Nevada Department of Employment, Training & Rehabilitation - Clark, Donna

Federal-State Unemployment Compensation (UC) Program Funding Goals for Interest-Free Advances: Proposed Rule Regulatory Information Number 1205-AB53 Comments from the Nevada Department of Employment, Training & Rehabilitation Employment Security Division Nevada supports the concepts of prudent trust fund management and agrees with the selection of Approach I as the proposed qualifying funding measure for interest-free advances. The State does, however, take exception with the proposed time frame of 2 years after its date of publication for implementing the final rule. Given the extraordinary depth and length of the current recession, Nevada believes a phased approach to the funding goals is necessary to provide states with extended time to adjust their financing systems. Linking a 5-year average to the current economic recession should be considered during the development of a reasonable phased approach. Above all, the time frame for the legislation should allow for situations like the present and avoid punishing states that have acted prudently but are faced with extenuating situations before their tax process has a chance to adjust for the difference. Finally, given the dramatic impact the current recession has had on the majority of state trust funds, Nevada urges an extension of the existing waiver of interest on trust fund loans through CY 2011.