web Services, SIDES E-Response, and SIDES Outreach, which are intended to increase quality, timeliness, and quantity of employer participation in the adjudication process. Since implementation, positive outcomes include: quicker employer response times, better and more complete information within the initial employer response, and immediate confirmation of receipt of the employer’s claim response instead of waiting on busy fax lines. While a few unintended consequences have arisen (e.g., differences in UI SIDES and SIDES E-Response functionality and some ISPs blacklisting DWD email addresses, which prevented the notification of many SIDES E-Response employers of claims), Indiana continues to be part of the 100% Club (since October of 2016), consistently meeting the requirement to receive 50% of employer responses to claims through UI SIDES and SIDES E-Response. We started meeting the requirement to receive 35% of employer responses to claims through SIDES E-Response in May 2018, only 24 months after the first SIDES E-Response requests were sent. In addition, DWD has been highlighted by NASWA Best Practices for promoting SIDES web service projects to high volume and multistate employers.  DWD has won the NASWA SIDES Overall Outstanding Performance for two consecutive years (2017 and 2018). DWD continues to be a top 10 performer in overall SIDES stats each month, often hitting the top 5. 

In prior years, Indiana struggled with overpayment recoveries. Indiana previously used SBR funds to implement the Treasury Offset Program (TOP) for fraud overpayments in FY 2015. The agency has fully implemented TOP for the recovery of fraudulent and eligible non-fraudulent overpayments and has vastly increased collections on overpayments by doing so. Additionally, Indiana has implemented automated wage garnishment for eligible claimants as of March 2019. The automated wage garnishment system is housed in the UI Program’s Uplink environment, which allows for better tracking, auditing, and data analytics. The automated system provides a mechanism for collections staff to review prioritized lists of debtors and sort the list using various parameters (e.g., total debt amount, total wage records, most recent wage records, etc.). All documentation, including orders and notices, will be housed within the system, which will automatically generate notices and orders when appropriate during the life of the garnishment case.

During the reporting period, the collections unit has collected a total of $2,830,574.91 through wage garnishments, $5,988,320.10 through voluntary payments, $5,192,353.42 through federal TOP intercepts, $2,399,782.77 through state tax intercepts, and $2,454,835.01 through offsets. Moreover, the agency has continued its partnership with county prosecutors and the Attorney General’s Office to prosecute fraudsters and collect overpayments. 

• UI Tax Administration:

1.  Performance Improvement: Indiana continues to exceed federal standards for new employer status determinations time lapse. The reorganization of the Tax Performance System (TPS) Unit under the same division as other quality units and trainers has resulted in improved communication between the TPS Unit and the Tax Divisions. This has, in turn, allowed the agency to identify root causes of several quality issues. Improvements in this area have led directly to the state’s passing performance in TPS reviews for all functions except Credits in at least one of the last three years.

Uplink system core functionality was launched for Tax in FY 2015 and FY 2016, as planned. Current system upgrades include identifying all barriers to quality that exist in Uplink at this time and to develop a multiple phase initiative to increase quality and integrity at all levels. In 2017, to correct its deficiencies, Indiana evaluated current the Uplink system defects. The agency then developed system resolutions for identified defects. Specifically, the agency completed the compilation of all known defects and required process improvements in the target areas of Status New, Successorship, Collections, and Inactivations. Tax and IT staff established a feasible timeline for addressing the defects and improvements and then moved forward to pursuing these projects beginning in FY 2017 and continuing through FY 2021. As development nears completion, staff will test application updates and then release application updates into production in a well-planned and widely-communicated manner.

Enhancements to the Employer Self Service (ESS) domain were released in spring of 2019.  Additional phases are planned to make improvements in the detection of registration errors, unreported successorships, and communication of credits in order to push computed measures with regard to timely determination of successorships to a more acceptable level, proactively correct registration errors including legal name and business type mismatches, provide for timely notification of employer overpayments (credits), and to fully integrate mandatory audit trail events into processing actions.

There is direct accountability in Indiana’s Status, Employer Account Maintenance, and Collection Enforcement Units, as work items are distributed by the last two digits of an account number.  The agency has gained some operational efficiency under this method and each auditor is able to take a more holistic approach to account resolution. With the process improvements and new work items created in future releases of the planned system enhancement, continued improvement in all quality review areas is expected.

2.  Addressing Worker Misclassification: The new field audit software package was fully implemented in June of 2016.  This implementation included integration with the Uplink system, which automated audit result processing of adjustments and wage records, in addition to ownership and profile updates. The IRS 1099 extract data are being compared with data from Indiana’s system to generate reports that provide the information needed to target existing employers who may be misclassifying workers. Additionally, these data analytics allow Indiana to identify businesses that currently have not registered for a SUTA account but are issuing 1099s. The investigators also investigate tips received from other DWD divisions, other governmental agencies, and the public.

• WIOA and Reemployment: Indiana has increased collaboration and communication between UI and our workforce development programs. Specifically, UI is working with the RESEA program on several projects: TAA/TRA; Wagner-Peyser; and regional WIOA partners. The official title of Indiana’s UI Leader is Chief Officer of UI and Workforce Solutions. She has been tasked with uniting both UI and WIOA Core Programs to ensure collaboration, communication, and efficiencies.  As such, she leads the DWD internal committee on Workforce Best Practices. This allows her to stay current on both UI and workforce development needs, accomplishments, and areas of growth. 

One example of increased collaboration and communication started with ensuring UI is represented on the regional customer service survey (see section F below). This collaboration has grown to include routine information sharing between UI and the workforce side. Specially, UI provides contact center stats to the WDB Regions quarterly. It is important that regional office staff understand wait times and customer services hurdles in order to provide general assistance to claimants who visit a WorkOne to engage with a UI kiosk. UI has developed, with the assistance of regional partners, FAQs regarding filing UI claims. UI works diligently with Wagner-Peyser staff and WIOA leadership to ensure regional staff are educated on the type of assistance they can and cannot offer and when to refer a UI clamant to the contact center. UI Contact Center leadership have visited several regional offices to observe claimant/regional staff interactions. This project has assisted in understanding the type of information the regional office staff need to assist claimants. 

TAA and UI TRA staff have recently started meeting bi-monthly. The focus of these meetings is to increase communication, gain a better understanding of the impact of processes to each side, and to collaborate on areas of improvements. 

UI is also an active participant in the Infrastructure Costs process, consulting with other DWD workforce programs prior to negotiation meetings. This level of communication ensures UI has an understanding of the full impact of funding decisions at the agency level. In addition, both UI contact center and adjudication staff refer claimants to their local WorkOne, when appropriate. Indiana continues to refer all UI claimants to RESEA (except those with relevant waivers) for reemployment services.  The Indiana UI program has focused on increased communication and collaboration with the RESEA program staff over the past year. This has resulted in increased communication between these two divisions.

In Indiana, UI claimants are granted access to IndianaCareerConnect.com (ICC) upon filing an initial claim for benefits. This strategy to quickly connect claimants to ICC, Indiana’s labor exchange service, assists in the reemployment efforts to refer claimants to available job openings early in their claims. ICC is also where all records are kept for a claimant’s reemployment activities and services received. In order to expedite the communication between RESEA and UI Adjudication, on May 17, 2019 Indiana implemented an integrated system communication structure between ICC and Uplink. This new line of communication electronically notifies UI Adjudication of potential issues in a streamlined process rather than the manual process that previously existed, which included faxing paper documents and manual data entry for issue creation. This integration has saved UI Adjudication staff and RESEA program staff a significant amount of time and resources.

Indiana has cross-trained the UI benefits unit and the RESEA policy unit to understand each other’s policies and requirements. The units have met many times and have worked together to study possible changes to programs. The UI benefits unit has also concentrated efforts on learning about the RESEA program and how it focuses on claimants work search activities. Statutorily in Indiana, the RESEA program is required to review the claimants work search activities. The UI benefits unit hopes to utilize the RESEA program’s knowledge on how to help claimants utilize their work search activity options to become reemployed, while meeting UI standards for work search activities.

UI is a full partner as Indiana makes decisions around the RESEA evaluation requirement.  UI leadership is co-leading this effort with DWD Research and Analysis leadership. DWD has identified a RESEA evaluation team, which is charged with developing and implementing the RESEA evaluation plan and will include opportunities for even better systems integration. 

Federal Emphasis (GPRA goals): Indiana’s efforts to meet the GPRA goals and National Priorities for FY 2019 are discussed generally in Part A (First Pay Promptness) above. The agency will continue to strive to meet or exceed performance goals against the GPRA goals. See CAP plans to review expectations and processes to be put into place to achieve these metrics (for First Pay Promptness).

Regarding the Employer Tax Liability Determinations Made Timely goal, Indiana made a significant change in UI reporting for 2019, which prevents an employer from filing until they have registered completely. This change should decrease the number of accounts that make payments without prior registration and which are always set up with a liability date in the 1^st quarter of the year. As the number of “pre-assigned” accounts with the default 1^st quarter qualification is decreased, the computed measure will increase.

Program Review Deficiencies (Causes for Failures): Data Validation: Indiana has successfully conducted and transmitted all data validation except for Benefits Module 4 – Appeals. Indiana has automated this review process in the Uplink system. There are hard-coded limitations and deficiencies to what information the system is able to produce over time.  As a result, the information required to conduct this review is not available to the data validator.

Throughout the year, data validation staff identified and resolved new issues with both Tax and Benefit populations. These issued were in part due to extracts, as well as the accuracy of Federal Report data. The state has identified the root cause for a majority of the remaining deficiencies; however, more research is needed, particularly into the cause of Module 4 Non-Separations and Module 4 Inactivation/Termination. One outstanding obstacle to be resolved is inadequate IT resources. The state implemented several system enhancements throughout 2018 and 2019.  These enhancements have occupied significant resources in previous years, reducing the ability to resolve Data Validation issues. The state intends to prioritize correcting issues with federal reporting as the next major IT project.

Program Deficiencies – (plans to correct deficiencies identified): Nothing to report.

Reporting Deficiencies Corrections (identify actions to correct):

• Incorrect Recording of Issue Detection Date: The deficiency to meet the metric for correct issue detection date is due to incorrect issue detection dates auto-populated by the Uplink system, as well as staff data entry errors. The auto-populated dates are fields that can be edited by adjudication staff while working on the issues. Each quarter, the BTQ staff provide a list of all incorrect or notable issue detection dates for analysis. The results are different each quarter, which makes solving the problem more complex. Previous efforts were focused on specific issue types, which were identified with incorrect detection dates. The focus of this analysis was too narrow, resulting in insignificant change. Recent efforts to identify and analyze the root causes are focused on hard-coded system information utilized to populate the fields.

Members of the BTQ unit and the Director of UI Benefits will continue to track and analyze the data utilized for Issue Detection Date recording to identify causes and to recommend changes.

• Lower Authority Appeals Monitoring Findings: The launch of the Uplink system resulted in unintended consequences for the Appellate Division. As noted in previous SQSP submissions and DOL monitoring responses, errors in the Uplink system caused federal reports to fail (specifically ETA 5130, ETA 9054, and ETA 9055). The Performance unit has been analyzing the problem to determine the root causes in order to resolve the problem.

In order to sufficiently identify the problem, the Performance unit has met with the Appeals unit to better understand their processes and procedures and specifically how activities in Appeals are counted in Uplink. Identified through these continuing conversations is the necessity of a manual count, which is not accounted for in Uplink reporting. Each of these manual processes are currently being reviewed to be better understood. Once understood, these manual processes can then be converted into automated processes in Uplink. If implemented prior to an accurate understanding, the problem of incorrect reporting would remain. After all accurate processes and counts have been finalized, the IT department will be notified of how to correct the problems and implement the solutions. The IT department has been made aware that necessary changes are forthcoming, and they will be prioritized accordingly. 

Customer Service Surveys:Customer Service Surveys: WorkOnes and Uplink Customer Service worked in partnership to design a customer satisfaction survey to identify and address the essential needs and level of service claimants receive while visiting the WorkOne office or speaking with representatives from the UI Contact Center. This includes over-the-shoulder help that Wagner-Peyser staff provide to UI claimants, telephone assistance provided by the UI Contact Center staff, and RESEA services provided in the WorkOne. The UI leadership team meets on a regular basis with the workforce leadership team to review the results and determine any action that might be needed.  

DWD continues to work with the Indiana General Assembly on trust fund solvency, as the funding of the trust fund is determined by the statutory framework in the Indiana Code. 

Assurances:The state will comply with the assurances listed in HB 336, Appendix I. Pertinent dates for the implementation, testing, and updating of the plans are as follows:

1. 1. IT Contingency Plan
      1. Implemented – 7/28/2008
      2. Tested – All DWD systems are highly redundant and clustered systems that are tested, maintained, and updated according to precise documented procedure that are delegated according to role. The last major test coincided with the replacement of all application and web servers coinciding with upgrades to all supporting software technologies. These server replacements and software upgrades were concluded on March 28, 2018. These upgrades reflect complete shutdowns, server replacements/rebuilds, software loads, complete system restores, and testing procedures. Another set of server upgrades were due before Q4 2019 to remove a few remaining Windows 2008 servers.
      3. Reviewed/Updated – All Contingency and Continuity of Operations Plans were reviewed by IRS auditors as part of a Safeguards Security Audit on July 24, 2018. DWD has received the results of that audit and has responded to noted findings in IRS-issued corrective action plans on April 30, 2019. Plans were updated during the 1^st quarter of 2018 in support of the server and software upgrades concluded on March 28, 2018.
   2. System Security Plan
      1. Implemented – 02/18/10
      2. Tested – 09/01/15 through 07/24/18
      3. Reviewed/Updated – DWD has developed agency and application security plans to fit current NIST 800-53 requirements and in a new prescribed format required by the Indiana Office of Technology. These documents were the foundation for an IRS Safeguards Security report that was submitted April 30, 2018, and was reviewed during an on-site Safeguards Security Audit that occurred on July 24, 2018. DWD has received the results of that audit and has responded to noted findings in IRS-issued corrective action plans on April 30, 2019. All security plans are stored in Archer, the state’s enterprise governance, risk, and compliance tracking system and updated on a yearly basis. The last updates to DWD’s security plans were completed on July 10, 2019.
   3. Risk Assessment
      1. Implemented – 5/1/2006
      2. Tested – 09/01/15 through 07/24/18
      3. Reviewed/Updated – 07/24/2018: DWD participates in the Indiana Office of Technology (IOT) monthly vulnerability assessments utilizing Nexpose reports and reviews of current security risks in biweekly security meetings with the state CISO. The state has also purchased a license for Tenable Nessus, which allows the state and individual agencies to scan servers and applications to the same level utilized by the IRS during Safeguards Security Audits. Application scanning is also performed every six months utilizing IBM Security AppScan. All security plans, including Risk Assessment Planning, have been reviewed during the full audit of DWD compliance with IRS Safeguards Publication 1075 conducted on July 24, 2018. DWD has provided a set of corrective action plan responses on April 30, 2019 and on October 31, 2019. All security plans have been given an annual update, as required by IOT, on July 10, 2019.  An annual review of risk assessment information, including system categorization, data classification, and recovery objectives, is conducted with system owners on a yearly basis.

Indiana has a centralized IT agency, the Indiana Office of Technology (IOT), which has the primary operational responsibility for the state’s IT systems. The IOT maintains and reviews the IT-related policies and plans referenced in this section. All plans identified above are up-to-date.

DWD continues its participation in the Treasury Offset Program (TOP), in conjunction with the United States Department of the Treasury – Bureau of Fiscal Service. Indiana submitted an initial Safeguards Security Report on January 16, 2015. DWD has participated in two tri-annual audits and has submitted bi-yearly corrective action plan reports since the initial report. The last full audit of agency compliance with IRS Safeguards Publication 1075 was conducted during the week of July 24, 2018 and the initial corrective action plan report was submitted on April 30, 2019.

In conjunction with IOT, DWD has fully implemented two new, robust information security tools, Archer and Varonis DatAdvantage. Archer is a governance, risk, and compliance tracking system that has been implemented statewide for managing the state’s and DWD’s information security profile and compliance issues. Additional modules are being added to Archer that allow for comprehensive audit results tracking and abatement management. A second tool, Varonis DatAdvantage, has been implemented to monitor file usage activity, user access rights to file servers, and shares across the agency. Additionally, DWD has embarked on an ambitious project to bring its Uplink system into a firewalled, protected zone on the state’s network. This will bring the entire Uplink system into compliance with the Defense Information Systems Agency (DISA) Security Technical Implementation Guides (STIGs). DWD has made significant progress in this initiative, both the A-Track and B-Track, for both development and QA database servers are in full operational, day-to-day use. Supporting systems for production batch scheduling and file transport have been moved to the protected zone and thoroughly tested. The Stage pre-production, 2-node database RAC servers have been tested and are in full operational, day-to-day use by September 30, 2019. The production 2-node database RAC servers were unit and regression tested in October 2019 and are in full operational use beginning in December 2019.  The cutover to Stage and production have been delayed in support of other state-level initiatives related to security improvements and in support of high priority DWD business needs to enhance the functionality of the Uplink system. All databases in all Uplink environments utilize Oracle Advanced Security for encryption of both data-at-rest and in-transit.