Located in:
- Unemployment Insurance (UI)
(OMB Control Number: 1205-0132)
The Unemployment Insurance (UI) program requires a State Quality Service Plan (SQSP) on a 2-year planning cycle that is a condition of receipt of administrative funding to administer the program. The SQSP is the State’s UI performance management and planning process that allows for an exchange of information between Federal and State partners to enhance the UI program’s ability to reflect their joint commitment to performance excellence and client-centered services. A formal two-year SQSP is submitted biennially. On the off years, States may be required to modify the SQSP with additional corrective action plans and narrative if they are failing any new performance measures, and they are required to provide updated budget documents, certifications, and assurances. ETA Handbook No. 336, 18th Edition provides detailed guidance for the preparation and submittal of the SQSP and supplemental guidance is provided in an annual UIPL, issued as UIPL 15-19 for the FY 2020 SQSP. The Social Security Act (SSA) sections 302 and 303 authorize the Secretary of Labor to provide funds to administer the UI program and govern the expenditure of those funds. States that choose the option to include UI in a WIOA Combined State Plan will be required to submit their SQSP through the Combined State Plan process. The SQSP must be prepared in accordance to the instructions in ET Handbook 336, 18th Edition and there are no changes to the established SQSP cycle if a State chose to submit their SQSP through the Combined State Plan process.
- a. Contents of a Complete UI SQSP Package
A complete UI SQSP package includes the following documents, as described in Chapter 1, ETA Handbook 336, 18th Edition:
- a. Contents of a Complete UI SQSP Package
a. 5. UI Program Integrity Action Plan (UI IAP)
The UI IAP outlines the strategies the State will undertake during the planning period regarding the prevention reduction and recovery of UI improper payments.
Current Narrative:
V. UI Integrity Action Plan (IAP)
Maryland’s Integrity Action Plan (IAP) Narrative for Biennial State Plan FY2020
Maryland DUI is implementing the following current and proposed Integrity efforts to address its top three root causes of improper payments: Work Search Errors, Benefit Year Earnings (BYE) and Separation Issues.
Work Search Errors - 65.0 percent
Maryland will continue to utilize the Reemployment Exchange (REX) Module housed within DWDAL’s MWE System. The REX solution is designed to provide claimants all the tools needed for success in landing a suitable job. REX will enable agency staff to track claimant’s work search efforts, evaluate the claimant's work status against thresholds set by DUI (i.e., at least three work search contacts weekly), and offer reemployment assistance and guidance as necessary. DUI will continue to monitor feedback from the Claim Centers and BAM staff to update instructions on how to complete work search screens in REX.
The MWE-REX system will assist with the agency’s ability to verify work search contact entries. It will notify the agency when a claimant is not seeking work, placing restrictions on their availability to work or has other barriers to employment. This will allow for the timely resolution of issues detected early in the claims process. While collecting claimants' work search information weekly, REX will monitor and ensure claimants are fulfilling all of their work search requirements while providing labor market information to help claimants become re-employed. Maryland is currently utilizing the REX Module (from phase 1 implementation) to collect claimants work search information.
Maryland will begin receiving real-time updates of claimants’ attendance for required workshops, i.e., the RESEA and ROW.
Phase 2 of REX integration to Reemployment BEACON is anticipated upon full implementation of BEACON during the 1st quarter of 2020.
To increase claimant accountability, DUI will increase the claimant’s awareness of their responsibilities concerning work search requirements. To this end, Maryland DUI is proposing the following:
1. Work Search Accountability:
a. Upon implementation of the BEACON System, all claimants will be required to use the internet to file their weekly certifications.
b. Maryland DUI will require all UI claimants to conduct at least three (3) required work searches in MWE system each week which the REX System will document and retain a permanent record. Claimant’s work searches in REX will be captured at the time they are completed, counted and documented for their weekly claim certification. This will reduce confusion for claimants and their weekly work search contacts will be properly recorded. Both, BEACON and REX Systems will accept attendance in a workshop, reporting to an AJC for additional services, and/or other services through an AJC as a valid work search contact each week.
c. To reduce work search errors, the MWE-REX System will restrict the number of weeks claimants may certify at one time.
d. The System will provide real‐time transmission of work search information from MWE‐REX to BEACON and vice versa from BEACON to MWE‐REX.
e. The MWE-REX System will continue to display a (weekly) reemployment strategy after the work searches have been documented in the MWE‐REX Module.
f. The BEACON System will send triggers to MWE in order for alert notifications (via email /text) to be sent to UI claimants.
g. Maryland DUI will establish fraud penalties more aggressively for false work search contacts.
2. UI Representation at Required Workshops:
Maryland is evaluating the effects of having a UI representative at all RESEA and ROW workshops to explain all work search requirements.
3. New Interactive Voice Response System:
Maryland installed a new IVR system in the 4th quarter of 2019. The new system provides additional messaging via phone to remind claimants of their work search contact requirements and other responsibilities.
4. New Online Integrity Video:
Claimants are encouraged to review the new Integrity Video “Sometimes Good People Make Bad Decisions”, prior to creating a PIN number to file their first weekly claim. Maryland has added the video to multiple pages on the DUI website. In the future, Maryland anticipates embedding the videos in the claims taking process.
4. Additional Work Search Contact Questions:
Work search contact questions have been added to all of the fact finding questionnaires. Whenever an issue is adjudicated, the claimant will be questioned about their work search contacts for previous weeks.
5. New Claimant Declaration Statement to the Web Claim Certification:
We have added a declaration statement for claimants to the web claim certification which reads as follows: “I understand that Maryland Law provides for fines and/or imprisonment in addition to disqualification and repayment of benefits, if I knowingly provide false information in order to obtain benefits. Falsification of my work search information will be considered fraud. I certify that the work search contact information I have provided on this weekly certification for Maryland UI benefits is complete and accurate. The answers to all questions are correct and truthful.”
6. Updated UI Correspondence to Claimants:
DUI is updating all claimant correspondence in preparation for changes related to the new system.
Benefit Year Earnings - 20.52 percent
Current Efforts:
National Directory of New Hires (NDNH):
1. Maryland will continue to use NDNH, quarterly and monthly cross-matches to help detect benefit year earnings. DUI is developing models to detect and prevent overpayments to incorporate in the new UI system, Reemployment BEACON. Additionally, the BPC Unit is addressing staffing issues and is currently in the process of hiring six (6) new staff specialists. This staffing shortage has affected BPC’s ability to address benefit year overpayment issues. To assist BPC, claim center staff is currently handling some NDNH cross-match and fraud issues.
2. A NDNH Congratulations Letter is being revised to incorporate a fraud warning statement.
3. The appointment notice for NDNH issues has been revised to include more information in advance on the possibility of an overpayment and/ or fraud.
4. Maryland DUI is in the process of recruiting a Data Analyst to develop and implement additional analytic tools to enhance fraud detection in the system.
5. Maryland DUI has also added a fraud statement to the internet continued claims filing page. Claimants must certify that they have read and understand the consequences of giving a false statement before they can complete their weekly claim.
Proposed Efforts:
a. Claims will be flagged as soon as there is a hit on the NDNH to stop benefits and force the claimant to call in for assistance in filing their claim. The claimant will then be transferred to a claims examiner who will interview the claimant concerning their employment and completing the claims process.
b. DUI will use additional methods, including the Systematic Alien Verification for Entitlements (SAVE) Program, to block identity thieves from completing claims.
c. Maryland DUI will use predictive analytics to assign a probability-of-fraud to claims.
Separations Issues – 9.35 percent
DUI is also combating Separation Issues by encouraging employers to use the State Information Data Exchange System (SIDES). Maryland employers are redirected to SIDES E-Response when responding electronically to requests for separation information through the Net 207 application. Only Maryland employers with a valid Maryland account number, Federal Employer Identification Number (FEIN), and a pending request for separation will be redirected to SIDES E-Response. All others will continue to be directed to the Net207 application.
Additional Integrity Action Plan Efforts:
Benefit Timeliness & Quality (BTQ)
The BTQ unit continues to review non-monetary determinations for quality fact-finding and timely decisions. BTQ has expanded the review process by reviewing the entire claim (i.e., not solely the final decision) to ensure all potential issues on the claim have been addressed. Problem areas identified by this expanded review process will be reported back to the affected units for training purposes.
Fraud
Maryland DUI has participated in national efforts to address UI fraud resulting from organized identity theft. Designated staff have been given access to the Suspicious Actor Repository (SAR) and utilization is encouraged for information related to fraud cases. BPC, BAM and TAX staff have also attended Fraud Investigator Training offered by the NASWA UI Integrity Center when it was conducted in Baltimore Maryland. Currently, DUI does not have a Data Analyst to fully benefit from the SAR program.
Training
Maryland staff is utilizing training modules located on the UI Integrity Academy for supplemental training for new hires and upgrading skills for current employees.
Training on the new system, Reemployment BEACON, has started and will continue up to implementation slated for the 4th quarter of 2020. This will give staff extra time to become familiar with the new system before it goes live.
BAM
NASWA recommended that BAM institutes utilization of sub-codes, specifically pertaining to BYE (i.e., 100 and 110 ei3 series) and Work Search (i.e., 420 ei3 series) Errors.
Communication
Maryland DUI will use claimant messaging tools provided by the NASWA State Intensive Services Team. The messaging will be modified to match Maryland’s laws and policies on work search and other reporting requirements. The Communications and Training Unit continues to ensure that claimant messaging is clear and concise. DUI's Communications Unit is exploring additional messaging via multiple communication mediums regarding work search requirements, what acts constitute fraud, and the consequences of engaging in fraud. DUI will educate the public on work search requirements through online videos and customer presentations. They will continue to ensure consistency in all platforms of messaging. In addition, they will work with MD Labor webmaster to insert links to all Integrity Videos created by the National Integrity Center of Excellence. Links to Integrity Videos for employers and claimant, created by the National Integrity Center of Excellence, are currently inserted on the MD Labor webpage. This process will be ongoing.
The 2020 Maryland Unemployment Insurance SQSQ UI Integrity Action Plan (IAP) can be found at the following link: http://www.dllr.state.md.us/employment/wioauisqsp.shtml.