October 14, 2011

Areas of focus: Benefit Year Earnings Separation Issues The State of Delaware’s “Action Plan” to reduce the incidence of improper UI payments, concentrating on the two areas of focus, is comprised of two basic components: 1. Education: a. Continuous staff training b. Outreach efforts to claimants and employers 2. Operational/ System enhancements 2

STRATEGIES : Provide refresher and continuous training for local office claims processing staff on specific questions to ask claimants concerning the reason for their separation. Develop and distribute a reference guide to front line claims staff as a “self-help tool” of what questions to specifically ask claimants when taking a claim. Develop a worksheet to add to the UI guide and distribute to front line staff to help claimant’s better understand how/when to report wages. 3

STRATEGIES: Place a hold on a week claimed and mail a letter to claimants who work during the first compensable week and do not report wages. Mail a letter to both claimants and employers at the same time when a “HIT” is discovered on the National Directory of New Hire [NDNH] and State Directory of New Hire [SDNH]. Place a hold on the claim. Benefit Payment Control Unit [BPC] will issue a determination of eligibility. Compose an informational brochure and poster to educate the claimants on wage reporting. Develop a PowerPoint presentation to inform claimants of the UI process including reporting wages to be displayed on TV’s in each local office. 4

STRATEGIES: Educate employers on the importance of completing the separation information form, NDNH, SDNH and quarterly cross-match forms accurately and timely. Add message to the IVR system explaining to claimants how to report wages and consequences of not properly reporting wages. Review and enhance the procedure manual for setting- up/processing overpayments. 5

STRATEGIES : Implement SIDES [State Information Data Exchange System]. Add full page in the UI guide explaining the law and claimant benefits rights and responsibilities. Hire contractual staff to assist BPC with conducting basic initial fact- finding interviews with claimants after there is a “hit” with the NDNH. 6

7 ACTION STEPS: Provide refresher and continuous training and work with front line and BPC staff on wage reporting when a claim is taken or information is received on cross-match or new hire response. Develop a “cheat sheet” of questions to be asked or information needed when a claim is taken or information is received on cross-match or new hire response. A wage/earnings calendar has been developed and inserted into the UI guide and distributed to local office staff to better explain to claimants how/when to report earnings. Streamline BPC overpayment review process and reorganize BPC staff to work activities to match their expertise.

8 ACTION STEPS Our system will be modified so that whenever a claimant, who works during the first compensable week and does not report wages when claiming that week, will be issued a letter and the payment will be put in “pending” status until the claimant contacts the division. Mail a letter to both claimants and employers at the same time when a “HIT” is discovered on the NDNH and SDNH. Place a hold on the claim. BPC will issue a determination of eligibility. Compose an informational brochure and poster to educate the claimants on wage reporting. Also, added a full page to the UI guide explaining the importance of wage reporting. Review and enhance the procedure manual for setting-up/processing overpayments.

ACTION STEPS Compose a letter to send to employers to educate them on the importance of completing the separation information form, NDNH, SDNH and quarterly cross-match forms accurately and timely. A message will be added to the current IVR system explaining to claimant’s how to report wages and the consequences of not reporting them properly. Also, make the questions on the IVR more user friendly so claimant’s better understand the wage reporting process. Add information on wage reporting to the Division’s website. The Division will implement SIDES [State Information Data Exchange System]. Funding received to hire contractual staff to assist BPC. 9

ACTION STEPS BPC is currently collaborating with the US Department of Labor, Office of the Inspector General [OIG], investigating fraud cases where a claimant has an existing overpayment balance of $10,000 or more, has not filed for bankruptcy, has no civil action pending and has made no payments to the balance. The OIG is prosecuting claimants for federal felonies including mail and wire fraud. After initially investigating 15 cases the OIG and BPC have successfully prosecuted 8 cases and made payment arrangements on the 7 remaining cases. On an annual basis BPC and the OIG will be reviewing additional cases for potential prosecution and the recovery of overpaid funds. 10

Communications Strategies: CLAIMANTS In order to better communicate wage information to claimants the Division is going to distribute a wage brochure at the claims counter when a claim is taken and add a full page to the UI guide explaining wage reporting. Additionally, posters explaining wage reporting will be prominently displayed in each office. Add wage reporting information to the Division’s website. The Division is also working on a PowerPoint presentation explaining the UI process, including wage reporting, to display on the TV’s in each local office. EMPLOYERS In order to better communicate with employers the Division is going to send employers a letter explaining the importance of submitting accurate and timely information on NDNH, SDNH, quarterly cross-match and separation information. 11

Communications Strategies, Continued UI STAFF: In order to better communicate with UI staff the division is going to conduct refresher and continuous training. Distribute a “cheat sheet” with specific questions for front line staff to ask claimant’s regarding wage reporting and/or their separation from employment. Develop an “e-newsletter” to keep staff abreast of policy/procedure changes and updates. Review and enhance the procedure manual for setting-up and processing overpayments. 12

Fourth Quarter 2011: Composing of letters, full page instructions in UI Guide and script of questions. Refresher training will be set up and conducted. Information on wage reporting will be provided to claimants and added to the division’s website. Working with BPC manager to review and enhance procedures. Changes in automated system to put a hold flag on claims as a result of NDNH and SDNH “hits” and for not reporting wages in the first compensable week. Hire contractual staff to assist with BPC conducting basic initial fact-finding interviews with claimants after there is a “hit” with NDNH. 13

ongoing: Completion of Power Point presentation explaining to claimants the UI process. Implementation of SIDES [State Information Data Exchange System]. Redesign IVR system to better explain to claimants how to report wages and consequences of not properly reporting wages. 14

It is Delaware’s plan to a work diligently to improve the detection and prevention of overpayments in an overall effort to reduce the improper payment rate. We will identify and recommend changes as needed on an ongoing basis from the creation and implementation of our plan to what will be an ongoing project. We will strive to provide education of the program requirements to both claimants and employers. Additionally, we will offer continued training to all of our staff, most importantly our front line and BPC staff. We will stay abreast of information provided by other states as to their positive efforts and results, and share with them and USDOL ours as well. As the saying goes “it takes a village to raise a child”, it will truly be the team effort of a dedicated team to create positive results. We are ready to be that team. We may be small, but we are ready to work towards big results. 15