Pandemic unemployment insurance

What the programs were

Regular unemployment insurance is a federal-state partnership that pays temporary benefits to workers who lose their jobs through no fault of their own. For the pandemic programs, the federal government paid for the benefits and their administration and, as the statute directed, relied on the 53 state workforce agencies of the 50 states, the District of Columbia, Puerto Rico and the U.S. Virgin Islands to take the claims and send the payments (GAO-23-106696, September 2023).

The CARES Act created three programs (GAO-23-106696):

• Pandemic Unemployment Assistance (PUA) paid people not otherwise eligible for unemployment insurance, "such as the self-employed and certain gig economy workers", who could not work for specified COVID-19 reasons. Federal spending on PUA benefits was $138 billion through May 31, 2023.
• Federal Pandemic Unemployment Compensation (FPUC) added $600 a week through July 2020, then $300 a week for weeks beginning after December 26, 2020 and ending on or before September 6, 2021, on top of regular and pandemic benefits. $442 billion through May 31, 2023.
• Pandemic Emergency Unemployment Compensation (PEUC) added weeks for people who had used up their regular benefits. $90 billion through May 31, 2023.

The Consolidated Appropriations Act, 2021 added Mixed Earner Unemployment Compensation (MEUC). The programs expired in September 2021, and 24 states ended their participation in at least one of them before then (GAO-23-106696). Between the first $600 and the later $300, a presidential authorization of August 8, 2020 let the Federal Emergency Management Agency pay Lost Wages Assistance through the states to people already receiving benefits (Pandemic Response Accountability Committee, April 2024).

GAO counts about $670 billion spent under the pandemic programs and about $230 billion under the regular programs over the same period (GAO-23-106696).

How the fraud worked

PUA paid people the regular system does not cover, on the strength of their own statements. The Labor Department's inspector general warned on May 26, 2020 that "this self-certification renders the individual eligible to receive payments immediately", and that relying on it alone "will lead to increased improper payments and fraud" (DOL-OIG alert memorandum).

In the cases the Pandemic Response Accountability Committee studied, most of the fraud used other people's names. Of 45 unemployment fraud cases it reviewed, 35 (78 percent) filed claims using a stolen identity and 29 (64 percent) involved two or more people conspiring (PRAC, April 2024).

The inspector general went looking in the states' data for Social Security numbers that should not have been paid: numbers filed in several states at once, numbers of dead people, numbers of federal prisoners, and numbers tied to suspicious email accounts. The count grew with each memo, from more than $5.4 billion for March to October 2020 (February 2021) to a cumulative $45.6 billion by April 2022, in a memo titled "Potentially Fraudulent Unemployment Insurance Payments in High-Risk Areas Increased to $45.6 Billion" (September 21, 2022).

In four states it audited, the inspector general estimated that $30.4 billion of the $71.7 billion in PUA and FPUC benefits paid from March 28 to September 30, 2020 was paid improperly (42.4 percent), and that $9.9 billion of that went to likely fraudsters (DOL-OIG audit, September 30, 2022).

The estimates, by what they measure

The official figures measure different things, and they cannot be added together. The unemployment fraud estimates table holds each one with its definition, its date and the words it rests on.

• Fraud. GAO estimates that fraud in the unemployment programs from April 2020 through May 2023 was "likely between $100 billion and $135 billion", about 11 to 15 percent of all benefits paid, from statistical sampling and imputation (GAO-23-106696). It is the only statistical estimate of fraud itself in the pandemic fraud estimates table.
• Improper payments. The inspector general's "at least $191 billion" applies the department's 21.52 percent improper payment rate to about $888 billion in pandemic unemployment spending; improper payments include errors and ineligible claims, and the inspector general says "a significant portion" was fraud (testimony, February 8, 2023).
• Rates. The Labor Department's published improper payment rate for unemployment insurance was 18.71 percent in fiscal 2021, 21.52 percent in 2022, 14.83 percent in 2023, 14.41 percent in 2024 and 13.14 percent in 2025. PaymentAccuracy.gov lists the programs in the department's monetary-loss calculation as state UI, UCFE, UCX, EB, EUC08, PEUC and FPUC; PUA is not among them. For PUA, the department's own review in August 2023 found a total improper payment rate of 35.9 percent, of which 17 percent was the overpayment rate, as the inspector general reports it (DOL-OIG, April 1, 2025).
• Potential fraud. The $45.6 billion above is money flagged by data matching, which the inspector general calls "Potentially Fraudulent".

Overpayments, and what came back

• An overpayment exists on the books once a state has determined it and notified the claimant. From state reports submitted as of April 26, 2026, the Labor Department counts $33.73 billion established in FPUC, $25.26 billion in PUA and $3.57 billion in PEUC, against $2.65 billion, $2.24 billion and $0.60 billion recovered (UIPL No. 11-26, Attachment I, May 18, 2026). The department adds that it is still reconciling the states' reports and that "Some states may report more amount recovered than established."
• The states did not establish most of what went wrong. For April 2020 through September 2022, the inspector general estimated that $118.1 billion in PUA, PEUC and FPUC overpayments should have been established, against $36.9 billion the states reported, and found the states had waived more ($3.8 billion) than they had recovered ($2.5 billion) (DOL-OIG, April 1, 2025).
• As of June 30, 2023, 47 states reported waiving recovery of $10.9 billion, 22 percent of $49.6 billion in established nonfraudulent overpayments (DOL-OIG, September 25, 2025).
• Time runs out on one collection tool. States may take PEUC, MEUC and FPUC overpayments out of later benefits only for three years after the payment; the limit does not apply to PUA (UIPL No. 11-26).
• The state-by-state table rebuilds these totals from the Labor Department's report files, retrieved September 23, 2026, and splits fraud from nonfraud. On those files, states have established $34.08 billion in FPUC overpayments, $2.68 billion of it as fraud, and recovered $2.83 billion; in the regular program, states established $13.38 billion in overpayments over the quarters ending June 30, 2020 through June 30, 2023. The department's $25.26 billion for PUA appears to count the fraud lines twice. Its footnote adds each state's fraud lines to the state's total lines, while its reporting instructions (UIPL 16-20, Change 6, Attachment IV) call the fraud lines a "sub-breakout" of those totals that "should be equal to or less than" them. Run on the same reports, up to the report date the department lists for each state, the footnote's formula gives $25.38 billion and matches the department's figure for 49 of the 53 states. Counting each dollar once, the same reports give $23.08 billion. The $2.30 billion between the two is the fraud lines.

The enforcement picture, counted

Counts from the enforcement records, not findings about any case.

• By the task force's April 2024 report, the inspector general had opened more than 205,000 unemployment fraud matters since the pandemic began. From August 2022 to December 31, 2023, its investigations led to 512 people being charged and 531 convicted, and more than $145 million in investigative monetary results (COVID-19 Fraud Enforcement Task Force 2024 Report).
• The DOJ press-release index holds 2,879 pandemic-fraud releases. 358 name unemployment insurance, from May 5, 2020 to September 15, 2026. By stage keyword: 112 sentencings, 65 guilty pleas, 46 charging announcements, 19 arrests, 18 indictments, 12 convictions and 86 unlabeled.
• The sentencing table holds 1,133 records; 400 name unemployment insurance in the program field, 332 of them without PPP or EIDL. Among the 297 with a numeric custodial sentence, the median is 40 months.

How it shows up in this archive

As of September 23, 2026, 681 court filings from 52 cases and 675 source documents are filed under pandemic unemployment insurance. Most of the court filings come from the Southern District of California (465).

The collections include the inspector general's unemployment insurance reports, from the first warnings of April 2020 to the prepaid-card alerts of 2026; the Congressional Research Service's report on permanent-law and COVID-19 programs; the state audits of unemployment insurance from Colorado, Nevada and Arizona, and state auditors' reports such as the California State Auditor's January 2021 report on EDD's approach to fraud prevention; and the Bank of America multidistrict litigation over California unemployment benefits (No. 3:21-md-02992, Southern District of California).

Four articles work from these records: The Filter That Froze California Unemployment, Pondera's 1.1 Million Flags, Blake Hall and ID.me's California Contract and PUA Was Built to Be Uncheckable.

In the data section: the state-by-state overpayment table, the unemployment fraud estimates, the cross-program pandemic fraud estimates, the sentencing table and the DOJ press-release index.

Start reading

1. GAO-23-106696 — Unemployment Insurance: Estimated Amount of Fraud during Pandemic Likely Between $100 Billion and $135 Billion (September 2023)The fraud estimate, and the program background.
2. DOL-OIG Alert Memorandum on PUA self-certification (May 26, 2020)The warning, eight weeks into the program.
3. DOL-OIG Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments in High-Risk Areas Increased to $45.6 Billion (September 21, 2022)Four data matches, and what they found.
4. DOL-OIG audit: ETA and States Did Not Protect Pandemic-Related UI Funds from Improper Payments (September 30, 2022)Four states, tested claim by claim.
5. DOL-OIG testimony: The Greatest Theft of American Tax Dollars (February 8, 2023)Where the $191 billion comes from.
6. PRAC: Why Unemployment Insurance Fraud Surged During the Pandemic (April 2024)45 cases, read for how the schemes worked.
7. DOL-OIG: ETA and State Workforce Agencies Need to Do More to Recover Pandemic UI Program Improper Payments (April 1, 2025)The $118.1 billion that should have been established.
8. DOL-OIG: COVID-19 recovery of pandemic-related UI overpayments improperly waived (September 25, 2025)What the states forgave.
9. DOL-OIG and SBA-OIG joint report: Data Sharing Project Finds Billions Paid to Same Likely Fraudsters (December 5, 2024)The same people in unemployment and EIDL.