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Home Court filings Bofa Ca Unemployment In re: Bank of America California Unemployment Benefits Litigation — S.D. Cal., No. 21-md-02992 Exhibit 15 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 350-16, S.D. Cal. No. 3:21-md-02992)

Court filing

Exhibit 15 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 350-16, S.D. Cal. No. 3:21-md-02992)

Filed October 24, 2024 in In re Bank of America California Unemployment Benefits Litigation; one of 1415 filings from this case.

Record facts

CourtU.S. District Court for the Southern District of California
Filed2024-10-24

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 350-16 · 2024-10-24 · Docket on CourtListener

Full text

EXHIBIT 15 
Case 3:21-md-02992-GPC-MSB     Document 350-16     Filed 10/24/24     PageID.11234 
Page 1 of 9

Post
New Report Details Lessons
from Massive Pandemic
Unemployment Fraud
By Matt Weidinger
AEIdeas
September 11, 2024
A new report (“Examining Widespread Fraud in Pandemic
Unemployment Relief Programs”) authored by the majority
staff of the US House Committee on Oversight and
Accountability spotlights the massive fraud and abuse
inflicted on unemployment benefits during the pandemic.
More importantly, it identifies why the abuse occurred, where
the misspending was at its worst, and what steps are needed
to prevent a repeat of such massive ripoffs. 
The report, released as the committee conducted
a hearing on next steps to address pandemic fraud, recounts
official government fraud and misspending figures that,
while not new, are nonetheless astonishing:
[T]he U.S. Government Accountability Office
(GAO) estimates that about 11 to 15 percent of
total benefits paid during the pandemic were
fraudulent, totaling between $100 to $135 billion.

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The Department of Labor (DOL) Office of Inspector
General (OIG) estimated that at least $191 billion
in pandemic UI [unemployment insurance]
payments could have been improperly paid, with
a significant portion attributable to fraud.
In August 2023, DOL reported that the PUA
program had a total improper payment rate of
35.9 percent.
Unofficial estimates suggest improper unemployment benefit
payments may have reached twice the official level,
potentially costing taxpayers $400 billion or “about a 40
percent loss rate.”
The report cites multiple factors contributing to elevated
fraud and misspending, including outdated IT systems,
staffing shortages, and simply the unprecedented crush of
benefit claims during the pandemic.  But it highlights that
“Congress and executive branch actions created problems
for states and the economy” while placing special blame on
the flawed design of the Pandemic Unemployment
Assistance (PUA) program Congress hastily created in March
2020:
The design of the PUA program led to massive fraud.
During the program’s first nine months, claimants did
not have to provide any evidence of earnings which
made the program susceptible to fraud. Only when
Congress reauthorized the PUA program in December
2020, did states require applicants to provide proof of
prior employment and wages.
Beyond federal mistakes, the report reviews states where
misspending was greatest, and reserves its most detailed
criticisms for California. Early in the pandemic, Julie Su led
California’s Labor and Workforce Development Agency
(LWDA), which oversees the Employment Development
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Department (EDD) that pays unemployment benefits.
President Biden has since nominated Su to be DOL Secretary,
although her nomination remains stalled despite Democratic
control of the Senate.
As the report notes,
EDD, under the leadership of LWDA Secretary Julie Su,
made the decision early in the pandemic to ‘pay and
chase’ after Su was informed that keeping integrity
checks in place would lead to backlog in processing
claims largely due to EDD’s outdated IT….
This led to many bad actors like international
organized crime and individual criminals cashing in
while eligible claimants were unable to obtain their
benefits. Initial reports about the amount of UI fraud
being committed in California were so extreme some
industry experts wondered if hackers had gained
control of EDD’s outdated IT… Despite repeated
warnings from OIG and ETA [Employment and Training
Administration], EDD did not make any substantive
changes to its fraud detection practices until late July
2020 when it finally began automating stopping
payment on suspicious claims.
The results included lengthy delays in accessing benefits for
deserving California residents alongside tens of billions of
dollars in improper payments to criminals.
The report includes a number of worthy recommendations to
improve future emergency responses, several of which track
recommendations Amy Simon and I proposed in our January
2024 report on unemployment benefit fraud:
All future temporary UI benefits programs must
require claimants to provide proof of prior work
before claims will be reviewed for eligibility.
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All future temporary UI benefits programs must
require state workforce agencies to cross-check
claimant PII [Personally Identifiable Information]
against all available databases, such as federal
prisoner databases, as recommended by OIG and
law enforcement, prior to approving benefits.
States and state workforce agencies should
prioritize modernizing IT systems to process UI
claims.
Congress should strongly weigh the long-term
implications of any proposal to expand regular UI
to include those groups of individuals eligible for
PUA benefits, including the self-employed, gig
workers, and independent contractors, as it is
simply too difficult to verify that those individuals
are unemployed through no fault of their own, are
ready, willing, and able to work, and are actively
seeking work as required by federal UC
programs.  
As bad as the massive abuse inflicted on taxpayers during the
pandemic was, the only thing that would be worse is if
lawmakers failed to recognize the causes of those losses and
simply repeated past mistakes. The committee’s report offers
a detailed guidebook of what went wrong during the
pandemic, which future lawmakers should heed both in
administering regular unemployment benefits and especially
in designing future emergency responses.
Learn more: Kamala Harris Wants to Turn the Tax Code into a
Mammoth ATM | Bill Clinton’s Misleading Job Creation
Statistic | Some Context Behind JD Vance’s Child Tax Credit
Comments | Kamala Harris Will Pay You Not to Work
Case 3:21-md-02992-GPC-MSB     Document 350-16     Filed 10/24/24     PageID.11238 
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Matt Weidinger
Senior Fellow and Rowe Scholar
Latest Work
October 09, 2024
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of TANF Funds
October 03, 2024
Op-Ed
Stop the Insanity. Our National Debt Now Tops $35
Trillion…
Tags:
Case 3:21-md-02992-GPC-MSB     Document 350-16     Filed 10/24/24     PageID.11239 
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Fraud | House of Representatives | pandemic | unemployment
benefits
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Case 3:21-md-02992-GPC-MSB     Document 350-16     Filed 10/24/24     PageID.11240 
Page 7 of 9

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Kamala Harris Wants to Turn
the Tax Code into a Mammoth
ATM
By Matt Weidinger
Bill Clinton’s Misleading Job
Creation Statistic
By Matt Weidinger
Article
August 28, 2024
COSM Commentary
Some Context Behind JD
Vance’s Child Tax Credit
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August 15, 2024
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Kamala Harris Will Pay You
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Case 3:21-md-02992-GPC-MSB     Document 350-16     Filed 10/24/24     PageID.11241 
Page 8 of 9

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