11.21 Supplemental Data Collection Policy

11.21.1 Supplemental Data Collection Policy

Effective date: June 1, 2018

Situations when Supplemental Data collection is necessary

Supplemental data satisfies reporting outcomes when employment and earning data is not available from state and interstate wage records. Supplemental employment and earning data may be collected during a participant's first four full quarters after exit. Wisconsin's WIOA Title I Programs must attempt a minimum of one time per quarter to collect supplemental data:

• when a program participant does not provide a social security number (SSN) for matching with quarterly wage record information;
• when a program participant is employed by business or in an occupation that is excluded by state unemployment insurance law. Businesses with "excluded employment" are not required to provide employee SSN and quarterly earnings to the state's unemployment insurance agency;
• must occur when UI wages are not reported.

Supplemental Wages May Include

Any form of unsubsidized employment including the following examples.  This is not an all-inclusive list of the types of unsubsidized employment: apprenticeship, military, commission for sales…etc.  Supplemental Wages may not include any form of subsidized employment.

 Participant does not provide SSN

Periodically, participants either do not have a SSN or do not wish to provide a SSN to the public workforce system.  WIOA does not allow exclusions from performance indicators due to a lack of a SSN. WIOA programs are not permitted to require disclosure of SSN as a condition of program participation.¹

 Participant is in excluded employment 

Excluded employment is a type of employment in which the employer is not required to submit wage record information to the state's unemployment insurance agency. Wisconsin Unemployment Insurance (UI) law, Chapter 108, defines employers and employees that must submit wage record information to the Division of Unemployment Insurance. The Unemployment Insurance online handbook assists in determining which employers for which employees must report.  Although rare in volume, there are many forms of excluded employment outlined in the UI handbook.²  The most common forms of excluded employment in Wisconsin are self-employment and some forms of agricultural employment.

Rules Around the Collection of Supplemental Data 

Participants who report a SSN will first be matched with the UI wage record. If the employment and earnings are detected in a specific quarter during the reporting period the employment and earnings reporting is complete. Supplemental data may still be collected and entered into the ASSET. Participants in multiple employment may report each employment and earnings.  However, the supplemental data will not be reported to USDOL when the UI wage record has employment or earnings data for the participant.

Authorized supplemental data sources³ are:

Tax documents, payroll records, and employer records such as:

• Copies of quarterly tax payment forms to the Internal Revenue Service, such as a Form 941 (Employer’s Quarterly Tax Return);
• Copies of pay stubs (minimum of two pay stubs within a quarter);
• Signed letter or other information from employer on company letterhead attesting to an individual's employment status and earnings; and
• Income tax records (Schedule C or other).

Other supplemental wage records such as:

• Follow-up survey (self-reported) from program participants;
• Documentation of income earned from commission in sales or other similar positions;
• Detailed documentation supplied by the employer and signed by the career planner or appropriate program staff entered into case notes;
• Automated database systems or data matching with other partners with whom data sharing agreements exist;
• One-Stop operating systems' administrative records, such as a current record of eligibility for programs with income-based eligibility (e.g., Temporary Assistance for Needy Families (TANF) or Supplemental Nutrition Assistance Program (SNAP));
• Self-Employment worksheets (net profit) signed and attested to by program participants.

Note: Although self-reporting options are available, states and local areas must ensure they don't report more than the actual amount earned during any quarter. Entries are subject to audit.

When to ask for Supplemental Data

Each WIOA Performance Indicator has a specific report timeframe for each quarterly or annual report. The report period takes into consideration how much time it takes for the result to happen and two additional quarters for data collection depending on the indicator. The chart below assists in determining when to contact participants for supplemental data.  ASSET System Reports and other Business Intelligence options have been created to assist in determining when a participant requires collection of supplemental data.

Table 1. When to Ask for Supplemental Data

Exceptions:

• Due to data sharing agreement restrictions, the existence of out-of-state wage records are not known until the WIOA performance report periods. Report periods occur after the timeframes in Table 1.
• For participants who are known to enter excluded employment, the recommended collection of supplemental data is the beginning of the quarter after the result happens (the quarter that counts for performance, see Table 2 and Table 3), because the UI wage record will not have the result at any point of the quarter.
• * Credential Attainment Rate timeframes address the employment aspect of the additional requirement that secondary school diploma recipients must be employed at a point during the first four full quarters after exit or enrolled in post-secondary education for a day within 365 days after exit.

Table 2: Supplemental Data Collection timelines for Q2 measured indicators

Table 3: Supplemental Data Collection timelines for Q4 measured indicators

See the WIOA Title I Performance TAG for directions to report Supplemental Data into ASSET.  WIOA Performance SharePoint Access is required.

• ¹20 CFR 677.175
• ²http://dwd.wisconsin.gov/ui201/
• ³TEGL 26-16