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Oregon Employment Department
The Pandemic’s Effects on
Oregonians Exposed
Risks and Highlighted the
Need to Modernize
Oregon’s Unemployment
Insurance System
July 2022
Report 2022-21

The pandemic was damaging to many Oregonians. Tens of thousands lost their jobs, and delays in paying unemployment
benefits hurt those already struggling. OED has made progress addressing some of the most public concerns, such as the
inability of its phone-based system to handle the spike in claims that occurred in March 2020. Regarding fraud, another
concern that garnered significant attention around the country, Oregon fared comparatively well. This audit focuses on
information and recommendations we can provide to improve the UI system ahead of future surges in unemployment.

Why this audit is important
 The Oregon Employment Department
(OED) administers the Unemployment
Insurance (UI) program, which provides
payments to workers who become
unemployed through no fault of their
own.
 The pandemic led to a sudden and
unprecedented surge in UI claims with
which every state struggled. OED’s
antiquated IT systems exacerbated
this difficulty.
 Prior audits and reviews have
documented why efforts to modernize
OED’s IT systems have been delayed,
including lingering effects of the Great
Recession, turnover among agency
leadership, and changes to state
processes after the CoverOregon
failure.
 Delayed UI payments for eligible
unemployed workers can cause serious
financial hardships and undermine the
system’s ability to support the
economy during future emergencies.
What we found
1. Complex UI claims go through a process called adjudication, in which OED
staff gather more information to determine whether a claimant is eligible
for benefits. Even before the pandemic, the agency struggled to meet
timeliness requirements to process these claims. (pg. 18) The pandemic
and its resulting surge in claims only exacerbated the problem, causing
some to wait months or more than a year to receive benefits. (pg. 19)
2. Delays were worsened by several inefficiencies in OED’s systems: a lack
of formal policies to monitor claims that need additional action; outdated
procedures on how to contact involved parties; and online resources
that contained conflicting and difficult-to-find information. (pg. 20)
3. Auditors found data anomalies in the agency’s current IT systems;
however, the agency’s antiquated and rigid IT systems make it difficult
to add additional controls. OED’s ongoing IT system modernization
should address this, as well as help simplify how the agency
communicates with parties involved in UI claims. (pg. 18)
4. Oregonians could benefit from an OED ombuds office to advocate for
and help individuals navigate the complex UI system. (pg. 25)
5. Auditors identified some concerning demographic trends during the
pandemic: adjudicated claims for some groups, separated by race or by
income, appeared to take longer on average than for others. Though the
cause of these trends was not determined, OED should continue to track
the data and develop strategies to reduce any disparities found. (pg. 27)

   What we recommend
We made seven recommendations to OED. OED agreed with all our recommendations. The response can be found at
the end of the report.

Audit Highlights
Oregon Employment Department
The Pandemic’s Effects on Oregonians Exposed Risks and Highlighted
 the Need to Modernize Oregon’s Unemployment Insurance System

Oregon Secretary of State | Report 2022-21 | July 2022 | page 1
Introduction
Unemployment insurance (UI) is a program delivered through a federal-state partnership that began in
1935 with the Social Security Act. The program is funded at both the federal and state level, with
administrative funding amounts tied to economic conditions; when unemployment is high, states
receive more federal funding. Employers contribute most of the funding through payroll taxes.
States develop and deliver their own unique UI program while following broader federal program
requirements. The program is administered in Oregon by the Oregon Employment Department (OED).
Each state also determines its own method for calculating weekly benefit amounts and the duration of
benefit coverage, with most states, including Oregon, offering up to 26 weeks of compensation. The
main purpose of unemployment insurance is twofold: provide temporary, partial wage replacement to
eligible unemployed workers, and help stabilize the economy during economic recessions.

The COVID-19 pandemic caused unprecedented increases in unemployment claims across the country.
Like many other states, Oregon struggled under this surge in claims and in setting up new, emergency
unemployment programs authorized by Congress. OED’s antiquated computer systems could not easily
handle the many program changes implemented during the pandemic and the agency’s phone-based
approach, while generally adequate in normal times, could not accommodate the wave of phone calls
OED received. The agency’s online published resources were also not updated timely during the
pandemic to reflect new legislation. OED’s shortcomings and challenges during the pandemic have been
well documented in the media.
Even before the pandemic, OED struggled with meeting federal timeliness guidelines for making
complex claim decisions, through a process called adjudication. Until January 2022, the agency had only
met federal timeliness standards for job separation-related adjudications once since 2014. Reasons
include inefficient communication procedures and a lack of detailed monitoring of claims that need
further action. Additionally, the agency’s outdated mainframe IT system includes many anomalies and
data entry errors. The system is so antiquated, updating it to add more controls and functionality is
difficult and expensive. OED is currently in the process of designing and implementing a new IT system,
which is estimated to be completed in the spring of 2024.
The devastating impacts from delays in UI benefits to so many during this pandemic compelled this
performance audit. People were desperate and often unable to reach someone to assist them in
getting their claims processed. Some reached out to their legislators. Some reached out to the media.
Some undoubtedly gave up. The purpose of this audit is to provide useful information and
Delays to UI benefit payments can cause significant financial hardships
UI is intended to be a safety net for individuals who lose work through no fault of their own. When eligible
workers experience delays in obtaining UI benefits, there can be significant financial and other impacts to
individuals, their families, and their communities. This can include the inability to pay utility bills, mortgage or
rent, medical care, prescriptions, and basic necessities such as food. These hardships can result in
homelessness, hunger, degraded mental and physical health, loss of savings and assets, and damage to one’s
credit, among other effects.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 2
14-Mar-2020,
4,269
21-Mar-2020,
30,054
28-Mar-2020,
47,498
04-Apr-2020,
62,788
Initial Claims
 (Processed)
recommendations for the agency to improve the UI process ahead of future events of significant
unemployment.
Like most states, OED struggled to pay unemployment benefits and
implement new programs during the pandemic

Source: Oregon Employment Department, QualityInfo.org
The COVID-19 pandemic caused a sudden and unprecedented spike in unemployment
claims. OED was greatly impacted, straining with the task of administering regular UI
benefits, multiple new pandemic-related programs, and retroactive changes to existing
UI programs while simultaneously trying to hire and train new staff — and existing staff
from other areas of the agency — to answer phones and address the growing backlog
of claims, as well as implementing an ongoing IT modernization project and creating the
new Paid Leave Oregon program.
By the end of March 2020, initial claims for unemployment were 10 times
higher than just two weeks earlier
The economic effects of the pandemic were unique, hitting state and local economies at
a time when unemployment rates were near record lows. In 2019, Oregon’s annual
unemployment rate hit a record low of 3.8% and the state achieved a record number of
employed workers, at over 2 million workers. When COVID-19 hit, many states, including
Oregon, made emergency declarations and shut down businesses, schools, and public
offices, bringing the state economy to a halt and triggering massive layoffs in multiple
industries. In just two months, Oregon’s unemployment rate nearly quadrupled, going
from 3.4% in February 2020 to 13.3% by April 2020.
As shown in Figure 1, initial claims for unemployment insurance in Oregon increased by
more than 10 times in March 2020, jumping from just 4,269 for the week ending on
March 14 to 47,498 by the week ending March 28. Initial claims peaked a week later at
62,788. Overall, OED reports just over 580,000 paid claimants for 2020, and a total of
nearly $7.5 billion in UI benefits paid to claimants that year.
Figure 1: In March 2020, initial UI claims in Oregon increased by more than a factor of 10

Oregon Secretary of State | Report 2022-21 | July 2022 | page 3
This represents a 600% increase in paid claims and a 1,400% increase in benefits paid out compared to
2019, when Oregon had approximately 93,000 paid UI claimants and paid out a total of $525 million in
unemployment benefits. Figure 2 shows how the number of employed workers, unemployed workers,
and the unemployment rate changed drastically from February to April 2020.
Figure 2: Due to the pandemic, the number of unemployed Oregon residents rose dramatically from
February to April 2020

February 2020
April 2020
Employed workers
2,015,218
1,759,680
Unemployed workers
71,765
268,802
Unemployment rate
3.4%
13.3%
Source: Bureau of Labor Statistics
According to OED, the job sectors hardest hit by the pandemic closures were Leisure and Hospitality,
Other (including barbers, hair and nail salons, tattoo parlors, repair shops, etc.), and private education.
OED and other state workforce agencies were confronted with the pandemic at a time when staffing
was already low due to record low unemployment numbers and years of federal underfunding of the
administration of state UI programs. OED needed to process the surge of pandemic-related claims while
quickly hiring and training new staff.
Congress passed several new federal UI programs as state workforce agencies were
already strained by record-high initial unemployment claims
Soon after COVID-19 hit the U.S., Congress passed the Families First Coronavirus Response Act, which
provided changes to the UI program, among other provisions. This was followed by the Coronavirus Aid,
Relief and Economic Security (CARES) Act. This legislation included the creation of new federal UI
programs that states were required to implement under the guidance and oversight of the U.S.
Department of Labor. The CARES Act created three federal UI programs: Pandemic Unemployment
Assistance (PUA), Pandemic Unemployment Emergency Compensation (PEUC), and Federal Pandemic
Unemployment Compensation (FPUC). Figure 3 shows the scope of benefits from these programs, as
well as other programs created by subsequent legislation.
Figure 3: The pandemic required OED to administer not only its multiple state programs, but several new
federal UI programs
Program
Benefit Scope
Detail
Federal Pandemic
Unemployment
Compensation
(FPUC)
Three eligibility periods:
• March 29, 2020, through July
25, 2020
• December 27, 2020, through
March 13, 2021
• March 14, 2021, through
September 4, 2021
Federal program increasing the weekly benefit
amount by $600 weekly (March 29, 2020,
through July 25, 2020) and $300 weekly
(December 27, 2020, through September 4,
2021).
Pandemic Emergency
Unemployment
Compensation
(PEUC)
Maximum of 53 weeks through
September 4, 2021
Federal extension to state unemployment
benefits for people who have exhausted state
benefits.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 4
Pandemic
Unemployment
Assistance (PUA)
Maximum 79* weeks through
September 4, 2021
Federal benefits for people who are:
• Ineligible for regular UI benefits and
extensions.
• Unable to work as a direct result of COVID-19
during each benefit week.
*Number of eligible weeks changed when High
Extended Benefits triggered off.
Lost Wages
Assistance (LWA)

Maximum 6 weeks July 26, 2020,
through September 5, 2020
Federal Emergency Management Agency funded
program providing additional $300 weekly
benefit to claimants whose calculated weekly
benefit amount was at least $100, who received
at least $1 in benefits, and who were
unemployed or had their hours reduced due to
the COVID-19 pandemic.
Source: OED
As the pandemic continued, Congress passed the Continued Assistance for Unemployed Workers Act,
which, among other provisions, extended the weeks of eligibility for the PUA, PEUC, and FPUC
programs. This act also created the Mixed Earner Unemployment Compensation program, which
provided an extra $100 per week for people who were receiving regular UI benefits and who had earned
both W-2 wages and at least an annual net income of $5,000 from self-employment work that was in
addition to the W-2 wages. Additionally, the Continued Assistance Act (CAA) contained a provision for
PUA that claimants were required to provide proof of employment and/or self-employment to continue
receiving benefits.
In August 2020, the Lost Wages Assistance program was created by Presidential Memorandum to
authorize the Federal Emergency Management Agency (FEMA) to extend Disaster Relief Funds to UI
recipients. LWA provided an extra weekly benefit of $300, similar to FPUC. To qualify, an individual had
to already be eligible to receive UI benefits, have a calculated weekly benefit amount of at least $100,
have received at least $1 in UI benefits during eligible weeks, and have lost their employment or had
their hours reduced directly due to COVID-19. This lower $300 additional weekly benefit lasted through
September 5, 2021. Because this program was administered by FEMA and not the U.S. Department of
Labor, all funding and benefit payments had to remain separate from the UI trust fund, creating
additional complexity and confusion for some claimants. In March 2021, Congress passed the American
Rescue Plan Act, which, among other provisions, extended the FPUC, PUA, and PEUC programs through
September 6, 2021.
A recent audit by the federal Department of Labor’s Office of Inspector General demonstrated many
states, including Oregon, struggled to implement the new programs created through the CARES Act.1 It
took Oregon an average of 31 days to make first payments to Pandemic Unemployment Assistance
recipients, 17 days for Federal Pandemic Unemployment Compensation recipients, and 49 days for
Pandemic Emergency Unemployment Compensation recipients. As shown in Figure 4, Oregon’s
performance in these areas was comparable to other states and U.S. territories included in the report.

1 See US Department of Labor Office of Inspector General Report No. 19-21-004-03-315, titled ‘COVID-19: States Struggled to
Implement CARES Act Unemployment Insurance Programs’

Oregon Secretary of State | Report 2022-21 | July 2022 | page 5
Figure 4: Despite not having a modernized UI Benefits system, Oregon’s average of 31 days to make first
payments on Pandemic Unemployment Assistance claims was less than the overall average of 38 days*
Rank
State
Pandemic
Unemployment
Assistance
(days to first
payment)
Federal
Pandemic
Unemployment
Compensation
(days to first
payment)
Pandemic
Emergency
Unemployment
Compensation
(days to first
payment)
UI Benefits IT
system
modernization
status
1
New Hampshire
3
21
44
Completed
2
Kentucky
6
9
20
Not completed
3
New York
10
10
17
Not completed
4
Louisiana
17
17
49
Completed
4
Rhode Island
17
14
45
Not completed
6
Texas
18
17
45
Not completed
7
Iowa
19
19
61
Not completed
8
Alabama
21
13
27
Completed
9
Puerto Rico
24
26
66
Not completed
9
Washington
24
24
24
Completed
11
Michigan
26
13
26
Completed
11
Missouri
26
17
38
Completed
11
Tennessee
26
17
46
Completed
14
Massachusetts
27
53
12
Completed
15
Connecticut
28
41
61
Not completed
15
Georgia
28
15
76
Not completed
15
Minnesota
28
12
19
Completed
15
Mississippi
28
14
34
Completed
15
New Mexico
28
21
28
Completed
15
North Carolina
28
18
56
Completed
15
South Carolina
28
15
61
Completed
22
Utah
29
15
57
Completed
23
Colorado
31
31
34
Not completed
23
Montana
31
16
37
Not completed
23
Nebraska
31
17
55
Not completed
23
Oklahoma
31
10
52
Not completed
23
Oregon
31
17
49
Not completed
28
California
32
16
61
Not completed
29
District of Columbia
33
24
40
Not completed
29
Florida
33
15
60
Completed
29
North Dakota
33
19
49
Not completed
32
South Dakota
34
12
53
Not completed
33
Virginia
38
25
101
Not completed
33
Wyoming
38
20
80
Completed
35
Maine
40
19
94
Completed
36
Indiana
42
42
21
Completed
36
Pennsylvania
42
15
50
Not completed
38
Maryland
43
21
43
Completed
39
Alaska
45
17
84
Not completed

Oregon Secretary of State | Report 2022-21 | July 2022 | page 6
39
Arizona
45
17
73
Not completed
41
Hawaii
48
18
53
Not completed
41
Illinois
48
10
25
Completed
43
West Virginia
49
10
42
Not completed
44
Ohio
52
26
38
Not completed
45
Wisconsin
56
33
90
Not completed
46
Nevada
60
18
45
Completed
47
Kansas
61
27
66
Not completed
48
Delaware
63
10
31
Not completed
49
Virgin Islands
101
61
101
Not completed

Overall Average
38
25
50

*Arkansas, Idaho, New Jersey, and Vermont are not included, as they did not respond to the OIG’s data request or did not
have numbers to report.
Source: OIG Report no. 19-21-004-03-315, “COVID-19 States Struggled to Implement CARES Act Unemployment Insurance
Programs”
Due to limitations in the agency’s IT systems, OED was unable to reprogram its systems to account for
new programs created during the pandemic, such as PUA, forcing the agency to implement many of
these programs using mostly manual processes.
Previous audits and reviews have documented problems with OED’s
IT systems and why modernization has been delayed
OED does not have a case management system. Instead, it uses multiple systems to process
adjudicated claims, including both an imaging system and OED’s mainframe system. The mainframe
system originally launched in the 1990s and though it continues to reliably process many claims, it has
been outdated for at least the last decade. Because of its age, the system is difficult to maintain or
upgrade. The system uses an obsolete computer language (COBOL) that can require hundreds of hours
of programming to make simple changes.
The Secretary of State’s Audits Division performed audits of OED’s mainframe system in 20122 and
2015,3 with the first audit finding the agency’s legacy IT systems to be rigid and inflexible in handling
complicated claims and implementing any rule or program changes, especially several federal programs
initiated during the Great Recession. This audit also found the department used many manual
processes and lacked sufficient internal system controls, leading to more errors. Three years later, the
2015 audit reemphasized the system’s challenges, including poor system documentation and difficulty
making program code changes and maintaining the system. This audit included a recommendation that
OED replace the legacy system.
The Audits Division also published an IT Management Letter in 20204 that provided an assessment of
the modernization project. This assessment found many of the same issues, with system challenges

2 See OAD Report 2012-25, “Oregon Employment Department: Computer Controls for the Oregon Benefit Information System
Need Attention”
3 See OAD Report 2015-31, “Oregon Employment Department: Computer Programs for Unemployment Tax Returns and Claims
Need Attention”
4 See OAD Report 471-2020-07-01, “Oregon Employment Department IT Modernization Program Project Review, Information
Technology”

Oregon Secretary of State | Report 2022-21 | July 2022 | page 7
implementing the new COVID-19 federal programs and temporary, or new, state UI program changes. It
also described high-risk areas involving staffing challenges with high turnover in the program, including
the project’s director, as well as shifting priorities due to impacts of COVID-19 and the need to develop
the new Paid Family and Medical Leave Insurance program (Paid Leave Oregon). These shifting
priorities have high risk in affecting the modernization project’s program schedule, with the legacy
systems being behind schedule at the time of project assessment.

The Legislative Fiscal Office report also attributed modernization delays during the Great Recession to
agency failures in IT oversight and project deliverables, describing the IT structure as decentralized,
which caused multiple projects being created at the same time with unclear prioritization or
communication.5 In the wake of the CoverOregon IT project failure, the state’s Chief Information Officer
and Legislative Fiscal Office implemented the Joint Stage Gate Review Process with third-party quality
assurance oversight in 2014. This is a thorough process with detailed monitoring, documentation, and
project deliverables that are required for agencies to move through the phases of a large IT project.6 In
May 2021, OED passed Stage Gate 3, allowing the project to move to the execution phase. At the same
time, OED contracted with a vendor, FAST Enterprises.
Regional U.S. Department of Labor representatives described OED as being thorough and thoughtful in
its planning, problem solving, and actions. They described OED as being methodical and thoughtful in its
approach to modernizing and conducting thorough research of other states and lessons learned from
their implementation experiences.
Most states who received federal ARRA funds in 2009 had not modernized their IT
systems by 2021
In 2009, Oregon received approximately $85 million from the U.S. Department of Labor through the
American Recovery and Reinvestment Act (ARRA). The funding provided through this initiative was
intended for states to expand UI eligibility and payments, with specific focus on low-wage workers,
though the program allowed state workforce agencies to use the money for various purposes. Oregon
chose to earmark most of the funds for replacing and modernizing the antiquated IT system.
OED began the modernization project in 2015 with a budget request in the 2015-17 biennium. This
project is still in process and projected to implement in two phases. First, OED’s Employer UI Tax and

5 See Legislative Fiscal Office Budget Information Report, titled ‘Oregon Employment Department Information Technology
Modernization’
6 See OAD Report 2015-06, “Major IT Projects: Continue Expanding Oversight and Strengthen Accountability”
Several factors have led to delays in OED’s IT modernization project
Both the 2020 IT Management Letter and a 2020 Legislative Fiscal Office Budget Information Report attributed
delays of the modernization project to several factors. After receiving federal funding in 2009, most of which
OED earmarked for system modernization, OED was still facing high claim volumes and administering federal UI
programs, as the Great Recession continued to affect employment. When workloads normalized, delays in the
project were attributed to several years of leadership turnover. OED has had four different agency directors in
the span of nine years, with the most recent resigning in May 2020, following the agency’s early struggles
during the pandemic and its strain on the agency. Another factor was a change in the state’s process for
implementing big IT projects following the $300 million CoverOregon IT project failure.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 8
Paid Leave Oregon contribution system is projected to go live in September 2022, with processing of
Paid Leave Oregon worker applications and small employer grant applications beginning September
2023. The UI Benefits system is projected to roll out by the end of March 2024.
Nationwide, less than half of states had modernized their UI Benefits system prior to COVID-19. Of the
39 states which received partial or full ARRA funding for broadening their UI program eligibility, 23 had
not yet modernized their UI Benefits IT system as of early 2021, including Oregon. As of early 2021,
Oregon and 29 other states were in either the planning or development phase of modernizing their UI
Benefits IT system, and 22 states and U.S. territories had completed modernization of their UI Benefit
system. Figure 5 shows all 39 states that received ARRA funds in 2009 and whether they are in the
process of modernizing the UI Benefits system or have completed that modernization.
Figure 5: Of the 39 states who received the 2009 ARRA funding, 15 completed UI Benefit IT system
modernization by early 2021
States who received ARRA funds and are in the
process of modernizing their UI Benefits system
States who received ARRA funds and have
completed modernizing their UI Benefits system
Alaska
Idaho
Arkansas
Illinois
California
Maine
Colorado
Maryland
Connecticut
Massachusetts
DC
Michigan
Delaware
Minnesota
Georgia
Nevada
Hawaii
New Hampshire
Iowa
New Mexico
Kansas
North Carolina
Montana
South Carolina
Nebraska
Tennessee
New Jersey
Utah
New York
Washington
Ohio

Oklahoma

Oregon

Rhode Island

South Dakota

Vermont

Virginia

West Virginia

Wisconsin

TOTAL: 24
TOTAL: 15
Source: OAD analysis

Oregon Secretary of State | Report 2022-21 | July 2022 | page 9
OED had one of the lowest levels of unemployment fraud in 2020 and
has worked to address shortcomings identified during the pandemic
Based on OED figures, Oregon experienced much less unemployment fraud than many other states,
with OED’s fraud totals coming in substantially lower than its neighbors, California and Washington. This
is likely due to a combination of employing fraud prevention practices, learning from the experiences of
other states, and fraudsters targeting states with better computer systems that paid out claims faster.
According to OED officials, internal figures for 2020 show the agency paid over $24 million in fraudulent
claims. While $24 million is still a large number, Oregon reported roughly 581,800 individuals received
unemployment compensation in 2020 totaling nearly $7.5 billion, meaning Oregon’s rate of fraudulent
payments was just 0.32% of total claims paid for the year.
Figure 6: Based on OED figures, Oregon had much lower UI fraud in 2020 than Washington or California

Source: OAD
By comparison, Washington experienced over $277 million in UI fraud in 2020 (after recovering roughly
$370 million in fraudulent claims), while Colorado faced $73 million in fraudulent claims over the same
period. In October 2021, California reported $20 billion in fraud, approximately 11% of total UI paid out
in the state. Additionally, a recent audit in Arizona estimated about $4.4 billion in fraud with the federal
UI pandemic programs alone, while an audit of Michigan’s unemployment claims concluded the state
experienced nearly $8.5 billion in UI fraud, with a majority occurring through the federal UI programs.
Over the past two years, Texas has reportedly paid out nearly $2.5 billion in fraudulent claims,
amounting to about 5% of all claims paid in this period. Federal U.S. Department of Labor officials noted
in December 2021 that Oregon had some of the lowest levels of fraud in the nation. Figure 6 illustrates
fraud amounts for Oregon, Washington, and California.
Oregon - $24 million
Washington -
$277 million
California -
$20 billion

Oregon Secretary of State | Report 2022-21 | July 2022 | page 10
OED has taken steps to address known shortcomings occurring during the pandemic
After early struggles, OED management made efforts to alleviate the enormous backlog in claims,
expediting hiring and training, suspending some rules to make UI eligibility easier and better fit with the
conditions of the pandemic, and improving engagement with the media. Some of these efforts included:
•
Opening new Contact Center locations in Salem and Wilsonville, due to the record high
volume of claims brought on by the pandemic. By July 2020, the new contact center
location in Wilsonville (the largest location) was staffed with nearly 500 employees.
•
Contracting with an outside vendor to process imaged documents received from
claimants that the system does not automatically attach to a claim, freeing up contact
center staff to answer phone calls and process claims.
•
Standing up a new website that was more user-friendly, translated into 15 languages
other than English, and updated with the latest program requirements and instruction,
as well as creating instruction guides and video clips to help people navigate the claim
process.
•
With the new website, creating a “Contact Us” feature that allows people to reach out
through a ticket system and wait for OED to get back to them.
•
During the pandemic, OED implemented a temporary measure called Benefits While You
Wait. This process provided benefits to individuals while their UI claims were still pending
review and determination in adjudication.
•
Revising communication procedures with employers to lessen the time needed to
adjudicate claims, to try to get benefits out quicker and reduce backlogs.
•
Speeding up adjudicator training by training adjudicators on one type of claim issue at a
time and then having them work just those types of claim issues.
•
Contracted with a local workforce board to stand up a call center specifically to help
individuals with limited English proficiency apply for and access UI benefits.
•
Contracted with the Oregon Health Authority to work with community-based
organizations to help individuals with limited English proficiency and other communities
facing additional access barriers with obtaining UI benefits.
OED also contracted with two consultants for assessments to improve agency efficiency with UI
including the adjudication process and agency communications. These contracts have ended, but the
agency is continuing to work on projects recommended by one of these consultants, developing
resources and strategies to implement better, standardized performance metrics and monitoring
procedures. OED is also in the execution phase of two projects to try to improve adjudication
timeliness and turnaround, including utilizing office specialists to conduct the initial adjudication case
file review, set up files, initiate claimant and employer notification, and assign cases to an adjudicator.
This process would free up adjudicators and begin outreach to claimants and employers earlier,
potentially reducing the amount of time needed for adjudication.
Additionally, the agency recently contracted with the U.S. Department of Labor and its “Tiger Team”
initiative, which deploys UI experts and private sector consultants to identify additional opportunities
to improve operations and service delivery in the areas of Timeliness and Backlog; Equity and
Accessibility; and Fraud Prevention and Detection.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 11
OED administers UI benefits, workforce training, and other
employment-related programs
Beyond managing Oregon’s UI program (UI Benefits and UI Tax), OED also administers several other
programs, including the Workforce Operations Division (a WorkSource Oregon partner), the Workforce
and Economic Research Division, and the new Paid Family and Medical Leave Insurance program (called
Paid Leave Oregon). The agency also provides administrative support to the Office of Administrative
Hearings and the Employment Appeals Board.
The Workforce Operations Division operates with state and local partners in 39 WorkSource Oregon
centers throughout the state, providing support and resources to job seekers and employers looking
for qualified workers. The Workforce and Economic Research Division provides data and reports on the
state’s workforce and economy, including regional labor market data.
The Paid Leave Oregon program, created in 2019 by House Bill 2005, will allow eligible employees to
receive some or all of their wages while on family or medical, or safe leave. This program will provide
employees with compensation while they are on approved leave to care for and bond with a child in its
first year of birth or arrival through adoption or foster care, provide care for a family member with a
serious health condition, recover from their own serious health condition, or take “safe leave” related
to domestic violence, stalking, sexual assault, or harassment. This new program has a planned rollout of
January 2023 for employer and employee contributions, and employees are projected to be able to
apply for this benefit starting in September 2023. Additionally, in September 2023, small employers can
begin applying for small business grants under Paid Leave Oregon. Originally scheduled to begin in
2022, House Bill 3398 (2021) postponed implementation of employer/employee contributions by one
year and delayed the start of benefits by eight months, at OED’s request, due to impacts of the
pandemic.
Figure 7: OED administers multiple UI programs
Program
Program Duration
Detail
Regular
Unemployment
Insurance Benefits
Program
Up to 26 weeks in a
year
Benefits people who(se):
Become unemployed due to no fault of their own.
Earned wages that were subject to unemployment tax.
Meet specific timeframe requirements related to subject wages or a combination
of hours worked and subject wages.
Meet weekly eligibility requirements.
Trade Act Programs
Weeks vary based
on petition filing
date (after
exhausting regular
UI/UI extensions)
Benefits people who lost eligible jobs due to foreign competition.
Work Share Program
(Short-time
compensation or STC)
Varies
Benefits individuals whose employers partner with OED and opt to reduce three
or more of their employees’ scheduled hours and wages (20% - 40%), allowing
employees to earn partial UI benefits while staying employed.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 12
Training
Unemployment
Insurance (TUI)
Program
Up to 26 weeks (ties
to regular UI claim
and may qualify for
more weeks if
eligible for SUD)
Benefits eligible dislocated workers who can collect regular UI while attending
approved school or training full-time.
Supplementary
Unemployment for
Dislocated Workers
(SUD)
Up to 26 weeks
(after exhausting
TUI)
Additional benefits for individuals in approved training (TUI), who have exhausted
regular UI benefits, and meet program eligibility requirements.
Self-Employment
Assistance (SEA)
Program
Up to 26 weeks (ties
to regular UI claim)
Benefits people who are interested in starting their own business, have an
approved business plan, and are likely to run out of regular UI benefits before
they return to work. Must work on their approved business at least 40 hours
each week they claim.
Temporary Lock Out
Benefits
Up to 26 weeks
(after exhausting
regular UI claim)
Benefits people who are involved in a labor dispute with their employer and have
been “locked out” of their place of employment. Must have exhausted regular UI
benefits before becoming eligible for Temporary Lock Out Benefits.
Apprenticeship
Training Program
Up to 26 weeks (ties
to regular UI claim)
Regular UI benefits for individuals attending up to 10 weeks of approved
apprenticeship training during a benefit year and may be exempt from available-
for-work and activity-seeking-work requirements.
Extended Benefits
(EB) / High Extended
Benefits (HEB)
Varies
During periods of high unemployment, a state will “trigger” on to EB or HEB which
provides additional weeks of regular UI benefits. EB provides up to 13 additional
weeks of UI benefits; HEB provides up to 20 additional weeks of benefits.
Additional Benefits
(OAB)
Varies
A state will “trigger on” on to OAB during periods of high unemployment,
traditionally right after the state “triggers off” EB. OAB pays up to 25% of the
regular UI claim’s maximum weekly benefit amount (approximately 6 weeks of
benefits).
Unemployment
Compensation for
Federal Employees
(UCFE)
Up to 26 weeks
Regular UI benefits for federal employees. Federal benefits which are
administered and paid in the same manner as state UI benefits. Federal
employers do not report wages to states; those wages must be requested from
the state workforce agency at the time the individual files a claim for benefits.
Must meet all weekly eligibility requirements.
Unemployment
Compensation for Ex-
Service Members
(UCX)
Up to 26 weeks
Regular UI benefits for ex-services members. Federal benefits which are
administered and paid in the same manner as state UI benefits. Service branches
do not report wages to states; those wages must be requested from the state
workforce agency at time the individual files a claim for benefits. Wages are not
tied to the location an individual worked, but to the place the individual is located
when they file their initial claim for benefits. Must meet all weekly eligibility
requirements.
Disaster
Unemployment
Assistance Program
(DUA)
Up to 26 weeks
If a disaster is declared by the President in one or more Oregon counties and an
offer of individual assistance is stated in the declaration, residents in impacted
counties, who are not eligible for any other UI benefits program and meet specific
criteria, can get DUA benefits. DUA was authorized twice in Oregon during the
pandemic, in response to flooding in Umatilla County and for the historic wildfire
season.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 13
OED is funded by a combination of employer UI taxes, federal funds, and state general
funds
To cover the cost of providing UI benefits, employers pay into their respective states’ UI trust funds
through UI taxes. Oregon uses a self-balancing tax structure to fund its UI trust fund, meaning
employers pay a tax rate determined by OED’s tax schedule as well as the employer’s experience
rating. Each year’s base tax rate is determined by the strength of the UI trust fund; if the trust fund’s
solvency is good, the tax rate is low, and if the solvency is poor, the tax rate is higher. This is typically
countercyclical — rates stay lower through recessions and rise afterwards to rebuild the UI trust fund
to pay benefits during the next economic downturn.
Additionally, new employers start at the assigned scheduled tax rate for a specific year, while
established employers are assigned a tax rate dependent on the assigned scheduled tax rate for the
year and their experience rating. At a high level, experience rating is determined by the amount of
benefits paid out from the employer’s account in the previous three years compared to the employer’s
overall payroll. Essentially, the more employees separated from work through no fault of their own and
eligible for benefits, the more the experience rating increases. Due to the many mandatory business
closures and related layoffs during the pandemic, the Legislature passed HB 3389, which holds
employers’ experience ratings at their pre-pandemic levels through 2024, among other provisions.
OED’s budget and staffing for the 2021-23 biennium grew substantially, largely due to increases in
pandemic-related federal funding, the vast increase in workload it saw, and the new Paid Leave Oregon
program under development (which is funded through a General Fund loan that must be repaid). As
shown in Figure 8, the agency’s budget for the current biennium more than quadrupled since the 2017-
19 biennium, going from just over $1.3 billion to nearly $6.8 billion, with staffing increased from 1,249 to
2,253 Full-Time Equivalent (FTE) positions, or by 80%. However, OED has limits on how it can use each
funding stream; for example, Other Funds (Nonlimited) can only be used to pay UI benefits.
Figure 8: OED’s budget grew considerably in the 2021-23 biennium, mostly due to funding for pandemic-
related programs
OED’s Adjudication Unit handles complex claims in which eligibility may be unclear
and more information is needed
OED’s UI program, like UI programs in many states, is complex, with multiple eligibility criteria and filing
requirements. With an unprecedented increase in claims at the start of the pandemic, OED had to hire
and train new staff on all the rules, requirements, and procedures in administering regular UI, as well as

2017-19 Actual
2021-23 Legislatively Approved
Budget
General Fund
$0
$48,765,505
Other Funds
$145,089,641
$285,661,087
Federal Funds
$146,465,578
$310,599,469
Other Funds (Nonlimited)
$980,218,895
$5,058,847,795
Federal Funds (Nonlimited)
$65,274,200
$1,081,179,119
Total Funds
$1,337,048,314
$6,785,052,975
Positions
1,303
3,304
FTE
1,249.88
2,253.62
Source: 2021-2023 Legislatively Approved Budget

Oregon Secretary of State | Report 2022-21 | July 2022 | page 14
training them on several new federal programs passed by Congress and changes made to existing
programs to adjust to the impacts of the pandemic on employees and businesses.
This was an even bigger challenge for hiring adjudication staff. Adjudication is the process by which
OED adjudicators review potential claim eligibility, conduct fact-finding interviews, and apply federal
and state laws and rules to determine whether an individual is eligible for UI benefits. Adjudicator
training can take 12 or more weeks to complete all subject areas. OED tripled its Adjudication team in
2020, growing from roughly 101 staff in the first quarter of 2020 to 319 by the third quarter of that
year.
Unemployed workers may be eligible for UI benefits if they cease working through no fault of their own.
Employment separation reasons that may allow someone to receive UI include being discharged for
reasons not related to misconduct, voluntarily leaving work with good cause, continuing to work but
less than 40 hours a week and earning less than their weekly benefit amount, and being laid off due to
lack of work, among other scenarios.
When an individual files for UI, they fill out an initial claim application and then file a separate weekly
claim. They continue to file weekly claims for every week they seek to receive UI benefits. The
individual can complete these claims online or using the automated telephone weekly claim line. If an
individual fills out a claim with information that triggers a possible eligibility issue, it must be
adjudicated. Additionally, during any week that an individual claims UI benefits, possible eligibility issues
can be referred to OED from employers or other parties, or be discovered by OED during claim audits or
eligibility reviews. Regardless of how the eligibility issue is discovered, it will need to be adjudicated.
Figure 9: Total adjudication decisions from 2019 to 2021 — More adjudicated claims were denied in 2021
than 2019 or 2020, with a majority attributed to PUA claim denials
Source: OED and OED website qualityinfo.org
In addition to separation circumstances, individuals eligible for UI benefits must also meet certain
requirements each week to receive benefits in that week, so an individual’s responses on their weekly
claim can also trigger a flag that requires adjudication. Examples include a person indicating they were
not fully able or available to work in their labor market the whole week, turning down a job offer, not
completing the minimum job search requirements, or earning income. Figure 9 shows number of
decisions made by OED adjudicators from 2019-2021, as well as the number of initial UI claims the
agency received in that period. According to OED, a higher percentage of adjudicated claims were

Adjudication
Decisions,
2019
%
Adjudication
Decisions,
2020
%
Adjudication
Decisions,
2021
%
Approved
46,146
42.2%
59,641
46.4%
99,396
27.0%
Denied
62,810
57.4%
67,492
52.6%
268,164
72.8%
Reduced*
479
0.4%
1,289
1.0%
709
0.2%
Total
109,435

128,422

368,269

2019

2020

2021

Initial UI Claims**
218,349

764,300

354,619

*In ”Reduced” decisions, a claimant is found to be eligible for UI benefits, but at a lower amount.
** While adjudication decision totals include PUA claims, initial UI claim totals do not.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 15
denied in 2021 because many people applied for both regular UI and PUA at the same time. An individual
can only be eligible for one program or the other, so in these cases, at least one of the two applications
had to be denied, leading to an overall increase in denials.
The agency’s online claim system automatically suspends claims (both initial and weekly) that require
further investigation. If an individual is filing their initial or weekly claims by phone with OED, agency
staff assisting the individual can manually set a flag and input notes on the claim about the potential
issue. The adjudicator will look at the claim, review the flags and notes, and conduct fact-finding
interviews and other research to determine the individual’s eligibility.
Sometimes, the adjudicator requires a simple clarification by the individual. Other times, the adjudicator
has to gather information from multiple parties to assess the claim issue and determine the final
eligibility decision. Some claims have multiple separations that require adjudicating, with each issue
requiring a separate determination. If an individual is denied benefits, or benefits are reduced, they
have the right to file an appeal, generally within 20 days.
To get a sense of the complexity of claim situations requiring adjudication due to either federal or state
program requirements, see Figure 10.
Figure 10: Many claim situations can trigger adjudication review
Discharges/suspensions
Voluntary Quits
Nonseparation
Temporary layoff (different eligibility
requirements if beyond 4 weeks)
Good cause (adjudicate situations for
possible good cause; some reasons
require employee to have attempted
to seek reasonable alternative work
assignment)
Deductible income (i.e., retirement)
Misconduct
Leave work to accompany spouse to a
different labor market (eligibility
parameters)
Able to work (physically and mentally
able to work each week claimed)
Isolated instance of poor judgment
Refuse to join bona fide union
membership when it is a requirement
for the job
Available for work (available to work
customary hours for type of
employment sought for each week
claimed)
Good faith error
Reduction in pay and/or hours
(adjudicate if meets allowable criteria)
Actively seeking work (meeting OED’s
required work-seeking activities for
each week claimed)
Unavoidable accident
Domestic violence, stalking, and
sexual assault
Out of the labor market for portion of
week claimed (possibly may not
qualify for benefits)
Absence due to illness, physical or
mental disability
Quit to accept other work (can qualify
under specific criteria)
Failure to register and complete
welcome process for OED’s
iMatchSkills service within required
timeframe
Inefficiency due to lack of job skills,
training, or experience
 Quit to avoid paying union dues
Incarcerated (adjudicate if created
availability issue for customary hours
of job being sought)

Oregon Secretary of State | Report 2022-21 | July 2022 | page 16
Discharges/suspensions
Voluntary Quits
Nonseparation
Drugs and alcohol reason (adjudicate if
worker was in state-certified
addiction program after separation;
adjudicate if employer had a
reasonable drug and alcohol policy)
Quits before being discharged
Attending school (adjudicate if it
conflicts with customary hours of job
they are seeking)
Administrative, investigative, or
disciplinary suspension (determine
eligibility depending on type of
suspension and whether it is a paid
suspension)
Quits before a planned voluntary exit
Job refusals (if job refused during
week claimed, did it meet job
suitability criteria)
Discharged 15 days or less before a
planned voluntary quit
Failing to maintain a
license/certification required for the
job
Late reports (filing week(s) outside of
acceptable timeframes)
Theft
Quit work to attend school
Fraud, misrepresentation
COVID-19 reasons
Compelling family reason
Identity theft, hijacked claim

Left work for self-employment
Apprenticeship training

COVID-19 reasons
Professional athletes

Failure to provide information

Education workers

Non-citizen workers (adjudicate if
worker is authorized to work)

Union member

Week(s) not claimed (adjudicate
whether to restart claim)

Failure to apply for a job when
referred

Labor Dispute

Oregon Secretary of State | Report 2022-21 | July 2022 | page 17
During the pandemic, OED staff knew “this is when people need us
the most”
Many unemployed workers faced a series of challenges trying to
claim unemployment benefits during the pandemic, on top of the
worries and uncertainties that already come with losing a job.
OED staff were keenly aware of the challenges these workers
were facing and felt the strain they were under.
“Take the normal stress of losing a job and just ratchet it up,” said
OED Lead Adjudicator Jenifer Stepat. She and her fellow
workers knew they needed to help as much as they could.
“Overnight, people lost their income. We felt it. We had so much
compassion for them. We had calls from people who were
suicidal... the desperation in people’s voices was really hard to
hear.” However, she also felt thankful to be in a position to help.
“Everyone pulled together as a team. We did everything we could
at the time to use our talents to make things better.”
“If 2008 was a slow mudslide, 2020 was like an avalanche.”
Like many other workplaces, OED staff had to navigate the challenges of changing workplace rules,
social distancing, and eventually learning how to function effectively in a virtual environment. “We had
staff getting up at 4:00 AM so we could stagger shifts,” Jenifer said. At the same time, the Adjudication
Unit faced a workload unlike anything during the Great Recession. “If 2008 was a slow mudslide, 2020
was like an avalanche,” she said. Jenifer pointed out that in normal times, it takes about a year to
become comfortable with the rules and situations an adjudicator has to navigate. With all the new
programs during the pandemic, adjudicators had to learn and apply the new rules quickly. “You went
from feeling like you knew your job well to – Ack!”
“We are 100% more prepared now than before.”
Jenifer described the agency as being more prepared for the next downturn, due to improvements in
training and everything they experienced with the surge of work during the pandemic. She also noted
that the forthcoming IT modernization will have a huge impact. “Everyone is looking forward to that.” In
the end, she described the role of an adjudicator as objectively applying law and rule to determine if
someone is eligible for benefits. “It can be hard to have to deny people benefits,” she said. “It can break
your heart.” But she explained that, by quickly and accurately making the eligibility decision, you can
get the claim resolved to help that person move on. “It can be a hard job, but that’s what the job is. My
coworkers and I care about the public — that’s why we do this work.”

Oregon Secretary of State | Report 2022-21 | July 2022 | page 18
Audit Results
State workforce agencies across the country, including OED, were overwhelmed by the surge of
pandemic-related UI claims. The agency’s inflexible computer systems could not be updated when
programs changed, and the phone system could not keep up with the extraordinary increase in calls
OED received. The agency also struggled to keep its published resources up to date with the many
legislative and UI program changes that occurred.
Long before the pandemic, however, OED struggled making timely decisions on adjudicated claims.
Federal timeliness standards compel state workforce agencies to make at least 80% of these decisions
within 21 calendar days. Prior to January 2022, OED has not consistently met this benchmark for
separation decisions since 2014. Inefficient communication procedures for contacting claimants and
employers can delay decisions; the agency’s IT system lacks some internal controls for tracking case
issues, allowing some claims to fall through the cracks; and adjudicator guidance is spread across
several systems. Auditors also found decisions for certain demographic groups took longer, on average,
than for others, though the cause for this discrepancy could not be determined due to limitations in the
data.
OED is already taking some steps to improve its communications, data system controls, and guidance,
but additional improvements could be made to improve adjudication timeliness, reduce the risk of
inconsistent determinations, and examine potential inequities. Establishing an ombuds office could also
help claimants navigate complex UI programs.
Some claims end up taking months or years to adjudicate due to
insufficient internal controls in OED’s antiquated IT systems
OED’s mainframe system, used to administer and adjudicate claims, is outdated and difficult to update,
as previous audits have found. Many of the data fields used by adjudicators are manually entered,
without automated or system edit checks or other controls to ensure information entered is accurate.
Adjudication managers and lead staff are tasked with monitoring lists of suspended, flagged, and
unresolved adjudicated claims, but at the time of the audit, the agency had not developed any formal
policies and procedures to ensure these checks are done.
Many adjudication system fields are manually entered by staff, without additional
controls to prevent errors
To review OED data on adjudicated claims, we looked at 155,582 records of separation-related
adjudications from January 2019 through December 2020.7  We found a significant number of anomalies
in the data, including system field errors, missing fields, and test data that should not have been in the
live production system. For example, we found over 900 adjudicated claims with missing issue
detection dates or illogical date sequences, such as the date on which an adjudication issue was
detected coming before the date of the first effective week of the claim.

7 Separation-related adjudications include adjudicated claims in which the claimant was fired, laid off, voluntarily quit, or
separated from their job in some way.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 19
We also identified 45,524 possible duplicate records, in which there were multiple adjudication records
— sometimes with the same detection date, decision date, and reason for adjudication — under one
claimant ID number. According to OED managers, there are many reasons why a claimant may have
multiple issues needing adjudication within the same claim. For example, a claimant may find and lose
more than one job over the life of a claim, or lose multiple jobs at the same time, in which case the
reason for each job loss may need to be adjudicated. However, without looking at the electronic file for
each claim, we could not determine with certainty which of these records were legitimate issues within
the same claim and which were potential errors.
Additionally, we found 2,298 records in which there was no tracking description entered. This field
captures the type of nonmonetary issue that needs to be adjudicated and is supposed to be a required
field. OED managers were initially unsure why this field was showing as blank for these records; they
were later able to determine the information is contained in the mainframe, but not coming up in data
queries. These examples demonstrate the difficulty of pulling reliable information from these aging data
systems.
Complicating matters further, many of the adjudication data fields in OED’s system are manually
entered, including the decision date, detection date, decision code, and nonmonetary tracking code.
While the system has some required fields and basic controls, such as not allowing some illogical dates,
most of the manually entered fields do not provide drop-down lists of options for staff to choose from,
which can reduce errors and typos, or include any input controls to warn staff that an entry may be
incorrect.
The errors found in the data and the lack of many basic controls make it difficult to know whether data
included in the system are correct without cross-checking them against individual claim files, a process
that would be extremely time-consuming given the number of claims OED received over this period.
Moreover, because the agency’s IT systems are so outdated, it is also difficult to automate these fields
or to put additional controls in place to reduce these errors within the current system.
Claim issues sent to adjudication, including those sent on for fraud investigations, can
take more than a year to be processed
We also found more than 1,000 claims that seemed to take a year or more to adjudicate from the time
of issue detection. Over 300 of these claims appeared to have occurred in 2019, long before any
pandemic-related delays should have been present. However, looking at the data, it was unclear
whether these cases actually took more than a year for a decision or whether they were the result of
errors in either of the date fields.
To examine this further, we asked OED managers about 10 adjudicated claims among those that
appeared to have taken the longest to be processed, ranging from 689 to 804 days. Of these 10 files,
six included errors in either the detection date or decision date. However, the other four files had been
sent to the Benefit Payment Control (BPC) unit within OED, which investigates claims for issues such as
potential fraud or identity theft. OED managers reached out to the BPC unit and determined the
detection and decision dates for these four claims, which took 729 to 804 days to process, were
accurate. According to agency managers, these claims appeared to have been investigated by BPC
staff and were set aside while waiting for additional information, where staff then lost track of them
and did not follow up on until they were finalized roughly two years later.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 20
Given the small sample of these reviewed claims, we cannot gauge how many more of the records that
appeared to have taken more than a year to process were also sent to BPC for investigation without
looking at each individual record. However, any number of claims taking that long is problematic and
could significantly affect those claimants.
The agency indicated it implemented some ad hoc procedures during the pandemic to manage claims
needing more information or action that end up being suspended or needing adjudication. However, at
the time of the audit, it had not developed formal policies or procedures to standardize that monitoring
to ensure work was consistently being done. OED management indicated they have implemented
procedures to make sure claims sent to BPC are tracked.
OED’s communication procedures for adjudications are outdated
and inefficient for contacting parties involved in adjudicated claims
While the agency has updated some of the ways in which it communicates with claimants, including
using caller ID for outgoing calls and accepting emailed information, it still relies heavily on phone calls
and letters, which can delay the process. Once implemented, OED’s long-planned IT system
modernization should help streamline the process.
When the pandemic began, OED relied on its phone system for educating and helping
people navigate the UI process
Prior to March 2020, OED’s phone system averaged less than a five-minute hold time. However, the
system could not keep up with the enormous influx of calls during the pandemic. In part because the
agency needed to quickly work with phone service providers to expand the capacity of the OED phone
lines, and also because OED did not have an online contact form
that could provide an alternative method for reaching the
agency other than a phone call, people were forced to wait on
hold for several hours, with some callers being disconnected or
getting a busy signal.
In the summer of 2020, OED improved its online resources to
help individuals access UI benefits without having to rely on
calling the agency for support. OED launched a new and
improved website in July 2020 with information translated into
15 languages other than English. The new website includes a
built-in chat-bot to provide general information to frequently
asked questions and a “Contact Us” feature that permits
individuals to reach out to the agency regarding their claim and
upload documents. In early 2021, OED updated the initial claim
application to include a version in Spanish, permitting Spanish-
speakers to file their initial claim online versus calling in or having
to submit a translated form.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 21
OED meets federal requirements for attempting to reach claimants and employers, but
delays inherent to OED’s process can impact timeliness
Federal Department of Labor standards require state workforce agencies to make reasonable attempts
to reach claimants and, for certain types of issue, employers, when claims are flagged for adjudication.
Per OED policy, adjudicators are required to make at least one attempt to reach claimants, by phone or
by mailed letter, which meets the federal minimum. Based on our conversations with several
adjudicators, they generally reach out to a claimant by phone, leaving their name and direct phone
number if they are unable to speak with the person directly. If they are unable to leave a message,
either by voicemail or with another individual who agrees to deliver the message, the adjudicator must
send a letter (or a secure email if an email address is on file) to the individual notifying them the
department is trying to reach them regarding their claim. If the person does not respond to the initial
contact, another call may be made or another letter (or email) may be sent.
By policy, adjudicators are required to allow a claimant at least 48 hours to respond to a voicemail or
email message and at least five days to respond to a letter. While this policy helps ensure people are
given time to reply to OED requests, it can quickly impact timeliness. For example: An individual might
call back after hours or when the adjudicator is on another call. If the individual is not available when
the adjudicator returns the call, the adjudicator must give them another 48 hours to respond. If the
adjudicator calls and is unable to speak with the person or leave a message, the adjudicator must then
send a letter or secure email, requiring a waiting period of 48 hours for email and at least five days for a
letter. OED did not previously have consistent caller ID for outbound calls, making it less likely people
would answer adjudicator calls, and the agency does not use texting as a method for contacting people,
as many UI fraud schemes also use texting. Furthermore, while some email capability is now included as
a part of the “Contact Us” form on the OED website, in addition to the agency’s secure email system,
neither are used as a primary method of contact, and the secure email system is not user-friendly or
efficient. OED also does not ask claimants for their preferred communication method when they apply
for UI benefits, due to limitations with the legacy mainframe system.
The 21-day federal timeliness benchmark for adjudications begins on the date on which the department
detected — or should have detected — an issue that requires adjudication and includes weekends and
holidays. If the staff person who initially receives a claim detects an issue needing adjudication, under
the federal standard, the adjudication timeliness period would generally start on the date the claim was
received; it could be several days into the 21-day period before it comes to an adjudicator, or even
beyond the 21-day mark. Also, if an issue is detected late in the work week, it may not get assigned to
an adjudicator until the following Monday, reducing the number of days available to adjudicate the issue
within the timeliness standard. According to adjudicators we spoke with, claims are often several days
into the timeliness period before the adjudicator receives the case.
Additionally, the high frequency of claim backdating during the pandemic exacerbated this issue. When
claims were backdated more than 21 days, the adjudication timeliness clock had already run out by the
time the issue was identified by OED, so the agency never had an opportunity to write a timely
decision. For example, if an initial claim was filed in September 2020 and backdated to April 2020, when
the individual separated from work, but OED staff identified an issue needing adjudication for a week
claimed in July 2020, the backdating makes it appear the agency should have known about the issue in
April, months before the initial claim was received.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 22
Adjudicated claims sometimes need additional information from an individual’s former employer to
determine eligibility. When an individual files an initial claim application, their former employers are sent
a form, called Form 220, to gather information about their job separation. Under state law, an employer
must respond to a Form 220 within 10 days to maintain their right to appeal the decision. If the
employer does not respond at all, the adjudicator can proceed with the adjudication using only the
information provided by the claimant. Also, adjudicators we spoke with noted that if the employer (or
their representative) only provides some of the information needed, they are required to make another
reasonable attempt to obtain the needed information via phone, email, or letter, which includes
another waiting period. Even in these instances, the 21-day timeliness standard still applies.
The National Association of State Workforce Agencies (NASWA) administers a system known as SIDES
that allows employers to electronically receive and respond to Form 220s, which can greatly reduce
delays inherent in mailed forms, such as incorrect addresses and delivery delays. While OED encourages
employers to use SIDES, it does not require any to do so, even larger employers, third-party
administrators, or businesses with higher experience ratings.8
Figure 11: The National Association of State Workforce Agencies (NASWA) administers the SIDES program,
which allows employers to electronically submit UI information to state UI programs

Source: NASWA website
The combined effect of these various policies and circumstances means more than a week can go by
before an adjudicator has an opportunity to talk with the claimant or, if necessary, the employer.
Auditors were unable to determine the percentage of adjudicated claims that are delayed in this way,
due to limitations in the adjudication data we received from OED (see pages 21-22 for more information
on these data limitations).
The agency’s planned modernization of its IT systems should present an opportunity to improve its
communications with claimants. The new system should allow:

8 To help support an equitable distribution of costs across employers, an employer’s UI tax rate is based in part on its experience
rating, which measures how many of a business’s former employees go on unemployment insurance.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 23
•
Easier submission of online claims, making it simpler for claimants and agency staff
to track and manage claims;
•
More questions to be asked up front, when a person is applying for benefits,
creating a more complete record with less need for follow-up by the agency; and,
•
OED to both ask for and use a claimant’s preferred communication method.
According to OED management, the modernized IT system will also incorporate the SIDES system,
which should allow OED to receive information more quickly from employers or third-party
administrators.
During the pandemic, published guidance for claimants and internal
guidance for adjudicators was often out-of-date or difficult to find
With the surge of pandemic-related claims, new UI programs, and retroactive federal guidance supplied
by the federal government, OED struggled to provide the public with accurate and up-to-date
information. To improve its communication, the agency created a separate UI website for UI claimants
to be updated with the newest information on pandemic-related changes and new programs. However,
information on the new site did not always match outdated guidance on OED’s regular website.
Additionally, adjudicators we spoke with indicated guidance for staff was not centralized or updated
regularly, and staff often had to create their own systems for organizing resources on new UI programs
and rule changes, increasing the risk of inconsistent adjudication decisions. According to OED
management, new information was provided timely to adjudicators by email, memo, and training
materials when necessary, but the pre-pandemic guidance repositories were not updated regularly.
The agency's published resources were not updated timely, and information could be
confusing, conflicting, and difficult to navigate
The surge of claims OED received during the pandemic put enormous strain on the agency. While
dealing with this unprecedented rise in claims, the agency also had to stand up new UI programs
created by Congress and implement multiple changes to these new benefit programs, as well as
existing programs, due to actions by Congress or the Legislature. As the pandemic continued,
retroactive guidance from the federal government created additional burdens on the agency as staff
and managers worked to implement these policies. Taken together, these challenges made it difficult
for OED to keep information on its websites up-to-date and accurate.
Early in the pandemic, Congress created new UI programs to help those who did not qualify for regular
UI, and the federal Department of Labor issued new guidance relaxing some UI requirements, as entire
industries were effectively shut down to help limit the spread of the COVID-19 virus. In an effort to
keep up with all the changes, OED created a secondary website that went live in the summer of 2020.
This new site contained information on the new UI programs created by Congress, as well as pandemic-
related changes to the regular UI programs, and was more accessible for non-English-speaking
populations, with UI information translated into multiple languages.
At the same time, OED kept its main agency website with pre-pandemic UI information. Some of this
information was outdated and did not reflect program changes made during the pandemic. Though a
link to the new site was included in a banner on the old site, a claimant would not get the most up-to-

Oregon Secretary of State | Report 2022-21 | July 2022 | page 24
date information on filing a claim during the pandemic if they did not see the link to the new site. Figure
12 shows the Unemployment Insurance section of the main OED website with the banner linking to the
new, updated site.
Figure 12: OED’s main website included a link at the top of each web page to the new website

Source: OED website
Similarly, the agency produced guidance documents and instructional videos to help walk claimants
through how to submit a valid online claim during the pandemic. Because OED’s IT systems are
antiquated and difficult to update, this guidance could not be built into the online claim system.
However, if a claimant did not see these guides or videos, they could enter their claim information
incorrectly, possibly resulting in delays, adjudication, or denial of benefits. Figure 13 shows a page from
an OED guidance document, pointing out information in their claim system was not updated based on
rule changes due to the pandemic.
Figure 13: Because OED’s antiquated IT systems are difficult to update, the agency had to create separate
guidance documents to walk claimants through how to submit a claim during the pandemic

Source: OED online guide, titled “Filing a New Unemployment Insurance Claim Application During COVID-19”

Oregon Secretary of State | Report 2022-21 | July 2022 | page 25
Adjudicator guidance is spread across different sources and is not updated, leading to
employee workarounds and increased risk of inconsistent determinations
According to our conversations with OED managers and staff, the agency provides several different
avenues through which adjudicators can receive support and guidance in conducting their work, in
addition to the enormous number of training documents they receive during initial training. Lead
adjudicators provide much of the day-to-day guidance, maintaining chat forums via Microsoft Teams in
which adjudicators can ask questions, as well as a shared database in which adjudicators can pose more
difficult questions for leads to answer. Some teams maintain their own Teams chats or other forums in
which staff can pose questions to their more experienced colleagues. Staff also mentioned the
Adjudication unit’s internal quality control process, in which a lead or manager reviews a certain number
of decisions from every adjudicator on their team each month, to help make sure decisions were made
correctly. These reviews are on top of federally required evaluations of benefit accuracy, quality, and
timeliness OED also conducts.9
When discussing written guidance, however, adjudicators we spoke with noted it is scattered across
several platforms, including an outdated benefit manual, an outdated online document library, emailed
guidance, laws and rules, U.S. Department of Labor requirement changes, and OED policy changes from
OED’s UI Operations and Program Support section. According to staff, many adjudicators develop their
own documents and systems for keeping track of guidance, which puts newer employees at a
disadvantage, as they may not know all the places where guidance might be stored. In conjunction with
the lack of organized written guidance, some adjudicators we spoke with also reported getting
different answers from different lead workers when requesting help on more difficult adjudication
scenarios, as well as confusion among leads on more recent rule changes.
Not providing adjudicators with timely guidance that is easy to access increases the chances of
inconsistent adjudication determinations, potentially resulting in erroneous decisions that could affect
both claimants and how the agency scores in federally required benefit accuracy and quality
evaluations. OED management indicated it is working on creating a centralized resource via Microsoft
OneNote that will include links to all the various sources of guidance for adjudicators.
Like other large state agencies with complex programs, OED could
benefit from an ombuds office to assist and advocate for claimants
As explained earlier in this report, many of the rules and requirements for UI are complicated and
decisions are often dependent upon an individual’s particular situation. Not all claimants can understand
these complexities themselves, and because they have lost employment, they are likely to be stressed
and anxious. Some state agencies in Oregon, as well as other states, provide an Ombuds office to
advocate for and assist individuals in getting their cases addressed more quickly.
An ombuds office can help individuals navigate complex, bureaucratic programs
Eligibility rules for UI can be incredibly complex, encompassing both federal requirements and additional
rules and policies implemented by individual states. How an individual became unemployed, the
circumstances around how and why they became unemployed, how much they worked and earned

9 The federally required reviews are Benefit Accuracy Measurement (BAM) and Benefit Timeliness and Quality (BTQ).

Oregon Secretary of State | Report 2022-21 | July 2022 | page 26
while employed, a person’s ability and availability to work, and whether they are actively seeking work
can all affect whether a claim is eligible for benefits. Not everyone is able to understand and navigate
these rules themselves.
Furthermore, adjudicated claims can take many weeks or months to resolve, and sometimes get lost in
the system, as we found when examining claims data. Individuals looking for help getting their claim
resolved have few avenues to turn to outside the regular claim and adjudication processes, short of
contacting their state legislator for help. Those who are less familiar with the unemployment system,
who have less education, or for whom English is not their first language, may not be comfortable
contacting their legislators or even know of that as an option. For these people, as well as those whose
claims may have fallen through the cracks, an ombuds office could help them navigate the complexities
of the system and get their claims resolved sooner.
The State of Oregon has already established ombuds offices for other critical state programs, such as:
•
Governor’s Advocacy Office, which manages the Oregon Department of Human
Services (ODHS) Ombuds and Foster Care Ombuds programs, as well as other
complaints regarding ODHS;
•
Office of Long-Term Care Ombudsman, which also includes the Oregon Public Guardian
and Residential Facilities Ombudsman programs;
•
Ombuds Office for Oregon Workers, which advocates for and helps workers understand
the state’s workers’ compensation system; and,
•
Office of Small Business Assistance, which offers ombuds services to Oregon
businesses with up to 100 employees who have questions or concerns about state or
local government.
Some other states have ombuds offices that
help resolve issues related to UI claims. The
ombuds office for the Arizona Department of
Economic Security acts as an impartial,
independent, and confidential resource for
individuals facing issues with UI and several other
programs, including the state’s food stamp, cash
assistance, and developmental disabilities
programs. In Alaska, the State Ombudsman
investigates citizen complaints about
administrative actions taken by state agencies.
Other states, such as Iowa and Hawaii, have ombuds offices that cover most of state government, as
well. According to the United States Ombudsman Association, some states also have public agencies
with their own ombuds offices, such as the Texas Health and Human Services Office, the Georgia
Department of Corrections, and the Minnesota Ombudsman for Mental Health & Developmental
Disabilities.
Implementing an ombuds office for UI could help people who may not be able to advocate for
themselves and help identify and document trends or gaps in the claims process OED could then
investigate, monitor, and improve upon.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 27
Certain demographic groups appear to have faced longer delays
during the pandemic
Based on adjudication data, it appeared that adjudications for individuals from some racial and ethnic
groups, as well as those with lower earnings, took longer to process during the pandemic than claims
from some other groups. Data from before the pandemic did not show this same trend. Due to
limitations in the data, we were unable to determine the exact cause of these disparities, but the data
are significant enough to warrant further research and attention from OED.
Though the cause could not be determined, adjudication decisions for certain ethnic
groups and claimants with lower wages appeared to take longer on average
As a part of our analysis of OED adjudication data, we examined whether there were differences in
adjudication timeliness by certain demographic and socioeconomic factors, including race, ethnicity,
and income, using claimants’ weekly benefit amount as a stand-in for income level. Though the data
issues mentioned previously prevent us from drawing many conclusions, we noticed certain trends in
the data that would be worthwhile for OED to further research and monitor.
When looking at the data on separation-related claims, we found adjudications for individuals from
certain racial and ethnic groups appeared to take longer to process during the pandemic. For claims
filed from March 2020 through December 2020, the longest average time span for an adjudication was
117 days for individuals identifying as Asian — 16 days longer than the shortest average time span, for
those claimants who did not indicate their race or ethnicity. Figure 14 shows how many extra days it
took for adjudication decisions, on average, by race or ethnicity both during and prior to the pandemic.
Figure 14: Average adjudication times were up to 16 days longer for certain racial and ethnic groups than
adjudications where no race or ethnicity was indicated, though the cause for this disparity is unclear

Note: Before the pandemic, decisions for individuals identifying as African American took an average of one day less than those
with no race/ethnicity indicated; this is shown here as -1 in the African American category.
Source: OED data
16
10
6
4
4
4
6
3
0
-1
3
7
11
15
19
Asian
Native
Hawaiian or
Pacific
Islander
Race Unknown
Indicated
African
American
White
Hispanic
Latino
American
Indian or
Alaskan Native
More than one
race/ethnicity
No
Race/Ethnicity
Indicated
Additional days to decision, March-December 2020
Additional days to decision, January 2019-February 2020

Oregon Secretary of State | Report 2022-21 | July 2022 | page 28
With decisions in the data we analyzed taking an average of over three months during the pandemic, an
extra two-week delay in receiving benefits can have a major impact on the lives of those eligible to
receive UI. A two-week delay could mean the difference in someone making an on-time car payment or
losing their vehicle to repossession, or the ability to purchase food.
OED adjudication data also showed that as the weekly benefit amount increased — which is based on
how much a claimant earned while they were employed — the average time to process the adjudication
went down. Based on the data, claims with a weekly benefit amount of $100 to $185 took an average
of 109 days to be adjudicated, while claims with an amount of $615 to $700 took an average of 95 days
to adjudicate. This would suggest adjudications for those with higher earnings were processed faster
than adjudications for those with lower earnings. Figure 15 shows the average adjudication times by
weekly benefit amount both during and before the pandemic.
Figure 15: Claims from those with lower weekly benefit amounts — those with lower earnings — appeared to
take longer to adjudicate than those with higher weekly benefit amounts, though the cause is uncertain

Source: OED data
Because of known data limitations, we could not draw any firm conclusions about the trends we saw.
These disparities could be the result of errors in the data that, if corrected, would show smaller
discrepancies in adjudication times by race, ethnicity, or earnings. It is also plausible the trends show
inequities in the system that need to be corrected. Therefore, it is important for OED to perform
further data collection and analysis to identify the potential cause.
Claimants are also not required to provide their race or ethnicity when applying for unemployment
benefits. In the data we analyzed, only roughly 33% of claims before the pandemic and 60% of claims
during the pandemic included this information. It is possible these trends would be different if every
claim had this information.
Even if the disparities found are accurate, there are many reasons they could be occurring. For
example, the equity report OED published in 2021 noted workers from communities of color were over-
represented in leisure and hospitality jobs, the sector of the economy hardest hit by the pandemic. As
14
11
8
5
3
3
0
0
4
8
12
16
$100 - 185
$186 - 271
$272 - 357
$358 - 442
$443 - 528
$529 - 614
$615 - 700
Additional days to decision, March-December 2020
Additional days to decision, January 2019-February 2020

Oregon Secretary of State | Report 2022-21 | July 2022 | page 29
with that sector, if a specific industry was forced to close or reduce operations during the pandemic,
there could be many related claims with complicated issues needing adjudication. The pandemic
affected virtually every sector of the economy in different ways.
OED should consider monitoring and researching these trends more fully over time. The agency is
already taking related steps, having received a grant from the U.S. Department of Labor to improve
equitable access to UI programs.
OED received a federal grant to improve UI accessibility, as the pandemic highlighted
barriers to equitable UI access
OED published an equity report in 2021 that highlights inequity trends in younger workers, women, low-
paid workers, and workers identifying with one or more race or ethnicity other than white.10 These
groups were identified as being more affected by the pandemic due to the high representation of these
demographics within many of the service-based job sectors that were hit the hardest. The report
concluded lower-wage workers suffered the most job loss brought on by the pandemic.
The report also identified possible UI access barriers for workers who primarily speak a language other
than English. These access challenges could be attributed to barriers in computer or internet access,
lack of in-person assistance (WorkSource Oregon offices and public libraries were closed due to COVID-
19), and barriers accessing timely information translated in languages other than English. Additionally,
the online claims application was initially only offered in English, so benefit seekers would need to try to
contact OED by phone for assistance. However, callers struggled getting through due to the agency’s
telephone lines during the pandemic. OED reported receiving more than 20 million calls in April 2020
alone.
Oregon was one of the first states to be granted a federal UI equity access grant, in the amount of just
over $4.5 million, in early 2022. OED plans to stand up an Equitable Access to Unemployment Insurance
Business Unit to conduct outreach at the community level and assess UI equity access through routine
data analysis to identify disparities and gaps.

10 See OED Report titled ‘Disparate Impacts of the Pandemic Recession in Oregon’

Oregon Secretary of State | Report 2022-21 | July 2022 | page 30
Recommendations
To improve adjudication timeliness and potential inequities, OED should:
1. Implement formal policies and procedures for oversight of adjudicated and suspended claims
and data systems;
a. Monitor the suspended claims list and adjudication data reports that identify claim files
that have not been reviewed within a set period;
2. Incorporate controls and functionality in the modernized IT system to:
a. Reduce data errors, such as illogical dates and manual entry errors;
b. Automatically flag claims that have not been reviewed within a set period;
c. Allow secure electronic communication methods and use claimants’ preferred method
of communication;
d. Allow individuals to securely upload documents and track the progress of their claim;
e. Continue to make communication available in languages other than English;
f.
Provide accurate guidance, explanations, and tips for filling out claim applications;
3. Explore whether other state workforce agencies use texting to communicate with claimants
and consider offering texting as an option for claimants who prefer that contact method;
4. Consolidate UI information into one website with detailed, updated guidance and resources for
current and prospective claimants;
5. Establish a central repository for adjudicator guidance and assign a manager or lead worker to
regularly update that guidance;
6. Study the creation of an ombuds office to help claimants navigate the complexities of the UI
system and address unresolved claim issues, in consultation with the Governor’s Office and
other states; and
7. Continue gathering and analyzing OED data on inequities to identify and address the causes for
any confirmed inequities.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 31
Objective, Scope, and Methodology
Objective
The objective of this audit was to determine how OED Unemployment Insurance can improve its claim
adjudication process to improve average processing times for suspended and adjudicated claims and
reduce hardships and inequities.
Scope
The scope of the audit includes nonmonetary determinations related to separations for claims with a
claim date from January 2019 through December 2020.
Methodology
To address our objective, we conducted interviews or corresponded with multiple stakeholders,
including OED personnel across divisions and programs, the Legislative Fiscal Office, Department of
Administrative Services Budget Analyst, regional U.S. Department of Labor representatives, Oregon
Department of Human Services Ombuds program, and auditors from other state audit offices. We
reviewed state and federal rules related to the program and our audit objective, as well as other states’
UI program rules and published federal data. We also reviewed federal audits and reports, UI studies,
and articles. We reviewed OED policies, procedures, processes, training materials, online resources, and
other agency-provided documentation. We reviewed U.S. Department of Labor unemployment
insurance program letters, data, and published standards and requirements.
We obtained adjudicated claim data through OED that was specific to separation-related claims with
original claim dates spanning from January 2019 to December 2020. Analysis of this data determined it
was reliable enough to support our audit objectives, but with significant limitations due to a lack of
system controls, leading to data entry errors, illogical date values, and test data in the production
environment. The data on claimant demographics is also sufficiently reliable to support our objectives,
but with limitations, as claimants are not required to enter race and ethnicity information, so only some
claimants have entered that information. We are unable to determine whether differences in
adjudication timeliness for these groups are representative of all claimants from these groups or are
specific to the subset of claimants who entered their race and ethnicity information.
Internal control review
We determined that the following internal controls were relevant to our audit objective.11
•
Control activities
•
We considered whether management has designed control activities related to
adjudication timeliness and whether management has designed information
systems and related control activities to achieve objectives and respond to risks.
•
Monitoring activities

11 Auditors relied on standards for internal controls from the U.S. Government Accountability Office, report GAO-14-704G.

Oregon Secretary of State | Report 2022-21 | July 2022 | page 32
•
We considered whether management was effectively monitoring internal controls
for adjudication timeliness and whether management remediated identified internal
control deficiencies on a timely basis.
Deficiencies with these internal controls were documented in the results section of this report.
We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
We sincerely appreciate the courtesies and cooperation extended by officials and employees of OED
during the course of this audit.

About the Secretary of State Audits Division
The Oregon Constitution provides that the Secretary of State shall be, by virtue of the office, Auditor
of Public Accounts. The Audits Division performs this duty. The division reports to the elected
Secretary of State and is independent of other agencies within the Executive, Legislative, and Judicial
branches of Oregon government. The division has constitutional authority to audit all state officers,
agencies, boards and commissions as well as administer municipal audit law.

Audit team
Ian Green, M.Econ, CGAP, CISA, CFE, CIA, Audit Manager
Olivia Rechecked, MPA, Audit Manager
Steve Winn, MPP, Principal Auditor
Christina Nichols, Staff Auditor

This report is intended to promote the best possible
management of public resources.
Copies may be obtained from:
Oregon Audits Division
255 Capitol St NE, Suite 180
Salem OR 97310
(503) 986-2255
audits.sos@oregon.gov
sos.oregon.gov/audits

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