1205-0177 Supporting Statement_FINAL 5-15-19

Benefit Rights and Experience Report

OMB Control No. 1205-0177

April 2019

Supporting Statement

Benefit Rights and Experience Report

OMB Control No. 1205-0177

A. Justification.

The Department of Labor, Employment and Training Administration (ETA) is renewing an extension without change for the ETA 218, Benefit Rights and Experience report.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

In order for an individual to be eligible for a State unemployment compensation program, the claimant must meet certain requirements, which demonstrate attachment to the labor force. The vast majority of states use past wages for this purpose, however, a few States use actual weeks of work. Information relative to this first test of eligibility, known as monetary eligibility, is reported on the ETA 218, Benefit Rights and Experience Report. The data in the ETA 218 report includes numbers of individuals who were and were not monetarily eligible, those eligible for the maximum benefits, the number of newly eligible claimants categorized by potential duration, and the number of benefit exhaustees categorized by their actual duration. Authority for collection of this information is under Section 303(a)(6) of the Social Security Act.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Data used to compile this report comes from information that is a by-product of administering the program. This data is collected as part of the initial claim process. It is transmitted electronically to the National Office on a quarterly basis. This data is used by the National Office in solvency studies, cost estimating and modeling, and to assess State benefit formulas. If this data were not available, cost estimating and modeling would be less accurate.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

All state information on Unemployment Insurance (UI) claimants is computerized, so the information states use to produce this report is already in an automated format suitable for producing this information. The ETA 218 is reported electronically to the National Office with States having the option of directly uploading data from their computer to the reporting system, which stores and transmits the data, thus eliminating any keying. States are free to further reduce reporting burden using any available technology.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The data collected on this report is not a duplication in any way: this level of detail is not available in any other report. There are some other reports where information is collected that allows us to verify that the values reported are reasonable. As an example, the ETA 5159 (1205-0010) has states report first payments, which should track closely with the number of monetary determinations on the 218. Therefore, although data with some similarities are collected on other reports, the specific data items on this report are not collected anywhere else, so there is no degree of duplication.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This collection does not involve small business or other small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If this collection were conducted less frequently, there would be fewer data points on which to project short-term trends. ETA’s allocation system is quarterly, therefore it is desirable to project workload and related information at least on a quarterly basis.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

This collection is consistent with the guidelines in 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years—even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with the Paperwork Reduction Act of 1995, the public was given 60 days to review and comment on this data collection by way of a Notice published in the Federal Register on February 7, 2019 (84 FR 2581). No public comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

There is no assurance of confidentiality.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The collection does not involve any questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information.

Respondents for this report are the 53 State Workforce Agencies (SWA). Each SWA must submit four reports per year, one for each calendar quarter of the year. Each State agency must also submit a report for each UI program in which claimants are receiving benefits. Given the possibility of claimants establishing entitlement in two benefit programs, a full estimate of potential reporting burden would include four quarterly reports in the regular program and two reports for the Federal-State Extended Benefits (EB).

The following table can be used as a guide to calculate the total burden of an information collection.

Activity	Number of Respondents	Annual Frequency	Total Annual Responses	Time Per Response	Total Annual Burden (Hours)	Hourly Rate*	Monetized Value of Respondent Time
ETA 218 for Regular Program Claimants	53	4	212	.5	106	$49.94	$5,293.64
ETA 218 for Federal-State EB Claimants	2	2	4	.5	2	$49.94	$99.88
Unduplicated Totals		///////////////	216	/////////////	108		$ 5,393.52

*Source: The hourly rate is computed by dividing the FY 2019 national average PS/PB annual salary for state staff as provided for through the distribution of state UI administrative grants (https://wdr.doleta.gov/directives/attach/UIPL/UIPL_10-18.pdf by the average number of hours worked in a year (1,711). For FY 2019, this calculation is $85,453 / 1,711= $49.94.

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

There are no other costs involved other than those mentioned in item 12.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Although, no staff is required to process this report, ETA has budgeted $965,920.33 in fiscal year 2019, to operate and maintain the Unemployment Insurance Required Reports system. Including the subject ICR, this system supports 30 information collections. For administrative purposes, each information collection is assumed to contribute an equal share of the cost for supporting the entire system; therefore, the cost allocated to this ICR is estimated to be $32,197.34 ($965,920.33 system cost/30 information collections).

15. Explain the reasons for any program changes or adjustments reported on the burden worksheet.

No changes were made on the burden worksheet for this collection.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The data collected on the ETA 218 describing monetary determinations, as well as potential and actual duration for claimants, are published as a complete quarterly series as part of the UI program’s online “Data Downloads” offerings. Additionally, the data are published in the annual ET Handbook 394, Unemployment Insurance Financial Data, summed over the four quarters of the calendar year.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

ETA displays the OMB control number and expiration date on the ETA 218 hard copy form as well as on the electronic input form. A menu option has also been incorporated into the UI electronic reporting system, which provides access to a complete listing of OMB control numbers, and expiration dates for all required reports, including the ETA 218. In addition, ETA will disseminate OMB control number and expiration date information for this report through an ETA Directive shortly after OMB action.

18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions,”

There are no exceptions.

B. Collections of Information Employing Statistical Methods.

This collection does not employ statistical methods.

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