Proposed Changes to UI Performs
NELP Administrative Comments

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Summary

On August 13, 2004, the National Employment Law Project wrote to U.S. D.O.L. in response to the proposed standards (69 Fed. Reg. 33,669) issued by the Office of Workforce Security (OWS) to measure the performance of the state unemployment insurance programs (“UI Performs”).

NELP believes that the proposed performance measures represent a substantial retreat from meaningful enforcement of standards that are critical to the operation of the program.

We are especially concerned with the proposed shift away from oversight and monitoring of those unemployment claims that have been pending in the system the longest and toward the “averaging” of the critical timeliness standards.  In addition, for the first time in the history of the program, the OWS has proposed a “reemployment” standard that would effectively adopt a “work first” model rewarding those states that push people back to work the fastest, without including any measure of the quality of the job compared to the skills and employment history of the individual worker.  Finally, while OWS proposes a new standard addressing the overpayment of benefits to workers, there is no meaningful improvement in the limited mechanisms to detect the millions of dollars in benefits that are underpaid to workers or to raise the level of enforcement against employers who fail to pay their fair share of unemployment taxes.