1. June 23, 2011

2.  Introduction:  We list the strategies New York has identified for each major area in order of priority.  To meet the proposed USDOL requirement of a 35% reduction of improper payments in 2012, and a 50% reduction in 2013, we will focus on strategies that we can implement quickly.  We will use technology as part of an overall strategy to alleviate workload issues.  As we develop each proposal, we will re-evaluate priorities. 2

3. Benefit Year Earnings  Proposal 1  Root Causes:  Claimants continue to certify for benefits after they start a new job. Claimants fail to report and under-report work from new employment. Some claimants fail to report work until they are paid.  Strategy  The State of New Jersey performs a claim file cross-match against the National Directory of New Hires to detect when a claimant is working. We will implement a similar data- matching program (match reported new hire date at the time a claimant certifies for benefits). This provides a daily cross-match against the new hire database. New York will also explore other up-front data matching at the time of original claim and during the weekly certification process. We also will post messages on the web site and telephone claim system that tell claimants they MUST report a return to work even if they have not yet received a paycheck.  Milestones  Study NJ model  Develop programming requirements  Plan for staff needs  Program  Test  Deploy 3

4. Benefit Year Earnings  Proposal 2  Root Causes  Claimant’s attempt to hide part-time, continuing, or new employment. Some claimants fail to appear for Employment Service (ES) interviews and fact finding.  Strategy  See if we can adjudicate on Failure-to-Report (FTR) the first time they do not show. New York is already doing this as part of its Reemployment and Eligibility Assessments (REA) and we will study the impact to assess the outcome on the larger UI caseload.  Milestones  Develop staff procedures  Update correspondence  Test  Deploy 4

5. Benefit Year Earnings  Proposal 3  Root Causes  Claimants under-report new or continuing employment. Historical data can provide insight into the likelihood of a BYE issue.  Strategy  New York will review claimant information and characteristics in historical data. We will use this evaluation to prioritize the workload. We will determine whether there are patterns of overpayment abuse based on industry, job classification, prior UI history, length of employment, and other indicators.  Milestones  Evaluate existing data  Develop profile based on data  Develop programming requirements  Program  Test  Deploy 5

6. Benefit Year Earnings  Proposal 4  Root Causes  Some claimants do not understand that they must report even part time/occasional work, and fail to report it.  Strategy  Explore legislation that would disregard earnings below a set level.  Milestones  Propose legislation 6

7. Separations  Proposal 1  Root Causes  Employers and agents do not respond to requests for information on time.  Strategy  Implement UI SIDES (programming work under way)  Milestones  Complete SIDES for “additional claims”  Test  Deploy  Program for original claims, other uses  Test  Deploy 7

8. Separations  Proposal 2  Root Causes  Employers and agents fail to respond to requests for information on time.  Strategy  Deploy a real-time Employer Portal (programming work already under way). The portal will give employers a way to provide separation information promptly. We also can use this portal for further fact-finding on claims.  Follow-up with robo calls/e-mails when a claim is filed. Allow automated responses. Tell employers why it is crucial to give separation information right away. Follow up on previous requests. Ensure that all communications are confidential.  Milestones  Complete programming for portal (single sign-on)  Develop staff procedures  Test  Deploy 8

9. Separations  Proposal 3  Root Causes  Individuals try to mask their identity or use identity theft to obtain benefits by fraud.  Strategy  Improve/extend Social Security Number matching against Social Security Administration data. Perform real-time matching (pre-programming work already under way).  Milestones  Complete programming for real-time matching  Develop staff procedures  Test  Deploy 9

10. Separations  Proposal 4  Root Causes  Employers and agents fail to respond timely to requests for information.  Strategy  Review procedures to get better ways of fact finding about separation. Use many ways to get more details from employers sooner. Develop better questions on the Original Claim (OC) and dig deeper. Follow-up with robo calls/e-mails when a claim is filed. Allow automated responses. Tell employers why it is crucial to provide separation data promptly. Follow up on previous requests. Ensure that all communications are confidential.  Milestones  Develop staff procedures  Test  Deploy 10

11. Separations  Proposal 5  Root Causes  Employers and agents do not reply to requests for information promptly. After months of failures to respond, claims are overturned, causing larger overpayment totals.  Strategy  Develop incentives and/or penalties to:  Elicit more timely responses from employers  Review practices and impose penalties when claims are frivolously blocked  Milestones  Propose legislation 11

12. ES Registration  Proposal 1  Root Causes  Claimants do not register for employment services.  Strategy  Not an issue for New York because we automatically register claimants for Employment Service (ES). We have no ES Registration errors. See BYE strategy on FTR for methods to improve reporting for ES services. Refer to BYE Proposal 2 for follow-up on Failure-to-Report.  Milestones  NA 12

13. State Specific  Proposal 1  Root Causes  None noted.  Strategy  80% of overpayments were due to BYE and Separation issues. New York will focus on those areas to address its improper payment rate.  Milestones  N/A 13

14.  Culture of Integrity  We will train staff to understand their role in controlling improper payments. This includes consistent, routine training that helps each staff member address overpayment causes within their control. Doing so builds a culture of integrity.  We will make staff aware of outcome measures by providing data that show goals along with global and individual progress in meeting integrity goals (including metrics by category and global talking points).  The Department will encourage an environment that solicits and welcomes feedback on reducing overpayments, giving staff a way to submit their suggestions and concerns, for management to reply, and for the Department to recognize individuals who make significant contributions.  Deliver global message on importance of integrity and everyone’s responsibilities, and theme for talking points  Develop vehicle for messages  Develop staff procedures  Develop training needs  Develop training plan and goals  Evaluate existing data for reporting  Develop reporting mechanisms 14

15.  Management Strategy  New York will develop a series of metrics along with comprehensive analysis to measure root causes and opportunities for improvement. We will distribute this information to management and our cross-functional team. Information sources will include data from the Office of Special Investigation, the USDOL Benefit Accuracy Measurement (BAM) program, USDOL Benefit Timeliness and Quality (BTQ) reviews, as well as overpayment amounts grouped by type. The cross-functional team will review policies and procedures that may contribute to the overpayment root causes, focusing on prevention. There will be regular cross-functional meetings to review data, discuss strategies, and make recommendations. This will help us analyze root causes and develop solutions to address the causes.  High-level management will oversee and review the cross-functional team’s recommendations. Management will set goals, ensure appropriate corrective actions are taken, and will monitor progress in meeting goals.  Establish cross-functional integrity team  Provide necessary information/data/metrics/tools  Establish steering committee  Establish communication/reporting/and evaluation means and methods 15

16.  Communication Strategy  Overall Message  “Everyone is responsible for integrity: claimants, employers, leaders, staff and the public.”  We will use the following vehicles to send these messages:  Web home page  IVR  Social media  Press  Weekly continuing claims process  Targeted robo calls/e-mails  Questionnaires  UI Handbook, forms and notices  Employer portal  Mailing inserts  Employer registration process  Tax rate notices 16

17.  Communication Strategy  For claimants, messages include:  Give us accurate data on your past and current work status.  Why did you lose your job? Include dates and details.  Do you know what constitutes “work” under the law?  If you lie to obtain UI benefits, you could suffer:  Loss of benefits  Fines  Repayment  Potential criminal action  For employers, messages to be conveyed include:  If you give us accurate and timely information on the time of a claim, it will:  Help keep your experience rate low  Protect your rights  Check your account and your charge statements regularly. This is a key way to control your UI costs.  For State UI staff, messages to be conveyed include:  Integrity is your responsibility. Ensure proper payment of benefits.  State Leaders  Continue consistent messages on UI Integrity.  Public  Mention UI Integrity in press releases and on the web site. 17

18.  Questions?  State Contact for follow-up:  James Konicki  E-mail: james.konicki@labor.ny.govjames.konicki@labor.ny.gov  Telephone: (518) 457-5713 18