BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 274
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          Date of Hearing:   April 13, 2011

                           ASSEMBLY COMMITTEE ON INSURANCE
                                 Jose Solorio, Chair
                 AB 274 (Garrick) - As Introduced:  February 7, 2011
           
          SUBJECT  :   Unemployment insurance: time period for employers to 
          respond.

           SUMMARY  :   Increases the period for employers affected by an 
          unemployment insurance (UI) claim to submit facts to dispute the 
          potential eligibility for UI benefits.  Specifically,  this bill  : 


          1)Authorizes each "employing unit" (hereafter: employer) 
            affected by a claim of UI benefits, within 30 days after the 
            mailing of the notice of the UI claim, to submit to the 
            Employment Development Department (EDD) any facts within its 
            possession disclosing whether the claimant left the employer's 
            employ voluntarily and without good cause or left due to 
            specified circumstances including misconduct, consumption of 
            alcoholic beverages or other intoxicants, to accompany a 
            spouse to a place from which it is impractical to commute, or 
            to protect his or her family or oneself from domestic violence 
            abuse.   
           
          2)Requires each employer, after being notified by EDD of an UI 
            claim, to submit within 30 days any facts known that may 
            affect the claimant's eligibility for benefits, and allows for 
            an extension for good cause. 

          3)If after the 30-day period the employer acquires knowledge of 
            facts that could not reasonably have been known within the 
            period, the employer shall within 30 days of acquiring the 
            knowledge submit the facts to EDD and the 30-day period may 
            also be extended for good cause.  
           
          4)Provides that if, after a notice of determination of UI 
            eligibility, the employer acquires knowledge of facts that may 
            affect the eligibility of the UI claimant and those facts 
            could not have reasonably been known within the 30-day period, 
            the employer shall within 10 days of acquiring that knowledge 
            submit those facts to EDD, and allows this 10-day period to 
            also be extended for good cause.  
           








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           EXISTING LAW  :

          1)Authorizes each employer affected by a claim of UI benefits, 
            within 10 days after the mailing of the notice of the UI 
            claim, to submit to EDD any facts within its possession 
            disclosing whether the claimant left the employer's employ 
            voluntarily and without good cause or left due to specified 
            circumstances including misconduct, consumption of alcoholic 
            beverages or other intoxicants, to accompany a spouse to a 
            place from which it is impractical to commute, or to protect 
            his or her family or oneself from domestic violence abuse.  
           
          2)Requires each employer, after being notified by EDD of an UI 
            claim, to submit within 10 days any facts known that may 
            affect the claimant's eligibility for benefits, and allows for 
            an extension for good cause. 
           
          3)Provides that if after the 10-day period, the employer 
            acquires knowledge of facts that could not reasonably have 
            been known within the period, the employer shall within 10 
            days of acquiring the knowledge submit the facts to EDD, and 
            the 10-day period may also be extended for good cause.   
           
          4)Provides that if, after a notice of determination of UI 
            eligibility, the employer acquires knowledge of facts that may 
            affect the eligibility of the UI claimant and those facts 
            could not have reasonably been known within the 10-day period, 
            the employer shall within 10 days of acquiring that knowledge 
            submit those facts to EDD, and the 10-day period may be 
            extended for good cause.  

           FISCAL EFFECT  :   Undetermined.

           COMMENTS  : 

           1)Background.   According to the author, the existing law 
            requires EDD to provide notice of the filing of an 
            unemployment claim to the claimant's last employing unit, and 
            requires the employer to submit, within 10 days after the 
            mailing of the notice, any facts that may affect the 
            claimant's eligibility for benefits.

           2)Support.   The author states this bill is needed because under 
            existing law, if the employer is required to travel for 
            business, they may not have adequate time to provide the 








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            required facts, thus violating the required process.  If there 
            are pertinent facts which may affect the claimant's 
            eligibility for benefits, the increased time frame allows for 
            accuracy and transparency.

          The California Association for Health Services at Home (CAHSAH) 
            states that the 30-day reporting period provides a much needed 
            reprieve for employers since the ten day timeframe often 
            creates barriers for employers to obtain all of the necessary 
            facts to provide EDD with a clear understanding of the causes 
            for the employee's termination.  CAHSAH also states that small 
            employers who do not have a Human Resource department often 
            have managers and owners that handle multiple roles for the 
            organization and may find it unnecessarily onerous to comply 
            within 10 days.
           
          3)Opposition.   The California Labor Federation, AFL-CIO, states 
            this bill would delay UI benefits to laid off workers, and 
            that current law already grants EDD the discretion to allow 
            for good cause extensions to the amount of time employers have 
            to respond.  The California Labor Federation also states that 
            this is no time to delay the delivery of safety net benefits 
            to laid off workers, and that eligible workers need immediate 
            benefit payments to stay in their homes, feed their families, 
            and gather the resources needed to continue to look for work.  
            Moreover, delaying benefits by nearly three weeks would run 
            the risk of irreparable harm to families and the economies of 
            local communities.  The CA Labor Federation also points out 
            that the recent State Auditor report on the administration of 
            UI benefits by EDD found that the Department is not meeting 
            federal standards for making first payments of UI benefits 
            (i.e., the federal standard is that 80% of the first payments 
            be made within 14 days of the first allowable week), that as a 
            result, California is designated as an  "At Risk" state, and 
            that the timelines proposed by this bill could threaten 
            California's receipt of the federal administrative funds for 
            the Department.
           
           The California Teamsters Public Affairs Council states that the 
            facts material to a claimant's eligibility are limited in 
            nature and consist of information reasonably known to 
            employers at the time of termination.  The CA Teamsters state 
            this would include whether the employee leaves voluntarily or 
            was let go due to misconduct.  Moreover, the existing 
            administrative process does not impose a time-consuming burden 








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            on employers since the submission of facts and the 
            administrative proceedings are informal.  The CA Teamsters 
            state that there are not sufficient reasons for extending the 
            deadline, and that imposing this delay on the families of 
            displaced workers would be inhumane and completely 
            unnecessary.  

          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Association for Health Services at Home (CAHSAH)

           Opposition 
           
          CA Conference Board of the Amalgamated Transit Union
          CA Conference of Machinists
          CA Official Court Reporters Association
          California Labor Federation, AFL-CIO
          California Teamsters Public Affairs Council
          Engineers and Scientists of California
          International Longshore and Warehouse Union
          Professional and Technical Engineers, Local 21
          SCOPE, Laborers International Union of North America
          UNITE HERE!
          United Food and Commercial Workers -Western States Conference
          Utility Workers Union of America, Local 132
           
          Analysis Prepared by  :    Manny Hernandez / INS. / (916) 319-2086