Alert Memorandum: ETA Needs to Ensure State Workforce Agencies Report Activities Related to CARES Act Unemployment Insurance Programs (DOL…

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An alert memorandum issued August 2, 2022 by the U.S. Department of Labor, Office of Inspector General, Report Number 19-22-004-03-315, addressed to the Assistant Secretary for Employment and Training from the Assistant Inspector General for Audit. It reports that states have either not submitted required CARES Act Unemployment Insurance program reports to the Employment and Training Administration or reported zero activity, and that ETA should obtain the missing reports even though the programs expired September 6, 2021. The memorandum states that ETA issued 11 Unemployment Insurance Program Letters and required 53 states to submit 14 different reports for seven programs, of which the OIG analyzed 8. It notes a prior finding that 42 percent of states did not complete quarterly overpayment reporting, and that $4.4 billion in reported UI benefit overpayments could not be relied upon.

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U.S. Department of Labor 
Office of Inspector General 
 
 
Washington, D.C. 20210 
 
Working for America’s Workforce 
 
August 2, 2022 
 
 
MEMORANDUM FOR: 
BRENT PARTON 
 
Assistant Secretary  
 
  for Employment and Training 
 
                                         
 
FROM: 
CAROLYN R. HANTZ 
Assistant Inspector General  
  for Audit 
 
 
SUBJECT: 
Alert Memorandum: The Employment 
and Training Administration Needs to 
Ensure State Workforce Agencies 
Report Activities Related to CARES Act 
Unemployment Insurance Programs  
Report Number: 19-22-004-03-315 
 
The purpose of this memorandum is to alert you to a concern the Office of 
Inspector General (OIG) has determined needs immediate attention. Specifically, 
states have either not submitted required Coronavirus Aid, Relief, and Economic 
Security (CARES) Act Unemployment Insurance (UI) program reports to the 
Employment and Training Administration (ETA) or reported zero activity. 
Although the CARES Act programs expired on September 6, 2021, it is important 
for ETA to obtain the missing reports and correct information. Without accurate  
state performance information, Congress and ETA are not able to fully assess 
state activities and mitigate the risk of overpayments and fraud for future 
programs of a similar nature. In addition, this was one of the two issues that 
ultimately resulted in the Department receiving its first qualified opinion on its 
consolidated financial statements in 25 years.  
 
Since the passage of the CARES Act in March 2020, ETA issued 
11 Unemployment Insurance Program Letters (UIPL) that specified state 
reporting guidelines for CARES Act UI programs (see Appendix A). ETA required 
states to report on UI programs established or extended by the CARES Act, 
Continued Assistance for Unemployed Workers Act of 2020 (Continued 
Assistance Act), and the America Rescue Plan Act of 2021. These programs 
include: 
 

 
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• Pandemic Unemployment Assistance (PUA);  
• Federal Pandemic Unemployment Compensation (FPUC);  
• Pandemic Emergency Unemployment Compensation (PEUC);  
• Temporary Full Federal Funding of the First Week of Compensable 
Regular Unemployment (TFFF);  
• Mixed Earners Unemployment Compensation (MEUC); 
• Emergency Unemployment Relief for State and Local Governmental 
Entities, Certain Nonprofit Organizations, and Federally-Recognized 
Indian Tribes (EURGENO); and  
• Short-Time Compensation (STC).  
 
These seven UI programs expired on September 6, 2021 (see Appendix B for a 
description of each program).  
 
ETA required 53 states1 to submit 14 different reports with information about their 
CARES Act UI activities (see Appendix C for a list of CARES Act UI reports). 
ETA said states had to program their systems to report the pandemic-related 
program data—a heavy lift for many and an important distinction as states could 
not report the data immediately without specific programming related to these 
new reports.  
 
Past OIG Reports Identified Pervasive Non-Reporting of Overpayments for 
CARES Act UI Programs 
 
In May 2021,2 we found, for the period of March 2020 to September 2020, 
42 percent of states did not complete the required quarterly reporting for 
overpayments in ETA 227 (Overpayment Detection and Recovery Activity) 
reports, and 60 percent did not do so for fraudulent payments. We recommended 
ETA assist states with claims, overpayment, and fraud reporting to create clear 
and accurate information, then use the overpayment and fraud reporting to 
prioritize and assist states with fraud detection and recovery. This 
recommendation remains open.  
                                                            
1 Per the CARES Act, the term “state” includes the 50 states, the District of Columbia, the 
Commonwealth of Puerto Rico, and the Virgin Islands. The term also applies to Guam, America 
Samoa, the Commonwealth of the Northern Mariana Islands, the Federated States of Micronesia, 
the Republic of the Marshall Islands, and the Republic of Palau, which were only required to 
complete two reports (ETA 902-P and ETA 227 FPUC). We did not examine the reporting of 
these Pacific Islands because they were only required to email the reports to ETA. Therefore, the 
reports are not available to access on ETA’s UI Data website. 
2 COVID-19: States Struggled to Implement CARES Act Unemployment Insurance Programs, 
OIG Report No. 19-21-004-03-315 (May 28, 2021), 
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf. 

 
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In addition, during our audit of the Department’s financial statements for fiscal 
year (FY) 2021, the issue of states’ non-reporting of overpayment activity in 
ETA 227 reports continued to exist. This was one of the two issues that ultimately 
resulted in the Department receiving its first qualified opinion on its consolidated 
financial statements in 25 years.3 Specifically, the $4.4 billion reported in 
UI benefit overpayments could not be relied upon because certain states did not 
report UI overpayment activity. We recommended ETA develop policies and 
procedures to coordinate with state workforce agencies to obtain the necessary 
information needed to support related balances and assumptions, and to perform 
benchmarking and/or other analyses to validate new assumptions. This 
recommendation also remains open. 
 
Because we identified the same concern (states’ non-reporting or incorrect 
reporting of overpayments in CARES Act UI programs) in two separate OIG 
reports, we decided to examine the extent to which states complied with all 
reporting requirements for UI programs authorized by the CARES Act and related 
subsequent legislation from the inception of the programs in March 2020 through 
their expiration in September 2021. 
 
Deficient Reporting of the UI Programs Authorized by the CARES Act and 
Subsequent Legislation  
 
ETA UI reports are housed on the agency’s UI Data website.4 We analyzed data 
on the website for 8 of the 14 reports states were required to submit.5 We 
acknowledge that for the first 90 days the programs were in existence, there may 
have been legitimate reasons for states not having any activity to report. 
However, applicable UIPLs did not waive the reporting requirement for this 
period. As such, our analysis included the first 3 months for which states were 
required to report—which some states did. 
 
Table 1 reflects the number of states that did not report CARES Act UI program 
information in one or more reporting periods and those that reported zero activity. 
For numbers in the column titled “Number of States That Reported Zero in One 
or More Periods” we were unable to determine whether zero was a default for 
missing data or a state actually reported zero activity—except for ETA 227 and 
902-M reports.  
 
                                                            
3 The Department received a qualified opinion on its FY 2021 financial statement audit; FY 2021 
Independent Auditor's Report on the DOL Financial Statements, OIG Report No. 22-22-003-13-
001 (November 19, 2021), available at: https://www.oig.dol.gov/public/reports/oa/2022/22-22-003-
13-001.pdf. 
4 ETA’s UI Data Website: https://oui.doleta.gov/unemploy/DataDownloads.asp 
5 Unable to access reporting activity for the remaining six reports. See Appendix C for details. 

 
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Table 1: Summary of States’ CARES Act Reporting Requirements 
Non-Reporting and Reporting of Zero Activity  
 
Report  
Number 
Report Title 
UI CARES 
Act 
Program 
Number of 
States That 
Did Not 
Report One 
or More 
Periods 
Number of 
States That 
Reported Zero 
in One or More 
Periods 
ETA 207 
Non-Monetary 
Determination Activity 
PEUC 
- 
9 
ETA 218 
Benefit Rights & 
Experience 
PEUC 
- 
8 
 
ETA 227 
Overpayment 
Detection & Recovery 
FPUC 
12 
12 
PEUC 
13 
15 
MEUC 
25 
26 
ETA 902-M 
Mixed Earners 
Unemployment 
Compensation 
MEUC 
20 
5 
ETA 902-P 
Pandemic 
Unemployment 
Assistance Activity 
PUA 
 
- 
 
36 
ETA 2112 
UI Financial 
Transaction Summary 
PUA 
53 
- 
FPUC 
51 
- 
PEUC 
30 
- 
TFFF 
- 
2 
EURGENO 
- 
10 
MEUC 
- 
8 
ETA 5130 
Benefit Appeals 
PEUC 
- 
1 
ETA 5159  
Claims and Payment 
Activities 
PEUC 
- 
34 
STC 
1 
- 
Source: OIG’s analysis using data from ETA’s UI Data Website between December 2021 and 
February 2022. 
 
 
ETA 207 
 
This quarterly report was to capture current information on the volume and nature 
of nonmonetary determinations and denials for the PEUC program under state 
UI, Unemployment Compensation for Federal Employees, and Unemployment 
Compensation for Ex-Servicemembers programs. The data is used to project 
budget and employee workloads, evaluate law changes, appraise disqualification 
processes, and relate actions to benefit appeals. States generally submitted this 
report. However, the Virgin Islands reported zero activity for four of the six 
quarters in our review period (see Appendix D, Table 1).  
 
 

 
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ETA 218 
 
This quarterly report (that in part captured PEUC program activity) contains 
information used to evaluate state benefit formulas for the UI program. The 
number of monetary determinations on new claims is used as a base to which 
other items reported may be related. States generally complied with this reporting 
requirement (see Appendix D, Table 2). 
 
ETA 227 
 
The quarterly ETA 227 report captured overpayments and recoveries for the 
FPUC, PEUC, and MEUC programs. However, our analysis focused on states’ 
reporting of overpayment activity. The number of states that did not report or 
reported zero overpayment activity for these three UI programs ranged from 
12 to 26. See Appendix E for the complete list of states that did not report 
overpayments and states that reported zero overpayment activity in ETA 227 
reports. 
 
ETA 902-M 
 
The ETA 902-M report captured monthly data on MEUC program activities,6 
including claims, payments, appeals, and administrative costs. Of the 51 states 
that opted into the program, California appropriately reported zero for the 
aforementioned activities in its 902-M report for the duration of the MEUC 
program. Of the remaining 50 states, 20 did not submit ETA 902-M reports at any 
time from January 2021 through the program’s expiration in September 2021 
(see Appendix F).  
 
According to ETA, this non-reporting was not a surprise because many of these 
states had not made any payments under the MEUC program. ETA officials also 
said many states delayed standing up MEUC until they had sufficient time to 
dedicate to its proper administration. ETA officials further maintained there was 
no statutory deadline for states to stand up the MEUC program—each state 
stood up the program near or after the program’s expiration on September 6, 
2021. For instance, Louisiana stood up the MEUC program and submitted 902-M 
reports reflecting program activity after the program terminated. These states 
should have at least reported zero as California did to indicate to ETA that no 
payments had been made. Without this information ETA could not determine 
whether these states actually had activity. 
 
                                                            
6 Of 53 states, 51 opted into the MEUC program (Idaho and South Dakota did not opt in). Twenty 
of these states ended their programs in June 2021. Three states ended their programs in 
July 2021. This information is available at: https://mixedearners.org/states. 

 
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ETA 902-P 
 
Another 902 report (ETA 902-P) captured overpayments monthly for the PUA 
program, as well as other activities such as applications, claims, determinations, 
and appeals data. Our analysis, however, focused on states’ reporting of 
overpayments. The states of Arizona, Connecticut, Georgia, Kansas, New 
Jersey, and Vermont reported zero overpayments for the entire 18-month 
reporting period. See Appendix E, Table 7 for full details about states’ 902-P 
reporting. 
 
ETA 2112 
 
The monthly ETA 2112 report captures all funds deposited into, transferred, or 
paid from a state’s unemployment fund, which consists of a state’s clearing 
account, unemployment trust fund account, and benefit payment account. 
States were to report this information for every CARES Act UI program except 
STC. See Appendix G for our analysis of ETA 2112 reporting for each 
applicable program. 
 
ETA 5130 
 
This monthly report is the basic source of information used to evaluate the 
appeals function, develop plans for remedial action when unreasonable backlogs 
develop, and support and justify the allocation of funds to service this functional 
area. The ETA 5130 reports contained monthly appeal activity for the PEUC 
program. The Virgin Islands was the only state that reported zero appeals activity 
for the entire 19-month period we examined. 
 
ETA 5159 
 
This monthly report contains data on claims activities, including the number  
and amount of payments used in budgetary and administrative planning, program 
evaluation, and reports to Congress and the public.  
 
For the PEUC program, UIPL 17-207 instructed states to report first and final 
payments on ETA 5159. Fourteen states complied with this reporting 
requirement. The remaining 39 states reported certain claims activities (such as 
eligibility reviews, continual weeks claimed, and weeks and amounts 
compensated) for various months. However, these states reported zero first 
payments and zero final payments each month, which was unlikely. 
 
                                                            
7 UIPL 17-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 – Pandemic 
Emergency Unemployment Compensation (PEUC) Program, Operating, Financial, and Reporting 
Instructions, issued April 10, 2020. 

 
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For the STC program, the 5159 report was modified for states to provide the 
number of participating employers with STC agreements under Section 2108 of 
the CARES Act. The 27 states with STC programs generally reported the number 
of participating employers with STC agreements as required. Appendix H 
contains a list of states with approved STC programs and their Section 2108 
funding as of February 2022. Vermont ceased operating its STC program on 
July 1, 2020, and did not receive any funding. 
 
States Informed to Submit Only Non-Zero Data for the PEUC Program 
 
In UIPL 17-20, ETA informed states—with respect to PEUC program reporting— 
only reports with non-zero data needed to be submitted. We identified multiple 
instances in which states did not submit PEUC reports or the PEUC information 
required within applicable reports (see Appendix E, Tables 3 and Table 4; and 
Appendix G). These states may or may not have had non-zero data. However, 
the absence of the required information could not be considered a reporting 
issue according to UIPL 17-20, and poses a risk that information needed to 
assess the PEUC program will not be obtained. According to ETA, the 
requirement to only submit non-zero data was intended to refer only to periods 
after the expiration of the program, and in which additional program activity 
occurred. However, this was not stated in UIPL 17-20. 
 
Conclusion 
 
Although the due dates for the CARES Act UI reports we discuss in this 
memorandum have passed, it is important for ETA to obtain the missing reports 
and correct information. Complete and accurate state data for CARES Act 
UI programs is necessary for the Department to assess CARES Act UI activities 
and to mitigate the risk of overpayments, including fraud. In addition, information 
in the required reports can be used to identify program weaknesses and 
establish lessons learned that may be leveraged to improve states’ performance 
under future temporary programs. Furthermore, ETA’s unsuccessful efforts to 
obtain the missing information that was critical to its FY 2021 financial statement 
audit could have a negative impact on the opinion the Department receives for 
FY 2022.  
 
According to ETA officials, since we brought this matter to their attention, they 
have made additional efforts to verify the accuracy of reporting for CARES Act 
UI programs. For example, ETA regional offices are following up with states that 
have not complied with reporting requirements. Also, ETA has provided 
documentation that indicates states submitted additional UI CARES Act reports 
since we conducted our analysis. Nevertheless, it remains critical that ETA obtain 
missing reports and correct information from the states. 
 

 
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Recommendations 
 
We recommend the Acting Assistant Secretary of Employment and Training: 
 
1. Continue to identify states that have not complied with ETA’s reporting 
requirements for CARES Act UI programs and work with them to ensure 
missing reports and information are submitted before the commencement of 
the Department’s FY 2022 financial statement audit. 
 
2. Continue to verify the accuracy of reports that cite no activity and ensure 
corrections are made where warranted.  
 
ETA provided us their response to the draft alert memorandum and 
recommendations. ETA agreed with our recommendations and has been working 
with the states to obtain missing reports and correct information. Subsequent to 
our review states have provided ETA more information. We have included ETA’s 
response (see Attachment). 
 
cc:  
Laura P. Watson, Deputy Assistant Secretary 
Jim Garner, Acting Administrator, Office of Unemployment Insurance 
Greg Hitchcock, Special Assistant, Office of Grants Management  
Teodora Ilieva, Audit Liaison 

 
-9- 
Appendix A: CARES Act Reporting UIPLs 
 
 
UIPL Number 
Subject and Issue Date 
UIPL 13-20, Change 1 
Family First Coronavirus Response Act, Division D 
Emergency Unemployment Insurance Stabilization and 
Access Act of 2020 (EUISAA) – Reporting Instructions, 
Modification to Emergency Administrative Grants 
Application Requirement, and Questions and Answers, 
issued May 4, 2020 
UIPL 15-20 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Federal Pandemic 
Unemployment Compensation (FPUC) Program 
Operating, Financial, and Reporting Instructions, 
issued April 4, 2020 
UIPL 15-20, Change 3 
Continued Assistance for Unemployed Workers 
(Continued Assistance) Act of 2020 – Federal 
Pandemic Unemployment Compensation (FPUC) 
Program Reauthorization and Modification and Mixed 
Earnings Unemployment Compensation (MEUC) 
Program Operating, Reporting, and Financial 
Instructions, issued January 5, 2021 
UIPL 16-20 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Pandemic Unemployment 
Assistance (PUA) Program Operating, Financial, and 
Reporting Instructions, issued April 5, 2020 
UIPL 16-20, Change 1 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Pandemic Unemployment 
Assistance (PUA) Program Reporting Instructions and 
Questions and Answers, issued April 27, 2020 
UIPL 16-20, Change 6 
Pandemic Unemployment Assistance (PUA) Program: 
Updated Operating Instructions and Reporting 
Changes, issued September 3, 2021 
UIPL 17-20 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Pandemic Emergency 
Unemployment Compensation (PEUC) Program, 
Operating, Financial, and Reporting Instructions, 
issued April 10, 2020 

 
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UIPL Number 
Subject and Issue Date 
UIPL 18-20 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Emergency Unemployment 
Relief for State and Local Governmental Entities, 
Certain Nonprofit Organizations, and Federally-
Recognized Indian Tribes, issued April 27, 2020 
UIPL 18-20, Change 1 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Emergency Unemployment 
Relief for State and Local Governmental Entities, 
Certain Nonprofit Organizations, and Federally-
Recognized Indian Tribes, issued August 12, 2020  
 
UIPL 20-20 
Coronavirus Aid, Relief, and Economic Security 
(CARES) Act of 2020 – Operating, Financial, and 
Reporting Instructions for Section 2105: Temporary 
Full Federal Funding of the First Week of 
Compensable Regular Unemployment for States with 
No Waiting Week, issued April 30, 2020 
UIPL 21-20 
Coronavirus Aid, Relief, and Economic Security 
CARES) Act of 2020 – Short-Time Compensation 
(STC) Program, Provisions and Guidance Regarding 
100 Percent Federal Reimbursement of Certain State 
STC Payments, issued May 3, 2020 
Source: ETA’s Website 
 
 
 

 
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Appendix B: CARES Act UI Programs/Provisions8 
ETA required states to report on seven UI programs established or extended by 
the CARES Act, the Continued Assistance for Unemployed Workers Act of 2020, 
and the America Rescue Plan Act of 2021 as follows: 
 
• The Pandemic Unemployment Assistance (PUA) program extended UI 
benefits to individuals who are not traditionally eligible for UI benefits. This 
includes self-employed workers, independent contractors, those with 
limited work history, and others.  
 
• The Federal Pandemic Unemployment Compensation (FPUC) program 
provided a supplemental payment of $600 per week (expired July 31, 
2020) to individuals receiving traditional and PUA benefits. It was 
reauthorized by the Continued Assistance Act of 2020 to resume at $300 
for weeks of unemployment after December 26, 2020. 
  
• The Pandemic Emergency Unemployment Compensation (PEUC) 
program provided up to an additional 13 weeks of unemployment 
compensation to individuals who exhausted their regular unemployment 
benefits.  
 
• The Temporary Full Federal Funding (TFFF) of the First Week of 
Compensable Regular Unemployment program provided federal funding 
for the first week of benefits if states agreed to waive their waiting week. 
Most states require a 1-week waiting period prior to a claimant being 
eligible for regular UI benefits.  
 
• The Emergency Unemployment Relief for Governmental Entities and 
Nonprofit Organizations program (EURGENO) provided payments to 
states to reimburse non-profits, government agencies, and Indian tribes 
for half the costs of UI.  
 
• The Temporary Financing of Short-Time Compensation (STC) program 
provided funding to support employers who reduced employee hours 
instead of laying off workers. The employees with reduced hours received 
a pro-rated unemployment benefit.  
 
                                                            
8 Source: UIPL 14-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 – 
Summary of Key Unemployment Insurance (UI) Provisions and Guidance Regarding Temporary 
Emergency State Staffing Flexibility, Issued April 2, 2020. 

 
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o Section 2108 provided that states with an existing STC program may 
be reimbursed for 100 percent of STC benefit costs for the maximum 
number of weeks per individual. 
o Section 2109 provided that states without an existing STC program 
may provide STC benefits under an agreement with the Secretary of 
Labor and be reimbursed for one-half of STC benefit costs for the 
maximum number of weeks per individual. 
o Section 2110 provided for a $100 million grant to be shared across 
states for implementation or improved administration, and promotion 
and enrollment of a state’s STC program. States can apply for grants 
through December 31, 2023. 
 
• The Mixed Earners Unemployment Compensation (MEUC) program 
provided a $100 supplemental benefit amount to certain individuals with 
self-employment income.  
 
 

 
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Appendix C: Reports ETA Required for CARES Act Activities 
Reports for CARES Act UI programs were to be submitted either weekly (two 
reports), monthly (six reports), or quarterly (six reports), as shown in the table. 
Three of the reports—ETA 902-M (Mixed Earners Assistance Activity), 
ETA 902-P (Pandemic Unemployment Assistance Activity), and ETA 9178-P 
(Quarterly Narrative Progress)—were specifically created for CARES Act UI 
programs. Ten reports existed before the pandemic, with new versions 
implemented specific to the new programs. One other pre-existing report was 
modified to include CARES Act UI programs. Due dates for the new reports—the 
same as for the regular versions of the reports—were established in applicable 
UIPLs. 
 
The reports with no submission data on ETA’s UI Data Website are marked with 
an asterisk (*). Also, the ETA 8403 report, marked with a double asterisk (**) in 
the “CARES Act UI Program” column, only applies to emergency administrative 
grant transfers. 
 
Report 
Number 
Report Title 
Frequency  
CARES Act 
UI Program 
ETA Reporting 
Guidance 
ETA 207 
Non-Monetary 
Determination Activity 
Quarterly 
PEUC 
MEUC 
 
UIPL 17-20 
UIPL 15-20, 
Change 3 
ETA 218 
Benefit Rights & 
Experience 
Quarterly 
PEUC 
UIPL 17-20 
ETA 227  
Overpayment 
Detection & Recovery  
Quarterly 
FPUC 
PEUC 
UIPL 15-20  
UIPL 17-20 
ETA 538* 
Advance Weekly Initial 
& Continued Claims 
Weekly 
PUA 
UIPL 16-20 
ETA 539* 
Claims & Extended 
Benefits Data 
Weekly 
PUA 
PEUC 
UIPL 16-20 
UIPL 17-20 
ETA 902-M 
Mixed Earners 
Assistance Activity 
Monthly 
MEUC 
UIPL 15-20, 
Change 3 
ETA 902-P 
Pandemic 
Unemployment 
Assistance Activity 
Monthly 
PUA 
UIPL 16-20 

 
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Report 
Number 
Report Title 
Frequency  
CARES Act 
UI Program 
ETA Reporting 
Guidance 
ETA 2112 
UI Financial 
Transaction Summary 
Monthly 
FPUC  
PUA 
PEUC 
TFFF 
MEUC 
 
EURGENO 
 
UIPL 15-20  
UIPL 16-20  
UIPL 17-20 
UIPL 20-20 
UIPL 15-20, 
Change 3 
UIPL 18-20 &  
18-20 Change 1 
ETA 5130 
Benefit Appeals 
Monthly 
PEUC 
UIPL 17-20 
ETA 5159  
Claims and Payment 
Activities 
Monthly 
PEUC 
STC 
UIPL 17-20  
UIPL 21-20 
ETA 8403* 
Summary of Financial 
Transactions 
Monthly 
N/A** 
UIPL 13-20,  
Change 1 
ETA 9178-P* 
Quarterly Narrative 
Progress 
Quarterly 
PUA 
TFFF 
UIPL 16-20, 
Change 1 
UIPL 20-20 
ETA 9130* 
Federal Financial 
Report 
Quarterly 
STC 
UIPL 21-20 
UI-3* 
Quarterly UI Above 
Base Earnings Report 
Quarterly 
PEUC 
UIPL 15-20  
UIPL 17-20  
Source: ETA’s Website 
 

 
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Appendix D: States’ Non-Monetary Reporting of PEUC Program Activity 
Please note the state abbreviations used in all tables can be found in Appendix I. 
 
Table 1: ETA 207 - Non-Monetary Determination Activity and 
States That Reported Zero Activity 
 
Quarter Ending 
States 
06/30/2020 
CO, GA, MD, ME, NH, VA, VI, WI 
09/30/2020 
GA, PR, VI 
12/31/2020 
VI 
03/31/2021 
VI 
Source: ETA’s UI Data Website 
 
 
Table 2: ETA 218 - Benefit Rights and Experience 
States That Reported Zero Activity 
 
Quarter Ending States 
06/30/2020 
CO, GA, LA, NH, VA, VI 
09/30/2020 
GA, LA 
12/31/2020 
VI 
03/31/2021 
WY 
09/30/2021 
GA, SD 
Source: ETA’s UI Data Website 
 
 
 

 
-16- 
Appendix E: States That Did Not Report and Reported Zero 
Overpayment Activity  
 
As seen in Table 1, Florida, New Jersey, Texas, and Vermont did not submit 
reports for FPUC program overpayments for any quarter during the entire period 
of March 2020 through September 2021.  
 
Table 1: ETA 227 (FPUC Program) 
States That Did Not Report Overpayments 
 
Quarter Ending 
States 
06/30/2020 
FL, NJ, TX, VT 
09/30/2020  
FL, NJ, TX, VT 
12/31/2020 
FL, NJ, TX, VT 
03/31/2021 
AZ, CA, CO, FL, IL, NJ, TX, VT 
06/30/2021 
AZ, CA, CO, DC, FL, HI, IL, NJ, TX, VT 
09/30/2021 
AZ, CA, CO, DC, FL, HI, IL, MI, NE, NJ, TX, VT 
Source: ETA’s UI Data Website 
 
 
As seen in Table 2, Pennsylvania reported zero FPUC overpayments for five of 
the six quarters. 
 
Table 2: ETA 227 (FPUC Program) 
States That Reported Zero Overpayments 
 
Quarter Ending 
States 
06/30/2020 
AZ, DE, KS, OR, PR, VA, VI 
09/30/2020  
GA, KS, PA, VI 
12/31/2020 
GA, OK, PA, VI 
03/31/2021 
GA, NV, OK, PA, VI 
06/30/2021 
CT, NV, OK, PA, VI 
09/30/2021 
OK, PA 
Source: ETA’s UI Data Website 
 
 
 
 

 
-17- 
As shown in Table 3, Florida, New Jersey, Illinois, and Vermont did not submit 
reports for PEUC program overpayments for any quarter during the entire period 
of March 2020 through September 2021. Florida and Nebraska filed reports, but 
did not report overpayment activity. 
 
Table 3: ETA 227 (PEUC Program)  
States That Did Not Report Overpayments 
 
Quarter Ending States 
06/30/2020 
CO, FL, IL, NH, NJ, VA, VT 
09/30/2020 
FL, IL, NJ, VT 
12/31/2020 
FL, IL, NJ, VT 
03/31/2121 
CA, CO, FL, IL, NE, NJ, VT 
06/30/2021 
CA, CO, FL, HI, IL, NE, NJ, VT 
09/30/2021 
AL, CA, CO, FL, HI, IL, KY, NE, NJ, VI, VT 
Source: ETA’s UI Data Website 
 
 
As seen in Table 4, Pennsylvania reported zero PEUC program overpayments 
for the entire program period, March 2020 through September 2021, which is not 
likely to be correct. 
 
Table 4: ETA 227 (PEUC Program)  
States That Reported Zero Overpayments 
 
Quarter Ending States 
06/30/2020 
AZ, CA, CT, DE, GA, HI, IA, KY, MD, ME, OR, PA, VI, WI, 
WV 
09/30/2020 
CA, CT, GA, MD, PA, VI 
12/31/2020 
CA, GA, PA, VI 
03/31/2121 
PA, VI 
06/30/2021 
KY, PA, VI 
09/30/2021 
PA 
Source: ETA’s UI Data Website 
 
 
 
 

 
-18- 
Table 5 shows 25 states did not report MEUC program overpayments during the 
three quarters that the program existed. ETA officials said the MEUC program 
may not have been stood up for these states and, being the first reporting quarter 
of a small program, states may not have had overpayment data to report. One 
state is waiting on a pending court ruling before implementing the program and 
has not filed any reports. 
 
Table 5: ETA 227 (MEUC Program)  
States That Did Not Report Overpayments 
 
Quarter Ending 
States  
3/31/2021 
AZ, CO, CT, FL, GA, HI, IA, IL, KS, LA, MA, MD, MI, MT 
NC, NJ, OK, PR, RI, SC, TX, UT, VT, WA, WY 
6/30/2021 
AZ, CO, CT, FL, GA, HI, IA, IL, KS, LA, MA, MD, MI, MT, 
NC, NJ, OK, PR, RI, SC, TX, UT, VT, WA, WY 
9/30/2021 
AZ, CO, CT, FL, GA, HI, IA, IL, KS, LA, MA, MD, MI, MT, 
NC, NJ, OK, PR, RI, SC, TX, UT, VT, WA, WY 
Source: ETA’s UI Data Website 
 
 
As seen in Table 6, Alaska, Arkansas, Ohio, Missouri, Pennsylvania, and Virginia 
reported zero MEUC program overpayments for the three quarters that the 
program existed. ETA officials said Arkansas has submitted ETA 227 MEUC 
reports with zero overpayments because it did not establish any MEUC 
overpayments. The state has maintained that the reports with zero overpayments 
are accurate, as it has a small application rate and very few approvals in the 
MEUC programs. 
 
Table 6: ETA 227 (MEUC Program)  
States That Reported Zero Overpayments 
 
Quarter Ending 
States  
3/31/2021 
AK, AL, AR, CA, DC, IN, MO, MS, NE, NH, NM, NY, OH, 
PA, TN, VA, VI, WI, WV 
6/30/2021 
AK, AL, AR, CA, DE, KY, ME, MN, MO, ND, NE, NH, NV, 
OH, OR, PA, TN, VA, VI, WI, WV 
9/30/2021 
AK, AR, DC, ME, MN, MO, ND, NV, OH, OR, PA, VA 
Source: ETA’s UI Data Website 
 
 
 

 
-19- 
As seen in Table 7, Arkansas, Arizona, Connecticut, Georgia, Kansas, New 
Jersey, and Vermont reported zero overpayments for all months during the 
during the entire period of March 2020 through September 2021. In the table, the 
states marked by an asterisk (*) reported zero overpayments for 1 or 2 of the 3 
months. All other states listed during the period reported zero overpayments for 
all three months.  
 
Table 7: ETA 902-P (PUA Program) 
States That Reported Zero Overpayment Activity 
 
Monthly Reporting Over 
Three Months Ending on 
the Following Dates  
States 
06/30/2020 
AK*, AR, AZ, CA*, CT, DE, FL*, GA, HI*, IA, ID*, 
IL*, IN*, KS, KY, MD, ME*, MI, MT*, NJ, NV*, NY*, 
OH, OK*, OR, PA, PR*, SD*, UT*, VA, VT, WI*, 
WV*, WY* 
09/30/2020 
AK*, AR, AZ, CT, DC, GA, IA*, IL, KS, NJ, NV*, 
OR*, UT, VA, VI*, VT, WI* 
12/31/2020 
AR, AZ, CT, DC*, GA, IL*, KS, NJ, VI*, VT  
03/31/2021 
AR, AZ, CT, GA, KS, NJ, VI*, VT, WI 
06/30/2021 
AR , AZ, CA, CT, GA, KS, MI, NJ, VI*, VT, WI*  
09/30/2021 
AR, AZ, CT, GA, KS, MI*, NJ, UT, VT 
Source: ETA’s UI Data Website 
 
 
 
 

 
-20- 
Appendix F: Twenty States That Did Not submit ETA 902-M Reports with 
MEUC Program Activities9 
 
1. Arizona 
2. Alabama 
3. Florida 
4. Georgia 
5. Hawaii 
6. Iowa 
7. Idaho 
8. Illinois 
9. Kentucky 
10. Michigan 
11. New Jersey 
12. Nevada 
13. Oklahoma 
14. Pennsylvania 
15. Puerto Rico 
16. South Carolina 
17. Texas 
18. Virgin Islands 
19. Vermont 
20. Washington 
 
 
 
 
                                                            
9 Source: ETA’s UI Data Website 

 
-21- 
Appendix G: States’ Reporting of Unemployment Trust Fund Account 
and/or Benefit Payment Account Activity  
in ETA 211210 
 
Our analysis of the states reporting in ETA 2112 reports showed each of the 
53 states did not report unemployment trust fund account (UTFA) and/or benefit 
payment account (BPA) information for applicable programs for at least one of 
the 19 months we examined. Moreover: 
 
• For the PUA program: Iowa did not report UTFA and BPA information at 
all.  
• For the FPUC program: Puerto Rico did not report BPA information for 
8 months.  
• For the EURGENO program: 10 states11 reported zero federal funds 
transferred into their UTFA for the 19-month duration of the program.  
 
• For the MEUC program: Eight states (Colorado, Kansas, Louisiana, New 
Jersey, Ohio, Puerto Rico, Rhode Island, and Washington) reported zeros 
for BPA information from the program’s start in January 2021 through its 
expiration on September 6, 2021. These levels of diminished activity are 
unlikely because these states were not among the 23 states that ended 
their MEUC programs early.12 ETA stated: 
 
o Colorado stood up the MEUC program on August 17, 2021, and 
made its first payment on September 1, 2021. 
o Louisiana stood up the MEUC program on September 16, 2021, 
and made its first payment on November 1, 2021. 
o New Jersey, Rhode Island, and Washington have not drawn MEUC 
funding as of March 11, 2022. 
 
                                                            
10 Source: OIG’s analysis of data on ETA’s UI Data Website. 
11 The 10 states included Alabama, California, Delaware, Kentucky, Mississippi, North Carolina, 
Puerto Rico, Rhode Island, Tennessee, and Washington. 
12 Twenty states ended their MEUC programs in June 2021 (Alabama, Alaska, Arkansas, Florida, 
Georgia, Indiana, Iowa, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North 
Dakota, Oklahoma, South Carolina, Texas, Utah, West Virginia, Wisconsin, and Utah). Three 
states ended their MEUC programs in July 2021 (Arizona, Maryland, and Tennessee). Source: 
https://mixedearners.org/states 

 
-22- 
• For the TFFF program: Only two states (Kentucky and Idaho) reported 
zeros for UTFA information for 2 separate months. The other 51 states 
reported non-zero activity every month. 
 
• For the PEUC program: States generally submitted ETA 2112 reports as 
required June 2020 through September 2021. However, Iowa did not 
report BPA information for 18 of the 19 months, and Puerto Rico did not 
report at all. 
 
Month Ending 
States 
03/31/2020 
All States (except AZ, CA MA, OK, RI) 
04/30/2020 
All States (except AL, AZ, IL, KY,MA, MI, MN, MT, NM, NY, 
WA) 
05/31/2020 
AK, CO, FL, GA, IA, KS, LA, ME, MS, NH, PR, VA, VI, WI, 
WY 
06/30/2020 
CO, IA, LA, NH, PR, VA, VI 
07/30/2020 
IA, LA, PR 
08/30/2020 
DE, IA, LA, PR 
09/30/2020 
DE, IA, PR 
10/30/2020 
DE, IA, PR 
11/30/2020 
DE, IA, PR 
12/31/2020 
DE, IA, PR 
01/31/2021 
DE, IA, PR 
02/28/2021 
DE, IA, PR 
03/31/2021 
DE, IA, PR 
04/30/2021 
DE, IA, PR 
05/31/2021 
IA, PR 
06/30/2021 
IA, PR 
07/30/2021 
IA, PR 
08/31/2021 
IA, PR 
09/30/2021 
PR 
Source: ETA’s UI Data Website 
 
 
 
 

 
-23- 
Appendix H: States With Approved STC Programs and  
CARES Act Section 2108 Funding as of February 2, 2022  
 
 
Count 
State 
Section 2108 Funding 
1 
Arizona 
$8,415,114 
2 
Arkansas 
$5,967,324 
3 
California 
$168,795,333 
4 
Colorado 
$15,828,738 
5 
Connecticut 
$56,598,435 
6 
District of Columbia 
$4,397,504 
7 
Florida 
$5,060,693 
8 
Iowa 
$10,305,278 
9 
Kansas 
$24,826,885 
10 
Maine  
$15,735,618 
11 
Maryland 
$7,290,210 
12 
Massachusetts 
66,179,555 
13 
Michigan 
$105,854,689 
14 
Minnesota 
$51,762,532 
15 
Missouri 
$29,921,660 
16 
Nebraska 
$7,386,433 
17 
New Hampshire 
$5,018,747 
18 
New Jersey 
$21,762,099 
19 
New York 
$180,924,787 
20 
Ohio 
$56,578,150 
21 
Oregon 
$112,795,897 
22 
Pennsylvania 
$10,073,972 
23 
Rhode Island 
$23,767,910 
24 
Texas 
$108,574,883 
25 
Vermont 
$0 
26 
Washington 
$136,698,120 
27 
Wisconsin 
$94,989,274 
 
Total  
$1,335,509,840 
Source: ETA and OIG’s analysis of data obtained from ETA’s UI Data Website.  

 
-24- 
Appendix I: State and Territory Abbreviations (Abbr.) 
 
Abbr. 
State 
AK 
Alaska 
AL 
Alabama 
AR 
Arkansas 
AZ 
Arizona 
CA 
California 
CO 
Colorado 
CT 
Connecticut 
DC 
District of Columbia 
DE 
Delaware 
FL 
Florida 
GA 
Georgia 
HI 
Hawaii 
IA 
Iowa 
ID 
Idaho 
IL 
Illinois 
IN 
Indiana 
KS 
Kansas 
KY 
Kentucky 
LA 
Louisiana 
MA 
Massachusetts 
MD 
Maryland 
ME 
Maine 
MI 
Michigan 
MN 
Minnesota 
MO 
Missouri 
MS 
Mississippi 
MT 
Montana 
 
 
Abbr. 
State 
NC 
North Carolina 
ND 
North Dakota 
NE 
Nebraska 
NH 
New Hampshire 
NJ 
New Jersey 
NM 
New Mexico 
NV 
Nevada 
NY 
New York 
OH 
Ohio 
OK 
Oklahoma 
OR 
Oregon 
PA 
Pennsylvania 
PR 
Puerto Rico 
RI 
Rhode Island 
SC 
South Carolina 
SD 
South Dakota 
TN 
Tennessee 
TX 
Texas 
UT 
Utah 
VA 
Virginia 
VI 
Virgin Islands 
VT 
Vermont 
WA 
Washington 
WI 
Wisconsin 
WV 
West Virginia 
WY 
Wyoming 
 
 
 
 
 

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