1 Everyone Owns Integrity: Strategies, Tools, and Best Practices to Address UI Improper Payments2011 National UI Directors’ Conference and IT/Legal Issues Forum State of Hope – Keeping the Safety Net Strong October 19, 2011 1
2 Gay Gilbert U.S. Department of LaborEmployment & Training Administration Administrator, Office of Unemployment Insurance 2 2
3 Our Agenda DOL Integrity Strategies One State’s Journey Best PracticesGay Gilbert – Administrator, Office of Unemployment Insurance, U.S. Department of Labor, Employment and Training Administration One State’s Journey Ronald Marino – Assistant Commissioner, Income Security, New Jersey Department of Labor and Workforce Development Best Practices Chris Peretto – Unemployment Insurance Integrity Project Manager, Information Technology Support Center Claimant Messaging Wade Gates – Managing Director, Burson- Marsteller 3 3
4 UI Improper Payment Rate
5 States Answering the Call to ActionCollaborative Fed/State Integrity Workgroup with NASWA Providing Direction High Impact States Leading the Way All States with Task Forces and Strategic Plans Focused on Prevention Early Success on ES Registration Issues Best Practices Collection/Dissemination $192 Million in SBR funding to support improved program integrity
6 Sustaining the MomentumHigh Level Leadership Engagement Empowering All Staff to Own Integrity Prioritizing High Impact Strategies Measuring Results Continuous Focus Communicating Success
7 Communicating SuccessStates Getting to Success
8 Looking Ahead Implement New Performance Measures Focused on Overpayment Prevention, Improper Payment Rate Reduction, and Recovery Claimant & Employer Messaging Campaigns Pilot New Data Sources Tackling Work Search as a Root Cause Targeted Technical Assistance
9 UI Community of Practice 9 9
10 UI Community of PracticeRegister for the UI CoP at NOTE: This is a CLOSED community (not public) - All registrations must be approved by ETA - you will receive an confirming your registration after approval. REGISTER NOW! 10 10
11 Improper Payments Ronald Marino Assistant CommissionerNew Jersey Department of Labor and Workforce Development 11 11
12 Improper Payments History of Improper Payments in New JerseyDivision of Fraud and Risk Management Improper Payment Initiatives National Directory of New Hire Application Identity Validation Software On-line Access to Benefit Charges Implementation Plans Going Forward
13 Three Year Average of Improper Payment Causes in New Jersey :History Three Year Average of Improper Payment Causes in New Jersey : Benefit Year Earnings 39% Base Period Wage Issues 30% Separation Issues 12% Able and Available 11%
14 History Cont. Emphasis was only on Detection/RestitutionIntegrity was localized in Benefit Payment Control Integrity was never part of front-end processing Reliance on notices mailed to employer and employee Struggling Economy and corresponding increased claim volume redirected integrity resources to address claim filing process
15 Division of Fraud and Risk ManagementCommissioner Harold Wirths in 2010 placed UI integrity as his primary initiative Creation of the Division of Fraud and Risk Management Organization consists of investigators, auditors and analytical staff Purpose is to address improper payments on wage benefit conflicts and fraudulent scams initiated by either claimants or employers
16 Improper Payment InitiativesCross-match for valid SSN, deceased, incarcerated UI SIDES charter member Cross-match sweep of wage record data Revision of affidavit procedures Cross-match of certification by affidavit by subsequent quarterly wage records Multiple claims using same IP address Claims using foreign IP address
17 Improper Payment Initiatives Cont.Multiple claims using same address and/or same phone number Multiple claims filed with direct deposit payment option using same bank, same bank account and same routing number Appeal Tribunal and Adjudicators training
18 Comprehensive InitiativesNational Directory of New Hire (NDNH) Identity Validation Software and Analytical Intelligence On-line Employer Access to Benefit Charges
19 National Directory of New HireCross-match identifies claimant’s start date and new employer Information populated in UI System and a “flag” is placed on claim requiring the claimant to speak with an agent Based on information provided by claimant payment is either released or requires a further investigation Incorporate INTEGRITY in the front-end process Application implemented April 2011 Annual cost savings $22M
20 National Directory of New Hire Cont.Certification responses to NDNH: Claimant discontinues certification Claimant started new job and is ineligible for payment from start date Claimant started new job but employment ended (separation issue???) Claimant never started new job; claimant will be paid but case referred for further investigation
21 Identity Validation SoftwareAt the time of claim filing the software will obtain public information concerning the claimant and formulate it into pre-established random identity- related questions Software will transmit to UI if the responses successfully confirmed the claimant’s identity Both successful and unsuccessful identity verification claimants will be alerted to the final results but will still be permitted to proceed with the completion of their claims
22 Identity Validation SoftwareThose claims filed over the Internet that have unsuccessful identity verification will receive a contact from the Division that additional proof of identity will be required prior to the issuance of any benefit payment Those claimants filing over the telephone via the IVR application will be immediately transferred to an agent and given instructions regarding the submission of additional proof of identity prior to the issuance of a benefit payment
23 On-Line Access to Benefit ChargesNJ has an existing web application with the appropriate protocols for employers to view Tax related matters Expansion of the web application to provide employers with benefit charges for former employees Provide vehicle for employers to protest charges Elimination of the mailing of benefit charges
24 Implementation Plans Going ForwardIncorporate integrity policies to all UI staff at every phase from initial claims processing through payment of benefits Create a repository of fraudulent scams and other integrity-related applications for sharing with other State agencies
25 Implementation Plans Going Forward Cont.Incorporate employers more fully into the process by: Timely submission of wage data Timely submit NDNH info Participate in UI SIDES View on-line benefit charges Respond timely for any requested information
26 Best Practices Chris PerettoUnemployment Insurance Integrity Project Manager, Information Technology Support Center 26 26
27 UI Integrity Project ObjectivesReview State Issues Implementing EUC/FAC/EB as it Relates to UI Integrity Form a National UI Integrity Work Group Visit and Study States Integrity Processes, Practices and Methods Identify and Publicize Integrity Best Practices and Lessons Learned 27 27
28 State UI Integrity StudiesObjectives Review State Issues Implementing EUC/FAC/EB as it Relates to UI Integrity “General Feel” of What is Happening in the Area of UI Benefit Integrity Review UI Benefit Integrity Functions and the Top Areas of Overpayments Identify Best Practices and Lessons Learned State Selection and Study Process
29 Integrity State StudiesHI TX FL TN NC VA NY MT OR ID WY UT CA SD MN WI LA ND CO NM IA IL WV MO OH KS ME AK WA NV AZ NE OK AR MS GA AL SC KY IN MI PA DC MD NJ DE CT RI MA NH VT PR VI Integrity State Study (16 states)
30 Best Practices & Lessons LearnedIdentification – Documented and Expert Opinion Identification of Great Ideas that Need Improvement Distribution Final Report On DOL Website
31 General Observations & Best PracticesStaffing – Having Enough Resources Getting Staff Involved and Talking with Peers Using Penalty & Interest $ Solely for BPC BAM Presentations to new staff Involved in operations meetings Task force meetings Claims Taking and Adjudication by Same Staff
32 Detection & Prevention Best PracticesCut Off Benefits When Claimants do not Respond Payment Stopped for Undeliverable Mail Running Cross Match Programs More Often Messaging – Claims Booklets Sending Letters to Both Claimant and Employers Automated Cross Match Systems Social Media – Face book, Twitter, Linked In ….. Foreign IP Address Search
33 Collection Best PracticesFish and Game License Denials Cross match Wage and Collections Databases Automatic Wage Garnishments Interest on Fraud Debts No Statute of Limitations on Fraud Debts
34 UI Integrity Project Contact Information: Chris Peretto (248)
35 Claimant Messaging Wade Gates Managing Director, Burson-Marsteller 35
36 The Mission Research why claimants behave as they do:Lack of understanding? Lack of appreciation? No awareness or fear of consequences? Then, develop messages and products to help states get the desired behavior Better compliance Enhanced utilization of available services
37 Working Hypothesis
38 The Process A review of existing materials, messagesNationwide opinion research Claimant attitudes, versus general public Separate breakout for Hispanic populations On-line and telephone research – to ensure economic diversity Insight and feedback from UI Integrity Workgroup and participating states
39 1. Top-Line Research FindingsStates are doing a good job in conveying information 95% of claimants (former and current) say they understand the process However . . . Great confusion on details Many falsely believe they do not have to report return to work until they receive their first paycheck
40 “When . . .” ?
41 2. Top-Line Research FindingsClaims of “necessity” are significant factor 96% claimed to understand the consequences associated with errant filing, but almost half did not stop filing for benefits at the correct time 17% agreed: “It is sometimes necessary to file for benefits until my first paycheck arrives” 9% admit it’s wrong to wait, but have convinced themselves that they have no other option
42 3. Top-Line Research FindingsMany misunderstand UI as an “a right” 16% believe that “benefits are a guaranteed right for all tax-paying citizens” The concept of “deserve” is a complex and powerful motivator, particularly in a negative sense Many believe that they “paid into it” like Social Security – it’s theirs to take
43 4. Top-Line Research FindingsWhile most universally believe there are consequences to their actions, many can’t specify them 96% believe there are consequences . . . 80% think there may be prosecution 73% believe there may be fines 70% believe they may lose future benefits “Broken link” between the threat and the punishment
44 Quick Example Clearly cites that not reporting is “illegal”Does not mention repercussions/penalties $6.4b in overpayments Does not indicate that actions were taken Impression that some “got away with it”?
45 Messaging Research
46 5. Top-Line Research Findings4:5 claimants registered with state agency 71% say it’s required to collect UI Yet awareness of other benefits and resources is low 47% registered for job referrals 1/3rd registered to receive other re-employment services
47 6. Key Findings - HispanicsGreater degree of misunderstanding and lack of awareness +50% unemployed Hispanics do not apply for UI because they did not know benefits are available 1/3rd didn’t know services are available Less than half claimants stopped filing for UI when they returned to work More reliance on written materials Control groups favored electronic sources
48 Outputs “Message Toolkit the States” Resource for agenciesSuggested messages, English-Spanish Text/verbiage for integration with existing tools Templates for use/customization In Microsoft Word – graphically limiting, yet universally acceptable Designers can adapt ideas into their own programs Videos – add logos/text before and after Webinar – more detailed presentation and discussion as resource, training Two sessions live, then available for on-demand
49 “Top 10 . . .” Offers quick, readable way to hit the highlightsOne-page document Expanded two-page document Web-text Excerpts for audio scripts E.g. Intros to prompts, “hold” messages
50 “Common mistakes . . .” Another approach to catch audiences Formats:Conveys same information, but in different tone Formats: Video series Audio scripts Web-text
51 “. . . fraud” Seeks to “call it what it is” Formats:“Improper payments” may be too polite in certain contexts Formats: Document Web-Text Audio Scripts
52 Testimonials Peer-to-peer is often strongest communication“You can take me off your mailing list! I started the job today that I told you I had hoped I would get. I am a procurement specialist helping companies bid on state and federal contracts. Thank you for finding me this job. It is a custom fit for my personality and military/civilian work experience.” Charley “Thank you for finding me this job.” Peer-to-peer is often strongest communication Can defuse guilt, break barriers Template provided States cultivate their own stories Posters Web highlights Videos
53 “Quick Tips” Brief notes and remindersTemplates offered for variety of digital outlets: Social media Web outlets
54 “Search for work . . .” Addresses key area of confusion, relevance in messages Formats: Document Web-text
55 Call-Center Messages Suggested messaging, phrasing for coaching call-center reps Also applicable for online claim-filing prompts CALL CENTER: “Do you understand your responsibilities to find work? Unemployment insurance benefits exist to help you while you are unemployed and searching for work. But you are required by law . . .”
56 Outputs Reminder “Message Toolkit for the States”Resource for agencies Suggested messages, English-Spanish Text/verbiage for integration with existing tools Templates for use/customization Documents Videos Webinar – more detailed presentation and discussion as resource, training Two sessions live, then available for on-demand
57 Please use the Chat Feature to indicate that you have a question.Questions and Answers Please use the Chat Feature to indicate that you have a question. 57 57
58 Thanks! Thank you! 58 58