Benefit Accuracy Measurement (BAM) Program

Forms and Documents

Document Name	Status
BAM Justification Part B 9 2012.doc Supporting Statement B	2012-10-18
BAM Justification_Part_A 9 26 2012.docx Supporting Statement A	2012-10-18
BAM Approval.pdf Supplementary Document	2012-09-25

IC Document Collections

IC ID	Document Title	Status
43790	Benefit Accuracy Measurement (BAM) Program-SWAs Instruction	Modified
204955	Benefit Accuracy Measurement: Businesses, Farms, and non-profits Instruction	New
204954	Benefit Accuracy Measurement, Individuals Instruction	New

ICR Details

OMB Control No: 1205-0245	ICR Reference No: 201209-1205-005
Status: Historical Active	Previous ICR Reference No: 200906-1205-002
Agency/Subagency: DOL/ETA	Agency Tracking No:
Title: Benefit Accuracy Measurement (BAM) Program
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 12/31/2012
	Date Received in OIRA: 11/30/2012
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2015	36 Months From Approved	12/31/2012
Responses	149,004	0	47,160
Time Burden (Hours)	524,749	0	429,897
Cost Burden (Dollars)	0	0	0

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Abstract: The Benefits Accuracy Measurement (BAM) program provides reliable estimates of the accuracy of benefit payments and denied claims in the UI program, and identifies the sources of mispayments and improper denials so that their causes can be eliminated.

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Authorizing Statute(s): US Code: 42 USC 5939(a) Name of Law: Social Security Act
   US Code: 26 USC 3305(b) Name of Law: Federal Unemployment Taxation Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 54927	09/06/2012
30-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 71449	11/30/2012
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
Benefit Accuracy Measurement: Businesses, Farms, and non-profits
Benefit Accuracy Measurement, Individuals
Benefit Accuracy Measurement (BAM) Program-SWAs

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	149,004	47,160	0	0	101,844	0
Annual Time Burden (Hours)	524,749	429,897	0	0	94,852	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The current total hour burden for both paid and denied claims and the 52 SWAs is: 52 SWAs X 3,445.1 responses = 179,145.2 responses averaged among 52 respondents 52 SWAs X 9,154.1 hours = 476,013.2 hours This contrasts with the 2009 estimated burden for both paid and denied claims and the 52 SWAs which was: 52 SWAs X 3,634.3 responses = 188,983.6 responses averaged among 52 respondents 52 SWAs X 8,267.25 hours = 429,897 hours The change reflects increased emphasis placed on gathering, verifying, and reporting payment accuracy information as mandated by law and regulation. Seventeen states provided information and feedback which was used in the revised burden estimates. The slightly downward change in the number of participants is based on calendar year 2011 data. The Improper Payments Elimination and Recovery Act (IPERA) of 2010 (signed into law on July 22, 2010) require agencies to examine the risk of erroneous payments in all programs and activities they administer. IPERA defines "significant erroneous payments" as annual erroneous payments exceeding both 2.5 percent of program payments and $10 million. The UI program meets both of these criteria. Additionally, IPERA codifies the requirement for valid statistical estimates of improper payments such as those generated by BAM and compels actions to reduce improper payments. Furthermore, the "Revised Parts I and II to Appendix C of OMB Circular A-123" (issued April 14, 2011) requires additional efforts on the part of the states to obtain complete and accurate information used for estimation purposes. SWAs make all UI payment decisions. Therefore, the Department of Labor (DOL) is requiring SWAs to review their BAM improper payment data and report their planned activities to prevent, detect, reduce, and recover improper payments in an UI Integrity Action Plan. In addition, ROCIS entries were adjusted by the addition of two ICs reflecting third party burden which should have been reflected in the previously approved submission. Thus, the totals appear larger overall even though the other two ICs appeared in the previously approved submission in 2009 (but did not show up in ROCIS, inadvertently, to reflect the third party burden attributed to this ICR).

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Annual Cost to Federal Government: $908,874

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 11/30/2012

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