Court filing
Performance Audit Report: ETA Did Not Ensure ARPA Grants Demonstrated Improvements in Access to Unemployment Benefits (DOL OIG, August 2025)
Record facts
| Court | U.S. Department of Labor, Office of Inspector General |
|---|---|
| Filed | 2025-08-28 |
Summary
A performance audit report issued August 28, 2025 by the U.S. Department of Labor, Office of Inspector General to the Employment and Training Administration, Report Number 19-25-006-03-315. The report states the American Rescue Plan Act of 2021 provided DOL $1 billion to prevent and detect fraud, promote equitable access and ensure timely payment of unemployment insurance benefits, and that ETA awarded $219 million in equity grants to 46 states. It finds ETA awarded more than $20.7 million for 16 projects whose applications did not provide evidence of a UI access issue, identified as funds for better use, and that three sampled states with closed-out grants did not achieve all expected outcomes, with more than $2.8 million claimed as questioned costs. It also finds ETA did not effectively monitor grant reporting. The report makes four recommendations, which ETA agreed with.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
REPORT TO THE
EMPLOYMENT AND TRAINING
ADMINISTRATION
ETA DID NOT ENSURE ARPA GRANTS
DEMONSTRATED IMPROVEMENTS IN
ACCESS TO UNEMPLOYMENT BENEFITS
DATE ISSUED: AUGUST 28, 2025
REPORT NUMBER: 19-25-006-03-315
BRIEFLY…
ETA DID NOT ENSURE
ARPA GRANTS DEMONSTRATED
IMPROVEMENTS IN ACCESS TO
UNEMPLOYMENT BENEFITS
Why We Did the Audit
The American Rescue Plan Act of
2021 (ARPA) provided DOL $1 billion in
funding to prevent and detect fraud,
promote equitable access, and ensure
timely payment of unemployment
insurance (UI) benefits. Subsequently,
the Employment and Training
Administration (ETA) awarded
$219 million in first-of-their-kind grants
to 45 states and the District of
Columbia (states) to promote equitable
access to UI programs.
We are aware Executive Order 14151
may impact the future of this specific
grant program. However, because our
audit focused on grant implementation
and performance measurement, our
results are not isolated to these grants
and can help inform ETA’s grant
governance practices agencywide.
Based on prior OIG audits, we were
concerned about ETA’s ability to deploy
this grant funding. Therefore, we
performed an audit to determine:
To what extent did ETA administer
these grants in accordance with
ARPA and DOL’s objectives for UI
access, and are grant recipients on
target to achieve performance
outcomes?
Read the Full Report
For more information, go to:
https://www.oig.dol.gov/public/reports/o
a/2025/19-25-006-03-315.pdf.
What We Found
While ETA designed these grants in accordance with ARPA and
DOL goals and objectives, we found ETA did not ensure the grants
demonstrated improvements in access to UI benefits nor were they
awarded in a way that would maximize impact of the funding. This
was inconsistent with ETA guidance and federal law on government
performance and results. Specifically, ETA awarded more than
$20.7 million in ARPA funding for 16 projects that failed to provide
evidence of the existence of a UI access issue in their state’s grant
application. We identified those monies as funds for better use. This
occurred because ETA did not establish effective criteria for
reviewing grant applications. Consequently, a risk exists that
completed and ongoing state projects may demonstrate limited to
no impact on improving access to UI benefits.
In addition, ETA did not ensure states reported complete and
accurate outcome metrics and status updates in quarterly progress
reports. Of 10 sampled states with closed-out grants, 3 did not
achieve all expected outcomes; we are claiming a total of more than
$2.8 million as questioned costs and recommend recovery. Further,
based on the latest quarterly progress reports reviewed, two
sampled states with active grants (still within their period of
performance) were either not on target to achieve all project goals
or their status was unknown. These problems occurred because
ETA did not effectively monitor grant reporting and performance.
Incomplete reporting of outcome metrics and inaccurate status
updates can hinder ETA’s ability to perform real-time monitoring,
provide timely interventions, and demonstrate the grants achieved
their goals.
Finally, ETA’s grant rollout was inefficient and the design was
duplicative of another program. Specifically, ETA announced these
grants and subsequently announced another ARPA grant
opportunity—Tiger Team grants. Both programs had similar goals
and required separate assessments of the same UI environment to
inform grant activities. However, ETA did not coordinate the two
opportunities in a way that would maximize the impact of the grant
funding. This prevented synergies between the two programs where
Tiger Team recommendations could have informed grant projects,
mitigated duplication of efforts, and increased project effectiveness.
What We Recommended
We made four recommendations to ETA to improve grant
governance in the areas of awarding, monitoring, and planning as
well as funds recovery. Specifically, we recommended ETA:
establish a policy requiring evaluation criteria to ensure grant
applications include appropriate evidence; develop additional
guidance and staff training to improve monitoring; review and
recover $2.8 million in questioned costs; and develop guidance for
the planning of new discretionary grant programs. ETA agreed with
and provided corrective action information in response to all four
recommendations.
U.S. Department of Labor – Office of Inspector General
-i-
TABLE OF CONTENTS
INSPECTOR GENERAL’S REPORT .................................................................... 1
RESULTS ............................................................................................................. 2
ETA Did Not Ensure States Provided Evidence of UI Access Issues
in Grant Applications .................................................................................. 3
ETA Did Not Ensure Projects Reported Complete and Accurate
Information ................................................................................................. 6
ETA Did Not Effectively Administer ARPA Funding to Maximize
Impact ...................................................................................................... 11
CONCLUSION .................................................................................................... 13
OIG’S RECOMMENDATIONS ............................................................................ 14
Analysis of ETA’s Comments ................................................................... 14
EXHIBIT 1: GRANT AWARDS ............................................................................ 16
EXHIBIT 2: FUNDS FOR BETTER USE ............................................................. 17
EXHIBIT 3: QUESTIONED COSTS .................................................................... 18
APPENDIX A: SCOPE AND METHODOLOGY .................................................. 19
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ............................... 23
U.S. Department of Labor
Office of Inspector General
Washington, DC 20210
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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
This report presents the results of the U.S. Department of Labor (Department or
DOL) Office of Inspector General’s (OIG) audit of the Employment and Training
Administration’s (ETA) American Rescue Plan Act of 2021 (ARPA) grants,
specifically those intended to improve equitable access to unemployment
insurance (UI) benefits. ARPA provided $2 billion1 in funding to the Secretary of
Labor to prevent and detect fraud, promote equitable access, and ensure timely
payment of benefits. ETA subsequently awarded $219 million in first-of-their-kind
“equity” grants (grants) to 46 states2 to promote equitable access to UI programs.
The intended grant outcomes included more UI applications, improved service
delivery so claimants receive initial benefits in a timely manner, and a better
understanding of access challenges.
Based on prior OIG pandemic and grant audits, we were concerned about ETA’s
ability to deploy the $219 million provided for the first-of-their-kind grants.
Therefore, we conducted a performance audit to determine:
To what extent did ETA administer these grants in accordance with ARPA
and DOL’s objectives for UI access, and are grant recipients on target to
achieve performance outcomes?
To answer this question, we reviewed ETA’s design of the grant requirements in
Unemployment Insurance Program Letter (UIPL) 23-21 and ETA’s approval
process for awarding the grants. We also judgmentally selected a sample of
10 states based on state size to determine if ETA ensured states met its
requirements to receive funds. In those 10 states, we reviewed a total of
36 projects during the grant approval phase and 37 projects during the period of
1 The Fiscal Responsibility Act of 2023 established new discretionary spending limits, rescinded
unobligated funds, and expanded work requirements for federal programs. As a result, ARPA
funding to DOL was reduced from an initial $2 billion to $1 billion.
2 This number includes the District of Columbia as a recipient as does our sample. See Exhibit 1.
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performance phase (see Exhibit 1).3 We also reviewed quarterly progress reports
for six quarters4 to determine whether states reported on their performance
metrics and were on target to achieve the outcomes in their grant agreements.
Additionally, we interviewed ETA national and regional staff. See Appendix A for
more details on scope and methodology.
We are aware a recent executive order5 may impact the future of this specific
grant program. However, because our audit focused on implementation and
performance measurement of the grants, our results are not isolated to these
grants and can help inform ETA’s grant governance practices agencywide.
RESULTS
While ETA designed these grants in accordance with ARPA and DOL goals and
objectives, we found ETA did not ensure the grants demonstrated improvements
in access to UI benefits nor were the grants awarded in a way that would
maximize impact of the funding. This was inconsistent with ETA guidance and
federal law on government performance and results.
Specifically, ETA awarded more than $20.7 million in ARPA funding for
16 projects that failed to provide evidence demonstrating the existence of a UI
access issue in their state’s grant application. We identified those monies as
funds for better use (see Exhibit 2). This occurred because ETA did not establish
effective criteria for reviewing grant applications. Consequently, a risk exists that
completed and ongoing state projects may demonstrate limited to no impact on
improving access to UI benefits.
In addition, ETA did not ensure states reported complete and accurate outcome
metrics and status updates in quarterly progress reports. Of 10 sampled states
with closed-out grants, 3 did not achieve all expected outcomes; we are claiming
a total of more than $2.8 million as questioned costs and recommend recovery
(see Exhibit 3). Further, based on the latest quarterly progress reports reviewed,6
two of the seven remaining sampled states with active grants (still within their
3 After grant award, Texas cancelled one project and added two, expanding the total project count
from 36 to 37.
4 The audit team reviewed the quarterly progress reports for 6 quarters over a 2-year period of
performance for the grants in our sample, for quarters ending: June 2023, September 2023,
December 2023, March 2024, June 2024, and September 2024.
5 Executive Office of the President, Executive Order 14151 of January 20, 2025: Ending Radical
and Wasteful Government DEI Programs and Preferencing, available at:
https://www.federalregister.gov/executive-order/14151
6 Quarterly Performance Report dated September 2024
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period of performance) were either not on target to achieve all project goals or
their status was unknown. These problems occurred because ETA did not
effectively monitor grant reporting and performance. Incomplete reporting of
outcome metrics and inaccurate status updates can hinder ETA’s ability to
perform real-time monitoring, provide timely interventions, and demonstrate the
grants achieved their goals.
Finally, ETA’s rollout of these grants was inefficient and its grant design was
duplicative of another grant program. Specifically, ETA announced these grants
and subsequently announced another ARPA grant opportunity—Tiger Team
grants. Both grant programs had similar goals and required separate
assessments of the same UI environment to inform grant activities. However,
ETA did not coordinate the two grant opportunities in a way that would maximize
the impact of this funding. This prevented synergies between the two programs
where Tiger Team recommendations could have informed grant projects,
mitigated duplication of efforts, and increased project effectiveness.
ETA Did Not Ensure States Provided
Evidence of UI Access Issues in Grant
Applications
In 7 of the 10 states, we found ETA approved funding for 16 projects where the
grant application did not include evidence demonstrating the existence of the UI
issue they proposed to address. ETA required states to provide an assessment
within their grant applications of specific issues or problems that each project
would address. However, during its grant application review, ETA did not ensure
the states’ assessments included such evidence of the issues or problems.
Consequently, ARPA funds may have been spent on projects that did not
address actual issues or improve access for underserved claimant populations.
Overall, as a result, we determined more than $20.7 million in funding could have
been put to better use.
UIPL 23-21 included the requirement for that assessment and an explanation of
how their proposed use of funds would address the problem or issue.
Specifically, the UIPL specified states should provide evidence of a thorough
analysis of current operations and show the strategic design of each project
would meet state needs in promoting equitable access to UI programs.
In response to our audit observations, ETA officials clarified that:
providing specific U.S. Census information or data from other
government agencies or reputable sources (i.e., university or
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publication) was not required to receive an equity grant award
[and]
states were required to provide information or minimally sufficient
justification on current operations to improve/promote access to the
[UI] program.
For the 10 states we sampled, we found grant applications for 16 of 36 projects
(44 percent) did not contain evidence to demonstrate the existence of the specific
access-related issue(s) the project intended to address in the state. Despite the
lack of evidence of an assessment for these 16 projects, ETA awarded more
than $20.7 million in ARPA funding to 7 states for these projects.
For example, Pennsylvania received $4.9 million to hire in-person staff and
acquire iPads to improve in-person services. Pennsylvania’s grant application
stated it believed individuals at risk of not receiving equal service included
claimants:
• living in rural areas with limited internet infrastructure,
• with low income or facing poverty,
• without technological skills (limited education or older claimants),
• with limited literacy skills, and
• with limited English proficiency.
However, Pennsylvania provided no evidence—such as UI claimant data or
population or employment surveys available through the U.S. Census Bureau or
the Bureau of Labor and Statistics—to demonstrate the presence of these
populations or that these populations were underserved by the Pennsylvania UI
system.
We found this lack of evidence in grant applications from other states, also. For
example, Texas received $4.7 million to upgrade its legacy UI systems. In its
application, Texas stated:
The new UI system will be mobile responsive, making it easier to
service customers who only have a mobile phone or small tablet,
versus a computer. The system will provide all services in English
and Spanish, with limited services in other languages, while
providing customers information on how to obtain additional
services in their preferred language.
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The new UI system will provide more interactive access to
individuals by expanding the number of self-service options
available to them versus our current internet-based system. The
mobile responsiveness and ability to obtain services in other
languages are expected to increase the percentage of Limited
English Proficiency and lower-income groups using internet
services, who now prefer interacting…by telephone.
Like Pennsylvania, Texas did not provide any evidence indicating the populations
it was targeting were experiencing barriers to accessing UI programs. Without
this evidence, ETA could not ensure ARPA funds were correctly allotted to meet
the goals of its grant program.
ETA indicated it analyzed state assessments during the grant application review
process. However, its analysis was not effective in ensuring the states’
assessments included evidence supporting the issues the grants were intended
to address. This occurred because ETA did not establish criteria to ensure
reviewers sufficiently considered states’ assessments during the review process.
Neither ETA’s UIPLs nor its grants management guidance contained:
(1) language establishing criteria or quality standards related to assessments for
grant applications or (2) procedures for analyzing assessments provided by state
applicants. Further, while review teams met bi-weekly to discuss application
statuses, ETA provided only one formal training for reviewers and the training did
not detail how to determine the quality of a state assessment.
ETA stated that, in reviewing grant applications, it considered qualitative data in
addition to the limited quantitative data available, a compelling rationale, and / or
broader state data as sufficient for purposes of demonstrating suitability of an
equity grant activity. ETA also stated that:
requir[ing] a standardized assessment likely would have resulted in
significantly fewer states participating and that would have reduced
the impact of these grants. The Department had to pursue and
promote these grants to an exhausted system in the midst of a
global pandemic and had to meet states where they were.
While we recognize the circumstances in which these grants were issued, ETA
could have been more diligent in reviewing grant applications by requiring states
to provide evidence supporting the populations they intended to target for UI
program improvements using ARPA funds.
These grants were created to improve the delivery of UI services to people who
faced obstacles in accessing state systems and benefits. States that did not use
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a thorough, data-driven assessment of their UI operations to determine the
underlying causes or even the existence of access issues risked implementing
solutions with no demonstrated positive impact towards improving claimant
access. As a result, states’ efforts may not achieve the intended outcomes of the
grant program.
ETA Did Not Ensure Projects Reported
Complete and Accurate Information
During our review of quarterly progress reports, we found ETA did not ensure
states consistently reported all outcome metrics as required by their grant
agreements. Additionally, states reported inaccurate project status information,
which could hinder ETA’s ability to effectively assess the status of project
activities and overall grant progress. Without enforcement of complete and
accurate reporting, ETA faced significant challenges in determining whether
projects were meeting intended outcomes. This was evidenced by our review of
three states that were in the grant close-out phase as of March 2024. We found
these states did not achieve six of the goals outlined in their grant agreements,
aimed at resolving issues like claim backlogs, timeliness, and accessibility.
Further, we found two of the seven remaining states with active projects were in
danger of not meeting their goals.
UIPL 23-21 required states, in their grant applications, to identify outcome
metrics to demonstrate quantifiable improvements expected in their UI programs.
The UIPL also required each state to report on these metrics in quarterly
progress reports, which ETA would use to monitor each state’s progress towards
achieving the timelines and outcome metrics and completing the deliverables
established in the grant application. ETA would also use these reports to ensure
a state’s use of funds was consistent with permissible activities that the UIPL
outlined. States were required to submit a quarterly progress report for each
project funded through their grant.
Incomplete Reporting of Outcome Metrics
To determine whether states provided quarterly updates on projects and
outcome metrics as required by their grant agreements, we reviewed the
quarterly progress reports submitted by the 10 states, comprising a total of
37 projects.7 We found, on average, 92 percent of these projects did not report
on all required outcome metrics (see Table 1).
7 During the period of performance, Texas cancelled one project and added two, expanding the
total project count from 36 to 37 during the performance phase.
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Table 1: Percent of Active Projects Reporting Incomplete Outcome Metrics,
Quarters Ending June 2023–September 2024
Quarter Ending
Number of
Active Projects
Number of Projects
Reporting Incomplete
Outcome Metrics
Percentage
June 2023
18
16
89%
September 2023
20
17
85%
December 2023
20
19
95%
March 2024
23
22
96%
June 2024
22
20
91%
September 2024
21
20
95%
Totals
124
114
92%
Source: OIG analysis of quarterly progress reports
For example, Nevada’s grant agreement identified two outcome metrics for its
chatbot8 project: (1) reducing wait times for non-English speaking callers and
(2) reducing claimant errors. According to the project’s quarterly progress
reports, the chatbot went live on July 25, 2023. In addition, as of the
September 2024 progress report, this project was completed with all funds
expended. Although the project reported some general usage statistics, it had not
reported any metrics related to reducing wait times for non-English speaking
callers or claimant errors as required by its grant agreement.
In addition to the incomplete reporting, we also found one state, Texas, reported
outcome metrics for three projects that were inconsistent with the metrics
identified and approved in its grant application. These projects were required by
the grant agreement to report outcome metrics for “timeliness of first payment for
the limited English proficient” and “timeliness of first payment for lower-income
groups.” Instead of reporting these timeliness metrics, the projects instead
reported metrics for updating forms, callback options, and chat services. Two of
these metrics—for forms and chat services—were especially problematic
because they did not measure the impact on targeted populations.
Outcome metrics were necessary for measuring program improvements. These
metrics were incorporated into grant agreements to ensure states were
8 A chatbot is a computer program designed to simulate conversation with human users,
especially over the internet.
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accountable for tracking specific outcomes and improving their UI programs.
Incomplete reporting of outcome metrics can hinder ETA’s ability to perform
real-time monitoring and provide timely interventions.
Inaccurate Reporting of Project Status
To determine if states reported accurate information regarding project status, we
reviewed the quarterly progress reports submitted by the 10 states. We
compared each state’s self-assessment of project status—on schedule, behind
schedule, or complete—with the detailed narrative provided and found
discrepancies for 5 of the 10 states. Specifically, we identified nine instances
where states reported projects were on schedule, but the detailed report
narrative indicated they were behind schedule.
For example, Kansas reported a project to modernize its computer systems was
on schedule in its December 2023 quarterly progress report. However, the report
narrative indicated application development had fallen behind schedule. Kansas
was estimating a 4-month delay in completing updates to its benefits system and
a 4- to 6-month delay in completing updates to its tax system. On
December 11, 2023, Kansas requested a grant modification to extend its period
of performance end date from March 31, 2024, to August 31, 2024.
Similarly, Texas reported a project to improve its claimant “callback” system was
on schedule in its June 2023 quarterly progress report. However, the project was
originally planned to be completed 6 months earlier in January 2023. The project
was later updated to end in August 2023, but was still ongoing and behind
schedule in the September 2024 performance report. In January 2024, Texas
also requested a 1-year extension for all its projects, to March 31, 2025.
ETA needed to ensure states’ quarterly progress reports contained accurate
information, particularly project status information. This could help prevent
unnecessary delays, minimize extensions, and allow for intervention to ensure
states stayed on target with their goals. ETA officials stated the agency reviews
the quarterly progress reports and follows up with states, but the communications
are informal and not documented. However, these efforts were ineffective in
improving the quality of reported data or overall recipient performance.
Status of Closed-Out and Active Grants
In our review of the final or most recent quarterly progress reports for grants, we
found projects that failed to meet their goals or were in danger of not meeting
their goals. Notably, three states with closed-out grants did not achieve many of
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the objectives outlined in their grant agreements, underscoring the importance of
ensuring complete and accurate reporting for monitoring grant recipient
performance. We also found, as of September 2024, two of seven remaining
sampled grants were either not on target to achieve all project goals or their
status was not determinable due to insufficient data.
Closed-Out Grants
Three states had entered the grant close-out phase as of March 2024. We
reviewed the final quarterly progress reports for the 3 states and found 6 of the
10 total projects did not achieve or report achievement of project goals outlined in
their grant agreements. We are claiming more than $2.8 million in costs
associated with these projects as questioned costs and recommend recovery.
Details follow.
New Mexico
New Mexico received more than $1.65 million for two projects to eliminate a UI
workflow backlog and improve the timeliness and accuracy of claimant
information for Spanish-speaking and low literacy claimants who were submitting
claim information via phone calls. However, the projects’ final progress reports
did not state the workflow backlog had been eliminated nor did they include
specific, quantifiable data to measure an actual improvement for the targeted
populations.
District of Columbia
The District of Columbia received $1.8 million for three projects to improve
claimant communications through the implementation and evaluation of audit
recommendations, improve customer service through system upgrades, and
expand customer collection and demographics data through outreach and staff
training. However, the projects’ final progress reports did not state audit
recommendations had been implemented and evaluated, did not describe how
the system upgrades had improved customer service to targeted populations,
and did not indicate if staff had received training. Of this total, we are claiming
$654,000 for one project as funds for better use9 and the remaining
$1,176,000 as questioned costs.
9 This project was included in the “funds for better use” previously identified in this report. To
prevent double counting, we are not claiming questioned costs for this project.
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Pennsylvania
Pennsylvania received $1.9 million to eliminate a backlog of Pandemic
Unemployment Assistance appeals and improve timeliness. However, the
project’s March 2024 final progress report stated timeliness did not improve.
Although this project did not report achievement of its timeliness goal, we are not
claiming or recommending recovery of questioned costs because the state
successfully eliminated its backlog and only spent $231,080 toward this project
before it modified its grant to move the remaining funds to another project.
Active Grants
Of the remaining seven states, two states—Nevada and Texas—were in danger
of not meeting all the goals of their grants as of September 2024. Overall, we
identified that 3 of 14 projects in these 2 states were not on track to meet goals
or did not report sufficient information to determine if they were on track. Details
follow.
Nevada
In Nevada, the status of one project appeared to be behind schedule and lacked
measurable outcomes. The purpose of this project was to add nine additional
languages to claimant resources on the state’s website to reduce call center
volume and requests. Only the Spanish translation was reported complete, but
there were no reports on its impact, such as reducing claimant wait times or
improving call center efficiency. Also, Nevada’s September 2024 report stated
the other translations for the new UI system were still in testing and would not go
live until mid-2025. A request for an additional extension for the project was
pending due to ongoing delays and challenges.
Texas
The status of two projects in Texas was unclear. One project, focused on data
gathering and analysis, reported the same status for four consecutive quarters,
from June 2023 through March 2024, indicating the project was not on track. A
second project to improve the callback system had not updated its metrics from
September 2023 through September 2024. Accordingly, the project status was
unclear. The period of performance for the Texas grant was scheduled to end on
March 31, 2025.
While ETA officials informed us that they were in regular communication with
states regarding their performance outcomes, ETA’s efforts were ineffective in
improving the quality of reported data or overall recipient performance. ETA did
not ensure outcome metrics were consistently reported to demonstrate intended
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improvements. Additionally, inaccurate performance reports hindered ETA’s
ability to adequately assess project progress and outcomes.
ETA officials stated grant progress is not linear and they expect states to
complete requirements by the end of the grant period. Additionally, according to
ETA, states were dealing with other pandemic-related grants, initiatives, and
programs; capacity issues; and the impact of natural disasters.
However, we identified projects in our sample that had been closed during our
audit and had not achieved desired outcomes by the grant’s end. If ETA does not
ensure accurate, complete, and consistent reporting from grant recipients during
the period of performance, it will be unable to assess progress or provide timely
technical assistance or other mitigating actions. These ETA mitigating actions
can be crucial to ensure states quickly get back on track and accomplish the
goals and achieve improvements outlined in their grant agreements. Further,
without such reporting, ETA is unable to demonstrate improvements in UI access
for claimants.
ETA Did Not Effectively Administer ARPA
Funding to Maximize Impact
ETA did not effectively plan the rollout of two ARPA grant opportunities.
Specifically, ETA issued two grant opportunities with similar goals that required
separate assessments of the same UI environment. This occurred because ETA
did not coordinate the two grant opportunities in a way that would maximize the
impact of the funding. ETA stated it had endeavored to ensure states did not use
funds from both grants for the same types of projects, but its lack of coordination
between the two grants may have inhibited states from applying maximum effort
and funding toward the most significant issues.
Passed in March 2021, ARPA appropriated $2 billion10 to the Secretary of Labor
“to detect and prevent fraud, promote equitable access, and ensure the timely
payment of benefits with respect to unemployment compensation programs.”
This was the first time the Department received major resources to work
collaboratively with states to improve UI systems and processes to address
disparities in access to UI benefits that, according to ETA, have historically
delayed delivery of needed financial support to claimants. ETA used the money
to fund several grant opportunities for state workforce agencies, which included
$219 million for the equity grants and up to $200 million for Tiger Team grants.
10 The Fiscal Responsibility Act of 2023 established new discretionary spending limits, rescinded
unobligated funds, and expanded work requirements for federal programs. As a result, ARPA
funding to DOL was reduced from an initial $2 billion to $1 billion.
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In August 2021, ETA issued UIPL 23-21, announcing grants for states to promote
equitable access to UI programs, which included (1) eliminating administrative
barriers to benefit applications; (2) reducing state workload backlogs;
(3) improving the timeliness of UI payments to eligible individuals; and
(4) ensuring equity in fraud prevention, detection, and recovery activities.
Approximately 2 months later, via UIPL 02-22, ETA announced its Tiger Team
grants to support states in improving UI systems and processes. These grants
had similar goals: (1) promoting equitable access and (2) ensuring the timely
payment of benefits as well as activities to reduce workload backlogs. The
Tiger Team grants also added a goal of preventing, detecting, and recovering
funds from fraud. Both grant opportunities required an assessment of a state’s UI
environment, creating a duplication of efforts. Overall, 46 states received equity
funds and 34 of those 46 also received Tiger Team funds.
To support the Tiger Team grants, DOL established multidisciplinary teams of
experts, Tiger Teams, who conducted assessments of state UI systems and
processes and then made recommendations to help inform states’ use of grant
funding. However, since the notice for equity grants had already been issued,
states had to perform an independent assessment of their UI operations for use
in their applications. Additionally, Tiger Teams could only assess six states at a
time. This prevented states from using Tiger Teams’ recommendations to inform
their equity grant activities and created a duplication of efforts to assess UI
environments.
ETA officials stated the reason the Tiger Team grants were rolled out later is
because it needed time to develop the Tiger Team infrastructure, which included:
1. recruiting and hiring staff to support the Tiger Team initiative,
2. soliciting and acquiring contract support that would form the expert teams
to conduct the assessments and work with staff in developing
recommendations, and
3. establishing workflow processes for these engagements.
According to ETA officials, the timing and overall direction of the design of the
grants was led by DOL’s Office of UI Modernization and ETA was charged with
implementing the grants according to that direction. Moreover, ETA also stated it
faced significant external pressure to obligate the funds quickly.
However, the ARPA funds were available until expended, with no time limit on
the use of the funds. Additionally, as indicated by ETA, states were challenged in
dealing with other pandemic-related grants, initiatives, and programs; capacity
issues; and the impact of natural disasters. Because there was no time limitation,
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ETA could have dedicated more time to planning these grants. This might have
helped reduce duplication and improve efficiency in the rollout. Additionally, it
might have allowed states more time to address other challenges they faced.
ETA further stated, as equity grants were awarded, it endeavored to ensure no
duplication of work between the two types of grants. However, we found 34 of the
36 states that received funds for Tiger Team assessments had already
undertaken their state assessments as part of the equity grant application and
29 states had completed their assessments prior to engaging with the
Tiger Teams.
According to ETA, the data available to states to undertake an assessment of
their UI environment varied greatly, with ETA stating the UI system “lacks
significant and universal data on the issue of impacts on equity.” ETA also noted
the newness of the equity program was a major challenge. Accordingly,
Tiger Teams’ analyses of state UI systems and access challenges could have
been a critical tool for states to ensure equity grant funds targeted existing issues
within their states.
The Government Performance and Results Act states waste and inefficiency in
federal programs undermines the confidence of the American people in the
government and reduces the general government’s ability to adequately address
vital public needs. By issuing equity grants prior to Tiger Team grants, ETA did
not fully leverage its Tiger Teams to the best extent possible. In a data-lacking
environment, the Tiger Teams’ analysis could have helped inform states’ grant
actions. Tiger Teams were intended to aid states in assessing and understanding
underlying causes of inequitable access to UI so that states could then efficiently
use ARPA funds for maximum benefit toward the most significant issues.
Further, by creating two grant opportunities that required UI assessments, ETA
inefficiently deployed ARPA funds and facilitated the potential for duplication of
effort by states. Ultimately, ETA’s planning of these two grant opportunities may
have inhibited states from applying maximum effort and funding toward the most
significant issues.
CONCLUSION
In our audit of these grants, we identified areas where ETA can strengthen its
grant awarding, monitoring, and planning processes. We found ETA did not
effectively monitor the grants to ensure approved projects demonstrated
measurable improvements in access to UI benefits nor were the grants awarded
in a way that would maximize the impact of the funding. Overall, we identified
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more than $20.7 million in funds for better use plus more than $2.8 million in
questioned costs. Although a recent executive order may impact the future of this
specific grant program, our audit results can be used to help inform ETA’s grant
governance practices agencywide.
OIG’S RECOMMENDATIONS
We recommend the Assistant Secretary for Employment and Training:
1. Establish a policy that requires evaluation criteria or standards to be used
to ensure grant applications include evidence of a specific issue prior to
awarding a grant intended to address said issue.
2. Develop additional guidance and staff training to improve monitoring of
grant recipients, including a focus on reviewing progress reports to ensure
reporting complies with requirements and grant recipients are on target to
achieve grant goals as identified in the grant agreement.
3. Review $2,827,736 in costs for grant projects that did not achieve project
goals and recover funds where appropriate.
4. Develop guidance for planning new discretionary grant programs to
ensure better coordination, minimize duplication of effort, and promote
more efficient use of grant funds.
Analysis of ETA’s Comments
In response to a draft of this report, ETA agreed with our four recommendations,
which are intended to improve grant governance in the areas of awarding,
monitoring, and planning as well as funds recovery. ETA also stated it is already
taking corrective action as follows:
• For Recommendations 1 and 4, ETA communicated it had updated its
template language for future funding opportunity announcements.
Specifically, ETA added language to ensure grant applications include
evidence of specific issues and to improve efficiency and coordination
while reducing potential duplication of efforts;
• For Recommendation 2, ETA intends to incorporate the report
recommendations into future training for Federal Project Officers; and
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• For Recommendation 3, on funds recovery, ETA requested a slight
revision to the language, asserting its first step would be to review the
information we provided and then to recover any disallowed amounts.
We carefully reviewed ETA’s response. We also slightly adjusted the wording of
Recommendation 3 for clarity, as ETA’s suggestion was aligned with the
recommendation’s intent.
We look forward to working with ETA personnel to ensure the intent of all four
recommendations is addressed. The agency’s response to the draft report is
included in its entirety in Appendix B.
We appreciate the cooperation and courtesies ETA extended to us during this
audit.
Laura B. Nicolosi
Assistant Inspector General for Audit
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EXHIBIT 1: GRANT AWARDS
Table 2: Grants Awarded to 10 Sampled States
State
Number of
Projects
Grant Award
California
2
$9,120,000
Texas*
6
$8,813,350
Colorado
4
$6,840,000
Pennsylvania
2
$6,839,813
Oregon
2
$4,562,000
Nevada
7
$4,562,000
Kansas
1
$4,562,000
District of Columbia
4
$2,283,000
South Dakota
4
$2,283,000
New Mexico
4
$2,258,460
Totals
36
$52,123,623
*After grant award, Texas cancelled one project and added two, which expanded
the total project count from 36 to 37.
Source: OIG analysis of grant agreements for the sampled states
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EXHIBIT 2: FUNDS FOR BETTER USE
Table 3: Funds For Better Use11
State
Number of
Projects
Dollar Amount Awarded
(Before Modifications)
Texas
5
$7,524,706
Pennsylvania
1
$4,924,023
Nevada
3
$4,392,913
Colorado
2
$1,987,261
District of Columbia
2
$1,107,000
New Mexico
2
$606,724
Oregon
1
$ 229,863
Totals
16
$20,772,490
Source: OIG analysis of grant agreements for the sampled states
11 As defined by the Inspector General Act of 1978, as amended, “funds for better use” means
funds that could be used more efficiently or achieve greater program effectiveness if
management took certain actions. These actions include reduction in future outlays and
deobligation of funds from programs or operations.
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EXHIBIT 3: QUESTIONED COSTS
Table 4: Questioned Costs12
State
Number of
Projects
Total
Questioned
Costs
Total Claimed
Questioned
Costs
New Mexico
2
$1,651,736
$1,651,736
District of Columbia
3
$1,830,000
$1,176,000
Pennsylvania
1
$231,080
0
Totals
6
$3,712,816
$2,827,736
Source: OIG analysis of grant performance for sampled states with closed-out grants
This table shows the total questioned costs identified and the total amount
claimed in this report. During this audit, we identified more than $3.7 million in
questioned costs. To prevent double counting, we are not claiming questioned
costs of $654,000 for one District of Columbia project because it was included in
the “funds for better use” captured in Exhibit 2. Additionally, we are not
recommending recovery of questioned costs for one Pennsylvania project.
Although the project did not meet a portion of its original goal of improving
timeliness, it successfully eliminated the existing backlog, thereby preventing
timeliness from worsening. After eliminating the backlog, the remaining funds for
this project were moved to another project. As a result, we are claiming a total of
more than $2.8 million in questioned costs in this report.
12 As defined by the Inspector General Act of 1978, as amended, questioned costs include
alleged violations of law, regulations, contracts, grants, or agreements; costs not supported by
adequate documentation; or the expenditure of funds for an intended purpose that was
unnecessary or unreasonable.
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APPENDIX A: SCOPE AND METHODOLOGY
Scope
This audit covered ETA’s processes for designing and awarding the grants and
monitoring grant recipients’ performance, from the passing of ARPA in
March 2021 through September 30, 2024.
While Executive Order 14151, issued in January 2025, may impact the future of
this specific grant program, our audit focused on implementation and
performance measurement of the grants to help inform ETA’s grant governance
practices agencywide.
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.
To answer our objective, we reviewed ETA’s grant design in UIPL No. 23-21,
which outlined the equity grant requirements, and ETA’s approval process for
awarding grants. We selected a sample of 10 of the 46 state grant recipients to
determine if ETA ensured states met UIPL 23-21 requirements to receive funds.
The sampling universe comprised 46 states that received grants. We
judgmentally selected 10 states based on size as defined by ETA in UIPL 23-21,
ensuring that we selected at least 2 states from each size category: small,
medium, large, and extra-large.
We reviewed quarterly progress reports (ETA 9178-ARPA) for the six quarters
ending June 2023 through September 2024 to determine whether states were on
target to achieve the outcomes and metrics outlined in their grant agreements.
We also reviewed relevant aspects of UIPL 02-22, which outlined the Tiger Team
grants.
We interviewed ETA national and regional staff. We also coordinated with the
OIG’s Office of Investigations and three other Office of Audit teams conducting
ETA audits to ensure our fieldwork remained informed of any emerging issues
related to our audit objective.
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Reliability Assessment
In planning and performing the audit, we relied on grant award data provided by
ETA. We assessed the reliability of this data by: (1) reviewing the various rounds
of awards displayed on ETA’s website to ensure they coincided with the award
dates and amounts provided by ETA and (2) confirming the funding awarded to
each state aligned with the parameters in UIPL 23-21 based on state’s UI
covered employment in 2020. We determined the data was sufficiently reliable
for the purposes of this audit report.
Internal Controls
A performance audit includes an understanding of internal controls considered
significant to the audit objective and testing compliance with significant laws,
regulations, and other requirements. In planning and performing our audit, we
considered whether internal controls significant to the audit objective were
properly designed and placed in operation. This included reviewing policies and
procedures. We confirmed our understanding of these controls and procedures
through interviews and the review and analysis of documentation. We evaluated
internal controls used for reasonable assurance. Our consideration of internal
controls for administering UI equity grants would not necessarily disclose all
matters that might be reportable conditions.
Criteria
• 2 C.F.R. Part 200 – Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards (November 2, 2023)
• American Rescue Plan Act of 2021 (November 16, 2023)
• Employment and Training Order No. 01-23, National Office and Regional
Office Responsibilities in Managing, Monitoring, and Overseeing State
Grants for Unemployment Insurance Programs Authorized Under the
American Rescue Plan Act of 2021 (November 23, 2022)
• Employment and Training Order No. 01-24, Grants Management Policies
and Responsibilities (December 4, 2023)
• Executive Order 14151, Ending Radical and Wasteful Government DEI
Programs and Preferencing (January 20, 2025)
• Unemployment Insurance Program Letter No. 10-23, Cancellation of
American Rescue Plan Act (ARPA) Related Guidance (July 13, 2023)
• Unemployment Insurance Program Letter No. 02-22, Grant Opportunity to
Support States Following a Consultative Assessment for Fraud Detection
and Prevention, Promoting Equitable Access, and Ensuring the Timely
Payment of Benefits, including Backlog Reduction, for all Unemployment
Compensation (UC) Programs (November 2, 2021)
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• Unemployment Insurance Program Letter No. 23-21, Grant Opportunity for
Promoting Equitable Access to Unemployment Compensation (UC)
Programs (August 17, 2021)
• U.S. Department of Labor Employment and Training Administration Core
Monitoring Guide (August 2018)
• Unemployment Insurance Program Letter No. 02-16, State
Responsibilities for Ensuring Access to Unemployment Insurance Benefits
(October 1, 2015)
Prior Relevant Coverage
During the last 4 years, the OIG has issued 7 reports of significant relevance to
the subject of this report, as follows:
1. COVID-19: Audit of State Workforce Agencies’ Information Technology
Systems Capability in Processing Unemployment Insurance Claims,
Report No.19-23-008-03-315 (September 19, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-008-03-315.pdf;
2. Tracking the Department of Labor’s Unemployment Insurance Response
to Local Communities during the Pandemic,
Report No. 19-23-007-03-315 (July 10, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-007-03-315.pdf;
3. “The Greatest Theft of American Tax Dollars: Unchecked Unemployment
Fraud,” Statement for the Record of Larry D. Turner, Inspector General,
U.S. Department of Labor, House Committee on Ways and Means,
Report No. 19-23-003-03-315 (February 8, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-003-03-315.pdf;
4. COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds
from Improper Payments Including Fraud or from Payment Delays,
Report No. 19-22-006-03-315 (September 30, 2022), available at:
https://www.oig.dol.gov/public/reports/oa/2022/19-22-006-03-315.pdf;
5. 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;
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6. Advisory Report: ETA’s Management of Workforce Development Grants:
Key Concerns, Report No. 09-22-001-03-001 (March 31, 2022),
available at:
https://www.oig.dol.gov/public/reports/oa/2022/09-22-001-03-001.pdf; and
7. ETA Did Not Sufficiently Plan and Execute the American Apprenticeship
Initiative Grant Program, Report No. 05-21-004-03-375
(September 30, 2021), available at:
https://www.oig.dol.gov/public/reports/oa/2021/05-21-004-03-375.pdf.
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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
August 25, 2025
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 – ETA Did Not Ensure ARPA Grants
Demonstrated Improvements in Access to Unemployment Benefits,
Report No. 19-25-XXX-03-315
The U.S. Department of Labor’s (Department) Employment and Training Administration (ETA)
appreciates the opportunity to respond to the above-referenced draft report regarding grants to
promote equitable access in the Unemployment Insurance (UI) program.
The report focuses on the extent to which ETA administered these grants in accordance with the
American Rescue Plan Act (ARPA) and the Department’s objectives for UI access. As a technical
clarification, ETA notes that the original appropriation under ARPA was for $2 billion and this
was the context within which these awards were announced. The amount was later reduced to $1
billion with enactment of the Fiscal Responsibility Act on June 3, 2023.
Responses to the Recommendations
ETA has an overarching comment about the recommendations in the draft report.
The scope of this audit and the work performance by the audit team focused only on the ARPA-
funded UI Equity Grants and was limited to the scope of activities occurring under Departmental
leadership between March 2021 and September 2024. More specifically, the Department
established the Office of UI Modernization (OUIM) within the Office of the Secretary in 2021 and
this office was responsible for the strategic direction of all activity occurring under the ARPA
appropriation, including the overall direction of the design of the UI Equity Grants offering and
the timing of the roll out. The more expansive application of the recommendations to ETA’s grant
governance practices agencywide is not based on any review of other ETA grants and is not
founded on the work conducted under this audit.
Please find below each of the recommendations contained in the draft report, followed by ETA’s
response to each of the recommendations.
2
Recommendation 1: Establish a policy that requires evaluation criteria or standards to be
used to ensure grant applications include evidence of a specific issue prior to awarding a
grant intended to address said issue.
ETA Response: ETA agrees with this recommendation. ETA updated its template language for
issuing funding opportunity announcements in February 2025 to include details about including
evidence of specific issues. As appropriate with future funding opportunities, ETA will
incorporate this language into its grant solicitations and subsequent reviews of grant
applications.
ETA respectfully requests the Office of Inspector General (OIG) resolve and close this
recommendation based on the corrective actions taken.
Recommendation 2: Develop additional guidance and staff training to improve monitoring
of grant recipients, including a focus on reviewing progress reports to ensure reporting
complies with requirements and grant recipients are on target to achieve grant goals as
identified in the grant agreement.
ETA Response: ETA agrees with this recommendation. ETA guidance already includes a focus
on reviewing progress reports; as such, this is something that is best emphasized in training. ETA
regularly provides tools and training on performance report reviews and monitoring of grant
performance and goals to all grant management staff through the Federal Project Officer (FPO)
Academy. These trainings are provided monthly and address the entire set of grant management
responsibilities. ETA will incorporate the recommendations of this report into the curriculum of
the FPO Academy that will be developed for future trainings and consider any feedback from this
training to determine if additional guidance is needed.
The Director of the Office of Regional Management is responsible for the implementation of this
recommendation. The anticipated completion date for this recommendation is the end of Fiscal
Year (FY) 2027.
Recommendation 3: Recover $2,827,736 in costs for grant projects that did not achieve
project goals in accordance with the grant agreements.
ETA Response: ETA agrees with this recommendation but suggests that the recommendation be
reworded to read: “Review $2,827,736 in costs for grant projects identified in this report and
recover funds where appropriate.” As part of ETA’s audit resolution process, ETA will review the
information provided by the OIG. Initial and final determinations will be issued to the grant
recipient in question, in accordance with the process outlined in the Department of Labor Manual
Series 8, Chapter 300, to determine if these costs are in fact not allocable to the grant, and, if so,
the disallowed amounts. Once the audit resolution process is complete, ETA will provide the OIG
with a copy of the final determinations and evidence of repayment of disallowed costs, if any.
The Administrator for the Office of Grants Management is responsible for the implementation of
this recommendation. The anticipated completion date for this recommendation is the end of FY
2028.
3
Recommendation 4: Develop guidance for planning new discretionary grant programs to
ensure better coordination, minimize duplication of effort, and promote efficient use of grant
funds.
ETA Response: ETA agrees with this recommendation. ETA’s discretionary grant programs are
designed based on the policy priorities and at the direction of Departmental leadership. As such,
ETA updated its template language when issuing funding opportunity announcements, including
new discretionary grant programs, in February 2025, to improve efficiency and coordination while
reducing the potential for any duplication of effort. As appropriate with future funding
opportunities, ETA will incorporate this language and proactive approach into its grant
solicitations and subsequent reviews of grant applications.
ETA respectfully requests the OIG resolve and close this recommendation based on the corrective
actions taken.
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
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