DCL-04-50, New Hire Reporting and Quarterly Wage Data Match for Employer Outreach
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Administration for Children and Families US Department of Health and Human Services

DEAR COLLEAGUE LETTER

DCL-04-50

ATTACHMENT:  Agenda for EPP call
Data Quality Issues
Estimating New Hires
FPLS-BLS New Hires Chart

DATE: November 23, 2004

TO:  ALL STATE IV-D DIRECTORS

RE:  New Hire Reporting and Quarterly Wage Data Match for Employer Outreach

Dear Colleague:

I would like to invite you and your New Hire and Employer Participation Project (EPP) staff to participate in a teleconference call on December 9th or 14th at 1:30 to 3:00PM (EST). The purpose of the calls is to discuss the outreach data that is provided to the states by the Federal Office of Child Support Enforcement (OCSE) and alternatives for improving how states target their employer outreach efforts. 

Every quarter, OCSE sends states the results of a comparison between Quarterly Wage (QW) data and New Hire Reporting (W-4) data. Formerly this data match was called the Employer Participation Project (EPP) and included a “W-4 Reporting Rate”. OCSE considers these new hire reporting rates to be unusually low and not indicative of how well states are running their New Hire Reporting programs. We have advised state staff to use the EPP data for employer outreach purposes only. However, some states interpreted the data to represent an employer new hire compliance rate. 

The PRWORA legislation mandating New Hire Reporting did not set performance standards for employer compliance. However, states have recognized the importance of increasing the number of New Hire reports and have developed impressive employer outreach programs for this reason. The staff in Virginia, for example, reports that 89 percent of employers report their new hires.  Pennsylvania estimates that 80 percent of employers comply with New Hire Reporting. The number of new hires reported nationally by OCSE is generally consistent with the number of new hires reported by the Department of Labor’s Bureau of Labor Statistics, indicating overall compliance of employers with the New Hire Reporting program.

Reporting an accurate employer new hire compliance rate is not possible using the former EPP methodology because of unresolved data anomalies occurring in the comparison of QW submissions to W-4 records. The problems with using this methodology to measure employer compliance include the following:

o Multistate employers report new hires with one Federal Employer Identification Number (FEIN), but report the quarterly wages of those same individuals using a different, subsidiary FEIN, making a comparison between the two databases problematic. 

o Employers’ temporary and seasonal hires may incorrectly appear as not compliant with New Hire Reporting requirements. For example, a teacher not working in the summer and, thus, for whom there would be no QW report for that quarter, may appear to be an unreported new employee when she/he returns to work in the fall.

Teleconference Call Information

The agenda will be the same for both days; therefore, participants should choose which day would be more convenient. The dial in number for the call is 1-866-732-9184. The passcode is 311214. Please plan to use only one port per state.

Enclosed you will find the agenda along with the following handouts which will provide additional information on the discussion:

• Data quality issues as reported in the User Guide for the Employer Participation Report

• Monthly Number of New Hires (2001-2004)

• Estimating New Hire Reporting Compliance

If you have any questions, please contact Carol Callahan at (202) 401-6969, or ccallahan@acf.hhs.gov.

Sincerely,

Sherri Z. Heller, Ed.D.
Commissioner
Office of Child Support Enforcement

Enclosure

cc: Regional Program Managers
    ACF Regional Administrators
    State New Hire Reporting contacts (formerly Employer Participation Project contacts)
    Employer Outreach Contacts