Concerns about the new pay state definition:
1. The front line interviewer will have the responsibility from providing information so
that the claimant will be able to make an informed decision about which states to
combine against. The interviewer will have to give CWC options for all states.
Example: Claimant worked in TN, TX and MI. Interviewer will have to figure the
WBA and MBA for TX using all the wages, for TN using all the wages and for MI
using all the wages(they have to consider the base period of the other state which
may be different than TN). We now only figure CWC for TN and if the claimant had
1 qtr of wages in each of the other states you would know that they were not
eligible in those states. This will take a lot of front line time.
2. If we file the CWC on TN and we are protesting the TN wages(because they do
not appear on our wage file), but we make the claim CWC with TX and MI. We will
not be able to add the other states wages and start paying the claimant, until the
wage protest is worked and we have TN wages on the system. If the wages are
not assignable to TN then we have to call the claimant back and give them another
option. Both of these scenarios would probably cause a late first pay. Also, we
are using up interviewer time again and the administrative cost of filing, canceling
and filing a claim.
3. Same situation as #2 but the TN wages are UCX wages and during the course
of the claim we find out the UCX wages can not be used.
4. Options for Federal employees will have to be done on an estimate from the
claimant, because Federal employment wages are not reported until the claim is
filed.
5. What happens when the claimant calls or goes to a local office and we have no
TN wages? They are contacting us for help. Do we say that they will have to
contact a state where they have wages or do we provide customer service and tell
them their options?
6. What happens to the claimant that has a little work in three states, but because
of each of their laws would not be eligible for CWC in any of the states? He would
be eligible on the state in which he is in, but has no wages in that state. Could
this be an option only if the claimant was not eligible in any of the other states?
7. We will need to notify the pubic of this change in some manner.
Tennessee Department of Labor and Workforce Development
This is comment on Proposed Rule
Federal-State Unemployment Compensation Program (UC); Interstate Arrangement for Combining Employment and Wages
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