FR 2025-00809

The Department of Labor (DOL) has submitted an information collection request for the Alien Claims Activity Report to the Office of Management and Budget (OMB) for approval. This report is crucial because it gathers data on the use of the USCIS Systematic Alien Verification for Entitlement (SAVE) Program by states to manage unemployment insurance claims for non-citizens. The department is inviting public comments until February 14, 2025, to discuss the necessity, accuracy, and efficiency of this information collection. While aiming for a three-year renewal under the Paperwork Reduction Act, the DOL seeks evidence on the program's usage and effectiveness.

General Summary

The document presents a notice from the Department of Labor regarding the submission of an information collection request to assess how alien claims for unemployment insurance are being handled across states using the federal SAVE system. The notice invites public comments and provides relevant details such as contact information, submission guidelines, and a brief overview of expected burdens on state workforce agencies.

Significant Issues and Concerns

The document could benefit from clearer language, particularly about why this information collection is necessary for the department's functions. While it includes specific figures, such as the estimated number of responses and the time burden, their relationship is not immediately clear, which might confuse some readers. Also, while it lists the "Total Estimated Annual Other Costs Burden" as zero, this could be misleading without elaboration on potential indirect costs associated with the data collection. The minimal "Total Estimated Annual Time Burden" of 212 hours across 53 agencies might also seem surprisingly low, which necessitates further explanation on how these figures were calculated.

References to previous related publications and regulations lack direct links or summaries, making it difficult for readers to cross-reference materials easily. Additionally, the document does not make clear why public commentary is important, which could result in low engagement. The technical nature of terms such as the "USCIS SAVE system" may not be easily understandable to the general public, further hindering public participation.

Furthermore, a crucial issue is the absence of an explanation on how data privacy and security are managed, especially considering the sensitive nature of the information being collected.

Impact on the Public

Broadly, this document informs the public about a data collection process that impacts how non-citizen claims for unemployment benefits are handled. Its implications are significant because it relates to the efficiency and compliance with federal requirements concerning unemployment insurance.

Impact on Stakeholders

For specific stakeholders, particularly state workforce agencies, this document lays out their expected roles and responsibilities and the time burden associated with this reporting requirement. While it emphasizes state compliance with federal verification systems, it does not sufficiently address the practical challenges or costs these agencies might face.

By inviting public comments, the document opens the floor for various stakeholders to voice their opinions or concerns, potentially influencing how the DOL handles similar processes in the future. However, the lack of clear encouragement and accessible language may limit real-world engagement with these stakeholders.

Overall, while the document represents an important step in ensuring effective administration of unemployment benefits, it could greatly benefit from additional clarity, context, and engagement strategies to maximize its effectiveness and relevance.

The document from the Department of Labor outlines an information collection request regarding the Alien Claims Activity Report, with specific references to financial aspects.

Summary of Financial References

The primary and perhaps sole financial reference in the document is noted as the "Total Estimated Annual Other Costs Burden: $0." This indicates that the Department of Labor does not anticipate any additional costs associated with the administration of this information collection request beyond staff time, which is detailed separately as a time burden rather than a monetary expense.

Relation to Identified Issues

One of the issues identified is the seeming lack of clarity and complete picture regarding the financial implications of the report. While the document states there are zero estimated annual other costs, this absence of cost may warrant further elaboration. It is unclear if indirect costs, such as those related to infrastructure, data management, or potential software updates involved in using the USCIS SAVE system, are thoroughly accounted for. The assertion that there are no additional costs would benefit from clarification, especially to address concerns about potential hidden expenses or secondary costs not noted within this document.

Furthermore, given that there are 53 respondents from state workforce agencies and an estimated 212 hours of total annual time burden, understanding the financial mechanics behind these figures could provide better transparency. The estimated time burden implies a certain level of operational commitment, possibly involving internal labor costs at each of these agencies. Detailing these aspects could further clarify if there are indeed costs being absorbed by these state agencies, thereby ensuring the document reflects a comprehensive cost analysis.

Overall, the financial references in this document, specifically the claim of no additional costs, should be subjected to further scrutiny to ascertain the completeness of the fiscal impact assessment related to the Alien Claims Activity Report.