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Audit Survey — States Cite Fraud Vulnerabilities from PUA Self-Certification Requirement

Filed October 21, 2020 in DOL OIG Unemployment Insurance; one of 15 filings from this case.

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CourtU.S. Department of Labor, Office of Inspector General
Filed2020-10-21

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EMPLOYMENT AND TRAINING 
ADMINISTRATION                                  
COVID-19: STATES CITE 
VULNERABILITIES IN DETECTING 
FRAUD WHILE COMPLYING WITH THE 
CARES ACT UI PROGRAM SELF-
CERTIFICATION REQUIREMENT   
DATE ISSUED: OCTOBER 21, 2020
REPORT NUMBER: 19-21-001-03-315

U.S. Department of Labor 
Office of Inspector General 
Audit 
 
BRIEFLY… 
 
 
 
 
 
 
 
 
 
 
 
 
COVID- 19: STATES CITE VULNERABILITIES 
IN DETECTING FRAUD WHILE COMPLYING 
WITH THE CARES ACT UI PROGRAM SELF-
CERTIFICATION REQUIREMENT  
 
October 21, 2020 
 
WHY OIG CONDUCTED THE AUDIT 
 
The Coronavirus Aid, Relief, and Economic 
Security (CARES) Act of 2020 creates several 
programs that temporarily expand 
unemployment benefits for workers affected by 
the COVID-19 pandemic. The CARES Act 
provides for up to 39 weeks of Pandemic 
Unemployment Assistance (PUA). The PUA 
program requires applicants to self-certify that 
they are unemployed because of a COVID-19 
related reason, and advises claimants against 
making fraudulent representations.  
 
This audit focused on the actions taken by the 
Employment and Training Administration (ETA) 
and states to deter and detect fraud relating to 
the self-certification process of the PUA 
program. 
 
WHAT OIG DID 
 
We conducted our audit to determine the 
following: 
 
What steps are states taking to implement 
the PUA program and deter and detect fraud 
related to applicants’ self-certification? 
 
We interviewed ETA to determine what steps 
the Department has taken to oversee states’ 
compliance. We also developed a survey to 
obtain information from states on their 
implementation of the PUA program, the self-
certification process, and tools used to detect 
and deter fraud.  
 
 
WHAT OIG FOUND 
 
While states have processes in place for 
claimants to self-certify they meet eligibility 
requirements for PUA benefits, they still 
reported challenges when implementing the 
program and detecting and deterring fraud.  
 
States cited challenges while implementing 
PUA program. All respondents said they have 
implemented processes for applicants to self-
certify for PUA benefits. However, 98 percent 
said their state faced challenges while 
implementing the PUA program. Specifically, 
states identified a lack of resources to address 
the high volume of claims, untimely and unclear 
guidance from ETA, and incompatible legacy 
systems as top challenges.  
 
States cited PUA self-certification 
requirement as a top fraud vulnerability. 
Despite strategies and tools for mitigating fraud, 
53 percent of respondents still cited fraud 
vulnerabilities within the PUA program. Ninety-
one percent of respondents said that they use a 
variety of tools to detect and deter fraud, such 
as predictive analytics and cross-matching with 
other databases to verify eligibility. In addition, 
89 percent of respondents said their state 
requires applicants to acknowledge that his/her 
self-certification is subject to penalty of perjury. 
However, states reported inherent vulnerability 
in the legislative self-certification process, 
systems issues, and inadequate fraud 
screening tools.  
 
We will follow up on the survey results in OIG’s 
current audit of DOL and States’ 
Implementation of CARES Act UI Provisions. 
 
 
    
 
READ THE FULL REPORT: 
 
http://www.oig.dol.gov/public/reports/oa/2020/19-
21-001-03-315.pdf 
 

U.S. Department of Labor – Office of Inspector General  
TABLE OF CONTENTS 
INSPECTOR GENERAL’S REPORT .................................................................... 1 
 
 
 
-I-  
BACKGROUND .................................................................................................... 2 
RESULTS ............................................................................................................. 3 
States cited challenges while implementing PUA program ........................ 3 
States cited PUA self-certification requirement as top fraud 
vulnerability ................................................................................................ 6 
CONCLUSION ...................................................................................................... 8 
Summary of ETA UI’s Response ................................................................ 9 
EXHIBIT 1: SUMMARY OF PUA SURVEY RESULTS ....................................... 10 
EXHIBIT 2: PUA SURVEY RESPONSES ........................................................... 11 
APPENDIX A: SCOPE, METHODOLOGY, & CRITERIA .................................... 12 
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ............................... 14 
APPENDIX C: ACKNOWLEDGEMENTS ........................................................... 16 
 
 

U.S. Department of Labor 
Office of Inspector General 
 
 
Washington, D.C. 20210 
INSPECTOR GENERAL’S REPORT 
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315  
John P. Pallasch 
Assistant Secretary  
 For Employment and Training 
U.S. Department of Labor 
200 Constitution Ave, NW 
Washington, DC 20210 
 
 
This report presents the results of our audit of the self-certification process for the 
Coronavirus Aid, Relief, and Economic Security Act’s (CARES Act) Pandemic 
Unemployment Assistance (PUA) program. The audit focused on the processes 
that state workforce agencies use to determine claimant eligibility and their 
actions to deter and detect fraud relating to self-certifications.   
 
The CARES Act’s PUA program expands Unemployment Insurance (UI) eligibility 
to individuals who are not typically eligible to obtain benefits and creates several 
programs that temporarily expand unemployment benefits for workers affected by 
the COVID-19 pandemic. The CARES Act provides for up to 39 weeks of PUA 
benefits and requires individuals to self-certify that they lost employment income 
due to a COVID-19 related reason. As of July 8, 2020, disbursements for PUA 
benefits were nearly $110 billion.1 Historically, UI programs have among the 
highest improper payment rates of all federal programs. An unprecedented 
volume of claims and the short timeframe to implement the PUA program under 
the CARES Act have contributed to the risk of improper payments and fraud.   
 
We conducted this audit to answer the following question: 
 
What steps are states taking to implement the PUA program and deter 
and detect fraud related to applicants’ self-certification? 
 
 
Based on the results of our audit, states reportedly are taking steps to deter 
and detect fraud related to the PUA program but continue to face challenges in 
implementing the program. One hundred percent of the 45 states that 
responded to the survey and had started paying PUA benefits said their state 
                                            
1 This includes an estimated $61.5 billion for the Federal Pandemic Unemployment 
Compensation (FPUC) portion of the PUA program. 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
complied with the self-certification requirements, however 98 percent reported 
challenges in implementing the PUA program.  
 
To conduct our audit, we reviewed federal and departmental guidance; 
interviewed DOL staff; and analyzed responses from our questionnaire used to 
survey states participating in the PUA Program.  
 
 
 
BACKGROUND 
 
 
The CARES Act §2102(a)(3) provides PUA coverage to individuals: (1) who are 
not eligible for regular unemployment compensation and (2) who self-certify that 
they are able and available for work but unemployed due to a COVID-19 related 
reason. This includes individuals who have exhausted eligibility for regular UI 
benefits, are self-employed, work in a gig economy, are clergy, and others not 
previously covered by UI programs. To meet eligibility requirements, claimants 
must self-certify that one of the reasons identified within §2102 applies to their 
employment situation. Claimants generally self-certify by checking a box next to 
a qualifying reason on the form submitted to state workforce agencies. The form 
requires the individual to acknowledge a warning that intentional 
misrepresentation to obtain PUA benefits constitutes fraud.  
 
The following are examples of COVID-19 related reasons that qualify individuals 
for PUA program benefits:  
 
• Place of employment is closed as a direct result of the COVID-19; 
• Unable to reach place of employment due to COVID-19; 
• Scheduled to commence employment but does not have a job as a 
direct result of the COVID-19; 
• Diagnosed with COVID-19 or experienced symptoms and is 
seeking medical diagnosis; 
• Providing care for a family or household member diagnosed with 
COVID-19; or  
• A child or other household member for which the individual has 
primary caregiving responsibility is unable to attend school or 
another facility that is closed due to COVID-19. 
 
Individuals who qualify for PUA are generally eligible to receive a weekly benefit 
amount (WBA) equivalent to the state’s regular unemployment compensation 
plus an additional $600 weekly payment. ETA uses multiple tools to oversee 
state implementation of the PUA program. These tools include publishing 
Unemployment Insurance Program Letters (UIPLs), guidance transmitted directly 
to states and posting that guidance on ETA’s public facing website. 
 

U.S. Department of Labor – Office of Inspector General  
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NO. 19-21-001-03-315 
 
 
RESULTS 
 
 
As part of our audit, the OIG developed a questionnaire to survey states 
participating in the PUA program. The purpose of this nationwide survey was to 
determine the actions and steps states have taken to deter and detect fraud 
related to PUA self-certifications. We sent a survey to all 50 states, the District of 
Columbia, Puerto Rico, and the Virgin Islands.2 We received 45 responses (85 
percent) consisting of 44 states and 1 U.S. territory (See Exhibit 2). Our survey 
revealed, while states have processes in place for claimants to self-certify they 
meet eligibility requirements for PUA benefits, they still reported challenges when 
implementing the program and detecting and deterring fraud.  
 
States cited challenges while implementing PUA program. All respondents 
said they have implemented processes for applicants to self-certify for PUA 
benefits. However, 98 percent said their state faced challenges while 
implementing the PUA program. Specifically, states identified a lack of resources 
to address the high volume of claims, untimely and unclear guidance from ETA, 
and incompatible legacy systems as top challenges. In addition to the challenges 
faced, states reported various fraud vulnerabilities.  
 
States cited PUA self-certification requirement as a top fraud vulnerability. 
Despite strategies and tools for mitigating fraud, 53 percent of respondents still 
cited fraud vulnerabilities within the PUA program. Ninety-one percent of 
respondents said that they use a variety of tools to detect and deter fraud, such 
as, predictive analytics and cross-matching with other databases to verify 
eligibility. In addition, 89 percent of respondents said their state requires 
applicants to acknowledge that his/her self-certification is subject to penalty of 
perjury. However, states reported inherent vulnerability in the self-certification 
legislative requirement, systems issues, and inadequate fraud screening tools as 
top fraud vulnerabilities.   
 
STATES CITED CHALLENGES WHILE 
IMPLEMENTING PUA PROGRAM 
 
Individuals covered by the CARES Act are required to self-certify, under the 
penalty of perjury, that they are able and available to work and lost employment 
income due to a COVID-19 related reason in order to be eligible for the PUA 
program. 
 
                                            
2 American Samoa, Northern Mariana Islands, Guam, and Palau were not included because at 
the time of our survey they had not received PUA funding. 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
On April 5, 2020, ETA issued the Unemployment Insurance Program Letter 
(UIPL) No. 16-20 to State Workforce Agencies as guidance on the self-
certification process. This UIPL informs states they are to do the following: 
 
“To ensure the efficacy and integrity of the self-certification process:  
 
• Include information on the self-certification form (either paper or on-
line) that the claimant completes, including:  
o Separate from the actual certification, an acknowledgement that 
the claimant understands that making the certification is under 
penalty of perjury; and  
o Information that advises the claimant that intentional 
misrepresentation in self-certifying that he or she falls in one or 
more of these categories is fraud. 
 
• Provide clear messaging online that claimants may be subject to 
criminal prosecution if they are found to have committed fraud.”  
 
All states that responded to our survey that were accepting applications and 
paying PUA benefits required claimants to self-certify that he/she meets one of 
the COVID-19 criteria. (See Exhibit 1) 
 
Because the CARES Act and UIPL 16-20 require states to take steps to ensure 
claimants are aware of the implications of fraudulent self-certification, we asked 
states three questions related to their messaging to claimants regarding fraud, 
perjury, and criminal prosecution.  
 
States that answered no to the survey question indicated that they did have fraud 
messaging but were unsure if they used or did not use the specific language 
“penalty of perjury”. We documented affirmative responses to these questions in 
Table 1.  
 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
Table 1: Fraud Messaging by States 
 
Survey Question 
Response: Rate 
1. Is the claimant advised that intentional misrepresentation in 
the self-certification process is fraud? 
Yes: 100% 
2. Is the claimant required to acknowledge that his/her self-
certification is subject to penalty of perjury? 
Yes: 89%  
 
3. Does your state website provide clear messaging online 
that claimants may be subject to criminal prosecution if they 
are found to have committed fraud? 
Yes: 91% 
 
 
Source: OIG analysis of PUA Survey results 
 
 
In UIPL 23-20, ETA strongly recommends states use cross-matching with state 
and national databases (e.g., Social Security Administration, Interstate Benefits, 
State Directory of New Hires, Incarceration…). However, the Department’s 
Solicitor’s Office asserts that states have no authority to require claimants to 
provide documentation of wages earned or income verification. The OIG 
believes state’s reliance on self-certifications alone to ensure eligibility for PUA 
will lead to increased improper payments and fraud. 
 
All of the states in our survey that implemented the PUA program indicated they 
require claimants to certify that he/she meets one or more of the COVID-19 
criteria when applying for PUA benefits. Fifty-eight percent of states responded 
that they use PUA eligibility requirements beyond self-certification. These 
additional requirements identified by states generally included: 
 
• documentation of wages earned or income verification; and 
• Cross-matching with the Social Security Administration, Department of 
Motor Vehicle, or other identity verification databases.  
 
States reportedly used these steps to verify claimant’s eligibility. Despite 
implementing these steps and complying with the self-certification and fraud 
messaging requirements, 98 percent of states reported they still faced 
challenges. 
 

U.S. Department of Labor – Office of Inspector General  
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NO. 19-21-001-03-315 
We asked states what challenges they faced in implementing the PUA provisions 
under the CARES Act and whether they have identified system vulnerabilities. 
Table 2 shows the top five challenges the 44 state respondents identified.  
Because of the historically high volume of UI claims due to COVID-19, it is not 
surprising that shortage of resources tops the challenges that most states faced 
in implementing the PUA program. Despite the guidance ETA issued, a 
significant number of states indicated it came too late or was not clear. The time 
constraints states were working under to implement the new UI programs poised 
another challenge as many of them struggled to pay benefits in a timely manner. 
What might be considered a familiar challenge is states’ continued use of legacy 
systems for the regular UI program. According to ETA most states had to bring 
up new IT systems to implement PUA that were not compatible with legacy 
systems. 
 
STATES CITED PUA SELF-CERTIFICATION 
REQUIREMENT AS TOP FRAUD 
VULNERABILITY  
 
Overall, states reported they were taking precautions to detect, deter, and report 
fraud related to the PUA program. As of June 18, 2020, 29 states provided the 
number of PUA claims they identified as possibly fraudulent. The number of 
potentially fraudulent PUA claims ranged from less than 1 percent to 51 percent. 
Figure 1 breaks down the number of states that reported potentially fraudulent 
 
 
Table 2: Top Challenges States Faced in Implementing PUA 
 
Challenges 
Percentage 
of States 
1. Shortage of resources to handle the volume of claims 
59% 
2. ETA guidance was untimely and unclear 
34% 
3. Legacy systems were not compatible to interface with current 
systems and tools 
32% 
 
4. The limited amount of time states were provided to implement PUA 
program  
30% 
5. Inability to leverage other UI program implementation processes 
with the requirements of the new  PUA program 
25% 
 
Source: OIG analysis of PUA Survey results 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
claims. The majority of the states reported less than 5 percent of potentially 
fraudulent PUA claims. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Source: OIG analysis of PUA Survey results 
 
We asked respondents to identify their strategies and tools for detecting and 
deterring fraud and to provide supporting documentation for those tools. Ninety-
one percent (41 of 45 states) reported they use a variety of existing strategies 
and tools used for traditional UI programs. Our survey revealed that of those 41 
states that reported as having strategies and tools: 
 
• 85 percent use predictive analytics to identify suspicious claims; 
• 68 percent generate and use ad hoc reports from legacy systems, 
Unemployment Integrity Center operated by the National Association of 
State Workforce Agencies;  
• 66 percent use cross-matching; 
• 39 percent partner with local investigative authorities, and utilize public 
tips and hotline complaints. 
 
Based on the responses from the survey, the majority of states used one or more 
of the following tools: stopping payment for claims when they detect suspected 
fraud, conducting investigations, and referring cases to DOL/OIG for 
investigation. In addition, some states also said they report suspected fraud to 
state and local law enforcement. Specifically, states noted they may take several 
actions with potentially fraudulent claims: 
 
Figure 1 
0
2
4
6
8
10
12
14
16
18
20
22
24
0 to 4%
5 to 10%
11 to 15%
16 to 20%
31 to 35%
46 to 50%
51 to 55%
Number of States 
Percentage of Potentially Fraudulent Claims Identified
Potentially Fraudulent Claims Identified by States

U.S. Department of Labor – Office of Inspector General  
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NO. 19-21-001-03-315 
• 28 states stop payments;  
• 35 states initiate investigations;  
• 38 states report suspected fraud to U.S.DOL OIG; and 
• 18 states report suspected fraud to state and local law enforcement 
agencies. 
 
Although states have reported various tools and strategies to detect and deter 
fraud, 53 percent of states reported that fraud vulnerabilities still exist. States 
identified the following fraud vulnerabilities in Table 3 below: 
 
 
Table 3: Top Fraud Vulnerabilities States Faced in Implementing PUA 
 
Fraud Vulnerabilities 
Percentage 
of States 
1. Vulnerabilities are inherent in the self-certification legislative 
requirement  
29% 
 
2. Inadequate fraud screen filters, tools, and program controls 
25% 
3. Issues with new systems and system enhancements 
21% 
4. Inability to interface legacy systems with databases limits cross-
matching verification capabilities  
17% 
5. Claim volume 
  8% 
 
Source: OIG analysis of PUA Survey results 
 
Based on the feedback we received in the survey, we found that there are 
various fraud vulnerabilities identified by states despite the tools and strategies 
implemented. States identified the self-certification legislative requirement as the 
top fraud vulnerability in implementing the PUA program. In addition, states 
reported inadequate fraud tools, filters, and program controls, system issues, 
cross-matching vulnerabilities and claim volume as other vulnerabilities in 
detecting and deterring fraud.  
 
 
CONCLUSION 
 
Based on the results of our survey, states have procedures in place for claimants 
to self-certify their eligibility for PUA benefits with the acknowledgement that 
making fraudulent representations could lead to prosecution. While most states 
appear to be taking steps to detect and deter suspected fraudulent claims, many 
still face resource and system challenges that lessen their ability to better detect 
and deter fraud. Although ETA has provided guidance to address some of these 
challenges, states reported that ETA guidance is often too late and requires 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
additional clarification. We will follow up on the survey results in OIG’s current 
audit of DOL and States’ Implementation of CARES Act UI Provisions. 
 
 
SUMMARY OF ETA UI’S RESPONSE 
 
The Assistant Secretary for Employment and Training agreed with our results. 
Specifically, ETA agreed that the PUA program’s legal structure makes it 
vulnerable to fraud and affirmed its commitment to working with states to ensure 
they have access to the most innovative and effective tools to combat fraud 
schemes. Demonstrating this continued commitment, ETA highlighted the 
Secretary of Labor’s letter to states and U.S. Territories dated September 29, 
2020, which outlines nine specific areas to stress the importance of program 
integrity and fraud prevention. 
 
ETA’s written response to our draft report is included in its entirety in Appendix B. 
 
    
 
We appreciate the cooperation and courtesies ETA extended us during this audit. 
OIG personnel who made major contributions to this report are listed in 
Appendix C. 
 
 
 
Elliot P. Lewis 
Assistant Inspector General for Audit 
 
 

U.S. Department of Labor – Office of Inspector General  
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NO. 19-21-001-03-315 
EXHIBIT 1: SUMMARY OF PUA SURVEY RESULTS   
 
 
 
Survey Questions 
 
Yes 
No 
1. Has your state started paying PUA benefits?  
98% 
2% 
2. Has the U. S. Department of Labor, Office of 
Unemployment Insurance provided adequate 
guidance to assist your state’s implementation 
of the PUA program? 
60% 
40% 
3. Does your state require claimants to self-certify 
that he/she meets one or more of the COVID-
19 related criteria when applying for PUA 
benefits? 
100% 
 
0% 
4. Does your state have other PUA eligibility 
requirements beyond the claimant’s self-
certification?  
58% 
42% 
5. Is the claimant advised that intentional 
misrepresentation in the self-certification 
process is fraud? 
100% 
0% 
6. Is the claimant required to acknowledge that 
his/her self-certification is subject to penalty of 
perjury? 
89% 
11% 
7. Does your state have strategies and tools in 
place for detecting and deterring fraud in the 
PUA Program?  
91% 
9% 
8. Does your state website provide clear 
messaging online that claimants may be 
subject to criminal prosecution if they are found 
to have committed fraud? 
91% 
9% 
9. Does your state refer suspected PUA fraud to 
the U.S. Department of Labor, Office of 
Inspector General for further investigation? 
84% 
16% 
10. Has your state identified any fraud 
vulnerabilities in its systems as it handles the 
high volume of claims due to the COVID-19 
Pandemic and CARES Act PUA?  
55% 
45% 
 
Source: OIG analysis of PUA Survey results 
 
 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
EXHIBIT 2: PUA SURVEY RESPONSES   
 
 
 
 
 
 
 
States and Territories that  
Responded to PUA Survey 
States and Territories 
that Did not Respond 
to the PUA Survey 
 
1 
 
Alaska 
 
24 
 
Nebraska 
 
1 
 
Alabama 
2 
Arizona 
25 
Nevada 
2 
Kentucky 
3 
Arkansas 
26 
New Hampshire 
3 
New Mexico 
4 
California 
27 
New Jersey 
4 
New York 
5 
Colorado 
28 
North Carolina 
5 
Puerto Rico 
6 
Connecticut 
29 
North Dakota 
6 
Tennessee 
7 
Delaware 
30 
Ohio 
7 
District of Columbia 
8 
Florida 
31 
Oklahoma 
8 
Idaho 
9 
Georgia 
32 
Oregon 
 
 
10 
Hawaii 
33 
Pennsylvania 
 
 
11 
Illinois 
34 
Rhode Island 
 
 
12 
Indiana 
35 
South Carolina 
 
 
13 
Iowa 
36 
South Dakota 
 
 
14 
Kansas 
37 
Texas 
 
 
15 
Louisiana 
38 
Utah 
 
 
16 
Maine 
39 
Vermont 
 
 
17 
Maryland 
40 
Virginia 
 
 
18 
Massachusetts 41 
Virgin Islands 
 
 
19 
Michigan 
42 
Washington 
 
 
20 
Minnesota 
43 
West Virginia 
 
 
21 
Mississippi 
44 
Wisconsin 
 
 
22 
Missouri 
45 
Wyoming 
 
 
23 
Montana 
 
 
 
 
 
                  Source: OIG analysis of PUA Survey results 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
APPENDIX A: SCOPE, METHODOLOGY, & CRITERIA 
 
SCOPE 
 
This report reflects audit work completed in DOL Headquarters in Washington, 
DC. Our work focused on the implementation of the PUA program under the 
CARES Act and the steps taken to detect and deter fraud in the self-certification 
process. The period covered for our audit was from March 27, 2020 (enactment 
of CARES Act) to June 18, 2020 (survey close date). We developed and sent a 
survey to all 50 states, the District of Columbia, Puerto Rico, and the Virgin 
Islands. 
 
METHODOLOGY 
 
We conducted this performance audit in accordance with generally accepted 
government auditing standards. Those standards require that we plan and 
perform the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit objective. 
We believe that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objective.  
 
We examined the CARES Act, UIPLs 16-20 and 23-20 issued by ETA. Based on 
our evaluation of the CARES Act and ETA’s guidance, we developed a 
questionnaire to survey states participating in the PUA program. In addition, we 
interviewed ETA’s staff on its oversight role. We sent the survey to all 50 states, 
the District of Columbia, Puerto Rico, and the Virgin Islands. We did not include 
American Samoa, Northern Mariana Islands, Guam, and Palau because at the 
time of our survey they had not received funding.  
 
Using the results of the survey, we were able to determine the steps states and 
ETA are taking to implement the PUA program, and to deter and detect fraud 
related to applicants’ self-certifications. In addition, we were able to identify the 
top challenges states faced in implementing the program, fraud vulnerabilities, 
and effectiveness of guidance received. 
 
RELIABILITY ASSESSMENT 
 
We did not perform a data reliability assessment. Our audit was limited to 
obtaining information from states via survey about the steps taken to implement 
the PUA program and detecting and deterring fraud in applicants’ self-
certification. In addition, through interview we obtained information about ETA’s 
administration and oversight of the CARES ACT UI provisions.   
 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
INTERNAL CONTROLS 
 
In planning and performing our audit, we considered ETA’s internal controls 
relevant to our audit objective by obtaining an understanding of those controls, 
and assessing control risks for achieving our objective. The objective of our audit 
was not to provide assurance of the internal controls; therefore, we did not 
express an opinion on ETA’s internal controls. Our consideration of internal 
controls for administering the accountability of the program would not necessarily 
disclose all matters that might be significant deficiencies. Because of the inherent 
limitations on internal controls, or misstatements, noncompliance may occur and 
not be detected. 
 
CRITERIA 
 
1. Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Title II, 
Assistance for American Workers, Families, and Businesses 
2. Unemployment Insurance Program Letter No. 16-20 
3. Unemployment Insurance Program Letter No. 23-20 
 
 
 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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APPENDIX B: AGENCY’S RESPONSE TO THE REPORT 
 
 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
 
 

U.S. Department of Labor – Office of Inspector General  
PUA SELF-CERTIFICATION 
 
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NO. 19-21-001-03-315 
 
 
APPENDIX C: ACKNOWLEDGEMENTS 
 
Key contributors to this report were: 
 
Dwight Gates, Audit Director 
Jaimie Richardson, Audit Manager 
Jennifer Dunbar, Management and Program Analyst 
Hilda Gil, Auditor 
Wangui Njuguna, Writer-Editor 
 
 
 
 

 
 
 
 
 
REPORT FRAUD, WASTE, OR ABUSE  
TO THE DEPARTMENT OF LABOR 
 
 
 
 
Online 
http://www.oig.dol.gov/hotline.htm 
 
Telephone 
(800) 347-3756 or (202) 693-6999 
 
Fax 
(202) 693-7020 
 
Address 
Office of Inspector General 
U.S. Department of Labor 
200 Constitution Avenue, NW 
Room S-5506 
Washington, DC 20210

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