Unemployment Insurance Program

III. State Plan Narrative

Division of Unemployment Insurance

Maryland Biennial State Plan Narrative

SQSP Federal Fiscal Year (FY) 2020

DAYNE M. FREEMAN,

DUI ASSISTANT SECRETARY

1100 N. EUTAW STREET

BALTIMORE, MARYLAND 21201

A. Overview

1. State priorities and the strategic direction the state has adopted to ensure continuous improvement.

Improving State Capacity to Administer and Operate the UI Program Effectively  

The Maryland DUI Program is a solid and mature functioning program. In ongoing efforts to administer and operate program effectiveness, much of DUI’s focus will continue being devoted to the UI modernization project, Reemployment BEACON. The system, which has steadily been developed to replace the legacy system, is well underway and slated for deployment Q1-2020.  With implementation, BEACON will streamline operations, increase data accuracy, facilitate real-time data sharing, eliminate manual labor intensive processes, automate current business processes, and most of all, improve overall customer service to Maryland stakeholders (i.e., employers, job seeker-claimants, and partners). DUI’s Program Management Office (PMO) is the backbone of Reemployment BEACON and is ensuring that every program change, functionality and system enhancement is managed and implemented effectively.

Over the biennial period, Maryland DUI is also committed to the following areas to ensure performance improvement: (1) intensive staff development training for effective BEACON utilization, (2) System Connectivity between Workforce and UI to reduce the benefit duration and exhaustion rate,  (3) improved reemployment outcomes by educating claimants on work search requirements and making claimants more accountable from the onset of the initial claims process (4) reduction of the improper payment rate through prevention, detection and aggressive recovery efforts, (5) federal compliance and improving program performance to meet and surpass USDOL’s acceptable levels of performance, and (5) continuing to provide excellent customer service to stakeholders. 

Maryland DUI continues to maintain a healthy trust fund balance of $1,317,545,821.06 as of June 30, 2019.  Total contribution deposits are $372,736,254.13 and the total UI benefits paid as of quarter ending June 30, 2019 are $291,127, 372.82.

Trust Fund Solvency

Total Contribution Deposits: $372,736,254.13

Total UI Benefits Paid: $291,127,372.82

Total Fund Balance for June 30, 2019: $1,317,545,821.06

For the fourth consecutive year, the trust fund balance on September 30th of the immediately preceding calendar year exceeded five percent of the total taxable wages in covered employment for the four completed calendar quarters immediately preceding September 30th, triggering application of Maryland’s Table A (the lowest rate range) of the Table of Rates in computing the assigned earned rate of contribution for employers. For additional information, see the section within this biennial - Other (e.g., approach to maintaining solvency, requests for technical assistance).

2. Assessment of past performance and expected future performance. Includes, at state discretion, a discussion of external factors that may have performance implications.

Assessment of past performance revealed the following primary factors contributed to overall program operations and performance:

Legacy IT Systems - The Maryland Automated Benefit System (MABS) and Tax system were built in the 1980s and upgraded in the 1990s as separate and distinct mainframe systems. In addition, DUI’s third system, Appeals, is incompatible with modern operating systems. As a result, Maryland’s IT systems are not integrated. Along with aging technology, programming, navigation and data sharing across platforms became increasingly difficult within the Division.

The Need for New Technology Solutions – With increasing demands for IT to program changes across legacy mainframe systems, the need for new technology solutions became apparently unavoidable. Hence, Maryland DUI began the task of replacing its outdated legacy mainframe (2014) to a fully integrated Benefits, Tax and Appeals System; furthermore, a system designed to be more intuitive, easily navigated, and flexible enough to support changes in laws and/or state policies. To present, countless hours have been spent in developing, programming, testing and ensuring operational functionality of the upcoming UI system, Reemployment BEACON. Full implementation of the BEACON system will not be deployed until all functionality is completely operational.  The anticipated timeframe is currently slated for Q1-2020.  In addition, Maryland DUI is upgrading its outdated Interactive Voice Response (IVR) telecommunications system to Voice over Internet Protocol (VoIP) to enhance UI services by phone to claimants (i.e., filing weekly certifications for benefits and obtain essential unemployment information.)

Staffing Challenges - Staffing of critical functions was insufficient due to a loss of key subject matter experts from retirement throughout the Division and employees who transitioned to new employment opportunities within or outside the agency.  Maryland has since restructured operational units, recruited and hired additional staff to fill some positions in critical areas, taken the opportunity to cross train staff, and rewrote job duties to allow for flexibility to move staff to the area of greatest need. A viable succession plan is also being developed by Maryland’s Tax (Contributions) Operations Team. 

Expected Future Performance:

To ensure program integrity, quality service delivery and performance improvement,  Maryland DUI will continue to infuse metrics-based management, accountability via data driven performance, staff training and development, core work behavior values, ongoing process review, along with identification and incorporation of best practices in collaboration with USDOL.

Improving Prevention, Detection and Recovery of UI Improper Payments

Maryland was identified by USDOL as a “high-rate/high-impact state” due to an improper payment rate currently at 21.66 percent. Maryland is working to aggressively reduce improper payments to ten percent or less. The following activities have commenced. During May 2019, Maryland DUI participated in a kick-off meeting with the National Association of State Workforce Agency (NASWA) UI Integrity Center team. Thereafter, the Maryland team participated in a series of on-site State Intensive Services from July 23, 2019 to July 26, 2019. Maryland’s team of subject matter experts were comprised of staff from the following areas:  Administration, Benefit Accuracy Measurement (BAM), Benefit Payment Control (BPC), Policy, Benefits (i.e., Claims and Adjudication), Workforce Development, Reemployment and Trade Unit, Program Integrity, and the Communications and Training Unit. The Maryland team engaged in a series of in-depth, open and honest discussions with NAWA’s team of instructional design and behavioral insight specialists. Specific topics discussed included:

•           RESEA/ROW Experience

•           Life Cycle of a Claim

•           BAM Data Review

•           BPC Operations

•           Staff Development/Training

•           Eligibility and Compliance Messaging

The goal of the on-site visit is to ultimately reduce Maryland’s improper payment rate, specifically focused on the root cause of work search and benefit year earnings’ errors. The on-site visit is to be followed by draft recommendations for the areas mentioned above. Maryland DUI Administration will then finalize NASWA’s recommendation into a Rate Reduction Plan. The full plan will be outlined in Maryland’s next SQSP quarterly submission.

In addition to the forthcoming Rate Reduction Plan, Maryland has developed detailed strategies to address improper payments within the Integrity Action Plan, along with the following:

Work Search Actions:

Claimants will be required to search for work via the MWE - Reemployment Exchange (REX) System. MWE is an online tool that serves as DWDAL’s official labor exchange system for the State of Maryland and has the capacity to automatically validate weekly work searches performed online. With over 30,000 citizens filing UI claims each week, this is the best methodology to validate weekly work searches in that it is impossible to manage this process manually.

Work Search Policy:

Maryland’s current work search policy is being revised to include additional activities conducted through the DWDAL that will count towards work search requirements.

Claimant Messaging:

Clear and targeted messaging to inform and educate claimants on their weekly work search requirements and penalties for failing to adhere to the requirement are being implemented. 

Reemployment BEACON Implementation:

The implementation of RE-BEACON will help alleviate many of the root causes of improper payments (e.g., BYE,) unrelated to weekly work search errors.

Suspicious Actor Repository (SAR):

Maryland will continue to utilize the Suspicious Actor Repository (SAR). Participating states upload data related to suspicious activity focusing on identity theft to a centralized database. States are then able to cross-match live claimant data against data submitted by all participating states to identify potential identity related fraud cases.

Prisoner Cross Match – Appriss Services:

Maryland will continue utilizing SBR funds, until liquidated, to maintain DUI's current contract with the vendor, Appriss. Appriss provides cross-match services to Maryland DUI by processing state claim records against nearly 2,500 monitored incarceration sources that comprise approximately 80 percent of all incarcerations in the country.  Appriss collects near real-time incarceration data from these sources; performs network analysis to enhance identity verification; and cross references state records on a weekly basis to identify claimants who are likely to have been incarcerated while filing for benefits. The DUI then develops internal reports to further reduce false positives and investigates claimants suspected of filing while incarcerated.

Prisoner Update Processing System (PUPS):

Maryland is still working with the Social Security Administration (SSA) to obtain approval for using their Prisoner Update Processing System (PUPS) to allow Maryland to identify those in prisons and other penal institutions who may have filed UI claims and/or have collected UI benefits fraudulently with assistance of another. Once Maryland is approved, PUPs will be utilized as a second resource for incarceration data for detection and ultimate recovery of improper payments. PUPs is a free resource for all states.

National and State Directories of New Hires:

Maryland continues to identify improper payments as DUI gets matches from the weekly National Report of New Hires (NDNH) and the State Report of Hires (SROH).  Claimants are sent notification of the report of hire from both NDNH and SROH and given the opportunity to dispute the report before any action is taken to create an overpayment or deny benefits.  Request for weekly earnings are sent to the employer for any weeks filed from the week in which the first day of work occurred. This process allows for earlier detection of improper payments and ultimate recovery.

*See the Integrity Action Plan Narrative for full details of all integrity efforts.

Improving Program Performance Nationally

Maryland DUI continues to seek guidance and utilize technical assistance provided by USDOL’s National and Regional offices. Benefit Accuracy Measurement (BAM) staff is working with the Region to aggressively correct the root causes of improper payments for Maryland, which is also a contributing factor to performance nationally.

The BAM Program plays a major role in identifying errors in the entire claims process and the accuracy of benefit payments. Additionally, the Benefit Timeliness & Quality (BTQ) program identifies the quality of non-monetary determinations (i.e. all issues detected on eligible unemployment claims) and the timeliness of determinations rendered (i.e. the decision must be rendered to the claimant within 21 days from the issue detection date (IDD) and within 14 days when payment is due.

Out of the top three root causes of improper payments nationally (i.e. work search, benefit year earnings and separation errors), work search errors continue to be the primary root cause of improper payments for the State of Maryland. The work search errors rate is currently 65.0 percent in Maryland and is the largest contributing factor to the 21.66 percent improper payment rate.

* See Maryland’s FY2020 Integrity Action Plan Narrative which outlines proposed corrective action steps to reduce work search errors.

Additionally, Maryland’s BAM and BTQ units are continuing cross training and quarterly rotations to collaboratively identify and correct systemic and programmatic errors found during reviews.  While utilizing the UI Benefit Operations State Self-Assessment Tool issued by USDOL and designed to support UI process improvements, it was determined that further staff guidance is needed in the areas of issue detection dates, quality fact-finding, and effective time-management for prompt completion of determination cases.  As a result, BTQ recently completed training materials and guides during Q3-2019 to assist staff in improving areas of deficiency.  Live training and dissemination of materials commenced during Q4-2019.  DUI expects significant improvement in the reduction of errors detected by BAM and the reducing the overall improper payment rate.

WIOA

Maryland DUI in conjunction with DWDAL is actively engaged in the execution of the WIOA signed into law July 22, 2014 and effective July 1, 2015. Under WIOA, the UI program is vital to Workforce and Maryland is connecting UI claimants early from the onset of their claim to a full range of reemployment services offered through Workforce Development’s AJC and their MWE online labor exchange system.

Maryland’s AJCs are conveniently located throughout the State and are fully equipped with Internet access, computer stations, printers, copy and fax machines, telephones, resource libraries and more. Maryland’s customer-driven reemployment-related services are designed to assist all job seekers regardless of their status to quickly return to the labor force. Services include reemployment workshops, labor market information, skills assessments, consultation and career guidance, career exploration and planning, training programs, apprenticeship programs, adult and family literacy programs, resume development, job search strategies, employer recruitments, job matching, job referral and placement assistance, including other supportive services.

Jobseekers and employers can access the MWE - Virtual One Stop (MWE-VOS) System which is an online web-based resource. MWE-VOS can also be accessed within the AJC, from an individual’s personal computer, or via mobile application. The mobile app was made available for users to download to their smart phones, tablets and other devices; to search jobs by locations or keywords; to filter job searches and set up job alert notifications announcements. By utilizing MWE-VOS employers can post job announcements, manage job openings, and pre-screen applicants at no cost any time day or night. MWE provides a wealth of comprehensive information that UI claimants can use in their job search efforts, including electronic connection to agencies, programs, services, education, training and much more.

Maryland DUI provides meaningful assistance through daily feedback, on-going instruction, guidance and periodic training to Workforce Development Staff, UI claimants and essential partners pertaining to mandated reemployment programs and other relevant services (i.e., RESEA, ROW, including Trade Adjustment Assistant (TAA), Reemployment Trade Adjustment Assistance (RTAA), Additional Training Benefits (ATB) and Work Sharing). 

DUI continues to collaborate with DWDAL to ensure claimants’ ongoing eligibility, compliance, and return to work efforts through multiple services which include: registration in the MWE System, required reemployment workshop attendance and completion in the RESEA program or the Maryland State Reemployment Opportunity Workshop referred to as ROW, required weekly work search activity (i.e., at least three work search contacts per week), eligibility reviews, detection of potential issues, fact-finding interviews, and adjudication of issues as required.

In addition, DUI and Workforce have been steadily working to effectuate enhanced service delivery approaches, additional reemployment activities throughout the claims series, universal dissemination of work search requirement information; and prompt response to claimant UI-related questions, concerns and challenges. UI claimants are provided with direct access via DUI inquiry lines to speak directly to a UI representative or subject matter expert to obtain answers to claims and benefit-related questions or concerns. Maryland DUI anticipates quicker reemployment outcomes as DUI implements these and other viable reemployment solutions, including the integration of the MWE-REX system to the upcoming UI System, Reemployment BEACON, slated for deployment during Q1-2020. The integration of Workforce Development’s MWE-REX System to BEACON will provide ongoing real-time feedback electronically between critical programs and platforms pertaining to UI claimants and employers.  For further details see the section - Reemployment of UI claimants.

Reemployment of UI Claimants

Maryland DUI’s mission is to “Put People Back to Work as Fast and Efficiently as Possible.” To support the mission, during 2016 the Division restructured and shifted the overall operational focus from strictly unemployment to reemployment. DUI goals and strategic initiatives were implemented to ensure the ongoing delivery of quality services to stakeholder claimants and employers.

DUI Mission: To Put People Back to Work as Fast and Efficiently as Possible

DUI Goal: Improve the Business Climate

DUI Strategic Objective: Foster a Business-Friendly Environment

DUI Goal: Drive Employment

DUI Strategic Objective: Serve as a Bridge to Reemployment

DUI Goal: Provide Excellent Customer Service

DUI Strategic Objective: Make Timely and Quality Determinations

DUI Goal: Foster Employee Engagement

DUI Strategic Objective: Ensure Accurate Employer Wage and Tax Records

DUI Strategic Objective: Prevent Fraud and Minimize Overpayments

DUI Strategic Objective: Deliver Quality Customer Service and Education to Claimants and Employers

Reemployment programs and services for DUI were realigned and integrated under one newly created unit, the first in the Division’s history. Robust reemployment discussions have been initiated and Reemployment Integration meetings conducted in collaboration with Division of Workforce Development (DWDAL) in an effort to break down silo activities, to engage and vocalize concerns, effectuate new strategies, reemployment touchpoints, and activities to impact claimant-jobseekers.

While MWE-VOS serves as a powerful job search engine and resource tool allowing jobseekers /UI claimants access to local, regional, statewide, and national job openings, Maryland Reemployment was awarded additional grant funds to establish an efficient and effective reemployment solution to link/integrate DUI and DWDAL’s IT systems, as the existing systems are not able to provide seamless connectivity for real-time exchange of critical information. Maryland identified and secured an effective reemployment solution, the Reemployment Exchange (REX) Module, developed by Geographic Solutions, Inc.

REX is a powerful integrative UI/Workforce IT tool that provides an extensive host of reemployment services to claimants and employers; all designed to help employers identify skilled job-seekers and facilitate quicker return-to-work results for claimants. The REX Module is comprised of progressive functionality components designed to help boost service delivery efforts and facilitate the ultimate sharing of real-time information between staff and systems. REX will immediately display suitable job openings to claimants that closely match their recent/ past employment, educational background, desired occupation and skill set; automatically create a reemployment roadmap designed to help the claimant obtain employment; display real -time labor market information  to help claimants make intelligent decisions; provide claimants real-time access to a comprehensive list of job openings repeatedly upon entering the system; allow claimants to enter job search contact information within the system; send system-generated alert notifications to claimants when they are not meeting work search requirements/established thresholds; monitor and notify claimants as to whether they have an active online resume and virtual recruiter; and allow staff to view claimants’ ongoing work search status.

The REX integration project involves two phases. The Maryland Reemployment team spearheaded Phase 1 of this labor intensive project. For Phase 1, REX module screens were added to DWDAL’s existing MWE-Virtual One–Stop operating system. Phase 1 functionality enables UI claimants to log-in to the system and enter their required number of valid job contacts (i.e. at least three per week) on the REX Work Search Verification log as a permanent retrievable record after filing their weekly claim certification with DUI. REX displays a new reemployment strategy weekly after the required work search contacts are entered as complete. With the Division’s collective efforts, Phase 1 of the Reemployment Exchange (REX) module was successfully implemented on December 31, 2017.

Phase 2 involves integration of the MWE-REX module to DUI’s BEACON System. This will allow critical data to be exchanged in real-time seamlessly between systems and for all users (i.e., claimants, employers and staff) to move seamlessly within the required workflow of both systems without having to log out and re-log in for each occasion. This single sign-on token exchange functionality will be critical for UI claimants needing to complete their weekly claim certification, their work search verification process and other required UI/reemployment activities for payment of benefits. DUI’s BEACON System will establish a viable feedback loop for the UI program and provide real-time transmission of claimant work search activity between systems. Phase 2 of REX is slated with the implementation and deployment of Reemployment BEACON duringQ1-2020.

In addition to system integration activities for enhanced delivery services to claimants, Maryland DUI is establishing new work search requirements and working with DWDAL to implement additional reemployment touchpoints activities with system alert notification reminders throughout the claims series (beyond the required mandated RESEA and Maryland ROW workshops) to hasten the claimant’s return to work efforts. Maryland DUI will require UI claimants to not only enter their work search contacts but to conduct at least three (3) required work search contact activities in the MWE-REX System which REX will document and retain as a permanent record. After the 8th consecutive paid week of benefits, including TO claims, the minimum work search contact requirement will automatically increase from three (3) to five (5) work search contacts per week to increase UI claimants’ opportunities for becoming reemployed.

Maryland anticipates the implementation of BEACON, along with Maryland’s work search requirements and reemployment touchpoint activities will allow the Division to fully attain the mission, goals and services.

Improving Data Validation and Federal Reporting

Maryland DUI utilizes Data Validation (DV) to validate the accuracy of UI required reports (UIRR). Currently, Maryland’s Reported and Validated counts failed to meet the two percent passing range of USDOL’s acceptable level of performance (ALP).  Some causes of the failing populations include: data entry errors, coding errors, incorrect timeframe in which data for reports are compiled, and failing to run UIRRs and data validation extract files simultaneously. 

Corrective steps have been implemented by Maryland to bring the Data Validation Program within compliance to USDOL’s ALP. These steps include: (1) meeting with Unit Supervisors to discuss the importance of staff accurately entering data codes in the system, (2) meeting with reporting staff to ensure the correct totals are entered in the SUN System, (3) and submitting a Work Order Request to Information Technology to request changes to the Data Validation Program (i.e., running the UIRRs simultaneously with the Data Validation reports).

It is important to note that every recommendation does not necessarily correct the problem on the first run. However, these processes have decreased the “Difference Percentages” on the Report Validation, bringing several Populations within ± 2 percent passing range.  These strategies proved effective in improving Data Validation performance for other failing populations (i.e., Benefit Populations 1, 4 and 6 and Tax Populations 1 and 4). This will result in an ongoing process until the issue is permanently resolved. The Data Validation Coordinator will continue to utilize the aforementioned processes and Maryland DUI anticipates steady improvement for Benefit Population 3, Tax Population 2 and Module 4 (Successor).

Addressing Worker Misclassification

Maryland DUI has a proven history of quality audit results. The Division has passed the national review of field audits for Tax Performance System (TPS) standards over the past ten years and met or exceeded the national minimum scores for USDOL Effective Audit Measures (EAM) for the past three years.  During 2018 through June 2019, the Tax Field Audit Unit discovered and converted 13,669 misclassified workers to employee status. Through these audits, tax agents added $171.6 million in unreported wages and $1.39 million in additional tax revenue to the Trust Fund.

In addition, during 2018, Maryland DUI enhanced its strategic audit assignment selection method alongside the improved tax audit system to ensure continued audit effectiveness and quality results, thereby meeting and exceeding USDOL’s acceptable level of performance (i.e., pass 4 factors/score > 7) for Effective Audit Measures.  In an effort to foster a positive business climate in the State, the Division sponsored a bill which was enacted as Maryland UI Code Section 8-604 effective October 1, 2017. The new law provides businesses with more time and an additional level of appeal to the Lower Appeals Division to pursue protests of audit findings. DUI continues to educate Maryland employers on the UI Law of covered employment in an effort to improve their compliance and provide excellent customer service. 

UI auditors have also worked in the context of the Workplace Fraud Act. UI auditors conduct workplace fraud audits following receipt of complaints from the general public, department inter-office referrals, and information sharing from the Joint Enforcement Task Force and other taxing authorities related to suspected workplace fraud.  In collaboration with Task Force member agencies, UI auditors perform joint audits with auditors from the Division of Labor and Industry and the Comptroller’s Office. These data driven audits are performed in industries with a history of large numbers of misclassification issues based on historical data, and on employers with disputed benefit claims resulting from workers misclassified as independent contractors.

Incorrect Recording of Issue Detection Date

For this FY20 biennial period, Maryland DUI fell below USDOL’s acceptable level of performance for the UI measure, “Incorrect Recording of Issue Detection Date.” The required ALP is 95 percent, however Maryland rated 84.2 percent. Analysis of this measure, reveals that additional focus is needed in the area of scheduling non-monetary appointments with timely completion. To meet the ALP measure, Adjudication Supervisors will devote additional time to ensure timely completion of cases and the Coordinator of BTQ will monitor the scheduling of issues and timely completion on a weekly basis utilizing the ETA- 9052 Non-Monetary Determination Time Lapse by Detection Date Report.

3. Coordination with other plans, including WIOA.

Most recently during July 2019, Maryland DUI collaborated with NASWA Integrity Center’s team of subject matter experts and participated in an on-site assessment with a series of discussions and recommendations designed to improve UI programs and services to stakeholders. DUI will continue their dialogues, as they works to improve program accountability and performance efforts.

For full details, see Improving Prevention, Detection and Recovery of UI Improper Payments within this Biennial State Plan Narrative.

Maryland DUI continues to address the WIOA provisions relative to the operations of the UI Program.  For full details on how Maryland DUI is addressing provisions within WIOA, please see both sections within this Biennial State Plan Narrative -Reemployment of UI Claimants and Workforce Innovation Opportunity Act (WIOA).

B. Federal emphasis (GPRA goals), if required

1. Maryland performance compared to the GPRA goal:

2. Actions planned to achieve GPRA goals and targets.

GPRA – Percent of Intrastate Payments Made Timely

Maryland FY20 performance level for this measure is 91.69 percent. The GPRA goal was exceeded by 2.36 percent. DUI is committed to maintaining compliance for this measure. Contributing factors to sustain this improvement include:

•           Reducing Backlogs – Reducing pending backlogs by utilizing Claims and Adjudication Center supervisory staff with claims processing

•           Metrics-Focused Reports – Utilizing appropriate metrics to track and monitor first pay timeliness

•           Case Aging Reports – Monitoring case aging reports to ensure non-monetary determinations are completed timely

•           Root Cause Analysis – Determining the root of claims not processed within the 21 day requirements

•           Staff Development – Educating claim center staff on federal reporting requirements to better understand the impact that improper payments have on the integrity rate

GPRA – Detection of Recoverable Overpayments

Maryland FY20 performance level for this measure is 44.47 percent. Maryland failed to meet the GPRA goal by 10.03. DUI attributes this primarily to both a loss in management and frontline staff. The Benefit Payment Control Unit is currently re-staffing and anticipates six (6) new hires by the end of the 1st quarter of federal FY 2020, with comprehensive training to follow. In addition, Maryland began expanding quarterly cross matches during quarter ending 6/30/2019 in order to detect additional overpayments. These actions should result in significant improvements for the GPRA measure.

GPRA - Percent of Employer Tax Liability Determinations Made Timely

Maryland FY20 performance level for this measure is 87.50 percent. Maryland missed the GPRA goal slightly by 1.5 percent. DUI attributes this to a decrease in staffing levels. To meet the GPRA target, the Tax Unit began streamlining procedures for non-liable determinations during the end of June 2019 in order to establish employer accounts in a more timely manner. In addition, with the deployment of the Reemployment BEACON system (slated for Q1-2020) employers will be able to register and establish new accounts on the same day. Once this new functionality is implemented, DUI anticipates exceeding the GPRA target.

C. Program Review Deficiencies

Maryland DUI completed all required reviews and activities:

•           All Internal Security Reviews/Security awareness training has been conducted for DUI staff

•           The BAM Unit is currently in compliance with all State and Federal measurements.

•           The Tax Performance System (TPS) annual report for 2018 was completed and submitted timely.

D. Program Deficiencies

There were no program deficiencies identified through Internal Security reviews or the TPS reviews.

E. Reporting Deficiencies

Maryland’s reporting deficiency for this biennial submission is pertaining to the ETA-9049 – Profiling and Reemployment Services Outcomes Report that captures the outcomes of reemployment service activities of claimants identified as likely to exhaust their UI benefits. The report is generated quarterly with populated data directly from Division of Workforce Development. The ETA-9049 reports in question were provided to DUI timely from DWDAL, however Q1-2018, Q2-2018, Q3-2018, Q4-2018, Q1-2019 and Q2-2019 reports were not submitted within the SUN System. The due date is by the 20th of the following month as required by USDOL. Maryland DUI has taken immediate corrective action for the missing reports and actions to prevent future occurrences of any potential reporting deficiencies. As of 8/30/2019, all missing quarters for 2018 have been entered in the SUN System. ETA-9049 Reports for 2019 -Q1 and Q2 will be entered by the end of the first week in September 2019 (i.e., 9/6/19), as these quarterly reports can only be entered sequentially. Effective 8/30/2019, Maryland DUI has established two additional (2) Federal Report Liaisons to ensure timely submission of ETA report submissions in the SUN System.

F. Customer Service Surveys (optional)

Maryland has no survey data to report for this submission.

G. Other (e.g., approach to maintaining solvency, requests for technical assistance)

Maryland has implemented strategies to grow the trust fund in an attempt to meet or exceed the solvency and tax maintenance requirements to be eligible for interest free borrowing in accordance with  20 C.F.R. §606.32.  In 2016, §8-612(f) was added to Maryland’s Unemployment Insurance Law requiring continuing applicability of the Table of Rates in effect for the immediately preceding calendar year for any calendar year beginning on or after January 1, 2017, if: (1) the trust fund balance on September 30 of the immediately preceding calendar year was at a level that would result in a Table of Rates that had lower rates being applied, and (2) the federal funding goals requirement in 20 C.F.R. §606.32 were not met as of December 31 of the second immediately preceding calendar year.

Maryland continues to aggressively collect overpaid unemployment benefits and delinquent employer taxes, and has worked to develop strategies to reduce the improper payment rate (as mentioned more specifically in areas of this plan).  Maryland also continues to effectively audit employers to identify misclassified workers.  The trust fund is strengthened as a result of these efforts.

Maryland routinely seeks guidance and/or technical assistance from the National and Regional USDOL Offices, and periodically with the National Association of State Workforce Agencies (NASWA) UI Integrity Center. DUI will continue their dialogues, as they work to improve program accountability and performance efforts.

H. Assurances

Per UIPL 15-19, by signing the SQSP Signature Page, Maryland Department of

Labor certifies that it will comply with the assurances Listed in Handbook 226,

18th Edition, Change 4. Maryland Department of Labor will institute any plans or measures necessary to comply with the requirements.

UIPL 15 requires information for Assurances “h” (i.e., Assurance of Contingency Planning) and “j” (i.e., Assurance of Automated Information Systems Security).

The following are the dates for which Maryland’s Information Technology (IT) Contingency Plan, Risk Assessment and System Security Plan were implemented, tested and reviewed/updated:

h. Assurance of Contingency Planning

•           Information Technology (IT) Contingency Plan Implemented: 11/2003

•              IT Contingency Plan Reviewed/Updated: May 2019

•              IT Contingency Plan Tested: June 2019

j. Assurance of Automated Information Systems Security

•              Risk Assessment Conducted: May 2019

•           System Security Plan Reviewed/Updated: April 2019