Source + trust record
Source checked as of September 18, 2026. Primary authority: USDOL TEGL 26-16, Change 1.
Check result: TEGL 26-16, Change 1 remains active continuing federal guidance. It permits supplemental wage information when reliable administrative wage records are unavailable or incomplete, while preserving wage-record matching as the preferred source. Supplemental data must be supported by acceptable documentation and used consistently with performance-reporting and validation rules. This AI-assisted brief does not receive human legal or compliance review. Official sources control.
When a real employment outcome is missing from the wage record
TEGL 26-16, Change 1 explains how WIOA programs can document employment and earnings when normal UI wage records do not capture the job. Supplemental wage information is especially important for self-employment, federal or military employment, the Postal Service, farmwork, and participants without an SSN available for matching.
At a glance
Agency
USDOL / USDOE
Guidance
TEGL 26-16, Change 1
Issued
July 10, 2025
Status
Continuing
Preferred source
Direct wage / administrative record match
Supplemental use
When standard wage data are unavailable or incomplete
Measures
Employment Q2 · Employment Q4 · Median Earnings Q2 · ESE
Executive takeaway
WIOA requires states to use wage records for performance accountability, and DOL still recommends direct wage-record matches whenever possible because they are the most reliable source. But wage systems do not capture every type of employment. TEGL 26-16, Change 1 allows states to use supplemental wage information so legitimate employment outcomes are not automatically lost from performance reporting.
The flexibility comes with controls. Programs need a method to identify participants whose wages are unlikely to appear in normal records, collect the information at the correct post-exit point, use an acceptable source, document actual earnings paid during the quarter, and maintain consistent procedures so the data are valid and repeatable.
Five things to know
- Direct wage records remain preferred. Supplemental information is an alternative when reliable administrative wage data are not available or do not capture the employment.
- Missing wage data are not neutral. If a state does not use supplemental information, participants without a wage match remain in applicable employment denominators and generally count as negative outcomes.
- Actual wages matter. Median Earnings Q2 must reflect wages actually paid during the quarter, not projected earnings.
- The source must be internally consistent. If supplemental information is used for both employment status and wages in the same reporting period, the same supplemental source should support both.
- Follow-up should start early. When staff already know UI wage data will not exist, they do not need to wait for a failed wage match before preparing to collect supplemental information.
When supplemental wage information is most useful
| Employment situation | Why normal UI wage data may not be enough |
|---|---|
| Federal employment | Federal employment can sit outside the state UI wage-record system. |
| Military employment | Military earnings may require federal/military administrative records or supplemental verification. |
| U.S. Postal Service | Postal employment may not appear in ordinary state UI records. |
| Self-employment / entrepreneurship | No employer UI wage report may exist; earnings can require self-employment documentation. |
| Farmwork or other employment not covered by the state UI system | The work can be real while the normal wage match remains incomplete. |
| No SSN available for matching | The program may need another reliable way to establish employment and earnings. |
Acceptable supplemental sources
| Source | What it can provide |
|---|---|
| Tax / payroll records | Quarterly tax forms, payroll records, and at least two pay stubs can support earnings and employment. |
| Employer documentation | A signed employer letter or equivalent company information can attest to employment and earnings. |
| Post-exit participant follow-up | Self-reported employment and wage information gathered through the program’s follow-up process. |
| Employer-verified case notes | Detailed case notes documenting employment and wage information obtained from the employer. |
| Administrative databases / data matching | Reliable records from partner agencies or other systems covered by data-sharing agreements. |
| Self-employment worksheet | Participant-signed and attested records supporting self-employment earnings or net profit. |
The timing problem
UI wage records are delayed. Second-quarter wage information generally does not become available until late in the third quarter after exit, and fourth-quarter information becomes available later still. DOL recommends collecting supplemental information as soon as practical after the relevant quarter closes when the program knows the wage record will not be available.
Before exit
Tell participants they may be contacted later, keep multiple contact methods current, and identify employment types likely to need supplemental verification.
After the relevant quarter
Collect information promptly while the participant and employer are easier to locate and the records are fresh.
Do not annualize wages into the performance record
DOL provides wage-conversion tools that can help staff understand earnings across different pay schedules, but the Median Earnings Q2 performance record must use wages actually paid during the quarter. A projected annual salary or a weekly wage multiplied forward is not the quarterly earnings value the indicator is designed to report.
Effectiveness in Serving Employers adds an employer-identity question
For the retention component of Effectiveness in Serving Employers, the system needs to know whether the second- and fourth-quarter employer is the same employer. A Federal Employer Identification Number is preferable. When the supplemental source does not contain a FEIN, the state should establish other details that reliably show the employer is the same.
WDB implementation considerations
- Identify likely no-match cases early. Flag self-employment, federal/military work, Postal Service, farmwork, and other employment likely to sit outside ordinary UI wage matching.
- Keep post-exit contact information current. Supplemental collection succeeds only if the participant or employer can still be reached.
- Use uniform written procedures. Staff should collect the same fields, ask the same core questions, and document the source consistently.
- Capture actual quarterly earnings. Avoid projected or annualized values in the performance record.
- Retain the supporting source. Supplemental wage data must survive validation and monitoring just like other performance data.
- Follow California procedures. Use current EDD CalJOBS, performance, and data-validation rules when entering and validating supplemental wage information.
Implementation traps
- Waiting for a wage-record failure when staff already know the job will not appear in the UI system.
- Using a participant’s expected salary instead of wages actually paid during the reporting quarter.
- Recording employment from one source and earnings from a conflicting source in the same reporting period.
- Collecting supplemental information informally without a source or documentation that can be validated later.
Source basis and interpretation
Primary source: USDOL TEGL 26-16, Change 1 — Supplemental Wage Information for WIOA Performance Accountability
California implementation context: use with EDD performance guidance, source-documentation requirements, and data-validation procedures.
How to use this brief: Federal methods summarize TEGL 26-16, Change 1. States control implementation through their reporting systems and procedures. California Local Areas should follow current EDD instructions for CalJOBS entry, source documentation, and data validation.