DOL-ETA - TAPR Response to Comment

A comment was received in response to the Department’s filing of the no change extension information collection request (ICR) for the Trade Activity Participation Report (TAPR) submitted to the Office of Management and Budget (OMB), in the Federal Register on July 7, 2016 (OMB Control Number: 1205-0392). The commenter raised two issues, asserting that the supporting statement does not indicate the data collection burden for states querying the Wage Record Interchange System (WRIS) for TAPR purposes and that it does not contain the number of TAPR entries that are incomplete as a result of failure to obtain out-of-state data.  It is important to note that the Department is in the process of revising the WRIS and will create an updated data sharing agreement that will be used to complete the TAPR.  Eventually, this new data sharing agreement will take the place of the WRIS. 

The Agency believes it has fully accounted for the data collection burden on states for participating in WRIS. More specifically, Supporting Statement section 12c calculates the burden of States submitting the TAPR, which includes the burden of obtaining interstate wages through the WRIS.  The Department estimates that each State spends approximately 6 minutes per year to query the WRIS to obtain the data necessary to complete the employment outcomes in the TAPR. For the 52 states participating in the Trade Adjustment Assistance programs, this totals 5 hours. Thus, the burden of querying the WRIS to report on performance outcomes through the TAPR was accounted for in the information collection request.

On the second part of the comment, the Department notes that the percent of incomplete TAPR submissions is not related to burden estimates or an information collection request. The Department can only assume that the commenter was referring to out-of-state wage records in this comment instead of other out-of-state records related to the provision of training or employment and case management services. There is no true way to know the number of records that are incomplete due to out-of-state wages in the TAPR. Cooperating state agencies submit individual records. These records include a field where the state indicates whether they are the liable state, agent state, or both. In situations where the reporting state is the liable state only, one can only assume that the employment after exit would be likely occur out-of-state. However, that is only an assumption and therefore cannot be a basis for any type of analysis of the “completeness” of records. There is also no way to confirm whether or not a participant is employed unless that employment is reported by a CSA. The records contain a state-generated unique identifier.  Therefore, it is not possible for the Department to independently track the same participant across submissions from multiple states. In conclusion, the Department cannot provide the percentage of incomplete TAPRs as requested by the commenter.