The Pre-Implementation Planning Checklist for UI Modernization Projects is one of the most consequential tools available to the Department of Labor for improving the operational integrity of state UI systems before they go live. When the checklist surfaces a critical function as unaddressed, states can act. When the checklist does not surface it, states often do not know to ask, and the gap gets built into a system that will operate for a decade. The Association of Unemployment Tax Organizations (“AUTO”) submits these comments to identify a category of critical functions the current checklist does not address: the workflows of authorized employer representatives and third-party administrators who are, in practice, the primary operational users of employer-facing state
UI system functions. Read more
