DOL-OIG Report 19-25-003-03-315, ETA and State Workforce Agencies Need to Do More to Recover Pandemic UI Program Improper Payments
- Document type
- report
- Date
- 2025-04-01
Summary
A U.S. Department of Labor Office of Inspector General audit report, No. 19-25-003-03-315, issued April 1, 2025, prepared under contract by Regis & Associates, PC and addressed to the Employment and Training Administration. It asks whether ETA ensured that state workforce agencies had adequate controls to recover unemployment insurance improper payments under the CARES Act, the Continued Assistance Act, and ARPA. For April 1, 2020, through September 30, 2022, the 10 audited SWAs reported $10.4 billion in overpayments, $676.3 million attributed to fraud, and waived approximately $601.6 million more than they recovered. Regis estimated approximately $23.5 billion of potential overpayments were not established, and made four recommendations to ETA. The report states that ETA did not provide a timely response to the draft report.
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 AND STATE WORKFORCE
AGENCIES NEED TO DO MORE TO
RECOVER PANDEMIC UI PROGRAM
IMPROPER PAYMENTS
This report was prepared by Regis & Associates, PC under contract to
the U.S. Department of Labor, Office of Inspector General, and by
acceptance, it becomes a report of the Office of Inspector General.
_____________________________
U.S. Department of Labor
Assistant Inspector General for Audit
DATE ISSUED: APRIL 1, 2025
REPORT NUMBER: 19-25-003-03-315
in-depth testing for 10 SWAs, and surveying 43 other SWAs
regarding activity under the CARES Act, Continued Assistance Act,
and ARPA.
What We Found
Regis concluded ETA and SWAs need to do more to recover
improper payments from federally-funded temporary pandemic UI
programs. For the period from April 1, 2020, through September 30,
BRIEFLY…
2022, the 10 audited SWAs reported a total of $10.4 billion in
overpayments for the programs reviewed, $676.3 million of which
was attributed to fraud. Regis found the overpayment recovery
ETA and State Workforce Agencies
rates for the selected SWAs were far below ETA’s core
Need to Do More to Recover
performance measure for regular UI paid from state trust funds.
Pandemic UI Program Improper
Further, Regis determined the 10 audited SWAs waived
Payments
approximately $601.6 million more in overpayments than they
recovered. This highlights the need for SWAs to do more to recover
Why We Did the Audit
overpayments, as well as prevent improper payments caused by
SWAs’ lack of adequate controls.
The economic emergency resulting
from the COVID-19 pandemic led to
The 10 audited SWAs—along with the other SWAs across the
new unemployment insurance (UI)
U.S.—established significantly less overpayments for recovery than
programs created under the
what was estimated by Regis using the ETA published UI
Coronavirus Aid, Relief, and Economic
overpayment rates. Regis estimated that, for the audited SWAs,
Security (CARES) Act. The CARES Act
approximately $23.5 billion of potential overpayments were not
and subsequent Continued Assistance
established; thus, they were not pursued for collection. Additionally,
for Unemployed Workers Act of 2020
Regis identified SWAs did not consistently use the recovery
(Continued Assistance Act) and the
methods mandated by law, nor the methods strongly recommended
American Rescue Plan Act of 2021
by ETA. Regis also noted SWAs’ ability to recover CARES Act UI
(ARPA) provided payments under three
program overpayments may be limited by states’ finality laws. ETA
key pandemic-related UI programs that
deferred to states to apply their finality laws to limit when a state
were implemented by state workforce
may reconsider a prior decision or determination made on a
agencies (SWA). The Employment and
CARES Act-funded UI claim. We are concerned this change in
Training Administration (ETA) provided
policy may hinder the recovery of overpayments and detection of
guidance and monitored SWAs’
fraud. Improper payment recovery activities are crucial for
administration of the programs.
maintaining the integrity of the unemployment benefits system and
public trust in these programs.
Based on audits of previous emergency
UI program implementation, we were
What We Recommended
concerned about SWAs’ ability to
effectively recover pandemic UI
Regis made four recommendations to ETA to improve improper
program improper payments. We
payments recovery. These recommendations included:
contracted with the independent,
(1) developing lessons learned and providing SWAs with resources
certified public accounting firm of Regis
to address the root causes of CARES Act-related overpayments,
& Associates, PC (Regis) to conduct an
(2) requiring SWAs to maximize all recovery methods, and
audit to answer the following question:
(3) continuing to work with Congress to lift restrictions and develop
incentives to recover federally-funded UI overpayments. While the
Did ETA ensure that SWAs had
Draft Report was provided to ETA in December 2024, due to recent
adequate controls to recover UI
senior leadership changes, ETA was unable to provide a timely
improper payments under the
response. When ETA provides a response, we will post it, along
CARES Act, Continued Assistance
with our analysis to our website.
Act, and ARPA?
Read the Full Report
Regis’ audit procedures included https://www.oig.dol.gov/public/reports/oa/2025/19-25-003-03-
assessing ETA’s oversight, performing 315.pdf
U.S. Department of Labor – Office of Inspector General
TABLE OF CONTENTS
INSPECTOR GENERAL’S REPORT .................................................................... 1
CONTRACTOR PERFORMANCE AUDIT REPORT ............................................ 6
RESULTS ............................................................................................................. 7
Improper Payment Recovery Rates of Emergency Pandemic UI Programs Were
Far Lower Than Regular UI Target Levels ............................................................ 7
SWAs Waived Recovery of Overpayments More Than They Recovered ........... 12
SWAs Did Not Consistently Use Mandatory and Strongly Recommended
Recovery Methods .............................................................................................. 14
State Finality Laws Restrict SWAs’ Ability to Collect UI Overpayments .............. 19
RECOMMENDATIONS ....................................................................................... 21
Analysis of Agency’s Comments ......................................................................... 22
EXHIBIT 1: OVERALL RECOVERY RATES FOR 10 AUDITED SWAS – APRIL
1, 2020, THROUGH SEPTEMBER 30, 2022 ...................................................... 23
EXHIBIT 2: NON-FRAUDULENT AND FRAUDULENT RECOVERY RATES FOR
10 AUDITED SWAS – APRIL 1, 2020, THROUGH SEPTEMBER 30, 2022 ...... 24
EXHIBIT 3: OVERALL RECOVERY RATES FOR ALL SWAS – APRIL 1, 2020,
THROUGH SEPTEMBER 30, 2022 .................................................................... 25
EXHIBIT 4: NON-FRAUDULENT AND FRAUDULENT RECOVERY RATES FOR
ALL SWAS – APRIL 1, 2020, THROUGH SEPTEMBER 30, 2022 ..................... 26
EXHIBIT 5: ESTIMATED UNESTABLISHED OVERPAYMENTS FOR 10
AUDITED SWAS – APRIL 1, 2020, THROUGH SEPTEMBER 30, 2022 ........... 27
EXHIBIT 6: ESTIMATED UNESTABLISHED OVERPAYMENTS FOR ALL SWAS
– APRIL 1, 2020, THROUGH SEPTEMBER 30, 2022........................................ 28
EXHIBIT 7: OVERALL OVERPAYMENT ACTIVITY FOR ALL SWAS –
JANUARY 1, 2024, THROUGH JUNE 30, 2024 ................................................. 29
APPENDIX A: SCOPE AND METHODOLOGY .................................................. 30
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U.S. Department of Labor Office of Inspector General
Washington, DC 20210
INSPECTOR GENERAL’S REPORT
Amy Simon
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) 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 (ETA). The audit evaluated ETA’s efforts to ensure state
workforce agencies (SWA) had adequate controls in place to recover
unemployment insurance (UI) improper payments under the Coronavirus Aid,
Relief, and Economic Security (CARES) Act, the Continued Assistance for
Unemployed Workers Act of 2020 (Continued Assistance Act), and the American
Rescue Plan Act of 2021 (ARPA).
The OIG monitored Regis’ work to ensure it met professional standards and
contractual requirements. Regis’ independent audit was conducted in
accordance with generally accepted government auditing standards.
Regis was responsible for the auditor’s evaluation and the conclusions
expressed in the report, while the OIG reviewed Regis’ report and supporting
documentation.
Background
Following the start of the COVID-19 pandemic in early 2020, unemployment
compensation claims across the U.S. rose exponentially to unprecedented levels.
On March 14, 2020, DOL reported 282,000 initial unemployment claims. Within
2 to 3 weeks, initial claims rose to 10 times pre-pandemic levels, which were far
higher than state systems were designed to handle.1 Within 5 months (through
August 15, 2020), DOL reported more than 57 million initial claims, which was
the largest increase since DOL began tracking UI data in 1967.
1 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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U.S. Department of Labor – Office of Inspector General
In a 2023 congressional testimony,2 the OIG stated it has repeatedly reported
significant concerns with DOL’s and SWAs’ ability to deploy UI program benefits
expeditiously and efficiently, while ensuring integrity and adequate oversight. In
April 2020,3 the OIG reported six initial areas of concern for ETA and SWAs to
consider as they implemented the UI provisions in the CARES Act. These
concerns were based on years of oversight work of DOL’s UI program, including
the use of prior stimulus funds. One of those six areas was improper payment
detection and recovery.
SWAs were required by the CARES Act, as amended, to pursue the recovery of
overpayments—unless a SWA waived recovery of payment in cases where the
claimant was without fault and recovery would have been against equity and
good conscience. In February 2022, ETA advised SWAs of seven circumstances
in which they could waive recovery of CARES Act overpayments without
case-by-case analysis. These types of waivers are called “blanket waivers.”
The OIG began conducting additional work in Fiscal Year 2023 to determine the
impact of waivers, including blanket waivers, on UI overpayments, fraud
investigations, and recoveries.4
Purpose
On March 27, 2020, the CARES Act was signed into law to provide expanded UI
benefits to workers who were unable to work due to the COVID-19 pandemic. On
December 27, 2020, the Consolidated Appropriations Act, 2021, which includes
the Continued Assistance Act, amended certain provisions of the CARES Act to
include extending the emergency UI programs.
Under the CARES Act, the Pandemic Unemployment Assistance (PUA) and
Pandemic Emergency Unemployment Compensation (PEUC) program benefits
expired on December 31, 2020. The Federal Pandemic Unemployment
Compensation (FPUC) program’s supplemental benefits of $600 per week
expired on July 31, 2020. The Continued Assistance Act extended the PUA and
PEUC programs to weeks of unemployment ending on or before March 14, 2021.
Additionally, FPUC was reauthorized and modified to provide $300 per week in
2 “The Greatest Theft of American Tax Dollars: Unchecked Unemployment Fraud,” Hearing,
Statement for the Record of Larry D. Turner, Inspector General, U.S. Department of Labor;
House Committee on Ways and Means (February 8, 2023), available at:
https://www.oig.dol.gov/public/testimony/02082023.pdf
3 Advisory Report, CARES Act: Initial Areas of Concern Regarding Implementation of
Unemployment Insurance Provisions, Report No. 19-20-001-03-315 (April 21, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2020/19-20-001-03-315.pdf
4 COVID-19: Impact of Waivers on UI Overpayments, Fraud Investigations, and Recoveries
(April 26, 2023), available at:
https://www.oig.dol.gov/public/oaprojects/COVID-
19%20Impact%20of%20Waivers%20Eng%20Ltr_042623.pdf
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U.S. Department of Labor – Office of Inspector General
supplemental benefits for weeks of unemployment beginning after
December 27, 2020, and ending on or before March 14, 2021. ARPA further
extended the PUA and PEUC programs to weeks of unemployment ending on or
before September 6, 2021. ARPA also extended the FPUC program of $300 per
week through the week ending on or before September 6, 2021 (see Figure 1
below).
Figure 1: Three Key Pandemic-Related UI Programs
Source: CARES Act and related extensions
Regis’ audit work focused on ETA’s and SWAs’ efforts to recover improper
payments in three key emergency UI programs—PUA, PEUC, and FPUC—for
the period March 27, 2020, to April 6, 2021. These programs were funded under
the provisions of the CARES Act, the Continued Assistance Act, and ARPA at
the height of the pandemic UI claims surge. An improper payment is any
payment that should not have been made. Specifically, the payment could have
been a duplicate payment or a payment made: (1) in an incorrect amount, (2) to
an ineligible recipient, (3) for an ineligible good or service, or (4) for a good or
service not received. An improper payment can be an underpayment or an
overpayment. 5
For the 12 months ending March 31, 2021, the cumulative underpayment rate for
the 526 SWAs whose Benefit Accuracy Measurement (BAM) program data was
available ranged from a low of 0 percent in Arizona, Indiana, Kansas, and
Maryland to a high of 4 percent in Alaska. The cumulative overpayments for the
52 SWAs for the same time period ranged from a low of 4 percent in Hawaii to a
5 Payment Integrity Information Act of 2019, 31 USC § 3301, Public Law 116-117 (March 2, 2020)
6 According to ETA’s BAM program fact sheet, BAM data for paid and denied claims are available
for the 50 states, the District of Columbia, and Puerto Rico. BAM data does not include the
U.S. Virgin Islands. The BAM fact sheet is available at:
https://oui.doleta.gov/unemploy/bam/2002/bam_fact.asp
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U.S. Department of Labor – Office of Inspector General
high of 47 percent in Virginia7. Accordingly, Regis’ work focused on
overpayments.
The scope of this audit covered PUA and PEUC claims, as well as FPUC
payments, of 10 SWAs for the period from April 1, 2020, through
September 30, 2022. Regis also performed analyses of recovery activities for the
period from April 1, 2020, through September 30, 2022, using data reported by
the SWAs on ETA required reports. The SWAs were selected by the OIG using a
risk analysis of factors that included, but were not limited to: funding amounts,
claims information, information technology modernization projects, and ETA’s
published improper payment rates.
The 10 SWAs the OIG selected for audit were Connecticut, Florida, New Jersey,
North Carolina, Pennsylvania, Rhode Island, South Carolina, Texas, Washington,
and Wisconsin. For the period from April 1, 2020, through September 30, 2022,
the 10 audited SWAs reported $176.1 billion8 of benefit payments for the PUA,
PEUC, and FPUC programs. On ETA reports, these 10 SWAs also reported a
total of $10.4 billion in overpayments9 for the programs reviewed, $676.3 million
of which was attributed to fraud.
In addition, Regis surveyed SWAs and territories that were not selected for
in-depth examination to gather similar information about their efforts to recover
PUA, PEUC, and FPUC improper payments. Surveys were sent to the remaining
43 SWAs. Sixteen (37 percent) of the 43 SWAs responded to the survey.
Regis conducted this performance audit to answer the following question:
Did ETA ensure that SWAs had adequate controls to recover UI improper
payments under the CARES Act, the Continued Assistance Act, and ARPA?
To answer this question, Regis reviewed SWAs’ improper payment recovery
strategies and compliance with applicable requirements. Regis obtained an
understanding of ETA’s and SWAs’ internal controls through interviews and
reviews of their policies and procedures. Regis also performed other audit
procedures of ETA’s and SWAs’ processes to determine compliance with
7 DOL, Unemployment Insurance Payment Accuracy Datasets, 12-Month Data
(April 1, 2020 – March 31, 2021), last accessed January 23, 2024, available at:
https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/data
According to ETA, the data presented only included three quarters of the calendar year because
the BAM program was suspended at the end of March 31, 2020, due to the COVID-19 pandemic.
Within the source document, ETA also notes several other limitations of the data.
8 Based on the amounts reported by SWAs for the PUA, PEUC, and FPUC programs on the
monthly ETA 902 PUA reports, ETA 5159 PEUC reports, and ETA 2112 reports, respectively.
9 Fraudulent and non-fraudulent benefit overpayments are reported on the monthly ETA 902
PUA, ETA 227 PEUC, and ETA 227 FPUC reports.
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program requirements. See Appendix A for additional details on scope and
methodology.
Results
Regis concluded ETA and SWAs need to do more to recover improper payments
from federally-funded temporary pandemic UI programs. Regis found that the
overpayment recovery rates for the selected SWAs were far below ETA’s core
performance measure for regular UI10 paid from state trust funds. Further, Regis
determined that the 10 audited SWAs waived approximately $601.6 million more
in overpayments than they recovered for the period from April 1, 2020, through
September 30, 2022. This highlighted the need for SWAs to do more to recover
overpayments, as well as prevent improper payments caused by SWAs’ lack of
adequate controls. Also, the 10 audited SWAs—along with the other SWAs
across the U.S.—established significantly less overpayments for recovery than
what was estimated by Regis using ETA’s published UI overpayment rates11.
Regis identified that SWAs did not consistently use the recovery methods
mandated by the CARES Act and the Continued Assistance Act, nor the methods
strongly recommended by ETA. Regis also noted that legal restrictions on some
of the overpayment recovery methods and states’ finality laws curtailed SWAs
ability to recover more overpayments.
We appreciate the cooperation and courtesies ETA extended to us during this
audit.
Laura B. Nicolosi
Assistant Inspector General for Audit
10 Core performance measures were not established for the federally-funded temporary UI
programs. Regis used ETA’s performance core measures for regular UI (paid from state trust
funds) as a benchmark to evaluate the performance of the federally-funded temporary UI
programs.
11 The overpayment rates used for the PEUC and FPUC programs were based on the results of
the BAM statistical survey conducted by ETA for regular UI to determine improper payment rates.
The BAM improper payment rates consisted of overpayment plus underpayment rates. The
regular UI improper payments rates data is available at:
https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/data.
ETA performed a separate analysis to determine the improper payment rate for the PUA
program, which was for individuals that did not qualify for the traditional UI program. The PUA
improper payment rate also included an unknown rate, which was for payments that could not be
determined as valid, overpaid, or underpaid. The PUA improper payment rate report is available
at:
https://oui.doleta.gov/unemploy/pdf/Pandemic_Unemployment_Assistance_Improper_Payment_
Rate_Report.pdf
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U.S. Department of Labor – Office of Inspector General
CONTRACTOR PERFORMANCE AUDIT REPORT
MANAGEMENT CONSULTANTS &
CERTIFIED PUBLIC ACCOUNTANTS
Independent Auditor’s Performance Audit Report on ETA’s and State Workforce
Agencies’ Efforts to Recover Improper Payments
Amy Simon
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) Office of Inspector
General (OIG) to conduct a performance audit of the Employment and Training
Administration’s (ETA) and state workforce agencies’ (SWA) efforts to recover
improper payments under programs authorized by the unemployment
insurance (UI) provisions of the Coronavirus Aid, Relief, and Economic Security
(CARES) Act and the Continued Assistance for Unemployed Workers Act of
2020 (Continued Assistance Act) and the American Rescue Plan Act of 2021
(ARPA). We conducted the audit to answer the following question:
Did ETA ensure that SWAs had adequate controls to recover UI
improper payments under the CARES Act, the Continued Assistance
Act, and ARPA?
To answer this question, we reviewed UI improper payments for the Pandemic
Unemployment Assistance (PUA), Pandemic Emergency Unemployment
Compensation (PEUC), and Federal Pandemic Unemployment Compensation
(FPUC) programs for the period from March 27, 2020, to April 6, 2021. We also
performed an analysis of recovery activities for the period from April 1, 2020,
through September 30, 2022, using data SWAs provided on ETA required
reports.
The OIG used a risk-based approach to select 10 SWAs for an in-depth
examination of policies, processes, and outcomes for three programs—PUA,
PEUC, and FPUC. The 10 audited SWAs were Connecticut, Florida, New Jersey,
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North Carolina, Pennsylvania, Rhode Island, South Carolina, Texas, Washington,
and Wisconsin. In addition, we sent surveys to 43 SWAs that were not selected
for in-depth examination to gather similar information about their efforts to
recover PUA, PEUC, and FPUC improper payments. Sixteen (37 percent) of the
43 SWAs responded to the survey. See Appendix A for additional details on
scope and methodology.
RESULTS
We identified that ETA and SWAs need to do more to recover improper
payments within the three key pandemic-related UI programs audited. We
observed that overpayment recovery rates under these key pandemic-related UI
programs for the selected SWAs were far below ETA’s core performance
measure for recovering overpayments of regular UI. Specifically, we found that
SWAs waived significantly more overpayments than they recovered.
Further, SWAs did not consistently perform mandatory and strongly
recommended activities to recover overpayments. Also, we found that legal
restrictions on some of the overpayment recovery methods and states’ finality
laws curtailed SWAs’ ability to recover more overpayments.
Improper Payment Recovery Rates of
Emergency Pandemic UI Programs Were Far
Lower Than Regular UI Target Levels
We found SWAs recovered improper payments at rates that were far lower than
the level deemed acceptable under ETA guidance for regular UI overpayments
(recovery core measure)12. Specifically, ETA guidance calls for a minimum
recovery rate of 68 percent. Given that ETA did not establish a core performance
measure for overpayment recoveries applicable to the three key
pandemic-related UI programs under audit, we used the regular UI
recovery-related core performance measure as a benchmark for evaluating the
key emergency programs.
To calculate the recovery rates, we used the data submitted by SWAs on ETA
required reports that were available on ETA’s website. However, we observed
12 The UI overpayment recovery core measure is the percentage of the amount of overpayments
recovered, divided by the (amount of overpayments established, minus overpayments waived).
More information is available at: https://oui.doleta.gov/unemploy/pdf/Core_Measures.pdf
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some SWAs did not report all of their overpayment activity, as required.13 For
example, based on reported data as of January 5, 2023, the Connecticut and
New Jersey SWAs had not reported any overpayments for the PUA program and
FPUC program, respectively, for the period from April 1, 2020, to
September 30, 2022. Based on data reported to ETA, the selected SWAs’
recovery rates were 27 percent, 12 percent, and 6 percent, for the PUA, PEUC,
and FPUC programs, respectively. Figure 2 shows the amounts of established
overpayments, recovered overpayments, and waived overpayments for the
10 audited SWAs for the three key pandemic-related UI programs, respectively,
in billions of dollars.
Figure 2: Overall Recovery Rates for the 10 Audited SWAs
April 1, 2020, through September 30, 2022
$6
$4.98 B
$5
$3.97 B
$4
$3
Billions
$2
$1.45 B $1.54 B
$1.07 B
$1
$0.41 B
$0.13 B $0.20 B
$0.05 B
$0
PUA PEUC FPUC
(Overall Recovery Rate 27%) (Overall Recovery Rate 12%) (Overall Recovery Rate 6%)
Established Overpayments Recovered Overpayments Waived Overpayments
Source: Regis analysis of information reported by SWAs (see Exhibit 1 for source data).
Compared to the 10 audited SWAs, the recovery rates for all SWAs across the
country were similarly low at 10 percent, 14 percent, and 5 percent for the PUA,
PEUC, and FPUC programs, respectively. Figure 3 shows the amounts of
13 This was consistent with what the OIG had previously reported on the 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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established overpayments, recovered overpayments, and waived overpayments
for all SWAs for the three key pandemic-related UI programs, respectively, in
billions of dollars.
Figure 3: Overall Recovery Rates for All SWAs
April 1, 2020, through September 30, 2022
$20
$18.68 B
$18
$16 $15.31 B
$14
$12
Billions
$10
$8
$6
$4 $2.94 B
$2.00 B
$2 $1.41 B $1.26 B
$0.79 B
$0.34 B $0.50 B
$0
PUA PEUC FPUC
(Overall Recovery Rate 10%) (Overall Recovery Rate 14%) (Overall Recovery Rate 5%)
Established Overpayments Recovered Overpayments Waived Overpayments
Source: Regis analysis of information reported by SWAs (see Exhibit 3 for source data)
We also evaluated the non-fraudulent and fraudulent overpayment activities and
recovery rates for the PUA, PEUC, and FPUC programs for the 10 audited SWAs
and for all SWAs. For the 10 audited SWAs, we noted a total of $676.3 million of
fraudulent overpayments was established, of which $40.9 million was recovered
(see Exhibit 2). For all SWAs, we noted a total of $3.6 billion of fraudulent
overpayments was established, of which a total of $145.3 million was recovered
(see Exhibit 4).
Based on the data reported to ETA, we determined SWAs recovered fraudulent
overpayments at a much lower rate than non-fraudulent overpayments.
Fraudulent payments—especially those involving identity theft where SWAs had
not identified the individuals that perpetrated the fraud—were especially difficult
to recover due to the investigative and legal processes that must first be
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completed to confirm the fraud and hold the perpetrators accountable. The PUA
program was particularly vulnerable to fraud because the program initially
allowed claimants to self-certify their eligibility for benefits without requiring
verification of identity or evidence of employment or self-employment. For the
10 audited SWAs, we found that, out of the three key pandemic-related
UI programs, the PUA fraud recovery rate was the lowest at 4 percent while
inversely having the highest non-fraud recovery rate at 30 percent (Exhibit 2). For
all SWAs, we found the PUA fraud recovery rate was the lowest at 2 percent,
while it had the second highest non-fraud recovery rate at 11 percent (Exhibit 4).
Based on our analysis, we noted ETA and SWAs need to do more to improve the
extremely low recovery rates. Our analysis showed SWAs have yet to establish a
significant number of overpayments that should have been subject to recovery
activities. This suggests that the recovery rates are far lower than we determined.
Using the prevailing overpayment rates derived from ETA’s Benefit Accuracy
Measurement (BAM) program14 for regular UI15 and ETA’s published PUA
program overpayment rate16, we estimated that $33.9 billion in overpayments
should have been established for the 10 audited SWAs for the period from
April 1, 2020, through September 30, 2022. This is much higher than the
$10.4 billion of overpayments reported by the 10 audited SWAs for that period.
This indicates that approximately $23.5 billion of potential overpayments were
not established and, thus, were not pursued for collection. Exhibit 5 shows the
estimated unestablished overpayments for the audited SWAs in further detail.
We performed a similar analysis for all SWAs and estimated $118.1 billion in
overpayments that should have been established for the period from
April 1, 2020, through September 30, 2022, for the PUA, PEUC, and FPUC
14 The Benefit Accuracy Measurement program is designed to determine the accuracy of paid
and denied claims in three major UI programs. It does this by reconstructing the UI claims
process for samples of weekly payments and denied claims using data verified by trained
investigators. More information is available at:
https://oui.doleta.gov/unemploy/bam/2002/bam_fact.asp
15 There is no separate improper payment rate for the PEUC or FPUC programs. ETA indicated it
is appropriate to apply the regular UI improper payment rate to both the PEUC and FPUC
programs. PEUC is an extension of the regular UI program and serves the same population. The
eligibility requirements for PEUC are generally the same as for the regular UI program.
Furthermore, FPUC was an additional payment to individuals receiving other UI benefits.
16 ETA released the results of its PUA program improper payment rates analysis in August 2023.
ETA reported to the Office of Management and Budget that the PUA program had a total
improper payment rate of 35.9 percent of which 17 percent was the overpayment rate. According
to ETA, the separate review process it used to calculate the estimated PUA improper payment
rate was not designed to produce a statistically valid rate for individual states or a small collection
of states. However, we deemed the rate to be conservative given that PUA was more prone to
fraud than regular UI because the PUA program initially allowed claimants to self-certify their
eligibility for benefits, without requiring verification of identity or evidence of employment or
self-employment.
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programs. This amount is much higher than the reported established
overpayments of $36.9 billion. This indicates that approximately $81.2 billion of
potential overpayments were not established and, thus, were not pursued for
collection. Exhibit 6 shows the estimated unestablished overpayments for all
53 SWAs.
According to ETA, the unestablished overpayments were in part the result of the
time required to complete the investigative process necessary to establish
overpayments. States may not establish overpayments until investigations have
been completed and determinations have been made that the payments were
improper. Further, proper notice of the overpayments must first be made to
claimants.
Additionally, ETA officials stated overpayment establishment and recovery
activity occurs later in time and is reported as of the date established—not the
date the overpayment occurred. Also, the establishment of overpayments had
been delayed in many states because states were initially focused on processing
adjudications and appeals concerning eligibility before investigating and
establishing overpayments.
During the pandemic, states made administrative decisions to meet the demand
for UI benefits, as well as to comply with Congress’ mandate to get benefits in
the hands of claimants as quickly as possible. Several factors likely contributed
to the disparity in the amount of estimated overpayments that should have been
established in the audited states. Among others, these factors included workload
backlogs, realignment of staff to claims-taking functions versus overpayment
detection functions, and other administrative challenges.
ETA officials stated they remained committed to assisting states in working
through backlogs and addressing recoveries of improper payments. However,
state finality laws, discussed in the latter part of this report, may hinder the
continued ability of SWAs to establish and recover overpayments related to the
three key pandemic-related UI programs.
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SWAS Waived Recovery of Overpayments
More Than They Recovered
During the period from April 1, 2020, through September 30, 2022, Regis found
that the 10 audited SWAs waived more overpayments than they recovered.
Specifically, of the $10.4 billion in established overpayments, $2 billion in
overpayments were waived by states, versus the $1.4 billion recovered (see
Figure 4). Ultimately, SWAs paid billions of dollars in erroneous payments that
could have been prevented with proper controls.
Figure 4: Total Established, Recovered, and Waived Overpayments for the
10 Audited SWAs, from April 1, 2020, through September 30, 2022
$2.0 Billion
$10.4 Billion
$1.4 Billion
Established Overpayments Recovered Overpayments Waived Overpayments
Source: Regis analysis of information reported by SWAs (see Exhibit 1 for source data)
Similarly, during the same period, SWAs across the nation—with a combined
total of $36.9 billion in established overpayments—waived more overpayments
($3.8 billion) than they recovered ($2.5 billion) (see Figure 5).
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Figure 5: Total Established, Recovered, and Waived Overpayments for All
SWAs in the U.S., from April 1, 2020, through September 30, 2022
$3.8 Billion
$36.9 Billion
$2.5 Billion
Established Overpayments Recovered Overpayments Waived Overpayments
Source: Regis analysis of information reported by SWAs (see Exhibit 3 for source data)
The CARES Act allows a SWA to waive the requirement to return overpayments
of PUA, PEUC, and FPUC program benefits if the SWA determines that the
benefit payments were not the fault of the claimant, and that such repayment
would be contrary to equity and good conscience.
Further, ETA issued guidance to SWAs that identified seven circumstances for
using blanket waivers.17 All overpayments that fell within the seven
circumstances and were not the fault of the claimant—and whose recovery would
be contrary to equity and good conscience—could potentially be waived without
requiring a review of the individual circumstances. However, SWAs are not
required to separately report on the use of blanket waivers. As a result, it is
difficult to determine to what degree SWAs have applied the blanket waiver
authority to pandemic UI programs’ overpayments. As stated earlier, to gain a
comprehensive understanding of this topic, the OIG has initiated an audit
focused of the impact of waivers, including blanket waivers, on the recovery of UI
overpayments, including fraud.
Specifically, our audit found the need for controls to prevent duplicate payments,
which were ultimately waived. This was exemplified by an instance in
Pennsylvania. In July 2020, a third-party contractor made duplicate UI payments
that amounted to approximately $305 million under the PUA program and the
17 ETA’s guidance in Unemployment Insurance Program Letter No. 20-21 and Unemployment
Insurance Program Letter No. 20-21, Change 1, provided SWAs with seven circumstances in
which they could waive overpayments for many individuals who were eligible for waiver of
repayment. These blanket waivers were applied to many individuals with the same set of facts
instead of individually determining eligibility.
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associated supplemental FPUC program. These payments were not the fault of
the recipients, but the fault of the contractor that was hired to process benefits.
Pennsylvania did not have an indemnification clause in its claims processing
contract that required insurance coverage for errors or omissions caused by the
contractor. Initially, the SWA attempted to recover these overpayments by
offsetting them against subsequent claims. In the end, pursuant to ETA guidance
on implementing blanket waivers under the CARES Act, the Pennsylvania SWA
waived the remaining uncollected balance. This resulted in $11 million in
overpayments being waived by the SWA. SWAs’ lack of adequate controls to
prevent and detect improper payments, similar to the issue noted for
Pennsylvania, create opportunities for greater loss to the UI program and
taxpayers.
SWAS Did Not Consistently Use Mandatory
and Strongly Recommended Recovery
Methods
ETA provided guidance to the SWAs under Unemployment Insurance Program
Letter (UIPL) No. 23-2018, issued May 11, 2020, on both mandatory and
strongly recommended overpayment recovery methods to be used for the PUA,
PEUC, and FPUC programs. However, we found that, during the 12-month
period from April 2020 through March 2021, 6 of the 10 SWAs reviewed did not
perform all of the 4 mandatory recovery methods in at least 1 of the
3 federally-funded programs. Further, all 10 audited SWAs did not perform all
of the 6 ETA strongly recommended recovery methods in at least 1 of the
3 federally-funded programs.
The results from our survey responses were like those of the audited SWAs for
the same time period. Seven (44 percent) of the 16 SWAs that responded to
the survey did not perform at least 1 of the 4 mandatory recovery methods.
Fifteen (94 percent) of the 16 SWAs that responded to the survey did not
perform at least 1 of the 6 ETA strongly recommended recovery methods
during our audit period.
The four recovery methods mandated by law were as follows:
1. Interstate Reciprocal Offset Recovery Arrangement
18 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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2. Cross-Program Offset Recovery Agreement
3. Treasury Offset Program (TOP)
4. Benefit Offset
Additionally, the six recovery methods strongly recommended by ETA were as
follows:
1. State Income Tax Offset Program
2. Wage Garnishments
3. Civil Actions
4. Property Liens
5. Collection Agency Referrals
6. Credit Bureau Referrals
Table 1 summarizes the number of audited SWAs that did not perform the
mandatory and strongly recommended recovery methods.
Table 1: Number of Overpayment Recovery Methods Not Performed by
Audited SWAs
Ten Audited SWAs
Recovery Methods Program:
PUA PEUC FPUC
Mandatory
Interstate Reciprocal Offset Recovery
5 4 5
Arrangement
Cross-Program Offset Recovery
3 2 3
Agreement
Treasury Offset Program 3 2 4
Benefit Offset 1 1 1
ETA Strongly Recommended
State Income Tax Offset Program 2 2 2
Wage Garnishments 6 6 6
Civil Actions 5 5 5
Property Liens 7 7 7
Collection Agency Referrals 9 9 9
Credit Bureau Referrals 9 9 9
Source: Compiled using information provided by the selected SWAs
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At the peak of the pandemic, during calendar year 2020, SWAs prioritized
benefit payments over prevention, detection, and recovery activities. This was
due to SWAs implementing new temporary programs while serving an
unprecedented number of claimants. As previously mentioned, the high
number of claims resulted in some SWAs shifting their staff resources from
recovery activities to focus on claims payment. For instance, through state
executive order, 3 of the 10 audited SWAs chose to suspend some collection
activities to focus on getting UI benefits to claimants.19
Additionally, antiquated information systems that were not easily modifiable to
accommodate the pandemic-related UI programs compounded some SWAs’
challenges. According to the audited SWAs, one reason SWAs did not use the
mandatory recovery methods was that they had not made the necessary
system modifications to allow them to perform recovery activities.
SWAs indicated that one of the reasons they did not use the ETA strongly
recommended recovery methods was because their state laws and regulations
did not allow them to collect overpayments using those methods. For those
states, legislation or other regulations would need to be passed for them to use
those methods to collect overpayments. For example, some SWAs did not use
the ETA strongly recommended State Income Tax Offset Program because
their states did not levy state income taxes. Further, other SWAs did not use
some of the ETA strongly recommended recovery methods because they did
not deem the respective methods to be cost-effective.
DOL has limited authority to compel SWAs to use mandatory and strongly
recommended procedures to prevent, detect, and recover overpayments,
resulting in high improper payment rates during economic crises. ETA conducts
monitoring activities of SWAs using historical data and issues findings to states
for corrective action. ETA also uses the State Quality Service Plan process to
hold states accountable for past performance deficiencies and to deal with
open monitoring findings that have not been corrected. ETA’s last resort
against states that do not comply with mandatory UI activities is to withhold
administrative funds. This action, however, would only occur after notice and
hearing.
19 On March 30, 2020, Texas suspended the use of the mandatory Benefit Offset, TOP, and
Cross-Program Offset Recovery Agreement recovery activities. These recovery activities were
not reinstated until May 28, 2021. Washington suspended the use of wage garnishments,
property liens, or civil actions during the period from March 2020 through April 6, 2021.
Washington’s use of these recovery activities resumed in the fall of 2021 with approval from the
SWA’s Commissioner and Deputy Commissioner. Rhode Island suspended the use of the state
income tax offset program during the period from March 2020 through April 6, 2021, to allow its
citizens to retain their tax returns during the COVID-19 pandemic.
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It is notable that the temporary pandemic programs were not administered
under the same laws as the regular UI program. Instead, through agreements
with DOL, states administered the pandemic UI programs under the CARES
Act, as amended. DOL could have terminated a state’s agreement if it
determined that the state was not complying with the requirements of the
CARES Act or applicable guidance. However, this would have stopped delivery
of temporary economic relief intended for those left unemployed by the
COVID-19 pandemic.
DOL included a legislative proposal in the President’s Fiscal Year 2024 and
Fiscal Year 2025 budgets to provide the DOL Secretary with meaningful
enforcement authority and the ability to reward good performance for the
regular UI program. The proposal would provide DOL with alternative
administrative options to withholding a state’s entire administrative grant for
failing to meet the performance measures or achieve minimum technology
standards. Specifically, the proposal would allow the DOL Secretary to require
a portion of the state’s administrative grant to be used to correct failing
performance and/or have the state participate in required technical assistance
activities offered by DOL. DOL has also proposed allowing states to retain up
to 5 percent of recovered fraudulent UI overpayments for program integrity use.
For example, for states to increase detection and recovery of improper
payments.
Limitations of Overpayment Recovery Methods
Additionally, we found both federal and state laws and regulations limit how
much SWAs could potentially collect on UI overpayments. When using TOP
and Benefit Offset recovery methods, existing federal and state laws and
regulations limit: (1) what types of overpayments can be recovered, (2) who
can recover the overpayments, (3) when to collect the overpayments, and
(4) how long overpayments can be recovered.
Treasury Offset Program Limitations
Federal law permits SWAs to collect certain UI overpayments using TOP.
Under TOP, the U.S. Department of Treasury collects certain delinquent
federal and state debts by intercepting federal income tax refunds. We
identified three key legal restrictions on SWAs’ ability to use TOP.
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First, by law,20 third-party contractors are prohibited from accessing TOP
Federal Tax Information for recovering benefit overpayments. As a result,
SWAs that use contractors to perform such recovery efforts may not be able to
use TOP as an overpayment recovery method. For example, Pennsylvania
used TOP to recover PEUC and FPUC program overpayments. However, it did
not enroll the PUA program in TOP because the SWA’s PUA program was
operated from a stand-alone UI system that was created and maintained by a
third-party contractor. Contractors played an essential role in SWAs’
implementation of emergency pandemic UI programs and would likely be
needed in handling benefit payments during future emergency programs. ETA
indicated that DOL included a legislative proposal in the President’s Fiscal
Year 2024 and Fiscal Year 2025 budgets that would allow SWAs to use
contractors to recover overpayments using TOP.
Second, SWAs can only use TOP when overpayments have been outstanding
for at least 1 year. This is a concern because the sooner SWAs can initiate
recovery activities, the more likely they are to recover overpayments. According
to ETA, states can use other recovery methods before submitting a debt to
TOP. ETA noted Congress intended TOP to be a recovery method of last
resort to be used after all other methods were unsuccessful.
Third, SWAs must only use TOP to recover fraudulent overpayments,
overpayments caused by the claimant’s failure to report earnings, or delinquent
unemployment compensation tax debt.21 Legislative changes would need to
address these limitations for TOP to be useful in circumstances like the
exampled overpayment error in Pennsylvania. ETA noted that Congress made
a deliberate policy decision to limit the use of TOP to situations involving fraud
and the other noted situations. According to ETA, the interception of an
individual’s federal tax refund in circumstances where the individual was not at
fault or made unintentional errors would seem to be rather harsh.
Benefit Offset Program Limitations
Under the Benefit Offset recovery method, SWAs are required to offset any UI
overpayments—paid under regular UI and other state and federal UI programs
and not previously recovered—against UI benefits due to a claimant under
20 Contractors may access TOP Federal Tax Information under the authority established in
26 U.S.C. § 6103 for purposes of tax administration. However, no contractors may be granted
access to TOP Federal Tax Information received under 26 U.S.C. § 6103(l)(10) for benefit
administration.
21 26 U.S.C. § 6402(f)(4), Covered unemployment compensation debt.
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states’ UI law22. The CARES Act23 did not allow SWAs to conduct Benefit
Offset after 3 years from the date overpayments were received by claimants
under the PEUC and FPUC programs. This 3-year limit does not apply to
overpayments under the PUA program. Some states also have limitations on
how long Benefit Offset can be applied against UI overpayments. According to
ETA, Congress limited the duration of Benefit Offset as a matter of policy.
ETA’s concern with an unlimited timeframe for use of Benefit Offset is that, in
the next recession when the economy is seeing a major infusion of funding into
the economy, UI benefits for many individuals would be reduced or not
available as they would be used to offset overpayments. ETA added there was
a conscious decision to ensure the recovery policy did not have that type of
impact in the next recession.
State Finality Laws Restrict SWAs’ Ability to
Collect UI Overpayments
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. In late December 2023, ETA issued UIPL No. 05-2424, which
authorized SWAs to apply state finality laws to CARES Act-funded UI benefits. In
doing so, ETA no longer required SWAs to perform retroactive actions to
reconsider or re-determine prior determinations or decisions regarding whether
benefits payments were proper. Therefore, if the period for reconsideration in the
state’s finality law has elapsed for any given claim, the SWA may no longer
review if that claim was properly disbursed.
According to ETA, a state that is relying on its finality law in administering the
CARES Act UI programs should evaluate its outstanding monitoring findings. If
the state’s finality law limits the extent of retroactive action necessary, the state
should provide an explanation to the appropriate ETA Regional Office. The
CARES Act allows SWAs to waive repayments of overpayments of PUA, PEUC,
and FPUC program benefits if the SWA determines that the benefit payments
were not the fault of the claimant, and that such repayment would be contrary to
equity and good conscience.
22 UIPL No. 05-13, Work Search and Overpayment Offset Provisions Added to Permanent
Federal Unemployment Compensation Law by Title II, Subtitle A of the Middle-Class Tax Relief
and Job Creation Act of 2012 (January 10, 2013)
23 Sections 2104(f)(3)(A) and 2107(e)(3)(A) of the CARES Act, as amended.
24 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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However, for the PEUC and FPUC programs, the CARES Act also states SWAs
“shall recover” improper payments within 3 years of the date of the improper
payment in accordance with the same procedures as apply to the recovery of
overpayments of regular unemployment benefits paid by the SWA. With ETA
now permitting SWAs to defer to their state finality laws, any fraudulent improper
payments that a SWA may have inadvertently waived for these programs will no
longer be reviewable if the state finality law has elapsed. Additionally, improper
payments that federal law would previously have required SWAs to collect will be
unrecoverable. While the additional guidance provided in UIPL No. 05-24 is a
policy decision within the purview of DOL, we are concerned about the
implications of the UIPL from an investigative and oversight perspective.
We are concerned that, by applying state finality laws to the emergency
pandemic funding, states will not have an incentive to identify overpayments and
fraud in pandemic UI programs. Per UIPL No. 05-24, there are some states that
have never operated certain CARES Act programs in compliance with federal
laws, rules, or regulations. Further, as noted above, we found that the
overpayment recovery rates for all SWAs, including the 10 we audited, were far
below ETA’s core performance measure for regular UI paid from state trust
funds. Specifically, the 10 audited SWAs and all SWAs waived more in
overpayments than they recovered and the 10 audited SWAs and all SWAs
established significantly less improper payments for recovery than what we
calculated using the reported UI improper payment rate. Additionally, we found
that all SWAs across the nation reported they established overpayments and
recovered overpayments of approximately $1.4 billion and $293.8 million,
respectively and collectively, in the first two calendar quarters of 2024 (see
Exhibit 7). This further shows there is still a significant amount of overpayments
yet to be established and recovered. Together, this information paints a
concerning picture regarding the potential impact of improper payments on the
American taxpayer if, due to finality laws, states stop identifying and recovering
overpayments including potentially fraudulent overpayments.
DOL has the authority to continue requiring states to correct implementation
errors in these programs, even in the face of state jurisdictional limitations. This
authority is crucial in ensuring compliance with federal requirements and in the
recovery of erroneously paid benefits. However, we are concerned that, instead
of requiring states to fix their errors and come into compliance with federal law,
this UIPL allows them to apply state finality laws so that millions of dollars in
overpayments—potentially including fraud—will no longer be allowed to be
reviewed.
While DOL’s guidance correctly states that recovery of fraudulent payments may
not be waived, there is the possibility that states may have unintentionally waived
or will waive fraudulent payments. ETA’s recent guidance regarding finality laws,
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combined with the use of waivers, could result in a substantial increase in the
amount of unrecovered improper payments, possibly including fraudulent
payments, in pandemic-related UI programs. For PEUC and FPUC, waivers
amplify the risk that deference to state finality laws presents. Specifically, by
permitting states to waive improper payments that appear not to be the fault of
the claimant—but which may in fact have been fraudulent—the SWAs are no
longer required or permitted to reconsider determinations on PEUC and FPUC
overpayments if their state finality law has elapsed. Further, while the application
of state finality laws does not prevent law enforcement agencies from
investigating and prosecuting fraud, the initial detection of such cases is often the
result of SWAs’ programmatic oversight activities. If state agencies are relieved
from their obligation to look into cases beyond the finality period, a significant
number of fraud cases might go undetected and, consequently, unprosecuted.
According to ETA, the application of finality laws was allowed with the goal of
enabling states to concentrate their energies and resources on adjudicating
current claims. Also, ETA’s aim was to help states engage in DOL’s
modernization and fraud prevention efforts to ensure they will be prepared in the
event of a future economic downturn. We recognize this change in policy signals
a shift in focus from retrospective correction and recovery to a more
forward-looking approach. While we agree such a focus is undoubtedly
important, and within DOL’s programmatic authority, it should not come at the
cost of SWAs ceasing to detect and address ongoing or past instances of
overpayment and fraud. These improper payment recovery activities are crucial
for maintaining the integrity of the unemployment benefits system and public trust
in these programs.
RECOMMENDATIONS
We recommend the Assistant Secretary for Employment and Training:
1. Develop lessons learned based on the control failures identified by
SWAs that led them to request the use of blanket waivers for
overpayments. Provide SWAs with guidance, technical assistance, and
other resources, as needed, to address the root causes of
overpayments.
2. Require SWAs to use all mandatory recovery methods permitted under
federal law and provide resources, as needed, for SWAs to use ETA’s
strongly recommended recovery methods.
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3. Continue to work with Congress to lift restrictions on the use of contractors
for the Treasury Offset Program recovery method.
4. Continue to work with Congress to develop incentives for SWAs to:
(1) detect and address ongoing or past instances of overpayment and
fraud, and (2) recover federally-funded UI overpayments.
Analysis of Agency’s Comments
The OIG issued a draft of this report to ETA officials for comment in
December 2024. Due to recent senior leadership changes, ETA was unable
to provide a timely response. As such, we are issuing the final report without
ETA’s response. Upon receipt of a response from ETA, we will post it, along
with our analysis of management’s comments, on our website.
We appreciate the cooperation and courtesies ETA extended to us during this
audit.
Regis & Associates, PC
Washington, DC
March 27, 2025
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EXHIBIT 1: OVERALL RECOVERY RATES FOR 10 AUDITED SWAS
– APRIL 1, 2020, THROUGH SEPTEMBER 30, 2022
Established Recovered Waived Recovery
Program Overpayments Overpayments Overpayments Rate
(a) (b) (c) (d=b/(a-c))
PUA $3,965,073,493 $1,068,614,533 $47,983,537 27%
PEUC $1,448,071,174 $126,993,172 $408,191,812 12%
FPUC $4,983,515,777 $203,382,816 $1,544,393,781 6%
Grand
$10,396,660,444 $1,398,990,521 $2,000,569,130 17%
Total
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs.
The data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on January 5, 2023). We
observed that some SWAs did not report all their activity.
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EXHIBIT 2: NON-FRAUDULENT AND FRAUDULENT RECOVERY
RATES FOR 10 AUDITED SWAS – APRIL 1, 2020, THROUGH
SEPTEMBER 30, 2022
Non-fraudulent
Established Recovered Waived Recovery
Program Overpayment Overpayments Overpayments Rates
(a) (b) (c) (d=b/(a-c))
PUA $3,510,163,746 $1,051,229,032 $47,983,537 30%
PEUC $1,398,190,980 $121,303,792 $408,191,812 12%
FPUC $4,812,002,762 $185,606,465 $1,544,393,781 6%
Grand
$9,720,357,488 $1,358,139,289 $2,000,569,130 18%
Total
Fraudulent
Established Recovered Waived Recovery
Program Overpayment Overpayments Overpayments Rates
(a) (b) (c) (d=b/(a-c))
PUA $454,909,747 $17,385,501 $0 4%
PEUC $49,880,194 $5,689,380 $0 11%
FPUC $171,513,015 $17,776,351 $0 10%
Grand
$676,302,956 $40,851,232 $0 6%
Total
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs.
The data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on January 5, 2023). We
observed that some SWAs did not report all their activity.
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EXHIBIT 3: OVERALL RECOVERY RATES FOR ALL SWAS – APRIL
1, 2020, THROUGH SEPTEMBER 30, 2022
Established Recovered Waived Recovery
Total Benefits
Program Overpayments Overpayments Overpayments Rate
Paid
(a) (b) (c) (d=b/(a-c)
PUA $131,139,943,797 $15,313,419,977 $1,408,453,706 $1,259,686,564 10%
PEUC $85,743,787,494 $2,938,287,156 $342,141,353 $497,872,012 14%
FPUC $441,598,718,343 $18,677,073,667 $792,744,134 $1,995,849,818 5%
Grand
$658,482,449,634 $36,928,780,800 $2,543,339,193 $3,753,408,394 8%
Total
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs.
The data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on January 5, 2023). We
observed that some SWAs did not report all their activity.
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EXHIBIT 4: NON-FRAUDULENT AND FRAUDULENT RECOVERY
RATES FOR ALL SWAS – APRIL 1, 2020, THROUGH
SEPTEMBER 30, 2022
Non-Fraudulent
Established Recovered Waived Recovery
Program Overpayment Overpayments Overpayments Rates
(a) (b) (c) (d=b/(a-c))
PUA $13,685,540,297 $1,369,010,168 $1,259,686,564 11%
PEUC $2,738,588,893 $312,398,940 $497,872,012 14%
FPUC $16,902,020,071 $716,675,885 $1,995,849,818 5%
Grand
$33,326,149,261 $2,398,084,993 $3,753,408,394 8%
Total
Fraudulent
Established Recovered Waived Recovery
Program Overpayment Overpayments Overpayments Rates
(a) (b) (c) (d=b/(a-c))
PUA $1,627,879,680 $39,443,538 $0 2%
PEUC $199,698,263 $29,742,413 $0 15%
FPUC $1,775,053,596 $76,068,249 $0 4%
Grand
$3,602,631,539 $145,254,200 $0 4%
Total
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs.
The data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on January 5, 2023). We
observed that some SWAs did not report all their activity.
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EXHIBIT 5: ESTIMATED UNESTABLISHED OVERPAYMENTS FOR
10 AUDITED SWAS – APRIL 1, 2020, THROUGH
SEPTEMBER 30, 2022
Estimated Estimated
Total Benefits Established
Program Overpayments Unestablished
Paid Overpayments
(c=a*Overpayment Overpayments
(a) (b)
Rate25) (d=c-b)
PUA $31,671,115,660 $3,965,073,493 $5,384,089,662 $1,419,016,169
PEUC $29,368,199,385 $1,448,071,174 $5,813,537,187 $4,365,466,013
FPUC $115,056,311,069 $4,983,515,777 $22,696,530,260 $17,713,014,483
Grand
$176,095,626,114 $10,396,660,444 $33,894,157,109 $23,497,496,665
Total
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs. The
data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on January 5, 2023). We
observed that some SWAs did not report all their activity.
25 We applied the ETA-determined overpayment rate of 17 percent for the PUA program to the
total benefits paid by each of the audited SWAs. This overpayment rate was part of the
ETA-determined PUA improper payment rate. The PUA improper payment rate report is
available at:
https://oui.doleta.gov/unemploy/pdf/Pandemic_Unemployment_Assistance_Improper_Payment_
Rate_Report.pdf. We obtained the overpayment rates for PEUC and FPUC from the improper
payments rates data available on the ETA website at:
https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/data. For the
PEUC and FPUC program, we applied the 2021, 1-year overpayment rates data for each state
to each SWAs’ benefits paid for the period from April 1, 2020, through June 30, 2021. For the
period from July 1, 2021, through September 30, 2022, we applied the 2022, 1-year
overpayment rates data for each state to each SWAs’ PEUC and FPUC benefits paid.
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EXHIBIT 6: ESTIMATED UNESTABLISHED OVERPAYMENTS FOR
ALL SWAS – APRIL 1, 2020, THROUGH SEPTEMBER 30, 2022
Estimated Estimated
Established
Total Benefits Overpayments Unestablished
Overpayments
Program Paid (c=a*Overpayment Overpayments
(b)
(a) Rate26) (d=c-b)
PUA $131,139,943,797 $15,313,419,977 $22,293,790,445 $6,980,370,468
PEUC $85,743,787,494 $2,938,287,156 $15,577,156,131 $12,638,868,975
FPUC $441,598,718,343 $18,677,073,667 $80,231,818,818 $61,554,745,151
Grand
$658,482,449,634 $36,928,780,800 $118,102,765,395 $81,173,984,595
Total
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs. The
data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on January 5, 2023). We
observed that some SWAs did not report all their activity.
26 We applied the ETA-determined overpayment rate of 17 percent for the PUA program to the
total benefits paid by all SWAs. This overpayment rate was part of the ETA-determined PUA
improper payment rate. The PUA improper payment rate report is available at:
https://oui.doleta.gov/unemploy/pdf/Pandemic_Unemployment_Assistance_Improper_Payment_
Rate_Report.pdf. We obtained the overpayment rates used for PEUC and FPUC from the
improper payments rates data available on the ETA website at:
https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/data. For the
PEUC and FPUC program, we applied the 2021, 1-year national average overpayment rate of
18.17 percent to all SWAs’ benefits paid for the period from April 1, 2020, through June 30,
2021. For the period from July 1, 2021, through September 30, 2022, we applied the 2022,
1-year national average overpayment rate of 18.15 percent to all SWAs’ PEUC and FPUC
benefits paid.
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EXHIBIT 7: OVERALL OVERPAYMENT ACTIVITY FOR ALL SWAS –
JANUARY 1, 2024, THROUGH JUNE 30, 2024
Established Recovered
Program
Overpayments Overpayments
PUA $405,506,955 $83,726,463
PEUC $116,726,769 $45,660,824
FPUC $927,538,254 $164,440,683
Grand Total $1,449,771,978 $293,827,970
Source: Compiled and calculated using data obtained from ETA reports submitted by SWAs.
The data was downloaded from the ETA website at:
https://oui.doleta.gov/unemploy/DataDownloads.asp (last accessed on September 16, 2024).
We observed that some SWAs did not report all their activity.
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APPENDIX A: SCOPE AND METHODOLOGY
Scope
The audit covered ETA’s and SWAs’ efforts to recover improper payments in the
three key pandemic-related UI programs—PUA, PEUC, and FPUC. Additionally,
analyses of recovery activities for the period from April 1, 2020, through
September 30, 2022, were also performed using data reported by the SWAs on
ETA required reports. There were 10 states selected by the OIG (at least 1 from
each of the 6 ETA regions) for in-depth examination. These states were
Connecticut, Florida, New Jersey, North Carolina, Pennsylvania, Rhode Island,
South Carolina, Texas, Washington, and Wisconsin. In addition, survey
questionnaires were sent to the remaining 43 states to obtain key information
about their efforts to recover improper payments.
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 objectives.
We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
To answer our audit objective, we:
• reviewed federal and state regulations, policies, and procedures,
• conducted walk-throughs and interviewed key management and
personnel from ETA and SWAs,
• designed audit procedures to test ETA’s and SWAs’ efforts on recovering
improper payments, and
• downloaded key ETA reports and analyzed the recovery-related data.
Internal Controls
In planning and performing the audit, we obtained an understanding of ETA’s
and SWAs’ internal controls that were considered significant to the audit
objective. We used our understanding of the internal controls to help design
audit procedures relevant to the audit objective and not to provide assurance on
the internal controls. Consequently, we did not express an opinion on ETA’s or
SWAs’ internal controls. Our consideration of internal controls for recovering
improper payments would not necessarily disclose all matters that might rise to
the level of significant deficiencies.
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Our approach for this performance audit was a risk-based methodology. This
approach ensured that we deployed resources to the most vulnerable areas of
waste, fraud, and abuse, while minimizing any redundant efforts.
We obtained and documented an understanding of ETA’s and the reviewed
SWAs’ relevant policies, procedures, and related controls, including identifying
risks related to:
• the nature of operations,
• structure, oversight, and governance,
• activities and external environment, including the regulatory, economic,
political, and social environment,
• specific risks related to the implementation of the CARES Act-related
programs,
• root causes resulting in improper benefit payments (i.e., fraudulent
payments, overpayments, and the inability of SWAs to validate initial and
ongoing program eligibility requirements), and
• other challenges (i.e., program fraud, fraud vulnerabilities, information
technology systems, staffing, and monitoring).
Additionally, if general information technology and information systems controls
were determined to be significant to meet the objective of our audit, we obtained
a sufficient understanding of the information systems controls necessary to
assess audit risk and plan our audit procedures within the context of the audit
objectives.
Selection of States
The OIG judgmentally selected the 10 states for an in-depth review based on
10 risk factors. These risk factors included total federal UI funding, the amount
of improper UI payments and improper UI payment rates, number of UI claims
filed, and UI fraud rate. The states selected must have signed agreements with
ETA under Section 2104(b) of the CARES Act. In selecting the states, the OIG
also considered whether a state had been selected in previous OIG audits
focusing on UI programs. We conducted an in-depth examination of the
10 states selected by the OIG. In addition, we sent surveys to 43 states that had
signed CARES Act-related agreements with ETA under Section 2104(b) of the
CARES Act—16 states27 responded to the surveys.
Sampling
We applied non-statistical sampling to verify compliance with the CARES Act,
Continued Assistance Act, and ARPA. To test controls and compliance with
27 The 16 states included Alaska, Colorado, Delaware, District of Columbia, Georgia, Iowa,
Louisiana, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New York, South
Dakota, and West Virginia.
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rules and regulations, we used an approach prescribed in the generally
accepted government auditing standards to judgmentally28 select a sample from
benefit payments and reports submitted to ETA.
Data Reliability
We corroborated the pandemic-related UI programs’ data obtained from the
ETA website with source data received from the SWAs. Data on benefit
payment overpayments, along with waiver and recovery of overpayments, was
obtained from summaries of required reports that SWAs submitted to ETA.
Criteria
• Coronavirus Aid, Relief, and Economic Security (CARES) Act, Public
Law 116-136 (March 27, 2020)
• Consolidated Appropriations Act, 2021, including Division N, Title II,
Subtitle A, the Continued Assistance for Unemployed Workers Act of
2020 (December 27, 2020)
• American Rescue Plan Act of 2021 (ARPA), including Title IX,
Subtitle A, Crisis Support for Unemployed Workers, Public Law 117-2
(January 3, 2021)
• UIPL No. 15-20, CARES Act of 2020 -- Federal Pandemic
Unemployment Compensation (FPUC) Program Operating, Financial,
and Reporting Instructions (April 4, 2020)
• UIPL No. 16-20, CARES Act of 2020 -- Pandemic Unemployment
Assistance (PUA) Program Operating, Financial, and Reporting
Instructions (April 5, 2020)
• UIPL No. 17-20, CARES Act of 2020 -- Pandemic Emergency
Unemployment Compensation (PEUC) Program Operating, Financial,
and Reporting Instructions (April 10, 2020)
• UIPL No. 23-20, Program Integrity for the Unemployment Insurance
(UI) Program and the UI Programs Authorized by the CARES Act of
2020 -- Federal Pandemic Unemployment Compensation, Pandemic
Unemployment Assistance, and Pandemic Emergency Unemployment
Compensation Programs (May 11, 2020)
• UIPL No. 28-20, Addressing Fraud in the Unemployment Insurance (UI)
System and Providing States with Funding to Assist with Efforts to
Prevent and Detect Fraud and Identity Theft and Recover Fraud
Overpayments in the Pandemic Unemployment Assistance (PUA) and
Pandemic Emergency Unemployment Compensation (PEUC) Programs
(August 31, 2020)
28 Judgmental sampling is a non-probability sampling technique in which the sample members
are chosen based on the auditor’s knowledge and judgment.
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• UIPL No. 09-21, Continued Assistance for Unemployed Workers Act of
2020 -- Summary of Key Unemployment Insurance (UI) Provisions
(December 30, 2020)
• 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)
Prior Relevant Coverage
During the last 3 years, the OIG issued 8 reports of significant relevance to the
subject of this report. Those reports are as follows:
1. COVID-19: ETA Needs a Plan to Reconcile and Return to the U.S.
Treasury Nearly $5 Billion Unused by States for a Temporary
Unemployment Insurance Program
Report No. 19-23-015-03-315 (September 28, 2023) available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-015-03-315.pdf
2. COVID-19: Pandemic Unemployment Assistance for Non-Traditional
Claimants Weakened by Billions in Overpayments, Including Fraud
Report No. 19-23-014-03-315 (September 27, 2023) available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-014-03-315.pdf
3. COVID-19: Audit of State Workforce Agencies’ Information Technology
Systems Capability in Processing Unemployment Insurance Claims
Report No. 19-23-008-03-315 (September 19, 2023) available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-008-03-315.pdf
4. COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds
from Improper Payments Including Fraud or from Payment Delays
Report No. 19-22-006-03-315 (September 30, 2022) available at:
https://www.oig.dol.gov/public/reports/oa/2022/19-22-006-03-315.pdf
5. COVID-19: States Struggled to Implement Cares Act Unemployment
Insurance Programs
Report No. 19-21-004-03-315 (May 28, 2021), available at:
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf
6. COVID-19: More Can Be Done to Mitigate Risk to Unemployment
Compensation under the CARES Act
Report No. 19-20-008-03-315 (August 7, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2020/19-20-008-03-315.pdf
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7. Alert Memorandum: The Pandemic Unemployment Assistance Program
Needs Proactive Measures to Detect and Prevent Improper Payments
and Fraud
Report No. 19-20-002-03-315 (May 26, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2020/19-20-002-03-315.pdf
8. Advisory Report, CARES Act: Initial Areas of Concern Regarding
Implementation of Unemployment Insurance Provisions
Report No. 19-20-001-03-315 (April 21, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2020/19-20-001-03-315.pdf
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REPORT FRAUD, WASTE, OR ABUSE
TO THE DEPARTMENT OF LABOR
Online
https://www.oig.dol.gov/hotline.htm
Telephone
(800) 347-3756 or (202) 693-6999
Fax
(202) 693-7020
Address
Office of Inspector General
U.S. Department of Labor
200 Constitution Avenue NW
Room S-5506
Washington, DC 20210
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