Pandemic Unemployment Assistance: Federal Program Supported Contingent Workers amid Historic Demand

Summary

U.S. Government Accountability Office report GAO-22-104438, Pandemic Unemployment Assistance: Federal Program Supported Contingent Workers amid Historic Demand, but DOL Should Examine Racial Disparities in Benefit Receipt, issued June 2022 as a report to congressional committees, with a letter dated June 7, 2022. The report examines how state implementation of the Pandemic Unemployment Assistance (PUA) program varied, how the pandemic affected contingent workers in selected states, and how PUA benefit receipt varied by demographic characteristics. It states that GAO found substantial racial and ethnic disparities in PUA benefit receipt in three of four selected states and that DOL has reported that $131.1 billion in PUA compensation was paid as of April 30, 2022. GAO makes two recommendations to DOL; DOL agreed with the first and partially agreed with the second.

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PANDEMIC
UNEMPLOYMENT
ASSISTANCE
Federal Program
Supported Contingent
Workers amid Historic
Demand, but DOL
Should Examine
Racial Disparities in
Benefit Receipt

Report to Congressional Committees
June 2022

GAO-22-104438

United States Government Accountability Office

 United States Government Accountability Office

Highlights of GAO-22-104438, a report to
congressional committees

June 2022
PANDEMIC UNEMPLOYMENT ASSISTANCE
Federal Program Supported Contingent Workers amid
Historic Demand, but DOL Should Examine Racial
Disparities in Benefit Receipt
What GAO Found
When the pandemic began, states faced historic demand and urgency to pay
unemployment insurance (UI) benefits, and their experiences implementing the
new Pandemic Unemployment Assistance (PUA) program varied. According to
data reported to the Department of Labor (DOL), most states started paying PUA
claims by the end of May 2020. States faced high demand for PUA early in the
pandemic and demand generally remained high through June 2021. As selected
states implemented PUA, they faced IT and staffing challenges, among others,
which contributed to payment delays. Selected states also had to balance paying
PUA claims quickly with minimizing improper payments.
The 48 contingent workers GAO spoke with in two states experienced sudden
unemployment, and those who reported receiving PUA generally said they relied
on the benefits to meet their basic financial needs. These workers also faced
challenges, such as long wait times for benefits, customer service difficulties, and
having to draw on savings or borrow money. With PUA’s expiration in September
2021, benefits are generally no longer available for self-employed and contingent
workers. DOL does not have plans to comprehensively assess if there are ways
for the UI system to support this substantial part of the workforce. Without doing
so, DOL may not realize its stated vision for a UI system that provides a lifeline to
workers in the modern economy and may limit information available to Congress
and other policymakers considering options to support these workers.
GAO found substantial racial and ethnic disparities in PUA benefit receipt in three
of four selected states (see table). For example, in two states, the percentage of
Black applicants who received PUA was about half that of White applicants.
Results from two national surveys show similar disparities in UI receipt. Various
factors could explain these disparities, such as how states reviewed claims or
whether fraudsters more frequently used certain demographics when filing. In its
August 2021 modernization plan, DOL emphasized the need to create a more
equitable UI system and subsequently made funds and technical assistance
available to states to examine and address equity issues. However, DOL has not
yet analyzed the extent and cause of racial disparities in PUA to determine
whether such inequities were isolated or caused by broader issues in the system.
Percentage of PUA Applicants Receiving Benefits in Selected States, by Race and Ethnicity
State
(analyzed through):
Louisiana
(Oct. 2020)
New York
(Dec. 2020)
North Dakota
(Apr. 2021)
Wisconsin
(Apr. 2021)
White, non-Hispanic/Latino
66.9%
84.4%
39.0%
43.3%
Black, non-Hispanic/Latino
72.3%
83.5%
19.5% *
21.9% *
Asian, non-Hispanic/Latino
91.7% *
91.4%
61.7% *
41.8%
American Indian/Alaskan Native,
non-Hispanic/Latino
73.7%
82.6%
39.6%
27.2% *
Hispanic/Latino
67.4%
85.5%
36.8%
24.8% *
Source: GAO analysis of aggregated Pandemic Unemployment Assistance (PUA) claimant data provided by states. | GAO-22-104438
Notes: GAO limited its analyses of Louisiana and New York PUA claims to those prior to influxes of
potentially fraudulent claims. GAO excluded the fifth state, Arizona, due to large amounts of potential
fraud in multiple months. Minority groups with substantial differences compared to White, non-
Hispanic/Latino (the largest group of applicants in each state) are shown with an asterisk.
Why GAO Did This Study
In response to widespread
unemployment caused by the COVID-
19 pandemic, the CARES Act created
the federal PUA program. The first
program of its kind and scale, PUA
temporarily expanded unemployment
benefits to workers generally ineligible
for UI, such as self-employed and
contingent workers—those without
traditional employment arrangements.
The CARES Act includes a provision
for GAO to monitor federal efforts to
respond to the COVID-19 pandemic.
This report examines (1) how state
implementation of PUA varied, (2) how
the pandemic affected contingent
workers in selected states, and to what
extent the UI system assisted them,
and (3) how PUA benefit receipt varied
by demographic characteristics.
GAO interviewed officials from DOL
and five states selected for variation in
claims volume and implementation
timing. GAO also analyzed PUA data
obtained from the selected states and
data DOL collects from all states. In
two states, GAO held discussions with
contingent workers who applied for
PUA. GAO also reviewed relevant
federal law and program guidance.
What GAO Recommends
GAO is making two recommendations
to DOL to advise the Congress and
other policymakers on future options to
support unemployed contingent
workers and examine the extent and
causes of inequities in the receipt of
PUA. DOL agreed with the first and
partially agreed with the second
recommendation, expressing concern
that an analysis of PUA would compete
with its other efforts to improve equity.
GAO continues to see value in this
analysis, as discussed in the report.
View GAO-22-104438. For more information,
contact Thomas Costa at (202) 512-4769 or
costat@gao.gov.

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GAO-22-104438  Pandemic Unemployment Assistance
Letter

1
Background
5
Amid Unprecedented Claims Volumes and Urgency to Pay
Benefits, States Faced Various Challenges in Building the PUA
Program and Processing Claims
15
Despite Some Challenges Accessing Benefits, Selected
Contingent Workers Relied on PUA, and DOL Has Not
Identified or Assessed Future Ways to Support Such Workers
24
Selected States’ Data Show Racial or Ethnic Disparities in Receipt
of PUA and DOL Has Not Yet Systematically Examined Such
Disparities in Its Efforts to Improve UI Equity
36
Conclusions
46
Recommendations for Executive Action
47
Agency Comments and Our Evaluation
48
Appendix I
Objectives, Scope, and Methodology
52

Appendix II
Counts of Pandemic Unemployment Assistance (PUA) Continued
Claims versus Individuals Claiming Benefits
62

Appendix III
Summary of Pandemic Unemployment Assistance (PUA) Data
Reported to the Department of Labor (DOL) by Selected States
through June 2021
65

Appendix IV
Comments from the Department of Labor
67

Appendix V
GAO Contact and Staff Acknowledgments
71

Tables
Table 1: Individuals Who Applied for and Received PUA Benefits
in Four Selected States
38
Table 2: Racial and Ethnic Disparities in the Receipt of PUA
Benefits in Selected States
39
Contents

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GAO-22-104438  Pandemic Unemployment Assistance
Table 3: Selected States’ PUA Applications, First Payments, and
Compensation through June 2021, According to Data
Reported by States to DOL
65

Figures
Figure 1: Timeline of Selected Laws and DOL Guidance
Regarding PUA
12
Figure 2: Number of States and Territories Making First PUA
Payments, by Week
16
Figure 3: Reported Time between Discussion Group Participants’
Employment Loss and Receipt of First PUA Payment
26
Figure 4: Discussion Group Participants’ Reported Total Weeks of
PUA Benefits Claimed
32
Figure 5: First Payments Made to PUA Claimants as a Percentage
of Initial Applications Submitted among 40 States, March
2020 through June 2021
37
Figure 6: Comparison of Average Number of PUA Continued
Claims Submitted Per Week and Number of Unique
Individuals Submitting PUA Claims during the Month
64

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GAO-22-104438  Pandemic Unemployment Assistance

Abbreviations

BLS

Bureau of Labor Statistics
Census
Census Bureau
COVID-19
Coronavirus Disease 2019
DOL

Department of Labor
DUA

Disaster Unemployment Assistance
ETA

Employment and Training Administration
FPUC
Federal Pandemic Unemployment Compensation
LWA

lost wages assistance
MEUC
Mixed Earner Unemployment Compensation
OIG

Office of Inspector General
PUA

Pandemic Unemployment Assistance
UI

unemployment insurance
UIPL
Unemployment Insurance Program Letter

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GAO-22-104438  Pandemic Unemployment Assistance
441 G St. N.W.
Washington, DC 20548
June 7, 2022
Congressional Committees
The COVID-19 pandemic caused significant economic disruptions
nationwide including widespread unemployment in part due to stay-at-
home orders, temporary business closures, and other reductions in
economic activity. In April 2020, the percentage of the U.S. population
that was employed reached the lowest level ever measured, according to
the Bureau of Labor Statistics (BLS).1 Enacted on March 27, 2020, the
CARES Act created temporary federal programs that expanded
unemployment insurance (UI) benefits in response to the crisis, including
Pandemic Unemployment Assistance (PUA).2 PUA expanded
unemployment benefit eligibility to traditionally ineligible workers—
including self-employed and certain contingent workers—who were
unemployed or unable to work due to COVID-19, were not otherwise
eligible for UI benefits, and met other eligibility criteria.3 We use the term
“contingent workers” to refer broadly to workers without traditional
employment arrangements, such as those with temporary or gig
employment, independent contractors, and self-employed workers.4
However, not all PUA claimants were contingent workers and not all
contingent workers were eligible for PUA.5

1The employment-to-population ratio, which measures the share of the civilian
noninstitutional population age 16 years and older that is currently employed, fell to 51.3
percent in April 2020. According to BLS, seasonally adjusted data are available back to
January 1948. Department of Labor, Bureau of Labor Statistics, The Employment
Situation—April 2020 (Washington, D.C.: May 8, 2020; reissued Sept. 23, 2020).
2Pub. L. No. 116-136, 134 Stat. 281.
3PUA also covered workers with limited recent work history and others who were not
covered by the UI program under some state laws.
4As self-employed workers are a sizable group among those who were potentially eligible
for PUA, we have included them in the term “contingent workers” for the purposes of
discussing the contingent worker experience during the pandemic and with the PUA
program. In other contexts, self-employed workers might be considered distinct from other
types of contingent workers given their greater control over the terms of their employment.
5For example, some PUA claimants had traditional employment but insufficient work
history to qualify for regular UI, and some contingent workers may have qualified for
regular UI if they also had a traditional part-time job.
Letter

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GAO-22-104438  Pandemic Unemployment Assistance
PUA was the first nationwide unemployment program that included
contingent workers and the Department of Labor (DOL) has reported that
a total of $131.1 billion in PUA compensation was paid to claimants as of
April 30, 2022.6 Given the urgency of the crisis and the scale of the PUA
program, it is critical to understand states’ experiences implementing PUA
and the role the program played in supporting contingent workers during
the pandemic. The CARES Act included a provision for us to conduct
monitoring and oversight of the use of funds made available to prepare
for, respond to, and recover from the COVID-19 pandemic.7 As part of
this monitoring effort, we issued a series of reports that include
information about UI programs, including PUA, and other issues. This
review, conducted under this CARES Act oversight provision, examines
the PUA program in greater depth, including: (1) how state
implementation of the PUA program varied in terms of timing and volume
of claims and benefits; (2) how the pandemic affected contingent workers
in selected states and to what extent the UI system assisted them; and
(3) how PUA benefit receipt varied by demographic characteristics in
selected states, and to what extent DOL has examined variation
systemwide. Determining the presence of improper payments and fraud
in PUA was outside the scope of this work, but is being addressed in
other reviews. We are also issuing two reports concurrently with this
review that cover other aspects of UI, including implementation and
administration of CARES Act UI programs and broad challenges facing
the UI program.8
To examine state implementation of the PUA program, we interviewed
officials from DOL and its Office of Inspector General (OIG), and analyzed

6Department of Labor, Employment and Training Administration, “Families First
Coronavirus Response Act and Coronavirus Aid, Relief, and Economic Security (CARES)
Act Funding to States,” accessed May 3, 2022:
https://oui.doleta.gov/unemploy/docs/cares_act_funding_state.html.
7Pub. L. No. 116-136, div. B, § 19010, 134 Stat. at 579-81. We have regularly issued
government-wide reports on the federal response to COVID-19. For the latest report, see
GAO, COVID-19: Current and Future Federal Preparedness Requires Fixes to Improve
Health Data and Address Improper Payments, GAO-22-105397 (Washington, D.C.: Apr.
27, 2022). Our government-wide reports are available on GAO’s website at
https://www.gao.gov/coronavirus.
8See GAO, Unemployment Insurance: Pandemic Programs Posed Challenges, and DOL
Could Better Address Customer Service and Emergency Planning, GAO-22-104251
(Washington, D.C.: June 7, 2022), and GAO, Unemployment Insurance: Transformation
Needed to Address Program Design, Infrastructure, and Integrity Risks, GAO-22-105162
(Washington, D.C., June 7, 2022).

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GAO-22-104438  Pandemic Unemployment Assistance
PUA data that states and territories reported to DOL, including the dates
they made their first PUA payments, and numbers of PUA applications
received, first payments made, weeks claimed, and amounts
compensated.9 To obtain nongeneralizable information about state
implementation experiences, we met with workforce agency officials in
five states: Arizona, Louisiana, New York, North Dakota, and Wisconsin.
We selected these states to include variety across several characteristics,
including the volume of PUA claims received and the timing of PUA
implementation. For additional context, we met with at least one worker
advocacy organization in each of our five selected states, as well as
representatives of national organizations.
To examine how the pandemic and PUA affected contingent workers in
selected states, we conducted nongeneralizable discussion groups with
contingent workers in two states—Arizona and New York—selected
because they both experienced a high volume of PUA claims but differed
in when they began making PUA payments.10 We held four discussion
groups in each state (8 total): three with contingent workers who reported
receiving PUA (37 workers total) and one with contingent workers who
reported applying for but not receiving PUA (11 workers total).
To examine how PUA benefit receipt varied by demographic
characteristics in selected states, we primarily analyzed aggregated PUA
claimant data obtained from four of our selected states on numbers of
individuals claiming and receiving benefits, including by race and
gender.11 We analyzed PUA benefit receipt rates overall, by gender, and

9States and territories may submit adjusted data for prior months at any time for up to 3
years, according to DOL officials; thus, the data are current as of the date they are
downloaded. Some states and territories have not submitted data for certain months or
data fields and we also observed data anomalies in some states’ and territories’ data. For
some analyses, such as those examining total claims or compensation paid, we included
all states’ and territories’ data. In these cases, missing data and anomalies introduce
imprecision, but we determined the data were sufficiently reliable to reflect nationwide
demand for benefits, dollars paid, and claims processing workloads. For other analyses,
such as those examining variation across states, we excluded states and territories with
substantial amounts of missing data or data anomalies. For more information, see
appendix I.
10We contracted with a vendor to recruit and screen discussion group participants and
transcribe the sessions.
11We obtained final data from selected states in June, July, and August 2021. We
determined the data obtained from Arizona were not sufficiently reliable for these analyses
due to substantial numbers of potentially fraudulent PUA claims that state officials said
were included in multiple months of the data. For more information, see appendix I.

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GAO-22-104438  Pandemic Unemployment Assistance
by racial and ethnic group. We established the following definitions to
characterize differences between groups:
•
Relatively similar: Differences of less than 3 percentage points
•
Relatively small differences: Differences of between 3 and 10
percentage points
•
Substantial differences: Differences of more than 10 percentage
points
Our analysis is generalizable to PUA claimants in the selected states we
analyzed, but not to other states. For additional context, we analyzed two
national surveys on UI benefit receipt during the pandemic: the Census
Bureau’s (Census) COVID-19 Household Pulse Survey (Household Pulse
Survey) and the Just Recovery Survey, which was administered by the
research firm SSRS.12
We conducted a reliability assessment for all of the data elements used in
our study and determined that the elements we used from DOL’s monthly
PUA data, the data we obtained from Louisiana, New York, North Dakota,
and Wisconsin for months prior to spikes in potentially fraudulent claims
identified by state officials, and the data from the Household Pulse Survey
and Just Recovery Survey were sufficiently reliable for the purposes of
this report.13 For all objectives, we also reviewed relevant federal laws
and regulations. See appendix I for more detailed information about our
scope and methodology, including our assessment of the reliability of
each data source.
We conducted this performance audit from July 2020 to June 2022 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

12The Household Pulse Survey was conducted in phases during 2020 and 2021 by
Census, in partnership with seven other federal agencies. The Just Recovery Survey was
administered in fall 2020 by the research firm SSRS, in coordination with the Cornell
Survey Research Institute. For more information about the surveys, see appendix I.
13Louisiana had a spike in individuals submitting PUA initial claims in November 2020 and
New York had a spike in January 2021. In both cases, state officials said these spikes
represented an influx of potentially fraudulent claims. Including large numbers of
potentially fraudulent claims could distort comparisons of benefit receipt rates between
groups.

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GAO-22-104438  Pandemic Unemployment Assistance
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Definitions of contingent work vary widely, focusing on the temporary
nature or precariousness of a work arrangement, the lack of a traditional
employer-employee relationship, or other concepts. Estimates of the size
of this workforce also vary based on the definition. The broad concept of
contingent workers we use includes a sizable population. For example, in
a 2015 report, we used data from the 2010 General Social Survey to
estimate that this population made up about a quarter of the employed
labor force.14 Specifically, agency temps, on-call workers, and contract
company workers, combined, represented an estimated 7.9 percent (+/-
1.7) of the employed labor force, independent contractors represented
12.9 percent (+/- 2.5), and self-employed workers represented 3.3
percent (+/- 1.2). We also found that certain contingent worker groups
were more likely than those with full-time, traditional work arrangements
to face employment instability and were less likely to receive employer-
provided retirement and health benefits.
Determinations about whether the contingent workforce has been growing
recently are inconclusive. Comparing the most recent data from the 2017
Current Population Survey supplement on contingent work with prior
surveys dating back to 1995, researchers found that more narrowly
defined estimates of the size of the contingent workforce that focus
primarily on temporary arrangements have declined slightly, and that
alternative work arrangements (like those included in the broad concept
of contingent work we use) have remained relatively steady.15 However,
other research that considers the 2017 survey data in combination with
other sources concludes that there has likely been a modest increase

14See GAO, Contingent Workforce: Size, Characteristics, Earnings, and Benefits,
GAO-15-168R (Washington, D.C.: Apr. 20, 2015). In the Current Population Survey’s
supplement on contingent work, most recently administered in 2005 and 2017, BLS uses
narrower definitions that focus primarily on temporary arrangements. We reported that
BLS’s definitions estimated the size of the contingent workforce in 2005 to be at most 4.1
percent of the labor force (+/- 1.0).
15See Katharine G. Abraham and Susan N. Houseman, “Contingent and Alternative
Employment: Lessons from the Contingent Worker Supplement, 1995–2017,” Prepared
for the Department of Labor, Chief Evaluation Office (Oct. 2020). See also GAO,
Contingent Workforce: BLS is Reassessing Measurement of Nontraditional Workers,
GAO-19-273R (Washington, D.C.: Jan. 29, 2019).
Background
Contingent Workers

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GAO-22-104438  Pandemic Unemployment Assistance
during the 2000s in the share of the U.S. workforce in alternative work
arrangements.16 A comprehensive study in 2020 by the National
Academies of Sciences, Engineering, and Medicine also noted that
evidence suggests that many people working solely in certain
nontraditional employment arrangements are not captured in household
surveys, and thus these surveys may underestimate the proportion of the
labor force in alternative arrangements, such as independent
contractors.17
The UI program is a federal-state partnership that provides temporary
financial assistance to eligible workers who become unemployed through
no fault of their own. According to DOL, UI is a social insurance program
designed to provide benefits to most individuals out of work such that a
significant proportion of their weekly needs can be met while they search
for work. The UI program also acts as an economic stabilizer during
economic downturns, according to DOL. States design and administer
their own UI programs within federal parameters and DOL oversees
states’ compliance with federal requirements.18 To be eligible for regular
UI benefits, applicants must generally demonstrate workforce attachment,
be able and available for work, and be actively seeking work.19 However,
according to DOL, state statutes establish the specific benefit structure,
eligibility provisions, benefit amounts, and other aspects of the program.
Regular UI benefits—those provided by state UI programs since before
the CARES Act was enacted—are funded primarily through state taxes
levied on employers. These benefits are intended to replace a portion of a
claimant’s previous earnings, according to DOL.
The proportion of unemployed workers filing for UI benefits (referred to as
the recipiency rate) declined overall from the 1950s to just before the
pandemic—the recipiency rate was 54.6 percent in 1958 and 28.1

16Lawrence F. Katz and Alan B. Krueger, “Understanding Trends in Alternative Work
Arrangements in the United States,” National Bureau of Economic Research, NBER
Working Paper 25425 (Jan. 2019).
17National Academies of Sciences, Engineering, and Medicine, Measuring Alternative
Work Arrangements for Research and Policy (Washington, D.C.: The National Academies
Press, 2020).
18Within DOL, the Employment and Training Administration’s (ETA) Office of
Unemployment Insurance is responsible for leadership and oversight of the UI system.
1942 U.S.C. § 503(a)(12).
Regular UI and Recipiency

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percent in 2019, according to DOL.20 The historical decline has multiple
causes, including state restrictions on eligibility, according to DOL.
Recently, researchers have examined other potential causes, including
the increase in workers experiencing long-term unemployment from 2000
to 2018, the percentage of workers who quit or were fired for cause, and
trends in certain types of contingent work; workers in each of these
groups do not typically qualify for UI.21
In response to the dual public health and economic crises brought on by
the COVID-19 pandemic, Congress established temporary, federally
funded programs that expanded eligibility and enhanced UI benefits.22
Among these programs, PUA generally authorized up to 79 weeks of
benefits (at the time of its expiration) to individuals not otherwise eligible
for UI benefits who were unable to work as a result of specified COVID-19
reasons.23 Individuals who were potentially eligible for PUA included self-
employed and contingent workers, individuals with insufficient work
history, workers who may not be covered by the regular UI program under
some state laws, and individuals who exhausted their regular UI and any
extended benefits. Individuals whose primary income was from self-

20This overall decline included a drop after the 2007-2009 recession, from 40.1 percent in
2009 to 25.7 percent in 2013. In 2020, the recipiency rate increased sharply due to the
large number of UI claims during the pandemic, according to DOL.
21See Ryan Nunn and David Ratner, Tax Policy Center, Urban Institute and Brookings
Institution, Rethinking Unemployment Insurance Taxes and Benefits (Oct. 28, 2019), and
William J. Congdon and Wayne Vroman, Urban Institute, Covering More Workers with
Unemployment Insurance: Lessons from the Great Recession (Washington, D.C.: Feb.
2021).
22These programs were created in March 2020 by the CARES Act and then amended in
December 2020 by the Consolidated Appropriations Act, 2021 and in March 2021 by the
American Rescue Plan Act of 2021.
23Pub. L. No. 117-2, § 9011(a), (b), 135 Stat. 4, 118; Pub. L. No. 116-260, div. N, tit. II, §
201(a), (b), 134 Stat. 1182, 1950-51 (2020); Pub. L. No. 116-136, § 2102, 134 Stat. 281,
313 (2020). The Consolidated Appropriations Act, 2021 increased the CARES Act’s
authorized maximum number of weeks of PUA benefits from 39 to 50 and generally
extended the expiration of the program from December 31, 2020, to March 14, 2021. The
American Rescue Plan Act of 2021 further increased the maximum number of weeks of
PUA benefits to 79 and generally extended the expiration of the program to September 6,
2021. The CARES Act also provided funding for up to an additional 7 weeks of PUA
benefits in certain states with high rates of unemployment. Department of Labor,
Employment and Training Administration, CARES Act of 2020 – Pandemic Unemployment
Assistance (PUA) Program Operating, Financial and Reporting Instructions,
Unemployment Insurance Program Letter (UIPL) No. 16-20 (Washington, D.C.: Apr. 5,
2020).
PUA and Enhanced
Unemployment Benefits
during the Pandemic

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employment or contingent work, but who had sufficient wage earnings to
qualify for regular UI were generally not eligible for PUA.
PUA was modeled after the Disaster Unemployment Assistance (DUA)
program, which provides benefits to workers who are not eligible for
regular UI if they lose their employment as a direct result of a
presidentially declared disaster, such as following a hurricane. Under the
CARES Act, the regulations for DUA generally applied to PUA.24 For
example, in its initial PUA guidance, DOL noted that to the extent
possible, states should administer the PUA program using the same initial
application, weekly certification, and other procedures used for the DUA
program.
Claims process. To claim PUA, individuals submitted an initial
application (also referred to as an initial claim) to their state to receive a
determination of basic eligibility for the program. The application process
included a self-certification that the applicant’s unemployment or inability
to work was due to one of the COVID-19 related reasons identified in the
CARES Act, such as an individual’s place of work was closed due to
COVID-19, or an individual was the primary caregiver for a child or
household member whose school or care facility was closed due to
COVID-19.25 After the initial application, claimants completed weekly
certifications of their continued eligibility for PUA, and to claim benefits for
the prior week of unemployment (also referred to as continued claims). As
we have previously reported, due to backlogs in states’ processing of
claims during the pandemic, individuals sometimes submitted continued
claims for multiple prior weeks of benefits at a time.26 In addition, although
not enacted until March 27, 2020, the CARES Act authorized PUA to be

24Pub. L. No. 116-136, § 2102(h), 134 Stat. 281, 317. The law states that the DUA
regulations would apply, except where section 2102 of the CARES Act conflicts with the
DUA regulations or section 2102 otherwise provides.
25For a complete list of reasons, see Department of Labor, PUA Program Operating,
Financial, and Reporting Instructions, UIPL 16-20 (Apr. 5, 2020) and Department of Labor,
Employment and Training Administration, Expanded Eligibility Provisions for the Pandemic
Unemployment Assistance (PUA) Program, Unemployment Insurance Program Letter
(UIPL) No. 16-20, Change 5 (Washington, D.C.: Feb. 25, 2021). The Consolidated
Appropriations Act, 2021 added new requirements to the PUA program, including that
individuals must generally provide documentation substantiating their prior employment or
self-employment. Pub. L. No. 116-260, div. N, tit. II, § 241(a), 134 Stat. 1182, 1959-60.
26GAO, COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal
Response, GAO-21-191 (Washington, D.C.: Nov. 30, 2020).

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payable retroactively for unemployment due to COVID-19 reasons for
weeks starting on or after January 27, 2020.27
Because each week claimed by an individual is counted as a separate
continued claim, the number of continued claims reported by states has
not approximated the number of individuals claiming benefits during the
pandemic.28 As we reported in November 2020, multi-week claims for
PUA were especially prevalent because individuals accumulated weeks
of unemployment as states implemented the new program. In that report,
we approximated the extent to which PUA continued claims exceeded the
number of claimants across a group of selected states. Using data we
obtained for this report, we have now refined this analysis for three
selected states (see app. II). In November 2020, we also made two
recommendations related to identifying UI claimant numbers, including
regular UI and PUA programs. DOL implemented one of these
recommendations and has begun efforts related to the second.29
Compensation amounts. Eligible PUA claimants were entitled to a
minimum weekly compensation amount of no less than the minimum

27Pub. L. No. 116-136, § 2102(c), 134 Stat. 281, 314-15. The Consolidated Appropriations
Act, 2021, limited the backdating for claims that were filed after December 27, 2020 to
weeks starting on or after December 1, 2020. Pub. L. No. 116-260, div. N, tit. II, § 201(f),
134 Stat. 1182, 1952.
28Prior to the pandemic, according to DOL officials, the number of continued claims
approximated the number of people claiming benefits because each week individuals
typically filed a claim for just the previous one week of continued unemployment.
29See GAO-21-191. Specifically, we recommended that DOL (1) revise its weekly news
releases to clarify that the numbers it reports for weeks of unemployment claimed do not
accurately estimate the number of unique individuals claiming benefits and (2) pursue
options to report the actual number of distinct individuals claiming benefits from January
2020 onward. DOL implemented our first recommendation and we consider it closed. DOL
partially agreed with our second recommendation, taking issue with implementing a
retroactive change in state reporting. DOL has stated that it is developing a new state
report that would capture data related to distinct individuals claiming regular UI benefits.
We maintain that DOL should pursue options to report the actual number of distinct
individuals claiming UI benefits, retroactive to January 2020. An accurate accounting of
the size of the population supported by the UI system during the pandemic may be critical
to helping DOL and policymakers identify lessons learned.

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GAO-22-104438  Pandemic Unemployment Assistance
weekly DUA benefit in the state where they claimed benefits.30 To
demonstrate eligibility for a weekly benefit amount higher than the
minimum compensation, claimants were to submit documentation of prior
earnings. In program guidance, DOL clarified that claimants could submit
documentation at any time during the program.31 As we have previously
reported, DOL officials told us that to facilitate implementation of the new
program, most states decided to initially pay PUA claimants the minimum
allowable benefit, and then recalculate their benefits at a later point based
on claimants’ documentation of their prior earnings.32 DOL officials said
they advised states to rely on self-certification when initially setting a
benefit amount, rather than defaulting to the minimum, and also noted
that some states previously used this approach in the DUA program to
pay benefits more expediently.
At times during the pandemic, PUA recipients were also eligible to receive
additional weekly benefits from the federally funded Federal Pandemic
Unemployment Compensation (FPUC) program, another of the CARES
Act UI programs, and the presidentially directed lost wages assistance

30According to DOL, states must use the amounts set in UIPL 3-20 as the minimum PUA
weekly benefit for all claims. See Department of Labor, Employment and Training
Administration, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 –
Pandemic Unemployment Assistance (PUA) Program Reporting Instructions and
Questions and Answers, Unemployment Insurance Program Letter (UIPL) No. 16-20,
Change 1 (Washington, D.C.: Apr. 27, 2020), and Department of Labor, Employment and
Training Administration, Minimum Disaster Unemployment Assistance (DUA) Weekly
Benefit Amount: January 1 - March 31, 2020, Unemployment Insurance Program Letter
(UIPL) No. 3-20 (Washington, D.C.: Dec. 12, 2019).
31DOL guidance also noted that when individuals submit sufficient documentation of
wages, states must recalculate their weekly benefits and pay the full PUA benefit amount
with the greatest promptness that is administratively feasible. Department of Labor, PUA
Program Reporting Instructions and Questions and Answers, UIPL 16-20, Change 1 (Apr.
27, 2020); see also 20 C.F.R. § 625.9(e). Under the CARES Act, the regulations for DUA
generally apply to PUA. Pub. L. No. 116-136, § 2102(h), 134 Stat. 281, 317.
32For more information, see GAO, COVID-19: Critical Vaccine Distribution, Supply Chain,
Program Integrity, and Other Challenges Require Focused Federal Attention, GAO-21-265
(Washington, D.C.: Jan. 28, 2021).

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GAO-22-104438  Pandemic Unemployment Assistance
(LWA) program.33 Specifically, for states with benefit weeks ending on
Saturdays:34
•
an additional $600 per week in FPUC from March 29 through July 25,
2020;
•
an additional $300 or $400 per week in LWA from July 26 through
September 5, 2020; and
•
an additional $300 per week in FPUC from December 27, 2020
through September 4, 2021.
DOL guidance and program revisions. DOL issued initial guidance on
the PUA program on April 5, 2020, and subsequently issued additional
guidance clarifying aspects of program implementation, and relaying
program changes, such as increased program integrity requirements and
expanded eligibility (see fig. 1). For example, guidance issued on April 27
and July 21, 2020, respectively, clarified that self-certification was not
sufficient to determine a claimant was ineligible for regular UI, and that
proof of net income (as opposed to gross) was required for self-employed
individuals to qualify for a higher benefit than the weekly minimum.35

33The CARES Act generally authorized, through FPUC, a $600 weekly benefit through
July 2020 for individuals who were eligible for weekly benefits under the regular UI and
CARES Act UI programs. Later, the Consolidated Appropriations Act, 2021 authorized an
additional $300 benefit for these workers for weeks of unemployment beginning after
December 26, 2020 and through March 14, 2021, and the American Rescue Plan Act of
2021 extended that benefit through September 6, 2021. Pub. L. No. 117-2, § 9013, 135
Stat. 4, 119; Pub. L. No. 116-260, div. N, tit. II, § 203, 134 Stat. 1182, 1953; Pub. L. No.
116-136, § 2104, 134 Stat. 281, 318. On August 8, 2020, the President signed a
memorandum directing the Federal Emergency Management Agency to provide grants to
states and territories to provide lost wages assistance to eligible claimants in addition to
their UI benefits—a $300 or $400 benefit per week, which included a $300 federal
contribution. The White House, Memorandum on Authorizing the Other Needs Assistance
Program for Major Disaster Declarations Related to Coronavirus Disease 2019 (Aug. 8,
2020). The funding ultimately provided benefits for 6 weeks, beginning with claims filed for
the week ending August 1, 2020, and continuing through the week ending September 5.
34According to DOL, a week of unemployment is generally considered to be Sunday
through Saturday, and benefit weeks in most states end on Saturday.
35Department of Labor, PUA Program Reporting Instructions and Questions and Answers,
UIPL 16-20, Change 1 (Apr. 27, 2020); and Department of Labor, Employment and
Training Administration, Coronavirus Aid, Relief, and Economic Security (CARES) Act of
2020 – Pandemic Unemployment Assistance (PUA) Additional Questions and Answers,
Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 2 (Washington, D.C.:
July 21, 2020).

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GAO-22-104438  Pandemic Unemployment Assistance
Figure 1: Timeline of Selected Laws and DOL Guidance Regarding PUA

PUA expiration. The PUA and FPUC programs expired on September 6,
2021, though some states ended participation earlier. As we have
previously reported, according to DOL, 20 states terminated participation
in the PUA program between mid-June and late July 2021.36 States
participated in PUA under agreements with the Secretary of Labor, and
according to DOL were permitted to terminate their participation, on
providing 30 days’ prior written notice to DOL. As we have previously

36The 20 states that terminated PUA early are Alabama, Arkansas, Georgia, Idaho, Iowa,
Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota,
Oklahoma, South Carolina, South Dakota, Tennessee, Texas, Utah, West Virginia, and
Wyoming. In addition, according to DOL, Indiana and Maryland announced their intent to
terminate participation in the PUA program early, but because of litigation at the state
level, did not end their participation before the program expired. See GAO, COVID-19:
Additional Actions Needed to Improve Accountability and Program Effectiveness of
Federal Response, GAO-22-105051 (Washington, D.C.: Oct. 27, 2021).

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GAO-22-104438  Pandemic Unemployment Assistance
reported, demand for PUA benefits across these states remained
relatively high prior to their early termination of the program.37
During the pandemic, regular UI initial claims rose to historic levels in
March 2020. Initial claims peaked at about 6.2 million submitted
nationwide during the week ending April 4, 2020, more than 30 times the
number submitted during the corresponding week in 2019.38 In addition,
the number of continued claims submitted each week for regular UI
(including any extended benefits) and Pandemic Emergency
Unemployment Compensation, which generally authorized additional
weeks of benefits for those who exhausted regular UI, remained at almost
12 million into March 2021.39
DOL, DOL’s OIG, and states have expressed concerns about the
potential for overpayments and fraud in UI programs during the
pandemic, given the urgency to pay benefits, historic numbers of claims,
and increased weekly benefit amounts from FPUC. As of March 28, 2022,
states and territories had identified $35.1 billion in overpayments made in
UI programs, including $13.3 billion in PUA overpayments, from April
2020 through December 2021.40 These reported overpayments may have
been caused by unintentional error, and were not necessarily a result of
fraud, though some were.41 As part of our regular monitoring of CARES
Act funds, we have previously recommended that DOL take steps to
better track PUA overpayments. Specifically, DOL has partially addressed

37For more information, including states’ reasons for terminating programs early, how we
measured demand for PUA, and states’ responsibilities for paying PUA benefits for any
weeks of unemployment that occurred prior to program termination (even if claimed
afterward), see GAO-22-105051.
38For more information, see GAO, COVID-19: Continued Attention Needed to Enhance
Federal Preparedness, Response, Service Delivery, and Program Integrity, GAO-21-551
(Washington, D.C.: July 19, 2021). Historically, prior to the pandemic, the highest number
of regular UI initial claims submitted during any given week was about 1 million.
39For more information, see GAO-22-105051. Historically, prior to the pandemic, the
highest number of regular UI continued claims submitted during any given week was
about 6.5 million.
40We accessed the overpayments data on March 28, 2022; these data are subject to
change as states and territories report data and revise previously reported data. For more
information, see GAO-22-105397.
41For more information, see GAO-22-105397. Fraud involves obtaining something of value
through willful misrepresentation. According to DOL, in the case of these payments made
by states, whether an act is fraudulent is defined by states and must be determined
through the appropriate adjudication process.
Historic Demand for
Regular UI
Increased Risk of
Improper Payments

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GAO-22-104438  Pandemic Unemployment Assistance
previous recommendations to collect data from states on the amount of
PUA overpayments recovered and waived.42
Early in the pandemic, DOL’s OIG flagged PUA’s reliance on self-
certification to determine program eligibility as a factor that could
potentially increase improper payments and fraud.43 DOL agreed with the
OIG’s concerns, but noted that self-certification was an intended aspect of
the PUA program set by the CARES Act. Subsequently, the Consolidated
Appropriations Act, 2021 added new requirements for the PUA program,
including that PUA claimants provide documentation substantiating
employment or self-employment, and that states have procedures to
verify or validate PUA claimant identities.44
We have made several recommendations related to managing fraud risks
in the UI system overall.45 In addition, since the pandemic began, DOL’s
OIG has opened thousands of complaints and investigations involving
alleged UI fraud. DOL’s OIG has also issued reports on CARES Act UI
program integrity, including PUA, and has multiple audit projects still
underway.46

42See GAO-22-105291.
43Department of Labor, Office of Inspector General, Alert Memorandum: The Pandemic
Unemployment Assistance Program Needs Proactive Measures to Detect and Prevent
Improper Payments and Fraud, 19-20-002-03-315 (Washington, D.C.: May 26, 2020).
44Pub. L. No. 116-260, div. N, tit. II, §§ 241(a), 242(a), 134 Stat. 1182, 1959-60.
45For more information, see the UI fraud risk management enclosure of GAO-22-105051.
46For example, see Department of Labor, Office of Inspector General, COVID-19: More
Can Be Done to Mitigate Risk to Unemployment Compensation Under the CARES Act,
19-20-008-03-315 (Washington, D.C.: Aug. 7, 2020). For more information on DOL OIG’s
ongoing work on unemployment insurance, see DOL OIG’s website on Oversight of the
Unemployment Insurance Program, https://www.oig.dol.gov/doloiguioversightwork.htm.

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GAO-22-104438  Pandemic Unemployment Assistance

Most states and territories began paying PUA benefits between mid-April
and the end of May 2020, though some took longer to begin paying
substantial numbers of claimants.47 Specifically, according to information
that DOL collected from states, 33 states and territories had begun paying
PUA benefits by May 2, 2020, about 5 weeks after the CARES Act was
enacted on March 27, 2020, 18 began paying PUA later in May 2020, and
two took longer (see fig. 2).

47We did not independently verify the accuracy of the PUA first payment dates that DOL
collected from states and territories. Throughout the report, we often refer to states and
territories, which includes the 50 states, the District of Columbia, Puerto Rico, and the
U.S. Virgin Islands, all of which administer the UI program. PUA was also available in
Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, the
Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of
Palau.
Amid Unprecedented
Claims Volumes and
Urgency to Pay
Benefits, States
Faced Various
Challenges in
Building the PUA
Program and
Processing Claims
Nationwide, Most States
Started Paying PUA
Claims by the End of May
2020, and PUA Demand
Generally Remained High

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GAO-22-104438  Pandemic Unemployment Assistance
Figure 2: Number of States and Territories Making First PUA Payments, by Week

Notes: We did not independently verify the accuracy of the PUA first payment dates that DOL
collected from states and territories. PUA was also available in Guam, American Samoa, the
Commonwealth of the Northern Mariana Islands, the Federated States of Micronesia, the Republic of
the Marshall Islands, and the Republic of Palau, though these entities are not included in the figure
because they are not traditionally covered by the UI system.

Although almost all states and territories reported making their first PUA
payments by the end of May, some did not start paying a substantial
number of claimants right away. For example, New York reported making
its first PUA payments on April 13, 2020. However, according to data
reported to DOL, New York paid about 7,000 PUA claimants their first
benefits in April 2020 before ramping up implementation and paying
about 568,000 PUA claimants their first benefits in May 2020.48 Similarly,
Wisconsin reported making its first PUA payments on May 21, 2020, but
paid less than 1,000 PUA claimants their first benefits by the end of May.
Wisconsin reported paying about 6,000 PUA claimants their first benefits
in June, followed by about 17,000 PUA claimants in July 2020.

48States and territories report to DOL the number of PUA first payments made by month.
According to DOL, a first payment is the first week in which assistance is paid to an
individual, and is reported in the month the payment is made. Each PUA recipient
generally receives only one first payment. We obtained first payment data on January 28,
2022.

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GAO-22-104438  Pandemic Unemployment Assistance
Variation in the timing of states initiating and ramping up PUA payments
may reflect both differences in how long states took to implement the
program and, to some extent, the variation in the timing of economic
shutdowns due to COVID-19 by state. For example, according to data
from the Centers for Disease Control and Prevention published in
September 2020, New York, New Jersey, and Illinois, among others,
issued statewide stay-at-home orders in late March 2020, whereas other
states, such as Arkansas and North Dakota, did not issue any such
orders from March through May 2020.
States faced high demand for PUA in the spring of 2020 as they
implemented the new program and generally demand remained high
throughout the program’s existence. Through May 2020, about 2 months
after the CARES Act was enacted, states and territories reported
receiving 8.0 million initial applications for PUA benefits, in addition to
millions of initial applications for regular UI.49 Although not all initial
applications are approved and result in benefit payments, this volume
indicates the magnitude of demand for PUA as well as the workload
facing states as they implemented the new program. Continued claims for
weekly benefits—claims filed by individuals who remain unemployed—
also increased significantly early and then remained relatively high
throughout the program’s existence. For example, states and territories
reported receiving claims for 70.2 million weeks of PUA benefits in July
2020 alone, though some of these claims were likely for unemployment
that occurred during prior months due to processing backlogs.50 Although
the total number of PUA weeks claimed nationwide declined somewhat
over time as states cleared claims backlogs and as some claimants
returned to work, the monthly total of weeks claimed remained above 25
million through June 2021, more than a year after the CARES Act was
enacted.51
In addition, the number of individuals submitting claims—which is distinct
from the number of weeks claimed—remained high each month from July

49We obtained PUA initial claims data on January 28, 2022. As we previously reported,
states and territories reported a spike in regular UI initial claims in late March and early
April 2020. See GAO-21-551. From March 15, 2020 through May 30, 2020, states and
territories reported receiving 38.4 million regular UI initial claims nationwide.
50We obtained PUA weeks claimed data on January 28, 2022.
51As we have previously reported, due to backlogs in states’ processing of claims during
the pandemic, individuals sometimes submitted continued claims for multiple prior weeks
of benefits at a time. See GAO-21-191.

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GAO-22-104438  Pandemic Unemployment Assistance
2020 through the end of 2020 in three of our five selected states.52 For
example, New York reported that about 1.1 million individuals submitted
PUA continued claims in July 2020, and 1.1 million individuals submitted
continued claims in December 2020. Similarly, Wisconsin reported that
about 28,000 individuals submitted PUA continued claims in July 2020,
and 24,000 individuals submitted continued claims in December 2020.53
From the beginning of the pandemic, states faced public urgency to
pay PUA benefits. As many states issued stay-at-home orders and
temporarily closed businesses to curb the spread of COVID-19, millions
of workers lost jobs and needed unemployment benefits, such as PUA, to
pay for living expenses. Officials in three selected states told us that
public perception was that when the CARES Act was enacted, states
would pay PUA benefits immediately. However, it took time for DOL to
issue guidance (see fig. 1) and for states to implement the PUA program
in line with that guidance.54 Officials from these three states told us that
they struggled to manage the public’s expectations of paying PUA
claimants quickly. This mismatch in expectations may have exacerbated
challenges faced by states as they rolled out the PUA program. For
example, North Dakota officials said that at the beginning of the pandemic
the volume of calls their agency received surged and included repeated
calls from some claimants who expected to receive their PUA benefits
right away. Louisiana officials told us that Congress and DOL should have
signaled to the public that implementing these programs would take some
time.
Underscoring the urgency to implement the new PUA program, New York
officials told us that individuals who experienced delays in receiving
benefits faced “pain and misery.” They said that despite their agency’s
efforts, some claimants went weeks or months without having their claims
processed and paid, and thus not receiving the income they needed to
feed their families or pay their bills. New York officials said that some

52In certain circumstances, an individual can submit multiple claims at a time. We
excluded Arizona and Louisiana from this analysis because each state experienced spikes
in potentially fraudulent claims before the end of 2020 and thus the data are not reliable
for the purposes of this analysis. For more information about the difference between
weeks claimed and individuals submitting claims and for graphs of PUA claims and
claimant numbers for the three selected states, see appendix II.
53In both New York and Wisconsin, individuals submitting PUA claims in each month were
not necessarily the same people.
54As previously noted, DOL issued initial PUA program guidance on April 5, 2020 and
then issued its first clarification guidance on April 27, 2020.
Selected States Built the
PUA Program amid
Urgency to Pay Benefits,
Though Staffing
Challenges and Persistent
Demand Hampered Their
Ability to Process Claims

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GAO-22-104438  Pandemic Unemployment Assistance
claimants called the state agency more than 100 times because they
were desperate to speak to anyone who could help them.
Selected states experienced IT and other challenges as they built
systems to process PUA claims in the face of intense expectations
and demand for benefits. Because PUA was a new program with its
own eligibility criteria, states had to build new or modify existing IT
systems to process and pay PUA claims. One North Dakota official
compared implementing the PUA program to “trying to build a house at a
million miles an hour [without] really know[ing] what you are doing.”
Our five selected states varied in the strategies they used to build
systems to process PUA claims. For example, Louisiana officials told us
they incorporated the PUA application into their regular UI system.
Arizona officials said they contracted with a vendor to develop a new IT
system for PUA, which provided some functionality that was not available
in their legacy UI system. Louisiana, New York, and North Dakota officials
told us their states used existing DUA programming to assist with PUA
implementation. However, New York and North Dakota officials said
some aspects of PUA were new and could not be modeled after DUA,
such as the PUA application.
States faced challenges using older IT systems to implement PUA. For
example, Wisconsin officials said the state’s unemployment data system
is antiquated, which made programming PUA challenging. Agency
officials said they often had to incorporate workarounds or manual fixes.
For example, Wisconsin’s system was not set up to pay claimants who
had been denied regular UI; however, PUA claimants were often first
denied regular UI benefits before officials could determine PUA eligibility.
Officials from DOL and DOL’s Office of Inspector General also told us that
legacy IT systems challenged many states’ PUA implementation efforts.
State Example of Challenges with Building a New IT System for PUA
Arizona: State agency officials said their agency used a new vendor-developed system,
which provided some efficiencies in PUA implementation. However, they also noted that
they faced other IT challenges. For example, officials said it was challenging to figure
out how the new PUA system should interact and exchange data with the state’s older
legacy systems. In addition, the contracting process and development of the new PUA
system took time and extended the state’s initial implementation; officials said the PUA
portal went live three weeks after they signed the contract with the vendor, which, in
total, was just over six weeks after the CARES Act was enacted.
Source: GAO analysis of interviews with officials in Arizona about Pandemic Unemployment Assistance (PUA) implementation. |
GAO-22-104438

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GAO-22-104438  Pandemic Unemployment Assistance
As states began processing claims, they faced high claims volumes
and staffing challenges. Officials in all five selected states told us that
they did not have enough staff to handle the enormous volume of PUA
and UI claims, and faced significant challenges hiring or training staff. For
example, Louisiana and North Dakota officials emphasized the difficulty of
finding staff with UI experience to quickly increase adjudications or call
center staffing levels. Officials in most selected states said training new
staff who are not familiar with UI under short timeframes posed
challenges, such as new staff being unable to answer claimants’
questions about the program. Louisiana officials said the typical training
period for UI staff is 6 months and they had to condense this into one
week. These officials noted that even experienced staff sometimes
struggled to understand all of the CARES Act programs’ complexities and
varying eligibility requirements, suggesting that it was even more
challenging for new staff who had little or no UI program experience.
North Dakota officials also noted this challenge and said that they triaged
claimants’ calls and routed more complex questions to experienced staff.
State Examples of Difficulties Related to Hiring and Training New Staff
North Dakota: State agency officials said they could not find the dozens of new staff
they needed to hire all at once, and instead, the agency had to hire staff sporadically, as
many as they could at a time. Officials described this process as time-consuming and
inefficient because each time the agency brought on new staff, it had to devote an
experienced staff member to train the new hires. Officials noted that training and
monitoring new staff also took its experienced staff away from their normal claims-
processing duties.
Wisconsin: State agency officials said that hiring and training new staff was
challenging, especially since agency staff simultaneously had to develop the PUA
program. Officials said the agency would have needed to hire and train new staff months
before the pandemic started to be prepared for the influx of claims the agency received.
As a result, the agency was already behind when the CARES Act was enacted, which
compounded challenges it faced.
Source: GAO analysis of interviews with officials in North Dakota and Wisconsin about Pandemic Unemployment Assistance (PUA)
implementation. | GAO-22-104438

In addition to needing more staff to handle claims and call volumes,
selected states also faced challenges ensuring they had the technical
expertise needed to implement the PUA program. North Dakota officials
said they lacked sufficient IT staff to quickly program the numerous
changes necessary for PUA. North Dakota officials also noted that their
staff had to perform the same steps and programming as larger states to
establish the PUA program, but with only six IT staff. New York officials
said IT staff and resources were spread thin across the needs of multiple
state agencies. For example, New York officials said they used state IT
staff to move the PUA application from a separate online form into the

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GAO-22-104438  Pandemic Unemployment Assistance
main UI system, but these shared IT staff also had to devote work time to
other agencies’ pandemic response efforts.
State Examples of How the Pandemic Strained Staff in Other Ways
Transition to telework: Officials in Wisconsin and Louisiana noted that it was
challenging to implement the CARES Act UI programs, including PUA, while
simultaneously transitioning staff to a virtual work environment. Louisiana officials said it
took up to four weeks to transition their staff to telework.
Staff burnout: Officials in North Dakota and Louisiana said their staff faced enormous
workloads implementing the CARES Act UI programs, including PUA, and worked
tirelessly to process these claims. Louisiana officials said their staff had worked long
hours since the beginning of the pandemic, which had taken a professional and
emotional toll on staff. North Dakota officials said that their staff worked day and night,
seven days a week, including holidays, to get the PUA program up and running and
emphasized that this was a big lift for staff.
Source: GAO analysis of interviews with officials in Louisiana, North Dakota, and Wisconsin about Pandemic Unemployment
Assistance (PUA) implementation. | GAO-22-104438

Staffing and IT challenges contributed to claims backlogs and
payment delays. Officials in all five selected states told us they
experienced a backlog of PUA claims at some point during the pandemic,
generally peaking from April through July 2020. State officials attributed
the backlogs to the overall volume of claims that needed to be processed,
and the lack of staff or IT capacity to do so. For example, North Dakota
officials said their agency faced a backlog at the end of April 2020
because it took several weeks to complete the PUA programming needed
to pay claimants. Arizona officials said that in the first week the PUA
application launched, their agency received about 77,000 applications,
with about 45,000 needing reviews. They noted that it could take a long
time to review claims with issues that needed clarification. For example,
officials told us that in August 2020, it generally took more than 3 weeks
to complete reviews of such claims. An official from another state
characterized the average time lapse between PUA initial claims and
payment of benefits that resulted from these backlogs as “just bad.”
However, by the time of our interviews from February through April 2021,
officials in most of our selected states said they had either cleared or
significantly reduced their backlogs.
In addition, as DOL issued new guidance and new legislation was
enacted, states had to adjust to PUA program changes. Officials from
Arizona, Louisiana, North Dakota, and Wisconsin told us that
implementing PUA changes strained staff and IT resources. Officials in
two states also said changes contributed to delays in processing claims.

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GAO-22-104438  Pandemic Unemployment Assistance
State Examples of Delays Caused by Changing PUA Guidance
North Dakota: State officials said their agency experienced bottlenecks in implementing
PUA changes because there was a limited number of staff who could program the
changes.
Wisconsin: State officials said PUA changes were challenging to implement because
their agency had to make IT system changes and their system is antiquated and
inflexible. According to officials, even changes that seemed simple, such as extending
PUA in December 2020, created significant delays due to IT programming issues.
Source: GAO analysis of interviews with officials in North Dakota and Wisconsin about Pandemic Unemployment Assistance (PUA)
implementation. | GAO-22-104438

Although all five selected states had to balance paying benefits quickly to
claimants in need with ensuring payments went exclusively to eligible
claimants, their efforts likely led to trade-offs between expediency and
accuracy. Officials in Arizona, New York, and North Dakota said they
prioritized getting PUA payments out quickly. For example, North Dakota
officials said they did not want to keep claimants waiting while the agency
built the PUA program “on the fly,” so they relied on self-certification, as
directed by DOL guidance. North Dakota officials said they processed
PUA claims expediently, but then continued to review information they
had on file from claimants and employers. Similarly, New York officials
said that the state paid PUA benefits according to claimants’ self-
certification that they were unemployed due to COVID-related reasons. In
contrast, officials in Louisiana and Wisconsin emphasized that their states
reviewed applications closely from the start to make eligibility
determinations. Wisconsin officials said that staff manually reviewed
every PUA application before making payments to claimants in an effort
to get payments out quickly without inadvertently creating overpayments.
States’ different PUA implementation approaches likely led to variation in
claimant experiences across states, such as with the timing and amount
of benefits received. For example, Arizona officials said that some
straightforward PUA applications could be paid automatically, as long as
claimants filed their weekly certifications and no issues were detected
(e.g., identity verification issues). In contrast, Wisconsin officials said it
took time for the agency to get a team of staff members trained and ready
to review applications, and because the state reviewed all PUA
applications manually, some claimants waited a long time for payments.
In addition, states took different approaches to calculating PUA weekly
benefit amounts.55 Officials from New York and North Dakota said they

55For more information about states’ approaches to calculating PUA benefit amounts, see
GAO-21-191.
Selected States’ Varied
Efforts to Balance
Processing PUA Claims
Swiftly with Minimizing
Improper Payments
Affected Payment Timing
and Amounts for
Claimants

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GAO-22-104438  Pandemic Unemployment Assistance
initially paid all PUA claimants the minimum weekly benefit amount and
then re-calculated the amount once claimants submitted sufficient
documentation of prior earnings. Officials from Arizona and Wisconsin
said they took a different approach, initially calculating the weekly benefit
amount based on claimants’ self-certification of earnings or
documentation provided.56 As a result, claimant experiences may have
also differed across states. For example, some individuals may have
temporarily received the minimum weekly benefit for many weeks until
their state paid the difference between the minimum amount and their
calculated weekly benefit amount. Other individuals may have been
overpaid and later had to pay back some funds to the state if, for
example, they did not submit sufficient documentation to support their
self-certified earnings amount.57
Facing large-scale potential fraud in the UI system during the pandemic,
states took actions to minimize improper payments due to fraud such as
by implementing identity verification measures, which sometimes slowed
PUA payments.58 According to state agency officials, three of our
selected states experienced drastic increases in potentially fraudulent
PUA claims at different times during the pandemic.59 Officials from all five
selected states emphasized the importance of detecting and preventing
potential fraud, and to that end, they implemented identity verification
measures for PUA claims. For example, officials from one state said that
after implementing an identity verification tool from a third party vendor,
they observed a substantial drop in potentially fraudulent claims.
However, officials from three states also noted that investigating
potentially fraudulent claims and adding identity verification measures
contributed to claims backlogs and delays in paying eligible claimants.
For example, officials from one of these states said they purchased

56Louisiana officials said they paid a majority of PUA claims filed in April 2020 the
minimum benefit amount. Starting in May 2020, claimants were able to self-certify the
amount of their previous wages when applying, which also prompted the agency to adjust
benefit amounts for some prior claims, as appropriate, according to officials.
57As previously reported, states and territories report to DOL the amount of PUA
overpayments identified each month. For more information about PUA overpayments, and
amounts recovered and waived, see GAO-22-105291.
58We do not name states in the following paragraphs because of sensitivities related to
fraud investigation activities. For more information about potential fraud in the UI system
during the pandemic, see the UI fraud risk management enclosure of GAO-22-105051.
59In general, states may have experienced large-scale potential fraud at different times
due to the changing types and targets of fraudsters.

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GAO-22-104438  Pandemic Unemployment Assistance
software to verify identities using driver’s licenses. However, according to
officials, because people who change their addresses or names often do
not update their driver’s licenses, agency staff often had to manually
review identity verification documents, which was a huge undertaking.
These officials also noted there have been more delays in paying PUA
claimants since establishing identity verification procedures in response
to an increase in potentially fraudulent claims. Officials said they have
reviewed tens of thousands of PUA claims to verify claimant identities.

Sudden unemployment. All but one of the 48 workers we spoke with
said they lost employment due to a sudden drop in client demand or
restrictions on in-person services.60 These individuals had varied careers
prior to the pandemic, including working as web developers, real estate
agents, actors, a hairstylist, rideshare drivers, cashiers, and construction
workers. Many described being available for work during the pandemic
but experiencing a sharp decline in client demand. For example,
rideshare drivers we spoke with said they no longer had clients
requesting rides. Many other workers we spoke with said they lost their
employment because they were unable to provide in-person services due

60Of the 48 contingent workers who participated in our Arizona and New York discussion
groups, 37 reported receiving PUA and 11 reported applying for but not receiving PUA.
The one worker who did not cite decreased demand for their services or restrictions on in-
person services explained that they stopped working due to childcare demands. We use
the terms “contingent worker”, “worker”, and “claimant” interchangeably in this section as
the participants in the discussion groups were all contingent workers who applied for PUA.
Despite Some
Challenges Accessing
Benefits, Selected
Contingent Workers
Relied on PUA, and
DOL Has Not
Identified or Assessed
Future Ways to
Support Such
Workers
Selected Contingent
Workers Experienced
Sudden Unemployment
and Challenges Claiming
PUA, Such As Long Waits
for Payments and
Customer Service

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GAO-22-104438  Pandemic Unemployment Assistance
to government restrictions, business closures, or their own concerns
about health risks. For example, a waiter told us their restaurant closed its
dining room due to government restrictions and a delivery driver with an
autoimmune disorder said they received medical instructions to stay at
home.
A few workers discussed difficulties related to their job loss that may be
more common to contingent employment.61 For example, a few workers
we spoke with said that due to the nature of their work, which relies on
many individual clients, they experienced extra financial insecurity due to
uncertainty in whether or when they would be paid for already completed
work. In addition, a freelance salesperson in New York told us that they
“felt very expendable” when the pandemic hit and “a little disheartened”
with the lack of communication and follow-up from their employers. The
Just Recovery Survey, administered during the pandemic, also
underscores the precarious nature of contingent employment. Although it
examined a more narrowly-defined subset of contingent workers, the
survey found that an estimated 36 percent of temporary workers,
freelancers, and independent contractors reported losing work during the
pandemic, nearly double the 19 percent of direct hire employees who
reported losing work.62
Waiting period to receive PUA. Many workers we spoke with reported
waiting a long time to receive their first PUA payment after losing their

61We generally characterize the frequency of workers’ experiences in broad terms such as
“a few,” “some,” and “many” because the open-ended format of most discussion questions
and time constraints meant that participants may not have discussed all aspects of their
experiences. Thus, exact counts of worker experiences could be misleading. We generally
consider “a few” to indicate two or more workers, “some” to indicate four or more workers,
and “many” to indicate more than half of the group of workers being discussed. However,
for multiple-choice poll questions we asked workers, we present exact counts of
responses.
62This difference is statistically significant at the 95 percent confidence level and the
margins of error for lost work for contingent worker and direct hire groups are +/- 9.1 and
2.5 percentage points, respectively. The survey finding does not control for other factors
that may have affected likelihood of job loss during the pandemic, such as industry,
location, or worker demographics. The survey, administered by the research firm SSRS in
September and October of 2020, used a nationally representative random sample with an
oversample of Black and Hispanic/Latino respondents. Of the 5,382 individuals invited to
participate, 3,100 respondents completed the survey. The authors of the survey report
shared this additional analysis of lost work with us. Color of Change, National Employment
Law Project, Time’s Up Foundation, and The Worker Institute at Cornell ILR, Foundations
for a Just and Inclusive Recovery: Economic Security, Health and Safety, and Agency and
Voice in the COVID-19 Era (National Employment Law Project, Feb. 3, 2021).

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GAO-22-104438  Pandemic Unemployment Assistance
employment. For example, 13 of 36 responding discussion group
participants who received PUA benefits reported that they received their
first payment more than 2 months after they lost their employment (see
fig. 3).63 The long waits workers reported likely reflect the challenges state
officials told us they had with processing payments quickly given the high
volume of claims, and the difficulties workers experienced in reaching
customer service staff and verifying their eligibility, discussed in more
detail below.
Figure 3: Reported Time between Discussion Group Participants’ Employment Loss
and Receipt of First PUA Payment

Notes: We posed this multiple-choice poll question to all 37 discussion group participants. However,
one PUA recipient experienced connectivity challenges during the discussion group and did not
respond to this question. We provided the categories, which overlap slightly, to help participants
recollect their experiences. Participants generally selected one of the options. Two participants said 8
weeks and we counted them in the 4-8 week category.

The long waits for payments caused financial and other hardships for
some workers. Some claimants we spoke with said they needed to
negotiate rent payment delays, defer bills, or accrue credit card debt while
they were waiting for their first PUA payment. For example, one worker
told us that despite cutting expenses, they had to arrange with their

63We posed a multiple-choice poll question to all 37 discussion group participants about
the length of time between employment loss and receipt of first PUA payment. However,
one participant experienced connectivity challenges during the discussion group and did
not respond to this question.

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GAO-22-104438  Pandemic Unemployment Assistance
landlord to pay half their rent upfront and the remainder upon receipt of
PUA.
Worker Perspectives: Long Wait for Pandemic Unemployment Assistance (PUA)
New York Worker: “[The waiting period] was extremely stressful. I had no other income
and no idea when I would start earning my regular income again. So although [PUA]
was a lifesaver, [because] it took eight to 12 weeks to arrive… I had to apply for
mortgage forbearance and borrow money to meet my commitments.”
Source: GAO analysis of information from discussion groups with unemployed contingent workers who applied for PUA benefits in
Arizona and New York. | GAO-22-104438

Customer service challenges. Many workers we spoke with reported
experiencing long wait times or an inability to reach customer service
representatives, and once connected, some reported a lack of clarity in
official communications or difficulty resolving their issue. These worker
experiences reflect some of the challenges state officials described. For
example, as previously discussed, state officials said they faced
significant challenges hiring and training staff for call centers. The long
wait times to reach customer service were a common theme in New York
discussion groups as participants described calling the state office to
verify their PUA eligibility as a final step in completing their online
application.64 Claimants in both Arizona and New York reported stress
and uncertainty over when their claim would be processed, and some
described being overwhelmed by the time demands of continually calling
state agencies.
Worker Perspectives: Long Wait Times to Reach Customer Service
New York Worker: “It was a nightmare… It took me about 15 to 20 times to get
through… [and] each time I waited for between an hour and a half [to] two hours [to get
through to] someone.”
New York Worker: “It took about… two months [to reach the state office] and that was
[with] making it almost a full-time job of… calling. I called hours and hours and hours
every single day for at least a month and a half to two months… [because the message
from the state office] was just keep on calling.”
Arizona Worker: “For the first 20 calls, I was not able to reach any person [on] the
customer care line.… [When] I was able to reach them finally… they put me on hold [for]
nearly three hours.”
Source: GAO analysis of information from discussion groups with unemployed contingent workers who applied for Pandemic
Unemployment Assistance (PUA) benefits in Arizona and New York. | GAO-22-104438

64All but four workers in the New York PUA recipient discussion groups said they had to
call the state office. Two of the workers who did not mention this step were both
experiencing technical difficulties during the discussion group and only responding
through the chat function at this point in the discussion.

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GAO-22-104438  Pandemic Unemployment Assistance
A few claimants also told us about difficulties with call center staff being
unfamiliar with the requirements of the new PUA program or a lack of
follow up when they were told someone would get back to them. For
example, one worker told us that they spoke with call center staff who
were not clear on whether independent contractors were eligible for PUA,
especially if they had a separate part-time job.
In addition, the 11 workers we spoke with who had not received PUA had
either had their claims denied as ineligible, or had claims that had been
pending for extended periods with no response from the state. Those
denied eligibility generally reported that they were unsure of the reason
they were deemed ineligible. According to DOL guidance issued in April
2020, states were not required to list all the eligibility criteria the applicant
did not meet, and could simply notify the claimant that they were not
considered unemployed, partially unemployed, or unable or unavailable to
work for one of the qualifying reasons listed in the CARES Act.65
However, some claimants we spoke with expressed frustration with that
lack of clarity. For example, one New York worker told us they were not
given any information on how to contact the state or file an appeal and
received no response to emails asking why they were not approved. The
worker said they stopped considering an appeal after sending 10 emails
requesting clarification with no response. In addition, one Arizona worker
said their application had been pending for months with no response,
which they described as being difficult emotionally and hindering their
ability to plan their next steps.
Eligibility verification challenges. Claimants we spoke with faced some
difficulties navigating how to verify their eligibility, including gathering and
providing the appropriate documentation and verifying their eligibility
when they had been victims of identity theft. A few of these workers said
these challenges were in part due to being new to the UI system and
unfamiliar with the process and its requirements. Some claimants
reported challenges with gathering required employment and income
documentation. Others said they were unsure what tax documentation
they needed to demonstrate their income, and a few claimants said they
had to reach back out to former employers to obtain proof of employment
and income. For example, one claimant who ultimately did not receive
benefits said they had difficulty verifying their employment because they

65DOL’s guidance states that qualifying reasons are listed under section
2102(a)(3)(A)(ii)(I) of the CARES Act. Department of Labor, PUA Program Reporting
Instructions and Questions and Answers, UIPL 16-20, Change 1 (Apr. 27, 2020).

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GAO-22-104438  Pandemic Unemployment Assistance
were an actor who worked for numerous production companies across
many separate shows.
Examples from Selected States: Technical Challenges with Obtaining Workers’
Documentation
Louisiana state officials told us they had significant challenges verifying identities due to
the poor resolution of uploaded drivers’ licenses. Officials said they ultimately
recommended that claimants use their Louisiana digital driver’s license, accessible
through a free app, rather than attempting to upload an image of their physical license.
Wisconsin state officials said initially claimants were required to mail or fax documents
until the state enhanced its online portal to enable uploading documents.
Source: GAO analysis of interviews with state officials in Louisiana and Wisconsin. | GAO-22-104438

Resolving claims delayed by identity theft. A few claimants we spoke
with who were victims of identity theft said they experienced long delays
before receiving benefits as the fraud was investigated. They also told us
they invested substantial time investigating their own cases. For example,
a victim of identity theft in New York said they had payments paused for
two months because a fraudulent account was opened in their name in
another state. The claimant told us they had to call both states’ UI
agencies repeatedly to resolve their case. An Arizona claimant who said
they applied for PUA in late October 2020 told us they were a victim of
identity theft and that they had not yet received PUA benefits as of early
July 2021 because their case had not yet been resolved. They said they
relied on mortgage forbearance and selling various possessions to get by
in the meantime.
Other challenges identified by state officials and worker advocates.
State officials and advocacy groups serving PUA claimants highlighted
challenges related to language barriers, workers paid in cash, and mixed
earners.
•
Language barriers. Worker advocates told us that non-English
speaking claimants faced challenges accessing translated information
in a timely manner. According to officials in Louisiana, North Dakota,
and Wisconsin, when we spoke with them, the PUA online application
was only available in English, and claimants who needed language
assistance were directed to call in to the state office for translation
services. In addition, officials with two New York worker advocacy
groups reported that some Spanish-speaking applicants who needed
a call back from the state workforce agency were called by a staff
person who did not speak Spanish.
•
Cash income. According to worker advocacy groups in Louisiana and
New York, cash workers faced difficulty reporting their earnings in

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GAO-22-104438  Pandemic Unemployment Assistance
PUA applications because many do not have the appropriate
documentation to prove their income, or must provide numerous
receipts to show earnings. Officials from two New York advocacy
groups told us these workers received lower benefit amounts than
they would have if their income had been formally documented.
•
Mixed earners. Worker advocates in Louisiana and New York told us
that some individuals whose primary income was from contingent
work but who had sufficient wages from traditional employment to
qualify for regular UI were not eligible for PUA, though they would
have received a higher benefit under PUA. As we have previously
reported, the Mixed Earner Unemployment Compensation (MEUC)
program was created in December 2020 to address this situation.66
However, earlier in the pandemic and while waiting on states to
implement their MEUC programs, contingent workers eligible for
MEUC received a lower than expected benefit given their prior
income. Moreover, two states decided not to participate in the MEUC
program, and not all participating states had begun paying benefits as
of February 2022, according to DOL.67
Resolving common challenges. While many claimants we spoke with
said they experienced customer service challenges, some recognized the
difficulties facing states as they received historic numbers of claims and
expressed appreciation for the efforts of state staff. In addition, some
claimants told us that when they connected with the correct staff person—
even if that took a long time and was after being transferred a number of
times—the representative was helpful and resolved their issue in a timely
manner. Workforce agency officials from Louisiana, New York, and North
Dakota told us that they took steps to reduce call wait times by increasing
call center staff and using various strategies such as implementing
interactive voice response systems or chat bots, and enabling applicants

66See GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its
Second Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021). MEUC benefits were
available to eligible individuals in participating states starting with the week of
unemployment beginning on December 27, 2020, according to DOL. Department of Labor,
Employment and Training Administration, Continued Assistance for Unemployed Workers
(Continued Assistance) Act of 2020 — Federal Pandemic Unemployment Compensation
(FPUC) Program Reauthorization and Modification and Mixed Earners Unemployment
Compensation (MEUC) Program Operating, Reporting, and Financial Instructions,
Unemployment Insurance Program Letter (UIPL) No. 15-20, Change 3 (Washington, D.C.:
Jan. 5, 2021).
67According to DOL, Idaho and South Dakota opted not to participate in the MEUC
program. For more information, see GAO-22-105051, GAO-22-105291, and
GAO-22-105397.

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GAO-22-104438  Pandemic Unemployment Assistance
to schedule a time to receive a call back. A few workers we spoke with in
New York told us they observed improvement over time.
Worker Perspectives: Gratitude for Efforts of State Customer Service Staff
New York Worker: “I can only imagine the stress and anxiety [of] the people
answering… from all of us calling in. And I always was impressed by how receptive and
easy they were to speak to.”
Arizona Worker: “I just had a little issue with the exact document to upload, but… I got
that figured out, thanks to the awesome customer service.”
Source: GAO analysis of information from discussion groups with unemployed contingent workers who applied for Pandemic
Unemployment Assistance (PUA) benefits in Arizona and New York. | GAO-22-104438

A few claimants we spoke with also reported that frequently asked
questions documents and other resources posted on social media helped
them resolve their challenges. State officials we spoke with in Arizona,
Louisiana, New York, and North Dakota said they identified common
questions and concerns by, for example, tracking inquiries and monitoring
social media. Officials said the states subsequently updated their
websites and social media pages to more efficiently address frequent
questions.
Meeting financial needs during the pandemic. Many of the 37
claimants who received PUA told us that their benefits allowed them to
pay for their housing and basic bills, though they needed to supplement
these benefits with other financial resources. Two claimants called PUA a
“lifesaver” and others echoed the sentiment that PUA was critical to
getting by financially during the pandemic.
Worker Perspectives: Importance of Pandemic Unemployment Assistance (PUA)
Support
New York Worker: “[PUA] gave me the ability to keep my business afloat, because I
could make sure that I had a place to live… and pay all my bills, and food… I don’t know
where I would be if it wasn’t available.”
Arizona Worker: “[With PUA] I was able to clear the rent bills that had accumulated and
I was able to find some funds to pay my utility bills, to be able to buy some groceries
and… everything for day-to-day life.”
Source: GAO analysis of information from discussion groups with unemployed contingent workers who applied for PUA benefits in
Arizona and New York. | GAO-22-104438

In addition, claimants we spoke with typically relied on PUA for a lengthy
period. For example, 28 of the 36 responding discussion group
participants who received PUA reported claiming benefits for longer than
4 months, and some were still receiving PUA at the time of our
Selected Contingent
Workers Relied on
Unemployment Benefits
and Other Resources, and
DOL Has Not Yet
Assessed How the UI
System Could Support
Such Workers Moving
Forward

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GAO-22-104438  Pandemic Unemployment Assistance
discussions in May through July 2021 (see fig. 4).68 The experiences of
the workers in our discussion groups were similar to PUA recipients
nationally, according to claims data states have reported to DOL. For
example, across the 40 states we analyzed, the average PUA benefit
duration was about 30 weeks.69
Figure 4: Discussion Group Participants’ Reported Total Weeks of PUA Benefits
Claimed

Notes: Weeks claimed are as of the time of the discussion groups, which we held with Arizona
workers in June and July 2021 and with New York workers in May and June 2021. Some workers
were still receiving PUA at the time of the discussion groups. We posed this multiple-choice poll
question to all 37 discussion group participants. However, one PUA recipient experienced
connectivity challenges during the discussion group and did not respond to this question. We
provided the categories, which overlap slightly, to help participants recollect their experiences.
Participants generally selected one of the options. One participant said 16 weeks and we counted
them in the 8-16 week category.

Some of the 37 claimants reported that while PUA was important for
being able to afford necessities, the benefits were not sufficient on their

68We posed a multiple-choice poll question to all 37 discussion group participants about
the length of time they received PUA. However, one participant experienced connectivity
challenges during the discussion group and did not respond to this question.
69We calculated average PUA benefit duration by dividing the total number of weeks
compensated by the total number of first payments made through June 2021 (an
approximation of individuals paid). We excluded states and territories from our analysis if
they had multiple months of missing data or data anomalies, such as reporting more first
payments made than initial claims submitted. For a full listing of average PUA benefit
duration in each of the states we analyzed, see appendix III.

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GAO-22-104438  Pandemic Unemployment Assistance
own. For example, one claimant told us that PUA enabled them to pay
rent, but they still sometimes had to “stretch” meals. Some claimants told
us that the cost of living in their community was an important factor in the
extent to which PUA met their financial needs. For example, a few
workers told us that PUA was barely sufficient to cover the high cost of
living in New York City. Across the 40 states we analyzed, the average
PUA compensation amount was $232 per week, though this varied
substantially by state and ranged from $113 in Mississippi to $326 in
Kansas.70
Some PUA claimants reported that benefits played a larger role in
meeting their basic needs when they received both PUA and the FPUC
supplement, which was $600 through July 2020 and later $300 in 2021.
One worker told us that when FPUC provided the $600 weekly
supplement they were able to meet their basic needs, but when it expired
and was later reauthorized at a reduced amount, they needed to get a
roommate and rely on their personal savings.
Other financial strategies. Although claimants told us PUA was helpful,
many said they had to rely on other strategies and forms of support to
supplement PUA benefits. Claimants who had high housing costs or
multiple children told us they were more reliant on other forms of support
to supplement PUA benefits. For example, one single mother with two
young children in New York told us she relied on a city emergency food
program to provide groceries for her family. She told us this city-provided
program prevented her from having to decide between paying for food or
making car and medical insurance payments. Some claimants also
described accruing debt through loans, use of credit cards, or
arrangements with companies to delay payments. In addition, some
claimants told us they supplemented their PUA benefits with personal
savings, income from a still-employed spouse, support from friends or
extended family, or limited work.
Many claimants described needing to cut expenses while receiving PUA.
For example, one worker told us they reduced their phone and internet
plans. A few participants reported losing or downgrading their health

70We calculated average PUA weekly benefits by dividing the total amount compensated
by the total number of weeks compensated through June 2021. We excluded states and
territories from our analysis if they had multiple months of missing data or data anomalies,
such as reporting more weeks compensated than weeks claimed. For a full listing of
minimum and average benefits in each of the states we analyzed, see appendix III.

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GAO-22-104438  Pandemic Unemployment Assistance
insurance during the pandemic, either due to working too few hours to
qualify or because they could no longer afford it.71 Similarly, officials from
the Freelancers Union told us they observed declines in health insurance
enrollment among their national membership, with over one third of
membership forgoing coverage due to cost, according to the officials.
Worker Perspectives: Other Household Income or Prior Savings Sometimes
Prevented Hardship
Some claimants who told us that they had sufficient savings or that they relied on their
partner’s income to supplement Pandemic Unemployment Assistance (PUA) said they
were able to meet their needs without significant hardship during the pandemic. For
example, one worker told us, “Once [augmented benefits from Federal Pandemic
Unemployment Compensation] got cut down, it definitely tightened things. But…
because I have… a significant other who has remained fully employed throughout [the
pandemic], we haven’t had any major crisis.”
Source: GAO analysis of information from discussion groups with unemployed contingent workers who applied for PUA benefits in
Arizona and New York. | GAO-22-104438

Support for contingent workers after PUA expiration. Although PUA
benefits were critical for many of the contingent workers we spoke with
during the pandemic, much of this population is generally ineligible for
regular UI benefits. Contingent workers, broadly defined, represent a
substantial proportion of the U.S. workforce, and states and territories
reported making 17.8 million PUA first payments through June 2021 (an
approximation of the number of individuals who received PUA).72
However, the UI system was not designed to cover self-employed
workers or others with nontraditional attachments to the workforce. Thus,
a significant population of workers do not generally have access to this
financial support during periods of unemployment. In addition, state
officials told us that some standard eligibility verification practices used for
regular UI are not applicable to some workers in alternative work
arrangements, and that they do not have other options for verifying these
workers’ prior employment if future temporary programs expand eligibility
to this population.

71As we have previously reported, employer-sponsored health insurance rates declined in
2020, but loss of employer-sponsored coverage was less than originally expected and
there was increased enrollment in alternative sources of coverage including Medicaid and
Patient Protection and Affordable Care Act exchanges. See GAO-22-105051 and
GAO-22-105397.
72Not all states and territories have reported data for all months, so the actual number of
individuals paid through June 2021 is likely greater. We obtained these data on January
28, 2022. States and territories may submit adjusted data to DOL over time.

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The mission of DOL’s Employment and Training Administration is to
contribute to the more efficient functioning of the U.S. labor market,
including through provision of income maintenance services. According to
DOL, UI is a social insurance program designed to provide benefits to
most individuals out of work such that a significant proportion of their
weekly needs can be met while they search for work. In August 2021,
DOL issued a UI modernization plan and announced the creation of
the temporary Office of Unemployment Insurance Modernization to create
a more resilient and equitable UI system. DOL’s UI modernization plan
refers to UI as “a lifeline for millions of workers” and calls for
“strengthening the [UI] system to ensure that it works for all workers.” The
modernization plan states that one of the principles for any reform of the
UI program is “addressing the lack of access to UI for [certain] workers…
[including] low-income and part-time workers, and workers with non-
traditional work histories.” DOL’s fiscal year 2022 and 2023 budget
justifications elaborate on these principles, noting, “The UI system must
reflect the modern economy and labor force… [and the] Administration
supports finding a way to address the lack of support in the existing UI
system for many workers, including independent contractors, low-income
and part-time workers, and workers with nontraditional work histories.”
According to DOL officials, the agency has historically provided technical
assistance to Congress about UI legislative proposals, including
comprehensive UI reform. As the agency responsible for leadership and
oversight of the UI system, DOL is uniquely positioned to identify and
assess the costs, benefits, and risks of various options for addressing the
lack of access to UI for underserved categories of workers identified in its
vision for UI modernization. Federal standards for internal control state
that management should identify, analyze, and respond to new risks
resulting from changing conditions, including economic instability or
potential emergencies.73 However, DOL officials stated that the agency
does not currently plan to comprehensively examine options for
systematically supporting contingent workers, beyond providing targeted
technical assistance to Congress on individual legislative proposals,
which, according to DOL, Congress had not sought as of April 2022.
Without proactive consideration of options by DOL, Congress and other
policymakers lack potentially valuable information about whether it is
feasible or what options may exist to serve the substantial population of
contingent workers outside of emergencies, or whether it is possible to

73GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington D.C.: Sept. 2014).

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GAO-22-104438  Pandemic Unemployment Assistance
better serve these workers through temporary disaster programs. As a
result, policymakers may also miss opportunities to respond more
effectively to future economic downturns, especially if short-term or
contract work become more common. In addition, states may again face
challenges and greater fraud risks if called on to implement temporary
benefit programs that include these workers without advance
consideration of options, including eligibility verification practices.
We found wide variation in the percentage of PUA claimants who
received benefit payments across the 40 states we analyzed, which
suggests substantial differences in the program circumstances and
claimant experiences across states (see fig. 5).74 Various factors could
explain the payment rate in a given state. For example, if a state received
a large number of claims from individuals who did not meet program
eligibility criteria or a large number of potentially fraudulent claims, which
the state then appropriately did not pay, then its payment rate would be
lower. Payment rates could also be affected by differences in how states
applied federal program criteria. As noted above, states structured
applications and reviewed claims differently, which could lead to higher or
lower approval and payment rates. In addition, because the payment
rates we calculated represent a snapshot in time, if a state had a large
number of pending claims that it later determined to be eligible, its
payment rate could increase.

74We calculated the percentage of PUA claimants who received benefits by dividing each
state’s total number of first payments made by the total number of initial applications
submitted. Generally, each PUA claimant submits one initial application and each recipient
receives one first payment. We ended our analysis at June 2021, the last month during
which the PUA program was in effect in all states; 20 states terminated the PUA program
from mid-June to late July, before its expiration. First payment and initial applications data
are from DOL’s ETA 902P data file, which we obtained on January 28, 2022. States and
territories may submit adjusted data to DOL over time. We limited our analysis to 40 of 53
states and territories because the PUA claims data they reported to DOL were sufficiently
reliable for our purposes. We excluded the other states and territories due to their having
multiple months of missing data or data anomalies.
Selected States’ Data
Show Racial or Ethnic
Disparities in Receipt
of PUA and DOL Has
Not Yet
Systematically
Examined Such
Disparities in Its
Efforts to Improve UI
Equity

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GAO-22-104438  Pandemic Unemployment Assistance
Figure 5: First Payments Made to PUA Claimants as a Percentage of Initial
Applications Submitted among 40 States, March 2020 through June 2021

Notes: We calculated the percentage of PUA claimants who received benefits (i.e., payment rate) by
dividing each state’s total number of first payments made by the total number of initial applications
submitted. Generally, each PUA claimant submits one initial application and each recipient receives
one first payment. Various factors could explain the payment rate in a given state, such as how a
state reviewed and determined claimant eligibility or the volume of potentially fraudulent claims in the
months analyzed. We ended our analysis at June 2021, the last month during which the PUA
program was in effect in all states; 20 states terminated the PUA program from mid-June to late July,
before its expiration. First payment and initial applications data are from the Department of Labor’s
(DOL) ETA 902P data file, which we obtained on January 28, 2022. States and territories may submit
adjusted data to DOL over time. We limited our analysis to 40 of 53 states and territories because the
PUA claims data they reported to DOL were sufficiently reliable for our purposes. We excluded the
other states and territories due to their having multiple months of missing data or data anomalies.

Aggregated claimant data provided by four of our selected states also
show substantial differences in the percentage of PUA applicants who
received benefits during the period analyzed for each state (see table
1).75

75We obtained aggregated data from our selected states on the number of unique
individuals who submitted PUA initial claims and who received benefits at any time during
specified periods of the pandemic. Due to substantial numbers of potentially fraudulent
PUA claims across multiple months, the program data we obtained from Arizona were not
sufficiently reliable for the purposes of this analysis. Louisiana had a spike in individuals
submitting PUA initial claims in November 2020 and New York had a spike in January
2021. In both cases, state officials said these spikes represented an influx of potentially
fraudulent claims. Thus, we analyzed PUA claims submitted and paid during the period
prior to the influx of these potentially fraudulent claims. Including large spikes in potentially
fraudulent claims could distort comparisons of benefit receipt rates. For more information,
see appendix I.

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GAO-22-104438  Pandemic Unemployment Assistance
Table 1: Individuals Who Applied for and Received PUA Benefits in Four Selected States
State
(period analyzed)
Louisiana
(through Oct.
2020)
New York
(through Dec.
2020)
North Dakota
(through Apr.
2021)
Wisconsin
(through Apr.
2021)
Number of unique individuals who submitted PUA
initial claims during the period
318,618
1,806,487
36,916
152,988
Number of unique individuals who received PUA
benefits during the period
217,523
1,534,911
12,846
58,242
Percentage of applicants who received PUA
benefits during the period
68.3%
85.0%
34.8%
38.1%
Source: GAO analysis of aggregated Pandemic Unemployment Assistance (PUA) claimant data provided by states. | GAO-22-104438
Notes: We obtained aggregated data from our selected states on the number of unique individuals
who submitted PUA initial claims and who received benefits at any time during specified periods of
the pandemic. Louisiana had a spike in individuals submitting PUA initial claims in November 2020
and New York had a spike in January 2021, which state officials said represented an influx of
potentially fraudulent claims. Thus, we analyzed PUA claims submitted and paid during the period
prior to the influx of potential fraud. Various factors could explain benefit receipt rates, such as how a
state reviewed and determined claimant eligibility or the volume of potentially fraudulent claims in the
months analyzed.

Racial and ethnic disparities. Our analysis of aggregated claimant data
from four selected states showed substantial racial and ethnic disparities
in PUA benefit receipt among individuals who submitted claims in three of
the states and relatively small differences between groups in one state
(see table 2).76 Both the magnitude and types of disparities we found
varied.77 For example, in two states, the percentages of PUA applicants in
certain racial and ethnic minority groups who had received benefits were
substantially lower than White applicants (the largest group of applicants
in each state). In three states, the percentages of Asian PUA applicants

76For purposes of this analysis, we consider groups within 3 percentage points of each
other to be relatively similar. We consider differences between groups of between 3 and
10 percentage points to be relatively small, and differences between groups of more than
10 percentage points to be substantial. We also analyzed differences in PUA benefit
receipt by gender. In New York, benefit receipt rates of female and male applicants were
relatively similar. In Louisiana, North Dakota, and Wisconsin, we found relatively small
differences with higher percentages of female applicants receiving benefits.
77Because disparities were among individuals who had already submitted claims, they
cannot be explained by barriers to applying for benefits that may affect certain groups
disproportionately.

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GAO-22-104438  Pandemic Unemployment Assistance
who had received benefits were substantially higher than other groups.78
Specifically:
•
In North Dakota and Wisconsin through April 2021, the percentage of
Black PUA applicants who had received benefits was about half the
percentage of White applicants.
•
In Wisconsin, the percentages of Hispanic/Latino and American
Indian/Alaskan Native PUA applicants who had received benefits
were also substantially lower than White applicants.
•
In Louisiana and North Dakota, a substantially higher percentage of
Asian PUA applicants had received benefits than all other groups
during the periods we analyzed.79 In addition, in Wisconsin, the
percentage of Asian PUA applicants who had received benefits was
relatively similar to White applicants, but substantially higher than
other racial and ethnic minority groups.
Table 2: Racial and Ethnic Disparities in the Receipt of PUA Benefits in Selected States
State
(period analyzed)
Louisiana
(through Oct. 2020)
New York
(through Dec. 2020)
North Dakota
(through Apr. 2021)
Wisconsin
(through Apr. 2021)
Percentage of PUA
applicants who received
benefits during the period

White, non-Hispanic/Latino
66.9%
84.4%
39.0%
43.3%
Black, non-Hispanic/Latino
72.3%
83.5%
19.5%a
21.9%a
Asian, non-Hispanic/Latino
91.7%a
91.4%
61.7%a
41.8%
American Indian/Alaskan
Native, non-Hispanic/Latino
73.7%
82.6%
39.6%
27.2%a
Hispanic/Latino
67.4%
85.5%
36.8%
24.8%a
Source: GAO analysis of aggregated Pandemic Unemployment Assistance (PUA) claimant data provided by states. | GAO-22-104438
Notes: We do not include individuals of other/unknown race or ethnicity because the mix of
individuals who did not select a race/ethnicity or selected more than one means the results cannot be
meaningfully interpreted. Louisiana had a spike in individuals submitting PUA initial claims in
November 2020 and New York had a spike in January 2021, which state officials said represented an
influx of potentially fraudulent claims. Thus, we analyzed PUA claims submitted and paid during the

78Unless otherwise noted, the racial groups discussed are limited to non-Hispanic/Latino
individuals.
79Louisiana had a spike in individuals submitting PUA initial claims in November 2020,
which state officials said represented an influx of potentially fraudulent claims. Thus, we
analyzed PUA claims submitted and paid during the period prior to the influx of these
potentially fraudulent claims. Including large spikes in potentially fraudulent claims could
distort comparisons of benefit receipt rates between groups, especially if the potentially
fraudulent claims were concentrated in certain racial or ethnic groups.

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GAO-22-104438  Pandemic Unemployment Assistance
period prior to the influx of potential fraud. Various factors could explain benefit receipt rates and
differences between groups, such as how states reviewed claimant eligibility or the volume of
potentially fraudulent claims in the months analyzed, especially if fraudsters more frequently selected
a certain race when applying. Non-Hispanic/Latino race groups in the table are listed, in general, in
order of descending population size, followed by the Hispanic/Latino ethnic group.
aMinority groups with substantial differences compared to White, non-Hispanic/Latino (the largest
group of applicants in each state). For purposes of this analysis, we consider groups within 3
percentage points of each other to be relatively similar. We consider differences between groups of
between 3 and 10 percentage points to be relatively small, and differences between groups of more
than 10 percentage points to be substantial.

In contrast to the substantial disparities we found in three states, in New
York through December 2020, benefit receipt rates between all but one
racial and ethnic group were relatively similar (i.e., within 3 percentage
points).80 Asian applicants in New York received benefits at a higher rate
than other groups, but the differences were relatively small. We also
found some other relatively small differences between non-Asian groups
in Louisiana. Through October 2020, Black and American Indian/Alaskan
Native groups received benefits at a higher rate than White and
Hispanic/Latino groups, but the differences were relatively small.
Results from two national surveys also suggest the presence of racial and
ethnic disparities in the receipt of any UI benefits during the pandemic,
including both regular UI and PUA.81 As we previously reported,
according to our analysis of nationwide data from Census’s Household
Pulse Survey, a higher percentage of White applicants than Black
applicants reported receiving benefits at some time during the pandemic
from UI programs, including regular UI and PUA (an estimated 80.2

80New York had a spike in individuals submitting PUA initial claims in January 2021, which
state officials said represented an influx of potentially fraudulent claims. Thus, we
analyzed PUA claims submitted and paid during the period prior to the influx of these
potentially fraudulent claims.
81In addition, prior to the pandemic, the Current Population Survey has included a
supplement with questions about respondents’ application for and receipt of UI benefits,
most recently in 2005 and 2018. In the 2018 survey’s news release, BLS reported that
there was little difference in the likelihood of receiving UI benefits by race or Hispanic
ethnicity. Department of Labor, Bureau of Labor Statistics, Characteristics of
Unemployment Insurance Applicants and Benefit Recipients—2018 (Washington, D.C.:
Sept. 25, 2019; reissued Nov. 7, 2019). However, a couple reports analyzing the 2005
survey results found some evidence of racial and ethnic disparities in UI receipt. Alix
Gould-Werth and H. Luke Shaefer, “Unemployment Insurance Participation by Education
and By Race and Ethnicity,” Monthly Labor Review, vol. 135, no. 10 (Oct. 2012). Wayne
Vroman, The Urban Institute, IMPAQ International, UI Benefits Study: An Analysis of
Unemployment Insurance Non-Filers: 2005 CPS Supplement Results, submitted to
Department of Labor, Employment and Training Administration (Sept. 2008).

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GAO-22-104438  Pandemic Unemployment Assistance
percent versus 73.0 percent, respectively).82 Though this difference is
relatively small compared to some of those we found in our selected
states’ aggregated PUA data, it is statistically significant and represents a
nationwide disparity. In addition, the Just Recovery Survey, administered
during the pandemic, found that among individuals who applied for some
form of unemployment support (including both regular UI and PUA)
between March and October 2020, an estimated 34 percent of Black
individuals and 26 percent of Hispanic/Latino individuals applying for
these benefits were denied, a significantly higher share than the 14
percent of White, non-Hispanic/Latino individuals who were denied.83
Various factors could explain the racial and ethnic disparities we
observed during the pandemic in the selected states’ aggregated PUA
data and in the national surveys. Racial and ethnic disparities could result
from any differences affecting benefit receipt rates—including eligibility

82GAO, Management Report: Preliminary Information on Potential Racial and Ethnic
Disparities in the Receipt of Unemployment Insurance Benefits during the COVID-19
Pandemic, GAO-21-599R (Washington, D.C.: June 17, 2021). Because the questions in
the Household Pulse Survey refer broadly to UI benefits, they likely include applicants for
regular UI and PUA benefits. Both Black and White applicant groups discussed are limited
to non-Hispanic/Latino individuals. The percentages represent responses to the final
phase 3 survey (week 27), which collected data from March 17, 2021 through March 29,
2021. The difference in the rate of reported UI benefit receipt is statistically significant at
the 95 percent confidence level and the margins of error for the White and Black, non-
Hispanic/Latino groups are +/- 1.9 percentage points and +/- 4.8 percentage points,
respectively. We also examined responses from each of the 10 phase 3 surveys (weeks
18-27). We found that applicants in the following racial and ethnic groups reported
receiving UI benefits at a lower rate than White, non-Hispanic/Latino applicants, and these
differences were statistically significant in multiple surveys: 1) Black, non-Hispanic/Latino
UI applicants (this difference was statistically significant in 8 of the 10 phase 3 surveys); 2)
Hispanic or Latino UI applicants (this difference was statistically significant in 2 of the 10
surveys); 3) Other or multiple races, non-Hispanic/Latino UI applicants (this difference was
statistically significant in 4 of the 10 surveys). In all remaining surveys, each of these
groups reported receiving benefits at a lower rate than White, non-Hispanic/Latino
applicants, but the differences were not statistically significant.
83According to additional information provided by the survey report authors, the 95 percent
confidence intervals around the Black, Hispanic/Latino, and White group results are +/-
9.7, +/- 10.1, and +/- 4.9 percentage points, respectively. According to the survey report,
Black respondents include those who identified as both Hispanic/Latino and non-
Hispanic/Latino, and the Hispanic/Latino group excludes those individuals who said they
were both Black and Hispanic/Latino. Color of Change, National Employment Law Project,
Time’s Up Foundation, and The Worker Institute at Cornell ILR, Foundations for a Just
and Inclusive Recovery: Economic Security, Health and Safety, and Agency and Voice in
the COVID-19 Era (National Employment Law Project, Feb. 3, 2021).

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GAO-22-104438  Pandemic Unemployment Assistance
requirements—if they are correlated with race and ethnicity.84 For
example, one potential explanation for the disparities we identified is that
systemic inequities—such as how states reviewed claims or applied
program criteria—or individual biases could result in some states
approving PUA claims differently based on applicants’ race or ethnicity.
Alternatively or in addition, a high volume of potentially fraudulent PUA
claims could result in the appearance of racial and ethnic disparities if
these claims were concentrated in certain groups (i.e., if fraudsters more
frequently selected a certain race).
We were not able to control for or otherwise take into account factors that
might explain PUA benefit receipt rates, due to the aggregated nature of
the state PUA data we obtained. Wisconsin officials stated that they did
not know what the possible causes might be for the racial and ethnic
disparities we found in their state data. Officials stated that their IT system
does not capture the reason for denial of claims, and that they would
need to examine each PUA application manually. Officials stated they are
interested in performing this analysis either fully, or on a sample basis in
the future to gain an understanding of these variances across groups.
Louisiana and North Dakota officials stated that fraudulent claims could
affect the PUA benefit receipt rates observed in their state data. For
example, to the extent individuals submitting fraudulent PUA claims
disproportionately used identities stolen from Black or Hispanic/Latino
individuals relative to a state’s PUA applicants, and the state denied
them, it could appear as though Black or Hispanic/Latino applicants
received PUA benefits at a lower rate.85 However, we did not examine
rates of potential fraud across demographic groups or the rates at which

84As we previously reported, according to DOL, claimants’ attachment to the workforce
can affect their eligibility for regular UI benefits; thus, if certain racial and ethnic groups
tend to have less continuous employment than other groups, they might receive regular UI
benefits at lower rates. See GAO-21-599R.
85North Dakota officials stated that the percentage of Black PUA applicants in the data
they provided us (22.4 percent) may be higher than the actual Black PUA claim filing
population in the state and disproportionate to the number of Black individuals living in the
state, potentially indicating fraudsters claiming PUA disproportionately chose that race.
Although not necessarily reflective of North Dakota, results from the Just Recovery Survey
shared with us by the survey report authors suggest that nationwide, a significantly greater
percentage of Black and Hispanic/Latino individuals applied for PUA than White
individuals.

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GAO-22-104438  Pandemic Unemployment Assistance
states may have initially flagged legitimate claims as potentially fraudulent
across groups.86
Because we cannot determine the causes, the disparities we found in the
three selected states and the national surveys suggest the need for a
more in-depth analysis of benefit equity in PUA, and potentially in other UI
programs. For example, such an analysis could find that disparities in
receipt of PUA were isolated, or it could find that disparities were caused
by broad issues that could also affect the regular UI program (e.g.,
insufficient program controls). DOL has not systematically analyzed or
monitored the extent of racial disparities in the UI system, including PUA,
even though ensuring equitable access to UI is a program priority. For
example, claims data DOL collects from states do not include information
on the number of claimants by demographic group whose claims were
approved and paid or denied. Federal standards for internal control state
that management should use quality information to achieve its
objectives.87
According to DOL, ensuring equitable access to UI is a longstanding
priority for the agency. In 2015 guidance on program access, DOL
emphasized that policies and practices must be carried out in a way that
does not have a disproportionate impact on members of protected
groups.88 The guidance also notes that DOL has a role in providing
technical assistance to states on program access. In addition, after PUA
was created, a January 2021 executive order reiterated the need for

86As part of its Equity Action Plan, released in April 2022, DOL noted that “fraud and
identity verification detection methods may deter or disproportionately flag as ineligible
underserved workers, especially workers of color or individuals who have changed names
or genders.” DOL also stated that one of the goals of its efforts to improve equity in the UI
system is to “revise fraud detection tools to ensure that screening methods do not have
disparate impacts on underserved communities, while still effectively combatting fraud.”
87GAO-14-704G.
88Department of Labor, Employment and Training Administration, State Responsibilities
for Ensuring Access to Unemployment Insurance Benefits, Unemployment Insurance
Program Letter (UIPL) No. 2-16 (Washington, D.C.: Oct. 1, 2015). Guidance issued in
2020 applied this to the CARES Act UI programs; see Department of Labor, Employment
and Training Administration, State Responsibilities for Ensuring Access to Unemployment
Insurance Benefits, Services, and Information, Unemployment Insurance Program Letter
(UIPL) No. 2-16, Change 1 (Washington, D.C.: May 11, 2020).

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GAO-22-104438  Pandemic Unemployment Assistance
federal agencies to support equity in federal programs.89 Subsequently,
DOL issued its UI modernization plan, which emphasizes, among other
things, that the agency is committed to ensuring the UI system “works for
all workers.”90 Among various efforts, the plan focuses on fixing short-
term issues regarding equitable access to UI, and creating a framework
for a more “equitable system for the long term.” In addition, in April 2022,
DOL released its Equity Action Plan in response to the January 2021
executive order. Among other things, the plan outlined existing barriers to
equitable outcomes in the UI system and summarized DOL’s ongoing and
planned actions to advance equity and support marginalized, vulnerable,
and underserved communities.
DOL has initiated some efforts to examine equity issues at the state level.
DOL has noted that states lacked the resources they needed to quickly,
accurately, and equitably manage the volume of claims submitted during
the pandemic. As a result, according to DOL, underrepresented
populations, among others, faced barriers in accessing unemployment
insurance. Using some of the $2 billion in funding made available by the
American Rescue Plan Act of 2021, DOL is deploying teams of experts to
states to help identify process improvements that can address equity,
among other issues.91 According to DOL officials, as of March 2022, 18
states had volunteered to participate in this effort in staggered cohorts. At
that time, the teams of experts had finished gathering information and
provided recommendations to six states, were finalizing their work with six
states, and had begun initial meetings with six states.92 Officials said they
are in the process of using the expert teams’ findings to identify best
practices and solutions for common challenges, which they plan to make
available as a resource for all states. In November 2021, DOL also

89Specifically, Executive Order 13985, signed on January 20, 2021, called on agencies to
assess whether underserved communities and their members face systemic barriers in
accessing benefits and opportunities.
90Department of Labor, “Fact Sheet: Unemployment Insurance Modernization: American
Rescue Plan Act Funding for Timely, Accurate and Equitable Payment in Unemployment
Compensation Programs” (Washington, D.C.: Aug. 11, 2021).
91The American Rescue Plan Act of 2021 appropriated $2 billion for DOL to detect and
prevent fraud, promote equitable access, and ensure the timely payment of UI benefits.
Pub. L. No. 117-2, § 9032, 135 Stat. 4, 121.
92For more information, see GAO-22-105397.

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GAO-22-104438  Pandemic Unemployment Assistance
announced the availability of up to $200 million in grant funding for states
to implement the expert teams’ recommendations.93
DOL is also providing a total of up to $260 million in grants to states to
promote equitable access to UI.94 According to DOL guidance, states
have broad flexibility to determine what activities to support with grant
funds, provided the activities will improve equity in the UI program.95 In its
guidance, DOL noted some examples of activities, including improving
claimant outreach and expanding and improving collection of
demographic data. DOL’s guidance also details that states must identify
and report progress on specific outcome measures for their grant-funded
activities. At the end of January 2022, DOL officials said that 49 of 53
states and territories had applied for grants, and that DOL was in the
process of reviewing submissions and working with states to ensure their
applications would meet the requirements for approval. As of May 2,
2022, DOL had awarded grants totaling about $56.5 million to the District
of Columbia and 11 states: Alabama, Idaho, Indiana, Kentucky, Missouri,
New Mexico, Oregon, Pennsylvania, Utah, Virginia, and Washington.
According to DOL, the agency has also begun work on its own analyses
of equity in the UI system, though on a limited scale thus far. Officials
stated that DOL has begun working with several selected states to
establish partnerships for sharing UI claims records and wage data with
DOL’s Chief Evaluation Office to analyze equity-related indicators,
including UI application, denial, and recipiency rates by demographic
groups. In its Equity Action Plan, released in April 2022, DOL noted that it
plans to recruit more states to participate throughout 2022 and 2023.
Though the effort is in its early stages, DOL stated that this analysis is

93See Department of Labor, Employment and Training Administration, Grant Opportunity
to Support States Following a Consultative Assessment for Fraud Detection and
Prevention, Promoting Equitable Access, and Ensuring the Timely Payment of Benefits,
Including Backlog Reduction, for All Unemployment Compensation (UC) Programs,
Unemployment Insurance Program Letter (UIPL) No. 2-22 (Washington, D.C.: Nov. 2,
2021).
94In its guidance to states announcing the grants, DOL referred to our management report
that provided preliminary information to DOL about potential racial and ethnic disparities in
the receipt of UI benefits in some states during the COVID-19 pandemic. See
GAO-21-599R.
95Department of Labor, Employment and Training Administration, Grant Opportunity for
Promoting Equitable Access to Unemployment Compensation (UC) Programs,
Unemployment Insurance Program Letter (UIPL) No. 23-21 (Washington, D.C.: Aug. 17,
2021).

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GAO-22-104438  Pandemic Unemployment Assistance
intended to test for demographic differences within and across states,
including by race and ethnicity, which can inform efforts to improve
program administration and outreach.
In addition to these efforts, DOL has also made available up to $15 million
in total grant funding for selected state UI agencies to form partnerships
with community organizations to help underserved workers learn about,
apply for, and if eligible, receive UI benefits (referred to as navigator
programs). It also launched a grant competition for an academic
institution to create a new center to conduct and disseminate research
related to the UI system, with a focus on equity in program administration
and outcomes.96
The technical assistance and grant funds DOL is providing to states, and
the planned effort to analyze claimant data in several states for
differences in equity-related indicators across demographic groups, are
positive steps towards achieving equity in the UI system. However, DOL
currently lacks comprehensive information about the extent of inequities
that may have occurred in the PUA program, and whether the underlying
causes suggest systemic challenges. Without this information, DOL may
be unable to determine whether states’ efforts to improve equity in the UI
system are addressing the most critical issues, including barriers
individuals face in applying and variations in benefit receipt rates among
eligible applicants. Addressing these issues will be important for DOL to
meet its goals for UI modernization and its longstanding priority of
ensuring equitable access to UI.
The scale of the COVID-19 pandemic and resulting unemployment placed
immense strain on the UI system. Despite challenges states faced
implementing the new PUA program amid public urgency, unprecedented
demand for benefits, and an influx of potentially fraudulent claims,
contingent workers we spoke with said that PUA was critical to meeting
their financial needs. Now that the PUA program has ended, however,
unemployment support is no longer available to a large population of U.S.
workers whose financial needs after a job loss are similar to those in
traditional employment arrangements.

96For more information about the navigator program grants, see Department of Labor,
Grant Opportunity for States to Participate in the American Rescue Plan Act (ARPA)
Unemployment Insurance (UI) Navigator Program, UIPL 11-22 (Washington, D.C.: Jan.
31, 2022). According to the guidance, states may apply for up to $3 million in funding.
Conclusions

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GAO-22-104438  Pandemic Unemployment Assistance
There are certain aspects of the UI system that may be challenging to
apply to contingent and self-employed workers during normal economic
times, such as determining when unemployment is involuntary for these
workers outside of an emergency and working with state authorities to
redefine benefit eligibility. However, without assessing whether there are
systematic ways to support these workers during periods of involuntary
unemployment, DOL cannot realize its vision for a modernized UI system
that provides a lifeline to all workers. More workers may miss out on this
vital lifeline if short term, intermittent, or contract work become more
common employment arrangements. In addition, without proactive
consideration about how best to support these workers in normal
economic times, states may again face challenges, including greater
fraud risks, if called on to implement temporary or disaster benefit
programs that include these workers. DOL is uniquely positioned to assist
the Congress and other policymakers by identifying options and providing
insight about the benefits, risks, and feasibility of those options, given the
agency’s oversight of the UI system and its responsibility to ensure high
performance of UI programs. According to DOL, it has historically
provided technical assistance to Congress about UI legislative proposals
and comprehensive UI reform and thus could do so again.
The racial and ethnic disparities we found in claimants’ receipt of PUA in
selected states suggest the need for more in-depth analysis of benefit
equity in the program. Various factors could explain the disparities, and
the data we analyzed did not allow us to examine potential causes. If the
underlying causes of inequities in PUA receipt are systemic or indicative
of insufficient program integrity controls, they may also affect the regular
UI program. DOL has begun some efforts to examine and address UI
equity issues at the state level and to modernize UI. However, without
comprehensive information about the extent or causes of inequities in
PUA benefit receipt and in the UI system nationwide, DOL may be
challenged to effectively monitor state practices—including how a state
reviews and determines claimant eligibility and whether it has barriers that
affect certain groups’ ability to access benefits—or meet its goals of
advancing racial, geographic, and gender equity in the UI system.
We are making the following two recommendations to DOL:
The Secretary of Labor should study and advise the Congress and other
policymakers on the costs, benefits, and risks of various options to
systematically support self-employed and contingent workers during
periods of involuntary unemployment outside of declared disasters,
Recommendations for
Executive Action

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GAO-22-104438  Pandemic Unemployment Assistance
including considering options’ feasibility and approach to fraud
prevention. (Recommendation 1)
The Secretary of Labor should ensure the Office of Unemployment
Insurance examines and publicly reports on the extent of and potential
causes of racial and ethnic inequities in the receipt of Pandemic
Unemployment Assistance benefits, as part of the agency’s efforts to
modernize UI and improve equity in the system. The report should also
address whether there is a need to examine racial, ethnic, or other
inequities in regular UI benefit receipt, based on the PUA findings.
(Recommendation 2)
We provided a draft of this report to DOL for review and comment. We
also provided relevant excerpts of this report to officials from Arizona,
Louisiana, New York, North Dakota, and Wisconsin for review and
comment. We received written comments from DOL that are reproduced
in appendix IV and summarized below. DOL and each state provided
technical comments, which we incorporated, as appropriate.
DOL agreed with our recommendation to study and advise the Congress
and other policymakers on the costs, benefits, and risks of various
options to systematically support self-employed and contingent workers
during periods of involuntary unemployment.
DOL partially agreed with our recommendation to examine and report on
the extent of and potential causes of racial and ethnic inequities in the
receipt of PUA benefits. DOL reiterated the importance of equitable
access to UI and outlined its various efforts to address equity in the
regular UI program. These efforts, which we discuss in more detail in our
report, include establishing partnerships with selected states to obtain
data to analyze measures of equity, awarding grants to states to support
activities that promote equitable access to UI, and deploying teams of
experts to states to identify actionable steps to improve equitable access
to UI. DOL agreed that there are aspects of PUA worth examining to
consider ways to structure future programs. However, DOL stated that
enhancing demographic data collection in the permanent UI programs to
inform actions to improve equity is a higher priority than performing a
complete retrospective review of the PUA program, which is no longer
operating.
We appreciate DOL’s stated commitment to improving equity in UI
programs, and to considering the insights in our report as it advances its
ongoing and planned efforts. We are eager to see the results of these
Agency Comments
and Our Evaluation

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GAO-22-104438  Pandemic Unemployment Assistance
efforts, and we agree that a retrospective review of equity issues in the
PUA program should not displace this important work. However, we
maintain that examining and reporting on the extent of and potential
causes of racial and ethnic inequities in the receipt of PUA benefits would
provide valuable information for DOL and policymakers. For example,
given the uniqueness of the PUA program—including the claimant
population it covered and their less-traditional employment
documentation—the causes of disparities in PUA benefit receipt may be
different from the issues affecting equitable access to regular UI benefits.
Understanding the extent and potential causes of disparities in the PUA
program could help safeguard against such disparities in any future
temporary programs that expand eligibility. Further, this understanding
could inform DOL’s consideration of options to systematically support
unemployed contingent and self-employed workers in response to our
first recommendation.
Recognizing that DOL has valuable efforts under way, we encourage
DOL to pursue such an analysis in tandem with these ongoing efforts. For
example, DOL could consider obtaining and analyzing PUA data from the
states with which DOL is establishing data partnerships, and then
assessing the need for further study based on initial findings.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Labor, and other interested parties. In
addition, the report is available at no charge on the GAO website at
https://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-4769 or costat@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix V.

Thomas Costa
Director, Education, Workforce, and Income Security

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GAO-22-104438  Pandemic Unemployment Assistance
List of Committees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Robert C. “Bobby” Scott
Chairman
The Honorable Virginia Foxx
Ranking Member
Committee on Education and Labor
House of Representatives

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GAO-22-104438  Pandemic Unemployment Assistance
The Honorable Frank Pallone, Jr.
Chair
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
The Honorable Danny K. Davis
Chairman
The Honorable Jackie Walorski
Republican Leader
Subcommittee on Worker and Family Support
Committee on Ways and Means
House of Representatives

Appendix I: Objectives, Scope, and
Methodology

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The objectives of this review were to examine (1) how state
implementation of the Pandemic Unemployment Assistance (PUA)
program varied in terms of timing and volume of claims and benefits; (2)
how the pandemic affected contingent workers in selected states and to
what extent the unemployment insurance (UI) system assisted them; and
(3) how PUA benefit receipt varied by demographic characteristics in
selected states, and to what extent the Department of Labor (DOL) has
examined variation systemwide. Determining the presence of improper
payments and fraud in PUA was outside the scope of this work, but is
being addressed in other reviews.
Throughout the report we use the term “contingent workers” to refer
broadly to workers without traditional employment arrangements.
Definitions of contingent work vary widely, focusing on the temporary
nature or precariousness of a work arrangement, the lack of a traditional
employer-employee relationship, or other concepts. We use a broad
concept of contingent work to be inclusive of many different types of
workers, such as those with temporary or gig employment, independent
contractors, and self-employed and other workers without traditional
employer-employee relationships.
The PUA program was designed to cover workers who were not eligible
for regular UI, such as certain gig economy workers, self-employed
individuals, and others with limited recent work history. Not all PUA
claimants were contingent workers, such as those who had a traditional
employment arrangement but insufficient work history to qualify for
regular UI. In addition, not all contingent workers were eligible for PUA,
such as gig workers who also had a part-time job with a traditional
employer that made them eligible for regular UI. However, the populations
of PUA claimants and the broad concept of contingent workers we use
likely overlap substantially.
To examine state implementation of the PUA program, we reviewed
federal agency documents, analyzed PUA data that states and territories
reported to DOL, and interviewed officials from DOL and the DOL Office
of Inspector General (OIG). We also met with officials from state
workforce agencies in five selected states—Arizona, Louisiana, New
York, North Dakota, and Wisconsin—to obtain nongeneralizable
information about their states’ experiences implementing the PUA
program and any challenges they faced. We selected these five states to
include variety across several characteristics, including the volume of
PUA claims, the timing of PUA implementation, and the percentage of the
overall workforce that was self-employed. We also considered other
Appendix I: Objectives, Scope, and
Methodology
PUA Implementation

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
factors in identifying a diverse selection of states, such as experience with
Disaster Unemployment Assistance (DUA), geographic dispersion, and
whether states experienced high COVID-19 case rates early in the
pandemic. We met with various state workforce agency officials in these
five states, including officials who were familiar with PUA program
implementation and administration, officials who worked with PUA
program data, and officials who were familiar with state agency
interactions with PUA claimants.
The PUA implementation experiences of these five selected states are
not generalizable to all states and territories. For additional context about
PUA implementation, we also met with national organizations familiar with
state implementation of the PUA program and claimant experiences,
including the National Association of State Workforce Agencies, the
National Employment Law Project, and the Freelancers Union, as well as
at least one worker advocacy organization in each of our five selected
states.
PUA first payment dates: To analyze the timing of PUA implementation
nationwide, we obtained from DOL the dates that states and territories
made their first PUA payments. DOL collected these first payment dates
from states and territories through its Employment and Training
Administration’s (ETA) regional offices, according to officials. We did not
independently verify these dates with states and territories.
DOL data on PUA claims: To analyze the volume of PUA claims,
benefits paid, and related issues, we used data from DOL’s ETA 902P
data file. States and territories submit PUA data to DOL on a monthly
basis, including total numbers of initial applications filed, first payments
made, weeks claimed, weeks compensated, and compensation amounts.
DOL compiles these data in the ETA 902P data file. Some states and
territories have not submitted data for certain months or certain data
fields. States and territories, generally, may submit adjusted data for prior
months at any time for up to three years following the reporting period,
according to DOL officials. Thus, these data are current as of the date
they are downloaded from DOL’s data website. We obtained the ETA
902P data file on January 28, 2022.
We aggregated these data across states and territories and across
months to examine PUA claims volumes, compensation paid, and
approximate numbers of individuals paid (i.e., first payments) nationwide

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
and by selected states.1 We also calculated summary information, such
as
•
average weekly compensation by dividing total compensation
amounts by total weeks compensated;
•
payment rate by dividing total first payments made by total initial
applications submitted; and
•
average duration that claimants received PUA by dividing total weeks
compensated by total first payments made (an approximation of the
number of individuals who received PUA).
Some states and territories did not report data in certain months or for
certain data elements. In addition, we observed some data anomalies in
some states’ and territories’ data. For some of our analyses, such as
those examining total claims volume or total compensation paid, we
included all states and territories’ data. In these cases, missing data and
anomalies may introduce some imprecision in the analyses, but we
determined the data were sufficiently reliable to reflect nationwide
demand for benefits, dollars paid, and claims processing workloads. For
other analyses, such as those examining variation across states or
situations in specific selected states, we excluded states and territories
with substantial amounts of missing data or data anomalies. Specifically,
for these analyses we generally excluded states and territories if:
•
they were missing key data elements for any months between June
2020 and June 2021 (by June 2020 almost all states and territories
had begun making PUA payments and after June 2021 some states
began withdrawing from the PUA program);
•
they reported more total first payments made than initial applications
received;
•
they reported more total weeks compensated than weeks claimed;
and
•
their reported data showed an average number of weeks
compensated per first payment that was less than 8 weeks or more
than 70 weeks (i.e., more than the maximum number of weeks from
March 2020 through June 2021)—although the length of time

1First payments approximate the number of individuals who received PUA because each
recipient, generally, receives only one first payment.

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
individual claimants received PUA certainly varied, an overall average
length beyond these extremes suggests a data anomaly.
We conducted a data reliability assessment of the data elements used in
our report from the ETA 902P data file. We reviewed technical
documentation about the data file and interviewed DOL officials about the
data file and specific data elements.2 We also spoke with officials in our
selected states about their reporting of PUA monthly data to DOL. We
determined that the variables we used were sufficiently reliable for the
purposes of this report.
To examine how the pandemic affected contingent workers in selected
states and how the UI system assisted them, we conducted eight
nongeneralizable discussion groups with contingent workers who
reported applying for PUA in two of our selected states: Arizona and New
York. We selected these states because they both experienced a high
volume of PUA claims but differed in when they began making PUA
payments. Specifically, New York was one of the first states to start
making PUA payments, and Arizona was one of the later states.
We contracted with a vendor to recruit and screen discussion group
participants, host the sessions virtually, and transcribe the sessions. To
recruit discussion group participants, we provided selection criteria to the
contractor. Specifically, we stipulated that potential participants must have
been contingent workers prior to their loss of employment or reduction in
work. We defined contingent workers as those workers who received their
primary individual income as an independent contractor, freelancer, gig
worker, tech-based app worker (e.g., rideshare apps), and/or self-
employed worker. In addition, we specified that potential participants must
have experienced a loss of employment or reduction in work due to the
pandemic, and must have applied for PUA benefits in Arizona or New
York. The contractor then contacted and screened potential participants.
In selecting discussion group participants, we considered demographic
characteristics, such as race, ethnicity, gender, and age, with the goal of
achieving diversity across these characteristics, to the extent possible.
We conducted these discussion group sessions virtually from May
through July 2021.

2According to DOL officials, certain data elements in the ETA 902P data file are generally
not reliable, including the state-reported data on the number of claims determined eligible
and the data for self-employed claimants. We did not use these data in our analyses or in
this report.
Contingent Worker
Experiences

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
We conducted four discussion groups in each state, including three
groups with workers who reported receiving PUA benefits and one group
with workers who reported applying for but not receiving PUA benefits.
Across the 8 groups, in total, we spoke with 48 contingent workers who
reported applying for PUA benefits. Of these, 37 contingent workers
reported receiving benefits, and 11 reported not receiving benefits.
Discussions were facilitated by a moderator who used a standardized list
of questions to encourage participants to share their thoughts and
experiences. During these discussion groups, we asked participants
about the reasons they lost employment or experienced reduced work,
and whether they returned to their prior work or obtained new work. We
also asked participants about their experiences applying for PUA benefits,
including what worked well for them, and what they found challenging
about the process. In the groups with workers who received PUA
benefits, we asked participants about their experiences certifying for and
receiving benefits, and whether the benefits they received were sufficient
to meet their financial needs. We also polled participants about how long
they waited between losing work and receiving PUA, and how long they
received PUA overall. In the groups with workers who did not receive
PUA benefits, we asked participants about the reason they did not
receive benefits, and how, if it all, not receiving benefits affected them
financially or in other ways. In all of the groups, we also asked
participants whether the pandemic affected them in other ways.
We conducted a content analysis of the eight discussion group transcripts
to identify similarities and differences across participants’ responses to
each discussion question, by subtopic. Our method of organization for the
content analysis was to develop codes that reflected objective subtopics
of each discussion group question. We used these subtopic codes to
organize participants’ responses for further analysis. For example, as
noted above, we asked participants what worked well and what was
challenging in applying for PUA benefits, submitting weekly certifications,
and receiving benefits. For that question, we analyzed participants’
responses by two subtopics: what worked well and what was challenging.
We identified key themes across responses, as well as illustrative
examples of these key themes. Given that participants shared a wide
variety of experiences, we also identified examples that were mentioned
less frequently, but that illustrated the variation in responses across
participants. This content analysis was conducted by one analyst and
verified by a second analyst. These two analysts discussed any
differences of opinion and reached agreement on the key themes and

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
illustrative examples that best represented the similarities and differences
in the experiences shared by discussion group participants.
Because the discussion groups were conducted in two states and
included 48 contingent workers, the information we collected is not
generalizable to all states or to all contingent workers or PUA applicants
in the two states. We generally characterized the frequency of workers’
experiences in broad terms such as “a few,” “some,” and “many” because
the open-ended format of most discussion questions and time constraints
meant that participants may not have discussed all aspects of their
experiences. Thus, exact counts of worker experiences could be
misleading. We generally consider “a few” to indicate two or more
workers, “some” to indicate four or more workers, and “many” to indicate
more than half of the group of workers being discussed. However, for
multiple-choice poll questions we asked workers, we present exact counts
of responses. For additional context about contingent worker experiences
and some of the challenges workers shared with us, we used information
from our interviews with officials from the state workforce agencies and
worker advocacy organizations in our selected states. We also used
results from some of our analyses of DOL’s monthly PUA data, as
previously discussed.
To examine how PUA benefit receipt varied by demographic
characteristics in selected states, we primarily analyzed aggregated PUA
claimant data obtained from our five selected states: Arizona, Louisiana,
New York, North Dakota, and Wisconsin. We obtained data from our
selected states on numbers of unique individuals claiming and receiving
benefits (because DOL’s monthly PUA data do not include this type of
information). Specifically, we obtained counts by race and gender of the
number of unique individuals who submitted initial claims for PUA benefits
at any time during a specified period of the pandemic, and the number of
unique individuals who received PUA benefits at any time during the
same period. We also obtained the following data elements by month,
racial and ethnic group, and gender:
•
number of individuals who submitted initial claims for PUA, and
•
number of individuals who submitted continued claims for PUA.
As part of our assessment of the reliability of these state data, we
observed that Arizona’s data included unreasonably high numbers of
individuals submitting initial claims across multiple months. We also
observed spikes in the number of individuals submitting PUA initial claims
Variation in PUA Benefit
Receipt

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
in Louisiana’s data in November 2020 and in New York’s data in January,
February, and March 2021. According to state officials, in all of these
cases, the inordinately large numbers and spikes represented influxes of
potentially fraudulent claims. Including large numbers of potentially
fraudulent claims could distort comparisons of benefit receipt rates
between groups, especially if these claims were concentrated in certain
groups. Thus, for Louisiana and New York, we analyzed PUA claimant
numbers during the period prior to the influx of the potentially fraudulent
claims in November 2020 and January 2021, respectively. However, we
determined the data we obtained from Arizona were not sufficiently
reliable for the purposes of our analyses due to the substantial numbers
of potentially fraudulent PUA claims across multiple months.
The final version of the data we obtained and analyzed from the four
selected states with sufficiently reliable data covered the periods:
•
Louisiana: January 2020 through October 2020;
•
New York: January 2020 through December 2020;
•
North Dakota: January 2020 through April 2021; and
•
Wisconsin: January 2020 through April 2021.3
For each of these four states, we calculated PUA benefit receipt rates by
dividing the number of unique individuals who received PUA benefits at
any time during the analysis period by the number of unique individuals
who submitted initial claims at any time during the period.4 We analyzed
the PUA benefit receipt rates for each state overall, by gender, and by

3For each state, we requested data starting in January 2020 because the PUA program
allowed retroactive claims for weeks of unemployment beginning on or after January 27,
2020. However, for our analyses, we refer to the period covered as the pandemic through
each state’s ending month. April 2021 is the latest ending month for any state due to the
timing of the final data requests. We received final data from Arizona on July 22, 2021,
Louisiana on August 10, 2021, New York on August 12, 2021, North Dakota on July 16,
2021, and Wisconsin on June 3, 2021.
4Submitting an initial claim for PUA is synonymous with applying for PUA. According to
DOL, an initial claim is filed by an unemployed individual after a separation to request a
determination of basic eligibility for the program. In Louisiana’s data, individuals who
selected multiple races are counted in each group they selected. As a result, some people
get counted multiple times and the total number of individuals across all race groups is
larger than the actual total number of unique individuals submitting initial PUA claims and
receiving PUA benefits (about 2 percent larger for each data element). Because the over-
counts are relatively small, the team determined the data were sufficiently reliable for the
purposes of our analysis.

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
racial and ethnic group.5 To summarize our findings, we established the
following definitions to characterize differences between groups:
•
Relatively similar: Differences of less than 3 percentage points
•
Relatively small differences: Differences of between 3 and 10
percentage points
•
Substantial differences: Differences of more than 10 percentage
points
Our analysis is generalizable to PUA claimants in the four selected states
and for the periods we analyzed, but not to other states or periods. For
additional context on overall PUA payment rates by state, nationwide, we
also used results from our analyses of DOL’s monthly PUA data, as
previously discussed.
We supplemented our analysis of state data with results from two national
surveys on UI benefit receipt. Specifically, we analyzed national data from
the Census Bureau’s (Census) COVID-19 Household Pulse Survey
(Household Pulse Survey), phase 3.6 We conducted our analysis of the
Household Pulse Survey as part of a previously published management

5We do not present results for individuals of other/unknown race or ethnicity because the
mix of individuals who did not select a race/ethnicity or selected more than one means the
results cannot be meaningfully interpreted. This group represented about 7 percent of
PUA applicants in the Louisiana data, 23 percent in the New York data, 2 percent in the
North Dakota data, and 12 percent in the Wisconsin data.
6The Household Pulse Survey, an experimental data product, is an interagency federal
statistical rapid response survey to measure household experiences during the COVID-19
pandemic. The survey was conducted by Census in partnership with seven other agencies
from the Federal Statistical System. Phase 3 surveys were conducted on a biweekly basis
from October 28, 2020, through March 29, 2021 (a total of 10 surveys). National-level
weighted response rates for the phase 3 biweekly surveys ranged from 5.3 to 7.5 percent.
For example, for the final phase 3 survey (week 27), 1,040,111 housing units were
randomly sampled and 77,104 respondents answered the survey questionnaire (the
national level weighted response rate was 7.2 percent). In March 2021, Census published
the results of a nonresponse bias analysis that identified evidence of response patterns
that could result in biased estimates. The report also concluded that Census found
evidence that its adjusted sampling weights help mitigate, though may not completely
eliminate, nonresponse bias in the final survey estimates. Census Bureau, Nonresponse
Bias Report for the 2020 Household Pulse Survey (Mar. 24, 2021).

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
report.7 As we reported, the Household Pulse Survey asked respondents
whether they had applied for UI benefits since March 13, 2020, and if so,
whether they had received UI benefits. Because the questions refer
broadly to UI benefits, they likely cover regular UI, PUA, and the other
temporary UI programs. To determine whether there were differences in
the receipt of benefits by race and ethnicity, we calculated the percentage
of UI applicants who reported receiving UI benefits by racial and ethnic
group, and tested differences for statistical significance.
We also analyzed published findings and additional analysis results
shared with us from the Just Recovery Survey, which was administered
during the pandemic by the research firm SSRS.8 Although we did not
independently analyze this survey’s data, we interviewed officials who
were responsible for administering the survey about its methods and
results, and determined that their findings were sufficiently reliable for the
purposes of our report. The additional analysis results were shared with
us by the survey report’s authors.
We conducted a data reliability assessment of the data elements we
obtained from our selected states and the data elements we used from
the Household Pulse Survey. For the state data, we interviewed officials
in our selected states about their data systems and also sent them
clarification questions about specific data elements they provided during
our preliminary analyses and reliability assessment. For the Household
Pulse Survey, we reviewed survey documentation, Census reports on the
survey data’s accuracy and potential nonresponse bias in the data, and
written responses to questions we sent to Census. We determined that
the variables we used from the data obtained from Louisiana, New York,

7For additional methodological details, see GAO, Management Report: Preliminary
Information on Potential Racial and Ethnic Disparities in the Receipt of Unemployment
Insurance Benefits during the COVID-19 Pandemic, GAO-21-599R (Washington, D.C.:
June 17, 2021).
8The survey research firm SSRS, in coordination with the Cornell Survey Research
Institute, administered the Just Recovery Survey in September and October of 2020. The
survey used a nationally representative random sample (n=3,100), with an oversample of
Black and Hispanic/Latino respondents; 5,382 panelists were invited to participate in the
survey. The report notes that survey weights were applied to provide estimates
representative of the U.S. adult population, 18 years of age and older, in the labor market,
and with internet access. Color of Change, National Employment Law Project, Time’s Up
Foundation, and The Worker Institute at Cornell ILR, Foundations for a Just and Inclusive
Recovery: Economic Security, Health and Safety, and Agency and Voice in the COVID-19
Era (National Employment Law Project, Feb. 3, 2021).

Appendix I: Objectives, Scope, and
Methodology

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GAO-22-104438  Pandemic Unemployment Assistance
North Dakota, and Wisconsin and from the Household Pulse Survey were
sufficiently reliable for the purposes of this report.
Related to multiple objectives, we interviewed DOL officials about the
agency’s activities related to PUA program implementation and
administration, as well as ongoing and planned activities analyzing the
PUA program, modernizing the UI system, and supporting equity across
UI programs. For all objectives, we also reviewed relevant federal laws
and regulations.
We conducted this performance audit from July 2020 to June 2022 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.

Appendix II: Counts of Pandemic
Unemployment Assistance (PUA) Continued
Claims versus Individuals Claiming Benefits

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In November 2020, we reported that the number of continued claims—
claims filed by individuals who remain unemployed—reported by states
during the pandemic does not approximate the number of claimants
because individuals sometimes submitted continued claims for multiple
prior weeks of unemployment at a time, and each benefit week is counted
as a separate claim.1 As we reported, multi-week claims for PUA were
especially prevalent because individuals accumulated weeks of
unemployment as states implemented the new program—especially given
claimants’ ability to claim benefits retroactively—and as states faced
claims processing backlogs. In that report, using claims data reported by
states to the Department of Labor (DOL), we estimated that across 20
selected states, the number of PUA continued claims submitted through
June 27, 2020, exceeded by almost 20 million the cumulative number of
individuals who had submitted an initial claim (an upper bound estimate of
individuals who could potentially claim benefits each week).2 However,
due to the nature of the data, this was a broad estimate.
Using aggregated PUA claimant data we obtained for this report, we have
refined this analysis for three selected states, and observed a similar
pattern of PUA continued claims numbers far exceeding the number of

1GAO, COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal
Response, GAO-21-191 (Washington, D.C.: Nov. 30, 2020). Prior to the pandemic,
according to DOL officials, the number of continued claims approximated the number of
people claiming benefits because each week individuals typically filed a claim for just the
previous one week of continued unemployment.
2As we reported, we selected states from among the 26 that, at the time, had begun
reporting PUA initial claims to DOL within 1 week of the implementation date they reported
to DOL. We excluded several of these states due to data reliability concerns. We
calculated the states’ total PUA initial claims submitted, at that time, from the beginning of
the program through the week ending June 27, 2020, and compared that to the number of
PUA continued claims submitted each week. Because individuals cannot submit a
continued claim without having first been counted as an initial claim, the cumulative count
of initial claims submitted represents an upper bound estimate of the number of individuals
who could submit a continued claim in any period. The actual number of individuals would
be lower than this estimate because some initial claims are denied during eligibility
reviews and for other reasons, and some individuals exit the PUA program each week due
to obtaining employment or for other reasons. Because initial claim denials and program
exits occur each week, an estimate of cumulative initial claims that does not account for
these reductions is less accurate the more weeks it includes—i.e., the estimated count is
increasingly higher than reality each week, thus underestimating the difference with the
number of continued claims. For that reason, our analysis only ran through the week
ending June 27, 2020. See GAO-21-191.
Appendix II: Counts of Pandemic
Unemployment Assistance (PUA) Continued
Claims versus Individuals Claiming Benefits

Appendix II: Counts of Pandemic
Unemployment Assistance (PUA) Continued
Claims versus Individuals Claiming Benefits

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GAO-22-104438  Pandemic Unemployment Assistance
individuals submitting claims.3 For example, in August 2020, the average
number of PUA continued claims submitted per week exceeded the
number of unique individuals submitting PUA claims that month by about
34 percent in New York, 41 percent in North Dakota, and 86 percent in
Wisconsin (see fig. 6).4 These illustrative examples depict the differences
between counts of PUA claims and claimants with greater precision than
the rougher estimate in our November report because we used counts of
individuals submitting PUA claims instead of having to use cumulative
initial claims as an approximation of people.

3We excluded Arizona and Louisiana from this analysis because each state experienced
spikes in potentially fraudulent claims before the end of 2020 and thus the data are not
reliable for the purposes of this analysis.
4We compared the number of unique individuals submitting continued claims each month
to the average continued claims submitted per week from DOL’s ETA 902P data file,
which we obtained on January 28, 2022 (states may submit adjusted data to DOL over
time). We calculated average continued claims submitted per week by dividing the total
number of claims in the month by the number of weeks in that month (e.g., for months with
30 days, we divided by 4.29). We used this comparison as a conservative estimate of the
extent to which counts of continued claims each week exceed the number of individuals
submitting those claims. If some individuals do not submit a continued claim in every week
of a month (which is likely to be the case), then we would expect the average claims
submitted per week to be less than the number of individuals submitting those claims.
Thus, the count of claims submitted would exceed that expectation by even more than our
conservative comparison.

Appendix II: Counts of Pandemic
Unemployment Assistance (PUA) Continued
Claims versus Individuals Claiming Benefits

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GAO-22-104438  Pandemic Unemployment Assistance
Figure 6: Comparison of Average Number of PUA Continued Claims Submitted Per Week and Number of Unique Individuals
Submitting PUA Claims during the Month

Notes: Average Pandemic Unemployment Assistance (PUA) claims submitted per week are from the
Department of Labor’s (DOL) ETA 902P data file, which we obtained on January 28, 2022. States
may submit adjusted data to DOL over time. We calculated average PUA claims submitted per week
by dividing the total number of PUA weeks claimed (i.e., continued claims) in the month by the
number of weeks in that month (e.g., for months with 30 days, we divided by 4.29). We used this
comparison as a conservative estimate of the extent to which counts of continued claims each week
exceed the number of individuals submitting those claims. We obtained data on the number of
individuals submitting PUA claims each month from New York, North Dakota, and Wisconsin.

Appendix III: Summary of Pandemic
Unemployment Assistance (PUA) Data
Reported to the Department of Labor (DOL) by
Selected States through June 2021

Page 65
GAO-22-104438  Pandemic Unemployment Assistance
The table below displays summary information about PUA claims and
payments for selected states, based on data they submitted to DOL. We
calculated, by state, total PUA applications received, total first payments
made, payment rate, total compensation paid, total weeks paid, average
amount paid per week, and weeks paid per first payment. We limited our
analysis to the 40 states we determined to have sufficiently reliable data
for this purpose and, to keep the data comparable, limited the period of
analysis to go through June 2021, prior to some states’ early termination
of the program.
Table 3: Selected States’ PUA Applications, First Payments, and Compensation through June 2021, According to Data
Reported by States to DOL
State
Total initial
applications
Total first
payments
made
Payment
ratea Total amount paid
Total weeks
paid
Average
amount
paid per
weekb
Minimum
weekly
compensationc
Weeks
paid per
first
paymentd
Alabama
260,102
132,854
51%
$342,454,019
2,654,923
$129
$113
20
Alaska
51,150
16,022
31%
$72,979,802
392,312
$186
$133
24
Arizona
4,345,223
1,394,983
32%
$2,791,883,503
18,723,477
$149
$117
13
Arkansas
270,055
82,204
30%
$459,728,583
3,371,467
$136
$132
41
California
4,866,321
2,589,038
53%
$27,288,172,207
101,195,736
$270
$167
39
Colorado
1,329,740
386,051
29%
$1,531,272,849
5,132,361
$298
$223
13
Delaware
17,218
9,115
53%
$64,791,043
378,372
$171
$133
42
Hawaii
182,412
57,190
31%
$671,845,354
2,397,011
$280
$263
42
Idaho
86,687
52,175
60%
$94,904,339
499,020
$190
$168
10
Illinois
740,439
294,081
40%
$3,479,323,699
14,623,847
$238
$198
50
Indiana
691,499
299,076
43%
$1,298,530,651
7,233,059
$180
$149
24
Iowa
98,863
38,926
39%
$259,833,617
1,089,524
$238
$203
28
Kansas
282,475
29,214
10%
$252,671,337
774,389
$326
$192
27
Louisiana
476,121
302,227
63%
$934,312,019
7,524,552
$124
$107
25
Maryland
869,654
522,207
60%
$3,351,516,908
13,319,126
$252
$176
26
Massachusetts
984,279
631,681
64%
$5,224,853,991
17,709,893
$295
$267
28
Michigan
1,782,312
996,048
56%
$6,275,630,198
29,078,945
$216
$160
29
Minnesota
112,695
103,685
92%
$888,045,473
3,081,476
$288
$234
30
Mississippi
321,567
185,201
58%
$406,304,387
3,596,093
$113
$106
19
Missouri
150,051
144,882
97%
$529,814,701
3,509,866
$151
$133
24
Montana
94,567
24,532
26%
$149,306,252
797,930
$187
$184
33
Nebraska
63,189
22,156
35%
$81,911,766
443,741
$185
$173
20
Nevada
1,471,538
193,720
13%
$1,155,365,017
4,667,035
$248
$181
24
New Jersey
800,024
593,233
74%
$5,403,450,376
20,375,078
$265
$230
34
Appendix III: Summary of Pandemic
Unemployment Assistance (PUA) Data
Reported to the Department of Labor (DOL)
by Selected States through June 2021

Appendix III: Summary of Pandemic
Unemployment Assistance (PUA) Data
Reported to the Department of Labor (DOL) by
Selected States through June 2021

Page 66
GAO-22-104438  Pandemic Unemployment Assistance
State
Total initial
applications
Total first
payments
made
Payment
ratea Total amount paid
Total weeks
paid
Average
amount
paid per
weekb
Minimum
weekly
compensationc
Weeks
paid per
first
paymentd
New Mexico
205,516
75,061
37%
$417,780,038
2,168,073
$193
$169
29
New York
2,878,819
1,950,612
68%
$15,996,395,098
71,713,718
$223
$178
37
North Carolina
502,777
268,930
53%
$1,213,532,572
8,396,506
$145
$132
31
North Dakota
37,670
15,851
42%
$70,506,873
261,865
$269
$228
17
Ohio
2,481,918
877,150
35%
$3,135,828,507
13,991,461
$224
$189
16
Oklahoma
120,808
39,508
33%
$242,615,224
1,218,234
$199
$189
31
Oregon
346,410
115,293
33%
$887,655,657
4,124,322
$215
$205
36
Pennsylvania
2,402,228
1,297,421
54%
$9,606,574,757
39,283,873
$245
$195
30
Rhode Island
357,018
134,823
38%
$591,293,870
2,446,931
$242
$183
18
Tennessee
280,546
142,276
51%
$629,757,733
4,214,254
$149
$120
30
Texas
1,190,185
765,499
64%
$5,602,108,328
26,816,085
$209
$207
35
Utah
72,615
12,824
18%
$82,745,573
333,577
$248
$211
26
Washington
617,850
205,243
33%
$2,172,803,051
8,732,179
$249
$235
43
West Virginia
201,934
36,292
18%
$129,992,650
774,728
$168
$158
21
Wisconsin
177,745
44,136
25%
$305,538,566
1,585,701
$193
$163
36
Wyoming
6,535
5,671
87%
$26,590,215
108,928
$244
$193
19
Source: GAO analysis of the Department of Labor’s (DOL) monthly Pandemic Unemployment Assistance (PUA) claims data reported by states. | GAO-22-104438
Notes: We ended our analysis through June 2021, prior to some states’ decisions to terminate the
PUA program before its expiration. Data are from DOL’s ETA 902P data file, which we obtained on
January 28, 2022. States may submit adjusted data to DOL over time. We limited our analysis to 40
of 53 states and territories because the PUA claims data they reported to DOL were sufficiently
reliable for our purposes. We excluded the other states and territories due to their having multiple
months of missing data or data anomalies.
aWe calculated PUA payment rate by dividing each state’s total number of first payments made (an
approximation of the number of individuals who received PUA) by the total number of initial
applications submitted. Generally, each PUA claimant submits one initial application and each
recipient receives one first payment.
bWe calculated average PUA compensation amount paid per week by dividing each state’s total
amount compensated by the total number of benefit weeks compensated.
cMinimum weekly compensation amounts for each state are from UIPL 3-20. According to DOL,
states must use the amounts set in UIPL 3-20 as the minimum PUA weekly benefit for all claims. See
Department of Labor, Employment and Training Administration, Coronavirus Aid, Relief, and
Economic Security (CARES) Act of 2020 – Pandemic Unemployment Assistance (PUA) Program
Reporting Instructions and Questions and Answers, Unemployment Insurance Program Letter (UIPL)
No. 16-20, Change 1 (Washington, D.C.: Apr. 27, 2020), and Department of Labor, Employment and
Training Administration, Minimum Disaster Unemployment Assistance (DUA) Weekly Benefit Amount:
January 1 - March 31, 2020, Unemployment Insurance Program Letter (UIPL) No. 3-20 (Washington,
D.C.: Dec. 12, 2019).
dWe calculated PUA weeks paid per first payment by dividing the total number of benefit weeks
compensated by the total number of first payments made (an approximation of the number of
individuals who received PUA). PUA weeks paid per first payment is an approximation of the average
duration claimants received PUA.

Appendix IV: Comments from the Department
of Labor

Page 67
GAO-22-104438  Pandemic Unemployment Assistance

Appendix IV: Comments from the
Department of Labor

Appendix IV: Comments from the Department
of Labor

Page 68
GAO-22-104438  Pandemic Unemployment Assistance

Appendix IV: Comments from the Department
of Labor

Page 69
GAO-22-104438  Pandemic Unemployment Assistance

Appendix IV: Comments from the Department
of Labor

Page 70
GAO-22-104438  Pandemic Unemployment Assistance

Appendix V: GAO Contact and Staff
Acknowledgments

Page 71
GAO-22-104438  Pandemic Unemployment Assistance
Thomas Costa, (202) 512-4769, costat@gao.gov
In addition to the contact named above, Nagla’a El-Hodiri (Assistant
Director), Michael Kniss (Analyst in Charge), Lauren Anderson, Caitlin
Croake, Abby Marcus, and Liz Spurgeon made key contributions to this
report. Also contributing to this report were Holly Dye, Justin Fisher, Alex
Galuten, Abigail Loxton, Mimi Nguyen, Ardith Spence, Walter Vance, and
Adam Wendel.

Appendix V: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments
(104438)

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