Tennessee Department of Labor and Workforce Development

Document ID: ETA-2007-0017-0004
Document Type: Public Submission
Agency: Employment And Training Administration
Received Date: December 14 2007, at 11:56 AM Eastern Standard Time
Date Posted: January 14 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: November 2 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: January 2 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8037a0ac
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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.

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