Court filing
Audit Report — ETA Needs a Plan to Reconcile and Return Nearly $5 Billion in Unused TFFF Funds to U.S. Treasury
Filed September 28, 2023 in DOL OIG Unemployment Insurance; one of 15 filings from this case.
Record facts
| Court | U.S. Department of Labor, Office of Inspector General (contracted to Rocha and Company, PC) |
|---|---|
| Filed | 2023-09-28 |
Full text
REPORT TO THE EMPLOYMENT
AND TRAINING ADMINISTRATION
COVID-19: ETA NEEDS A PLAN TO
RECONCILE AND RETURN TO THE U.S.
TREASURY NEARLY $5 BILLION
UNUSED BY STATES FOR A
TEMPORARY UNEMPLOYMENT
INSURANCE PROGRAM
This report was prepared by Rocha & Company, PC under contract to
the U.S. Department of Labor, Office of Inspector General, and, by
acceptance, it becomes a report of the Office of Inspector General.
____________________
U.S Department of Labor
Assistant Inspector General for Audit
DATE ISSUED: SEPTEMBER 28, 2023
REPORT NUMBER: 19-23-015-03-315
U.S. Department of Labor
Office of Inspector General
Audit
BRIEFLY…
COVID-19: ETA NEEDS A PLAN TO
RECONCILE AND RETURN TO THE U.S.
TREASURY NEARLY $5 BILLION UNUSED
BY STATES FOR A TEMPORARY
UNEMPLOYMENT INSURANCE PROGRAM
September 28, 2023
WHY OIG CONDUCTED THE AUDIT
On March 27, 2020, Congress passed the
Coronavirus Aid, Relief, and Economic Security
(CARES) Act to provide expanded
Unemployment Insurance (UI) benefits to
workers unable to work due to the COVID-19
pandemic. The Temporary Full Federal Funding
of the First Week of Compensable Regular
Unemployment for States with No Waiting
Week (TFFF) program reimbursed states for UI
benefits paid to eligible claimants who did not
wait a week to receive regular UI benefits. The
Employment and Training Administration (ETA)
was responsible for program oversight. We
contracted this audit to address concerns about
risks associated with the expansion of UI
benefits and the disbursement of federal funds
to claimants in need during the pandemic.
WHAT OIG DID
We contracted with the independent certified
public accounting firm of Rocha & Company,
PC (Rocha) to answer the question:
Did ETA ensure states met TFFF program
requirements and used funding according to
the statutory intent of the CARES Act and
related subsequent legislation?
To answer this question, Rocha assessed
ETA’s oversight, performed in-depth testing of
6 states, and surveyed an additional 47 state
workforce agencies (SWAs or states).
WHAT OIG FOUND
ETA and states did not always meet the
requirements or statutory intent of the TFFF
program. Specifically, individual claimants
waited to receive urgently needed UI benefits,
states received TFFF funding when they were
not eligible, and states’ TFFF accounts have
unused fund balances that have not been
reconciled, closed out for deobligation, and
returned to the U.S. Department of Treasury.
Four states were allowed to access TFFF
funding as reimbursements despite not meeting
program requirements. For example, 2 states
with waiting weeks required by their existing
laws did not waive those weeks but were
reimbursed for UI benefits paid after making
claimants wait for their first week of UI
compensation—contrary to the intent of the
program. In addition, another 2 states used
first-week UI compensation amounts paid
outside the scope of the program period as the
basis to be reimbursed. As a result, these
states were reimbursed $105.1 million of
federal funding they were not eligible to receive.
Further, of the $12.5 billion in funding made
available to the 53 SWAs through the TFFF
program, nearly $5 billion remained unused as of
July 31, 2023—more than 22 months after the
TFFF benefit eligibility period expired—with no
formal plan to reconcile states’ accounts and
deobligate remaining funds for return to the U.S.
Department of Treasury.
These issues occurred because ETA did not
have sufficient controls in place to ensure
states accessing funds were in fact eligible for
reimbursements or that unused TFFF funds
were returned to the federal government.
WHAT OIG RECOMMENDED
Rocha made 8 recommendations to improve
oversight of TFFF and similar programs. ETA
agreed or partially agreed with 5 and disagreed
with the remaining 3 recommendations.
READ THE FULL REPORT
https://www.oig.dol.gov/public/reports/oa/2023/1
9-23-015-03-315.pdf
U.S. Department of Labor – Office of Inspector General
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TABLE OF CONTENTS
INSPECTOR GENERAL’S REPORT .................................................................... 1
CONTRACTOR PERFORMANCE AUDIT REPORT ............................................ 1
RESULTS ............................................................................................................. 5
FOUR STATES WERE REIMBURSED $105.1 MILLION IN TFFF
FUNDING DESPITE NOT MEETING CARES ACT
REQUIREMENTS ...................................................................................... 6
22 MONTHS AFTER THE TFFF BENEFIT ELIGIBILITY PERIOD
EXPIRED, NEARLY $5 BILLION REMAINED IN FUA ............................. 14
RECOMMENDATIONS ....................................................................................... 20
ANALYSIS OF MANAGEMENT’S COMMENTS ...................................... 22
EXHIBIT 1: FUNDS PUT TO BETTER USE AND QUESTIONED COSTS ......... 25
EXHIBIT 2: DELAWARE DRAWDOWN OF INELIGIBLE WEEKS AFTER
SEPTEMBER 6, 2021 ......................................................................................... 26
EXHIBIT 3: SUMMARY OF TFFF TRANSACTIONS AND ENDING BALANCES
THROUGH JULY 31, 2023 ................................................................................. 27
APPENDIX A: SCOPE AND METHODOLOGY .................................................. 29
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ............................... 33
U.S. Department of Labor
Office of Inspector General
Washington, DC 20210
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INSPECTOR GENERAL’S REPORT
Brent Parton
Principal Deputy Assistant Secretary
for Employment and Training
U.S. Department of Labor
200 Constitution Ave. NW
Washington, DC 20210
The U.S. Department of Labor (DOL) Office of Inspector General (OIG)
contracted with the independent certified public accounting firm of Rocha
& Company, PC (Rocha) to conduct a performance audit of the Employment and
Training Administration’s (ETA) oversight of Temporary Full Federal Funding of
the First Week of Compensable Regular Unemployment for States with No
Waiting Week (TFFF) program, a provision of the Coronavirus Aid, Relief, and
Economic Security (CARES) Act.
The OIG monitored Rocha’s work to ensure it met professional standards and
contractual requirements. Rocha’s independent audit was conducted in
accordance with generally accepted government auditing standards.
Rocha was responsible for the auditors’ evaluations and the conclusions
expressed in the report while the OIG reviewed Rocha’s report and supporting
documentation.
PURPOSE
The COVID-19 pandemic was historic in its impact on the UI system. Following
the start of the pandemic in the United States in early 2020, unemployment
compensation claims rose exponentially to historically unprecedented levels.
Prior to the pandemic, the numbers of UI claims were low.
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On March 27, 2020, the CARES Act1 was signed into law with the goal of
providing expanded UI benefits to workers who were unable to work due to the
COVID-19 pandemic. According to ETA, the CARES Act did not include a
program development period prior to implementation that would have provided
the Department and states an opportunity to properly sequence guidance and
operations of the key program requirements. ETA officials reported that states
faced the combined challenges of (1) managing and processing an
unprecedented increase in claims volume at an unprecedented pace, (2) making
the statutory changes to existing UI programs, and (3) implementing the CARES
Act UI programs. In addition, states had to develop new systems in order to
implement the new programs.
Section 2105 of the CARES Act authorized the TFFF program, whereby the
federal government paid the cost of the first week of an eligible claimant’s regular
UI compensation for states with no waiting week and for states choosing to waive
their waiting week requirements. ETA made approximately $12.5 billion of TFFF
funding available in Federal Unemployment Accounts2 (FUA) for 53 participating
state workforce agencies (SWAs or states)3 to access as reimbursement for
first-week regular UI compensation already paid to eligible individuals by the
state.
The CARES Act created the TFFF program to arrange for emergency relief,
specifying that the FUA would provide to each state that entered into an
agreement an amount equal to 100 percent of the total amount of regular
compensation paid to eligible individuals by the state for their first week of regular
UI benefits. Under the CARES Act, weeks between March 29, 2020, and
December 31, 2020, were eligible for reimbursement. On December 27, 2020,
the Continued Assistance Act (CAA)4 extended the TFFF program through
March 14, 2021. On March 11, 2021, the American Rescue Plan Act (ARPA)
of 20215 further extended the TFFF program through September 6, 2021.
Based on the risks associated with expansions of the UI program, we contracted
with Rocha to conduct a performance audit to answer the question:
1 Pub. L. 116–136 (Mar. 27, 2020).
2 The U.S. Department of Treasury transfers funds from the general fund to the Federal
Unemployment Account (FUA) in amounts estimated by ETA to be necessary to reimburse the
states for first week regular UI compensation paid. FUA is an account within the federal
Unemployment Trust Fund that pays for the costs to administer the UI program, emergency
benefits, loans to state trust funds, and program expansions like the CARES Act.
3 When referring to UI, this report uses “state” or “SWA” to refer to the administrative body that
administers the UI program within the state, district, or territory. For the 50 states, as well as the
U.S. Virgin Islands, Puerto Rico, and the District of Columbia, that administrative body is a SWA.
4 Division N, Title II, Subtitle A, Chapter 1, Pub. L. 116–260 (Dec. 27, 2020).
5 Pub. L. 117–2 (Mar. 11, 2021).
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Did ETA ensure states met TFFF program requirements and used
the funding according to the statutory intent of the CARES Act and
related subsequent legislation?
To answer this question, Rocha conducted a performance audit that covered the
period March 27, 2020, through September 6, 2021. To determine the amount of
TFFF funding that remained in the FUA after September 6, 2021, Rocha
obtained TFFF account balances from ETA’s summary of the U.S. Department of
Treasury’s FUA transaction statements as of July 31, 2023. The audit included
procedures at both the ETA and the state level to determine compliance with
program requirements. Rocha performed in-depth testing and analysis for
6 states—Delaware, Iowa, Louisiana, Minnesota, Nevada, and Oregon—selected
by the OIG. The OIG selected these 6 states based on the amount of TFFF
funding that states received, stratified into the highest, middle, and lowest range
and the extent to which states had not been selected for review in previous OIG
audits. Rocha also sent surveys to the remaining 47 SWAs to obtain key
information and examine documentation.
RESULTS
Rocha found that ETA and states did not always meet the requirements or
statutory intent of the TFFF program. Specifically, individual claimants waited to
receive urgently needed UI benefits during the pandemic, states received TFFF
funding when they were not eligible, and states’ TFFF accounts have unused
fund balances that have not been reconciled and closed out for deobligation. As
a result, Rocha identified $105.1 million in questioned costs.6 Rocha also
identified nearly $5 billion in funds put to better use.7 These funds remained in
states’ TFFF accounts after the benefit eligibility period expired8 and should be
returned to the U.S. Department of Treasury.
6 Questioned costs are costs: (A) resulting from an alleged violation of a law, regulation,
contract, grant, or other document or agreement governing the use of Federal funds; (B) that are
not supported by adequate documentation (also known as an unsupported cost); or (C) that
appear unnecessary or unreasonable.
7 Funds put to better use estimate funds that could be used more efficiently. Some examples
would be reducing spending, deobligating funds, or avoiding unnecessary spending.
8 TFFF benefit eligibility period, for states without a waiting week provision in their state law, was
the week ending April 4, 2020, through the week ending September 6, 2021.
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We appreciate the cooperation and courtesies ETA extended to Rocha and the
OIG during this audit.
Carolyn R. Hantz
Assistant Inspector General for Audit
U.S. Department of Labor – Office of Inspector General
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CONTRACTOR PERFORMANCE AUDIT REPORT
Independent Auditors’ Performance Audit Report on the Effectiveness of the
Execution of the Temporary Full Federal Funding of the First Week of
Compensable Regular Unemployment for States with No Waiting Week Program
and Compliance with the Coronavirus Aid, Relief, and Economic Security Act and
Related Subsequent Legislation
Brent Parton
Principal Deputy Assistant Secretary
for Employment and Training
U.S. Department of Labor
200 Constitution Ave. NW
Washington, DC 20210
We were engaged by the Office of Inspector General (OIG), U.S. Department of
Labor (DOL) to conduct a performance audit of the Department of Labor
Employment and Training Administration’s (ETA) and states’ execution of the
Temporary Full Federal Funding of the First Week of Compensable Regular
Unemployment for States with No Waiting Week (TFFF) program under the
Coronavirus Aid, Relief, and Economic Security (CARES) Act. We conducted the
audit to answer the question:
Did ETA ensure states met TFFF program requirements and used
the funding according to the statutory intent of the CARES Act and
related subsequent legislation?
To answer this question, we conducted procedures at the ETA and state level to
determine compliance with program requirements. For ETA, we submitted
questions to UI officials and reviewed their responses and underlying support.
For 6 states—Delaware, Iowa, Louisiana, Minnesota, Nevada, and Oregon—we
performed in-depth analysis and testing. Five of the 6 states—Delaware,
Louisiana, Minnesota, Nevada, and Oregon— had laws that required UI
claimants to wait one week before receiving their first benefit payment.9 The OIG
9 The state of Iowa did not have a waiting week provision in its state law.
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selected these 6 states based on state funding percentages and their selection
for analysis in other OIG audits of CARES Act programs. We also sent surveys to
the remaining 47 state workforce agencies (SWAs or states) to obtain related
information about the program. In addition, we examined state-level executive
orders, agreements between ETA and states, correspondence between ETA and
the states, individual first-week claims paid by the states, as well as TFFF
funding activity between the Federal Unemployment Account (FUA) and the
states. Our audit covered the period March 27, 2020, through
September 6, 2021, and we obtained information subsequent to that period as
needed.
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 the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective. Our scope, methodology, and
criteria are detailed in Appendix A.
BACKGROUND
On March 27, 2020, Congress passed the CARES Act to provide expanded
Unemployment Insurance (UI) benefits to workers unable to work due to the
COVID-19 pandemic. ETA was required to oversee one such provision—TFFF.
The TFFF program reimbursed states 100 percent for first-week UI benefits paid
to eligible claimants who did not have to wait a week, provided there was an
agreement in place and no waiting week was required (or it was waived) under
state law. States with a mandatory waiting week provision in their state law could
waive the provision to be eligible. Eligible claimants benefited from the TFFF
program because states expedited the delivery of UI benefits to claimants.
On December 27, 2020—in addition to extending the TFFF program through
March 14, 2021—the CAA decreased federal funding for TFFF program
reimbursements from 100 percent to 50 percent. On March 11, 2021—in addition
to extending the TFFF program through September 6, 2021— the ARPA restored
federal funding for TFFF program reimbursements to 100 percent and allowed for
retroactive application for weeks ending after December 31, 2020. See Figure 1
for a legislative timeline of the TFFF program.
U.S. Department of Labor – Office of Inspector General
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Figure 1. Legislative Timeline for TFFF Program
Source: UIPL 20-20, UIPL 9-21, UIPL 14-21
a Under ARPA, the amount of federal funding for reimbursement was retroactively established at
100 percent for weeks of unemployment ending after December 31, 2020.
To fund the program, ETA estimated how much money participating states
needed and requested the funding from the Office of Management and Budget
(OMB). Once OMB approved the requests, the funds were disbursed to
uninvested FUA until ETA allotted10 the money to Invested FUA, which states
accessed for reimbursement of first-week UI benefits already paid (see Figure 2).
ETA is responsible for decreasing or increasing estimated allotments provided to
the states based upon actual monthly amounts that should have been paid to the
states.
10 The term “allotted” refers to the act of ETA making the funds available to the states.
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Figure 2. TFFF Funding and Reimbursement Process
Source: Rocha graphical representation of TFFF funding process.
*Apportionment is defined as distribution of funds available for obligation.
This report focuses on the performance of ETA and states’ TFFF operations
during the audit period—March 27, 2020, through September 6, 2021—which
coincided with the COVID-19 pandemic. The pandemic had a profound impact on
the UI program, presenting states with unprecedented challenges. According to
ETA officials, these challenges included managing an unprecedented surge in
claim volume, adapting to remote work environments, and implementing three
new significant temporary UI programs (Federal Pandemic Unemployment
Compensation, Pandemic Unemployment Assistance and Pandemic Emergency
Unemployment Compensation).
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RESULTS
We found ETA and states did not always meet the requirements or statutory
intent of the TFFF program. Specifically, individual claimants waited to receive
urgently needed UI benefits during the pandemic, states received TFFF funding
when they were not eligible, and states’ TFFF accounts have unused fund
balances that have not been reconciled and closed out for deobligation. As a
result, we identified $105.1 million in questioned costs.11 We also identified
nearly $5 billion in funds put to better use12—in states’ TFFF accounts after the
benefit eligibility period expired13—that should be deobligated and returned to the
U.S. Department of Treasury.
ETA allowed 4 states to access TFFF funding as reimbursements despite not
meeting program requirements. For example, 2 states with waiting week
provisions (Oregon and Louisiana) required by their state laws did not waive
those weeks, but were reimbursed for UI benefits paid, after making claimants
wait for their first week of UI compensation—contrary to the intent of the
program. In addition, 2 states (Delaware and Mississippi) used first-week UI
compensation amounts paid outside the scope of the program period as the
basis for reimbursement. As a result, states were reimbursed $105.1 million of
federal funding they were not eligible to receive.
Furthermore, of the $12.5 billion in funding made available to the 53 SWAs
through the TFFF program, nearly $5 billion remained unused as of
July 31, 2023—more than 22 months after the benefit eligibility period expired.
ETA had no formal plan to reconcile states’ accounts and return funds to the U.S.
Department of Treasury. These funds could have been put to better use.
These issues occurred because ETA did not have sufficient controls in place to
ensure states accessing funds were in fact eligible for reimbursements or that
unused TFFF funds were returned to the federal government.
11 Questioned costs are costs: (A) resulting from an alleged violation of a law, regulation,
contract, grant, or other document or agreement governing the use of Federal funds; (B) that are
not supported by adequate documentation (also known as an unsupported cost); or (C) that
appear unnecessary or unreasonable.
12 Funds put to better use estimate funds that could be used more efficiently. Some examples
would be reducing spending, deobligating funds, or avoiding unnecessary spending.
13 TFFF benefit eligibility period, for states without a waiting week provision in their state law, was
from the week ending April 4, 2020, through the week ending September 6, 2021.
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FOUR STATES WERE REIMBURSED
$105.1 MILLION IN TFFF FUNDING DESPITE
NOT MEETING CARES ACT REQUIREMENTS
We found 4 states accessed $105.1 million in TFFF funding—as
reimbursements—without meeting program eligibility requirements. Specifically,
waiting week provisions were not appropriately waived or reimbursements
accessed by the states were based on first-week UI compensation amounts that
were outside the program period. These are deemed to be questioned costs; see
Table 4 in Exhibit 1 for this data.
Under the CARES Act, which went into effect on March 27, 2020, the federal
government would pay 100 percent of an individual claimant’s first week of
regular UI compensation to states that entered into an agreement with ETA to
participate in the TFFF program. States were eligible to enter into these
agreements if state law (including waiver of state law) provided compensation be
paid to claimants for their first week of regular unemployment compensation
without requiring a waiting week.14 First week of UI compensation amounts that
were eligible for reimbursement applied only to the period from March 29, 202015
to September 5, 2021,16 provided states had agreements in place with ETA.
ETA issued Unemployment Insurance Program Letter (UIPL) 20-20 to offer
further guidance to states on TFFF program requirements, including how states
would not qualify for TFFF reimbursements for any weeks of claimant
unemployment that began before the effective date of a state waiver or change in
state law, even if that law was worded to apply retroactively prior to
December 31, 2020.17 According to UIPL 20-20, ETA’s agreement with a given
state will be terminated immediately upon ETA’s determination that the state law
(or waiver) does not provide payment to claimants for their first week of regular
UI compensation without a waiting week and, pursuant to Section 2105 of the
14 In total, only 8 of the 53 states did not have a waiting week to waive to participate in the TFFF
program.
15 According to UIPL 20-20, “In states where the week of unemployment ends on a Saturday, the
first week for which states may request reimbursement is the week of unemployment ending
April 4, 2020. In states where the week of unemployment ends on a Sunday, the first week for
which states may request reimbursement is the week of unemployment ending April 5, 2020.”
16 According to UIPL 14-21, “In states where the week of unemployment ends on a Saturday, the
last week of unemployment for which reimbursement is available is the week ending on
September 4, 2021. In states where the week of unemployment ends on a Sunday, the last week
of unemployment for which reimbursement is available is the week ending on
September 5, 2021.”
17 On March 11, 2021, ARPA allowed for retroactive application for weeks ending after
December 31, 2020. This retroactive application effectively removed the controls previously
established that ensured claimants received timely benefits.
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CARES Act, the state will be required to return any reimbursements made during
the period that the state law or waiver was not in effect.
TWO STATES DID NOT WAIVE THEIR WAITING
WEEKS, RESULTING IN THE DELAY OF
$91.2 MILLION IN NEEDED BENEFITS
We determined that 2 states selected for in-depth analysis—Oregon and
Louisiana—accessed a total of $91.2 million in TFFF funding as reimbursements
for weeks when the states did not have a waiting week waiver in effect, and
claimants waited to receive their first week of regular UI compensation. These
states were not eligible to receive reimbursement if state law required a waiting
week or if waiting week waivers were not in place, even if such waivers were
worded to apply retroactively from March 27, 2020, to December 31, 2020.18
Oregon: Oregon signed an agreement with ETA on March 27, 2020, to
participate in the TFFF program. Oregon’s state law required individuals to serve
a waiting week; therefore, Oregon needed to issue a waiver of this provision to
be eligible to enter into this agreement.
Although Oregon’s intent was to implement the TFFF program timely and waive
the waiting week, legacy software issues created obstacles causing delays in UI
benefit delivery. Specifically, Oregon’s computer systems were built on
technology from 1993 using outdated programming. When Oregon initially
researched removing the waiting week, it estimated it would take the state
approximately 4,000 labor hours to complete the effort, and thus was uncertain
that waiting week compensation could be paid to individual claimants by the end
of the 2020 calendar year.
Oregon communicated to ETA these challenges, along with its concerns of how
the delays could impact the availability of federal funding. On October 8, 2020,
ETA communicated its position to Oregon that “[f]ailure to implement the waiting
week benefit by December 31, 2020, will result in the Department terminating the
agreement as it relates to reimbursement for payment of waiting week benefits
under Section 2105 of the CARES Act.” However, according to Section 2105 of
the CARES Act, the agreement did not meet the TFFF eligibility requirements
because Oregon was not able to implement a waiver of the waiting week
provision.
18 § 4.c UIPL 20-20.
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According to ETA’s UIPL 20-20:
…the Department reserves the right to terminate this Agreement if
it determines that the state does not have an adequate system for
administering the section 2105 program…
ETA elected not to terminate the agreement with Oregon despite the evidence
that the state’s system was not able to pay first-week UI compensation until
November 23, 2020—approximately 8 months into the TFFF program. Oregon
did not access any TFFF federal funding as reimbursements during this 8-month
period. Nevertheless, ETA did not conclude Oregon breached its contractual
terms and terminate the agreement—despite Oregon not having an adequate
system to administer TFFF.
According to an Oregon Employment Department official, the waiting week was
waived on March 8, 2020, when Oregon’s Governor issued Executive Order
20-03, declaring a state of emergency. The Oregon official cited Oregon Revised
Statute 401.186 which states:
If the Governor by proclamation has declared a state of emergency
under ORS 401.165, the Governor may waive the one-week waiting
period required by ORS 657.155 for persons making a claim for
unemployment benefits who reside within the geographical area
subject to the proclamation and specified by the Governor.
The Executive Order made no mention of waiving the waiting week for UI
programs, and under Oregon law, the Governor’s authority to waive the waiting
week is discretionary and not automatic upon the declaration of a state of
emergency. Nonetheless ETA agreed with the Oregon official’s interpretation of
Oregon’s state law. According to ETA officials, their practice is to defer to the
states to interpret state laws. ETA is responsible for federal oversight of state
administration of UI programs, including ensuring that states did not have a
waiting week provision in their state laws or the waiting week provision was
waived for the TFFF program. ETA did not exhibit proper oversight when they
deferred to Oregon’s interpretation of the Governor’s state of emergency
declaration as the waiting week waiver.
We determined that Oregon did not waive its waiting week until
November 23, 2020—when the state began issuing first-week regular UI
compensation. On December 30, 2020, Oregon’s Governor directed the state’s
Employment Department (in writing) to retroactively waive the waiting weeks for
the period March 8, 2020, through the week ending March 13, 2021. However,
UIPL 20-20 expressly prohibited retroactive waivers of the waiting week during
the initial TFFF program period under the CARES Act. Oregon’s waiver of the
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waiting week was therefore only effective from the date of the waiver—on
November 23, 2020—going forward.
As a result of the waiting week waiver delay, 254,427 Oregon claimants had to
wait for first-week regular UI compensation from March 8, 2020, through
November 22, 2020. Therefore, Oregon was not eligible to participate in the
TFFF program and not entitled to the $90.5 million in TFFF funds it drew down as
reimbursement for first-week regular UI compensation paid for unemployment
weeks prior to November 29, 2020, the first week after Oregon’s waiver was in
effect.19
Louisiana: The Governor of Louisiana signed an agreement with ETA on
March 28, 2020, to participate in the TFFF program. The Governor issued a
series of intermittent short-term waivers for first-week regular UI compensation
periods. Two of these short-term waiting week waivers resulted in gap periods
when a waiting week waiver was not in effect and individual claimants had to wait
to receive first-week regular UI compensation. Specifically, the Governor issued
a waiting week waiver on December 4, 2020, that covered the period beginning
on December 6, 2020, and ending on December 26, 2020.20 The second
short-term waiting week waiver occurred on March 16, 2021, when the Governor
reinstated the waiver and made it retroactively effective January 3, 2021, with an
ending date of March 31, 2021. As a result, no waiver was in effect from
December 27, 2020, through January 2, 2021, meaning the weeks ending
January 2, 2021, and January 9, 2021, were not covered by a waiver.21 However,
19 UIPL 20-20 explains that “[f]or states without a waiting week, reimbursement for the first week
of regular UC is available for weeks of unemployment beginning after the date on which the state
enters into an agreement with the Department… The agreement is valid only if the state law
(including a waiver of state law) making the first week compensable is in effect.” (emphasis
added). Oregon issued the first waiting week waiver on Monday, November 23, 2020. Oregon’s
unemployment benefit weeks begin Sunday and end on Saturday. Since the first waiver was
issued on Monday, any UI payments made during the week of November 22-28, 2020, were not
eligible for reimbursement under the TFFF program. Therefore, November 29, 2020, was the first
week Oregon was eligible for reimbursement.
20 The Governor’s proclamation declared that the waiver covered the period beginning Saturday,
December 5, 2020, and ending Wednesday, December 23, 2020. However, Louisiana’s
unemployment compensation week begins on Sunday and ends on Saturday. Therefore, the
waiver covered the period beginning Sunday, December 6, 2020, and ending Saturday,
December 26, 2020.
21 Louisiana’s first short-term waiting week waiver expired on December 26, 2020, making the
agreement invalid on December 27, 2020. Louisiana issued the second short-term waiting week
waiver on Sunday, January 3, 2021, which validated the agreement again. Reimbursement for
the first week of regular UC is available for weeks of unemployment beginning after the date on
which the state enters into an agreement with the Department. Louisiana’s unemployment benefit
weeks begin Sunday and end on Saturday. Since the second waiver was effective on Sunday, UI
payments made during the week of January 3-9, 2021, were not eligible for reimbursement under
the TFFF program. Therefore, the week ending January 16, 2021, was the first week Louisiana
was eligible for reimbursement.
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Louisiana drew down approximately $735,000 in TFFF funds to reimburse their
first-week benefit expenses paid to 4,254 individual claimants during these
2 weeks for which it was not eligible.
Retroactive Waivers Permitted Under ARPA Had Unintended
Consequences: On December 27, 2020, the CAA decreased federal funding for
TFFF program reimbursements from 100 percent to 50 percent. These changes
unintentionally discouraged some states from participating in the TFFF program
and issuing waiting week waivers that would have allowed claimants to receive
the urgent relief the program was originally intended to provide in a timely
manner. We noted CAA’s reimbursement reduction to 50 percent influenced the
decisions of Louisiana (1 of the 6 states) and Washington (a surveyed state) to
opt out of the TFFF program and allow the waiting week waivers to expire. On
March 11, 2021, ARPA restored federal funding for TFFF program
reimbursements to 100 percent and allowed for retroactive application22 for
weeks ending after December 31, 2020.
Louisiana. Louisiana decided not to renew its waiver, which expired on
December 26, 2020, in anticipation that the enactment of CAA
(December 27, 2020) would reduce federal reimbursements from
100 to 50 percent. On March 16, 2021, after the enactment of ARPA and
restoration of federal reimbursements to 100 percent, Louisiana retroactively
waived the waiting week and subsequently paid claimants. However, for the
weeks ending January 16, 2021, to March 13, 2021, there were 13,780 claimants
who had to wait to receive retroactive first-week regular UI compensation that
totaled approximately $2.4 million because of Louisiana’s information technology
programming needs. Of the 13,780 claimants that had to wait, 13,491 claimants
had to wait 4 months or longer to receive payments totaling approximately
$2.3 million.
Washington. On March 11, 2021, when ARPA was passed, Washington state
law automatically waived the first waiting week moving forward. However,
payments were delayed as the state determined if it could apply state laws to
retroactively waive the waiting week. Further, Washington then needed to build
an information technology infrastructure to retroactively waive the waiting week.
The infrastructure required to pay claimants for the first week of regular UI
compensation related to weeks ending after December 31, 2020, was not
22 In this report “retroactive application” refers to ARPA permitting states to waive waiting weeks
and establish an effective date prior to the date of the waiver. For example, states could issue
waivers on or after March 11, 2021, i.e., the date when ARPA went into effect, while making the
effective date retroactive to January 4, 2021, and then qualify to receive reimbursements under
the TFFF program for weeks beginning after January 4, 2021. Retroactive application was not
permitted prior to the enactment of ARPA.
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operational until May 7, 2021, approximately 2 months after the waiting week
provision was waived. The total amount of first-week regular UI compensation
delayed due to these factors was approximately $29.8 million.
Although claimants in Louisiana and Washington waited at least a week to
receive first-week regular UI benefit payments, ARPA allowed the states to draw
down federal funds as reimbursement of those delayed payments.
TWO STATES WERE REIMBURSED $13.9 MILLION IN
TFFF FUNDS FOR PAYMENTS OUTSIDE THE
ALLOWABLE PERIOD
According to ETA guidance, states were eligible to receive reimbursement for the
weeks ending April 4, 2020, through September 6, 2021, provided a TFFF
agreement was in place and there was no waiting week provision in their state
law (including waiver of state law).23 We identified 2 states, Delaware (1 of the
6 states) and Mississippi (a surveyed state), that accessed $13.9 million in TFFF
funds as reimbursement for payment of first-week UI compensation that was
outside of the allowable time period (weeks ending April 4, 2020, through
September 6, 2021).
Delaware: On March 28, 2020, Delaware entered into an agreement with ETA to
participate in the TFFF program. In June 2020, Delaware drew down $4.1 million
in TFFF funding for reimbursement of first-week UI compensation payments
related to claim weeks that were prior to the TFFF program’s earliest eligible
week ending April 4, 2020. Specifically, Delaware drew down $74,706 in
reimbursement for first-week UI compensation payments for the weeks ending
January 11, 2020, through February 29, 2020, and $4,045,569 for the weeks
ending March 21, 2020, and March 28, 2020. According to Delaware officials,
they were unsure as to why the state would have drawn down these amounts for
periods that did not qualify, and indicated it was possibly due to confusion when
the pandemic first occurred.
Delaware continued to draw down TFFF funds after the benefit eligibility period
expired. According to UIPL 14-21, the last week Delaware was eligible to receive
23 According to UIPL 20-20, in states where the week of unemployment ends on a Saturday, the
first week of which states may request reimbursement is the week of unemployment ending
April 4, 2020, provided an agreement was in place no later than March 28, 2020. According to
UIPL 14-21, for states without a waiting week provision in their state law, 100 percent
reimbursement of the first week of regular UI compensation is available through weeks of
unemployment ending on or before September 6, 2021. In states where the week of
unemployment ends on a Saturday, the last week of unemployment for which reimbursement is
available is the week ending on September 4, 2021.
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reimbursement for first-week UI compensation payments was for weeks of
unemployment ending on or before September 6, 2021. However, Delaware
continued to draw down TFFF funding after September 6, 2021. Specifically,
Delaware drew down approximately $1.4 million during a 41-week period from
September 13, 2021, through June 21, 2022. These weeks were not eligible for
reimbursement under the TFFF program. Delaware officials indicated that the
state’s program did not account for the first-week regular UI benefit payments
made after the benefit eligibility period expired. See Exhibit 2 for details of these
drawdowns.
Mississippi: On March 28, 2020, Mississippi entered into an agreement with ETA
to participate in the TFFF program. Mississippi waived its waiting week provision
through its governor’s executive order effective March 8, 2020. Mississippi used
March 8, 2020, as the effective date for the administration of CARES Act UI
programs to provide a common reference point for identifying filed claims related
to the COVID-19 pandemic and for consistency of program changes. However,
UIPL 20-20 established that the earliest week states could be eligible to receive
reimbursement for first-week UI compensation payments was the week ending
April 4, 2020. Nonetheless, Mississippi drew down $8.4 million in TFFF
reimbursement for ineligible weeks ending March 14, 2020, through
March 28, 2020.
PRIMARY CAUSES THAT ALLOWED STATES TO
ACCESS TFFF FUNDING AS REIMBURSEMENTS
WITHOUT MEETING CARES ACT REQUIREMENTS
States were able to access TFFF funding as reimbursements without meeting
CARES Act requirements primarily because ETA did not: (1) implement sufficient
controls to ensure waivers were in place and thus, accepted retroactive waivers
not permitted under the program; and (2) validate TFFF reimbursements drawn
down by states.
ETA RELIED ON INSUFFICIENT CONTROLS
REGARDING WAITING WEEK WAIVERS
ETA indicated their state conformity and compliance team routinely reviewed
legislation, regulations, and executive orders related to the unemployment
compensation system for conformity. As part of this process, ETA developed a
tracker that documented states’ policy changes regarding waivers for states with
a waiting week law. ETA’s fiscal and actuarial services team used the tracker as
a compliance control tool to initiate or stop allotments to the states. Our
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examination of the tracker identified deficiencies with Oregon, Louisiana, and
Washington.
Oregon: ETA noted that Oregon had a waiting week, with a waiver effective date
of March 8, 2020, and an expiration date of September 4, 2021. According to
comments within the tracker, Oregon confirmed that prior to December 31, 2020,
the states information technology system was programmed to waive the waiting
week in accordance with state law. The tracker did not indicate the retroactive
application was used by Oregon or its impact on eligible reimbursements.
Louisiana: ETA noted that Louisiana had a waiting week, with a waiver effective
date of March 11, 2020, and an expiration date of September 29, 2021. The
tracker did not document the 2 short-term waivers, or the gap period that was not
covered by the waiver.
Washington: On December 28, 2020, Washington’s waiting week waiver
expired, and the state was no longer eligible to participate in the TFFF program.
Washington continued to pay claimants (despite state law indicating such
payments were not permitted) and drew down approximately $4 million in TFFF
funding for reimbursement. If ETA’s tracker was operating appropriately, ETA
could have prevented Washington from drawing down these funds, which they
were not eligible to receive at the time.24
ETA DID NOT REQUIRE STATES TO SUPPORT
TFFF DRAWDOWN AMOUNTS
ETA did not require states to provide supporting schedules or monthly
certifications for TFFF drawdowns. Of the 6 states selected for in-depth analysis,
all 6 indicated they did not submit documentation to validate the amounts being
drawn down. We originally surveyed 47 states; however, only 32 states
responded. We issued a second survey to the 32 responding states. The second
survey included a question asking whether ETA required the state to submit
schedules or other details to support that the funds being drawn down from the
TFFF account were for reimbursement of eligible first-week regular UI claims. Of
the 32 states, 15 states indicated that such schedules were not provided to ETA.
24 The subsequent passage of ARPA on March 11, 2021, provided states the option to
retroactively waive waiting weeks and receive reimbursement for weeks ending after
December 31, 2020. As such, the state was ultimately eligible for reimbursement but could not
have foreseen this option on December 28, 2020.
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22 MONTHS AFTER THE TFFF BENEFIT
ELIGIBILITY PERIOD EXPIRED, NEARLY
$5 BILLION REMAINED IN FUA
ETA provided the 53 participating SWAs with $12.5 billion in TFFF funding
through 2 allotments. States were entitled to receive estimated allotments that
were to be decreased or increased based upon the actual prior monthly amounts
that should have been provided to the states. As ETA was more focused on initial
funding than subsequent adjustments, ETA made a minimal number of
adjustments even though its internal controls were not sufficient to verify the
reasonableness of allotted amounts. Although states accessed $7.5 billion of
TFFF funding as reimbursements, nearly $5 billion remained in FUA for states to
access more than 22 months after the benefit eligibility period expired (see
Exhibit 3). With no formal plan to reconcile state accounts and return unused
TFFF funds, these remaining balances are vulnerable to fraud, waste, and
abuse. Further, the remaining funds could have been put to better use (see Table
5 in Exhibit 1).
ETA provided $12.5 billion in TFFF funding, which comprised 2 separate
allotments. The first allotment of $10.6 billion was made available in May 2020,
and the second allotment of $1.9 billion was made available in August 2021.
From July 24, 2020, through January 31, 2022, ETA made adjustments on
7 occasions involving a series of transfers between 26 of the 53 SWAs’ TFFF
accounts totaling $1.2 billion.25 States were to draw down these funds as
reimbursement26 to cover the cost of compensation paid to individuals for their
first week of regular unemployment without a waiting week.27 Overall, the
53 SWAs drew down $7.5 billion of the $12.5 billion made available, leaving
nearly $5 billion (40 percent) unused as of July 31, 2023 (more than 22 months
after the TFFF benefit eligibility period expired on September 6, 2021).
For the 6 states we sampled for in-depth testing (Delaware, Iowa, Louisiana,
Minnesota, Nevada, and Oregon), ETA made $932.1 million available through
allotments of $709.8 million and another $222.3 million through transfers of funds
previously provided to other states. The three ETA initiated transfers that were
25 These transfers occurred between state accounts with no net change in overall allotments or
funding. The last allotment adjustment was January 31, 2022.
26 States could also be advanced TFFF program funds. On December 27, 2020, the CAA
decreased federal funding for TFFF program reimbursements from 100 percent to 50 percent. On
March 11, 2021, ARPA restored federal funding for TFFF program reimbursements to
100 percent.
27 States could also receive payment for any additional TFFF program related administrative
expenses incurred through the Unemployment Trust Fund’s Employment Security Administration
account.
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made to 3 of the 6 states (Delaware, Nevada, and Oregon) were each lump sum
amounts occurring during the period November 25, 2020, through
January 31, 2022. The 6 states drew down a total of $689 million with
$243.1 million (26 percent) remaining as of July 31, 2023; see Table 1 for details.
Table 1: Transactions and Remaining Balances for the Six Sampled States
through July 31, 2023
State
Allotments1
Transfers2
Drawdowns3
Ending
Balance
Percent of
Funding
Remaining
DE
$23,295,000
$5,000,000
($21,503,729)
$6,791,271
24%
IA
$126,676,000
0
($89,090,770)
$37,585,230
30%
LA
$115,749,000
0
($76,858,660)
$38,890,340
34%
MN
$236,969,000
0
($177,948,019)
$59,020,981
25%
NV
$147,471,000
$70,000,000
($194,596,384)
$22,874,616
11%
OR
$59,620,000
$147,342,000
($129,003,622)
$77,958,378
38%
Total
$709,780,000
$222,342,000
($689,001,183)
$243,120,817
26%
Source: ETA allotment and drawdown reports provided to the OIG.
1 “Allotments” refers to amount of funds ETA made available in the FUA to the states.
2 “Transfers” refers to allotment adjustments made between states’ accounts to increase or
decrease state balances.
3 “Drawdowns” refers to the amount of federal funds the states accessed from FUA for
reimbursement of first-week regular UI compensation paid out by the states directly to claimants.
Furthermore, of the nearly $5 billion in total TFFF funding that was unused,
$1.1 billion (approximately 22 percent) represented TFFF funds that 7 of the
53 SWAs never accessed even though ETA allocated those funds to their
accounts (see Table 2).
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Table 2: States That Did Not Draw Down TFFF Funds Through July 31, 2023
State
Funding Provided
Illinois
$584,351,000
Kansas
$181,068,000
Arizona
$129,063,000
Alabama
$104,885,000
Vermont
$31,203,000
Alaska
$24,593,000
Wyoming
$15,217,000
Total
$1,070,380,000
Source: ETA provided allotment and drawdown reports to the OIG.
ETA’S EMERGENCY RESPONSE FOCUSED MORE
ON INITIAL TFFF FUNDING THAN SUBSEQUENT
ADJUSTMENTS
According to Section 2105(c)(2) of the CARES Act, the TFFF program would
provide states payment either through an advance or reimbursement, as
determined by the Secretary. Estimated amounts provided to the states would be
decreased or increased, as the case may be, by the amount the estimated
allotments deviated from actual amounts the state should have been paid in the
prior calendar months. ETA guidance provided through UIPL 20-20, emphasizes
this CARES Act language, specifically: “[a]s a state’s drawdown of allotments is
monitored, monthly amounts will be adjusted as needed.” This same section of
the CARES Act also explains that estimates may be made on the basis of such
statistical, sampling or other method as may be agreed upon by the Secretary
and the state workforce agency of the state involved.
ETA prioritized getting relief funding to states as quickly as possible during the
pandemic, and instead of allotting funds on a monthly basis, two estimated
allotments for the anticipated duration of the program were provided. ETA did not
reach out to states to coordinate estimates for initial program funding. ETA
officials stated the following:
“ETA recognized the importance and intended CARES Act goals of
getting funding to claimants quickly in the early days of the pandemic
and the structure of the TFFF funding mechanism was set up with
this in mind. ETA also recognized that states were not in a position to
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respond to quick turn-around requests for TFFF program estimates
while processing these massive claims loads and as such did not
attempt to require this information from states before providing
access to funding.”
ETA adjusted amounts allotted to the states on 7 occasions28 during the period of
March 27, 2020, through June 30, 2022, with the majority of ETA’s adjustments
impacting a minimal number of states. For example, of the 7 total adjustments,
4 adjustments reallocated allotments between 2 states on each occurrence.
Twenty-seven of the states did not have any adjustments to their allotments
during that period.
Throughout the duration of the program, ETA did not coordinate or analyze
allotment adjustments with the states. Specifically, ETA did not consult the states
with regards to 1) the need for additional allotments, or 2) the existing allotments
being in excess of anticipated needs. The absence of ETA’s consultation with
states regarding their needs for the program limited ETA’s ability to effectively
estimate allotments and then make well-informed adjustments.
None of the 6 states indicated ETA had consulted with them regarding the initial
allotment, subsequent adjustments, or sufficiency of prior allotments. Further,
ETA did not communicate with the states regarding adjustments ETA made to
their available allotments. This includes 4 of the 6 states that received allotments
totaling $109.4 million29 less than a month before the TFFF benefit eligibility
period expired. For the 47 states we surveyed, we received 32 responses. Of
those 32 responses, 28 (88 percent) stated that ETA did not conduct a state
review related to the TFFF program. The responses for the other 4 states did not
specifically mention that a TFFF review was performed.
According to ETA officials, ETA did not receive additional funding to support the
oversight of the TFFF program until the enactment of ARPA. Despite the
expansion of pandemic-related UI programs, ETA staffing resources remained at
similar levels before the pandemic. ETA officials further stated the following:
“ETA notes that it was not provided any additional funding to
support this program. The same staff had to support the operation
of this and the other new pandemic-related programs, in addition to
the regular UI program. In fact, no additional funding for ETA
operations was provided until the enactment of ARPA in
28 Allotment adjustments were made 7/24/2020 (10 states impacted), 7/31/2020 (2 states
impacted), 11/25/2020 (2 states impacted), 3/11/2021 (9 states impacted), 6/30/2021 (11 states
impacted), 10/13/2021 (2 states impacted), 1/31/2022 (2 states impacted)
29 On August 18, 2021, the states receiving additional allotments included: Delaware
($3.6 million), Iowa ($21.2 million), Nevada ($25.0 million), and Oregon ($59.6 million).
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March 2021. This information is not provided as an excuse, but as
realistic context of the challenges facing the operations of these
programs.”
Although the pandemic presented ETA and states with unprecedented
challenges, ETA should have coordinated with states to determine funding needs
for initial allotments and subsequent adjustments.
ETA’S INTERNAL CONTROLS WERE NOT
SUFFICIENT TO VERIFY REASONABLENESS OF
AMOUNTS ALLOTTED OR ENSURE CLOSEOUT OF
UNUSED TFFF BALANCES
According to the U.S. Government Accountability Office (GAO’s) Standards for
Internal Control in the Federal Government, documentation is a necessary part of
an effective internal control system, and written policies and procedures provide
the foundation for effective internal controls. ETA did not have adequate
procedures established for:
• Retaining documentation for review of the initial allotments or
subsequent adjustments; and
• Monitoring remaining balances and ensuring unused amounts were
returned to the federal government.
UIPL 20-20 required states to maintain records during the administration of the
TFFF program and make all records available for inspection, examination, and
audit by such federal officials, employees as the Department may designate, or
as may be required by law. Further, the guidance requires that records created
during the administration of TFFF be retained for 3 years after final action
(including appeals or court action) on the payments. 30 However, ETA did not
document or maintain a record of calculations and related underlying data used
to estimate TFFF initial allotments and base decisions for subsequent
adjustments. Upon our request, ETA was unable to produce supporting
information for their calculations of initial allotments or subsequent adjustments;
written policies and procedures for preparing or reviewing allotments and
adjustments; or procedures for reconciling remaining balances and closing out
allotments. ETA asserted the initial allotment estimates were developed from UI
claims and advance claims data. However, the calculations and datasets used to
determine the states’ initial TFFF allotments (as well as subsequent adjustments)
30 According to UIPL 20-20, records may be retained for less than 3 years if copied by
microphotocopy or by electronic imaging method.
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were not maintained by ETA. Therefore, we could not analyze and determine the
validity of ETA’s estimates or adjustments.
ETA officials stated that ETA did maintain the calculations and general data but
continued to update the estimate file as additional data became available,
overwriting much of the original data utilized for the initial estimates. Further, ETA
officials indicated that on an ongoing basis, it monitored the actual drawdowns
from the initially allotted amounts and made adjustments based upon drawdown
activity, disbursement figures, and UI first payment reports submitted by states.
ETA indicated its staff accessed state drawdown data on a daily basis and
compiled a spreadsheet reflecting the daily activity. This daily spreadsheet was
used to track drawdowns instead of using ETA 211231 reporting since daily
transactions were timelier.
Of the 6 states selected for in-depth analysis, none of those states had
completed a final closeout for their unused balances of TFFF funds in FUA. ETA
officials stated the following:
ETA will continue to work with Treasury and state partners to
reconcile TFFF funding and will return any excess funding to the
general fund in coordination with the Bureau of the Fiscal Service
once reconciliation for TFFF has been completed. ETA anticipates
that a substantive amount of the remaining $5 billion will still be
drawn by states (including 8 states that still had not drawn any of
their allotted funds as of July 29, 2022) as ongoing reconciliation
efforts are completed.
However, updated TFFF account balances obtained from ETA through
July 31, 2023, showed that only $56.4 million had been drawn down among the
53 states within the 7 months from January 1, 2023, to July 31, 2023, and
35 states did not have additional drawdowns during that period. For 5 of the
6 states on which we performed in-depth procedures, we noted that a substantial
amount of time (approximately 405-789 days) had passed between the states’ last
drawdown and July 31, 2023 (see Table 3).
31 ETA 2112 is a monthly summary of transactions in a state unemployment fund which consists
of the Clearing Account, Unemployment Trust Fund Account, and Benefit Payment Account.
UIPL 20-20, Section 4.e required SWAs to report the receipt and disbursement of federal funds
for the first week of regular UI.
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Table 3: Total Number of Months between 6 States’ Last Drawdown and
July 31, 2023
State
Amount of
Last
Drawdown
Date of Last
Drawdown
Number of Days
Between Last
Drawdown and
July 31, 2023
DE
$26,639
June 21, 2022
405 days
IA
$2,148,083 December 6, 2021
602 days
LA
$2,387,282
October 5, 2021
664 days
MN
$358,916
June 2, 2021
789 days
NV
$3,533,067
February 1, 2022
545 days
OR
$5,306
July 12, 2023
19 days
Viewed collectively, the minimal dollar amount of drawdowns across 53 states
and the time lapse since the last drawdowns for 5 of the 6 in-depth states allows
us to conclude that most of the remaining almost $5 billion will not be drawn
down for eligible benefit reimbursement.
ETA had not issued formal guidance to states on how to reconcile and close out
funds, and the agency was not aware of any states completing the necessary
reconciliations to close out the program and return unused funds. ETA stated
they will provide UIPL guidance to states on the reconciliation requirements and
anticipated most of the reconciliations would be conducted once the guidance is
provided.
RECOMMENDATIONS
We recommend the Principal Deputy Assistant Secretary for Employment and
Training:
1. Work with Oregon, Louisiana, Delaware, and Mississippi to ensure the
appropriate return of approximately $105.1 million in TFFF
reimbursements for first-week regular UI compensation paid that were
associated with ineligible weeks.
2. Establish a deadline by which states are required to perform a timely
review of past drawdowns and provide evidence that drawdowns were for
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reimbursement of eligible first-week regular UI compensation paid by the
state for claim weeks that fell within the TFFF program period.
3. Reassess the eligibility of all states with waiting week provisions according
to their state laws to ensure that the waiting week was not in effect when
states accessed TFFF funds prior to December 31, 2020.
4. Ensure that any state drawdowns of the remaining almost $5 billion in
TFFF funds are only for the reimbursement of first-week regular UI
compensation paid by the state that fall within the TFFF program period
(March 27, 2020, through September 6, 2021).
5. Establish a deadline for states to reconcile and close out TFFF accounts
so ETA can facilitate deobligation of the funding.
6. Establish written procedures and deadlines for the timely return of funding
for TFFF and future similar programs and consult with OMB and Treasury
officials to execute the proper return of unused funds that remain within
states’ accounts.
7. Capture lessons learned from the TFFF program and use the information
to develop effective internal control procedures to ensure states meet
program requirements, including eligibility, and have sufficient
infrastructure in place to pay claimants’ UI benefits without delay for
similar temporary emergency UI programs that may be established in the
future.
8. Capture lessons learned from the TFFF program and use the information
to develop and implement controls to ensure the methodology and
procedures are documented and maintained for estimating allotments and
subsequent adjustments for similar temporary emergency UI programs
that may be established in the future.
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ANALYSIS OF MANAGEMENT’S COMMENTS
ETA expressed several concerns regarding the findings of our report. However,
the agency’s concerns did not result in any changes to our reported results or
conclusions. Synopses of ETA’s concerns and our corresponding response to
each are detailed below.
a. ETA stated that the draft report incorrectly indicates in a number of places
that the TFFF provisions had ended on September 6, 2021, given states
may have to work through backlogs, appeals, fraud investigations,
overpayment establishments, and recoveries after the program’s technical
end date. We acknowledge that such activities will occur after the end of
the program, and it was not our intention to indicate otherwise. Given
ETA’s confusion over this report language, we revised the report to clarify
what was intended as it relates to the end of the TFFF program.
b. ETA stated that the report inaccurately portrays certain states (Oregon
and Louisiana) as not meeting TFFF eligibility requirements. We disagree
with ETA on this matter based upon audit evidence obtained.
c. ETA expressed concern regarding our conclusions that Delaware and
Mississippi accessed TFFF funds that were outside of the allowable
period. As part of the reconciliation process, ETA plans to review the
payments and determine if payments for the weeks of eligibility were
within or outside the allowable timeframe. Our audit evidence supports
that the period of first-week regular UI benefit payments were outside the
eligible period.
d. ETA expressed concern regarding our conclusion that Washington
continued to draw down funds for first-week regular UI benefit payments
that occurred after the waiting week period expired. Our audit evidence
supports the finding as stated.
e. ETA stated that our report incorrectly implies that remaining TFFF
balances are vulnerable to fraud, waste and abuse, and that remaining
funds could have been put to better use. We disagree with ETA’s position
on this matter. As evidenced by Delaware, the state was able to draw
down funds that did not meet eligibility requirements provided through
legislation. The drawdowns by Delaware ended shortly after our inquiries
with the state. While we did not identify fraud, waste, or abuse in
Delaware’s drawdowns, the ability for states to access ineligible funds
without ETA’s knowledge is a risk for fraud, waste, and abuse.
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This is particularly relevant when approximately $5 billion of funds remain
accessible by the states without any ETA controls to prevent improper
drawdowns. In addition, ETA asserted that TFFF funds cannot be used for
anything else and to infer that funds could be used elsewhere is incorrect.
We also disagree with ETA’s assertion. While the TFFF provision limits
DOL’s use of the funds to the TFFF program, our recommendation for
ETA to deobligate and return the unused TFFF funds to the U.S.
Department of Treasury would allow the funds to be put to better use
within the federal government.
ETA agreed or partially agreed with five of the eight recommendations
(Recommendations 2, 3, 4, 5, and 6) and outlined ETA’s corrective plan of
action. However, ETA did not agree with Recommendations 1, 7, and 8, and
partially disagreed with 6.
ETA disagreed with Recommendation 1 and stated that ETA provided
information indicating Oregon and Louisiana met the eligibility requirement to
participate in TFFF. In addition, ETA requested that OIG revise the
recommendation to, “Conduct appropriate reviews and make any necessary
determinations to appropriately address costs associated with identified issues in
Oregon, Louisiana, Delaware, and Mississippi related to $105.1 million in TFFF
reimbursements for first-week regular UI compensation.” We disagree with ETA
that the recommendation should be revised. Our audit evidence showed that
Oregon, Louisiana, Delaware, and Mississippi received at least $105.1 million in
TFFF funds for the first-week regular UI benefit payments that were ineligible for
reimbursement.
ETA did not agree with part of Recommendation 6, which applies to future
programs. ETA stated that they are unable to develop written procedures for
future programs because they will not know specific requirements for future
legislation. However, ETA’s Office of Unemployment Insurance will formulate
general guidelines in anticipation of bottlenecks in accounting and reconciliation
procedures and processes that may be helpful for future programs. We disagree
with ETA’s assertion that procedures cannot be developed for future programs.
ETA should have controls in place to establish a timeframe to deobligate and
return unused funds, regardless of the program.
ETA disagreed with Recommendations 7 and 8. Specifically, ETA stated that it is
extremely challenging to develop controls for a program that does not currently
exist and for which the requirements are unknown. However, ETA stated that
ETA’s Office of Unemployment Insurance will capture lessons learned to help
inform actions for similar future programs. Therefore, ETA recommended that
Recommendations 7 and 8 be consolidated and revised to: “Develop a document
that captures lessons learned from the operation of the TFFF program and use
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this information to inform technical assistance and operating guidance for similar
temporary emergency UI programs that may be established in the future.” We
partially agree with ETA. Although the exact requirements of future programs
may be unknown, lessons learned from similar programs should provide
sufficient knowledge to develop controls that are likely to address future
programs. Therefore, we revised Recommendations 7 and 8.
ETA’s response is included in its entirety in Appendix B. We appreciate the
cooperation and courtesies ETA extended us during this audit.
Rocha & Company, PC
Gaithersburg, MD
September 28, 2023
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EXHIBIT 1: FUNDS PUT TO BETTER USE AND QUESTIONED
COSTS
Table 4: Questioned Costs for Ineligible States’ Drawdowns of TFFF
Allotments
Description
Amount
Funding accessed for periods when
waiting week was not waived
$ 91.2 million
Funding accessed for periods prior to
the period Federal guidance allowed
$ 12.5 million
Funding accessed for periods after the
period Federal guidance allowed
$ 1.4 million
Total Questioned Costs32
$ 105.1 million
Source: OIG-generated based on Rocha analysis
Table 5: Funds Put to Better Use for Allotments that Remain Unused
Description
Amount
Allotments provided by ETA for the
TFFF program that remain unused as
of July 31, 2023
$ 4.9 billion
Total Funds Put to Better Use33
$ 4.9 billion
Source: OIG-generated based on Rocha analysis
32 Questioned costs are costs: (A) resulting from an alleged violation of a law, regulation,
contract, grant, or other document or agreement governing the use of Federal funds; (B) that are
not supported by adequate documentation (also known as an unsupported cost); or (C) that
appear unnecessary or unreasonable.
33 Funds put to better use estimate funds that could be used more efficiently. Some examples
would be reducing spending, deobligating funds, or avoiding unnecessary spending.
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EXHIBIT 2: DELAWARE DRAWDOWN OF INELIGIBLE WEEKS
AFTER SEPTEMBER 6, 2021
Applied
Date
Subsequent
Drawdowns
09/13/2021
29,053
09/20/2021
43,553
09/27/2021
29,150
10/04/2021
32,462
10/12/2021
39,110
10/18/2021
35,678
10/26/2021
32,295
11/01/2021
29,855
11/08/2021
32,229
11/15/2021
25,977
11/22/2021
39,542
12/01/2021
33,615
12/06/2021
29,149
12/13/2021
27,427
12/20/2021
34,508
12/27/2021
36,470
01/04/2022
23,852
01/10/2022
26,576
01/18/2022
43,593
01/24/2022
34,875
01/31/2022
41,831
Subtotal
$700,800
Applied
Date
Subsequent
Drawdowns
02/07/2022
$35,251
02/14/2022
45,729
02/22/2022
41,055
02/28/2022
44,962
03/07/2022
38,732
03/14/2022
20,104
03/21/2022
46,147
03/28/2022
45,455
04/04/2022
40,968
04/11/2022
41,512
04/18/2022
32,983
04/25/2022
41,227
05/02/2022
34,588
05/09/2022
27,333
05/16/2022
25,823
05/23/2022
25,283
05/31/2022
28,655
06/02/2022
16,575
06/07/2022
25,544
06/13/2022
29,928
06/21/2022
26,639
Subtotal
$714,493
TOTAL SUBSEQUENT DRAWDOWNS:
$1,415,293
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EXHIBIT 3: SUMMARY OF TFFF TRANSACTIONS AND ENDING
BALANCES THROUGH JULY 31, 2023
State
1st Allotment
Transfers
2nd Allotment
Drawdowns
Ending Balance
Percent of
Funding
Remaining
AK
$23,213,000
$0
$1,380,000.00
$0
$24,593,000
100%
AL
95,135,000
0
9,750,000
0
104,885,000
100%
AR
48,434,000
0
1,740,000
(14,550,628)
35,623,372
71%
AZ
119,393,000
(20,000,000)
29,670,000
0
129,063,000
100%
CA
1,221,909,000
432,267,000
291,290,000
(1,639,369,833)
306,096,167
16%
CO
160,679,000
110,363,000
3,040,000
(267,519,097)
6,562,903
2%
CT^
137,394,000
30,000,000
0
(151,519,083)
15,874,917
9%
DC
26,903,000
14,465,000
8,880,000
(30,067,851)
20,180,149
40%
DE
19,695,000
5,000,000
3,600,000
(21,503,729)
6,791,271
24%
FL
880,226,000
(415,000,000)
0
(440,248,411)
24,977,589
5%
GA^
643,306,000
(334,426,000)
0
(241,244,429)
67,635,571
22%
HI
103,496,000
0
0
(59,789,017)
43,706,983
42%
IA^
105,456,000
0
21,220,000
(89,090,770)
37,585,230
30%
ID
32,751,000
0
0
(10,829,100)
21,921,900
67%
IL
322,621,000
0
261,730,000
0
584,351,000
100%
IN
157,374,000
23,570,000
11,110,000
(152,683,858)
39,370,142
20%
KS
74,838,000
0
106,230,000
0
181,068,000
100%
KY
268,383,000
(110,400,000)
0
(102,958,422)
55,024,578
35%
LA
115,749,000
0
0
(76,858,660)
38,890,340
34%
MA
323,962,000
0
180,520,000
(241,773,910)
262,708,090
52%
MD^
185,338,000
0
0
(93,182,238)
92,155,762
50%
ME
44,566,000
0
2,930,000
(1,711,001)
45,784,999
96%
MI^
360,198,000
0
115,590,000
(226,870,915)
248,917,085
52%
MN
236,969,000
0
0
(177,948,019)
59,020,981
25%
MO
132,257,000
0
0
(47,519,587)
84,737,413
64%
MS
53,702,000
3,527,000
0
(46,630,503)
10,598,497
19%
MT
25,550,000
0
0
(19,602,232)
5,947,768
23%
NC
218,215,000
(50,000,000)
23,270,000
(104,993,701)
86,491,299
45%
ND
25,884,000
0
9,280,000
(28,808,094)
6,355,906
18%
NE
29,899,000
0
2,380,000
(18,609,007)
13,669,993
42%
NH
47,885,000
0
0
(35,957,959)
11,927,042
25%
NJ^
417,152,000
0
0
(299,273,220)
117,878,781
28%
NM
47,580,000
0
12,330,000
(41,878,303)
18,031,697
30%
NV
122,471,000
70,000,000
25,000,000
(194,596,384)
22,874,616
11%
NY
697,563,000
(3,500,000)
305,780,000
(362,638,182)
637,204,818
64%
OH
302,912,000
0
59,220,000
(224,440,916)
137,691,084
38%
OK
193,020,000
(10,000,000)
0
(118,993,112)
64,026,888
35%
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EXHIBIT 3: SUMMARY OF TFFF TRANSACTIONS AND ENDING
BALANCES THROUGH JULY 31, 2023
(CONTINUED)
State
1st Allotment
Transfers
2nd Allotment
Drawdowns
Ending Balance
Percent of
Funding
Remaining
OR
0 147,342,00034
59,620,000
(129,003,622)
77,958,378
38%
PA
467,177,000
0
96,900,000
(293,696,357)
270,380,643
48%
PR
0
81,503,00035
4,170,000
(9,876,426)
75,796,574
88%
RI
42,167,000
35,000,000
22,480,000
(65,083,597)
34,563,403
35%
SC
130,027,000
(10,000,000)
0
(88,692,717)
31,334,283
26%
SD
13,719,000
0
0
(8,930,500)
4,788,500
35%
TN
103,905,000
30,000,000
31,780,000
(104,861,534)
60,823,466
37%
TX
882,344,000
(167,342,000)
137,680,000
(616,760,796)
235,921,204
28%
UT
51,279,000
0
11,990,000
(25,145,976)
38,123,024
60%
VA
202,375,000
134,178,000
42,560,000
(158,579,692)
220,533,308
58%
VI
86,000
3,500,000
0
(2,641,660)
944,340
26%
VT^
0
24,953,00036
6,250,000
0
31,203,000
100%
WA
460,857,000
0
0
(335,173,424)
125,683,576
27%
WI
137,652,000
(30,000,000)
15,880,000
(73,215,525)
50,316,475
41%
WV
49,818,000
5,000,000
0
(49,818,000)
5,000,000
9%
WY^
10,797,000
0
4,420,000
0
15,217,000
100%
TOTAL
$10,574,281,000
$0 $1,919,670,000
($7,545,139,994)
$4,948,811,006
40%
^ Indicates a state with no waiting week in its existing state law. In total, only 8 of the 53 states
did not have a waiting week to waive to participate in the TFFF program.
34 This transfer was made on 11/25/2020 and represents the first funding made available to the
Oregon SWA.
35 This transfer was made on 7/24/2020 and represents the first funding made available to the
Puerto Rico SWA.
36 This transfer was made on 7/24/2020 and represents the first funding made available to the
Vermont SWA.
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APPENDIX A: SCOPE AND METHODOLOGY
SCOPE
The audit of TFFF covered the period of March 27, 2020, to September 6, 2021.
To determine the amount of TFFF allotments that remained accessible to states
following the end of the program (September 6, 2021), we obtained reports from
ETA that identified total allotments (including adjustments) made to the states,
amounts accessed, remaining balances as of July 31, 2023, ETA internal reports
utilized to monitor the program, and surveys.
The objective of the audit was to determine if ETA ensured states met TFFF
program requirements and used funding according to the statutory intent of the
CARES Act and its related subsequent legislation.
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.
This performance audit was conducted remotely and covered 6 states
judgmentally selected by the OIG for in-depth testing. In addition, we sent
surveys to an additional 47 states. To answer our audit objective, we reviewed
the CARES Act and related subsequent legislation, ETA guidance, ETA program
monitoring reports, state agreements and executive orders, program funding, and
states’ financial reports.
Furthermore, we analyzed datasets used by the states to draw down funds and
tested those databases at the individual payment level to verify that those
amounts were first-week compensation amounts eligible for reimbursement
under the program.
SELECTION OF SIX STATES
To perform our audit, the OIG judgmentally selected 6 states—Delaware, Iowa,
Louisiana, Minnesota, Nevada, and Oregon—for in-depth analysis based on:
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• the amount of TFFF funds that states received from March 27, 2020,
through July 31, 2021, stratified into the highest, middle, and lowest
ranges; and
• the extent to which the states had not been selected for review in previous
OIG audits.
Our sampling plan was designed under the assumption of Moderate to High Risk.
This called for a design with 95 percent confidence and 7 percent relative
precision of estimate. We used multi-stage sampling comprising 3 levels from
which simple random samples were selected. When the testing was complete,
our statistician projected differences to the population using appropriate
statistical estimation formulas, unless differences were clearly inconsequential.
STATES SURVEYED
We sent surveys to the remaining 47 states to verify which states participated in
the program, the level of oversight and support provided by ETA to those states,
allotment amounts made available, funding accessed by states, remaining
balances, and any challenges with implementing the program or instances of
non-compliance (including assessing retroactive implementation) states may
have experienced.
DATA RELIABILITY
Methods of determining data reliability were dependent upon availability of
information at the state level. However, the primary method of ensuring data
reliability involved reconciliations of first-week compensation datasets to the
amounts drawn down from the TFFF account as identified in the states’
Automated Standard Application for Payments (ASAP) system. Key reports
received from ETA were compared to source documents received at the state
level, as well as to survey responses.
INTERNAL CONTROLS
A performance audit includes an understanding of internal controls considered
significant to the audit objective and testing compliance with significant laws,
regulations, and other requirements. In planning and performing our audit, we
considered whether internal controls significant to the audit objective were
properly designed and placed in operation. This included reviewing policies and
procedures. We confirmed our understanding of these controls and procedures
through interviews and the review and analysis of documentation. The objective
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of our audit was not to provide assurance on internal controls; therefore, we did
not express an opinion on ETA’s internal controls. Our consideration of internal
controls for administering key CARES Act UI programs 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
• Coronavirus Aid, Relief, and Economic Security (CARES) Act, Public Law
116-136 (March 27, 2020)
• Consolidated Appropriations Act, 2021, Division N, Title II, Subtitle A,
Chapter 1, the Continued Assistance for Unemployed Workers Act of
2020, Public Law 116-260 (December 27, 2020)
• American Rescue Plan Act of 2021, Public Law 117-2 (March 11, 2021)
• GAO-14-704G: Standards for Internal Control in the Federal Government
(September 2014)
• Unemployment Insurance Program Letter 14-20: CARES Act of 2020 –
Summary of Key Unemployment Insurance (UI) Provisions and Guidance
Regarding Temporary Emergency State Staffing Flexibility
• Unemployment Insurance Program Letter 20-20: 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, of the CARES
Act of 2020
• Unemployment Insurance Program Letter 9-21: Continued Assistance for
Unemployed Workers Act of 2020 (Continued Assistance Act) – Summary
of Key Unemployment Insurance (UI) Provisions
• Unemployment Insurance Program Letter 14-21: American Rescue Plan
Act of 2021 (ARPA) – Key Unemployment Insurance Provisions
PRIOR RELEVANT COVERAGE
During the last 4 years, the OIG has issued 3 reports of significant relevance to
the subject of this report. Those reports are the following:
1. Advisory Report — CARES Act: Initial Areas of Concern Regarding
Implementation of Unemployment Insurance Provisions, Report
No. 19-20-001-03-15 (April 21, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2020/19-20-001-03-315.pdf;
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2. COVID-19: More Can Be Done to Mitigate Risk to Unemployment
Compensation under the CARES Act, Report No. 19-20-008-03-315
(August 7, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2020/19-20-008-03-315.pdf; and
3. COVID-19: States Struggled to Implement Cares Act Unemployment
Insurance Programs, Report No. 19-21-004-03-315 (May 28, 2021),
available at: https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-
315.pdf.
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APPENDIX B: AGENCY’S RESPONSE TO THE REPORT
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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
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