By Hope Kinglock, Certifying Officer and Supervisor, USDOL/ETA Office of Trade Adjustment Assistance
Hello! My name should ring a bell for many of you in the TAA community, as I am one of the TAA Certifying Officers, responsible for authorizing TAA group eligibility determinations. My tenure in OTAA investigations extends back about 18 years; in addition to my certifying officer role, I’ve managed a team of investigators for several years and was an investigator before that. As a result of this combined experience as an investigator, supervisor, and certifying officer, I have worked through thousands of investigations. Therefore, it’s fair to say I know a thing or two about what information is necessary to expedite the collection of information for establishing worker group eligibility!
In response to popular demand, I am providing a quick set of tips for what we in OTAA have identified as some of the most important things that states can do to support petition filing and group eligibility investigation. If you incorporate these tips into your TAA procedures, you will provide OTAA investigators with critical information they need to do their jobs as quickly as possible for the purpose of allowing certifying officers to issue group eligibility determinations.
- Identifying and Providing Company Official Information – This is easily the MOST important data point on a valid petition for investigation purposes. A significant amount of time is taken up with securing an appropriate company official. When confirming the correct company official, state staff should work with the company to identify who can verify:
- worker group description
- sales, production, imports, and customer information
- employment numbers.
It makes an enormous difference if states can assist with identifying an initial contact who can provide some of this information.
- Dislocated Worker Information – This correlates to section 1(i) of the petition: “Describe the worker group on whose behalf this petition is being filed.” If there is an official name (e.g. IT Division, Finance Department, etc.) for the specified worker group at the work address specified, this should be provided. Where this does not apply, please provide as much descriptive detail as possible (e.g. coders, account payable, research and development, etc.). It is helpful, especially for service sector firms/worker groups, to have the dislocated worker group(s) name(s).
For investigative purposes, this information is used to help in working with the company official to hone in on the worker group when a worker description is missing, too vague, or incorrect. This ensures that the investigator is on the right track.
International Trade Commission (ITC) – Please be sure to keep reviewing the notification emails that the Performance Management Data Reporting division sends out regarding worker groups that may be eligible through the ITC provision. Given that this provides an expedited path to certification, it is an easy probable win for quick certification. Note, however, that the verification of a company official who can validate employment count and worker group information is essential in order to capitalize on this unique expedited path to certification.
Communication between TAA investigator and State – Though last on this list, it is VITAL in importance. Our ability to connect with our state partners cannot be overestimated. This holds true whether or not the state filed the petition! Note that investigator names are provided in petition notification letters for all petitions filed within a state. This initial communication serves not only as an introduction, but to initiate the communication process that can occur throughout the investigation. Investigator outreaches occur at the start of a state-filed petition, to confirm/clarify petition filings, as well to obtain additional information to aid companies in completing the data request form as needed. Communications from the investigator likely means there is key information needed to move the investigation forward that you may be able to provide. One goal/one team is a motto we can work towards with communications being the foundation we build this upon. Our relationship with the states is one that we look forward to continue grow and cultivate!