Performance Audit Report: COVID-19 — ETA Needs to Improve Its Oversight of States' Efforts to Identify Multistate UI Fraud (DOL OIG, August 2025)

Summary

A Department of Labor Office of Inspector General performance audit report, No. 19-25-004-03-315, issued August 4, 2025 and prepared by Regis & Associates, PC under contract, titled COVID-19: ETA Needs to Improve Its Oversight of States' Efforts to Identify Multistate UI Fraud. It is the first of four audits in the series on high-risk areas for potential UI fraud. Regis found that 7 of the 10 state workforce agencies tested confirmed some multistate claimants filed fraudulent claims, and that ETA took limited oversight action. Of 181 multistate claimants tested, $1.6 million in benefits was paid and states confirmed $404,288 as fraudulent, 25 percent of the benefits paid to them. The report makes recommendations to ETA, which generally agreed.

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Full text

REPORT TO THE 
EMPLOYMENT AND TRAINING 
ADMINISTRATION  
 
 
 
 
 
 
 
 
 
COVID-19: ETA NEEDS TO IMPROVE ITS 
OVERSIGHT OF STATES’ EFFORTS TO 
IDENTIFY MULTISTATE UI FRAUD 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DATE ISSUED: AUGUST 4, 2025 
REPORT NUMBER: 19-25-004-03-315 
This report was prepared by Regis & Associates, PC (Regis) 
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 
AUDIT SERIES: HIGH-RISK AREAS FOR POTENTIAL 
UI FRAUD, AUDIT ONE OF FOUR 

 
 
BRIEFLY… 
 
COVID-19: ETA NEEDS TO IMPROVE 
ITS OVERSIGHT OF STATES’ 
EFFORTS TO IDENTIFY 
MULTISTATE UI FRAUD 
 
Why We Did the Audit 
 
As of September 2022, the OIG had 
reported a cumulative $45.6 billion paid 
in four high-risk areas of unemployment 
insurance (UI) fraud the OIG had 
identified; multistate claimants—
$29 billion—was the largest area. The 
OIG shared its data and methodology 
for identifying those claimants with the 
Employment and Training 
Administration (ETA). ETA is 
responsible for providing states with UI 
program direction and oversight; the 
states are responsible for ensuring UI 
payments go only to eligible claimants 
and for making determinations of fraud.  
 
Based on the OIG’s concerns regarding 
UI benefits paid in each of the high-risk 
areas, the OIG began a series of four 
audits; this is the first in the series. 
Specifically, for multistate claimants, we 
contracted with Regis & Associates, PC 
(Regis) to answer the following 
question:  
 
To what extent have ETA and state 
workforce agencies (SWA) 
addressed potentially fraudulent 
CARES Act UI claims filed by 
multistate claimants? 
 
Read the Full Report 
For more information, go to: 
https://www.oig.dol.gov/public/reports/o
a/2025/19-25-004-03-315.pdf. 
 
 
What We Found 
 
Regis found 7 of the 10 SWAs selected for testing confirmed some 
multistate claimants filed fraudulent UI claims. However, ETA took 
limited action to ensure states properly addressed the potentially 
fraudulent UI claims filed by multistate claimants. While ETA 
transmitted claimant data associated with potentially fraudulent UI 
claims to the 53 SWAs and Guam, including instructions and 
requirements on investigations and due process, ETA did not 
perform the following oversight actions: 
 
• monitor nor require states to report the results of research or 
investigations of potentially fraudulent UI claims, which would 
have assisted ETA in identifying high-risk areas for UI fraud;  
• ensure the National Association of State Workforce Agencies’ 
Integrity Data Hub (IDH) effectively provided states with useful 
information to assist in identifying UI fraud; or 
• ensure states consistently established and reported fraudulent 
overpayments distributed to imposter claimants or identify 
systemic weaknesses that resulted in states reporting zero 
fraudulent overpayments when UI fraud risk was at its height 
during the pandemic. 
 
These deficiencies occurred because ETA considered its oversight 
responsibilities to be limited. Specifically, ETA: (1) did not consider 
monitoring the results of states’ research and investigations as part 
of its responsibilities; (2) measured IDH effectiveness by the 
number of claims submitted to and flagged by the IDH rather than 
by the outcomes of states’ fraud investigations; and (3) did not 
detect states’ information technology systems or staffing were 
insufficient to establish or report fraudulent overpayments. 
 
Without knowledge of the states’ investigative results, ETA’s ability 
to assess UI program performance, identify high-risk areas, and 
provide states with additional tools and guidance to prevent 
fraudulent overpayments was impaired. In addition, without ETA 
establishing an outcome-based metric for IDH cross-matches, ETA 
was unable to determine the IDH’s effectiveness in assisting states 
with identifying fraud. 
 
The OIG selected 181 multistate claimants that filed potentially 
fraudulent UI claims across 10 SWAs for Regis to test. Regis 
determined $1.6 million in UI benefits were paid, and the states 
confirmed $404,288 was fraudulent. The fraudulent overpayments 
confirmed by the states represented 25 percent of the UI benefits 
paid to the claimants tested.  
 
What We Recommended 
 
Regis made three recommendations to ETA to improve its oversight 
of states’ efforts to identify fraudulent UI claims filed by multistate 
claimants. ETA generally agreed with the recommendations.  

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 ............................................ 6 
RESULTS ............................................................................................................. 7 
ETA Needs to Improve Its Oversight of States’ Efforts to Identify 
Multistate UI Fraud ..................................................................................... 8 
CONCLUSION .................................................................................................... 28 
RECOMMENDATIONS ....................................................................................... 28 
Analysis of ETA’s Comments ................................................................... 29 
EXHIBIT: TESTING RESULTS, FRAUDULENT AND NONFRAUDULENT 
PAYMENTS FOR THE 10 SWAS ....................................................................... 33 
APPENDIX A: SCOPE AND METHODOLOGY .................................................. 35 
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT. .............................. 40 

U.S. Department of Labor 
Office of Inspector General 
 
Washington, DC 20210 
 
HIGH-RISK AUDITS: UI CLAIMS FILED IN MULTIPLE STATES 
 
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NO. 19-25-004-03-315 
 
 INSPECTOR GENERAL’S REPORT 
Lori Frazier Bearden 
Acting 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 or Department) 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 
Employment and Training Administration’s (ETA) and state workforce agencies’ 
(SWA or state)1 efforts to address potentially fraudulent unemployment insurance 
(UI) claims filed by multistate claimants.2 
 
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 auditors’ evaluation and the conclusions 
expressed in the report while the OIG reviewed Regis’ report and supporting 
documentation. 
Purpose 
Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act and 
subsequent legislation,3 Congress provided expanded UI benefits to workers who 
were unable to work due to the COVID-19 pandemic. UI is a joint federal-state 
 
1 This report uses “state” or “SWA” to refer to the 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. Therefore, there are 53 SWAs. 
2 Multistate claimants include: (1) individuals who used their own Social Security numbers to file 
UI claims in multiple states and (2) victims of identity theft whose Social Security numbers were 
used by fraudsters to file UI claims in multiple states.  
3 The CARES Act expanded UI benefits through December 31, 2020. On December 27, 2020, the 
Continued Assistance for Unemployed Workers Act of 2020 extended the CARES Act 
UI programs through March 14, 2021. On March 11, 2021, the American Rescue Plan Act of 
2021 further extended the CARES Act UI programs through September 6, 2021. 

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program with each state administering a separate UI program under its own laws 
while following uniform guidelines established by federal law.  
 
According to ETA, which is responsible for providing UI program leadership, 
direction, and assistance to SWAs, as of January 2023, about $888 billion was 
paid in pandemic­related UI benefits. Additionally, from January 2021 through 
July 2022, ETA made $562.6 million available to support the 53 SWAs and 
Guam with fraud detection and prevention, including identity verification and 
overpayment recovery activities in pandemic-related UI programs.  
 
The OIG conducts independent oversight of the UI program through audits to 
strengthen the integrity and efficiency of the program and through criminal 
investigations to detect and deter large-scale fraud. Applying the Department’s 
Fiscal Year 2022 estimated improper payment rate of 21.52 percent to pandemic 
UI expenditures, the OIG estimated at least $191 billion (22 percent) of the 
$888 billion in pandemic UI benefits could have been paid improperly, with a 
significant portion attributable to fraud. 
 
As of September 2022, the OIG—aided by data analytics—had identified 
$45.6 billion in potentially fraudulent UI benefits paid in four specific high-risk 
areas, involving claims with Social Security numbers: 
 
1. filed in multiple states, 
2. of deceased persons, 
3. used to file with suspicious email accounts, and 
4. of federal prisoners.4  
 
That $45.6 billion included $29 billion to individuals who filed claims in multiple 
states (multistate claimants) between March 2020 and October 2020. ETA 
required a claimant who worked in more than one state and became unemployed 
due to COVID-19-related reasons to only file for UI benefits in one state in any 
given week of unemployment.  
 
When the OIG identifies anti-fraud measures that may help the UI program, it 
shares them with the Department and SWAs as appropriate. As of 
September 2022, the OIG had shared its claimant data and methodology on 
potential fraud in the four high-risk areas with ETA for distribution to the 53 SWAs 
and Guam. The states are responsible for ensuring UI benefits are paid only to 
eligible claimants and for making determinations of fraud. Based on our concerns 
regarding UI benefits paid in each of the four high-risk areas, we began a series 
 
4 Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments in High-Risk 
Areas Increased to $45.6 Billion, Report No. 19-22-005-03-315 (September 21, 2022), available 
at: https:///www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-315.pdf  

U.S. Department of Labor – Office of Inspector General 
 
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of four audits; this is the first in the series. Specifically, for multistate claimants, 
we contracted with Regis to answer the following question: 
 
To what extent have ETA and SWAs addressed potentially fraudulent 
CARES Act UI claims filed by multistate claimants?  
 
To answer this question, Regis reviewed the actions taken by ETA and  
SWAs—from April 7, 2021, through September 15, 2022—to address the  
OIG-identified potentially fraudulent UI claims filed by multistate claimants from 
March 2020 through October 2020. Using a risk-based approach, the OIG 
selected 181 claimants for Regis to test from the States of Alabama, California, 
Connecticut, Florida, Illinois, Iowa, New York, and Texas; the District of 
Columbia; and the U.S. Virgin Islands (10 SWAs).5 Regis also reviewed the 
10 SWAs’ policies, processes, and results of relevant actions taken. However, 
Regis did not make determinations of fraud or evaluate whether the states made 
the correct determinations. In addition, Regis surveyed the remaining 43 SWAs 
and Guam; 28 SWAs (64 percent) responded. Regis also reviewed updated 
guidance and UI payment reporting activities that extended outside of the audit 
period. See Appendix A for additional details on scope and methodology. 
Results 
Regis found 7 of the 10 SWAs (Alabama, California, Connecticut, Florida, Illinois, 
New York, and Texas) confirmed some multistate claimants filed fraudulent UI 
claims.6 However, ETA took limited action to ensure states properly addressed 
the potentially fraudulent UI claims filed by multistate claimants.  
 
ETA is responsible for providing oversight of UI fraud risk management and 
states’ management should report internal control deficiencies to ETA—
consistent with the Government Accountability Office’s Standards for Internal 
Control in the Federal Government. Specifically, the standards state the 
oversight body is responsible for overseeing the strategic direction of the entity 
and obligations related to the accountability of the entity. This includes 
 
5 The OIG selected this sample based on the highest per capita benefits paid. The OIG calculated 
per capita benefits using the number of claimants flagged for multistate claims and the benefit 
amounts paid to these claimants. The OIG then ranked the SWAs by the per capita amount, 
largest to smallest, and selected the top 10 SWAs. The OIG also controlled for repetition of SWAs 
within the four high-risk areas. Therefore, the OIG did not select the same SWAs if they appeared 
in a higher ranked risk area, resulting in the selection of 10 different SWAs for each of the four 
high-risk audits. The OIG ranked the high-risk areas from highest to lowest: multistate claimants, 
deceased persons’ Social Security numbers, suspicious email accounts, and federal prisoners’ 
Social Security numbers. 
6 The remaining three SWAs (District of Columbia, Iowa, and Virgin Islands) determined that the 
UI claims were nonfraudulent. 

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overseeing management design, implementation, and operation of an internal 
control system. Further, management should report deficiencies identified in the 
internal control system to the oversight body.  
 
ETA transmitted the OIG’s claimant data and methodology to the 53 SWAs and 
Guam in April 2021, including instructions and requirements on investigations 
and due process. However, ETA did not perform the following oversight actions: 
 
• monitor nor require states to report the results of research or 
investigations of potentially fraudulent UI claims, which would have 
assisted ETA in identifying high-risk areas for UI fraud;  
 
• ensure the National Association of State Workforce Agencies’ 
Integrity Data Hub (IDH) effectively provided states with useful 
information to assist in identifying UI fraud; or  
 
• ensure states consistently established and reported fraudulent 
overpayments distributed to imposter claimants or identify systemic 
weaknesses that resulted in states reporting zero fraudulent 
overpayments when UI fraud risk was at its height during the 
pandemic.  
 
These deficiencies occurred because ETA considered its oversight 
responsibilities to be limited. Specifically, ETA: (1) did not consider monitoring 
the results of states’ research and investigations as part of its responsibilities; 
(2) measured IDH effectiveness by the number of claims submitted to and 
flagged by the IDH rather than by the outcomes of states’ fraud investigations; 
and (3) did not detect states’ information technology systems or staffing were 
insufficient to establish or report fraudulent overpayments.  
 
Without knowledge of the states’ investigative results of potentially fraudulent UI 
claims, ETA’s ability to assess UI program performance, identify high-risk areas, 
and provide states with additional tools and guidance to prevent fraudulent 
overpayments was impaired. In addition, without ETA establishing an 
outcome-based metric for IDH cross-matches, ETA was unable to determine the 
IDH’s effectiveness in assisting states with identifying fraud.  
 
We selected 181 multistate claimants that filed potentially fraudulent UI claims 
with 10 SWAs for Regis to test. Regis determined $1.6 million in UI benefits were 
paid, and states confirmed $404,288 was fraudulent. The fraudulent 
overpayments confirmed by the states represented 25 percent of the UI benefits 
paid to the claimants tested. 
 

U.S. Department of Labor – Office of Inspector General 
 
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We appreciate the cooperation and courtesies ETA extended to us during this 
audit. 
 
 
 
Laura B. Nicolosi 
Assistant Inspector General for Audit 
 
 

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CONTRACTOR PERFORMANCE AUDIT REPORT 
 
MANAGEMENT CONSULTANTS & 
CERTIFIED PUBLIC ACCOUNTANTS 
 
Independent Auditors’ Performance Audit Report on Unemployment Insurance 
Claims Submitted by Multistate Claimants 
 
Lori Frazier Bearden 
Acting 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 or Department) Office 
of Inspector General (OIG) to conduct a performance audit of the Employment 
and Training Administration’s (ETA) oversight of state workforce agencies’ 
(SWA or state)7 efforts to address potentially fraudulent unemployment insurance 
(UI) claims filed by multistate claimants.8  
  
Specifically, we conducted the audit to answer the following question: 
 
To what extent have ETA and SWAs addressed potentially fraudulent 
Coronavirus Aid, Relief, and Economic Security (CARES) Act UI claims 
filed by multistate claimants?  
 
To answer this question, we reviewed the actions taken by ETA and SWAs—
from April 7, 2021, through September 15, 2022 (the audit period)—to address 
the OIG-identified potentially fraudulent UI claims filed by multistate claimants 
from March 2020 through October 2020. Using a risk-based approach, the OIG 
selected 181 claimants for us to test from the States of Alabama, California, 
Connecticut, Florida, Illinois, Iowa, New York, and Texas; the District of 
Columbia; and the U.S. Virgin Islands (10 SWAs). We also reviewed the 
 
7 This report uses “state” or “SWA” to refer to the 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. Therefore, there are 53 SWAs. 
8 Multistate claimants include: (1) individuals who used their own Social Security numbers to file 
UI claims in multiple states and (2) victims of identity theft whose Social Security numbers were 
used by fraudsters to file UI claims in multiple states. 

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10 SWAs’ policies, processes, and results of relevant actions taken. However, 
we did not make determinations of fraud or evaluate whether the states made the 
correct determinations. In addition, we surveyed the remaining 43 SWAs and 
Guam; 28 SWAs (64 percent) responded. We also reviewed updated guidance 
and UI payment reporting activities that extended outside of the audit period. See 
Appendix A for additional details on scope and methodology. 
RESULTS 
We found 7 of the 10 SWAs (Alabama, California, Connecticut, Florida, Illinois, 
New York, and Texas) confirmed some multistate claimants filed fraudulent UI 
claims.9 However, ETA took limited action to ensure states properly addressed 
the potentially fraudulent UI claims filed by multistate claimants.  
 
ETA is responsible for providing oversight of UI fraud risk management and 
states’ management should report internal control deficiencies to ETA—
consistent with the Government Accountability Office’s (GAO) Standards for 
Internal Control in the Federal Government. Specifically, the standards state the 
oversight body is responsible for overseeing the strategic direction of the entity 
and obligations related to the accountability of the entity. This includes 
overseeing management’s design, implementation, and operation of an internal 
control system. Further, management should report deficiencies identified in the 
internal control system to the oversight body.  
 
ETA transmitted the claimant data associated with potentially fraudulent UI 
claims to the 53 SWAs and Guam in April 2021, including instructions and 
requirements on investigations and due process. However, ETA did not perform 
the following oversight actions: 
 
• monitor nor require states to report the results of research or 
investigations of potentially fraudulent UI claims, which would have 
assisted ETA in identifying high-risk areas for UI fraud;  
 
• ensure the National Association of State Workforce Agencies’ 
(NASWA) Integrity Data Hub (IDH) effectively provided states with 
useful information to assist in identifying UI fraud; or  
 
 
9 The remaining three SWAs (District of Columbia, Iowa, and Virgin Islands) determined that the 
UI claims were nonfraudulent. 

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• ensure states consistently established and reported fraudulent 
overpayments distributed to imposter claimants or identify systemic 
weaknesses that resulted in states reporting zero fraudulent 
overpayments when UI fraud risk was at its height during the 
pandemic. 
 
These deficiencies occurred because ETA considered its oversight 
responsibilities to be limited. Specifically, ETA: (1) did not consider monitoring 
the results of states’ research and investigations as part of its responsibilities; 
(2) measured IDH effectiveness by the number of claims submitted to and 
flagged by the IDH rather than by the outcomes of states’ fraud investigations; 
and (3) did not detect states’ information technology (IT) systems or staffing were 
insufficient to establish or report fraudulent overpayments. 
 
Without knowledge of the states’ investigative results, ETA’s ability to assess UI 
program performance, identify high-risk areas, and provide states with additional 
tools and guidance to prevent fraudulent overpayments was impaired. In 
addition, without ETA establishing an outcome-based metric for IDH 
cross-matches, ETA was unable to determine the IDH’s effectiveness in assisting 
states with identifying fraud. 
ETA Needs to Improve Its Oversight of 
States’ Efforts to Identify Multistate UI 
Fraud 
ETA is the federal agency responsible for providing states UI program direction 
and oversight. ETA provided states with claimant data associated with potentially 
fraudulent UI claims, recommended states use the IDH’s cross-match, and 
required states to report aggregated fraudulent overpayment data. However, 
after taking these actions, ETA did not sufficiently monitor states’ fraud detection 
and reporting activities to ensure improvements to the integrity of the UI program. 
This occurred because ETA considered its oversight responsibilities to be limited, 
resulting in an impairment of its ability to assess performance of the UI program 
and identify high-risk areas. 
ETA Neither Monitored Nor Required States to 
Report Results of Research or Investigations 
In April 2021, ETA transmitted to 53 SWAs and Guam a list of multistate 
claimants who filed potentially fraudulent UI claims, as identified by the OIG. 
Specifically, ETA sent the list with investigative instructions and due process 

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requirements. We confirmed all 10 SWAs selected for detailed review as part of 
this audit received their respective claimant lists from ETA’s April 2021 
transmission. However, after distributing the list, ETA did not monitor nor require 
the states to report the results of any research or investigations performed, which 
would have assisted ETA in identifying high-risk areas for UI fraud. GAO’s 
Standards for Internal Control in the Federal Government prescribes 
management should report deficiencies identified in the internal control system to 
the oversight body—which, in the case of the UI system, is ETA. 
 
The 10 SWAs informed us they did not communicate the results of subsequent 
research or investigations to ETA, even though 7 SWAs’ (Alabama, California, 
Connecticut, Florida, Illinois, New York, and Texas) investigations had confirmed 
the occurrence of fraudulent transactions. We submitted detailed testing 
questionnaires to the 10 SWAs for each of the selected 181 UI claimants to 
determine SWA actions taken to address the potentially fraudulent CARES Act 
UI claims filed by multistate claimants. Each SWA’s response indicated whether 
the claims had been determined by the state to be fraudulent or nonfraudulent.  
 
We found the 10 SWAs paid $1.6 million in UI benefits, and the states confirmed 
$404,288 was fraudulent. The fraudulent overpayments confirmed by the states 
represented 25 percent of the UI benefits paid to the claimants tested. This 
included $53,824 (13 percent) paid to claimants who filed in multiple states and 
$350,464 (87 percent) paid to claimants who filed claims for other fraudulent 
reasons, including identity fraud (see Exhibit, Tables 2 and 3). 
 
In survey responses, 23 of 27 responding states10 (85 percent) indicated they did 
not report to ETA any results of research or investigations regarding the claimant 
list. The remaining four respondents indicated they generally report fraudulent 
overpayments to ETA but did not report the results of investigations specific to 
the claimant list. 
 
In addition, 4 of the 10 SWAs experienced issues of which ETA would likely have 
been aware had it been monitoring the states’ results for trends and emerging 
issues. For example, three states (Texas, California, and Florida) did not 
successfully perform an IDH Multistate Cross-Match (cross-match). Through 
Unemployment Insurance Program Letter (UIPL) No. 23-20,11 ETA strongly 
recommended states use the cross-match, which can identify when the same 
 
10 During a survey, we asked 43 SWAs and Guam whether they reported results of investigations 
to ETA and received responses from 27 SWAs. 
11 UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program and the UI 
Programs Authorized by the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 
2020 - Federal Pandemic Unemployment Compensation (FPUC), Pandemic Unemployment 
Assistance (PUA), and Pandemic Emergency Unemployment Compensation (PEUC) Programs 
(May 11, 2020) 

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claimant information is used to file UI claims in multiple states, for regular UI as 
well as the Pandemic Unemployment Assistance (PUA) and Pandemic 
Emergency Unemployment Compensation (PEUC) programs. However, Texas 
experienced difficulties in exchanging data with the IDH, which prevented it from 
completing the cross-match. Further, we found California and Florida had not 
implemented the cross-match as an internal control tool. Finally, District of 
Columbia SWA officials stated that, due to staff turnover, they could not confirm 
whether the SWA performed a cross-match on the OIG’s list. 
ETA Did Not Consider Monitoring Results of SWAs’ Investigations as Part of 
Its Oversight Responsibilities 
ETA did not monitor the results of the SWAs’ research and investigations of 
potentially fraudulent UI claims because it did not consider such monitoring 
activities to be a required part of its oversight responsibilities. This is contrary to 
government standards on management reporting and managing fraud risks, as 
well as recommendations from both the OIG and GAO. 
 
ETA relied on the SWAs’ submissions of aggregated overpayment and fraud 
data on the following two distinct pandemic program reports: 
 
1. Quarterly ETA 227: Overpayment Detection and Recovery reports12 
for the Federal Pandemic Unemployment Compensation (FPUC) 
and PEUC programs; and  
2. Monthly ETA 902P: Pandemic Unemployment Assistance 
Activities13 reports for the PUA program.  
 
ETA required states to report aggregated data on UI claims, including 
established overpayments and non-monetary determinations. ETA officials 
asserted it is not ETA’s responsibility to require states to report the results of their 
individual investigations. Specifically, ETA officials stated the agency provides 
guidance and funding to states to operate UI programs and they had no reason 
to collect claimant-level results of the SWAs’ investigations, nor did they have the 
capacity to evaluate or analyze such data. However, ETA is the federal agency 
responsible for providing UI program direction and oversight. This responsibility 
includes distributing federal funds for states’ implementation of the CARES Act 
UI programs, ensuring the integrity of the UI system, and managing fraud risks. 
 
 
12 For FPUC and PEUC, SWAs used ETA 227 to report quarterly program activities, including the 
establishment of overpayments, recoveries of overpayments, criminal and civil actions involving 
overpayments obtained fraudulently, and an aging schedule of outstanding benefit overpayment 
accounts. 
13 For PUA, SWAs used ETA 902P to report monthly data on PUA activities, including application 
and payment, denials and appeals, and overpayments. 

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ETA agreed with the OIG’s finding in a previous COVID-19 report14 that there 
was a significant increase in fraudulent activity in the UI program. In addition, 
ETA subsequently provided the OIG’s list of multistate claimants to SWAs and 
informed the SWAs it would collaborate with them to combat the sophisticated 
imposter fraud affecting the UI system. Accordingly, ETA accepted and 
demonstrated its monitoring responsibilities. Given this prior action, ETA’s 
decision not to monitor the results of the SWAs’ research and investigations of 
potentially fraudulent claims filed by multistate claimants did not align with its 
proposed collaborative effort to combat imposter fraud expressed to the SWAs. 
 
Further, ETA’s oversight responsibility to ensure the integrity of the UI system 
includes managing its fraud risk environment. In October 2021,15 GAO 
recommended DOL designate a dedicated entity and document its 
responsibilities for managing the process of assessing fraud risks to the UI 
program consistent with leading practices as provided in its Fraud Risk 
Framework (see Figure). In addition, GAO recommended DOL should have, 
among other things, clearly defined and documented responsibilities and 
authority for managing fraud risk assessments and for facilitating communication 
among stakeholders regarding fraud-related issues. 
 
 
14 Alert Memorandum: The Employment and Training Administration (ETA) Needs to Ensure 
State Workforce Agencies (SWA) Implement Effective Unemployment Insurance Program Fraud 
Controls for High-Risk Areas, Report No. 19-21-002-03-315 (February 22, 2021), available at: 
https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-315.pdf 
15 GAO, COVID-19: Additional Actions Needed to Improve Accountability and Program 
Effectiveness of Federal Response, GAO-22-105051 (October 27, 2021), available at: 
https://www.gao.gov/products/gao-22-105051 

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Figure: GAO’s Framework for Managing Fraud Risks in Federal Programs 
 
 
 
Source: GAO, A Framework for Managing Fraud Risks in Federal Programs, 
Report No. GAO­15­593SP (July 2015), available at:  
https://www.gao.gov/assets/gao-15-593sp.pdf  
 
GAO has closed this recommendation based on actions taken by the 
Department. On January 6, 2023, the DOL Secretary designated DOL’s Chief 
Financial Officer (CFO) as the dedicated entity responsible for managing the 
process of assessing fraud risks in the UI program. This designation is consistent 
with leading practices as provided in GAO’s Fraud Risk Framework. However, 
the designation came almost 3 years after the onset of the pandemic. The 
beginning of the pandemic was the most critical time for administering new 
temporary programs and states struggled to process the highest level of claims in 
the history of the UI program.  
 
ETA, with the advisory support of the Office of the Chief Financial Officer (OCFO) 
Fraud Risk Working Group, also developed a UI Fraud Risk Profile in 
August 2023. However, this was 8 months after the CFO was designated as the 

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anti-fraud risk entity. In April 2024, ETA published “Building Resilience: A Plan to 
Transform Unemployment Insurance.” This plan details seven transformation 
activities, including bolstering state UI programs against fraud. The plan also 
listed ongoing and completed strategies, as well as legislative reform proposals.  
 
In May 2024, the OIG and OCFO met to discuss OCFO’s role and responsibilities 
as it related to the UI program. OCFO officials stated OCFO did not specialize in 
UI programs; rather, OCFO advised ETA on UI fraud risk management. 
According to OCFO officials, the UI Fraud Risk Profile is a living document. 
Further, they stated ETA identified the risks it contains based on high-risk areas 
reported in previous GAO and OIG reports, as well as data ETA regional offices 
collected from the states. Altogether, ETA identified 18 UI fraud risks in the UI 
Fraud Risk Profile, including: 
 
• applicants fraudulently filing claims and receiving benefits across 
multiple states; 
• deceased persons’ identities used to file for UI benefits; 
• suspicious email addresses or devices used to file UI claims; and 
• incarcerated individuals or prison inmates applying for UI benefits, 
while misrepresenting their eligibility.16 
 
In the UI Fraud Risk Profile, ETA and OCFO included responses to mitigate each 
fraud risk. According to OCFO officials, the challenges to mitigating the risks 
included the 53 SWAs having: (1) statutory authority to use or not use IDH 
services and (2) varying laws that define fraud. Nonetheless, ETA developed a 
UI Integrity Strategic Plan through which it updated, oversaw, and communicated 
its UI anti-fraud strategies. According to ETA, the strategic plan continuously 
evolves and includes strategies and anti-fraud controls to combat emerging fraud 
schemes and address the highest residual risks identified in the UI Fraud Risk 
Profile. ETA requires states to submit Integrity Action Plans every 6 months to 
capture ongoing and planned actions to mitigate each fraud risk and reduce 
improper payments. Further, according to the plan, ETA tracks and evaluates 
each fraud risk mitigation strategy and action quarterly to determine their 
effectiveness in mitigating each UI fraud risk and the level of risk that remains.  
 
ETA officials stated, if ETA determined a risk response effectively decreased the 
UI fraud risk to an acceptable tolerance level, the agency would update the risk 
ratings in the UI Fraud Risk Profile. Accordingly, these updates could reprioritize 
the remaining UI risks. If UI risks are reprioritized, ETA would revise the 
associated control strategies in the UI Integrity Strategic Plan to target higher 
priority risks. However, if ETA determined a risk response was not effective 
 
16 In some cases, fraud perpetrators steal inmates’ personally identifiable information to apply for 
and receive UI benefits. 

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enough to lower a risk to an acceptable risk tolerance level, the agency would 
develop additional control strategies. These additional strategies would be added 
to the UI Integrity Strategic Plan and tracked on a quarterly basis until the control 
was fully implemented.  
 
This process would be repeated until ETA determined the risk response 
effectively decreased the risk to an acceptable tolerance level. As new fraud 
threats emerge, ETA would: (1) update the UI Fraud Risk Profile and 
(2) incorporate and track additional risk response activities to mitigate the newly 
identified risks in the UI Integrity Strategic Plan. However, ETA could not provide 
documented evidence that it performed quarterly evaluations of strategies and 
actions to determine their effectiveness in mitigating each fraud risk and the 
remaining levels of risk. 
 
On June 27, 2024, ETA, through Training and Employment Notice No. 32-23, 
announced the launch of the WorkforceGPS UI Fraud Risk Management 
webpage.17 ETA and OCFO developed the webpage to encourage states to 
share feedback with their ETA regional office, including states’ best practices in 
fraud risk management that could assist other states in operating their UI 
programs. 
 
In GAO’s Framework for Managing Fraud Risks in Federal Programs, GAO 
emphasized it is critical that the anti-fraud entity be located within the agency and 
not the OIG, so the OIG can retain independence to serve its oversight role.18 
However, since June 2020, the OIG has been the leading federal entity collecting 
pandemic-related UI claimant data from states nationwide, performing risk 
assessments, and identifying high-risk areas. As previously noted, the OIG 
provided ETA and states with claimant data associated with high-risk potentially 
fraudulent UI claims and its methodology. These efforts should not be deferred to 
the OIG’s independent oversight. As the oversight agency for UI programs, ETA 
is responsible for establishing a routine program integrity function. With the 
support of the CFO as the designated anti-fraud entity, ETA needs to: (1) perform 
its own data analytics and risk assessments, (2) identify high-risk areas, and 
(3) update the UI Fraud Risk Profile.  
 
 
17 Accessible with account creation request at: 
https://ui.workforcegps.org/resources/2024/05/01/18/20/Unemployment_Insurance_Fraud_Risk_
Management  
18 GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP 
(July 2015), available at: https://www.gao.gov/assets/gao-15-593sp.pdf 

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In a September 2023 OIG report,19 the OIG identified the importance of data 
analytics in providing effective UI program oversight and combating fraud. In 
addition, the OIG recommended ETA create an integrity program that 
incorporates a data analytics capability and regularly monitor state UI claims data 
to detect and prevent improper payments, including fraudulent payments, and 
identify trends and emerging issues that could negatively impact the UI program.  
 
In ETA’s response to the OIG’s report, ETA cited limited funding as the reason 
for not being able to staff a data analytics team. In addition, ETA stated creating 
a data analytics capability and monitoring state UI claims data would duplicate 
DOL’s ongoing investment in the UI Integrity Center,20 including the IDH. As an 
alternative, ETA stated it would leverage ongoing investments in the UI Integrity 
Center’s IDH and work with the UI Integrity Center to improve IDH data analytics 
capabilities to better identify fraud trends. However, states are not required to 
participate in the IDH and those that do participate do so to varying degrees, 
which has limited the IDH’s effectiveness. As of September 21, 2023, 51 of the 
53 SWAs21 used IDH services to some degree. The OIG’s recommendations 
remained unimplemented as of July 8, 2025. We are not reissuing these 
recommendations but emphasize the importance of addressing them to resolve 
the deficiencies identified within this report. 
ETA Encouraged the Use of NASWA’s IDH 
Cross-Match without Ensuring Its Effectiveness in 
Assisting States with Detecting Fraud  
In UIPL No. 23-20, ETA strongly recommended states employ multiple 
techniques, including the use of the IDH’s cross-match, to validate UI claims and 
uncover suspicious or fraudulent characteristics. We found 8 of the 10 SWAs 
(80 percent) responded they used the IDH cross-match to identify UI claims filed 
by multistate claimants. These responses align with the survey responses where 
24 of 28 respondents (86 percent) stated they used the IDH cross-match. 
However, ETA did not ensure the IDH cross-match was effective in assisting 
states with detecting fraud. 
 
 
19 Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to Improve Oversight 
of the Unemployment Insurance Program, Report No. 19-23-012-03-315 (September 25, 2023), 
available at: https://www.oig.dol.gov/public/reports/oa/2023/19-23-012-03-315.pdf 
20 The UI Integrity Center, established by the Department and operated by NASWA, is designed 
to: (1) assist states in their efforts to more effectively prevent, detect, and recover improper and 
fraudulent payments and (2) improve program integrity by developing and promoting innovative 
program strategies. 
21 Guam does not have an IDH agreement. 

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According to NASWA’s data, claims filed by multistate claimants from 
March 2020 through October 2020 were flagged on 1,232,628 occasions for 
having matching data points in multiple states. However, the number of flags 
alone did not indicate the effectiveness of the IDH cross-match tool in assisting 
states with detecting fraudulent UI claims filed by multistate claimants.  
 
In a previous audit report,22 the OIG found NASWA’s IDH was less effective at 
identifying potentially improper multistate claims when compared to the OIG’s 
data analytics efforts. Further, the OIG found greater oversight of IDH 
performance was needed if ETA’s and states’ reliance on the tool for program 
integrity, including fraud identification, was to continue. The OIG recommended 
ETA complete an evaluation of the effectiveness of the IDH system, including the 
methodology used in cross-matching data.  
 
In response to the OIG’s recommendation, ETA contracted with a consulting firm 
to perform a study23 of the IDH to answer the following questions: 
 
1. How do participating states use the IDH to detect and prevent 
fraud? 
2. How effective do states consider the IDH to be in detecting and 
preventing fraud? 
3. What options are available to inform continuous improvement and 
effectiveness of the IDH? 
 
The consulting firm found states lacked consistency in how and when they used 
the IDH, which made it difficult to measure the tool. According to the IDH study, 
data sharing is the most significant value in the IDH. However, when states, 
particularly larger states, do not contribute data to the IDH, other states do not 
benefit and the IDH loses its value. The consulting firm also found many states 
only reported initial UI claims data to the IDH and did not contribute continued 
claims information. 
ETA Measured IDH’s Effectiveness by the Number of Claims Submitted and 
Flagged Rather Than by the Outcomes of SWAs’ Investigations 
The purpose of the IDH is not to identify fraud, but rather to provide states with 
information to help them accurately identify potentially fraudulent claims, with a 
minimum number of false positives and false negatives. A false positive would be 
a legitimate claim incorrectly flagged for review, and a false negative would be a 
fraudulent claim not flagged as suspicious. However, ETA did not establish a 
 
22 COVID-19: ETA Can Improve Its Oversight to Ensure Integrity over CARES Act UI Programs, 
Report No. 19-23-011-03-315 (September 22, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-011-03-315.pdf 
23 Exploratory Study of the Integrity Data Hub (IDH) Final Internal Report (March 2024) 

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performance metric to effectively assess how well the IDH results achieved this 
goal because the current metrics focus on inputs and outputs24 rather than the 
outcomes (fraud or nonfraud) of states’ fraud investigations. The SWAs are not 
required to report investigative outcome data back to the IDH system. Without 
ETA establishing an outcome­based metric for IDH cross-matches, ETA is 
unable to determine how effective the IDH is in assisting states with identifying 
fraudulent claims.  
 
In a September 2022 OIG report,25 the OIG recommended ETA work with 
NASWA to: (1) update the IDH Participant Agreement to require states to submit 
the results of their UI fraud investigations and (2) ensure IDH cross-matches are 
effective at preventing the types of fraud detected during the pandemic and 
regularly update the IDH system using the results of state fraud investigations.  
 
ETA offered to revise its required UI-related reports as an alternate approach to 
meet the intent of the OIG’s recommendations. The revised reports would 
capture: (1) the tools or interventions, including the IDH, a state used to detect 
potential fraud issues and (2) the aggregated data for outcomes (e.g., 
determination, overpayment amounts) of the issues such tools or interventions 
detect. ETA stated revising its required UI-related reports would be more 
effective. Specifically, the revisions would allow ETA to gather information on IDH 
outcomes to track the results of investigations and determinations based on the 
use of the IDH and other information. ETA estimated completing this alternative 
approach to the recommendations in Fiscal Year 2024. However, as of 
June 3, 2025, these OIG recommendations remain unimplemented. We are not 
reissuing these recommendations but emphasize the importance of addressing 
them to resolve the deficiencies identified within this report. 
ETA Did Not Ensure States Consistently 
Established and Reported Fraudulent 
Overpayments or Identify Systemic Weaknesses 
that Resulted in States Reporting Zeros 
We found states did not consistently establish and report fraudulent 
overpayments to ETA, including those resulting from identity fraud. Four of the 
10 SWAs (Connecticut, Florida, Iowa, and New York) did not establish nor report 
overpayments related to imposter claimants unless an investigation subsequently 
 
24 Inputs are the number of claims submitted to the IDH, and outputs are the number of claims 
flagged by the IDH. 
25 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 

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identified the imposter. However, the non-identification of an imposter does not 
negate the fact that an overpayment was made. Without complete overpayment 
reporting, ETA cannot sufficiently perform its oversight role and effectively direct 
its resources to address identity fraud. Table 1 lists the 10 SWAs’ responses 
regarding whether they established and reported overpayments related to 
imposter claimants. 
 
 
Table 1: Summary of 10 SWAs’ Processes for Establishing and Reporting 
Overpayments Disbursed to Imposter Claimants 
 
SWA  
 Did the SWA have a 
process for establishing 
overpayments disbursed 
to imposter claimants? 
Did the SWA have a 
process for reporting 
overpayments 
disbursed to imposter 
claimants? 
Connecticut  
No 
No 
Florida 
No 
No 
Iowa 
No 
No 
New York 
No 
No 
Alabama 
Yes 
Yes 
California 
Yes 
Yes 
District of Columbia 
Yes 
Yes 
Illinois 
Yes 
No 
Texas 
Yes 
Yes 
Virgin Islands 
Yes 
Yes 
Source: Regis-generated, based on responses from the 10 SWAs 
 
According to Connecticut, Florida, Iowa, and New York officials, since the 
perpetrators of identity fraud did not have UI accounts, the states did not 
establish or report overpayments. The officials indicated that, if the states were to 
establish overpayments, it would unduly impact the victims of identity fraud. 
However, both Alabama and Texas, per their respective officials, were able to 
address the impact on the victims by removing the payments from identity fraud 
victims’ accounts and creating pseudo accounts. The SWAs then established 
and reported the fraudulent overpayments under the pseudo account until the 
perpetrator of the identity fraud was identified.  
 
Additionally, we found, while Illinois established overpayments for imposter 
claimants, the state did not report those overpayments. According to Illinois 
officials, they encountered significant challenges due to a shortage of staff and 
the use of manual IDH data reviews to detect fraudulent claims. They stated both 

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of these factors delayed the reporting of fraudulent overpayments on the 
ETA 227 reports. However, as of January 2025, the state had finalized its 
imposter claim numbers and began reporting to ETA fraudulent overpayments 
made to imposters. 
 
Since April 2020, UIPL Nos. 15-20,26 16-20,27 and 17-2028 have required SWAs 
to report FPUC, PUA, and PEUC overpayments, including fraud, on ETA 227 (for 
FPUC and PEUC) and 902P (for PUA) reports. We acknowledge that, for the first 
3 months the programs were in existence, there may have been legitimate 
reasons the states lacked activity to report. However, the applicable UIPLs did 
not waive the reporting requirements for that period. Therefore, we analyzed the 
UI reporting activity for the 10 SWAs from April 2020 through September 2022, 
including the first 3 months for which states were required to report. 
 
As of January 2025, we found that, from April 2020 through September 2022, the 
10 SWAs reviewed periodically reported zero fraudulent overpayments related to: 
(1) the FPUC and PEUC programs on ETA 227 reports and (2) the PUA program 
on ETA 902P reports. However, it is unlikely there were no fraudulent 
overpayments disbursed for multiple quarters considering the: (1) high UI fraud 
risks associated with the quick implementation of the new, high-dollar value 
pandemic programs; (2) evolving guidance; and (3) rapid increase in UI claims. 
As part of ETA’s oversight role, it should have identified systemic weaknesses 
that resulted in states reporting zero fraudulent overpayments when UI fraud risk 
was at its height during the pandemic. 
 
For FPUC, the following seven SWAs reported zero fraudulent overpayments on 
the quarterly ETA 227 reports: 
 
• California reported zero FPUC fraudulent overpayments for the 
10 quarters ending June 30, 2020, through September 30, 2022; 
 
• Connecticut reported zero FPUC fraudulent overpayments for the 
quarter ending June 30, 2020;  
 
 
26 UIPL No. 15-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020—
Federal Pandemic Unemployment Compensation (FPUC) Program Operating, Financial, and 
Reporting Instructions (April 4, 2020) 
27 UIPL No. 16-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020—
Pandemic Unemployment Assistance (PUA) Program Operating, Financial, and Reporting 
Instructions (April 5, 2020) 
28 UIPL No. 17-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020—
Pandemic Emergency Unemployment Compensation (PEUC) Program Operating, Financial, and 
Reporting Instructions (April 10, 2020) 

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• District of Columbia reported zero FPUC fraudulent overpayments 
for the quarter ending June 30, 2020; 
 
• Florida reported zero FPUC fraudulent overpayments for the eight 
quarters ending June 30, 2020, through March 31, 2022;  
 
• Iowa reported zero FPUC fraudulent overpayments for the two 
quarters ending June 30, 2020, and September 30, 2020; 
 
• Texas reported zero FPUC fraudulent overpayments for the 
10 quarters ending June 30, 2020, through September 30, 2022; 
and 
 
• Virgin Islands reported zero FPUC fraudulent overpayments for the 
two quarters ending September 30, 2020, and December 31, 2020. 
 
For PEUC, the following seven SWAs reported zero fraudulent overpayments on 
the quarterly ETA 227 reports: 
 
• California reported zero PEUC fraudulent overpayments for the 
three quarters ending June 30, 2020, through December 31, 2020; 
 
• Connecticut reported zero PEUC fraudulent overpayments for the 
two quarters ending June 30, 2020, and September 30, 2020;  
 
• District of Columbia reported zero PEUC fraudulent overpayments 
for the quarter ending September 30, 2020; 
 
• Florida reported zero PEUC fraudulent overpayments for the five 
quarters ending June 30, 2020, through December 31, 2020, and 
September 30, 2022, and December 31, 2022; 
 
• Iowa reported zero PEUC fraudulent overpayments for the two 
quarters ending June 30, 2020, and September 30, 2020; 
 
• Illinois reported zero PEUC fraudulent overpayments for the quarter 
ending June 30, 2021; and 
 
• Texas reported zero PEUC fraudulent overpayments for the quarter 
ending September 30, 2020. 
 

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For PUA, all 10 SWAs reported zero fraudulent overpayments on the monthly 
ETA 902P reports:29 
 
• Alabama reported zero fraudulent PUA overpayments for the month 
ending April 2020; 
 
• California reported zero fraudulent PUA overpayments for the 
13 months ending April 2020 and October 2021 through 
September 2022; 
 
• Connecticut reported zero fraudulent PUA overpayments for the 
30 months ending April 2020 through September 2022; 
 
• District of Columbia reported zero fraudulent PUA overpayments for 
the 7 months ending April 2020 through October 2020; 
 
• Florida reported zero fraudulent PUA overpayments for the 
20 months ending April 2020 through June 2020, September 2020 
through January 2021, April 2021, August 2021 through 
October 2021, December 2021, February 2022, March 2022, and 
May 2022 through September 2022; 
 
• Illinois reported zero fraudulent PUA overpayments for the 
14 months ending April 2020 through November 2020, and 
January 2021 through June 2021; 
 
• Iowa reported zero fraudulent PUA overpayments for the 7 months 
ending April 2020 through September 2020, and September 2021; 
 
• New York reported zero fraudulent PUA overpayments for the 
month ending April 2020; 
 
• Texas reported zero fraudulent PUA overpayments for the 
5 months ending April 2020, July 2020, August 2020, 
October 2020, and November 2020; and 
 
 
29 PUA fraudulent overpayments excluded fraudulent payments made as a result of identity theft. 
States are required to report overpayments made as a result of identity theft separately on the 
ETA 902P report. 

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• Virgin Islands reported zero fraudulent PUA overpayments for the 
19 months ending April 2020 through March 2021, June 2021 
through September 2021, December 2021, July 2022, and 
August 2022. 
Previous OIG reports identified states’ pervasive non-reporting of overpayments, 
including fraud, for CARES Act UI programs due to antiquated IT systems. In 
May 2021,30 the OIG recommended ETA assist states with claims, 
overpayments, and fraud reports to create clear and accurate information. In 
August 2022,31 the OIG similarly recommended ETA work with states to ensure 
submission of missing reports and information before the commencement of 
ETA’s Fiscal Year 2022 financial statement audit.  
 
In response to the August 2022 report, ETA agreed with the OIG that complete 
and accurate reporting is important to the administration and oversight of the 
temporary UI programs created under the CARES Act and related subsequent 
legislation. To address the issue, ETA: (1) provided states training on reporting 
accurate data and submitting ETA 227 and ETA 902P reports, (2) required 
corrective action plans for states with challenges in reporting as part of their 
State Quality Service Plans,32 and (3) conducted state-specific technical 
assistance.  
 
Also, in UIPL No. 28-20, Change 4,33 ETA announced the availability of up to 
$225 million for the SWAs’ administrative costs related to reporting and 
overpayment detection and recovery activities under CARES Act UI programs. 
As of April 2023, ETA had awarded $181.2 million to 46 SWAs. ETA anticipates 
completion of this effort to occur by the end of Fiscal Year 2025. 
 
As of January 2025, more than 2 years since the OIG’s August 2022 
recommendation, 9 of the 10 SWAs (Alabama, California, Connecticut, District of 
 
30 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 
31 Alert Memorandum: The Employment and Training Administration Needs to Ensure State 
Workforce Agencies Report Activities Related to CARES Act Unemployment Insurance 
Programs, Report No. 19-22-004-03-315 (August 2, 2022), available at: 
https://www.oig.dol.gov/public/reports/oa/2022/19-22-004-03-315.pdf 
32 The annual State Quality Service Plan is the principal vehicle the state UI programs use to 
plan, record, and manage improvement efforts. The State Quality Service Plan serves as the 
programmatic plan portion of the grant document through which states receive federal UI 
administrative funding. 
33 UIPL No. 28-20, Change 4, Support for States to Resolve Outstanding Items from the Expired 
Coronavirus Aid, Relief, and Economic Security (CARES) Act Unemployment Compensation 
(UC) Programs, Including Additional Funding to Assist States with Reporting and Detection and 
Recovery of Overpayments (July 22, 2022) 

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Columbia, Florida, Iowa, New York, Texas, and Virgin Islands) are still 
establishing and reporting fraudulent overpayments for the pandemic UI 
programs. The remaining SWA, Illinois, has completed its reporting efforts. The 
following list contains specifics on the status of the nine SWAs with reporting 
efforts ongoing:  
• Alabama SWA officials stated the SWA expects to complete its 
effort by December 2025, but it may take longer. According to SWA 
officials, Alabama had dealt with a massive claims backlog that 
consumed the agency’s resources. SWA officials stated, now that 
the backlog issue has been resolved, the SWA will focus its 
resources on establishing and reporting fraudulent overpayments; 
 
• California SWA officials did not provide an anticipated completion 
date for identifying, establishing, and reporting fraudulent 
overpayments; 
 
• Connecticut SWA officials stated it could not provide a completion 
date based on pending investigations, but will continue to identify 
and report fraudulent overpayments over the next few years; 
 
• District of Columbia SWA officials stated they expect to complete 
the investigation process for establishing fraudulent overpayments 
no later than March 31, 2025. According to agency officials, once 
fraudulent overpayments are established, the benefit payment 
control staff will review and report the fraudulent overpayments to 
ETA; 
 
• Florida SWA officials stated they expect to complete establishing 
fraudulent overpayments for the pandemic UI programs by 
February 2025 and reporting by March 2025;  
 
• Iowa SWA officials stated, due to the complexity and volume of the 
pandemic UI claims, the process of identifying, reporting, and 
recovering fraudulent overpayments will likely extend for several 
years; 
 
• New York SWA officials stated they are continuing with UI 
modernization efforts and anticipate completing fraudulent 
overpayment reporting by September 2025; 
 

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• Texas SWA officials stated establishing fraudulent overpayments 
for the pandemic UI programs is an ongoing process that will never 
be completed. Agency officials provided examples of circumstances 
where overpayments are established when: (1) prior eligibility 
determinations are reversed through the appeal process, or (2) the 
owner of a Social Security number (SSN) used to commit identity 
fraud later files a legitimate claim; and 
 
• Virgin Island SWA officials did not provide an anticipated 
completion date for assessing the overpayments for the pandemic 
UI programs. According to agency officials, their efforts to establish 
fraudulent overpayments have been lagging due to issues with 
limited staff and delayed responses from employers and claimants. 
 
We commend ETA for continuing to work with the states to identify and report 
fraudulent overpayments in the CARES Act UI programs. However, these efforts 
to establish and report fraudulent overpayments have been ongoing for more 
than 2 years and, based on the 9 SWAs’ anticipated completion dates or 
absence of a completion date, could take longer. 
Antiquated IT Systems or Staffing Challenges Caused States’ Fraudulent 
Overpayment Reporting Issues 
The SWAs did not consistently establish and report fraudulent overpayments 
because some SWAs did not have the IT system capability to establish and 
report fraudulent overpayments distributed to imposter claimants without flagging 
the victims’ SSNs, thus penalizing the victims. Without this IT system capability, 
the overpayment reporting on the ETA 227 and 902P reports was inconsistent 
among states and likely understated. However, the association of the fraudulent 
activity with victims’ SSNs does not negate the SWAs’ responsibility to report all 
overpayments, including those due to identity fraud.  
 
ETA issued guidance to SWAs to protect identity fraud victims and ensure the 
owners of SSNs are not held responsible. Specifically, UIPL No. 16-2134 notes, 
when a state determines identity fraud has occurred, it must take precautions to 
protect the rights of and mitigate the negative consequences to the identity fraud 
victim, including:  
 
• ensuring that if a future claim is filed under the victim’s SSN, the 
claimant undergoes a secondary identity verification process, while 
minimizing the burden on the victim; 
 
34 UIPL No. 16-21, Identity Verification for Unemployment Insurance (UI) Claims (April 13, 2021) 

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• ensuring the owner of the SSN is not held responsible for any 
overpayment or, whenever possible, is not issued a Form 1099G at 
the end of the year; 
• excluding the overpayment from the Treasury Offset Program and 
suspending Benefit Payment Control collection activity; and 
• refraining from initiating any legal actions against the actual owner 
of the SSN. 
 
The UIPL recommends an option that states can use to mitigate negative 
impacts on a victim: establishing a pseudo claim record and transferring all claim 
information regarding the imposter’s claim to the pseudo claim once the state 
makes a fraud determination. The pseudo claim record removes the fraudulent 
activity from the victim’s SSN. This allows the victim to file UI claims in the future 
and preserves data from the fraudulent activity to be used for future analytics. 
 
According to UIPL No. 20-21, Change 1,35 states that may not have the 
administrative capability to move fraudulent activity to a pseudo claim may 
choose to temporarily mark the overpayment as “uncollectible.” This ensures 
victims are not negatively impacted while the state develops a process to 
disassociate fraudulent activity from the victim’s SSN. However, this temporary 
“uncollectible” classification does not constitute waiving recovery of the 
overpayment. Therefore, the overpayment should still be reported to ETA on 
ETA 227 or 902P reports.  
 
Additionally, due to IT system programming or staffing challenges, 8 of 10 SWAs 
reviewed experienced difficulties that led them to report zero fraudulent 
overpayments for the FPUC, PEUC, or PUA programs, as follows:36 
California 
California officials stated the SWA was implementing a new UI system that was 
completed in June 2024. In addition, California officials stated the SWA did not 
report PUA fraudulent overpayments because it was working on integrating 
overpayment programming into the existing system. According to state officials, 
 
35 UIPL No. 20-21, Change 1, Additional State Instructions for Processing Waivers of Recovery of 
Overpayments under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, as 
Amended (February 7, 2022) 
36 Alabama and New York were excluded from our root cause analysis of states reporting zero 
fraudulent overpayments because fraudulent overpayments are reported in the month they are 
detected rather than in the month the payments were made. The two SWAs reported zero 
fraudulent PUA overpayments for the month ending April 2020, which marked the beginning of 
PUA program implementation. Therefore, any fraudulent overpayments made in April 2020 would 
have been detected and reported in later months. 

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the accurate reporting of FPUC and PEUC fraudulent overpayments began with 
the quarter ending September 30, 2024. 
Connecticut 
Connecticut officials stated the SWA initially experienced some setbacks with its 
new UI system implementation, which resulted in delays in establishing and 
reporting FPUC and PEUC fraudulent overpayments. In addition, according to 
officials, the state reported zero PUA fraudulent overpayments because 
processing accurate overpayments would have delayed its UI system 
modernization. 
District of Columbia 
District of Columbia officials stated, due to the large volume of UI claims 
submitted during the pandemic, resources were focused on processing claims. 
According to agency officials, the District’s PUA Unit did not begin identifying 
potentially fraudulent claims and referring to the Benefit Payment Control Branch 
for further investigation until September 2021.  
Florida 
Florida officials stated the SWA was not able to report FPUC fraudulent 
overpayments on its ETA 227 reports because it first had to integrate the 
program into its UI benefits system. According to officials, in January 2022, 
Florida completed the system integration; however, it has not yet reported any 
FPUC fraudulent overpayments. In addition, Florida officials stated the SWA did 
not report PUA fraudulent overpayments due to strained staffing resources. The 
staffing limitations required the SWA to reassign staff from other departments to 
manage the increased number of claims and perform system updates to 
implement pandemic federal programs.  
Illinois 
According to Illinois officials, insufficient staffing led the SWA to report zero 
PEUC and PUA fraudulent overpayments on its ETA 227 and ETA 902P reports, 
respectively. Officials stated limited staffing made it challenging to review the 
large volume of data received related to imposter claims during the pandemic. 
Further, Illinois officials stated staff had to manually review IDH data to detect 
fraudulent claims, which delayed the reporting of fraudulent overpayments.  
Iowa 
Iowa officials stated the SWA reported zero FPUC and PEUC fraudulent 
overpayments on its ETA 227 reports and zero PUA overpayments on its 

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ETA 902P reports due to delays attributed to modifying its mainframe and 
overpayment database system. In addition, officials stated the database needed 
to accommodate the new types of overpayments generated in the new pandemic 
programs.  
Texas 
Texas officials stated the SWA experienced IT resource constraints because the 
same IT resources used to program CARES Act payments were also needed to 
program establishment of FPUC overpayments and PEUC and PUA waivers. 
Therefore, according to officials, Texas prioritized its programming in the 
following order: claims payments, overpayments and waivers establishment, and 
ETA reporting. 
Virgin Islands 
Virgin Island officials stated delays programming FPUC and PUA claims into its 
UI system resulted in delays in processing applications and approving and 
disbursing payments. According to agency officials, this led to delays in 
performing the necessary cross-matches to detect and report fraudulent 
overpayments. 
State Finality Laws May Restrict SWAs’ Ability to Establish and Report 
Overpayments 
The 10 SWAs reviewed were taking ongoing corrective actions to comply with 
fraudulent overpayment reporting requirements. However, many states have 
unemployment compensation laws, or finality laws, that limit the length of time 
during which they may reconsider a prior determination on a regular UI claim, 
thus establishing and reporting overpayments. In December 2023, ETA issued 
UIPL No. 05-24,37 which authorized SWAs to apply state finality laws to 
CARES Act­funded UI claims. We are concerned that, by applying state finality 
laws to the pandemic-funded UI claims, states will not have an incentive to 
identify overpayments and fraud. The states already have a backlog of UI claims 
to review for establishment and reporting of fraudulent overpayments. If the 
period for reconsideration of those claims in the state’s finality law has elapsed, 
the SWA may no longer review the claim to determine if the disbursement was 
proper or an overpayment, including a fraudulent overpayment, was made. 
 
37 UIPL No. 05-24, Application of State Finality Laws Regarding Temporary Unemployment 
Compensation (UC) Programs under the Coronavirus Aid, Relief, and Economic Security 
(CARES) Act (December 29, 2023) 

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CONCLUSION 
The OIG has estimated at least $191 billion (22 percent) of $888 billion in 
pandemic UI benefits could have been paid improperly, with a significant portion 
attributable to fraud. We acknowledge ETA demonstrated a responsibility toward 
improving UI program integrity by: (1) transmitting the OIG’s list of potentially 
fraudulent claimants to states, along with instructions and specific requirements 
for conducting investigations and due process, and (2) developing a UI Fraud 
Risk Profile based on risks reported by GAO and the OIG.  
 
While these actions served to guard against fraud in the UI program, SWAs could 
benefit from more direction and assistance from ETA to identify and address 
suspected fraudulent activity. This is even more critical when federal funds are at 
stake—such as with the key UI programs authorized by the CARES Act that 
provided an unprecedented level of funding and thus created an increased risk of 
UI program fraud and abuse. ETA needs to take a leading role in collecting UI 
claimant data from states, performing risk assessments, and identifying high-risk 
areas. This will allow the agency to be better positioned to effectively assist 
states with developing response activities to address ever-evolving fraud risks 
that threaten the integrity of the UI program.  
RECOMMENDATIONS 
We recommend the Assistant Secretary for Employment and Training:  
 
1. Evaluate fraud risk mitigation strategies and actions on a quarterly basis to 
determine their effectiveness and document the results accordingly, in 
compliance with the processes set forth in ETA’s UI Integrity Strategic 
Plan. 
 
2. Issue guidance to states to address the issue of inconsistent reporting of 
overpayments involving identity fraud. 
 
3. Identify the states that have not complied with ETA 227 reporting 
requirements for FPUC and PEUC and ETA 902P reporting requirements 
for PUA and work with the states to ensure fraudulent overpayments for 
the CARES Act UI programs are reported before the commencement of 
DOL’s Fiscal Year 2025 financial statement audit. 

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Analysis of ETA’s Comments 
In response to the draft of this report, ETA generally agreed with our three 
recommendations to improve its oversight of states’ efforts to identify fraudulent 
UI claims filed by multistate claimants. Specifically, ETA partially agreed with 
Recommendation 1 and fully agreed with Recommendations 2 and 3. ETA also 
expressed concerns regarding the findings of our report. We carefully reviewed 
ETA’s response in full; our report was accurate as stated, thus the agency’s 
response did not result in any material changes to our reported results or 
conclusions. Synopses of ETA’s comments on our recommendations and 
findings along with our corresponding responses follow: 
 
• ETA partially agreed with Recommendation 1 and stated it updates, 
oversees, and communicates its UI anti-fraud strategies through the UI 
Integrity Strategic Plan and tracks the actions to implement each strategy 
quarterly. However, ETA disagreed that it should evaluate the 
effectiveness of each strategy quarterly. ETA stated that a quarterly 
evaluation is not practicable because most anti-fraud strategies are unable 
to be implemented in a single quarter, and typically span multiple quarters 
and in some cases, multiple years. In addition, ETA asserted that a 
quarterly evaluation of a strategy—which takes 6 months or more to have 
an effect or has a statutorily required annual reporting cadence—would 
not be valuable and would be a waste of resources.  
 
ETA stated its current practice is to assess the effectiveness of each anti-
fraud strategy after the strategy is fully implemented. Given that ETA 
tracks the actions toward implementation for each fraud risk mitigation 
strategy on a quarterly basis in the UI Integrity Strategic Plan and has a 
process in place to ensure anti-fraud strategies are assessed for 
effectiveness upon full implementation, ETA respectfully requested that 
this recommendation be considered for closure. The implementation date 
for this recommendation was September 1, 2024, when ETA committed to 
assessing and evaluating anti-fraud strategies upon implementation and 
reported this process to GAO to close its open UI fraud risk management 
recommendations. 
 
o We disagree that ETA’s proposed corrective action fully meets the 
intent of our recommendation. ETA’s FY 2025 UI Integrity Strategic 
Plan states strategies and actions are tracked and evaluated each 
quarter to determine their effectiveness. Therefore, ETA should 
adhere to the process described in the UI Integrity Strategic Plan. 
In addition, ETA stated its process ensures anti-fraud strategies are 
assessed for effectiveness upon full implementation. According to 

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the FY 2023 UI Integrity Strategic Plan, these anti-fraud strategies 
and processes for assessing these strategies have been in place 
since October 2022. As of July 17, 2025, these strategies had been 
in place for 31 months, which should be sufficient time to fully 
implement and subsequently assess for effectiveness. However, 
ETA was unable to provide such written assessments upon 
request. 
 
• ETA agreed with Recommendation 2 and stated it will issue additional 
guidance to address inconsistent reporting of overpayments involving 
identity fraud. 
 
o We determined that ETA’s proposed corrective action to issue 
guidance to address inconsistent reporting of overpayments 
involving identify fraud meets the intent of our recommendation.  
 
• ETA agreed with Recommendation 3, but it stated this recommendation 
duplicated a recommendation in the OIG’s May 2021 report.38 Specifically, 
the OIG previously recommended ETA: (1) assist states with claims, 
overpayment, and fraud reporting to create clear and accurate information 
and (2) use the overpayment and fraud reporting to prioritize and assist 
states with fraud detection and recovery. ETA stated it has and continues 
to provide targeted technical assistance to states on establishing, 
reporting, and recovering overpayments.  
 
o We determined that ETA’s proposed corrective action meets the 
intent of our recommendation. The OIG closed the previous 
recommendation in its May 2021 report. While Recommendation 3 
may be duplicative of the recommendation in the OIG’s previous 
report, we determined it was necessary to issue a similar 
recommendation because the OIG closed its previous 
recommendation. Further, as of June 2025, 4 years after the OIG 
published its report, we found the overpayment reporting issue 
persisted. 
 
• ETA also provided a comment on the audit finding. The agency stated the 
draft report conveyed a misconception that because ETA did not require 
the SWAs to report the results of research or investigations regarding 
each individual claimant contained in the OIG’s claimant data, ETA did not 
generally assess performance regarding UI eligibility determinations. ETA 
 
38 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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stated it conducted extensive monitoring of states’ administration and 
operation of UI programs and has established program performance 
measures to assess the timeliness and quality of SWAs’ adjudications of 
UI claims.  
 
In addition, ETA disagreed with the draft report assertion that ETA’s 
decision not to monitor the results of SWAs’ research and investigations of 
the referred potentially fraudulent claims was inconsistent with its 
collaborative position expressed to the OIG. ETA asserted that it never 
discussed with the OIG nor committed to following up with each SWA on 
their investigations of every claim included in the OIG’s claimant data, as 
this was not ETA’s intent.  
 
Further, ETA stated it completed an initial study to identify opportunities 
for improvement of the IDH. ETA stated it would also continue to explore 
other opportunities, including, but not limited to, seeking Congressional 
authority to require states’ use of certain anti-fraud tools, such as the IDH. 
ETA requested the OIG’s support in this endeavor and any other ideas or 
suggestions to strengthen the UI system and further bolster the program 
against fraud. 
 
o We disagree that the draft report concluded ETA did not assess 
performance regarding UI eligibility determinations. In the draft 
report, we stated without knowledge of the states’ investigative 
results, ETA’s ability to assess UI program performance is 
impaired, or weakened. Further, in ETA’s transmission of the OIG’s 
claimant data to the states, it informed the SWAs that it was 
committed to work with states to combat the sophisticated imposter 
fraud impacting the UI system. The transmission of claimant data 
with investigative instructions alone was insufficient. ETA’s 
monitoring of the SWAs’ investigative results was necessary to 
confirm the extent to which fraud existed in the high-risk fraud 
areas identified by the OIG.  
 

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The agency’s response to the draft report is included in its entirety in Appendix B. 
We appreciate the cooperation and courtesies ETA extended to us during this 
audit. 
 
  
Regis & Associates, PC  
Washington, DC 
August 4, 2025 

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EXHIBIT: TESTING RESULTS, FRAUDULENT AND 
NONFRAUDULENT PAYMENTS FOR THE 10 SWAS 
Table 2: Fraudulent and Nonfraudulent Payment Breakdown of Multistate 
Claimants for 10 SWAs 
 
State  
Total 
Claimants 
Sampled 
Total Benefit 
Payments 
Number of 
Nonfraudulent 
Claimants 
Nonfraudulent 
Amounts Paid 
Number of 
Fraudulent 
Claimants 
Fraudulent 
Amounts 
Paid 
Alabama 
10 
$16,761  
4 
$15,109  
6 
$1,652  
California 
72 
$455,447  
64 
$338,713  
8 
$116,734  
Connecticut 
10 
$81,287  
9 
$74,162  
1 
$7,125  
District of 
Columbia 
10 
$135,151  
10 
$135,151  
0 
$0  
Florida 
11 
$57,855  
2 
$13,800  
9 
$44,055  
Illinois 
13 
$170,142  
8 
$108,520  
5 
$61,622  
Iowa 
10 
$142,622  
10 
$142,622  
0 
$0  
New York 
17 
$212,729  
6 
$85,230  
11 
$127,499  
Texas 
18 
$178,171  
12 
$132,570  
6 
$45,601  
Virgin 
Islands 
10 
$180,070  
10 
$180,070  
0 
$0  
Totals 
181 
$1,630,235  
135 
$1,225,947  
46 
$404,288  
Source: Regis’ analysis based on SWAs’ responses to questionnaires. 
 
 

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Table 3: Fraudulent Payment Breakdown of Multistate Claimants and Other 
Fraudulent Reasons* for 10 SWAs 
 
State  
Number of 
Fraudulent 
Claimants 
Fraudulent 
Amounts Paid 
Number of 
Multistate 
Claimants 
Total Paid 
to 
Multistate 
Claimants 
Number of 
Claimants 
with Other 
Reasons  
Total Paid 
to 
Claimants 
with Other 
Reasons 
Alabama 
6 
$1,652  
0 
$0  
6 
$1,652  
California 
8 
$116,734  
0 
$0  
8 
$116,734  
Connecticut 
1 
$7,125  
0 
$0  
1 
$7,125  
District of 
Columbia 
0 
$0  
0 
$0  
0 
$0  
Florida 
9 
$44,055  
0 
$0  
9 
$44,055  
Illinois 
5 
$61,622  
2 
$41,130  
3 
$20,492  
Iowa 
0 
$0  
0 
$0  
0 
$0  
New York 
11 
$127,499  
4 
$12,694  
7 
$114,805  
Texas 
6 
$45,601  
0 
$0  
6 
$45,601  
Virgin 
Islands 
0 
$0  
0 
$0  
0 
$0  
Totals 
46 
$404,288  
6 
$53,824  
40 
$350,464  
*Other fraudulent reasons include identity fraud and bank account fraud. 
Source: Regis’ analysis based on SWAs’ responses to questionnaires. 
 

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APPENDIX A: SCOPE AND METHODOLOGY 
Scope 
The audit covered the actions taken by ETA and SWAs from April 7, 2021, 
through September 15, 2022, to address OIG-identified, potentially fraudulent 
CARES Act UI claims filed by multistate claimants from March 2020 through 
October 2020. To ensure currency and relevance, we also reviewed updated 
ETA guidance and UI payment reporting activities that extended outside of the 
audit period. 
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. 
 
We obtained and reviewed the CARES Act and SWAs’ policies and procedures 
related to the UI claims process, establishment and recovery of overpayments, 
and identification of fraudulent or nonfraudulent payments. We submitted process 
review and internal control questionnaires to the 10 SWAs to gain an 
understanding of the SWAs’ internal control tools used to investigate potentially 
fraudulent claimants. We also conducted walkthroughs to gain a better 
understanding of SWAs’ internal controls that were considered significant to the 
audit objective. 
 
Additionally, we obtained and reviewed ETA’s UIPLs and guidance provided to 
the states on investigation of the potentially fraudulent multistate UI claims that 
the OIG identified. Furthermore, we submitted detailed testing questionnaires to 
10 SWAs for each of the selected 181 UI claimants. We used the questionnaires 
to determine the SWAs’ actions to address the OIG-identified potentially 
fraudulent CARES Act UI claims filed by multistate claimants. Based on each 
SWA’s response, we categorized the claims as having been determined by the 
state to be either fraudulent or nonfraudulent. We also separated fraudulent 
claims attributable to the claimants who filed in multiple states from fraudulent 
claims for other reasons. 

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Selection of SWAs 
We conducted an in-depth examination of 10 OIG-selected SWAs—Alabama, 
California, Connecticut, Florida, Illinois, Iowa, New York, and Texas; the District 
of Columbia; and the U.S. Virgin Islands. The OIG selected this sample based on 
the highest per capita benefits paid. The OIG calculated per capita benefits using 
the number of claimants flagged for multistate claims and the benefit amounts 
paid to these claimants. The OIG then ranked the SWAs by the per capita 
amount, largest to smallest, and selected the top 10 SWAs. The OIG also 
controlled for repetition of SWAs within other high-risk areas. Therefore, the OIG 
did not select the same SWAs if they appeared in a higher ranked risk area, 
resulting in the selection of 10 different SWAs for each of the four high-risk 
audits. The OIG ranked the high-risk areas from highest to lowest: multistate 
claimants, deceased persons’ SSNs, suspicious email accounts, and federal 
prisoners’ SSNs. In addition, we surveyed the remaining 43 SWAs and Guam39 
to obtain information on processes related to investigating and reporting 
fraudulent UI claims filed in multiple states. 
Data Reliability 
We conducted tests to determine the reliability of UI claimant data provided by 
the SWAs related to UI claims filed by multistate claimants. To assess the 
reliability of the data, we performed procedures to test for completeness, 
accuracy, consistency, and validity. This included corroborating the claimant data 
against the SWAs’ UI systems records, including evidence of payment and other 
evidence provided by the SWAs. The supporting evidence was used to confirm 
whether the claims were paid, the determination made on whether a claim was 
fraudulent or nonfraudulent, and the status of any ongoing fraud investigation, et 
cetera.  
 
We also provided the SWAs with questionnaires to provide responses related to 
each of the selected claimants. We then reviewed the responses to ensure they 
were consistent with the supporting documentation. When necessary, we held 
meetings and requested additional documentation to substantiate the validity of 
the claimant data and responses provided. 
Internal Controls 
We obtained an understanding of SWAs’ internal controls, including information 
technology and systems, that were considered significant to the audit objective. 
We used our understanding of the internal controls to help design audit 
procedures relevant to the audit objective and not to provide assurance on the 
 
39 We sent out surveys to 43 SWAs and Guam. We excluded the 10 SWAs subject to in-depth 
examination. Of the 43 SWAs and Guam surveyed, 28 SWAs (64 percent) responded.  

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internal controls. Consequently, we did not express an opinion on ETA’s or 
SWAs’ internal controls. Our consideration of internal controls for SWAs to 
address the risks associated with fraudulent claims filed in multiple states would 
not necessarily disclose all matters that might rise to the level of significant 
deficiencies.  
Sampling 
We used sampling in this audit to evaluate ETA’s and SWAs’ efforts to address 
potentially fraudulent UI claims filed in multiple states. We extracted a random 
stratified sample of claimants from the selected states to determine whether 
corrective actions were taken. We determined the sample size using statistical 
sampling that factored a desired precision of 5 percent, a confidence level of 
95 percent, and an expected error rate of 10 percent to select sample claimants 
from the population. Per statistical sample size standards, we used 10 as the 
sample size for states with a calculated sample size less than 10.  
Criteria 
• Coronavirus Aid, Relief, and Economic Security Act, 
Public Law 116-136 (March 27, 2020) 
• Continued Assistance for Unemployed Workers Act of 2020, 
Subchapter VI, Section 261, Mixed Earner Unemployment Compensation  
(December 27, 2020) 
• American Rescue Plan Act of 2021, including Title IX, Subtitle A, Crisis 
Support for Unemployed Workers, Public Law 117-2 (March 11, 2021) 
• GAO-14-704G, Standards for Internal Control in the Federal Government 
(September 2014) 
• GAO-15-593SP, A Framework for Managing Fraud Risks in Federal 
Programs (July 2015) 
• GAO-22-105051, COVID-19: Additional Actions Needed to Improve 
Accountability and Program Effectiveness of Federal Response 
(October 27, 2021) 
• UIPL No. 15-20, Coronavirus Aid, Relief, and Economic Security (CARES) 
Act of 2020—Federal Pandemic Unemployment Compensation (FPUC) 
Program Operating, Financial, and Reporting Instructions (April 4, 2020) 
• UIPL No. 16-20, Coronavirus Aid, Relief, and Economic Security (CARES) 
Act of 2020—Pandemic Unemployment Assistance (PUA) Program 
Operating, Financial, and Reporting Instructions (April 5, 2020) 
• UIPL No. 17-20, Coronavirus Aid, Relief, and Economic Security (CARES) 
Act of 2020—Pandemic Emergency Unemployment Compensation 
(PEUC) Program Operating, Financial, and Reporting Instructions 
(April 10, 2020) 

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• UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) 
Program and the UI Programs Authorized by the Coronavirus Aid, Relief, 
and Economic Security (CARES) Act of 2020 - Federal Pandemic 
Unemployment Compensation (FPUC), Pandemic Unemployment 
Assistance (PUA), and Pandemic Emergency Unemployment 
Compensation (PEUC) Programs (May 11, 2020) 
• UIPL No. 16-21, Identity Verification for Unemployment Insurance (UI) 
Claims (April 13, 2021) 
• UIPL No. 20-21, Change 1, Additional State Instructions for Processing 
Waivers of Recovery of Overpayments under the Coronavirus Aid, Relief, 
and Economic Security (CARES) Act, as Amended (February 7, 2022) 
• UIPL No. 28-20, Change 4, Support for States to Resolve Outstanding 
Items from the Expired Coronavirus Aid, Relief, and Economic Security 
(CARES) Act Unemployment Compensation (UC) Programs, Including 
Additional Funding to Assist States with Reporting and Detection and 
Recovery of Overpayments (July 22, 2022) 
• UIPL No. 05-24, Application of State Finality Laws Regarding Temporary 
Unemployment Compensation (UC) Programs under the Coronavirus Aid, 
Relief, and Economic Security (CARES) Act (December 29, 2023) 
• Training and Employment Notice No. 32-23, Unemployment Insurance 
(UI) Fraud Risk Management Resources (June 27, 2024) 
Prior Relevant Coverage 
During the last 4 years, the OIG has issued 8 reports of significant relevance to 
the subject of this report, as follows: 
 
1. Alert Memorandum: The Employment and Training Administration 
(ETA) Needs to Ensure State Workforce Agencies (SWA) Implement 
Effective Unemployment Insurance Program Fraud Controls for High-Risk 
Areas, Report No. 19-21-002-03-315 (February 22, 2021), available at: 
https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-315.pdf; 
 
2. 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; 
 
3. Alert Memorandum: The Employment and Training Administration Needs 
to Issue Guidance to Ensure State Workforce Agencies Provide 
Requested Unemployment Insurance Data to the Office of Inspector 
General, Report No. 19-21-005-03-315 (June 16, 2021), available at:  
https://www.oig.dol.gov/public/reports/oa/2021/19-21-005-03-315.pdf; 
 

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4. Alert Memorandum: The Employment and Training Administration Needs 
to Ensure States Workforce Agencies Report Activities Related to CARES 
Act Unemployment Insurance Programs, Report No. 19-22-004-03-315 
(August 2, 2022), available at: 
https://www.oig.dol.gov/public/reports/oa/2022/19-22-004-03-315.pdf; 
 
5. Alert Memorandum: Potentially Fraudulent Unemployment Insurance 
Payments in High-Risk Areas Increased to $45.6 Billion,  
Report No. 19-22-005-03-315 (September 21, 2022), available at 
https:///www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-315.pdf; 
 
6. 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; 
 
7. COVID-19: ETA Can Improve its Oversight to Ensure Integrity over 
CARES Act UI Programs, Report No. 19-23-011-03-315 
(September 22, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-011-03-315.pdf; and 
 
8. Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability 
to Improve Oversight of the Unemployment Insurance Program, 
Report No. 19-23-012-03-315 (September 25, 2023), available at: 
https://www.oig.dol.gov/public/reports/oa/2023/19-23-012-03-315.pdf. 

U.S. Department of Labor – Office of Inspector General 
 
HIGH-RISK AUDITS: UI CLAIMS FILED IN MULTIPLE STATES 
 
-40- 
NO. 19-25-004-03-315 
 
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT 
The agency’s response to our draft report follows. 
 

U.S. Department of Labor     
Employment and Training Administration
      200 Constitution Avenue, N.W. 
Washington, D.C.  20210
MEMORANDUM FOR:
LAURA B. NICOLOSI   
Assistant Inspector General for Audit 
FROM:
LORI FRAZIER BEARDEN
Acting Assistant Secretary for Employment and Training 
SUBJECT:
Response to Draft Report – COVID-19:  ETA Needs to Improve Its 
Oversight of States’ Efforts to Identify Multistate UI Fraud, Report 
No. 19-25-XXX-03-315 
The U.S. Department of Labor’s (DOL) Employment and Training Administration (ETA) 
appreciates the opportunity to respond to the above-referenced draft report.  
In the draft report, DOL’s Office of Inspector General (OIG) reviewed the extent to which ETA 
and State Workforce Agencies (SWA) addressed potentially fraudulent claims filed by multi-state 
claimants.  The Administration acknowledges that there is still much work to be done to reduce 
fraud, waste, and abuse in the unemployment insurance (UI) program.  ETA is committed to this 
goal and continues to take important steps to this end.  For example, ETA has invested in the UI 
Integrity Center’s Integrity Data Hub (IDH) and dedicated resources for significant progress 
during the pandemic, incorporated additional data sources, and worked with the UI Integrity 
Center and states to re-evaluate risk scoring investigation prioritization.   
ETA would like to clarify a few areas in the draft report.  The draft report acknowledges that ETA 
provided the OIG’s files containing potentially fraudulent multistate claimants to SWAs and 
agreed to collaborate with the SWAs to combat the sophisticated imposter fraud affecting the UI 
system.  ETA agreed to share the OIG-analyzed claims data with the SWAs as potential fraud tips 
for the SWAs to conduct further appropriate investigations and actions regarding these claims.  
However, the draft report conveys a misconception that because ETA did not require the SWAs to 
report the results of research or investigations regarding each individual claim contained in the 
OIG files, ETA does not, in general, assess performance regarding UI eligibility determinations.  
The OIG’s draft report also asserts that ETA’s decision not to monitor the results of SWAs’ 
research and investigations of the referred potentially fraudulent claims was inconsistent with its 
collaborative position expressed to the OIG.  ETA disagrees with both assumptions.   
ETA conducts extensive monitoring of the states’ administration and operation of UI programs 
and has established program performance measures to assess the timeliness and quality of 
adjudications made by SWAs.  Further, ETA never discussed with the OIG, nor committed to 
following up with each state regarding the SWA’s investigation of every claim in the OIG files.  
This was not the intent when ETA agreed to share the OIG-analyzed claims data with states.

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Lastly, ETA has also completed an initial study to identify further opportunities for improvement 
in the IDH.  ETA will also continue efforts to explore potential avenues to address ongoing 
opportunities, including, but not limited to, seeking Congressional action.  ETA has limited 
statutory authority to require states’ use of certain fraud fighting tools, such as the IDH.  ETA 
requests the OIG’s support to help move things in a positive direction.  ETA welcomes any 
specific ideas or suggestions that the OIG may have to strengthen the UI system and to further 
bolster the program against fraud. 
Responses to the Recommendations
 
Please find below each of the recommendations contained in the draft report, followed by ETA’s 
response to each of the recommendations. 
 
Recommendation 1:  Evaluate fraud risk mitigation strategies and actions on a quarterly 
basis to determine their effectiveness and document the results accordingly, in compliance 
with the processes set forth in ETA’s UI Integrity Strategic Plan. 
 
ETA Response:  ETA agrees with this recommendation for fully implemented fraud risk 
mitigation strategies.  As acknowledged in the draft report, ETA currently updates, oversees, and 
communicates its UI anti-fraud strategies through the UI Integrity Strategic Plan, and tracks the 
actions to implement each strategy on a quarterly basis.   
 
However, ETA disagrees with the part of the recommendation regarding evaluating the 
effectiveness of each strategy on a quarterly basis.  This approach is generally not practicable as 
most antifraud strategies are unable to be implemented in a single quarter, and typically span 
multiple quarters and, in some cases, multiple years.  Many strategies require more than a single 
quarter of implementation before evaluation is possible, or the response cadence is simply 
greater than a month.  Quarterly evaluation of a strategy with a statutorily required annual 
reporting cadence, or which takes six months or more to have effect, would not have value and 
would be a waste of taxpayer resources.  In other cases, a strategy cannot undergo evaluation to 
determine its effectiveness until the strategy is fully implemented.
 
ETA’s current practice is to assess the effectiveness of each antifraud strategy after the strategy 
is fully implemented.  Fraud risk mitigation is a constant and ever-evolving process that requires 
assessing risks, designing and implementing strategies and control activities to mitigate assessed 
risks, and continuous evaluation of outcomes to adapt activities and improve the risk responses.   
 
Given that ETA already tracks the actions toward implementation for each fraud risk mitigation 
strategy on a quarterly basis in the UI Integrity Strategic Plan and has a process in place to 
ensure anti-fraud strategies are assessed for effectiveness upon full implementation, ETA 
respectfully requests that this recommendation be considered for closure.  The implementation 
date for this recommendation was September 1, 2024, when ETA committed to assessing and 
evaluating antifraud strategies upon implementation and reported this process to the Government 
Accountability Office (GAO) to close the GAO’s open UI fraud risk management 
recommendations. 
 
 

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Recommendation 2:  Issue guidance to states to address the issue of inconsistent reporting 
of overpayments involving identity fraud.
ETA Response:  ETA agrees with this recommendation.  ETA will issue additional guidance to 
address inconsistent reporting of overpayments involving identity fraud.  
The Administrator for the Office of Unemployment Insurance is responsible for the 
implementation of this recommendation.  The anticipated completion date for this 
recommendation is the end of Fiscal Year (FY) 2025. 
Recommendation 3:  Identify the states that have not complied with ETA 227 reporting 
requirements for [Federal Pandemic Unemployment Compensation] FPUC and [Pandemic 
Emergency Unemployment Compensation] PEUC and ETA 902P reporting requirements 
for [Pandemic Unemployment Assistance] PUA and work with the states to ensure 
fraudulent overpayments for the [Coronavirus Aid, Relief, and Economic Security] 
CARES Act UI programs are reported before the commencement of DOL’s Fiscal Year 
2025 financial statement audit. 
ETA Response:  ETA agrees with this recommendation but considers this recommendation 
duplicative of a prior OIG recommendation that ETA is in the process of addressing from OIG 
Report Number 19-21-004-03-315 0F1.  Specifically, Recommendation 3 from this earlier audit 
report states, “Assist states with claims, overpayment, and fraud reporting to create clear and 
accurate information.  Then use the overpayment and fraud reporting to prioritize and assist 
states with fraud detection and recovery.”   
 
ETA acknowledges states struggled to report overpayments accurately during the early stages of 
the pandemic.  ETA has and continues to provide targeted technical assistance to states on 
establishing, reporting, and recovering overpayments.  In fact, in the draft report, the OIG 
commends ETA for continuing to work with the states to identify and report fraudulent 
overpayments in the CARES Act UI programs.
The Administrator for the Office of Unemployment Insurance is responsible for the 
implementation of this recommendation.  The anticipated completion date for this 
recommendation is the end of FY 2026. 
 
 
 
1 OIG Report No. 19-21-004-03-315, COVID-19:  States Struggled to Implement CARES Act Unemployment Insurance 
Programs, issued May 28, 2021, https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf.  

 
 
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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