Audit Report — ETA Did Not Ensure States Sufficiently Implemented the Mixed Earners Unemployment Compensation Program

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_____________________________ 
REPORT TO THE 
EMPLOYMENT AND TRAINING 
ADMINISTRATION 
ETA DID NOT ENSURE STATES 
SUFFICIENTLY IMPLEMENTED THE 
MIXED EARNERS UNEMPLOYMENT 
COMPENSATION PROGRAM 
This report was prepared by Regis & Associates, 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 11, 2024 
REPORT NUMBER: 19-24-005-03-315 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
BRIEFLY… 
ETA DID NOT ENSURE STATES 
SUFFICIENTLY IMPLEMENTED THE 
MIXED EARNERS UNEMPLOYMENT 
COMPENSATION PROGRAM 
WHY WE DID THE AUDIT 
The Continued Assistance for 
Unemployed Workers Act of 2020 
created the Mixed Earners 
Unemployment Compensation (MEUC) 
program. The program provided an 
additional, supplemental weekly benefit 
payment to individuals covered by an 
unemployment insurance (UI) program 
other than the Pandemic 
Unemployment Assistance program 
and who had significant 
self-employment income. The 
Department of Labor’s Employment 
and Training Administration (ETA) was 
required to oversee the state workforce 
agencies’ (SWA) implementation of the 
MEUC program. 
Based on prior Office of Inspector 
General (OIG) pandemic audits, we 
were concerned about ETA’s ability to 
deploy the $1.5 billion provided to the 
MEUC program. We contracted with 
the independent certified public 
accounting firm of Regis & Associates, 
PC (Regis) to conduct a performance 
audit to answer the following question: 
Did ETA ensure SWAs 
implemented the MEUC program 
for the benefit of eligible 
unemployed individuals, pursuant 
to the intent of the Continued 
Assistance for Unemployed 
Workers Act of 2020 and the 
American Rescue Plan Act 
of 2021? 
For this audit, Regis performed in-depth testing on 6 SWAs, 
surveyed an additional 24 SWAs, reviewed policies and 
procedures, and interviewed ETA and SWA officials. 
WHAT WE FOUND 
Regis determined the six SWAs reviewed generally met the MEUC 
program requirements and used the related funds as intended by 
pandemic-related legislation. However, Regis found ETA did not 
ensure SWAs sufficiently implemented the MEUC program. 
Specifically, MEUC benefit payments were significantly delayed, 
there was low participation in the program, and benefits did not 
reach a large population. 
For the six audited SWAs, some claimants waited as long as 
8 months after the start of the program for their first payment. The 
six SWAs took between 78 to 273 days to make their first MEUC 
payments to claimants, and 79 percent of the surveyed SWAs took 
between 63 to 378 days. Regis determined that the six SWAs paid 
only 707 claimants under MEUC, and two SWAs served only 
21 claimants each. Although the initial MEUC allotment for these 
SWAs totaled $79.3 million, as of September 6, 2021, only about 
$1.4 million had been paid to the 707 claimants. Furthermore, 
despite discontinuing their participation in the MEUC program 
in 2021, $1.3 million in MEUC funds remained available for 
drawdown in these SWA accounts, as of September 30, 2023. 
In addition, Regis noted that the funds obligated for MEUC were 
appropriated by Congress without fiscal year limitation. This 
requires ETA to set aside pandemic funds to reimburse SWAs for 
eligible MEUC claims years after the conclusion of the program. 
The lack of time for ETA to develop and administer a new benefit 
payment program for mixed earners, as well as competing priorities, 
resulted in the delayed payments and the underutilization of funds 
for the six audited SWAs. The SWAs also experienced a lack of 
lead time for preparation, an inadequate number of staff, IT 
constraints, and a lack of information on mixed earners. If these 
challenges are left unresolved, ETA and SWAs may again struggle 
to provide timely and useful assistance to this population during 
future emergencies. 
WHAT WE RECOMMENDED 
Regis made four recommendations to improve ETA’s and 
Congress’ knowledge of the mixed earners population and to 
monitor SWAs’ levels of benefit payment activity to better meet the 
future needs of mixed earners. ETA agreed to take corrective 
actions for three recommendations. ETA stated it would be unable 
to address one recommendation due to current funding limitations. 
READ THE FULL REPORT 
For more information, go to: 
https://www.oig.dol.gov/public/reports/oa/2024/19-24-005-03­
315.pdf. 

U.S. Department of Labor – Office of Inspector General 
TABLE OF CONTENTS 
 
 
 
 
INSPECTOR GENERAL’S REPORT....................................................................1 
CONTRACTOR PERFORMANCE AUDIT REPORT ............................................4 
RESULTS .............................................................................................................7 
SWAs Did Not Pay Benefits Timely and MEUC Had Low 
Participation ...............................................................................................8 
Lack of Fiscal Year Limitations Hinders the Ability to Properly 
Manage MEUC Pandemic Funds.............................................................10 
OIG’S RECOMMENDATIONS............................................................................12 
Analysis of Agency’s Comments ..............................................................12 
EXHIBIT 1: MEUC BENEFITS PAID AS OF SEPTEMBER 30, 2021.................15 
EXHIBIT 2: SUMMARY OF DEOBLIGATED MEUC AMOUNTS........................16 
APPENDIX A: SCOPE AND METHODOLOGY ..................................................17 
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ...............................22 
-i-

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
U.S. Department of Labor 
Office of Inspector General 
Washington, DC 20210 
INSPECTOR GENERAL’S REPORT 
José Javier Rodríguez 
Assistant Secretary 
for Employment and Training 
U.S. Department of Labor 
200 Constitution Avenue 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 Regis & 
Associates, PC (Regis) to conduct a performance audit of the Mixed Earners 
Unemployment Compensation (MEUC) program. The Employment and Training 
Administration (ETA) was responsible for the oversight and monitoring of the 
state workforce agencies’ (SWA or state)1 implementation of the MEUC program 
and compliance with legislation. This legislation included the Continued 
Assistance for Unemployed Workers Act of 2020 and the American Rescue Plan 
Act of 2021. 
The OIG monitored Regis’ work to ensure it met professional standards and 
contractual requirements. Regis’ independent audit was conducted in 
accordance with generally accepted government auditing standards. 
Regis was responsible for the auditor’s evaluation and the conclusions 
expressed in the report, while the OIG was responsible for reviewing Regis’ 
report and supporting documentation. 
Purpose 
The OIG has previously reported2 concerns with ETA and states’ ability to deploy 
unemployment insurance (UI) benefits expeditiously and efficiently while 
ensuring integrity and adequate oversight, particularly in response to national 
emergencies and disasters. 
1 This report uses “state” or “state workforce agency” 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, the Commonwealth of Puerto Rico, and the District of Columbia, that 
administrative body is a state workforce agency. 
2 See Prior Relevant Coverage in Appendix A. 
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U.S. Department of Labor – Office of Inspector General 
The UI program is a joint federal-state program that provides temporary benefits 
to workers who become unemployed through no fault of their own. The 
Continued Assistance for Unemployed Workers Act of 20203 was designed to 
help mitigate the economic effects of the COVID-19 pandemic and provided 
$1.5 billion in funding to the MEUC program. The American Rescue Plan Act of 
2021 extended the MEUC program through September 6, 2021.4 
The MEUC program provided additional benefits to certain self-employed 
individuals, who were available for work from the week ending January 2, 2021, 
through the week ending September 6, 2021. Specifically, the program provided 
an extra $100 in benefits, per week, to self-employed individuals who had earned 
$5,000 or more in self-employment income in the previous tax year and were 
receiving certain UI benefits.5 Recipients of Pandemic Unemployment Assistance 
were not eligible to receive MEUC. 
We contracted with Regis to conduct a performance audit to answer the 
following question: 
Did ETA ensure SWAs implemented the MEUC program for the 
benefit of eligible unemployed individuals, pursuant to the intent of 
the Continued Assistance for Unemployed Workers Act of 2020 and 
the American Rescue Plan Act of 2021? 
To answer this question, the OIG judgmentally selected six SWAs based on 
ten risk factors for in-depth testing and analysis for the period of 
January 2, 2021, to September 6, 2021. These risk factors included total 
federal UI funding, improper UI payments and improper UI payment rates, UI 
claims, and UI fraud rate. The six states were: Alabama, Alaska, Arkansas, 
Indiana, New Hampshire, and Ohio. Regis developed a survey to obtain key 
information from 31 SWAs not selected for in-depth examination. Regis also 
reviewed relevant policies, procedures, and related controls and interviewed 
ETA officials. 
3 The Continued Assistance for Unemployed Workers Act of 2020 was signed into law on 
December 27, 2020. 
4 The American Rescue Plan Act of 2021 was signed into law on March 11, 2021. 
5 MEUC applied to certain individuals who were eligible to receive regular unemployment 
compensation, including Unemployment Compensation for Federal Employees, Unemployment 
Compensation for Ex-Service members, Pandemic Emergency Unemployment Compensation, 
Extended Benefits, Short-Time Compensation, Trade Readjustment Allowances, Disaster 
Unemployment Assistance, and payments under the Self-Employment Assistance program. 
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U.S. Department of Labor – Office of Inspector General 
Results 
Regis found the six SWAs generally met MEUC program requirements and used 
the related funds as intended by the Continued Assistance for Unemployed 
Workers Act of 2020 and the American Rescue Plan Act of 2021. However, 
Regis also found ETA did not ensure SWAs sufficiently implemented the MEUC 
program. Specifically, approved MEUC benefits payments to claimants from the 
six SWAs reviewed were significantly delayed, with some claimants waiting 
8 months to receive their first payment. 
Additionally, Regis noted that states had low claimant participation, and the 
benefits did not reach a large population. Initial MEUC allotments for the six 
SWAs reviewed totaled $79.3 million. By the end of the MEUC program, 
September 6, 2021, the six SWAs had paid only around $1.4 million (2 percent), 
to 707 claimants. Regis also determined that of the six SWAs, two served only 21 
claimants each. ETA reduced the initial allotment of $79.3 million based on the 
states’ actual experience with the program. As of September 2023, $1.3 million 
remained available to the SWAs for drawdown. 
Regis also noted that the funds obligated for MEUC, like most pandemic UI 
programs, were appropriated by Congress without fiscal year limitation. Because 
of this, ETA sets aside pandemic funds to reimburse SWAs for eligible MEUC 
claims, as ETA must reimburse states until all eligible claims from the program 
period have been administered, even if this requires doing so years after the 
conclusion of the program period in September 2021. Given the “without fiscal 
year limitation” congressionally-legislated parameter, ETA can potentially justify 
delaying the return of MEUC pandemic funds to Treasury ad infinitum. If the 
enacting law and subsequent agreements between DOL and the SWAs 
contained a termination date by which all claims must be administered or 
returned to the U.S. Department of the Treasury (Treasury), remaining MEUC 
pandemic funds could be returned to Treasury sooner and reprogrammed for the 
more urgent needs of the American taxpayer. 
We appreciate the cooperation and courtesies ETA extended to us and Regis 
during this audit. 
Carolyn R. Hantz 
Assistant Inspector General for Audit 
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U.S. Department of Labor – Office of Inspector General 
CONTRACTOR PERFORMANCE AUDIT REPORT 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Independent Auditor’s Performance Audit Report on the Mixed Earners 
Unemployment Compensation Program 
José Javier Rodríguez 
Assistant Secretary
  for Employment and Training 
U.S. Department of Labor 
200 Constitution Avenue NW 
Washington, DC 20210 
We were engaged by the U.S. Department of Labor (DOL) Office of Inspector 
General (OIG), to conduct a performance audit of the Mixed Earners 
Unemployment Compensation (MEUC) program. The Employment and Training 
Administration (ETA) was responsible for the oversight and monitoring of the 
state workforce agencies’ (SWA or state) implementation of the MEUC program 
and compliance with legislation. This legislation included the Continued 
Assistance for Unemployed Workers Act of 2020 (Continued Assistance Act) and 
the American Rescue Plan Act of 2021 (ARPA). 
We conducted the audit to answer the following question: 
Did ETA ensure SWAs implemented the MEUC program for the 
benefit of eligible unemployed individuals, pursuant to the intent of 
the Continued Assistance for Unemployed Workers Act of 2020 and 
the American Rescue Plan Act of 2021? 
To answer this question, we analyzed ETA and SWAs’ processes and controls to 
determine if they were accordance with the requirements of the Continued 
Assistance Act and ARPA. This included information technology (IT) and 
information systems controls utilized to implement the MEUC program. We also 
examined evidence supporting states’ compliance with legislation. 
Of the 37 SWAs that received MEUC funding, we performed in-depth testing and 
analysis on 6 states: Alabama, Alaska, Arkansas, Indiana, New Hampshire, and 
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U.S. Department of Labor – Office of Inspector General 
Ohio. For the 31 SWAs that were not selected for in-depth examination, we 
designed and submitted a survey questionnaire focused on the SWAs’ 
implementation of the MEUC program. We received responses from 24 of the 
31 surveyed states. See Appendix A for additional details on scope and 
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 the evidence obtained provides a reasonable basis for our findings 
and conclusions based on our audit objective. 
MEUC Eligibility, Benefits, and Reporting 
On December 27, 2020, the Continued Assistance Act was signed into law, 
which, in addition to amending certain provisions of the Coronavirus Aid, Relief, 
and Economic Security (CARES) Act, created the MEUC program.  
Under the Continued Assistance Act, MEUC program benefits were available 
from the week of unemployment ending January 2, 2021, to the week of 
unemployment ending March 14, 2021. ARPA, which was signed into law on 
March 11, 2021, extended the MEUC program through the week of 
unemployment ending on or before September 6, 2021. 
MEUC was intended to support mixed earners, which are workers who earn 
money through both self-employment income and traditional W-2 employment. 
MEUC provided qualifying individuals with a $100 supplemental weekly payment, 
in addition to the Federal Pandemic Unemployment Compensation program’s 
supplemental payment of $300 and claimants’ underlying unemployment 
insurance (UI) benefit payments. MEUC was an optional program, and SWAs 
had discretion as to whether to administer the program for their state. On 
January 5, 2021, ETA provided guidance to SWAs regarding the new MEUC 
program through Unemployment Insurance Program Letter No. 15-20, Change 3. 
Since this program was new, states initiated different strategies to quickly notify 
potential beneficiaries about the MEUC program and eligibility criteria. 
In order to be eligible for MEUC program benefits, individuals must have earned 
at least $5,000 in self-employment income in the most recent taxable year ending 
prior to their application for regular UI. Similar to Federal Pandemic 
Unemployment Compensation, MEUC applied to certain individuals who were 
eligible to receive regular UI, Pandemic Emergency Unemployment 
Compensation, Permanent Federal-State Extended Benefits, Short-Time 
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U.S. Department of Labor – Office of Inspector General 
Compensation, Trade Readjustment Allowances, Disaster Unemployment 
Assistance, and payments under the Self-Employment Assistance program. 
Individuals receiving Pandemic Unemployment Assistance6 were not eligible to 
receive MEUC. 
In accordance with ETA guidance, SWAs were required to report to ETA the 
number and amounts of claims paid, monthly and quarterly, for as long as they 
were paying MEUC benefits,7 using the following forms: 
x ETA 902M Mixed Earners Unemployment Compensation Activities 
reports identified MEUC claims, payment, and appeals activity. This 
report also calculated the ongoing administrative funding for this 
program based on the reported initial claims and appeals 
dispositions workloads. The ETA 902M report was due on the 30th 
of the month following the month to which the data related. 
x ETA 227 Overpayment Detection and Recovery Activities reports 
provided data regarding the establishment of MEUC overpayments 
and recoveries. The ETA 227 report was due quarterly on the first 
day of the second month after the quarter of reference. 
x ETA 2112 UI Financial Transaction Summary reports identified 
financial transactions data that included the amount of MEUC funds 
transferred from the federal general fund account to the state 
benefit payment account and the net amount of MEUC paid. The 
ETA 2112 report was due on the first day of the second month 
following the month of reference. 
MEUC funding was provided to SWAs through the Automated Standard 
Application for Payments System, which was operated jointly by the U.S. 
Department of the Treasury’s (Treasury) Bureau of Fiscal Service and the 
Federal Reserve Bank of Richmond. ETA used the Automated Standard 
Application for Payments System to transfer funds quickly and securely to SWAs, 
from which they could draw funding from pre-authorized accounts.  
6 Pandemic Unemployment Assistance refers to a program that temporarily expanded UI eligibility 
to people who wouldn't otherwise qualify to receive traditional unemployment benefits. This 
included self-employed workers, gig workers, freelancers, independent contractors, and part-time 
workers impacted by the coronavirus pandemic. Additional pandemic relief legislation allowed 
these benefits to last for up to 79 weeks. 
7 Unemployment Insurance Program Letter No. 15-20, Change 3, Attachment III, Continued 
Assistance for Unemployed Workers (Continued Assistance) Act of 2020 — Federal Pandemic 
Unemployment Compensation (FPUC) Program Reauthorization and Modification and Mixed 
Earners Unemployment Compensation (MEUC) Program Operating, Reporting, and Financial 
Instructions, issued January 5, 2021. 
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U.S. Department of Labor – Office of Inspector General 
ETA is responsible for ensuring states have access to a reasonable amount of 
MEUC funding to ensure all eligible program benefits are paid. According to ETA 
officials, the ultimate payment of benefits under MEUC may be delayed for many 
years beyond the program’s expiration due to benefit appeal decisions, among 
other reasons. 
RESULTS 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We found the six SWAs reviewed (Alabama, Alaska, Arkansas, Indiana, New 
Hampshire, and Ohio) generally met the MEUC program requirements and used 
the related funds as intended by the Continued Assistance Act and ARPA. The 
six states appropriately verified the eligibility of claimants before disbursing 
MEUC funds, verified the amount of the claimant’s benefit payments, and 
submitted all required reports to ETA, in compliance with the program terms and 
conditions. 
However, ETA did not ensure SWAs sufficiently implemented the MEUC program. 
Specifically, we identified approved MEUC benefit payments were significantly 
delayed, with some claimants waiting 8 months to receive their first MEUC 
payment. Furthermore, the six states we reviewed had low claimant participation, 
and the benefits did not reach a large population.8 
In addition, Regis noted that the funds obligated for MEUC, like most pandemic 
UI programs, were appropriated by Congress “without fiscal year limitation.” 
Because of this, ETA continues to set aside pandemic funds to reimburse SWAs 
for eligible MEUC claims and it could potentially justify delaying the return of 
MEUC pandemic funds to Treasury ad infinitum. ETA must reimburse states until 
all eligible claims from the program period have been administered—even if this 
requires ETA to do so years after the conclusion of the program period in 
September 2021. If the enacting law and subsequent agreements between DOL 
and the SWAs contained a termination date by which all claims must be 
administered or returned to Treasury, remaining MEUC pandemic funds could be 
returned to Treasury sooner and reprogrammed for the more urgent needs of the 
American taxpayer. However, given the “without fiscal year limitation” 
congressionally-legislated parameter, ETA can potentially justify delaying the 
return of MEUC pandemic funds to Treasury ad infinitum. 
8 The cause of the low participation for this temporary program is unknown, and 
Recommendations 1 and 2 serve to address the low claimant participation issue in future UI 
programs. 
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U.S. Department of Labor – Office of Inspector General 
SWAs Did Not Pay Benefits Timely and 
MEUC Had Low Participation 
MEUC benefits were not paid in a timely manner. Specifically, it took the six 
SWAs 78 to 273 days to make their first MEUC payments to claimants (see 
Exhibit 1). This lack of timeliness resulted in claimants waiting for benefits 
intended to provide prompt relief from the effects of the COVID-19 pandemic. For 
example, one state took 266 days to issue its first payment. This state reported 
that delays in implementing a new automated system needed for issuing MEUC 
payments resulted in untimely benefit payments. In this particular state, paper 
applications were accepted; however, actual benefit payments were delayed until 
the implementation of the new automated system was complete. 
We identified similar results with the 24 SWAs that responded to our survey. 
Specifically, it took 79 percent of the SWAs 63 to 378 days to issue their first 
MEUC benefit payment. One surveyed SWA informed us that it had not reported 
any MEUC activity because it had not reprogrammed its computer to generate 
the reports. According to this state, it planned to correct its activity reports after 
the last benefits were paid.  
Furthermore, although ETA established UI Performance Core Measures and 
metrics for first payment promptness for regular UI benefits, it did not set prompt 
payment goals for the MEUC program. For regular UI, ETA’s goal is that all 
SWAs pay 87 percent of first payments within 14 to 21 days. SWAs with no 
waiting period should issue the first regular UI benefit payment within 14 days. 
SWAs with a 1-week waiting period should issue the first regular UI benefit 
payment within 21 days. The MEUC program did not have similar performance 
metrics. 
We also found the MEUC program had low participation. Specifically, we 
determined the six SWAs paid only 707 claimants under MEUC, with two serving 
only 21 claimants each. As of September 6, 2021, the end of the MEUC program, 
only around $1.4 million had been paid to the 707 claimants (see Exhibit 1). 
Initial MEUC allotments for the six states reviewed totaled $79.3 million. 
However, ETA indicated that it reduced the level of funding allotted to the states 
based on the states’ actual experience with the program. As of September 2023, 
$1.3 million remained available for drawdown within the six SWAs’ Automated 
Standard Application for Payments accounts—24 months after the program 
ended on September 6, 2021. Without the proper review and estimate of funds 
needed by SWAs, excess funds could be made available to SWAs that no longer 
need the funds (see Exhibit 2). 
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U.S. Department of Labor – Office of Inspector General 
Ultimately, we found the six SWAs discontinued their participation in the MEUC 
program in June and July 2021, instead of accepting MEUC claims through the 
program’s end date of September 6, 2021. SWAs states cited the need for 
workers to return to work as their main reason for terminating the program early. 
Of the 24 survey respondents, 42 percent reported they ended the program early 
as a result of increasing vaccination rates, improving economies, and the need 
for workers to return to work. 
Multiple Obstacles Caused Low Participation and 
Untimely Payments of MEUC Benefits 
We found SWAs needed more time to develop and effectively administer a new 
benefit payment program for mixed earners. In addition, competing priorities and 
the simultaneous implementation of multiple CARES Act programs were 
obstacles in efficiently implementing the MEUC program. This resulted in delayed 
MEUC payments and the underutilization of MEUC funds. 
MEUC was a new program created by the enactment of the Continued 
Assistance Act. As the enactment approached, states were navigating the 
potential expiration of other pandemic programs on December 26, 2020, such as 
Pandemic Unemployment Assistance, Federal Pandemic Unemployment 
Compensation, and Pandemic Emergency Unemployment Compensation. After 
enactment, states had to adapt to the subsequent extension and substantial 
modifications of these pandemic programs, for example, new documentation 
requirements, new identity verification requirements, and a new tiered phase-out 
period. This effort was intended to avoid, where possible, cutting off millions of 
eligible individuals who had been receiving these pandemic benefits. 
MEUC was created as a supplemental program, which was offered to only a 
subset of individuals receiving benefits under other programs, in addition to the 
Federal Pandemic Unemployment Compensation supplemental payments. Many 
states gave priority to implementing the extension and modification of these other 
programs, which impacted significantly larger populations of workers. 
In addition, while mixed earners were eligible for the new, temporary MEUC 
benefits when the law was passed, SWAs had little lead time to: 
x determine how to implement the program; 
x reprogram computers to issue, administer, and report MEUC 
benefits; 
x prepare materials to explain how potential mixed earners could 
apply for benefits; and 
x determine which applicants were eligible to receive MEUC benefits. 
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U.S. Department of Labor – Office of Inspector General 
According to ETA, it normally takes 2 to 4 years to implement a new government 
benefit program. Therefore, the MEUC program implementation, which took less 
than one year, was much faster by comparison. Additionally, SWAs indicated 
they had no experience in administering a program for mixed earners. They also 
cited competing priorities as a result of simultaneously implementing multiple 
CARES Act programs that had varying requirements. Most SWAs noted they did 
not have adequate staff to administer the MEUC program, and some also said 
their antiquated systems were not able to be easily configured to the new MEUC 
program requirements. 
Prior to the MEUC program being enacted, there was little information available 
on mixed earners in the United States. ETA, similarly, noted that data on mixed 
earners was extremely limited and based its estimate for MEUC program funding 
on internally developed data. Without updated and accurate information on the 
mixed earner population, ETA may struggle to provide timely and useful 
assistance to this population during future emergencies. These factors, along 
with the challenges that SWAs faced in quickly implementing a new benefit 
program with limited staff and competing priorities, made it difficult for SWAs to 
meet the requirements to identify and notify the mixed earner population of 
program eligibility. 
Lack of Fiscal Year Limitations Hinders the 
Ability to Properly Manage MEUC Pandemic 
Funds 
Under the enacting law and agreements between DOL and the SWAs, SWAs are 
entitled to the reimbursement of 100 percent9 of the cost of eligible benefits paid 
under the MEUC program. Funds for this program, like most pandemic UI 
programs, were appropriated by Congress without fiscal year limitation.10 
Because of this, ETA continues to set aside pandemic funds to reimburse SWAs 
for eligible MEUC claims. ETA must reimburse states until all eligible claims from 
the program period have been administered—even if this requires ETA to do so 
years after the conclusion of the program period in September 2021. 
9 Public Law 116-136—MAR. 27, 2020, Title II Assistance for American Workers, Families and 
Business, Subtitle A – Unemployment Insurance, Section 2104(d)(1)(A), Payments to States, as 
amended by Public Law 116-260 Dec. 27, 2020, Title II Assistance to Individuals, Families, and 
Businesses, Subtitle A – Unemployment Insurance, Section 261 Mixed Earner Unemployment 
Compensation 
10 Public Law 116-136—MAR. 27, 2020, Title II Assistance for American Workers, Families and 
Business, Subtitle A – Unemployment Insurance, Section 2104(d)(3) Appropriation 
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If the enacting law and subsequent agreements between DOL and the SWAs 
contained a termination date by which all claims must be administered or 
returned to Treasury, remaining MEUC pandemic funds could be returned to 
Treasury sooner and reprogrammed for the more urgent needs of the American 
taxpayer. The pandemic assistance funds, such as MEUC, were authorized to 
quickly meet the urgent financial needs of American taxpayers during the 
pandemic crisis. However, paying pandemic-related claims, long after the 
pandemic has ended and the U.S. economy has recovered, is counterproductive 
to the original intent of the funds—even if claimants are eligible under the 
program period. 
ETA has already begun reaching out to SWAs to identify unused pandemic funds 
and return them to Treasury. For example, in response to a prior OIG report,11 on 
January 19, 2024, ETA issued Unemployment Insurance Program Letter 
No. 20-20, Change 1, which provided states with instructions for reconciling 
funding, under Section 2105 of the CARES Act, as amended, for the Temporary 
Full Federal Funding of the First Week of Compensable Regular Unemployment 
for States with No Waiting Week (TFFF) program. These instructions required 
SWAs to reconcile its TFFF accounts, submit any necessary requests for 
reimbursement, and identify any unused funds to be returned to Treasury by the 
end of Fiscal Year 2024. 
During our audit, we inquired if SWAs could treat the MEUC program similarly to 
the TFFF program and identify any unused funds that could be returned to 
Treasury. ETA officials stated that, unlike with the reimbursement of TFFF benefit 
payments, ETA may allot or de-allot funding as necessary based on states’ 
continuing needs, as retroactive payments continue to be made for MEUC using 
a separate federal account that states could not access in the same manner they 
can access TFFF funds through their State Unemployment Trust Funds. 
Accordingly, DOL has more direct control over the amounts disbursed to states 
for MEUC benefits because the states cannot unilaterally access MEUC funds 
the way they could with funds to pay TFFF claims. 
According to ETA officials, retroactive payments are common in the UI program, 
especially in temporary federal emergency programs, such as MEUC. In addition, 
ETA officials stated that, in the authorizing language and agreements between 
DOL and the SWAs, SWAs are entitled to the reimbursement of 100 percent of 
the cost of benefits paid under the MEUC program without time limitations on the 
payment of eligible claims. Benefits are being distributed from the MEUC account 
to allow states to pay out any remaining backlogged MEUC claims. However, this 
11 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, Report No. 19-23-015-03­
315 (September 28, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-015-03-315.pdf 
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U.S. Department of Labor – Office of Inspector General 
does not preclude ETA from identifying the minimal amount of MEUC funds 
required to meet benefit payment needs for any remaining eligible claims. 
Therefore, ETA could identify excess funds to be returned to Treasury and 
reprogrammed to support other critical needs. 
OIG’S RECOMMENDATIONS 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We recommend the Assistant Secretary for Employment and Training: 
1. Perform an assessment on mixed earners, including a cost-benefit 
analysis of the Mixed Earners Unemployment Compensation program, to 
aid future decision-making regarding this segment of the work population 
and advise Congress based on lessons learned.  
2. Collaborate with the Bureau of Labor Statistics to track and report data 
specific to mixed earners in the U.S. economy to allow for the provision of 
timely and useful assistance to the mixed earner population during future 
emergencies. 
3. Monitor the state workforce agencies’ levels of benefit payment activity 
and establish timeframes to reduce the remaining allotment to the 
sufficiently minimal amount required to meet future benefit payment needs 
and ensure the remaining Mixed Earners Unemployment Compensation 
funds are expended appropriately or returned to Treasury. 
4. Perform an assessment of previous emergency unemployment insurance 
(UI) programs and the pandemic-related UI programs to determine an 
appropriate historically-based time limit for states’ acceptance of 
emergency program benefit claims after the expiration of the UI programs’ 
eligibility periods and consider making a legislative proposal to Congress 
to use the determined the time limit on future emergency programs. 
Analysis of Agency’s Comments 
In response to a draft of this report, ETA generally or partially agreed with three 
of the four recommendations to improve ETA’s and Congress’ knowledge of the 
mixed earners population and to monitor SWAs’ levels of benefit payment activity 
to better meet the future needs of mixed earners. ETA did not agree with 
Recommendation 2. The OIG and Regis reviewed the response; however, the 
agency’s concerns did not result in any changes to the report. Synopses of ETA’s 
comments and our corresponding responses are detailed as follows: 
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U.S. Department of Labor – Office of Inspector General 
x ETA partially agreed with Recommendation 1 and stated that it would 
conduct a similar study on the costs, benefits, and risks of various options 
to systematically support self-employed and contingent workers during 
periods of involuntary unemployment outside of declared disasters, 
including considering feasible and effective approaches to fraud 
prevention. This study was recommended by the Government 
Accountability Office, and ETA has set aside funds to pursue this study. 
o The OIG agrees with ETA that the completion of the study 
recommended by the Government Accountability Office will address 
Recommendation 1. 
x ETA did not agree with Recommendation 2 and stated that, with recent 
reductions in funding to support research and evaluations in the UI 
program, it is not in a position to commit to this recommendation in the 
near term. 
o The OIG understands that agency funding reductions can affect the 
undertaking of discretionary projects. However, as Regis reported and 
ETA agreed, prior to the pandemic, there was little information about 
mixed earners in the United States. As such, working with the Bureau of 
Labor Statistics would provide crucial data on the mixed earner 
population to better inform ETA and Congress in the event of future 
economic crises. In developing future budget requests, ETA should 
consider requesting additional funds to collaborate with the Bureau of 
Labor Statistics on UI data collection and analysis to better inform ETA 
on all types of UI program participants. 
x ETA agreed with Recommendation 3 and stated that it already reviews 
monthly state MEUC drawdown activity by reviewing account records in 
the U.S. Department of the Treasury’s Automated Standard Application for 
Payments. 
x ETA partially agreed with Recommendation 4 and stated, “the draft report 
seems to advocate for a finite limitation on the life of funds for any similar 
future program. This recommendation is more appropriate for Congress, 
whose members are the policymakers responsible for setting any such 
time limits.” 
o The OIG agrees with ETA that Congress is responsible for setting such 
time limits; however, the OIG continues to be concerned that, without a 
finite limitation on the life of funds for any similar future programs, 
pandemic-related claims could continue to be paid—long after the 
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U.S. Department of Labor – Office of Inspector General 
pandemic has ended, and the U.S. economy has recovered. This, as 
Regis stated in the report, is counterproductive to the original intent of 
the funds to quickly meet the urgent financial needs of American 
taxpayers during the pandemic crisis. ETA has various annual reporting 
mechanisms through which it can express its concern to Congress 
regarding the importance of setting an appropriate finite time limitation 
for states’ acceptance of emergency program benefit claims after the 
expiration of the UI programs’ eligibility periods. 
The OIG looks forward to working with ETA personnel to ensure the intent of the 
recommendations is addressed. The agency’s response to the draft report is 
included in its entirety in Appendix B. We appreciate the cooperation and 
courtesies ETA extended us during this audit. 
Regis & Associates, PC 
Washington, DC 
September 11, 2024 
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U.S. Department of Labor – Office of Inspector General 
EXHIBIT 1: MEUC BENEFITS PAID AS OF SEPTEMBER 30, 2021 
  
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 1: Summary of MEUC Key Dates, Claimants, and Funds Activities
as of September 30, 2021 
State 
Workforce 
Agency 
Agreement
Execution 
Date 
(A) 
Termination 
Date 
(B) 
First 
Payment
Date 
(C) 
Days
Elapsed
(D=C-A) 
Number 
of 
Claimants 
Funds Paid 
to Claimants 
as of 
9/30/2021 
Alabama 
12/31/2020 
06/19/2021 
03/19/21 
78 
279 
$591,700 
Arkansas 
New 
Hampshire 
Indiana 
12/31/2020 
12/31/2020 
12/29/2020 
06/26/2021 
06/19/2021 
07/19/2021 
03/30/21 
04/05/21 
06/07/21 
89 
95 
160 
21 
67 
319 
$32,490 
$96,150 
$677,300 
Alaska 
12/30/2020 
06/19/2021 
06/08/21 
160 
21 
$29,100 
Ohio12 
01/01/2021 
06/26/2021 
-
-
-
$0 
Total 
707 
$1,426,740 
Source: Compiled using data provided by the reviewed SWAs and SWA statements from the 
Automated Standard Application for Payments. 
12 Ohio did not make any claimant payments as of September 30, 2021. The Ohio SWA made the 
first payment on October 1, 2021, which was 273 days after it signed the MEUC agreement with 
DOL. 
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U.S. Department of Labor – Office of Inspector General 
EXHIBIT 2: SUMMARY OF DEOBLIGATED MEUC AMOUNTS  
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2: Summary of MEUC Funding Activity as of September 30, 2023 
State 
Workforce 
Agency 
Funds 
Provided by
DOL 
Claimant 
Payments 
Funds 
Deobligated
by ETA 
Remaining Balance 
after MEUC 
Program Ended 
Alabama 
$6,800,000 
$700,150 
$5,877,400 
$222,450 
Arkansas
 $4,900,000 
$36,200 
$4,614,350 
$249,450 
New Hampshire 
$4,500,000 
$98,600 
$4,151,400 
$250,000 
Indiana 
$20,100,000 
$1,233,983 
$18,635,311 
$230,706 
Alaska 
$4,300,000 
$32,000 
$4,168,000 
$100,000 
Ohio 
$38,700,000 
$1,016,086 
$37,444,124 
$239,790 
Total 
$79,300,000 
$3,117,019 
$74,890,585 
$1,292,396 
Source: Data provided by SWAs, MEUC grant agreements with SWAs, and Automated Standard 
Application for Payments Account information for each SWA. 
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U.S. Department of Labor – Office of Inspector General 
APPENDIX A: SCOPE AND METHODOLOGY 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Scope 
The audit covered how ETA ensured SWAs sufficiently implemented the MEUC 
program, under the Continued Assistance Act and ARPA, for the period of 
January 2, 2021, to September 6, 2021. There were six SWAs selected by DOL 
OIG for in-depth examination using a risk-based approach. The six SWAs 
consisted of Alabama, Alaska, Arkansas, Indiana, New Hampshire, and Ohio. 
In addition to the six selected states, we sent survey questionnaires to the 
remaining 31 SWAs that received MEUC funding to obtain key information on 
how the SWAs implemented the MEUC program. Only 24 SWAs responded to 
the survey. 
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 objectives. 
In planning and performing the audit, we obtained an understanding of ETA’s and 
SWAs’ internal controls that were considered significant to the audit objective. 
We obtained an understanding of the internal controls to help design audit 
procedures relevant to the audit objective and not to provide assurance on the 
internal controls. We, therefore, did not express an opinion on DOL’s or SWAs’ 
internal controls. Our consideration of internal controls for implementing the 
MEUC program would not necessarily disclose all matters that might be 
significant deficiencies. 
Our approach for this performance audit was a risk-based methodology. This 
approach ensured that we deployed resources to the most vulnerable areas of 
waste, fraud, and abuse, while minimizing any redundant efforts. 
We obtained and documented an understanding of ETA’s and the reviewed 
SWAs’ relevant policies, procedures, and related controls, including identifying 
risks related to: 
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U.S. Department of Labor – Office of Inspector General 
x the nature of operations; 
x structure, oversight, and governance; 
x activities and external environment, including the regulatory, 
economic, political, and social environment; 
x specific risks related to the implementation of the MEUC program; 
x root causes resulting in improper benefit payments (i.e. fraudulent 
payments, overpayments, and the inability for the SWAs to validate 
initial and ongoing program eligibility requirements); and 
x other challenges (i.e. program fraud, fraud vulnerabilities, IT 
systems, staffing, and monitoring). 
We used sampling in this audit. However, we tested all the claimants for Alaska 
and Arkansas as these states only had 21 claimants each. Additionally, if general 
IT and information systems controls were determined to be significant to meet 
the objective of our audit, we obtained a sufficient understanding of the 
information systems controls necessary to assess audit risk and plan our audit 
procedures within the context of the audit objectives. 
Selection of States 
The OIG judgmentally13 selected the six states for an in-depth review based on 
10 risk factors. These risk factors included total federal UI funding, improper UI 
payments and improper UI payment rates, UI claims, and UI fraud rate. The 
states selected must have signed MEUC agreements under Section 2104(b) of 
the CARES Act with ETA. In selecting the states, the OIG also considered 
whether a state had been selected in previous OIG audits focusing on 
unemployment insurance programs. We conducted an in-depth examination of 
the six states selected by the OIG. In addition, we sent surveys to 31 states that 
had signed MEUC agreements with ETA under Section 2104(b) of the CARES 
Act—24 states responded to the surveys. 
Data Reliability 
We conducted tests to determine the reliability of MEUC benefit payments as 
well as the additional administrative costs for MEUC implementation, which was 
13 Judgmental sampling is a non-probability sampling technique in which the sample members 
are chosen based on the auditor’s knowledge and judgment. 
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U.S. Department of Labor – Office of Inspector General 
provided to us to review. To assess the reliability of the data, we performed 
procedures to test for completeness, accuracy, consistency, and validity by 
performing the following: 
x For MEUC benefit payments, we compared claimant payment data 
provided (by state) via the ETA 2112 reports. The ETA 2112 report 
is a monthly report of information on Unemployment Trust Fund 
financial transactions. We further corroborated the benefit 
payments amounts to reports generated from payments recorded in 
Treasury’s Automated Standard Application for Payments. 
x For the additional administrative costs for MEUC implementation, 
we agreed the funds made available to the specific state grant 
agreements and the Application for Federal Assistance form 
SF-424. We corroborated the expenditures to detailed general 
ledger reports and back-up documentation as well as the state 
ETA 9178-P Quarterly Narrative Progress Report Form. 
Sampling 
To verify compliance with the Continued Assistance Act and ARPA, we applied 
judgmental sampling on four SWAs’ claimant payments. However, we tested all 
the claimants for Alaska and Arkansas as these states only had 21 claimants 
each. We used an approach prescribed in Government Auditing Standards to 
judgmentally select a sample from benefit payments and reports submitted to 
ETA to test controls and compliance with rules and regulations. 
To assess compliance with the CARES Act, we verified: 
x the selected SWAs appropriately determined eligibility of claimants, 
x the selected SWAs appropriately approved the claimants’ benefit 
payments, and 
x whether the selected SWAs submitted the required reports to ETA. 
Criteria 
x Continued Assistance for Unemployed Workers Act of 2020, Subchapter 
VI, Section 261, Mixed Earner Unemployment Compensation 
(December 27, 2020) 
x Coronavirus Aid, Relief, and Economic Security Act, Public Law 116-136 
(March 27, 2020) 
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U.S. Department of Labor – Office of Inspector General 
x Unemployment Insurance Program Letter No. 15-20, Change 3 Continued 
Assistance for Unemployed Workers (Continued Assistance) Act of 2020 
— Federal Pandemic Unemployment Compensation (FPUC) Program 
Reauthorization and Modification and Mixed Earners Unemployment 
Compensation (MEUC) Program Operating, Reporting, and Financial 
Instructions (January 5, 2021) 
x Unemployment Insurance Program Letter No. 15-20, Change 4, American 
Rescue Plan Act of 2021 (ARPA) — Extensions to the Federal Pandemic 
Unemployment Compensation (FPUC) Program and Mixed Earners 
Unemployment Compensation (MEUC) Program 
x Unemployment Insurance Program Letter No. 9-21, Continued Assistance 
for Unemployed Workers Act of 2020 (Continued Assistance Act) – 
Summary of Key Unemployment Insurance (UI) Provisions 
(December 30, 2020) 
x Unemployment Insurance Program Letter No. 14-21, Change 1, State 
Responsibilities After the Temporary Unemployment Benefit Programs 
under the Coronavirus Aid, Relief, and Economic Security (CARES) Act 
as amended, End Due to State Termination of Administration or When the 
Programs Expire (July 12, 2021) 
Prior Relevant Coverage 
During the last 3 years, the OIG has issued eight reports of significant relevance 
to the subject of this report. Those reports are the following: 
1. 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, Report No. 19-23-015-03-315 
(September 28, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-015-03-315.pdf; 
2. COVID-19: Pandemic Unemployment Assistance for Non-Traditional 
Claimants Weakened by Billions in Overpayments, Including Fraud, 
Report No. 19-23-014-03-315 (September 27, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-014-03-315.pdf; 
3. COVID-19 – Audit of State Workforce Agencies’ Information Technology 
Systems Capability in Processing Unemployment Insurance Claims, 
Report No. 19-23-008-03-315 (September 19, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-008-03-315.pdf; 
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U.S. Department of Labor – Office of Inspector General 
4. COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds 
from Improper Payments Including Fraud or from Payment Delays, 
Report No. 19-22-006-03-315 (September 30, 2022), available at: 
https://www.oig.dol.gov/public/reports/oa/2022/19-22-006-03-315.pdf; 
5. 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; 
6. 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; 
7. Alert Memorandum: The Pandemic Unemployment Assistance Program 
Needs Proactive Measures to Detect and Prevent Improper Payments and 
Fraud, Report No. 19-20-002-03-315 (May 26, 2020), available at: 
https://www.oig.dol.gov/public/reports/oa/2020/19-20-002-03-315.pdf; and 
8. 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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U.S. Department of Labor – Office of Inspector General 
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT 
  
 
  
 
 
 
 
 
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U.S. Department of Labor – Office of Inspector General 
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U.S. Department of Labor – Office of Inspector General 
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REPORT FRAUD, WASTE, OR ABUSE  
TO THE DEPARTMENT OF LABOR 
Online 
https://www.oig.dol.gov/hotline.htm 
Telephone
(800) 347-3756 or (202) 693-6999 
Fax 
(202) 693-7020 
Address 
Office of Inspector General 
U.S. Department of Labor 
200 Constitution Avenue NW 
Room S-5506 
Washington, DC 20210

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