Sample Investigation Project for DOL EBSA
Challenge: The U.S. Department of Labor (DOL) Employee Benefits Security Administration (EBSA) ensures the security of private-sector, employer-sponsored retirement, health and other workplace-related benefits of American workers. EBSA needed to establish outcome-based measures for its enforcement program to prevent violations of the Employee Retirement Income Security Act (ERISA).
Solution: Summit worked across DOL offices to obtain and interpret individual-level enforcement data and map it to tax form data, as well as final data on enforcement outcomes. To attain a complete understanding of the enforcement process, Summit experts shadowed enforcement staff, observing how the different steps of the enforcement process were captured in the Office of Enforcement data systems that became the basis of our analysis. This project has involved the use of several novel statistical techniques to deal with the methodological challenges of this engagement. This has included the use of survival analysis to provide estimates of preliminary evaluation outcomes before the evaluation is complete, use of nonparametric re-sampling methods to estimate the confidence intervals around estimates, and use of a complex sampling design that takes into consideration both statistical issues, as well as the workload concerns of enforcement staff. Use of these advanced methods ensures that EBSA’s evaluation is rigorous enough to withstand scrutiny from the Office of Management and Budget, the U.S. Congress, and industry.