Report — COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds from Improper Payments (OIG)
Summary
A Department of Labor Office of Inspector General report to the Employment and Training Administration, report number 19-22-006-03-315, issued September 30, 2022, titled COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds from Improper Payments Including Fraud or from Payment Delays. The report states that, of the 4 states tested, from March 28, 2020, through September 30, 2020, OIG estimated $30.4 billion of the $71.7 billion in PUA and FPUC benefits were paid improperly (42.4 percent). It states that OIG made five recommendations to ETA and that ETA agreed or partially agreed with three of the five recommendations.
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“Report — COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds from Improper Payments (OIG).”
Original at www.oig.dol.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/dol-oig-19-22-006-318e56994a/
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REPORT TO THE EMPLOYMENT
AND TRAINING ADMINISTRATION
COVID-19: ETA AND STATES DID NOT
PROTECT PANDEMIC-RELATED
UI FUNDS FROM IMPROPER
PAYMENTS INCLUDING FRAUD OR
FROM PAYMENT DELAYS
DATE ISSUED: SEPTEMBER 30, 2022
REPORT NUMBER: 19-22-006-03-315
U.S. Department of Labor
Office of Inspector General WHAT OIG FOUND
Audit
We found ETA and states did not ensure
pandemic-related UI funds were paid only to
eligible individuals promptly. Of the 4 states we
BRIEFLY… tested, from March 28, 2020, through
September 30, 2020, we estimated $30.4 billion
of the $71.7 billion in PUA and FPUC benefits
were paid improperly (42.4 percent). We
COVID-19: ETA AND STATES DID NOT
estimated $9.9 billion of that was paid to likely
PROTECT PANDEMIC-RELATED UI FUNDS
fraudsters (13.8 percent). Notably, in the
FROM IMPROPER PAYMENTS INCLUDING
4 states, 1 in 5 dollars initially paid in
FRAUD OR FROM PAYMENT DELAYS
PUA benefits went to likely fraudsters.
September 30, 2022
Federal guidance required states to prioritize
expediency, but we also found many Americans
WHY OIG CONDUCTED THE AUDIT
faced lengthy delays in receiving UI payments.
States continued to be challenged by the
On March 27, 2020, under the Coronavirus Aid,
increase in claims’ volume while implementing
Relief, and Economic Security (CARES) Act,
the new UI programs. From March 28, 2020,
Congress provided expanded Unemployment
through March 14, 2021, the 4 states were able
Insurance (UI) benefits to workers who were
to pay 86 percent of PUA claimants timely;
unable to work as a direct result of the
however, they took more than 30 days to pay
COVID-19 pandemic. The expanded benefits
14 percent of all reported PUA claimants. Also,
required the Employment and Training
during the year after the CARES Act passed,
Administration (ETA) to oversee states’
48 of 53 SWAs were unable to timely pay
implementing major changes to the UI system.
regular UI claims, and, based on our analysis of
ETA’s timeliness reports, at least 6.2 million
Our pandemic response oversight focus
American workers nationwide waited a month
includes three high-risk temporary UI programs:
or more for pandemic-related UI benefits.
Pandemic Unemployment Assistance (PUA),
Pandemic Emergency Unemployment
ETA and states made significant efforts;
Compensation (PEUC), and Federal Pandemic
however, they did not protect pandemic-related
Unemployment Compensation (FPUC). The
UI funds from historic levels of improper
3 programs, as of April 23, 2022, had paid
payments. We attribute this to four causes:
$663.8 billion in pandemic-related UI benefits.
states did not perform eligibility testing, ETA’s
oversight was not timely enough, PUA initially
WHAT OIG DID
allowed claimants to self-certify their eligibility,
and ETA suspended 1 of their primary oversight
We conducted this performance audit to answer
tools for the first 3 months of the CARES Act.
the following question:
Furthermore, ETA’s interpretation of its
regulations hindered the OIG’s timely and
Did ETA and states ensure UI benefits were
complete access to state UI claims data to
paid only to eligible individuals promptly?
assist in detecting and deterring fraud.
To do so, we assessed ETA’s oversight,
WHAT OIG RECOMMENDED
surveyed 49 State Workforce Agencies
(SWA or state), and performed in-depth testing,
We made five recommendations to ETA to
including case file reviews, for 4 states.
improve oversight to minimize payment delays
and improper payments, including fraud. ETA
READ THE FULL REPORT
agreed or partially agreed with three of the five
recommendations and provided an acceptable
https://www.oig.dol.gov/public/reports/oa/2022/
alternative for one recommendation.
19-22-006-03-315.pdf
U.S. Department of Labor – Office of Inspector General
TABLE OF CONTENTS
INSPECTOR GENERAL’S REPORT .................................................................... 1
RESULTS ............................................................................................................. 3
IN 6 MONTHS, 4 STATES PAID 42.4 PERCENT OF UI BENEFITS
IMPROPERLY, INCLUDING NEARLY 14 PERCENT PAID TO
LIKELY FRAUDSTERS .............................................................................. 4
MORE THAN 6 MILLION AMERICANS WAITED AT LEAST A
MONTH FOR PANDEMIC-RELATED UI BENEFITS ............................... 21
OIG’S RECOMMENDATIONS ............................................................................ 26
SUMMARY OF ETA’S RESPONSE ......................................................... 26
EXHIBIT 1: FUNDING FOR THREE NEW KEY PANDEMIC-RELATED UI
PROGRAMS, AS OF 3/14/20 ............................................................................. 28
EXHIBIT 2: COSTS PAID TO LIKELY FRAUDSTERS OR IDENTITY FRAUD
CASES ................................................................................................................ 29
EXHIBIT 3: TIMELINESS REPORTING BY STATE ........................................... 30
APPENDIX A: SCOPE, METHODOLOGY, & CRITERIA .................................... 32
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ............................... 36
APPENDIX C: ACKNOWLEDGMENTS .............................................................. 56
-i-
U.S. Department of Labor Office of Inspector General
Washington, DC 20210
INSPECTOR GENERAL’S REPORT
Brent Parton
Acting Assistant Secretary
for Employment and Training
U.S. Department of Labor
200 Constitution Ave. NW
Washington, DC 20210
This report presents the results of the Office of Inspector General’s (OIG) audit of
the Employment and Training Administration (ETA) and states’ Unemployment
Insurance (UI) programs under the Coronavirus Aid, Relief, and Economic
Security (CARES) Act and related extensions. Among other support, the
CARES Act expanded UI benefits to workers unemployed as a direct result of the
COVID-19 pandemic, including by creating three key pandemic-related UI
programs: Pandemic Unemployment Assistance (PUA), Pandemic Emergency
Unemployment Compensation (PEUC), and Federal Pandemic Unemployment
Compensation (FPUC).
Shortly after the CARES Act passed, we issued an advisory report 1 that identified
concerns about state preparedness. In our May 2021 CARES Act UI audit, 2 we
found states struggled to pay claimants and to protect funds from improper
payments, including fraud. States were challenged by the unprecedented
increase in claims and by implementing the new programs and statutory changes
to existing UI programs and did not perform required and recommended
improper payment detection and recovery activities. As of April 23, 2022, ETA
reported the 3 key pandemic-related UI programs had paid $663.8 billion of the
total estimated $872.5 billion paid in pandemic-related UI benefits.
1
CARES Act: Initial Areas of Concern Regarding Implementation of Unemployment Insurance
Provisions, Report No. 19-20-001-03-315 (April 21, 2020),
https://www.oig.dol.gov/public/reports/oa/2020/19-20-001-03-315.pdf
2
COVID-19: States Struggled to Implement Cares Act Unemployment Insurance Programs,
Report No. 19-21-004-03-315 (May 28, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf
PANDEMIC-RELATED UI ELIGIBILITY AND TIMELINESS
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U.S. Department of Labor – Office of Inspector General
As part of our continuing pandemic response oversight work, we conducted this
performance audit to answer the following question:
Did ETA and states ensure UI benefits were paid only to eligible
individuals promptly?
To answer this question, we focused on high-risk UI benefit programs including,
but not limited to: PUA, PEUC, and FPUC. Essentially, PUA provided UI benefits
to workers who were not traditionally eligible, 3 PEUC provided additional weeks
of UI benefits to workers who had exhausted their regular benefits, and FPUC
provided a supplement ($600 weekly through July 2020, then, starting in
December 2020, $300 weekly) to workers eligible for at least $1 of UI benefits
(see Figure 1).
Figure 1: Three Key Pandemic-Related UI Programs
Source: CARES Act and related extensions
Created by the CARES Act on March 27, 2020, the three programs were later
extended by the Continued Assistance for Workers Act of 2020 (CAA) and the
American Rescue Plan Act (ARPA), ending on September 6, 2021.
This audit focused on UI benefit payments made between March 28, 2020, and
March 14, 2021. As of March 14, 2021, State Workforce Agencies (SWA or state)
had drawn down $472.2 billion in federal funds to pay UI benefits for PUA,
PEUC, and FPUC (see Exhibit 1). Of the $472.2 billion funds paid in federal
UI funds, almost a third (28 percent) was drawn down by 4 states: California,
Georgia, Kentucky, and Michigan (4 states). We selected these 4 states for
in-depth analysis based on a risk analysis, including an analysis of funding
3
PUA included independent contractors, those with limited work history, and those who otherwise
did not qualify for regular UI or extended benefits under state or federal law or under PEUC.
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U.S. Department of Labor – Office of Inspector General
amounts, law enforcement intelligence, congressional interest, and media
reports.
We asked the other 49 SWAs 4 to complete questionnaires. We also assessed
ETA’s guidance and oversight such as Unemployment Insurance Program
Letters (UIPL) and monitoring reports. Last, we analyzed data all SWAs
submitted in response to Inspector General (IG) subpoenas. We identified
two universes of claimants, one to assess claimant eligibility and the other to
assess SWAs’ timeliness in issuing payments to claimants.
RESULTS
We found ETA and states did not ensure pandemic-related UI funds were paid
only to eligible individuals promptly. Of the 4 states we tested, from
March 28, 2020, through September 30, 2020, we estimated $30.4 billion of the
$71.7 billion in PUA and FPUC benefits were paid improperly (42.4 percent). We
estimated $9.9 billion of that was paid to likely fraudsters 5 (13.8 percent).
Notably, in the 4 states, 1 in 5 dollars initially paid in PUA benefits went to likely
fraudsters. The percentages of improper payments identified during this audit
applied only to the 4 states and were not projected to the nation.
Federal guidance required states to prioritize expediency, but we also found
many Americans faced lengthy delays in receiving UI payments. States
continued to be challenged by the increase in claims’ volume while implementing
the new UI programs and statutory changes to existing UI programs. From
March 28, 2020, through March 14, 2021, the 4 states were able to pay
86 percent of PUA claimants timely; however, they took more than 30 days to
pay 14 percent of all reported PUA claimants. Also, during the year after the
CARES Act passed, 48 of 53 SWAs were unable to timely pay regular UI claims,
and, based on our analysis of ETA’s timeliness reports, at least 6.2 million
4
The 50 states, the District of Columbia, the U.S. Virgin Islands, and Puerto Rico have SWAs
that administer UI programs.
5
We specifically use the term “likely” when referring to fraudulent claims for which the source of
the claim has yet to be identified and convicted in a court of law. For our analysis, the OIG’s
Office of Investigations’ data scientist team identified claims with fraud indicators, and we then
analyzed the case file or subpoenaed data for supporting evidence, such as multiple claims filed
from one physical address.
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U.S. Department of Labor – Office of Inspector General
American workers nationwide waited a month or more for pandemic-related UI
benefits. 6
ETA and states made significant efforts; however, they did not protect
pandemic-related UI funds from historic levels of improper payments, including
fraud. We attribute this to four causes. Specifically, states did not perform
eligibility testing, ETA’s oversight was not timely enough, PUA initially allowed
claimants to self-certify their eligibility, and ETA suspended 1 of their primary
oversight tools for the first 3 months of the CARES Act. Furthermore, ETA’s
interpretation of its regulations hindered the OIG’s timely and complete access to
state UI claims data to assist in detecting and deterring large-scale fraud.
IN 6 MONTHS, 4 STATES PAID
42.4 PERCENT OF UI BENEFITS
IMPROPERLY, INCLUDING NEARLY
14 PERCENT PAID TO LIKELY FRAUDSTERS
Paying claimants accurately and preventing improper
payments, including fraud, continued to challenge states
throughout the effective period for the CARES Act and
CAA—March 28, 2020, through March 14, 2021. To assess
eligibility, we statistically sampled and tested 214 cases in
the 4 states where claimants received either PUA or regular
UI with an FPUC supplement between March 28, 2020, and
September 30, 2020. Additionally, we judgmentally selected
40 cases (10 from each of the 4 states) from
January 1, 2021, through March 14, 2021, to assess any
impact of legislative changes after CAA required proof of
wages for PUA rather than relying solely on self-certification.
From March 28, 2020 through September 30, 2020, we
found the 4 states paid 118 of 214 cases improperly—$1,435,132 of the total
$3,381,823 (42.4 percent) paid. During that time, the 4 states submitted data that
6
Based on data submitted by states in response to an IG subpoena: from March 28, 2020,
to September 30, 2020, 4 states submitted claims data for 9,546,807 claimants and
$71,663,117,052 in benefits for the PUA and FPUC programs. A stratified random sample of
214 was extracted from the universe and a total of 118 improper payments were identified. Based
on this sample, it is projected that approximately 5,264,127 improper payments are among the
total universe, with 95 percent confidence the true value falls between 4,895,638 and 5,632,616.
Furthermore, it is projected that approximately $30,411,417,895 were improperly paid, with
95 percent confidence that the true value falls between $28,282,618,642 and $32,540,217,148.
PANDEMIC-RELATED UI ELIGIBILITY AND TIMELINESS
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U.S. Department of Labor – Office of Inspector General
showed they paid a total of 9.5 million claimants $71.7 billion in UI benefits for
PUA and FPUC. By projecting our statistical sample across the 4 states, we
estimated that, in about 6 months after the CARES Act passed, the 4 states
improperly paid approximately 5.3 million claimants $30.4 billion, with $9.9 billion
attributed to 1.1 million likely fraudulent claims.
For comparison, in the 3 years leading up to the pandemic (April 1, 2017,
to March 31, 2020), ETA’s Benefit Accuracy Measurement (BAM) program 7
estimated the 4 states averaged an improper payment rate of 15.6 percent
annually, with 2.8 percent attributable to fraud. Nationwide, for the last 18 years,
ETA has estimated the UI improper payment rate between 9.17 percent and
13.03 percent (see Figures 2 and 3).
Figure 2: Comparison of Improper Payment Rates, Pre-Pandemic Annual
Averages and 4 States in First 6 Months of CARES Act
Source: ETA reports and OIG analysis of case files
7
According to ETA, BAM is a quality control statistical survey used to identify errors and support
corrective action in the state UI system. It usually focuses on the three major UI programs:
regular UI, Unemployment Compensation for Federal Employees, and Unemployment
Compensation for Ex-service members. BAM data is used to estimate the total improper
payments in the UI program, in each state and in the nation as a whole, based on a statistically
valid examination of a sample of paid and denied claims.
PANDEMIC-RELATED UI ELIGIBILITY AND TIMELINESS
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U.S. Department of Labor – Office of Inspector General
Figure 3: Comparison of Fraud Rates, Pre-Pandemic Annual Averages and
First 6 Months of CARES Act for the 4 States
Source: ETA reports and OIG case file analysis
Based on case files and data subpoenaed from states, we identified that
25 of 214 sampled claimants were likely fraudulent actors. 8 These likely
fraudsters received $465,723 of the total $3,381,823 paid, equating to a fraud
rate of 13.8 percent.
Furthermore, nine of the sampled claimants appeared to be victims of identity
fraud. In total, 951 claims filed in 28 different states were attached to likely
fraudsters or identity fraud cases. States prevented payments to 495 of these
UI claims; however, 456 claims received $7,092,604 in unemployment benefits
from 14 different states (see Exhibit 2).
ETA reminded states of their roles and responsibilities in preventing improper
payments, including those related to fraud:
• In August 2020, ETA issued UIPL No. 28-20, which reiterated
Section 303(a)(1) of the Social Security Act requirements that, as a
condition of a state receiving administrative grants for its UI program, state
law must provide for “methods of administration…As are found by the
8
Prior to the release of this audit report, the claimants associated with the fraudulent claims were
referred to the OIG’s Office of Investigations to assess and determine if the claims warrant
investigation. If the claims do not warrant investigation, they will be referred to the SWA, in
accordance with UIPL 04-17.
PANDEMIC-RELATED UI ELIGIBILITY AND TIMELINESS
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U.S. Department of Labor – Office of Inspector General
Secretary of Labor to be reasonably calculated to insure full payment of
unemployment compensation when due.” Also, UIPL No. 04-01 interprets
the “when due” requirement to also require states to ensure that payment
of benefits is not made when payment is not due. DOL has consistently
interpreted Section 303(a)(1) to require “that state law include provision for
such methods of administration as are, within reason, calculated (1) to
detect benefits paid through error by the agency through willful
misrepresentation or error by the claimant or others, and (2) to deter
claimants from obtaining benefits through willful misrepresentation.”
• In May 2020, ETA issued UIPL No. 23-20, which specified that the
CARES Act programs operate in tandem with the fundamental eligibility
requirements of the federal-state UI program. The UIPL further specified
that state UI laws must include provisions for administration methods to
detect and deter improper payments accomplished through SWAs’ Benefit
Payment Control (BPC) units or other designated staff responsible for
promoting and maintaining the integrity of the UI program through
prevention, detection, investigations, establishment, and recovery of
overpayments.
STATES PAID CLAIMANTS IMPROPERLY
For the period March 28, 2020, to September 30, 2020, we identified
114 9 of 214 claimants received improper payments for PUA and regular UI with a
FPUC supplement, not including fraud.
This includes:
• 47 claimants who were ineligible due to not being or not certifying that
they were able to or available for work;
• 23 claimants whose identity could not be verified by the state;
• 11 claimants who were ineligible due to voluntarily quitting employment,
being discharged for cause, or stating their employment ended due to the
pandemic despite their last date of employment occurring significantly
before the pandemic started;
• 7 claimants who were ineligible due to claiming benefits after returning to
work or failing to accurately report earnings;
• 1 claimant who refused suitable work; and
9
Forty-six percent (53 of the 114) of claimants with improper payment issues had multiple types
of improper payments. In instances where a violation would result in questioned cost as part of
multiple violations, the greater of the costs was used.
PANDEMIC-RELATED UI ELIGIBILITY AND TIMELINESS
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U.S. Department of Labor – Office of Inspector General
• 69 claimants who were ineligible due to violations of PUA-specific
requirements (details follow).
ETA reported states were particularly challenged while implementing the
PUA program because it was very different compared to the regular UI program,
served a unique population, and had new eligibility requirements. 10 Included in
our 214 sampled claimants were 98 PUA claimants. Of these, we found states
did not comply with PUA specific requirements when paying
69 11 of 98 PUA claimants (70 percent). Specifically, we found:
• 31 claimants who were paid more than the minimum weekly benefit
amount without supporting documentation,
• 28 claimants who did not recertify being eligible due to a
COVID-19-related reason, 12
• 19 claimants who were paid benefits under CAA and ARPA without
documentation substantiating employment or self-employment as
required,
• 4 claimants who received PUA despite eligibility for the regular UI
program, and
• 3 claimants who were paid without a valid COVID-19-related reason.
In addition to the 214 sampled claimants, to test the expanded PUA eligibility
requirements under the CAA, we judgmentally selected 10 claimants from each
state. We identified that 22 13 of 40 sampled PUA claimants received
$148,110 of $346,805 in federal UI (43 percent) benefits improperly. Specifically,
we found:
• 18 claimants who were paid benefits under CAA and ARPA without
documentation substantiating employment or self-employment,
• 7 claimants whose identity could not be verified by the state,
10
ETA provided this statement on May 28, 2021, in response to a CARES Act UI draft report,
specifically, COVID-19: States Struggled to Implement Cares Act Unemployment Insurance
Programs, Report No. 19-21-004-03-315 (May 28, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf.
11
Seventy percent (48 of the 69) of claimants with PUA-specific improper payment issues had
multiple types of improper payments. In instances where a violation would result in questioned
cost as part of multiple violations, the greater of the costs was used.
12
CARES Act Section 2102(a)(3)(A)(ii)(I) requires PUA claimants to self-certify that they are
otherwise able and available to work, except that the individual is unemployed, partially
unemployed, or unable and unavailable to work based upon certain COVID-19-related reasons.
13
Thirty-two percent (7 of 22) of claimants with PUA-specific improper payment issues had
multiple types of improper payments. In instances where cost were questioned as part of multiple
violations, the greater of the costs was used.
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U.S. Department of Labor – Office of Inspector General
• 2 claimants who were ineligible due to not being able to work or not being
available for work,
• 1 claimant who was paid more than the minimum weekly benefit amount
without supporting documentation, and
• 1 claimant who was ineligible due to voluntarily quitting employment or
being discharged for cause.
ETA officials objected to the use of the time period March 28, 2020,
to September 30, 2020, to test claimants’ eligibility. ETA officials stated this was
early in the pandemic when states were implementing the new programs and
states have since made significant improvements. We acknowledge the likely
accuracy of these statements; however, during this period, states spent
approximately 51 percent, $340.1 billion, of UI funds for the new key
pandemic-related programs. Therefore, increased scrutiny is valid.
Further, the OIG did not have timely and complete access to state UI claims data
due to ETA’s interpretation of the Code of Federal Regulations (C.F.R.) and
significant delay in issuing guidance to states that they were required to provide
access to their UI data to OIG for audits and investigations. On August 3, 2021,
ETA revised its position and facilitated the OIG’s access for the pandemic period,
but ETA’s policy revisions came more than a year after the OIG first notified ETA
of potential large-scale fraud and of the need for access to state UI claims data.
STATES DID NOT PREVENT LIKELY FRAUDULENT
PAYMENTS
In our February 22, 2021, CARES Act Alert Memorandum, 14 we reported ETA
needed to take immediate action to mitigate fraud in pandemic-related UI
programs. For the 3 years leading up to March 31, 2020, ETA estimated the
UI fraud rate for the 4 states was 2.8 percent; however, from the cases we
tested, we estimated the likely fraud rate in the 4 states during the period
March 28, 2020, to September 30, 2020, was 13.8 percent, a 393 percent
increase compared to the prior 3 years.
To determine the likely fraudulent claims, we collaborated with the OIG’s Office
of Investigations’ data scientist team, who reviewed each case for a fraud
indicator. We then reviewed those case files against IG-subpoenaed data for all
the SWAs to substantiate the fraud indicator.
14
Alert Memorandum: The Employment and Training Administration (ETA) Needs to Ensure
State Workforce Agencies (SWA) Implement Effective Unemployment Insurance Program Fraud
Controls for High Risk Areas, Report No. 19-21-002-03-315 (February 22, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-315.pdf
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U.S. Department of Labor – Office of Inspector General
For example, we identified a claimant who filed a claim from a 3-bedroom house
that was the shared location for 90 other claims. The same claimant also shared
a flagged 15 email address with 145 other claims. In total, this claimant was
connected to 235 other claims for unemployment benefits in 3 states—receiving
benefits on 87 of those claims, all filed in California, for a total amount of
$1,569,762. California was unable to verify the sampled claimant’s identity and
stopped payment on September 8, 2020, 164 days after the initial payment.
Overall, of the 214 claimants, we identified 25 who likely committed fraud to
receive UI benefits. These 25 claimants were connected to 603 claims filed in
24 different states but were only successful in 13 states. On average, we found
those 25 likely fraudsters succeeded in receiving UI benefits for claims filed at a
rate of 60.5 percent. We classified the claimants by the following fraud indicators:
• Flagged physical address—21 claimants filed with a flagged physical
address. For example, one claimant filed 48 different claims from one
address and received $406,566 unemployment benefits on 21 of those
claims. Claimants with a flagged physical address fraud indicator received
$4,570,604 in UI benefits;
• Multi-state claimants—14 claimants filed for benefits in multiple states.
Claimants with multi-state fraud indicators received $1,371,192 16 in
UI benefits;
• Flagged email address—10 claimants filed with a flagged email address.
For example, 1 claimant filed 30 different claims from a shared flagged
email address and received $589,800 on 25 of those claims. Claimants
with email fraud indicators received $3,726,267 in UI benefits;
• Flagged phone number—9 claimants filed with a flagged phone number.
For example, one such claimant filed in three different states using the
same phone number but with different addresses in a short period of time.
In total, the claimant received $120,290 on 8 of those claims. Claimants
with flagged phone number fraud indicators received $1,149,960; and
• Flagged Bank Account—3 claimants filed with a flagged bank account.
For example, one claimant with a flagged bank account filed in 3 different
states with a shared flagged email address for 15 other claims and shared
physical address for 48 different claims. In total, the claimant filed
65 different claims and received $322,453 on 21 of those claims.
Claimants with bank account fraud indicators received $675,917.
15
Flagged claimants are those that were indicated by the OIG’s Office of Investigations as
potentially fraudulent.
16
Claimants often had multiple fraud indicators; therefore, these include duplicate benefit
amounts for each fraud flag.
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U.S. Department of Labor – Office of Inspector General
HISTORIC LEVELS OF IMPROPER PAYMENTS,
INCLUDING FRAUD, HAD FOUR COMMON CAUSES
While states were able to initiate pandemic-related UI programs and ETA was
able to offer guidance and perform monitoring, improper payments including
fraud reached historic levels. We attribute the historic levels of improper
payments, including fraud, to four common causes. Specifically,
(1) states did not always perform required procedures necessary to ensure
claimants were eligible,
(2) ETA’s guidance and oversight was not timely enough to prevent improper
payments,
(3) the PUA program’s initial reliance solely on self-certification left it
vulnerable to improper payments, and
(4) ETA suspended the BAM program for the first 3 months of the CARES
Act.
Additionally, ETA’s interpretation of the C.F.R. and significant delay in issuing
guidance to states hindered the OIG’s timely and complete access to data to
assist in detecting and deterring large-scale fraud.
More information on each cause follows.
(1) STATES DID NOT ALWAYS PERFORM
REQUIRED PROCEDURES TO ENSURE
ELIGIBILITY
ETA officials reported 17 states faced the combined challenges of (1) managing
and processing an unprecedented increase in claims volume at an
unprecedented pace, (2) making the statutory changes to existing UI programs,
and (3) implementing the three new key pandemic-related UI programs.
We found the 4 states did not perform required procedures to determine
eligibility. These requirements were not specific to the pandemic-related UI
programs and would be performed as part of any regular UI program.
Specifically, states did not always perform required procedures such as verifying
claimants’ availability and ability to work, did not sufficiently verify the identity of
17
On April 6, 2021, ETA officials stated this in their technical response to the draft of COVID-19:
States Struggled to Implement Cares Act Unemployment Insurance Programs,
Report No. 19-21-004-03-315 (May 28, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf.
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claimants, and did not prevent paying claimants that had separation or return to
work issues.
In addition, states did not comply with all eligibility requirements when approving
PUA claimants. Our prior CARES Act UI report 18 detailed that states were able to
implement the PUA program, on average, in 38 days. However, we found states:
were not obtaining weekly eligibility re-certifications, paid claimants more than
the allowable minimum weekly benefit amount without supporting documentation,
or paid benefits under CAA and ARPA without documentation substantiating
employment or self-employment as required.
Moreover, states prioritized expediency over safeguards. For example, the
4 states suspended eligibility and payment controls. Federal guidance issued by
the Office of Management and Budget (OMB) on April 10, 2020, required
agencies to prioritize expediency, defined as the rapid issuance of awards to
meet crucial needs, while also reminding agencies to balance the need for
expediency with steps to mitigate fraud, waste, abuse, and improper payments. 19
While expediency was required, prioritizing it over essential payment functions—
such as suspending eligibility procedures—was not.
Finally, at the start of the pandemic, not all states were participating in the
National Association of State Workforce Agencies’ (NASWA) Integrity Data Hub
(IDH), which provides cross-matching functionality for SWAs to combat UI fraud.
In March 2020, 19 states had not executed an IDH participation agreement to
cross-match with the IDH datasets and 50 states were not participating in the
multi-state cross-match. Of the 4 states, only one state, Michigan, participated in
the multi-state cross-match and the new identity verification service. Despite
participation in the IDH, Michigan had higher than typical fraudulent payments
(see Tables 1 and 2).
ETA officials reported that, since the timeframe of our testing, the IDH has
experienced increased participation and created an identity verification service.
As of March 2022, all 53 states executed an IDH Participation Agreement,
35 states are receiving identity verification results, and 43 states were using the
multi-state cross-match.
(2) ETA’S GUIDANCE AND OVERSIGHT WAS NOT
TIMELY ENOUGH
18
COVID-19: States Struggled to Implement Cares Act Unemployment Insurance Programs,
Report No. 19-21-004-03-315
(May 28, 2021), https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf.
19
OMB Memorandum 20-21, Implementation Guidance for Supplemental Funding Provided in
Response to the Coronavirus Disease 2019 (April 10, 2020)
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After the CARES Act passed, ETA worked quickly to obtain signed state
agreements and ensure pandemic-related UI funds were available. ETA issued
48 UIPLs, created monitoring tools, issued a self-assessment tool, produced
training webinars, and reviewed states’ implementation of key pandemic-related
UI programs. ETA also created a website for state officials that listed guidance,
policies, and resources to help states respond to the pandemic, including fraud
alerts from the OIG and other law enforcement agencies.
Despite its efforts, ETA’s guidance and oversight was not timely enough to
prevent historic improper payments of UI benefits. We previously reported that
state officials cited ETA’s guidance about initial and continued eligibility was
untimely and unclear. 20 We found ETA’s monitoring reports demonstrated its
oversight addressed issues after billions had already been paid.
For example, in July 2020, ETA notified California that their PUA monetary
determination form did not have a procedure in place for re-determining the
claimant’s weekly benefit if the claimant did not provide proof of earnings or
provided insufficient proof. California responded that the problem would be
addressed by the end of August 2020. However, by the end of August, California
had paid approximately $25.4 billion in PUA benefits, including FPUC.
A similar issue occurred in Michigan. On June 17, 2020, ETA notified Michigan
that their PUA form did not include the required able and available questions.
However, by then, Michigan had paid approximately $4.6 billion in PUA benefits,
including FPUC.
ETA was able to provide states guidance on areas of improper payments as
early as May 2020. However, ETA and states must be prepared for disasters
before they occur. In a response to the draft of the OIG’s Semiannual Report to
Congress, Volume 87, 21 ETA highlighted that the time it took to initialize the
pandemic-related UI programs would typically take up to 4 years. Specifically,
ETA officials stated:
States’ ability to provide benefit payments within one to two months
for a new, temporary UI program is a very impressive achievement
given the extensive, complex requirements and activities that were
necessary for implementation. For comparison purposes, a swift
rollout of a new government benefit program—including the policy,
product and operations—would be 30-48 months. States
20
COVID-19: States Struggled to Implement Cares Act Unemployment Insurance Programs,
Report No. 19-21-004-03-315 (May 28, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf
21
Semiannual Report to Congress, Volume 87, October 1, 2021 – March 31, 2021,
https://www.oig.dol.gov/public/semiannuals/87.pdf
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concurrently handled the launch of three new programs, which
included the unprecedented PUA program that covered a
population previously excluded by the UI program and for which no
state UI processes were prepared to accommodate. This was all
accomplished while the states were navigating a ten-fold claims
volume increase, never before encountered in the program’s
85-year history.
We are concerned that, given the nature of emergency situations, states would
be unlikely to have a lengthy rollout period for emergency programs. ETA and
states must include risk planning that would identify measures to facilitate the
creation of new programs similar to the ones created in response to the
COVID-19 pandemic. This risk planning should include steps to ensure eligibility
procedures and BPC operations continue to function during emergency situations
to prevent improper payments before they occur.
Compounding the issue, states drew down about $281 billion from April 1, 2020,
to July 31, 2020, which was more than the states drew down from
August 1, 2020, through March 31, 2021 (see Figure 4).
Figure 4: State-Reported Drawdowns for PUA, FPUC, and PEUC
Source: OIG analysis of ETA’s reported information
(3) RELIANCE ON SELF-CERTIFICATION MADE
PUA HIGHLY SUSCEPTIBLE TO FRAUD
The CARES Act provided up to 39 weeks of PUA coverage to individuals who
were not traditionally eligible for UI benefits. During the program’s first 9 months,
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PUA claimants did not have to provide evidence of earnings and states relied
solely on claimant self-certifications, rendering the program extremely
susceptible to improper payments, including fraud. We reported our concerns
regarding this risk in an alert memorandum issued in May 2020, approximately
2 months after the enactment of the CARES Act. 22 We advised ETA that the OIG
interprets the CARES Act as requiring individuals to submit documentation to
substantiate employment. 23 However, ETA disagreed with our assessment based
on their interpretation of the CARES Act and underlying regulations.
In October 2020, we further reported 24 states had confirmed our concern about
this risk. Specifically, states reported inherent vulnerability in the PUA
self-certification process and cited the PUA self-certification requirement as a top
fraud vulnerability. Subsequent to our work identifying the fraud risks, Congress
took action to require supporting documentation to improve SWAs’ abilities to
ensure proper claimant eligibility and to mitigate fraud.
In this audit, we tested 98 PUA cases and found 22 (22 percent) were likely
fraudulent. In fact, $1 out of $5 initially paid to PUA claims in the 4 states went to
likely fraudsters. In contrast, we identified only 3 regular UI claims out of 116 as
likely fraudulent.
(4) BAM SUSPENDED FOR THE FIRST 3 MONTHS
AFTER THE CARES ACT PASSED
One of ETA’s primary oversight tools is the BAM program, a statistical survey
designed to determine the accuracy of paid and denied UI claims. It does this by
reconstructing the UI claims process for samples of weekly payments and denied
22
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),
https://www.oig.dol.gov/public/reports/oa/2020/19-20-002-03-315.pdf
23
The CARES Act (§ 2102(h)) states that federal regulations governing the Disaster
Unemployment Assistance (DUA) program apply to the PUA program unless there is a conflict
between the regulations and CARES Act § 2102, or an express provision in § 2102 applies. The
DUA regulations at 20 C.F.R. § 625.6(e) require states to immediately determine eligibility upon
an initial application based on the individual’s statement of employment/self-employment.
Furthermore, states are required to make an immediate determination of a weekly benefit amount
based on documentation provided, at the time of initial application, or if not available, on any state
agency records of employment or self-employment and related earnings; or on an individual’s
statement of employment or self-employment wages earned. DUA regulations at
20 C.F.R. § 625.6(e)(1) state that individuals receiving a benefit payment based solely on the
claimant’s statements are required to submit documentation to substantiate employment or
self-employment wages within 21 days of the initial filing.
24
COVID-19: States Cite Vulnerabilities in Detecting Fraud While Complying with the CARES Act
UI Program Self-Certification Requirement, Report No. 19-21-001-03-315 (October 21, 2020),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-001-03-315.pdf
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claims using data verified by trained investigators. BAM is used to identify the
root causes of improper payments; it is a diagnostic tool for the use of federal
and state staff in identifying errors and causes as well as for correcting and
tracking solutions to these problems.
However, ETA allowed states to temporarily suspend the BAM program from
April 1, 2020, through June 30, 2020, due to the significant and sudden increase
in workload brought on by COVID-19 pandemic. ETA and states cannot,
therefore, estimate the amount spent improperly for the first 3 months of the
pandemic-related UI programs.
Consistent with an OIG recommendation, ETA is beginning to estimate the
improper payment rate for pandemic-related UI programs. To do so, ETA
applied the regular UI improper payment rate to the FPUC and PEUC
programs. ETA stated it will develop a separate methodology and report the
PUA improper payment rate in 2022.
For July 1, 2020, through June 30, 2021, ETA estimated the national improper
payment rate as 18.71 percent. Based on our audit and investigative work, as
stated in our pandemic response oversight plan and in Congressional
testimony, 25 the improper payment rate for pandemic-related UI programs is
likely higher. Based on our testing, we estimated an improper payment and fraud
rate for each of the 4 states and compared it to ETA’s estimated BAM rate
(see Tables 1 and 2).
Table 1: OIG Estimated Improper Payment and Fraud Rates
(March 28, 2020–September 30, 2020)
Improper
Estimate Fraud
State Programs Payment
Source Rate %
Rate %
California 36.6 19.2
Georgia 38.4 7.8
OIG Audit PUA and FPUC
Kentucky 20.1 2.2
Michigan 67.9 3.9
Source: OIG analysis of case files
25
“Pandemic Response and Accountability: Reducing Fraud and Expanding Access to COVID-19
Relief through Effective Oversight,” March 17, 2022, Hearing of the U.S. Senate Committee on
Homeland Security and Governmental Affairs, Statement of Larry D. Turner, Inspector General,
Office of Inspector General, U.S. Department of Labor, Report No. 19-22-003-03-315,
https://www.oig.dol.gov/public/testimony/20220317.pdf
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Table 2: ETA BAM Estimated Improper Payment and Fraud Rates
(April 1, 2020–March 31, 2021)
Improper
Estimate Fraud
State Programs Payment
Source Rate %
Rate %
California 8.9 3.1
Georgia BAM FPUC and 12.9 5.9
Kentucky Program PEUC 6.0 4.1
Michigan 16.0 0.9
Source: ETA BAM reports
Michigan’s improper payment rate was largely driven by the state not initially
implementing able and available certifications for the PUA program. ETA
identified the issue, and Michigan corrected it by June 15, 2020. OMB Circular
A-123, Appendix C, Requirements for Effective Estimation and Remediation of
Improper Payments, states: “when an agency's review is unable to discern
whether a payment was proper as a result of insufficient or lack of
documentation, this payment must also be considered an improper payment.”
ETA’s BAM estimated improper payment rates for the 4 states was lower than
the OIG estimate likely due to two primary factors. First, the OIG audit estimate
focuses on the initial 6 months of the CARES Act programs, including the
3 months ETA suspended the BAM program. During this time, states had not
completely initialized their programs with all required elements and did not
perform all eligibility testing.
Second, ETA’s BAM program estimate does not include PUA claimants. ETA has
not yet reported improper payment data for the PUA program, which, as
previously noted, was highly susceptible to improper payments, including fraud.
In the 4 states, we found PUA claimants received 44 percent of benefits
improperly while regular UI claimants with an FPUC supplement received
31 percent of benefits improperly.
ETA’S INTERPRETATION OF REGULATIONS
LIMITED DOL OIG FROM ASSISTING IN DETECTING
AND DETERRING LARGE-SCALE FRAUD
The OIG conducts independent oversight of the UI program to, in part, detect and
deter large-scale fraud. The power and use of data and predictive analytics
enables the OIG to continuously monitor DOL programs and operations to detect
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and investigate fraud. Continuous monitoring serves as a deterrent to fraud,
allows the OIG to promptly discover areas of weakness, and assists DOL
management to timely correct problems. However, ETA’s interpretation of its
regulations and significant delay on issuing guidance to the states hindered the
OIG’s timely and complete access to state UI claims data to assist in detecting
and deterring UI fraud.
Early in the pandemic, OIG requested that DOL instruct the states of the
requirement to disclose UI information to the OIG for program audits and
investigations. The OIG expressed the urgent need for DOL to issue this
guidance to the states immediately due to increasing allegations of UI fraud. In
response, DOL disagreed with the OIG and relied on a legal interpretation of its
own UI disclosure regulations, asserting it could not require states to provide
UI data to the OIG for audits. As a result, the OIG was forced to take the
unprecedented step of issuing IG subpoenas to every SWA in order to obtain this
critical claims data. ETA’s inaction in providing early guidance to the states
caused delay and confusion among the states. ETA could have issued guidance
earlier; however, by the time it did so, fraudsters had already taken billions in
federal funding.
For example, from March 2020 to October 2020, the OIG identified 26 almost
$17 billion including approximately $915 million identified under more than one
category resulting in over $16 billion in potentially fraudulent unemployment
insurance (UI) pandemic benefits. The over $16 billion in potentially fraudulent
UI benefits were paid in four high-risk areas, to individuals with Social Security
numbers: 1) filed in multiple states, 2) of deceased persons, 3) of federal
inmates, and 4) used to file for UI claims with suspicious email accounts. We
shared our methodology and the underlying data with DOL and the states, and
we recommended they establish effective controls to mitigate fraud and other
improper payments to ineligible claimants. The data provided to DOL and the
states included more than 3 million suspicious claimants.
Notably, DOL has revisited its position. On August 3, 2021, ETA issued UIPL
No. 04-17, Change 1, which required states to provide UI data for investigations
and audits. However, this was a temporary measure that sunsetted on payments
26
Alert Memorandum: The Employment and Training Administration Needs to Ensure State
Workforce Agencies Implement Effective Unemployment Insurance Program Fraud Controls for
High Risk Areas, Report No. 19-21-002-03-315 (February 22, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-315.pdf; and
Alert Memorandum: The Employment and Training Administration Needs to Issue Guidance to
Ensure State Workforce Agencies Provide Requested Unemployment Insurance Data to the
Office of Inspector General, Report No. 19-21-005-03-315 (June 16, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-005-03-315.pdf
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made for the week ending September 6, 2021. 27 Further, ETA reported 28 that, by
July 31, 2021, states had drawn down $614.8 billion in pandemic-related UI
funds, or approximately 92.6 percent of the benefits paid, meaning that only after
the majority of benefits had been paid did ETA issue guidance consistent with the
OIG’s authority to access claim and wage information for oversight of the
UI programs.
AS A RESULT, 4 STATES PAID $30.4 BILLION
IMPROPERLY, INCLUDING $9.9 BILLION PAID TO
LIKELY PANDEMIC FRAUDSTERS
Highlighting the importance of proper planning and oversight, the 4 states paid
more improperly than the total amount typically paid for the entire UI program.
From March 28, 2020, to September 30, 2020, we projected the 4 states
improperly paid $30.4 billion. In the prior 3 years leading up to March 31, 2020,
50 states, the District of Columbia, and Puerto Rico paid an average of
$27.2 billion in UI benefits annually, with an estimated $3.1 billion in improper
payments. If the selected states had been able to maintain their prior year’s
improper payment rates, then states would have paid $19.3 billion less in
improper payments (see Figure 5).
Figure 5: Improper Payments Comparison
Source: OIG case file analysis and ETA reported data
27
ETA has required grant recipients to share state UI data with the OIG as a condition of
accepting the fraud prevention grants offered under the American Rescue Plan (ARP) Act, which
will continue to facilitate OIG’s access through December 31, 2023.
28
As reported on ETA’s website, “Families First Coronavirus Response Act and Coronavirus Aid,
Relief, and Economic Security (CARES) Act Funding to States through July 31, 2021,
https://oui.doleta.gov/unemploy/docs/cares_act_funding_state.html.
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We cannot project the results for the 4 states to the nation since the states were
judgmentally selected. However, evidence indicates these issues were prevalent
nationwide. Specifically, the 4 states were not alone in suspending eligibility and
payment controls. In our survey, 77 percent of responding SWAs indicated they
used BPC staff to process payments and 54 percent of responding states
indicated they temporarily suspended payment integrity functions to pay
claimants faster.
ETA’s nationwide BAM program identified overpayment causes among most
states common to those we identified in the 4 states, such as:
• Benefit Year Earnings (BYE) Issues where claimants filed for UI benefits
after returning to work or failed to accurately report earnings,
• Separation Issues where paid claimants were ineligible for UI benefits due
to quitting employment or being discharged for cause, and
• Able and Available (A/A) Issues where paid claimants were ineligible for
UI benefits due to not being able to or available for work (see Table 3).
Table 3: Improper Payments (IP) and Causes for the 4 States
(April 1, 2020–March 31, 2021)
IP BYE Separation A/A
State Rank Rank Rank Rank
Rate Issues Issues Issues
KY 6.0% 3rd 2.1% 7th 2.0% 13th 0.5% 21st
CA 8.9% 8th 1.5% 4th 1.4% 8th 2.2% 41st
GA 12.9% 18th 3.8% 21st 6.3% 32nd 0.7% 27th
MI 16.0% 29th 8.6% 45th 5.2% 27th 0.5% 22nd
Source: OIG analysis of ETA’s reported information
Curbing large-scale, organized UI fraud is not only a function of protecting public
funds, it also protects the safety of Americans. Criminal enterprises have
discovered that UI fraud is a low-risk, high-reward crime. They have invested
fraudulent UI proceeds to further other criminal activity, such as purchasing guns
and drugs. Individuals who we find are central to this conduct have been indicted
on charges including racketeering conspiracy. The allegations included in these
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indictments often relate to numerous violent, drug-trafficking, and economic
crimes committed in furtherance of a criminal enterprise.
MORE THAN 6 MILLION AMERICANS
WAITED AT LEAST A MONTH FOR
PANDEMIC-RELATED UI BENEFITS
In our May 28, 2021, CARES Act UI Audit Report, we highlighted that states
were challenged in ensuring claimants were paid promptly. Payment promptness
continued to be a challenge for states for the entire CARES Act and CAA
effective periods, and, in fact, worsened. To test timeliness, we assessed
9.4 million claimants in the 4 states who received either regular UI or PUA
benefits for weeks between March 28, 2020, and March 14, 2021. We used this
data in conjunction with publicly-available data reported by ETA to assess
payment timeliness for all 53 SWAs.
OMB issued federal guidance on April 10, 2020, requiring agencies to prioritize
expediency, which OMB defined as the rapid issuance of awards to meet crucial
needs. 29 In addition, ETA’s first payment promptness standard for the regular
UI program requires 87 percent of claimants to receive their first payment within
14 to 21 days. 30 Further, as previously noted, many states reassigned BPC staff
or suspended controls to process claims, contributing to improper payments.
However, we found 48 of 53 SWAs were untimely in paying regular UI claimants;
only 5 states were able to pay at least 87 percent of claimants within the required
time period.
Also, states sometimes took weeks to implement the new programs and
claimants could not file for benefits until the new programs were active. As the
pandemic-related UI programs were temporary, ETA did not apply its first
payment promptness standard to them. However, since this is the standard DOL
uses for the timeliness of regular UI payments, we used it for both our regular UI
and PUA timeliness analysis, along with other timeliness indicators, to provide
context as to the performance of states.
Most states paid at least half of regular UI claimants timely. However, based on
our analysis of ETA’s timeliness reports, the time required to implement the new
29
OMB Memorandum 20-21, Implementation Guidance for Supplemental Funding Provided in
Response to the Coronavirus Disease 2019 (April 10, 2020).
30
ETA requires states to pay 87 percent of claimants in 14 or 21 days after the first compensable
week depending if there is waiting week. Most states require that an individual, who is otherwise
eligible for UI benefits, must first serve a waiting period (generally 1 week) prior to receiving
benefits in a particular benefit year.
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UI programs and the volume of claims resulted in millions of claimants waiting a
month or more for their first payment, including at least 6.2 million Americans
eligible for regular UI nationwide.
STATES HAD VARYING SUCCESS PAYING
CLAIMANTS TIMELY, AND IT WORSENED
For the regular UI program, eligibility and weekly payment amounts vary by state.
However, the regular UI program generally provides 26 weeks of unemployment
compensation for individuals who are unemployed through no fault of their own
and were working for a certain length of time earning a certain amount of money
before becoming unemployed. We included regular UI claimants in our analysis
of pandemic-related UI benefits’ timeliness as they also received FPUC, the
weekly federal supplement.
From our analysis of ETA’s reporting, only 5 of the 53 SWAs were able to pay
regular UI claimants in compliance with ETA’s first payment promptness standard
(see Table 4, and see Exhibit 3 for details on timeliness for all 53 SWAs).
Table 4: Five States Met Timeliness Standard for Regular UI
(April 1, 2020–March 31, 2021)
Total Claimants Paid Percentage Paid
State Claimants Timely Timely
Minnesota 42,418 38,081 90%
Wyoming 32,283 28,591 89%
Louisiana 418,031 369,465 88%
North Dakota 71,912 63,550 88%
Rhode Island 139,518 122,900 88%
Source: OIG analysis of ETA-reported information
All but 5 of the 53 SWAs were able to pay more than 50 percent of regular UI
claimants within the ETA’s payment promptness standard (see Table 5).
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Table 5: Five States Did Not Pay Half of Claimants Timely for Regular UI
(April 1, 2020–March 31, 2021)
Total Claimants Paid Percentage Paid
State Claimants Timely Timely
Ohio 826,516 356,790 43%
Florida 1,772,328 684,051 39%
Puerto Rico 278,772 94,886 34%
Hawaii 192,294 58,102 30%
Virgin Islands 7,804 730 9%
Source: OIG analysis of ETA-reported information
For our analysis of PUA timeliness, we found only 1 of the 4 states was able to
pay PUA claimants consistent with ETA’s first payment promptness standard.
However, the other 3 of 4 states were able to pay the majority of claimants timely
(see Table 6).
Table 6: The 4 States Paid Most PUA Claimants Timely
(March 27, 2020–March 14, 2021)
Claimants Paid Percentage
Total Claimants
State Timely Paid Timely
California 2,485,306 2,187,324 88%
Michigan 659,249 555,379 84%
Georgia 333,268 276,637 83%
Kentucky 123,771 92,290 75%
Source: OIG analysis of information collected during the audit
While states had varying success with timeliness for the first payment during our
audit scope, the timeliness nationwide over time worsened after the first quarter
of implementation of pandemic-related UI programs. Ninety-four percent of
SWAs (50 of 53) paid claimants faster during April through June 2020 than
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during July through September 2020. In the first quarter after implementation,
67 percent of claimants were paid timely; however, only 51 percent were paid
timely in the next quarter. While the number rose during the following quarter,
2020 ended with fewer claimants receiving their first UI payment on time than in
April 2020. This trend continued through March 31, 2021 (see Figure 6).
Figure 6: States’ Regular UI Payment Timeliness Worsened Over Time,
(April 1, 2020–March 31, 2021)
Source: OIG analysis of ETA-reported information
STATES WERE CHALLENGED BY THE VOLUME OF
CLAIMS AND IMPLEMENTING NEW PROGRAMS
States were challenged by the volume of claims and the implementation of new
UI programs. The COVID-19 pandemic was historic in its impact on the
UI system. In 2019, DOL reported 11 million initial claims and 89 million
continued claims for regular UI. In contrast, from March 28, 2020,
to March 14, 2021, DOL reported more than 101 million workers filed an initial
claim for PUA or regular UI. In addition, during this same time period, DOL
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reported 1.1 billion PUA, regular UI, or PEUC continued claims and
approximately 647 million FPUC claims. 31
In addition to the sheer volume, states had to develop new systems to implement
the UI new programs, resulting in backlogs in processing claims for weeks and,
in some cases, months.
ETA officials stated the new pandemic-related UI programs were stood up in
record time for any new program and under a period when the UI program was
facing unprecedented demand and claims volume. This occurred as states were
forced to transition all staff to full remote work due to the pandemic and rapidly
hire and train staff.
AS A RESULT, MILLIONS OF AMERICANS FACED
LENGTHY DELAYS
Delays in UI payments have real, long-lasting effects on Americans. We
previously reported 32 those effects include the inability to pay bills, increased
credit card debt, high-interest rate borrowing, depleted savings, and food
scarcity.
In 2019, the Bureau of Labor and Statistics reported 6.3 million Americans were
among the “working poor,” defined as those who worked at least 27 weeks but
whose income fell below the official poverty level. Those same workers were also
most likely to be service industry employees, the most susceptible occupation
group to become unemployed due to the pandemic. Further, a 2020 National
Endowment for Financial Education study indicated 52 percent of Americans are
living paycheck to paycheck.
Despite these very real needs, we assess that, from April 1, 2020,
through March 31, 2021, at least 6.2 million of 29 million Americans nationwide
eligible for regular UI waited a month or more to receive their first UI payments.
Additionally, the 4 states took at least 30 days to pay
492,109 of 3,601,594 (14 percent) PUA claimants.
Further, our analysis does not account for discouraged applicants, applicants that
attempted to apply for UI but did not get a response or felt the process was too
31
DOL did not track initial claims for PEUC since claimants were not required to file a separate
application.
32
COVID-19: States Struggled to Implement Cares Act Unemployment Insurance Programs,
Report No. 19-21-004-03-315 (May 28, 2021),
https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf
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difficult to continue. ETA reports did not capture information on these individuals,
and our analysis could not logically identify how many potential applicants were
discouraged applicants. However, the Economic Policy Institute national survey 33
indicated the number could be in the millions.
OIG’S RECOMMENDATIONS
We recommend the Acting Assistant Secretary for Employment and Training:
1. Use data collected from monitoring and BAM reports to identify the areas
of highest improper payments including fraud and create a plan to prevent
similar issues in future temporary UI benefit programs.
2. Require states to have written policies and procedures, which apply
lessons learned during the COVID-19 pandemic, to continue eligibility
testing and BPC procedures during emergencies or other times of
increased claims volume. These policies and procedures should include
strategies to pay claimants timely.
3. Work with NASWA to update the IDH Participant Agreement to require
state to submit the results of their UI fraud investigations.
4. Work with NASWA to ensure the IDH cross-matches are effective at
preventing the types of fraud that were detected during the pandemic and
regularly update using the results of state fraud investigations.
5. Work with the OIG and states to recover the greatest practicable amount
of the $7,092,604 paid to claimants connected to likely fraudulent claims.
SUMMARY OF ETA’S RESPONSE
While ETA agreed or partially agreed to three of five recommendations, it
expressed three primary concerns regarding the report. First, ETA stated the
amount of case files reviewed was not statistically valid for reporting a national
improper payment rate. We cautioned readers of this report that the improper
payment rate presented is the result of our specific testing of the 4 states and is
33
Economic Policy Institute, “Unemployment Filing Failures: New Survey Confirms that Millions of
Jobless Were Unable to File an Unemployment Claim,” Working Economics blog post
(April 28, 2020), last accessed March 28, 2022, available at:
https://www.epi.org/blog/unemployment-filing-failures-new-survey-confirms-that-millions-of-
jobless-were-unable-to-file-an-unemployment-insurance-claim/
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not intended to be projected to the nation. Also, ETA expressed concern that the
OIG’s methodological approach would misrepresent the PUA improper payment
rate. The OIG’s purpose was to determine if UI benefits were paid only to eligible
individuals promptly rather than identifying an improper payment rate, which
remains an ETA responsibility. The OIG maintains its characterization of these
issues are accurately presented in our report.
Second, ETA stated the report repeats findings from prior OIG reports and alert
memoranda but does not acknowledge the steps taken to address these
concerns, specifically ETA’s efforts to combat fraud in the UI program since
February 2021. This is the first audit report to include case file testing, which
provides an in-depth analysis of issues at the state-level.
Third, ETA stated the report failed to appropriately consider the challenges facing
states and ETA during the pandemic. The OIG unequivocally acknowledges, in
this report and others, that staff at ETA and states struggled during the
COVID-19 pandemic as SWAs worked to ensure timely and accurate UI benefit
payments of more than $870 billion to workers unemployed through no fault of
their own. The OIG’s recommendations in this report are partly intended to help
alleviate such issues should the nation face another disaster.
We considered other technical comments provided by ETA and made clarifying
adjustments as appropriate. For example, ETA technically disagreed with our
Recommendation 3 and provided an alternative approach. The alternative
approach involves ETA revising its reports to capture the tools or interventions
used by a state to detect potential fraud issues (including the IDH) and include
the aggregated data for outcomes (e.g., determination, overpayment amounts) of
the issues detected by these tools or interventions. In our view, this alternative
approach satisfies the intent of our recommendation.
We appreciate the cooperation and courtesies ETA extended us during this audit.
OIG personnel who made major contributions to this report are listed in
Appendix C.
Carolyn R. Hantz
Assistant Inspector General for Audit
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EXHIBIT 1: FUNDING FOR THREE NEW KEY PANDEMIC-
RELATED UI PROGRAMS, AS OF 3/14/20
Pandemic-Related Funds Drawn Down Funds Drawn Down in the
UI Program Total 4 States
FPUC $331,742,201,334 $92,987,427,406
PUA 95,666,665,202 29,988,852,388
PEUC 44,755,749,596 10,953,664,456
TOTALS $472,164,616,132 $133,929,944,250
Source: ETA-reported data
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EXHIBIT 2: COSTS PAID TO LIKELY FRAUDSTERS OR
IDENTITY FRAUD CASES
In total, 951 claims filed in 28 different states were attached to likely fraudsters or
identity fraud cases. States prevented payments to 495 of these UI claims;
however, 456 claims received $7,092,604 in unemployment benefits from
14 different states.
Amount Paid to Likely Fraudsters
State
of Victims of Identity Fraud
Arizona $70,296
California 6,527,934
Florida 45,741
Georgia 11,287
Illinois 143,840
Kentucky 10,432
Louisiana 78,163
Massachusetts 3,552
Maryland 5,393
Michigan 112,183
New Jersey 1,846
Tennessee 3,500
Texas 58,920
Wisconsin 19,517
Total $7,092,604
Source: OIG analysis of case files
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EXHIBIT 3: TIMELINESS REPORTING BY STATE
REGULAR UI - TIMELINESS BY STATE
Did State Meet ETA's
Initial Claims Cases Paid Percentage
State Timeliness
Workload Timely Paid Timely
Standard?
Alabama 362,723 279,441 83% No
Alaska 75,906 45,587 60% No
Arizona 395,813 288,731 73% No
Arkansas 181,863 141,054 78% No
California 4,613,109 2,707,352 59% No
Colorado* 571,923 459,586 80% No
Connecticut* 420,905 327,384 78% No
Delaware* 65,718 50,025 76% No
District of
91,628 47,550 52%
Columbia No
Florida 1,772,328 684,051 39% No
Georgia* 1,007,163 742,173 74% No
Hawaii 192,294 58,102 30% No
Idaho 85,871 48,924 57% No
Illinois 1,269,763 959,082 76% No
Indiana 551,976 331,827 60% No
Iowa* 287,677 226,174 79% No
Kansas 374,968 278,224 74% No
Kentucky 351,969 250,315 71% No
Louisiana 418,031 369,465 88% Yes
Maine 122,466 68,067 56% No
Maryland* 330,205 189,859 57% No
Massachusetts 1,028,245 660,543 64% No
Michigan* 1,214,282 801,894 66% No
Minnesota 42,418 38,081 90% Yes
Mississippi 249,314 126,145 51% No
Missouri 355,333 281,503 79% No
Montana 14,040 10,867 77% No
Nebraska 87,100 57,355 66% No
Nevada* 483,554 294,747 61% No
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REGULAR UI - TIMELINESS BY STATE
Did State Meet ETA's
Initial Claims Cases Paid Percentage
State Timeliness
Workload Timely Paid Timely
Standard?
New Hampshire 124,591 75,916 61% No
New Jersey* 725,240 532,711 73% No
New Mexico 99,693 63,110 63% No
New York 2,235,140 1,214,593 54% No
North Carolina 721,891 436,889 61% No
North Dakota 71,912 63,550 88% Yes
Ohio 826,516 356,790 43% No
Oklahoma 299,210 233,494 78% No
Oregon 440,778 233,110 53% No
Pennsylvania 1,240,729 738,662 60% No
Puerto Rico 278,772 94,886 34% No
Rhode Island 139,518 122,900 88% Yes
South Carolina 361,665 267,186 74% No
South Dakota 39,445 29,868 76% No
Tennessee 523,490 367,647 70% No
Texas 1,983,897 1,433,989 72% No
Utah 137,010 106,080 77% No
Vermont* 78,600 57,594 73% No
Virgin Islands 7,804 730 9% No
Virginia 593,101 500,080 84% No
Washington 536,428 356,521 66% No
West Virginia 140,099 100,518 72% No
Wisconsin 370,170 240,244 65% No
Wyoming* 32,283 28,591 89% Yes
Source: OIG analysis of information publicly reported by ETA for April 1, 2020, to March 31, 2021
*State did not traditionally utilize a waiting week—used the 21-day standard
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APPENDIX A: SCOPE, METHODOLOGY, & CRITERIA
SCOPE
This audit covered DOL’s and states’ UI benefit programs including, but not
limited to, regular UI, PUA, PEUC, and FPUC. Our testing covered the period
March 28, 2020, to March 14, 2021.
METHODOLOGY
This performance audit was conducted remotely and included an in-depth
analysis of four states: California, Georgia, Michigan, and Kentucky (4 states).
Survey questionnaires were sent to an additional 49 SWAs. We completed this
audit in accordance with Generally Accepted Government Auditing Standards
(GAGAS).
To answer our audit objective, we reviewed the CARES Act, CAA, ETA
guidance, OMB guidance, the Social Security Act, and other criteria as required.
We performed internal control procedures and interviews with the Office of
Unemployment Insurance (OUI) national office and at the relevant OUI regional
offices. For the 4 states, we analyzed internal controls, reviewed policies and
procedures, conducted walkthroughs, and interviewed key agency personnel.
Additionally, we statistically selected claimants to test case files for eligibility
including fraud. In conjunction, with data selected for in-depth analysis we
analyzed public data to assess the timeliness of payments for all 53 SWAs.
Based on our initial testing, we created survey questionnaires and sent to
non-selected states. The audit team administered 49 survey questionnaires to
SWAs not included in in-depth analysis and received 44 responses.
We reviewed and analyzed public summary data available from the states on
UI claims and funding.
SAMPLING PLAN
Statistical Sampling Plan
To perform our audit, we judgmentally selected 4 states for more intense
analysis. To determine which states would be selected for more in-depth
analysis, we performed a risk assessment using several risk factors. Specifically,
we assessed program funding amounts, law enforcement intelligence,
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congressional interest, and media reports. Based on this analysis, we selected
California, Georgia, Kentucky, and Michigan.
This audit focused on UI benefit payments made between March 28, 2020,
and March 14, 2021. As of March 14, 2021, SWAs had drawn down
$472.2 billion in federal funds to pay UI benefits for PUA, PEUC, and FPUC
(see Exhibit 1). Of that $472.2 billion, almost a third (28 percent) was drawn
down by the 4 states selected.
Based on data submitted by states in response to an IG subpoena, we identified
the population of claimants who received an initial PUA program payment or
regular UI program payment with an FPUC supplemental payment from
March 28, 2020, to September 30, 2020. In total, from March 28, 2020,
to September 30, 2020, the 4 states submitted claims data for
9,546,807 claimants and $71,663,117,052 in benefits for the PUA and
FPUC programs.
We used the stratified random sampling method to select a sample from the
universe of PUA and regular UI claimants. The total sample size for the 4 states
was 214 with 98 PUA claimants and 118 regular UI claimants with a
FPUC supplement. Based on our sample size, the confidence level was
95 percent with a 7 percent precision rate.
Non-Statistical Sampling Plan
For each of the 4 states selected for in-depth analysis, we obtained a universe of
PUA claimants, from March 28, 2020, to March 14, 2021. From these universes,
we judgmentally selected 10 claimants from each to test under the revised
eligibility requirements of the CAA.
RELIABILITY ASSESSMENT
We assessed the reliability of computerized data provided by states. We
evaluated the appropriateness of the data provided by assessing the data,
controls over the data, and when possible, corroborated it to public data.
Specifically, the audit team performed analytical tests of the data and inquired
with data analysts for any data discrepancies. We assessed controls
implemented by states over pandemic-related UI programs and information
technology. The audit team also corroborated PUA claims against public reports.
Finally, as part of testing, the audit team traced the data provided by the states to
claimant case files.
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INTERNAL CONTROLS
A performance audit includes an understanding of internal controls considered
significant to the audit objective and testing compliance with significant laws,
regulations, and other requirements. In planning and performing our audit, we
considered whether internal controls significant to the audit objective were
properly designed and placed in operation. This included reviewing policies and
procedures. We confirmed our understanding of these controls and procedures
through interviews and the review and analysis of documentation. We evaluated
internal controls used for reasonable assurance. Our consideration of internal
controls for administering key pandemic-related UI programs would not
necessarily disclose all matters that might be reportable conditions.
CRITERIA
• Coronavirus Aid, Relief, and Economic Security Act, Public Law 116-136
(March 27, 2020)
• Consolidated Appropriations Act, 2021, specifically Division N, Title II,
Subtitle A, the Continued Assistance for Unemployed Workers Act of 2020
(December 27, 2020)
• American Rescue Plan Act of 2021 (Pub. L. 117-2), specifically Title IX,
Subtitle A, Crisis Support for Unemployed Workers (March 11, 2021)
• Section 303 of the Social Security Act (42 U.S.C. 503) (August 14, 1935)
• Office of Management and Budget Memorandum 20-21, Implementation
Guidance for Supplemental Funding Provided in Response to the
Coronavirus Disease 2019 (April 10, 2020)
• Unemployment Insurance Program Letter 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 (FPUC), Pandemic Unemployment Assistance (PUA), and
Pandemic Emergency Unemployment Compensation (PEUC) Programs
(May 11, 2020)
• Unemployment Insurance Program Letter 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)
• Unemployment Insurance Program Letter 04-01, Payment of
Compensation and Timeliness of Determinations during a Continued
Claims Series (October 27, 2000)
• Unemployment Insurance Program Letter 04-17, Disclosure of
Confidential Unemployment Compensation (UC) Information to the
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Department of Labor’s Office of Inspector General (OIG)
(December 16, 2016)
• Unemployment Insurance Program Letter 04-17, Change 1, Requirement
for States to Refer Allegations of Unemployment Compensation (UC)
Fraud, Waste, Abuse, Mismanagement, or Misconduct to the Department
of Labor’s (Department) Office of Inspector General’s (DOL-OIG) and to
Disclose Information Related to the Coronavirus Aid, Relief, and Economic
Security (CARES) Act to DOL-OIG for Purposes of UC Fraud Investigation
and Audits (August 3, 2021)
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APPENDIX B: AGENCY’S RESPONSE TO THE REPORT
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APPENDIX C: ACKNOWLEDGMENTS
Key Contributors to this report were:
Dennis Asante, Information Technology Specialist
Nick Cumby, Lead-Audit Manager
Dwight Gates, Audit Director
Jonathan Heinz, Attorney Advisor
Carla Orvis Hunt, Writer-Editor
Velma Ivey, Auditor
LaKeisha Jones, Statistician
Sharon Newby, Auditor
Le Nguyen, Attorney Advisor
Phu Nguyen, Supervisory Information Technology Specialist
Christy Powell, Auditor
Michael Roberts, Auditor
Mark Sanderson, Audit Manager
Travis Williams, Auditor
Chaze Williams-Bey, Auditor
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REPORT FRAUD, WASTE, OR ABUSE
TO THE DEPARTMENT OF LABOR
Online
http://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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