Utah Quarterly Wage Unemployment Insurance Claim Provider Address Cleanup

Issue

A problem with the Employer Address on Quarterly Wage (QW) records was identified by many states. It occurred when states provided the Unemployment Insurance (UI) claim provider, administrator, employer representative, or agent’s address in the Employer Address fields. The results of this problem are:

• IV-D agencies are sending income-withholding orders (IWOs) to the wrong address.
• UI claim providers are being inundated with IWOs and requests for verification of employment they do not have the resources to process.

Explanation

10.37% of Utah’s QW file had UI claim provider addresses in the Employer Address fields. Utah’s State Employment Security Agency, which operates the UI Division of Workforce Services and their Unemployment Insurance Tax and Wage Reporting System, maintains a tax, work-site, claims, and new hire reporting address. The employer new hire reporting addresses are updated monthly from the data received by the new hire registry. They were using the employer’s UI tax address as the address for QW reporting. In Utah, if an employer is using an agent or tax representative, the tax address will include a ‘c/o %’ at the beginning of the first Address line. Utah decided they would never use an address that started with ‘%’ or ‘c/o %’.

Solution

They programmed the system to look first for a new hire address. If the new hire address is available, it is inserted as the employer address for the wage data. If there is no new hire address, the system searches for a tax address. If the tax address does not begin with ‘%’ or ‘c/o %’, it is inserted as the employer’s address. When the tax address starts with ‘%’ or ‘c/o %’, the system searches for a work-site address. The work-site address will be inserted if it is the employer record and is complete. If there is no useable work-site address and the tax address begins with ‘%’ or ‘c/o %’, the employer address is left empty.

When the employer’s Federal Employer Identification Number (FEIN) is missing, the tax address is inserted if there is no work-site address. This means that Utah will be submitting some QW data records without an employer address. When the NDNH processes these records, it will match against the Social Security Administration’s (SSA) FEIN table. If the FEIN is located, the corresponding employer address is retrieved and stored in the NDNH. If the FEIN is located on SSA’s FEIN table, the NDNH will match the FEIN to its own FEIN table. If the FEIN is located, the corresponding employer address is retrieved and stored in the NDNH.

Summary

Utah’s idea to use the available new hire reporting address whenever possible and to never send an address of the UI claims administrator or representative. Substituting the best address available is a best practice that may be used by other states experiencing a similar problem. If a valid alternate address is not available, Utah does not send an address, only the FEIN.