Evaluation Memorandum: A Review of Pandemic Unemployment Insurance Relief and Its Impact on Six Different U.S. Communities (DOL OIG, March…

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An evaluation memorandum issued March 28, 2024 by the U.S. Department of Labor Office of Inspector General, Report Number 19-24-002-03-315, addressed to the Principal Deputy Assistant Secretary for Employment and Training. It reports the OIG's work in the second phase of a Pandemic Response Accountability Committee review of pandemic relief in six communities, among them Springfield, Massachusetts and Coeur d'Alene, Idaho. The memorandum covers three CARES Act unemployment insurance programs, FPUC, PUA and PEUC, and reports 33,433 claimants receiving $516,034,956 between March 27, 2020 and September 6, 2021. It states that 339 claimants were selected for in-person interviews, that satisfaction was rated 4.1 on a 5-point scale, and that 7.6 percent of claims, totaling $46,436,308, carried fraud indicators. The memorandum makes no recommendations.

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U.S. Department of Labor 
Office of Inspector General 
 
 
 
Washington, DC 20210 
 
Working for America’s Workforce 
March 28, 2024 
 
 
MEMORANDUM FOR: 
BRENT PARTON 
 
 
 
 
Principal Deputy Assistant Secretary 
 
 
 
 
  for Employment and Training 
 
 
 
 
 
 
FROM: 
 
 
CAROLYN R. HANTZ 
 
 
 
 
Assistant Inspector General  
  for Audit 
 
 
SUBJECT: 
A Review of Pandemic Unemployment 
Insurance Relief and Its Impact on Six Different 
U.S. Communities 
 
Report Number: 19-24-002-03-315 
 
The Pandemic Response Accountability Committee (PRAC)1 led a two-phased 
review to identify the federal funds distributed to local communities2 across the 
United States in response to the COVID-19 pandemic as of September 30, 2021, 
and to determine if the spending of the funds aligned with program goals. In 
support of this review, the Office of Inspector General (OIG) conducted an 
evaluation of the Department of Labor’s (DOL) unemployment insurance (UI) 
response to the COVID-19 pandemic. 
 
We specifically evaluated the DOL programs that expanded UI benefits for 
workers who were impacted by the pandemic. The federal UI benefits from the 
following three key Coronavirus Aid, Relief, and Economic Security (CARES) Act 
UI programs were reviewed: Federal Pandemic Unemployment Compensation 
(FPUC), Pandemic Unemployment Assistance (PUA), and Pandemic Emergency 
Unemployment Compensation (PEUC). The programs were initiated by the 
CARES Act on March 27, 2020, and concluded on September 6, 2021. These 
programs were selected based on federal spending research and program 
funding amounts. 
 
                                            
1 The PRAC was created by the Coronavirus Aid, Relief, and Economic Security Act to support 
and coordinate independent oversight of more than $5 trillion in pandemic relief programs and 
spending. For more information, visit: https://www.PandemicOversight.gov/. 
2 The PRAC selected six locations for review across three types of geographic areas (two small-
to-medium sized cities, two rural counties, and two tribal areas). 

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To conduct this review and measure the federal government’s pandemic 
response, the PRAC selected3 six communities of different sizes and geographic 
areas from across the country: Springfield, Massachusetts; Coeur d’Alene, Idaho; 
Marion County, Georgia; Sheridan County, Nebraska; White Earth Nation 
Reservation in Minnesota; and Jicarilla Apache Nation Reservation in New 
Mexico.  
 
To complete our review, we evaluated the CARES Act, Continued Assistance for 
Unemployed Workers Act of 2020, the American Rescue Plan Act of 2021, 
Employment and Training Administration (ETA) guidance, the Department of 
Homeland Security’s Federal Emergency Management Agency guidance, and 
state agreements to participate in pandemic UI programs. We analyzed DOL 
pandemic-related UI program funding allocated to the designated communities 
based upon USASpending.gov data, PandemicOversight.gov data, ETA – Office 
of Unemployment Insurance public data, state-reported data, and 
correspondence with ETA. We also analyzed summary data on UI claims and 
funding available from the states.  
 
To assess the benefit recipients’ experiences with the three key CARES Act UI 
programs in the designated geographic areas, we judgmentally4 selected 
339 claimants with whom OIG investigators performed on-site interviews. The 
review team also worked with OIG data scientists to determine the amount of 
fraud indicators associated with benefits paid within the three key CARES Act 
programs in the designated geographic areas. We conducted this review in 
accordance with the Quality Standards for Inspection and Evaluation issued by 
the Council of the Inspectors General on Integrity and Efficiency. Those 
standards require that we plan and perform the review to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our objective. 
 
This memorandum applies to our work conducted in the second phase of the 
PRAC review, which focused on identifying the UI program funding provided to 
local communities to help them respond to the pandemic, as well as the benefit 
recipients’ experiences and the integrity of the programs. For additional detailed 
reports for the six communities, including analyses from the nine other 
                                            
3 To select the six local communities in the three geographic areas in the review, the PRAC 
employed a random selection process using several data sources. 
4 Judgmental sampling, a non-probability sampling technique, was employed in this review, 
whereby sample members were selected based on the auditor’s knowledge and judgment. To 
ensure the integrity of the interviews and to avoid interfering with ongoing or future investigations, 
claimants with fraud indicators were excluded from the selection process. Specifically, we 
removed any claimants with a fraud indicator, then judgmentally selected 60 claimants for our 
sample. However, in the case of Sheridan County, Nebraska, our approach of judgmental 
sampling was limited to 39 claimants, as only this number met our criteria for inclusion. 

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participating federal agencies, and an overall PRAC Insights Report, see the 
PRAC’s Impact Project webpage.5 
 
Identified Pandemic Funds for UI Programs 
 
On March 27, 2020, the CARES Act was signed into law with the intent of 
providing expanded UI benefits to workers who were unable to work as a direct 
result of the COVID-19 pandemic. The pandemic-related UI programs were later 
extended by the Continued Assistance for Unemployed Workers Act of 2020 and 
the American Rescue Plan Act of 2021, which ended on September 6, 2021. Our 
review focused on three key CARES Act programs: 
 
• Federal Pandemic Unemployment Compensation. Under the 
CARES Act, the FPUC program provided a supplemental payment 
of $600 per week to individuals with at least one dollar ($1) of 
underlying benefits from designated unemployment compensation 
programs6 until July 31, 2020. The program resumed under the 
Continued Assistance for Unemployed Workers Act of 2020 with 
supplemental payments of $300 per week and extended by the 
American Rescue Plan Act of 2021 until September 6, 2021. 
• Pandemic Unemployment Assistance. The PUA program 
extended UI benefits to individuals who were not traditionally 
eligible for UI benefits. This included self-employed workers, 
independent contractors, those with limited work history, and those 
who otherwise did not qualify for regular unemployment 
compensation or extended benefits under state or federal law or 
PEUC. With all the legislative extensions, claimants could receive 
up to 79 weeks of PUA payments. 
• Pandemic Emergency Unemployment Compensation. The 
PEUC program provided additional weeks of unemployment 
compensation to individuals who: exhausted their regular 
unemployment benefits under state or federal law; had no rights to 
regular unemployment compensation under any other state law or 
federal law; were not receiving compensation under the UI laws of 
                                            
5 The Insights Report (PRAC, “A Review of Pandemic Relief Funding and How it Was Used in Six 
Different U.S. Communities,” Report No. PRAC-2024-02) was issued by the PRAC on 
March 28, 2024. Subsequent detailed reports, including the OIG’s survey results and fraud 
indicator analyses for each of the six locations, are planned to be released between April and 
December 2024 and made available on the PRAC’s website, which can be found at: 
https://www.pandemicoversight.gov/spotlight/focus-on-six-communities. 
6 UI programs eligible for FPUC were regular UI, Unemployment Compensation for Federal 
Employees, Unemployment Compensation for Ex-Servicemembers, Pandemic Emergency 
Unemployment Compensation, Pandemic Unemployment Assistance, Extended Benefits, 
Short-Time Compensation, Trade Readjustment Allowances, Disaster Unemployment 
Assistance, and payments under the Self-Employment Assistance program. 

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Canada; and were able to work, available to work, and actively 
seeking work, while recognizing that states must provide flexibility 
in meeting the “actively seeking work” requirement. With all the 
legislative extensions, claimants could receive up to 53 weeks of 
PEUC payments. 
 
Under an agreement with DOL, state workforce agencies (SWA) made UI 
payments to claimants, and DOL made funding available to cover the cost of the 
additional payments, ongoing administrative support, and reasonable 
implementation costs. For the period March 27, 2020, through 
September 6, 2021, we identified more than 33,400 UI beneficiaries across the 
six communities; collectively, they received over $516 million (see Table 1). 
 
Table 1: Total Pandemic-Related UI Benefits in the Six Communities 
(March 27, 2020, through September 6, 2021) 
 
Program 
Total Benefits Paid 
Total  
Claimants 
Average Benefit 
Per Claimant 
FPUC 
$323,248,650 
33,329 
$9,699 
PUA 
$118,434,214 
7,893 
$15,005 
PEUC 
$74,352,092 
10,192 
$7,295 
Total 
$516,034,956 
33,4337 
$15,435 
Source: OIG data analysis of SWA claims data for the period March 27, 2020, to 
September 6, 2021 
 
Benefit Recipient Experience 
 
To assess the new CARES Act UI programs (FPUC, PUA, and PEUC), we 
judgmentally selected 339 residents (claimants) from the six communities. OIG 
investigators traveled to the areas, confirmed the individuals filed a UI claim, and 
performed in-person interviews with the claimants. Of the 339 claimants, 
100 (29 percent) who received benefits from at least one of the three key 
pandemic UI programs chose to respond. The surveys were conducted from 
May 2022 to December 2022. 
 
The OIG deliberative process for this project’s sample selection included 
removing possible fraudulent claims to ensure interviews of only eligible UI 
claimants. To do so, we used fraud indicators. This removal also ensured that 
OIG investigators did not impact ongoing investigations or interact with possible 
subjects or targets of future OIG investigations. 
 
                                            
7 Individual claimants could receive benefits from multiple pandemic-related UI programs. 

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Satisfaction with the New CARES Act UI Programs Was High—Both Overall 
and with Specific Components 
 
Generally, the majority of surveyed claimants reported the ease of completing the 
application process, overall experience filing a claim, promptness of UI benefit 
payments, and certification process to continue to receive benefits as satisfying.8 
Overall, satisfaction with the UI system was rated 4.1 on a 5-point scale, with 
46 percent of surveyed claimants rating their experience as extremely satisfying 
(see Figure 1).  
 
Figure 1: Surveyed Claimants Assessment of Claims Process9 
 
 
Source: OIG data analysis of claimant surveys conducted from May 2022 to 
December 2022 
                                            
8 Surveyors asked claimants a series of questions and claimants responded based on a five-point 
scale where 1 was extremely dissatisfied and 5 was extremely satisfied. 
9 In the State of Georgia, employers are permitted to file UI claims for employees. As a result, 
claimants with an employer-filed claim were not asked certain questions, which are indicated with 
an asterisk (*) in Figure 1 and Figure 3. 

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The accessibility of the UI office to answer questions and offer assistance was 
rated the lowest of all aspects—18 percent of surveyed claimants rated their 
experiences as extremely dissatisfying. In addition, surveyed claimants 
encountered various difficulties throughout the process, including claim denials, 
issues with the certification process, completing the application, gathering 
necessary information, confusion regarding program eligibility and weekly 
certifications, contacting the SWA, and technical challenges such as identity 
proofing.  
 
Regional SWA officials10 mentioned technical obstacles related to the online 
application’s accessibility, language barriers, and high website traffic. The 
officials also acknowledged the significant increase in customers, with people 
waiting in halls for services. For example, the Georgia Department of Labor 
processed more UI claims than in the previous 8 years combined. Additionally, 
there were technological problems with claimant identity verification and payment 
distribution to the correct address. 
 
Surveyed Claimants Generally Felt the CARES Act UI Programs Were 
Impactful, Sufficient, and Fair 
 
The majority of surveyed claimants reported either somewhat agreeing or 
strongly agreeing that benefits provided by the CARES Act had a positive impact 
on their ability to meet their needs, were sufficient to pay for basic necessities, 
and were fair and reasonable (see Figure 2).11 The surveyed claimants also 
agreed or strongly agreed that the number of weeks that benefits were provided 
was sufficient. On average, 2 to 8 percent of surveyed claimants strongly 
disagreed that the benefits had a positive impact, were sufficient, or were fair and 
reasonable. 
 
                                            
10 The PRAC and/or DOL OIG audit teams interviewed officials at the MassHire Springfield 
Career Center; Idaho Department of Labor - Post Falls Office; the Regional Nebraska 
Department of Labor office in Scottsbluff, Nebraska; and the Georgia Department of Labor Career 
Center in Americus, Georgia. 
11 Surveyors offered claimants a series of statements and, for each statement, asked claimants to 
indicate if they: (a) strongly agreed, (b) somewhat agreed, (c) neither agreed nor disagreed, 
(d) somewhat disagreed, or (e) strongly disagreed. 

-7- 
Figure 2: Surveyed Claimants Assessment of Benefits 
 
 
Source: OIG data analysis of claimant surveys conducted from May 2022 to 
December 2022 
 
Surveyed Claimants Generally Still Experienced Difficulty in the 
Labor Market 
 
At the times the surveys were conducted, 21 percent of claimants reported they 
were not currently working for pay, and 37 percent reported they were unable to 
find employment before benefits ran out (see Figure 3). 
 
Additionally, 84 percent of surveyed claimants reported the SWAs did not assist 
them with gaining re-employment. The survey did not address whether the 
claimants were aware of the SWAs’ job placement services. Furthermore, 
according to ETA officials, the COVID-19 pandemic led to a tenfold increase in 
initial claims for federal and state programs, overwhelming the capacity of states’ 
systems. In interviews with regional SWA officials, it was revealed that 

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employment services had to shift their focus to processing UI claims to meet the 
heightened demand. 
 
Figure 3: Surveyed Claimants Return to Work Assessment12 
 
 
Source: OIG data analysis of claimant surveys conducted from May 2022 to December 2022 
 
Interviews with the regional SWA officials noted that some employers felt 
surveyed claimants could earn more by collecting UI and, therefore, would not 
return to work. However, SWA officials stated there were other factors that 
affected individuals’ choices to not to return to work, such as health concerns and 
virtual school requiring adults to stay home. Furthermore, inflation impacted the 
cost of resources, like housing in Coeur d’Alene, which deterred certain workers 
from applying for work in the area. Additionally, regional SWA officials reported 
there were labor shortages prior to the pandemic. 
 
Program Integrity 
 
With the passage of the CARES Act and subsequent pandemic legislation, 
pandemic-related UI programs became a target for fraud. OIG investigators, 
                                            
12 In the State of Georgia, employers are permitted to file UI claims for employees. As a result, 
claimants with an employer-filed claim were not asked certain questions, which are indicated with 
an asterisk (*) in Figure 1 and Figure 3. 

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auditors, and data scientists have created a series of fraud indicators13 to identify 
potentially fraudulent UI claims. Specifically, we identified 7.6 percent of the 
claims submitted to the OIG for the six geographic areas as potentially fraudulent 
(see Table 2). 
 
Table 2: Fraud Indicators Analysis for the Six Geographic Areas14 
 
Category 
Claimants 
Percent of 
Total 
Amount Paid 
Total Claimants  
33,433 
- 
$516,034,956 
Claimants w/ Potential 
Fraud Indicator: 
 
 
 
 
Multistate 
1,781 
5.3% 
$31,622,552 
 
Suspicious Email 
826 
2.5% 
$23,337,048 
 
State Flagged 
77 
<1% 
$1,803,651 
 
Deceased Person 
4 
<1% 
$93,381 
 
All Preceding Fraud 
Indicators (claimants with 
multiple indicators were 
only included once to 
avoid duplication) 
2,548 
7.6% 
$46,436,308 
Source: OIG data analysis of SWA claims data for the period March 27, 2020, to 
September 6, 2021 
 
Prior to the release of this report, the potentially fraudulent claims were referred 
to the OIG’s Office of Investigations to assess and determine if the claims 
warrant investigation. If the claims did not warrant investigation, we referred the 
claims to the appropriate SWA. 
 
Conclusion 
 
One of the primary aims of the CARES Act and subsequent related legislation 
was to mitigate the economic ramifications stemming from the COVID-19 
pandemic. In this context, the satisfaction reported by surveyed claimants 
                                            
13 Potentially fraudulent claims are based on data analytics and have not been investigated, 
adjudicated, or confirmed as fraud by a SWA. Flagged transactions may not be fraudulent, and 
not all fraudulent transactions may be flagged. More generally, these types of potential fraud 
measures can be used to identify transactions that may be indicative of potential fraud. They 
cannot, though, be interpreted directly as measures of the extent of UI fraud in any specific 
geographic area. 
14 Fraud indicators were created by the OIG to flag potential incidents of fraud. Multistate 
claimants applied for benefits in multiple states. Claimants with suspicious emails used the same 
email for multiple applications, used a temporary email address, or an email address with a 
common fraud technique. Also flagged were claimants with Social Security numbers of a person 
that was deceased. Additionally, SWAs identified certain claimants as potentially fraudulent. 

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regarding the CARES Act UI programs was high, both in terms of the overall 
experience and specific program components, such as the claims process, 
benefit amount, and benefit duration. These claimants consistently expressed 
that the programs were impactful, sufficient, and characterized by fairness. 
Nevertheless, it is important to acknowledge that these individuals still 
encountered difficulties in navigating the labor market, underscoring the lingering 
challenges that persist in the face of economic recovery. 
 
This evaluation was intended to identify the federal pandemic funds distributed to 
local communities to help them respond to the pandemic, assess benefit 
recipients’ experiences, and recognize issues with integrity of the 
pandemic-related UI programs. As such, we do not provide any 
recommendations. 
 
We appreciate the cooperation of ETA, state, local, and reservation officials 
involved in this evaluation. If you have any questions regarding this 
memorandum, please contact Betty Norwood, Audit Director, at 
norwood.betty@oig.dol.gov. 
 
 
cc:  
Lenita Jacobs‐Simmons, Deputy Assistant Secretary for ETA 
Laura Watson, Deputy Assistant Secretary for ETA 
Jim Garner, Administrator, Office of Unemployment Insurance 
Suzanne Simonetta, Chief, Division of Performance Management, Office 
of Unemployment Insurance 
Randall Denison, Oversight and Communications Coordinator, Office of 
Unemployment Insurance 
Thomas Kodiak, Administrator, Office of Grants Management  
Subri Raman, Deputy Administrator, Office of Grants Management 
Greg Hitchcock, Special Assistant, Office of Grants Management 
Chantel Sollers, Senior ETA OIG Liaison, Office of Grants Management

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