1205-0177 Supporting Statement 071522 FINAL

Benefit Right and Experience Report

OMB Control Number 1205-0177

OMB Expiration Date: September 30,2022

SUPPORTING STATEMENT FOR

BENEFIT RIGHT AND EXPERIENCE REPORT

OMB CONTROL NO. 1205-0177

This information collection request (ICR) requests an extension without change to OMB 1205-0177, Benefit Rights and Experience Report, ETA 218.

1. JUSTIFICATION

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. This report includes separate versions for the Regular State UI program and the episodic Federal-State Extended Benefit (EB) program, which provides additional benefits when states experience increased levels of unemployment.

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 for the states to compile this report comes from information that is a by-product of administering the UI 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 and reports, cost estimating and modeling, and to assess and produce reports on State benefit formulas. If this data were not available, cost estimating and modeling would be less accurate and the Office of Unemployment Insurance would lose a key source of data used to develop various metrics and reports on the Unemployment Insurance (UI) system.

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 UI claimants is computerized, so the information states use to produce this report is available in an electronic 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 A.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:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

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 January 13, 2022 (87 FR 2185).

A comment was received on March 3, 2022 in support of extending ETA-218, Benefit Rights and Experience Report from Iowa Workforce Development. An email of acknowledgement was sent on March 3, 2022.

9. Explain any decision to provide any payments or gifts 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. This data is reported at an aggregate level and does not include any sensitive or personally identifiable information.

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. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Estimated Annualized Respondent Cost and Hour Burden

Activity	No. of Respondents	No. of Responses per Respondent	Total Responses	Average Burden (Hours)	Total Burden (Hours)	Hourly Wage Rate	Total Burden Cost
ETA 218 for Regular Program Claimants	53	4	212	.5	106	$53.27	$5,646.62
ETA 218 for Federal-State EB Claimants	2	2	4	.5	2	$53.27	$106.54
Unduplicated Totals	55	///////////////	216	/////////////	108		$ 5,753.16

*Source: The hourly rate is computed by dividing the FY 2022 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/corr_doc.cfm?DOCN=6102)by the average number of hours worked in a year (1,711). For FY 2022, this calculation is: $91,144 / 1,711= $53.27.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital

and start up cost component (annualized over its expected useful life); and (b) a

total operation and maintenance and purchase of service component.

The estimates should take into account costs associated with generating,

maintaining, and disclosing or providing the information. Include descriptions of

methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no other costs involved other than the monetized value of the time burden mentioned in item 12.

14. Provide estimates of the annualized cost 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), any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a single table.

Although no staff is required to process this report, ETA has budgeted $1,055,487.22 to operate and maintain the Unemployment Insurance Required Reports system. Including the subject ICR, this reporting 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 $35,182.91 ($1,055,487.22 system cost/30 information collections).

15. Explain the reasons for any program changes or adjustments.

No changes were made to the information collection or the burden estimates for this collection.

16. For collections of information whose results will be published, outline plans for tabulations, 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, and are used to develop certain metrics presented in other annual UI reports.

17. If seeking approval to not 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 certification statement.

There are no exceptions.

B. COLLECTIONS OF INFORMATON EMPLOYING STATISTICAL METHODS.

This collection does not employ statistical methods.

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