Report of Responses to the UI Benefits Operations Self-Assessment Tool

Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

Unemployment Insurance (UI) Benefit Operations
Self-Assessment Tool:

Lower Authority Appeals (LAA) and
Higher Authority Appeals (HAA)
This self-assessment review of the state’s Lower and Higher Authority Appeals functional areas
will examine appeals processes as well as program performance. The reviewer will consult with
appropriate staff regarding each operational element, as necessary, to ensure accurate and
complete information is reported. This will include Unemployment Insurance (UI)
administrators, IT managers, fiscal officers, the appeals office manager, and appeals office
supervisors. Numerous questions cover both the Lower Authority Appeals (LAA) and Higher
Authority Appeals (HAA) processes, and the reviewer should be certain to provide the
information that is applicable to each area.
The reviewer will provide information regarding the state’s performance for each calendar
quarter of the review period for the average age of pending lower authority appeals, average age
of pending higher authority appeals, and lower authority appeals quality. Use this link for more
information regarding UI PERFORMS ALPs/Performance Criteria: Acceptable Level of
Performance.
Upon completion of this review, the results should be shared with UI administrators, program
manager(s), and supervisors. The self-assessment findings, in conjunction with the state’s
quarterly appeals quality review scores, can provide a very good analysis of the appeals
operations and performance. The results can be used to drive process and program-improvement
initiatives.
A comments section is provided for each operational element, which the reviewer should use to
document any observations regarding issues identified related to that specific operational
element. This space may also be used to provide any additional information relating to a specific
question in this section. In doing so, the reviewer should reference the specific question by
number and insert the additional information related to that question.
In addition, a concluding comments section is provided at the end of the self-assessment
instrument to capture any strengths identified by the reviewer in this functional area which could
constitute a successful practice(s) to be shared with other states; any issues identified by the
reviewer in the functional area that adversely impacts the state’s performance and to identify any
possible corrective actions to address the issue; and general comments about this functional area
that are not covered elsewhere. The reviewer can provide information here that Federal
reviewers and state UI administrators and managers can use to assess program operations and the
state’s effectiveness in providing quality services in this functional area.
Save your entries regularly as you complete the review and when you close the selfassessment, to ensure your answers are saved.
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Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

SECTION 1:

Procedures, Policies and Confidentiality

The purpose of this section is to review the policies and procedures provided by the agency for
staff to use in operating this functional area of the UI program. These are the written (in hardcopy, electronically, or both formats) standards, instructions, and guidelines that staff regularly
use in the operation of the program. The reviewer may utilize resources that include manuals,
handbooks, desk aids, computer help screens, training guides, organized collections of
procedures or policies, or other readily accessible instructions which can help staff do their work
correctly, including ETA Handbook No. 382 for guidance regarding Lower Authority Appeals
Quality. Instructions will normally include general information such as compilations of relevant
laws and regulations, as well as detailed instructions for carrying out individual jobs in the
agency. Reviewers may need to look in many places to examine all relevant instructions and
consult with UI administrators, the appeals manager, and appeals office supervisors.
The reviewer will document whether the state has policies and procedures sufficient to provide
guidance and instruction to staff that conduct appeal hearings as well as support staff. Existing
policies and procedures should be examined to determine whether they are up-to-date and
address all law changes, organizational changes, and technology changes that occurred during
the review period.
Helpful Info.
Question 6: The reviewer should indicate all methods the state offers for filing Lower
Authority Appeals (LAA) and Higher Authority Appeals (HAA).
Question 8a: If the state has an established practice of reviewing appeal filings to
determine if the issue should be re-determined instead of having a hearing docketed, the
reviewer should indicate what unit is responsible for this review process.
Question 11: The adequacy of a LAA hearing notice is an element that is included in the
appeals quality review and it must contain all of the elements indicated to be scored as
adequate.
Question 12: The reviewer will document which of the listed hearing-related tasks are
covered by the state’s policies and procedures.
Question 13: The adequacy of LAA and HAA decisions is an element that is included in
the appeals quality review and the decisions must contain all of the elements indicated to
be scored as adequate.
Questions 14 and 14a: The reviewer should review confidentiality requirements of 20
CFR 603.5(b) to determine whether the state’s handling of LAA and HAA information
conforms to the requirements set forth.

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Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

SECTION 2:

Training

Managers/employees should possess and maintain a level of expertise which enables them to
accomplish their assigned duties. Training systems should be sufficient to ensure that personnel
understand and perform their duties properly. When reviewing training systems, the reviewer
should consult with the state’s training unit/staff and examine formal training procedures (e.g.,
the training is conducted using an established schedule and using set guidelines to make
judgments about the quality of work being produced). The state should have procedures for
identifying general and specific training needs, for developing a training curriculum and training
materials, and for delivering training as needs are identified.
Helpful Info.
Question 8: The reviewer will determine whether the state uses decisions, particularly
reversals and remands of appeals to determine training needs for hearing officers.
Question 14: The reviewer should document the means that the state uses to provide
training to LAA and HAA staff regarding confidentiality of personally identifiable
information.

SECTION 3:

Workload Analysis/Management Controls

The reviewer will examine the state’s ability to manage appeals workloads, particularly through
periods of unforeseen spikes in appeals cases, is analyzed. The reviewer will also review
methods used by the state to mitigate backlogs, when they occur, to ensure the state’s ability to
provide timely, quality appeal hearings and decisions. The reviewer will document processimprovement initiatives aimed at minimizing appeal backlogs. The reviewer will interview the
appeals manager, appeals office supervisors, and performance management staff to thoroughly
document the state’s practices for managing its appeals workloads.
Helpful Info.
Question 4a: If the state has a systematic plan to manage LAA backlogs, document the
methods used and explain in the Training section how training is delivered to supplemental
staff, if used.
Question 7: If the state has a systematic plan to manage HAA backlogs, document the
methods used and explain in the Training section how training is delivered to supplemental
staff, if used.

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Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

Helpful Info. (continued)
Question 9a: If the state has the requirement that one or more members of the HAA must
be an attorney, the reviewer should indicate to whom this requirement applies, for
example, to all members, the chairperson only, etc.
Question 10a: Describe all business process analysis initiatives the state conducted during
the review period regarding its LAA and HAA processes and what operational changes
have been implemented as a result of those initiatives. (If space is not adequate to fully
respond to this question, the reviewer may use space in the Comments area at the end of
this section.)
Questions 11a and 11c: If the state uses an automated system to docket LAA or HAA
hearings, describe the system that is used. If the state’s system for docketing hearings is
considered to be especially effective and/or efficient, explain fully in the Comments area at
the end of this section.

SECTION 4:

Performance Management

The reviewer will examine the state’s practices for monitoring program performance and
compliance with Federal and state law and regulations. Review the state’s practices for the
preparation and monitoring of corrective action plans to ensure timely and accurate submittal and
methods for continued monitoring of program performance in relation to designated milestones.
If the state has a performance management unit, the reviewer should consult with performance
management staff in addition to the appeals manager when completing this section.
Helpful Info.
Question 1a: The reviewer should consult with UI managers for information regarding
any Corrective Action Plan(s) or Narrative that the State Quality Service Plan (SQSP)
contained during the review period for its Appeals performance.
Question 2a: If the state did not meet designated milestones on its SQSP during any
quarter(s) during the review period, the reviewer will need to provide information about
why the milestones were not met from the appeals manager and performance management
staff.

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Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

Helpful Info. (continued)
Question 3a: If the state has submitted multi-year CAP(s) the reviewer will document
progress made in meeting designated milestones based upon information obtained from the
appeals manager.
Question 4b: The reviewer will document the methods the state uses to monitor its appeals
operations. If the state’s processes for monitoring its LAA and HAA operations are
considered to be particularly effective and/or efficient, explain fully in the Comments area
at the end of this section.

SECTION 5:

Information Technology (IT)

When completing this section of the self-assessment, the reviewer should consult with UI and IT
administrators and the appeals manager. IT projects relating to UI Appeals that were completed
during the review period and planned for the future will be detailed. The reviewer will assess the
IT department’s delivery of programming and technical support to the UI Appeals functional
areas.
Helpful Info.
Question 1a: The reviewer should describe any major IT projects that were conducted
during the review period that impacted the appeals programs and provide information
regarding the project status, and if completed, the success of the project. (If space is not
adequate to fully respond to this question, the reviewer may use space in the Comments
area at the end of this section.)
Question 2a: If the state had IT needs related to its appeals operations that were not met,
the reviewer should document the needs that were not met and the impact it had on the
timeliness and/or quality of appeals, if any.

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Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

SECTION 6:

Claimant/Employer Access & Communication

The reviewer will examine the state’s methods for conducting appeal hearings. Methods used
must comply with requirements set forth in Federal law and must meet Federal regulations and
guidance regarding accessibility, including UIPL No. 02-16. The reviewer will provide
information regarding the interaction of claimants and employers with the appeals operation.
The reviewer will consult with UI administrators and the appeals manager when completing this
section of the self-assessment.
Helpful Info.
Question 6: The reviewer should review Section 508 of the Rehabilitation Act (29 U.S.C.
794d), UIPL No. 30-11, UIPL No. 02-16 and the state’s accessibility guidance to acquaint
themselves with requirements for accessibility before completing this section.

SECTION 7:

Operational Efficiency/Resource Allocation

Through interviews with UI administrators and the appeals manager, the reviewer will determine
whether the state has allocated sufficient resources to training, facilities, staff, etc. to support
program operations. The reviewer will identify efficiencies and automation the state has used to
improve performance and provide better service to the public.
Helpful Info.
Question 1: The reviewer will provide the ratio of FTEs allotted to appeals management
staff compared to front-line appeals staff.

SECTION 8:

Staffing

The reviewer will examine organizational changes that occurred during the review period, if any,
and their effect on the state’s ability to manage its appeals workload and to meet timeliness and
quality standards for its Lower Authority Appeals. The reviewer should consult with UI
administrators, the appeals manager, and the state agency’s human resource manager when
completing this section of the self-assessment.

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Unemployment Insurance (UI) Benefit Operations Self-Assessment Tool: Lower and Higher Authority Appeals

Helpful Info.
Question 1: Staffing allocations are examined to determine whether an adequate number
of FTEs is allocated for appeals support staff and hearing officers.
Question 2: The number of FTEs budgeted and dedicated to appeals support staff and
hearing officer positions impact the state’s ability to meet Federal requirements for
timeliness and quality of its appeal decisions. The reviewer will report the number of
FTEs budgeted, that is, the positions budgeted by the state after Federal “base” allocations.
Dedicated FTEs means the number of FTEs that were charged to the function.

SECTION 9:

Concluding Summary Comments

The reviewer will use the Concluding Summary Comments section to highlight the state’s
strengths and weaknesses that impact the Lower Authority Appeals and Higher Authority
Appeals functional areas and to identify issues that have not been addressed in any other section
of the self-assessment. These comments are intended to provide Federal reviewers and the
state’s UI administrators with additional insight into these program areas, focusing on methods
that have proven to be successful and can be capitalized upon or areas where corrective measures
may be needed.
The first comment area provides the reviewer an opportunity to share any examples of good
and/or exemplary operations in this functional area after reviewing each operational element.
The reviewer can use this space to identify any policy, procedure or operation that would
constitute a successful practice that can be shared with other states.
The second comment area provides the reviewer to document issues detected during the review
that are having an adverse impact on the functional area, affecting the state’s performance,
ability to meet performance standards or customer service. It is also a place to recommend
corrective actions for the agency’s leadership to consider implementing.
The final comment area in this section provides the reviewer space to share any additional
comments, concerns or observations regarding the state’s operations in this functional area.

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