Semiannual Report to Congress, Office of Inspector General for the U.S. Department of Labor, Volume 92 (April 1, 2024–September 30, 2024)
Summary
Volume 92 of the Semiannual Report to Congress of the Department of Labor Office of Inspector General covers April 1, 2024 to September 30, 2024. Inspector General Larry D. Turner writes that several years of flat funding and the depletion of supplemental pandemic oversight funds in FY 2024 left the OIG unable to keep pandemic oversight at past levels, so it significantly curtailed new pandemic unemployment insurance (UI) fraud investigations and canceled several pandemic-related audits. For the period the OIG reports 291 investigative reports issued/cases closed, 253 indictments, 249 convictions and more than $60 million in monetary accomplishments. Since April 2020, it says, its work has secured more than 1,900 indictments or initial charges and 1,300 convictions associated with UI fraud.
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Full text
Volume 92 April 1, 2024–September 30, 2024
Semiannual Report
to Congress
Office of Inspector General for the U.S. Department of Labor
A Message from the Inspector General
I am pleased to submit our Semiannual Report to
Congress summarizing the activities of the U.S.
Department of Labor (DOL or Department), Office of
Inspector General (OIG), for the 6-month period ending
September 30, 2024.
The OIG remains committed to conducting independent
and objective oversight to assess the effectiveness,
efficiency, and integrity of DOL programs and
operations. As reflected in our semiannual report, my
office continues to highlight the major issues facing
DOL identified through the OIG’s independent audits
and investigations.
Resource Limitations
While our oversight commitment is unwavering, ongoing resource limitations have hampered
the OIG’s ability to meet its core mission while addressing the remaining challenges of
pandemic-related oversight. Several years of flat funding, along with the depletion of
supplemental pandemic oversight funds in Fiscal Year (FY) 2024, resulted in insufficient
resources to conduct pandemic-related oversight work at the same high levels as in the past.
Forced to address this funding shortfall, in FY 2024, the OIG: significantly curtailed the
initiation of new pandemic unemployment insurance (UI) fraud investigations; refocused
our data analytics program to post-pandemic programs across DOL; and canceled several
pandemic-related audits, including most of our Phase 4 work within the DOL-OIG’s Pandemic
Response Oversight Plan. These actions follow steps, which were first taken in FY 2023,
including a hiring freeze and the termination of our hotline triage contract for processing
pandemic-related UI fraud complaints.
I remain concerned these actions will have detrimental results, thus leading to fewer OIG
audits and recommendations, lost opportunities to hold fraudsters accountable, and hundreds
of millions of taxpayer dollars left unrecovered.
Statute of Limitations
The impending expiration of the statute of limitations for many pandemic-related UI fraud
cases also remains a significant concern to the OIG. As many of the statutes used to
prosecute UI fraud begin to expire in early 2025, this is the final Semiannual Report in
Semiannual Report to Congress | April 1, 2024–September 30, 2024 1
which we are able to highlight this issue. Despite dwindling resources, the OIG anticipates
continuing to investigate open pandemic-related UI fraud matters until the statute of
limitations expires. Through congressional action, the extension of the statute of limitations
would provide investigators and prosecutors the time to pursue and hold accountable those
who defrauded the UI program and victimized the American people during the pandemic.
Pivoting Priorities
Due to these challenges, the OIG has pivoted our post-pandemic oversight to focus on
priority areas such as: (1) worker benefit programs, including UI and workers’ compensation;
(2) worker safety and health, including occupational and miner safety and health and
workplace rights; and (3) employment and training programs, including grants and the Job
Corps program.
OIG Accomplishments
Despite the ongoing challenges, OIG staff continues to deliver high-quality oversight. In total,
during this reporting period, the OIG issued 14 audit reports with 27 recommendations.
Among our many significant findings, we reported:
• Due to the Employment and Training Administration’s (ETA) insufficient monitoring of
states’ reimbursements under Section 2108 of the Coronavirus Aid, Relief, and Economic
Security Act, seven states were allowed to draw down about $129.6 million in questioned
costs. To date, four states have returned $11.6 million to ETA;
• Six State Workforce Agencies (SWA) generally met the Mixed Earners Unemployment
Compensation Program (MEUC) program requirements and used the related funds as
intended by pandemic-related legislation. However, ETA did not ensure SWAs sufficiently
implemented the MEUC program;
• The Division of Energy Employees Occupational Illness Compensation (DEEOIC) could
improve its existing guidelines for processing claims. DEEOIC did not use complete
information to measure and publicly report how long it took to make claims decisions, from
start to finish, which distorted the perception of how long claimants waited for decisions. Gaps
in DEEOIC’s oversight of its decision-making processes increased the risk of errors; and
• Mine Safety and Health Administration (MSHA) district and field offices generally displayed
a consistent understanding of internal controls, policies, and procedures and conducted
oversight of miner training, including the review of the training plans submitted by mine
operators. However, MSHA could enhance its internal controls over miner training by
applying a tool already used for Metal/Nonmetal inspections to its coal mine inspections.
2 Semiannual Report to Congress | April 1, 2024–September 30, 2024
The OIG’s investigative work also continued to yield impressive results, with a total of
291 investigative reports issued/cases closed, 253 indictments, 249 convictions, and
more than $60 million in monetary accomplishments. Highlights of this work include:
• A Detroit man pled guilty to one count of conspiracy to commit wire fraud for his role in
a UI fraud scheme that targeted multiple SWAs and resulted in the loss of more than
$6 million in UI benefits;
• Three Texas defendants were sentenced to prison and ordered to pay restitution,
jointly and severally, of more than $59 million for their roles in a wide-ranging
healthcare fraud scheme;
• A federal jury found the owner and operator of a pizza restaurant chain in Massachusetts
guilty of three counts of forced labor and three counts of attempted forced labor; and
• Two Connecticut residents were sentenced for their roles in a $40 million scheme to steal
health care funds and defraud lenders.
While OIG staff members faced significant challenges during this reporting period, these
outstanding accomplishments reflect their dedication and commitment to our mission.
In closing, I would like to thank Congress and the Department for their support of our work
to identify improvements to DOL programs and operations and to protect the interests and
benefits of the nation’s workers and retirees.
Larry D. Turner
Inspector General
Semiannual Report to Congress | April 1, 2024–September 30, 2024 3
OIG Fiscal Year 2022–2026 Strategic Plan
OIG Mission
We serve the American people, DOL, and Congress by providing independent and
objective oversight of Departmental programs through audits and investigations,
and by combatting the influence of labor racketeering in the workplace.
Core Values
Excellence
We deliver relevant, quality, timely, high-impact products and services, through a
workforce committed to accountability and the highest professional standards.
Integrity
We adhere to the highest ethical principles and perform our work in an honest and
trustworthy manner.
Independence
We are committed to being free of conflicts of interest through objectivity and impartiality.
Service
We are a unified team, vigilant to duty through dedicated public service.
Transparency
We promote an environment of open communication through information sharing,
accountability, and accurate reporting.
Strategic Goals
Goal 1: Deliver timely, relevant, and high-impact results.
Goal 2: Foster an internal OIG culture that drives high performance and engagement.
Goal 3: Promote responsible stewardship of OIG financial and non-financial resources.
4 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Contents
Selected Statistics . . . . . . . . . . . . . . . . . . . . 6 Appendices . . . . . . . . . . . . . . . . . . . . . . . . 89
Funds Recommended for Better Use . . . 92
Significant Concerns . . . . . . . . . . . . . . . . . . 8
Questioned Costs . . . . . . . . . . . . . . . . . . 93
Worker and Retiree Benefit Programs . . . 31 Final Audit Reports Issued . . . . . . . . . . . 94
Unemployment Insurance Programs . . . . 32 Other Reports . . . . . . . . . . . . . . . . . . . . . 96
Office of Workers’ Compensation Unresolved Audit Reports Over 6 Months
Programs . . . . . . . . . . . . . . . . . . . . . . . . 43 Old . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
Employee Benefit Plans . . . . . . . . . . . . . 46 Management Decision Made During this
Office of Labor-Management Standards . . 47 Reporting Period on Audits, Inspections,
or Evaluations Issued during a Previous
Reporting Period: Final Audit Reports Issued
Worker Safety, Health, and Workplace
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99
Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Management Decision Made During This
Occupational Safety and Health
Reporting Period on Audits, Inspections,
Administration . . . . . . . . . . . . . . . . . . . . . 50
or Evaluations Issued During a Previous
Mine Safety and Health Administration . . 52 Reporting Period: Other Reports . . . . . . . 101
Wage and Hour Division . . . . . . . . . . . . . 54 Corrective Actions Taken by
the Department . . . . . . . . . . . . . . . . . . . . 102
Employment and Training Programs . . . . 55 Unimplemented Recommendations . . . . . 107
Employment and Training Administration 56 High-Priority Unimplemented
Foreign Labor Certification Programs . . . 57 Recommendations . . . . . . . . . . . . . . . . 108
Summary of Reports with Unimplemented
Labor Racketeering . . . . . . . . . . . . . . . . . . 59 Recommendations with Cost Savings /
Funds Put to Better Use . . . . . . . . . . . . . 112
Departmental Management . . . . . . . . . . . . 64 Reports with Unimplemented
Single Audits . . . . . . . . . . . . . . . . . . . . . . 70 Recommendations for Management
Improvement or Disallowed Costs Owed . . 114
Employee Integrity Investigations . . . . . . 73 Investigative Statistics . . . . . . . . . . . . . . . 118
Peer Review Reporting . . . . . . . . . . . . . . 120
OIG Whistleblower Activities . . . . . . . . . . 75
OIG Hotline . . . . . . . . . . . . . . . . . . . . . . . 122
Legislative Recommendations . . . . . . . . . 79
Acronyms and Abbreviations . . . . . . . . . . 123
Audit Statistics
14 27
Audits and Other Reports Issued Recommendations for Corrective Action
OIG Unimplemented Recommendations
OIG recommendations not fully implemented as of September 30, 2024
BLS 4
EBSA 2
ETA 49
MSHA 34
OASAM 12
OCFO 11
OFCCP 1
OSEC 5
OSHA 21
OWCP 3
WHD 2
0 10 20 30 40 50
6 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Investigative Statistics
Investigative Results Labor Racketeering 137/291
Program Fraud
291
253 249
137
95 87
137 investigative
2 cases opened and
291 cases closed
r r s s ry ts
s d
se ose
s d
se ene fo tion fo tion e nt i on to en
a a d u d c t u
C Cl C Op rre ec rre l A ict
m ic at rm
fe ros e fe ivi d o nv St eba
e
R P R /C In C D
s es ses min
a a d
C C A
Monetary Accomplishments
$
Types include: $1,687,042
Recoveries
Cost-Efficiencies
Restitutions
Fines/Penalties
Forfeitures
Civil Monetary Actions
$58,690,188
$60,377,230
Total Labor Racketeering
Program Fraud
Semiannual Report to Congress | April 1, 2024–September 30, 2024 7
Significant Concerns
Significant Concerns
The Office of Inspector General (OIG) has identified the following areas of significant concern
that cause the U.S. Department of Labor (DOL or Department) to be at particular risk for fraud,
mismanagement, waste, abuse, or other deficiencies. The identified areas of concern reflect continuing
matters as well as emerging issues. Many of these issues are detailed in our annual Top Management
and Performance Challenges report, which can be found in its entirety at www.oig.dol.gov.
Time Is Running Out for
Congress to Extend the Protecting Workers’
Statute of Limitations Right to Unionize
on Pandemic-Related through Enforcing
Unemployment Insurance Persuader Activity
Fraud Disclosure
Resource Constraints
Forcing the OIG to Maintaining the
Significantly Curtail Integrity of Foreign
Oversight Work, Labor Certification
Including on Pandemic Programs
Unemployment Insurance Curtailing Child Labor
Law Violations
Deploying Unemployment Managing Medical
Insurance Benefits Benefits in the
Expeditiously and Protecting the Safety and Office of Workers’
Efficiently While Reducing Health of Workers Compensation
Improper Payments Programs
Providing the OIG Protecting the Safety Ensuring the Solvency
Access to UI Claimant and Health of Miners of the Black Lung
Data and Wage Records Disability Trust Fund
Improving the
Risk of Unused Funds Ensuring the
Performance
in State UI Accounts Safety of Students
Accountability of
Not Being Returned to and Staff at Job
Workforce Development
the U.S. Treasury Corps Centers
Programs
Ensuring Reliable
Estimates for Protecting the Managing and
Unemployment Trust Fund Security of Securing Data and
Amounts Reported in the Employee Benefit Information Systems
Consolidated Financial Plan Assets
Statements
8 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Time Is Running Out for Congress to Extend the Statute of Limitations on
Pandemic-Related Unemployment Insurance Fraud
We are extremely concerned that, unless Congress acts
Even with the OIG’s tireless
urgently to extend the criminal statute of limitations for fraud
efforts, a failure to extend
associated with pandemic-related Unemployment Insurance
the current statute of
(UI) programs, many groups and individuals that have
limitations associated
defrauded the UI program may escape justice. Currently, the
with UI fraud means
statute of limitations for many pandemic-related UI fraud cases
federal law enforcement
will begin to expire in early 2025, as the statutes most often
will have to stop short
used to prosecute UI fraud have 5-year limitations. This is
of fully investigating and
the final Semiannual Report to Congress in which we plan to
prosecuting the most
highlight this issue before the statute of limitations begins to
egregious cases of UI fraud.
expire, which will significantly limit our ability to pursue justice in
these cases.
During the pandemic, the OIG was tasked with investigating an exceptional volume of complex
pandemic-related UI fraud cases that increased a thousandfold compared to pre-pandemic levels.
Since April 2020, the OIG has opened more than 209,000 investigative matters involving the UI
program. We continue to receive up to 100 new UI fraud complaints each week. Even with the
OIG’s tireless efforts, a failure to extend the current statute of limitations associated with UI fraud
means federal law enforcement will have to stop short of fully investigating and prosecuting the
most egregious cases of UI fraud.
Furthermore, the pandemic-related UI fraud referrals we receive often include complex schemes
involving criminal enterprises and bad actors who use sophisticated techniques to maintain
anonymity. As such, these investigations require significant resources and time. Supplemental
pandemic resources from Congress allowed the OIG to hire more criminal investigators and
significantly expand the number of staff reviewing UI fraud matters. Unfortunately, the OIG
has been forced to reduce staffing to below pre-pandemic levels due to the exhaustion of
supplemental funding.
Despite dwindling resources, the OIG anticipates continuing the investigation of open pandemic-related
UI fraud matters until the statute of limitations expires. However, due to resource constraints and
the pending expiration of the statute of limitations, the OIG has begun to pivot away from pandemic
UI investigations. As a result, we have significantly curtailed the opening of any new pandemic UI
fraud investigations. Further, we will continue the pause we implemented in Fiscal Year (FY) 2024
in reviewing the approximately 150,000 open pandemic UI fraud complaints we currently have
awaiting review.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 9
Significant Concerns
In August 2022, an extension of the statute of limitations was implemented for crimes involving the
U.S. Small Business Administration’s (SBA) Paycheck Protection Program (PPP) and Economic
Injury Disaster Loan (EIDL) program. Congress should likewise consider immediately extending
the statute of limitations for existing laws when pandemic-related UI programs have been
defrauded. The expansion of the statute of limitations would provide investigators and prosecutors
time to pursue and hold accountable those who defrauded the UI program and victimized the
American people during the pandemic.
Resource Constraints Forcing the OIG to Significantly Curtail Oversight Work,
Including on Pandemic Unemployment Insurance
We are concerned the actions we have had to take to
These detrimental impacts
significantly curtail our oversight work due to resource
could result in fewer audits
constraints will detrimentally impact the American taxpayer.
that identify much-needed
These detrimental impacts could result in fewer audits that
improvements in DOL
identify much-needed improvements in DOL programs
programs and operations,
and operations, lost opportunities to hold fraudsters
lost opportunities to hold
accountable, and hundreds of millions of taxpayer dollars
fraudsters accountable,
left unrecovered. The OIG expended the $38.5 million
and hundreds of millions
under the Coronavirus Aid, Relief, and Economic Security
of taxpayer dollars left
(CARES) Act and the American Rescue Plan Act of 2021 to
unrecovered.
oversee DOL’s pandemic-related programs and operations,
funds Congress had appropriated with an emphasis on
combatting the unprecedented levels of UI fraud. Our ability to continue combating UI fraud has been
further exacerbated by lower-than-expected appropriation levels for FY 2023 and FY 2024 and the
impending expiration of the statute of limitations associated with pandemic-related UI fraud.
The OIG has seen great success in its oversight work, including on pandemic-related UI fraud. Past
congressional funding was essential in the OIG being able to secure more than: 1,900 indictments
or initial charges, 1,300 convictions, 30,000 months of incarceration, and $1.1 billion in investigative
monetary outcomes associated with UI fraud since April 2020. These funds also allowed the OIG to
issue 55 audit reports that included 160 recommendations for corrective action by DOL, as well as to
identify more than: $74 billion in funds for better use and $407 million in questioned costs related to
DOL’s pandemic-related programs and operations (see Table 1).
10 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Table 1: DOL-OIG’s Cumulative Pandemic-Related Results,
April 2020–September 2024
Audit Reports 55
Recommendations 160
Funds Identified for Better Use $74 billion+
Questioned Costs $407 million+
Indictments/Initial Charges 1,900+
Convictions 1,300+
Months of Incarceration Ordered 30,000+
Investigative Monetary Results 1
$1.1 billion+
However, due to resource constraints, we have had to take the following actions:
FY 2023
• implemented a hiring freeze;
• canceled 10 pandemic-related audit performance contracts;
• terminated the hotline triage contract for processing pandemic-related UI fraud complaints;
FY 2024
• significantly curtailed the initiation of new pandemic UI fraud investigations;
• assessed ongoing investigations for potential termination due to resource constraints and the
expiration of the statute of limitations in early 2025;
• discontinued our pandemic-related UI proactive fraud data analytics program and refocused our
analytics program on post-pandemic programs across DOL;
• reduced our participation on the DOJ National UI Fraud Taskforce and COVID-19 Fraud
Enforcement Taskforce; and
• canceled certain pandemic-related audits, including almost all of our Phase 4 work within the
DOL-OIG’s Pandemic Response Oversight Plan.
Considering the significance of our resource constraints, the OIG also suspended certain non-pandemic
discretionary audits included in our FY 2024 Audit Workplan. This ensured we could operate within
FY 2024 funding levels and complete ongoing pandemic-related work. The OIG will continue using our
existing resources efficiently and effectively by applying our risk assessment process. This process
will help determine how to best focus our limited resources to provide impactful audit and investigative
oversight across all DOL agencies and programs.
1 This includes recoveries, cost-efficiencies, restitutions, fines/penalties, forfeitures, and civil monetary actions.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 11
Significant Concerns
The OIG is committed to serving the American people, DOL, and Congress by providing independent
and objective oversight of Departmental programs and operations through audits and investigations
and by combatting the influence of labor racketeering in the workplace. However, absent dedicated
funds to oversee pandemic-related programs and operations, the OIG has begun to pivot away
from pandemic-related UI oversight. We will not be able to complete the full body of work previously
outlined within our fourth and final phase of our pandemic response oversight plan, which was
intended to focus on lessons learned ahead of future emergencies. Given our expected level of
funding, we now must manage remaining limited resources while rebalancing our oversight of all DOL
programs and operations.
Deploying Unemployment Insurance Benefits Expeditiously and Efficiently While
Reducing Improper Payments
The OIG has long reported significant concerns with the
Department and state workforce agencies’ (SWA)2 ability
to deploy UI program benefits expeditiously and efficiently
while ensuring integrity and adequate oversight. Since the
onset of the COVID-19 pandemic, these concerns have
grown. Workers faced delays in receiving UI benefits,
improper payments soared, and our audit and investigative
work found program weaknesses persisted during the
pandemic and beyond—vulnerabilities that criminal
organizations continue to exploit. We remain particularly
concerned about deployment of UI benefits in response
to future emergencies, including natural disasters and
economic downturns, as well as an immediate need to
improve internal controls against fraud.3
At the start of the pandemic, we identified critical
issues, such as staffing shortages and outdated system
capabilities, for DOL and states to address while
implementing the CARES Act programs. While the
2 When referring to UI, this Semiannual Report to Congress uses “state” or “SWA” to refer to the body that
administers the program within the state, district, or territory.
3 Fraud is a type of improper payment. OMB explains that, at a high level, a payment is “improper” if made in
an incorrect amount or to the wrong recipient. Improper payments can result in a money loss that was either
unintentional (accidental) or intentional (fraud). For more information, see OMB, Appendix C to OMB Circular A-123,
Requirements for Payment Integrity Improvement, Memorandum (March 5, 2021), last accessed September 27, 2022,
available at: https://www.whitehouse.gov/wp-content/uploads/2021/03/M-21-19.pdf.
12 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Employment and Training Administration (ETA) and states made significant efforts to improve the
program, challenges persist in reducing improper payments and ensuring timely benefit distribution.
For example, despite improvements in payment timeliness since the end of the pandemic4, only
24 percent of reporting states were paying regular UI claimants on time in June 2024, compared
to 75 percent before the pandemic started.5
Furthermore, the fraud risk to the UI program did not end with the pandemic. The program remains
a target for criminals using sophisticated and ever-evolving fraud schemes. While the Department
and states have implemented multiple tools and measures to prevent fraud, both foreign and
domestic criminal organizations continue to exploit of system weaknesses, raising serious concerns
about program integrity and the effectiveness of state-level controls. For example, state UI systems’
controls were unable to prevent criminal organizations from exploiting security flaws to change
payment information, diverting benefits payments into their own accounts. Unless more is done at
the federal and state levels to increase systemic integrity, the program’s weaknesses will continue
to expose American taxpayers and workers to significant financial risks and losses.
Reducing Improper Payments, Including Fraud
For over 20 years, the OIG has reported on weaknesses in the Department’s ability to measure,
report, and reduce improper payments in the UI program, which has experienced some of the highest
improper payment rates across the federal government. For 17 of the last 20 years,6 the reported
estimated improper payment rate for the regular UI program has exceeded 10 percent.7
Over the last 3 years, DOL reported historically high rates of UI improper payments.
Specifically, DOL reported an estimated improper payment rate of 18.71 percent for FY 2021
and 21.52 percent for FY 2022. Based on our audit and investigative work, the actual improper
payment rate for these periods was likely higher. According to the ETA, the rates for the regular UI
program were also applied to pandemic programs, and the rates likely did not capture the actual
improper payment rate for the temporary programs8. Although the FY 2023 estimated improper
4 Payment timeliness has improved since the pandemic, with the national rate of timely first payments rising from
57.8 percent in FY 2022 to 72.4 percent by the third quarter of FY 2024. However, despite these gains, further
improvements are needed as states are challenged in meeting payment timeliness standards due to the new identity
verification processes, essential for fraud prevention.
5 Based on OIG analysis of data on the Employment and Training Administration’s public reporting on States’ UI
Benefit Timeliness and Quality, available at: https://oui.doleta.gov/unemploy/btq.asp.
6 UI improper payments data for FY 2004-FY 2023 as reported to the Office of Management and Budget.
7 To fully comply with the Payment Integrity Information Act of 2019, agencies must report an improper payment rate
of less than 10 percent for each program and activity for which an estimate was published.
8 ETA applied the improper payment rate to the Federal Pandemic Unemployment Compensation program and the
Pandemic Emergency Unemployment Compensation program, which paid over $530 billion in UI benefits.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 13
Significant Concerns
payment rate was reported as 14.83 percent, this rate still exceeds pre-pandemic levels and fails
to meet federal requirements.
In February 2023,9 Inspector General Larry D. Turner testified to Congress that an estimated
$191 billion in UI benefits during the pandemic period could have been paid improperly, with a
significant portion attributable to fraud. This unprecedented loss underscores the urgent need for
systemic improvements and the importance of recovery efforts to mitigate the financial impact on
both states and the federal government.
In August 2023, we started assessing the effects of waivers, including blanket waivers, on the
recovery of UI overpayments, including fraud. While DOL provided guidance stating recovery of
fraudulent payments may not be waived, we remain concerned states may have unintentionally
waived or will waive fraudulent payments. In December 2023, ETA issued guidance allowing states
to apply their finality laws to pandemic-related UI programs. This guidance provides that states may
defer to state law to limit the time period in which a state is required to reconsider a prior decision or
determination made with regard to pandemic UI claims. Alongside overpayment waivers, allowing
states to apply finality laws raises concerns about incentives for states to identify and recover
improper payments. Furthermore, if states are not required to investigate cases beyond the finality
period, fraud might go undetected and unprosecuted.
Combatting Large-Scale Fraud
During the COVID-19 pandemic, the UI program became an attractive target for fraud, a problem
that persists today. Criminal groups—including malicious cyber-enabled10 bad actors and those
operating outside the United States—continually adapt their tactics to exploit systemic weaknesses
in the UI program.
States face a wide range of sophisticated fraud schemes, including: claims filed using fraudulent,
stolen, or false identities; traditional eligibility fraud; “claims hijacking” or “claims/account takeovers”
(where criminals change bank account or address information on a legitimate claim to intercept UI
benefits); and cyber-attacks, such as phishing, social engineering, and bot attacks that overwhelm state
UI systems. Criminals have even created duplicate state UI websites and social media pages to steal
personally identifiable information (PII) and account access information like usernames and passwords.
9 “The Greatest Theft of American Tax Dollars: Unchecked Unemployment Fraud,” Hearing, Statement for the
Record of Larry D. Turner, Inspector General, U.S. Department of Labor; House Committee on Ways and Means
(February 8, 2023), available at: https://www.oig.dol.gov/public/testimony/02082023.pdf
10 Per Executive Order 13984, issued January 19, 2021, “malicious cyber-enabled activities” refers to activities,
other than those authorized by or in accordance with United States law that seek to compromise or impair the
confidentiality, integrity, or availability of computer, information, or communications systems, networks, physical or
virtual infrastructure controlled by computers or information systems, or information resident thereon.
14 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Our investigators have identified extensive criminal activity linked to UI fraud, both domestically and
internationally. Since April 1, 2020, this includes over 1,900 UI-related indictments/initial charges,
which implicated criminals in organized groups whose members and associates engaged in acts
involving murder, assault, narcotics trafficking, identity theft, and other crimes. Furthermore, our
investigators, auditors, and data scientists collaboratively identified11 $46.9 billion in potentially
fraudulent UI benefits paid in six high-risk areas involving claims with Social Security numbers:
• filed in multiple states,
• of deceased persons,
• of federal prisoners,
• used to file for UI claims with suspicious email accounts,
• belonging to individuals under 14 years of age, and
• belonging to individuals 100 years of age or older.
The sheer scale of UI fraud highlights the urgent need for systemic improvements, including updated
technology, and, according to ETA, increased funding. If left unaddressed, the UI program will remain
vulnerable to exploitation by increasingly advanced criminal schemes.
Providing the OIG Access to UI Claimant Data and Wage Records
Barriers to the OIG’s ongoing, timely, and complete access to UI
Barriers to the OIG’s
claimant data and wage records from SWAs for both regular and
ongoing, timely, and
emergency UI programs remain a significant concern. This situation
complete access
adversely impacts the OIG’s ability to provide independent oversight,
to UI claimant data
to combat fraud, waste, and abuse, and to otherwise help DOL
and wage records
improve the integrity of the UI program. The primary barrier to such
from SWAs for
access is from DOL’s interpretation of its own regulations, including
both regular and
a historical view that such access be restricted to specific suspected
emergency UI
instances of fraud. This interpretation and subsequent guidance to
programs remain a
SWAs contradicts the Inspector General Act of 1978, as amended,
significant concern.
which authorizes mandatory Inspector General access to information
available to DOL, including grant recipient information related to DOL
programs such as SWAs’ UI data. DOL has taken steps to ensure
temporary access and is engaged in rulemaking.
11 Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to Improve Oversight of the
Unemployment Insurance Program, Report No. 19-23-012-03-315 (September 25, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-012-03-315.pdf
Semiannual Report to Congress | April 1, 2024–September 30, 2024 15
Significant Concerns
However, in our September 2022 alert memorandum,12 the OIG highlighted DOL’s authority to amend
its interpretation of its regulations without changing the regulations themselves. Specifically, ETA
can issue guidance to inform SWAs they must timely provide UI data and wage records without any
constraints to the OIG for audits and investigations consistent with the Inspector General Act of 1978,
as amended. The historic levels of improper payments the OIG has identified, including potential
fraud, support the conclusion that the OIG’s continued access to state UI data is imperative.
While DOL is in the process of amending regulations to facilitate the OIG’s ongoing access to UI
data and wage records, the OIG is authorized and needs to have timely access without constraints
to this data and these records. Ongoing, timely, and complete access to SWA UI claimant data
and wage records would further enable the OIG to quickly identify large-scale fraud and expand its
current efforts to share emerging fraud trends with ETA and states to strengthen the UI program
and deter fraud.
Risk of Unused Funds in State UI Accounts Not Being Returned to the U.S. Treasury
We remain concerned that a significant amount of pandemic-related federal funding remains in
state UI accounts. For example, in two CARES Act UI programs—Temporary Full Federal Funding
of the First Week of Compensable Regular Unemployment for States with No Waiting Week (TFFF)
and Emergency Unemployment Relief for Governmental Entities and Nonprofit Organizations
(EURGENO)—we identified the need for reconciliation of more than $5 billion.13
Specifically, during our audit of TFFF, we identified the Department made approximately $12.5 billion
of funding available in the 53 SWAs’ invested Federal Unemployment Accounts.14 Overall, the
53 SWAs drew down about $7.5 billion of the approximately $12.5 billion made available, leaving
nearly $5 billion (40 percent) unused as of July 31, 2023—more than 22 months after the benefit
eligibility period expired. To reduce unused funds’ vulnerability to fraud, waste, and abuse, the
12 Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments in High-Risk Areas Increased to
$45.6 Billion, Report No. 19-22-005-03-315 (September 21, 2022), available at:
https://www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-315.pdf
13 COVID-19: ETA Needs a Plan to Reconcile and Return to the U.S. Treasury Nearly $5 Billion Unused by States
for a Temporary Unemployment Insurance Program, Report No. 19-23-015-03-315 (September 28, 2023), available
at: https://www.oig.dol.gov/public/reports/oa/2023/19-23-015-03-315.pdf; and COVID-19: Unemployment Relief For
Governmental Entities and Nonprofit Organizations Should Have Been Better Managed,
Report No. 19-23-010-03-315 (September 21, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-010-03-315.pdf
14 Treasury transfers funds from the general fund to the Federal Unemployment Account in amounts estimated by
the Department to be necessary to reimburse the states for first week regular UI compensation paid. The Federal
Unemployment Account is an account within the federal UI trust fund that pays for the costs to administer the UI
program, emergency benefits, loans to state trust funds, and program expansions like the CARES Act.
16 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Department needs to ensure that states reconcile and close out these accounts and return the funds
to the U.S. Treasury.
Furthermore, during our audit of EURGENO, we identified the Department made approximately
$6.3 billion of relief funds available to the 53 SWAs’ UI trust funds. Our audit identified that, 16 months
after EURGENO ended,15 approximately $844.1 million of EURGENO relief funds (19 percent of the
total $4.5 billion allocated) remained unused in 32 states’ UI trust funds. Given that this data does not
include 21 SWAs, there could potentially be millions of dollars more remaining in other states’ UI trust
funds that need to be returned to the federal government.
Ensuring Reliable Estimates for Unemployment Trust Fund Amounts Reported in
the Consolidated Financial Statements
In November 2024, DOL received its fourth
The OIG is concerned DOL has
consecutive qualified opinion and material weakness
been unable to remediate its
on its consolidated financial statements. This
material weakness over estimates
happened due to the agency’s inability to provide
for certain reported Unemployment
sufficient appropriate audit evidence about the
Trust Fund amounts, hampering
methodology and underlying assumptions used to
its ability to obtain an unqualified
estimate certain COVID-19-pandemic-related UI
opinion on the consolidated
amounts. Although the UI pandemic programs expired
financial statements.
at the end of FY 2021, there continues to be UI benefit
disbursement and related activities reported in DOL’s
financial statements. As of September 30, 2024, the financial statements included estimates
of $7.0 billion in Unemployment Trust Fund obligations of COVID-19 funding and $10.0 billion
in COVID-19 benefit overpayment receivables. The OIG is concerned DOL has been unable
to remediate its material weakness over estimates for certain reported Unemployment Trust
Fund amounts, hampering its ability to obtain an unqualified opinion on the consolidated
financial statements.
The preparation of the financial statements requires management to make certain estimates and
assumptions related to the UI pandemic programs that affect amounts it reports therein. In FY 2021,
DOL first reported an estimated obligation on its financial statements for future outlays of certain
UI claims. These claims were for unemployed weeks that occurred prior to the expiration of the UI
COVID-19 pandemic programs that were still in appeal or had not yet been processed. DOL also
reported on its financial statements an estimate for UI benefit overpayment accounts receivable
for those SWAs that had not reported any benefit overpayment receivables to DOL. However, DOL
15 The EURGENO program ended on September 6, 2021. As of February 1, 2023, the total balance for the 32 states
remained at approximately $844.1 million.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 17
Significant Concerns
has not developed sufficient processes or controls to properly validate the reasonableness of the
methodology and assumptions used to develop the estimates that were still being reported in its
financial statements in FY 2024.
Curtailing Child Labor Law Violations
Collectively, U.S. labor laws cover most private, state, and local government employment and protect
more than 165 million of America’s workers in more than 11 million workplaces. The Fair Labor
Standards Act of 1938 sets standards for minimum wage and overtime, among others, including
youth employment. Enforced by DOL’s Wage and Hour Division (WHD), the standards for youth
employment are commonly known as child labor laws and are meant to ensure youth employment is
safe, appropriate, and does not jeopardize youth health, wellbeing, or educational opportunities. We
are concerned about the rise in child labor law violations and some recent changes in state child labor
protections with additional proposals pending.
In FY 2023, DOL concluded 955 investigations that found child labor violations—a 14 percent
increase from the previous year. DOL found nearly 5,800 children employed in violation of the law—
an 88 percent increase within the last 5 years. In addition, DOL assessed more than $8 million in
related penalties—an 83 percent increase from the previous year. Notably, this increase in child
labor law violations is occurring while budget appropriations have generally been flat and the agency
struggles to retain investigators. To address the increase in violations, DOL has spearheaded an
interagency task force to combat child labor exploitation and engaged in other federal and local
collaboration to improve the safety of working minors.
However, further complicating the issue, two laws recently passed in Arkansas and Iowa reduced
state child labor protections. Similarly, in 2023, multiple bills to weaken child labor protections were
introduced in Minnesota, Missouri, Nebraska, Ohio, and South Dakota. Furthermore, in 2024,
Alabama, Florida, Indiana, Iowa, Kentucky, and West Virginia all enacted legislation to weaken child
labor protections. We are currently examining WHD’s efforts to curtail child labor law violations and
are attempting to determine the cause for the rise of these violations. Our ongoing audit will identify
high-risk areas of child labor for additional oversight in FY 2025 and beyond.
Protecting the Safety and Health of Workers
Responsible for the safety and health of approximately 130 million workers employed at more
than 8 million worksites, the Occupational Safety and Health Administration (OSHA) must ensure
employers are providing the level of protection required under relevant laws and policies. Failure to
keep workplaces free of known safety and health hazards can lead to serious legal consequences,
injuries, illnesses, and fatalities. The OIG remains concerned about OSHA’s ability to target its
compliance activities to areas where it can have the greatest impact.
18 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
OSHA carries out its compliance responsibilities through a combination of self-initiated inspections
and those resulting from complaints and referrals. For FY 2023, OSHA reported conducting 34,273
inspections, including 17,480 unprogrammed inspections. Unprogrammed inspections result from
employee complaints, injuries/fatalities, and referrals. OSHA must target the most egregious or
persistent violators to protect the most vulnerable worker populations. OSHA has since increased its
number of inspectors—from 750 in 2021, to 846 as of February 29, 2024. However, OSHA continues
to be challenged with reaching the number of worksites for which it is responsible.
As we reported in 2023,16 OSHA’s targeting programs that were specifically designed to reach workplaces
with high rates of serious injuries have internal control weaknesses. Few inspections of targeted
establishments meant workers remained vulnerable to continuously high rates of injury and illness.
Further, OSHA’s ability to target enforcement is also
We found, on average,
impacted by its limited visibility into the numbers and types
between 2016 and 2020,
of injuries and illnesses occurring in warehouses, including
59 percent of establishments
those classified as online retailers. We found, on average,
in all industries failed to
between 2016 and 2020, 59 percent of establishments in
submit their mandatory
all industries failed to submit their mandatory annual injury
annual injury and illness
and illness reports to OSHA. Additionally, OSHA could not
reports to OSHA.
identify if an establishment met the criteria for mandatory
reporting and, therefore, could neither proactively remind
specific establishments that they must report, nor effectively
cite employers for non‑compliance. Establishments’
non‑reporting continues to be a challenge for OSHA and
results in an incomplete view of workplace injury and illness.
Protecting the Safety and Health of Miners
The Mine Safety and Health Administration’s (MSHA) mission is to prevent death, injury, and illness
from mining and promote safe and healthful workplaces for U.S. miners. The OIG is significantly
concerned about four aspects of MSHA’s ability to successfully fulfill its mission: (1) conducting
inspections; (2) writing violations for identified hazards; (3) reducing fatalities; and (4) improving the
frequency of MSHA’s sampling for silica.
First, we are concerned about MSHA’s ability to conduct inspections. The Federal Mine Safety and
Health Act of 1977 requires MSHA to inspect every underground mine at least four times per year and
16 COVID-19: OSHA Needs to Do More to Address High Injury Rates of Warehouse Workers,
Report No. 19-23-013-10-105 (September 27, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-013-10-105.pdf
Semiannual Report to Congress | April 1, 2024–September 30, 2024 19
Significant Concerns
every surface mine at least two times per year. A 2023 OIG audit17 found MSHA did not complete an
estimated 1,589 mandatory inspections during FY 2018 through FY 2021 despite reporting a nearly
100 percent completion rate.
Subsequently, MSHA agreed to transparently report each year the number of attempted inspections
caused by either a mine not operating at the time of the inspector’s visit or a mine operator denying
an MSHA inspector entry to the mine. However, accurate reporting will remain a concern for the OIG
until we can verify MSHA’s reporting changes. Further, agency data contains inaccurate operating
statuses for some mines. Inaccurate operating statuses are of serious concern because it can lead to
MSHA not conducting required inspections, thereby risking miner safety.
Second, we are concerned about
MSHA’s ability to write violations
for hazards it identifies during
inspections. An OIG audit18 found
MSHA inspectors were not writing
violations that adhered to the
Federal Mine Safety and Health
Act of 1977 and MSHA guidance
for two reasons: (1) they were
not following the guidance and
(2) system controls were missing
or improperly designed. We also
found MSHA inspectors were
extending violations for unjustified
reasons and not timely verifying
whether mine operators had
abated hazards by required due dates. This was generally due to inspectors being responsible for
mines located across large geographic areas and not revisiting the mines by the due dates. This
concern is compounded by MSHA’s lack of implementing the OIG’s nine recommendations from 2019
to improve MSHA’s pre-assessment conferencing program, in which mine operators can challenge
violations they feel MSHA inspectors did not write correctly.19
17 COVID-19: MSHA Did Not Complete or Accurately Report Mandatory Inspections, Report No. 19-24-001-06-001
(October 17, 2023), available at: https://www.oig.dol.gov/public/reports/oa/2024/19-24-001-06-001.pdf
18 MSHA Can Improve How Violations Are Issued, Terminated, Modified, and Vacated,
Report No. 05-21-002-06-001 (March 31, 2021), available at:
https://www.oig.dol.gov/public/reports/oa/2021/05-21-002-06-001.pdf
19 MSHA Can Improve Its Pre-Assessment Conferencing Program, Report No. 05-19-001-06-001 (September 23, 2019),
available at: https://www.oig.dol.gov/public/reports/oa/2019/05-19-001-06-001.pdf
20 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Third, we are concerned about the level of miner fatalities in two areas. According to MSHA’s data,
powered haulage and machinery accidents are the leading causes of miner fatalities (see Figure 1).
These accidents have accounted for more than half of all mine fatalities for nearly 7 years.
Figure 1: Number and Percentage of Top 8 Classes of Mining Fatalities,
Calendar Years 2018–2024
Powered Haulage 67 32%
Machinery 56 27%
Slip or Fall of Person 16 8%
Other 14 7%
Electrical 12 6%
Fall of Roof or Back 10 5%
Falling/Sliding/Rolling 4%
9
Materials
Fall of Face/Rib/Pillar/Side/ 8 4%
Highwall
0 10 20 30 40 50 60 70
Source: MSHA’s Accident Injuries public dataset, as of August 30, 2024
On January 19, 2024, MSHA’s final rule for the Safety Program for Surface Mobile Equipment
became effective. The rule requires mine operators to develop, implement, and update written safety
programs describing the actions it will take to identify hazards and risks to reduce accidents, injuries,
and fatalities related to surface mobile equipment. This final rule is a positive mitigating step in
conjunction with the performance of other prevention outreach. However, we will remain concerned
with the high number of powered haulage and machinery fatalities until the data shows a consistent
decline in these incidents.
Finally, we remain concerned regarding how often MSHA is sampling for the presence of respirable
crystalline silica. MSHA published a final rule on April 18, 2024, lowering the permissible exposure
limit for respirable crystalline silica for all miners. This rule also includes other requirements to protect
miner health, such as exposure sampling, corrective actions to be taken when a miner’s exposure
exceeds the permissible exposure limit, and medical surveillance for metal and nonmetal mines.
While this rule should help reduce occupational disease in miners and improve respiratory protection
against airborne contaminants, the frequency of sampling performed by inspectors must be sufficient
to address higher risk levels at mines.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 21
Significant Concerns
In our November 2020 audit report,20 we noted MSHA generally performed sampling during its
mandatory inspections conducted quarterly for underground coal mines and semiannually for surface
mines. Because silica levels can fluctuate, we have concerns regarding whether this frequency
is enough to ensure the safety of miners at high-risk mines. Therefore, we recommended MSHA
enhance its sampling program to increase the frequency of inspector samples where needed, such as
through implementation of a risk-based approach. While MSHA agreed to study this recommendation
and determine the necessity of increasing the frequency of inspector sampling by November 2021, it
has yet to provide the results of that study or any corrective actions.
Ensuring the Safety of Students and Staff at Job Corps Centers
Ensuring the safety and health of students and staff at Job Corps
Preventing on-campus
centers—which are mostly residential, with students living on-campus—
violence and other
continues to be a concern due to ongoing issues with on-campus
potentially criminal
violence. In Program Year 2022, Job Corps centers reported almost
behavior remains a
1,300 on-campus assaults. Preventing on-campus violence and
challenge for Job
other potentially criminal behavior remains a challenge for Job
Corps centers.
Corps centers.
The use of fentanyl, a synthetic opioid that has rapidly become the leading cause of overdose
death in the United States since 2016, and other dangerous drugs is also a significant concern
within the Job Corps program. In Program Year 2022, 6 Job Corps students died of suspected
unintentional drug overdoses, with 3 occurring on campus. Our analysis of Job Corps data for
Program Year 2022 also identified 5 students and 1 staff who had to be revived from a suspected
drug overdose after being found unresponsive. A March 2021 OIG audit report showed Job Corps
centers lacked the appropriate tools and resources to properly evaluate and mitigate issues related
to substance abuse and mental health, which center personnel frequently attributed to causing
student and staff safety concerns.
The significant age range of Job Corps students21 can also pose challenges. Given the occurrence
of sexual assaults and harassment on center campuses, there is an inherent risk with having adults
co-enrolled with minors. The OIG will soon resume an audit focused on whether Job Corps ensured
the safety of and mitigated program disruptions involving its minor students. The OIG also continues
to monitor various safety initiatives and actions taken by Job Corps to keep students and staff safe.
20 MSHA Needs to Improve Efforts to Protect Coal Miners from Respirable Crystalline Silica,
Report No. 05-21-001-06-001 (November 12, 2020), available at:
https://www.oig.dol.gov/public/reports/oa/2021/05-21-001-06-001.pdf
21 Per the Workforce Innovation and Opportunity Act, individuals aged 16 through 24 years are eligible to enroll in
Job Corps and, once enrolled, can be in training for up to 3 years before finishing the program.
22 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
Protecting the Security of Employee Benefit Plan Assets
The OIG remains concerned about the Employee Benefits Security Administration’s (EBSA) ability
to protect the integrity of pension, health, and other benefit plans of more than 156 million workers,
retirees, and their families under the Employee Retirement Income Security Act of 1974 (ERISA).
In particular, the OIG is concerned about the statutory limitations on EBSA’s oversight authority and
inadequate resources to conduct compliance and enforcement. From FY 2018 to FY 2023, EBSA’s
resources dropped 19 percent from 404 to 326 frontline staff.22 As a result, EBSA needs to focus its
limited available resources on investigations that are most likely to result in the prevention, detection,
and correction of ERISA violations. This is particularly important given the number of benefit plans
EBSA oversees relative to the number of investigators it employs. This concern is increased given
volatility and instability in cryptocurrency and other digital assets.
A decades-long challenge to EBSA’s compliance program, ERISA provisions allow billions of dollars
in pension assets to escape full audit scrutiny. ERISA generally requires every employee benefit
plan with more than 100 participants to obtain an audit of the plan’s financial statements each year.
However, an exemption in the law allowed auditors to perform “limited-scope audits.” These audits
excluded pension plan assets already certified by certain banks or insurance carriers and provided
little to no confirmation regarding the actual existence or value of the assets.
Past OIG work23 revealed that approximately $3 trillion in pension assets—including an estimated
$800 billion to $1.1 trillion in hard-to-value alternative investments—received only limited-scope
audits. According to EBSA, the pension asset amount increased to $5.3 trillion as of 2022. In 2019,
the American Institute of Certified Public Accountants updated its accounting standards,24 replacing
limited-scope audits and imposing new performance requirements. We will follow up on our previous
work on EBSA’s oversight of limited-scope audits.
Further, EBSA lacks the authority under the Federal Employees’ Retirement System Act to effectively
oversee hundreds of billions of dollars in federal employee Thrift Savings Plan (TSP) assets.25 EBSA
has limited legal authority to compel the Federal Retirement Thrift Investment Board to implement its
recommendations, which includes enforcing its recommendations to improve the TSP’s cybersecurity
posture. As a significant portion of the TSP’s infrastructure was recently transferred to an outside
22 EBSA’s frontline staff includes investigators, auditors, and senior investigators who are responsible for detecting
and correcting any and all ERISA violations.
23 EBSA Needs to Provide Additional Guidance and Oversight to ERISA Plans Holding Hard-to-Value Alternative
Investments, Report No. 09-13-001-12-121 (September 30, 2013), available at:
https://www.oig.dol.gov/public/reports/oa/2013/09-13-001-12-121.pdf
24 ERISA Section 103(a)(3)(C)
25 The total value of TSP assets fluctuates over time and is affected by market volatility.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 23
Significant Concerns
third-party vendor, we are concerned about the threat cybersecurity breaches pose to the TSP. More
generally, identifying and mitigating cyber threats requires a high degree of technical expertise. Cyber
threats potentially place at risk trillions of dollars in other ERISA-covered retirement plan assets.
Complicating the cyber landscape, EBSA has been cautioning investors about the volatility and instability
of cryptocurrencies; expressed custodial, recordkeeping, and valuation concerns; and indicated that
these investments are subject to significant risks of fraud, theft, and loss. In March 2022, EBSA issued
a Compliance Assistance Release26 cautioning plan fiduciaries to exercise extreme care before they
consider adding a cryptocurrency option to a 401(k) plan’s investment menu for plan participants.
In FY 2025, we plan to review EBSA’s oversight of cryptocurrency options within retirement plans.
Protecting Workers’ Right to Unionize through Enforcing Persuader Activity
Disclosure
We are concerned the Office of Labor-Management Standards (OLMS) does not have the necessary
tools to deter violations or enforce compliance to protect workers’ rights to unionize. OLMS is
responsible for enforcing requirements under the Labor-Management Reporting and Disclosure Act
of 1959 for disclosing persuader activity when an employer hires someone to influence an employee
regarding unionization. Timely, complete, and accurate receipt and subsequent disclosure of this
information enables employees to protect their rights and interests to unionize. This transparency, in
turn, helps union members to self-govern and workers to determine whether to exercise their rights to
organize and bargain collectively.
In May 202427, we reported OLMS did not effectively enforce persuader activity requirements to
protect workers’ rights to unionize. Specifically, OLMS did not effectively ensure required persuader
activity reports were filed and employers and consultants that filed did so timely and accurately.
In addition, OLMS did not ensure it addressed tips provided by the public and did not effectively
coordinate with the National Labor Relations Board (NLRB) to obtain information related to persuader
activities. These issues occurred because OLMS: (1) had limited enforcement authority; (2) lacked
sufficient policies, procedures, and systems for monitoring reports and tips; and (3) did not fully
implement processes for sharing information and resources with NLRB.
26 U.S. Department of Labor, Employee Benefits Security Administration, Compliance Assistance Release
No. 2022-01: 401(k) Plan Investments in “Cryptocurrencies” (March 10, 2022), available at:
https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/compliance-
assistance-releases/2022-01
27 OLMS Can Do More to Protect Workers’ Rights to Unionize Through Enforcing Persuader Activity Disclosure,
Report No. 09-24-002-16-001 (May 3, 2024), available at:
https://www.oig.dol.gov/public/reports/oa/2024/09-24-002-16-001.pdf
24 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
In response to our audit, OLMS took steps to implement quality control measures, policies and
procedures, and collaborative processes for sharing persuader activity and other relevant information
with the NLRB, among other improvements. However, OLMS’ limited enforcement authority, such as
the ability to levy fines and penalties, gives employers and consultants little incentive to comply.
Maintaining the Integrity of Foreign Labor Certification Programs
The DOL foreign labor certification (FLC) programs
are intended to permit U.S. employers to hire
foreign workers to meet their workforce needs while
protecting U.S. workers’ jobs, wages, and working
conditions. DOL’s administration of FLC programs
under current laws has been a concern for the OIG for
decades. Our work has shown these visa programs—
in particular the H-1B program for workers in specialty
occupations—to be susceptible to significant fraud
and abuse from perpetrators, including immigration
agents, attorneys, labor brokers, employers, and
organized criminal enterprises.
DOL continues to have limited authority over the H-1B
program and permanent employment certification
program (PERM), which challenges the goal of
protecting the welfare of the nation’s workforce. The
statute limits DOL’s ability to deny H-1B applications
and to investigate potential violations. Specifically, DOL
may only deny incomplete and obviously inaccurate
H-1B applications and has only limited authority to
conduct H-1B investigations in the absence of a
complaint. Without statutory authority, the Department
generally cannot verify employers’ attestations to the
H-1B certifications unless a complaint is filed or the
Department utilizes a Secretary-certified investigation.
As some foreign workers may be reluctant to file
complaints for fear of retaliation and losing their
jobs, the Department’s process is unlikely to result in
verification action being taken.
Some employers exploit FLC program vulnerabilities to
facilitate labor trafficking—a type of human trafficking—
Semiannual Report to Congress | April 1, 2024–September 30, 2024 25
Significant Concerns
sometimes committing FLC fraud to do so. Engaging in the FLC process allows prospective
employers to recruit able, willing, skilled, motivated, and legally well-intentioned workers, and also
entice them to the jobsite. This saves the employer from paying costly human smuggling expenses
and limits liability associated with smuggling or the harboring of undocumented workforces.
Once the workers are onsite, the employer can control/compel labor and services by: holding
workers’ travel documents; threatening to revoke their visas and “blacklisting” them in the future;
controlling how much money they possess; and limiting their access to adequate food, housing,
or outside contact. For example, in an ongoing OIG investigation,28 16 individuals have pled guilty
and 13 individuals have been sentenced to date as part of a federal racketeering conspiracy, which
victimized agricultural workers from Mexico and Guatemala admitted to the United States under
the H-2A temporary visa program. The investigation revealed the conspirators were able to commit
multiple offenses, including subjecting H-2A workers to forced labor, harboring and concealing
workers, visa fraud, and fraud in foreign labor contracting. Because criminals can exploit FLC
program weaknesses to expose people to forced labor and labor trafficking, it is vital that the
Department take all action possible to ensure the integrity of these programs.
Managing Medical Benefits in the Office of Workers’ Compensation Programs
The OIG has concerns about the Office of Workers’ Compensation Programs’ (OWCP) ability to
effectively manage the use and cost of pharmaceuticals in the Federal Employees’ Compensation
Act (FECA) program and about rising home health care costs in the Energy Employees Occupational
Illness Compensation Program Act (Energy) program. The Department needs to ensure the medical
benefits it provides to FECA claimants and energy workers are safe, effective, medically necessary,
and economical.
Our audit work in the FECA program continues to identify concerns with OWCP’s management of
pharmaceuticals. In March 2023,29 we reported OWCP did not effectively manage pharmaceutical
spending in the FECA program from FY 2015 through FY 2020. Specifically, OWCP did not pay the
best available prices for prescription drugs resulting in up to $321 million in excess spending during
the audit period. We also found OWCP failed to timely identify and address emerging issues and did
28 DOJ, U.S. Attorney’s Office, Southern District of Georgia, “Human Smuggling, Forced Labor Among Allegations
in South Georgia Federal Indictment,” press release (November 22, 2021), available at: https://www.justice.gov/
usao-sdga/pr/human-smuggling-forced-labor-among-allegations-south-georgia-federal-indictment; and DOJ,
U.S. Attorney’s Office, Southern District of Georgia, “Three Men Sentenced to Federal Prison on Charges Related to
Human Trafficking,” press release (March 31, 2022), available at:
https://www.justice.gov/usao-sdga/pr/three-men-sentenced-federal-prison-charges-related-human-trafficking
29 OWCP Did Not Ensure Best Prices and Allowed Inappropriate, Potentially Lethal Prescriptions in the FECA
Program, Report No. 03-23-001-04-431 (March 31, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/03-23-001-04-431.pdf
26 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
not perform sufficient oversight of prescription drugs that are highly scrutinized and rarely covered in
workers’ compensation programs.
In March 2021, consistent with our prior audit While using a pharmacy benefit
recommendations, OWCP implemented a pharmacy manager may improve OWCP’s
benefit manager30 responsible for FECA pharmaceutical management of pharmaceuticals,
transactions, including pricing for prescription drugs. In OWCP needs to provide
addition, OWCP expanded pharmacy benefit manager adequate oversight over the
coverage to the Energy and Black Lung Benefits pharmacy benefit manager
programs. While using a pharmacy benefit manager to ensure the pharmaceutical
may improve OWCP’s management of pharmaceuticals, benefits it provides are safe,
OWCP needs to provide adequate oversight over the
effective, medically necessary,
pharmacy benefit manager to ensure the pharmaceutical and economical.
benefits it provides are safe, effective, medically
necessary, and economical.
In May 2024,31 we reported OWCP could improve its medical claims processing in the Energy
program. For example, we found OWCP did not use complete information to measure and publicly
report how long it took to make claims decisions, from start to finish. This distorted the perception
of how long claimants waited for decisions needed to receive compensation and medical expense
coverage. Our analyses showed wait times for final decisions increased from an average of 182 days
in FY 2018 to 207 days in FY 2022, even though there were fewer final decisions to process.
In the Energy program, with an aging claimant population and an increased demand for home health
care services, there is a risk of providers exploiting these benefits through unethical practices. Since
2010, home and residential health care costs paid by the Energy program have grown from almost
$100 million to more than $1.1 billion in FY 2023. OWCP needs to continue its efforts to analyze
home health care billing for abusive practices and to identify and refer allegations involving potential
fraud or abuse to the OIG for further investigation.
Ensuring the Solvency of the Black Lung Disability Trust Fund
Miners and their dependent survivors receive lifetime benefits when awarded under the Black Lung
Benefits Act. Mine operators pay these benefits when possible, and the Black Lung Disability Trust
30 Pharmacy benefit managers are third-party administrators of prescription drug programs, primarily responsible
for: developing and maintaining formularies, which include an approved listing of prescriptions; negotiating discounts
and rebates with drug manufacturers; and processing and paying prescription drug claims.
31 OWCP Could Improve its Existing Guidelines for Processing DEEOIC Claims, Report No. 09-24-001-04-437
(May 2, 2024), available at: https://www.oig.dol.gov/public/reports/oa/2024/09-24-001-04-437.pdf
Semiannual Report to Congress | April 1, 2024–September 30, 2024 27
Significant Concerns
Fund (Trust Fund) pays the benefits when a miner’s former employer does not or cannot assume
liability. The OIG’s primary concern is that the current annual income of the Trust Fund (primarily from
an excise tax on domestic sales of coal) is not sufficient to cover annual benefit obligations to meet
administrative costs and to service past debt.
The Trust Fund expenditures have consistently exceeded revenue, and the Trust Fund has
essentially borrowed with interest from Treasury’s general fund almost every year since 1979.
According to DOL’s FY 2024 Agency Financial Report, the Trust Fund had to borrow approximately
$3.03 billion to cover its expenditures, which included debt and interest payments. As of
September 30, 2024, the Trust Fund was carrying close to a $6.62 billion deficit balance, which is
projected to grow to $14.42 billion (in constant dollars) by September 30, 2049.
The excise tax that funds the Trust Fund is levied on domestic sales of coal mined in the United
States. On August 16, 2022, the Inflation Reduction Act of 2022 made permanent the temporary
increased excise tax rates of $1.10 per ton of underground mined coal and $0.55 per ton of
surface-mined coal, with a cap of 4.4 percent of the sales price. However, we remain concerned the
permanent tax increases are still not sufficient to ensure solvency of the Trust Fund.
Improving the Performance Accountability of Workforce Development Programs
The OIG has concerns about the Department’s ability to ensure its investments in workforce
development programs are successful in enhancing participants’ skills and placing them in meaningful
and appropriate employment. Our work has identified weaknesses in three key areas: (1) awarding
grants, (2) reviewing grant recipients’ use of funds, and (3) measuring program performance. ETA
must ensure it focuses on these areas to improve the accountability of the Department’s workforce
development programs.
The OIG’s September 2021 audit32 of the American Apprenticeship Initiative grant program—
which aimed in part to expand Registered Apprenticeships—identified systemic weaknesses in the
execution of the grants, as well as in ETA’s planning and awarding processes. DOL received an
estimated $285 million in FY 2024 and requested $335 million for the Registered Apprenticeship
Program in FY 2025. The Department must ensure its significant investments into Registered
Apprenticeships are used efficiently and effectively to develop new pathways to good-quality jobs.
Strengthening oversight of how grant recipients and subrecipients spend funds can improve
performance accountability in DOL workforce development programs. In September 2023, we
32 ETA Did Not Sufficiently Plan and Execute the American Apprenticeship Initiative Grant Program,
Report No. 05-21-004-03-375 (September 30, 2021), available at:
https://www.oig.dol.gov/public/reports/oa/2021/05-21-004-03-375.pdf
28 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Significant Concerns
reported33 ETA needs to improve its oversight of grant recipients and sub-recipients34 in the State
of New Jersey to ensure grant funds serve their intended purposes. We found ETA did not ensure
recipients effectively: (1) used over $100 million to serve the intended population; (2) enrolled eligible
individuals in the grant programs, costing $96,580 in training services; and (3) complied with federal
requirements when paying $168,460 in services. We also questioned $6.9 million in grant funding
because the sub-recipients could not show how these funds were used.
The Department must also obtain appropriate, accurate, and reliable data to measure, assess, and
make decisions regarding the performance of its workforce development programs.
Our September 2020 audit report found that, although ETA had data to determine whether
participants were employed after exiting grant-funded training programs, it lacked data to measure
the impact credentials had on participants’ outcomes and did not ensure participants’ data was
accurate, valid, and reliable. Similarly, in a 2018 audit, we found that Job Corps was unable to
demonstrate the extent to which its training programs helped participants obtain meaningful
jobs appropriate to their training within 5 years of completing the program. Without appropriate,
accurate, and reliable data, the Department is challenged to effectively assess the performance of
its workforce development programs.
Managing and Securing Data and Information Systems
We remain concerned with DOL’s ability to manage and
secure its data and information systems, more so with the
rapidly expanding use of artificial intelligence (AI). The
Department and its program agencies depend on reliable
and secure IT systems to perform their mission critical
functions. In carrying out their missions, the agencies
obtain and create vast amounts of information and data.
Included in these data are the PII and personal health
information of the public, including federal employees.
While DOL has improved IT management, such as
implementing a shared services model, we remain
concerned with its governance structure and information
security program.
33 COVID-19: The Employment and Training Administration Needs to Improve Oversight of Grants Awarded in
New Jersey, Report No. 19-23-016-03-391 (September 28, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-016-03-391.pdf
34 A sub-recipient is a non-federal entity that receives a sub-award from a pass-through entity to carry out part of a
federal program. It does not include an individual who is a beneficiary of the program.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 29
Significant Concerns
Fundamentally, we continue to be concerned DOL has not fully empowered the Chief Information
Officer (CIO) position to ensure the Department’s IT governance is effectively implemented.
Specifically, DOL’s CIO reports to the Assistant Secretary for Administration and Management—
not the Secretary or Deputy Secretary as required by law—and does not have sufficient authority or
representation on key senior level management boards. In addition, we continue to have concerns
with the Department’s information security program in the following areas: cybersecurity oversight;
supply chain; cloud/third-party; end user/remote security; and emerging technology and security
requirements, such as AI and zero trust architecture.
We continue to identify recurring deficiencies in DOL’s efforts to manage and implement security
controls throughout its information security program. The Department has not adequately
implemented information security controls and technology tools required to manage and monitor IT
security. Further, we are still concerned the 30 percent of systems outside the IT shared services
environment, including the Bureau of Labor Statistics, are not receiving the governance and oversight
required to sufficiently secure all of DOL’s data and information systems.
Additionally, we are concerned about DOL’s oversight for the rapidly expanding use of AI across
agencies. Specifically, there is insufficient clarity in the roles and responsibilities regarding AI
implementation and monitoring, leading to potential risks in data privacy, security, and ethical usage.
Without developed and mature standardized guidelines and continuous oversight, AI systems may
perpetuate bias or malfunction in critical operations. The CIO must establish robust frameworks to
ensure AI aligns with public trust and governance standards.
These areas represent ongoing risks to the confidentiality, integrity, and availability of DOL’s
information systems, which are necessary to support the Department’s mission. DOL needs to
implement the necessary strategies and tools to provide effective management and security for its
data and information systems.
30 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree
Benefit Programs
Unemployment Insurance Programs
Office of Workers’ Compensation Programs
Employee Benefit Plans
Office of Labor-Management Standards
Worker and Retiree Benefit Programs
Unemployment Insurance Programs
Enacted more than 80 years ago as a federal-state partnership, the unemployment insurance
program is the Department’s largest income-maintenance program. This multi-billion-dollar
program provides unemployment benefits to eligible workers who become unemployed through
no fault of their own. The program is generally administered by states with oversight from DOL’s
Employment and Training Administration.
COVID-19: ETA’S OVERSIGHT OF SHORT-TIME COMPENSATION DID
NOT DETECT $129.6 MILLION IN QUESTIONED COSTS
Why OIG Conducted the Audit
On March 27, 2020, Congress passed the CARES Act to
provide expanded UI benefits to workers unable to work due
to the COVID-19 pandemic. Section 2110 provided grants
to support the administration of Short-Time Compensation
(STC) programs. Under Section 2108, the STC program
provided for 100 percent federal reimbursement of STC
benefits to states that previously operated a permanent or
temporary program under state law.
To address concerns about risks associated with the
disbursement of federal funds during the pandemic, we
contracted with the independent certified public accounting
firm of Regis & Associates, PC (Regis) to answer the
following question:
Did the Employment and Training Administration
(ETA) ensure states met STC requirements and
used the related funds as intended by the CARES
Act and related subsequent legislation?
32 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
What OIG Found
Regis found only 5 of the 10 states selected for in-depth testing received Section 2110 grants and
used the funds to promote and enroll employers in their STC programs and implement or improve the
administration of STC in their localities. Regis found no compliance exceptions with those five states.
With respect to benefit reimbursements under Section 2108, Regis found ETA did not ensure states
met STC reimbursement requirements or used the related funds as intended by the CARES Act and
related subsequent legislation. Specifically, of the 10 states reviewed, Regis identified 7 states drew
down federal reimbursements that were questionable. Specifically, Regis identified the following:
• Six states drew down $28.1 million in excessive federal reimbursements. One of the six states
drew down an additional $100.1 million in reimbursements for payments without verifying the
eligibility of claimants’ employment status.
• One state drew down $1.4 million in reimbursements without providing records to support their
STC payments and drawdowns.
The states’ noncompliance went undetected because ETA did not assess risks and establish controls
to sufficiently monitor states’ compliance with STC reimbursement requirements. ETA solely relied
upon the review of claims and payment activity reports, which was insufficient in detecting the
noncompliance issues found by Regis.
Due to ETA’s insufficient monitoring of states’ reimbursements under Section 2108, Regis identified
the seven states were allowed to draw down about $129.6 million in questioned costs. As a result of
Regis’ findings, four states have already returned $11.6 million to ETA.
What OIG Recommended
Regis made three recommendations to ETA to improve oversight of STC and similar future temporary
UI programs. ETA agreed with the recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/19-24-003-03-315.pdf,
Report No. 19-24-003-03-315 (June 26, 2024).
Semiannual Report to Congress | April 1, 2024–September 30, 2024 33
Worker and Retiree Benefit Programs
ETA DID NOT ENSURE STATES SUFFICIENTLY IMPLEMENTED THE
MIXED EARNERS UNEMPLOYMENT COMPENSATION PROGRAM
Why OIG Conducted the Audit
The Continued Assistance for Unemployed Workers
Act of 2020 created the Mixed Earners Unemployment
Compensation (MEUC) program. The program provided
an additional, supplemental weekly benefit payment to
individuals covered by an UI program other than the
Pandemic Unemployment Assistance (PUA) program
and who had significant self-employment income. ETA
was required to oversee the SWAs’ implementation of the
MEUC program.
Based on prior OIG pandemic audits, we were concerned
about ETA’s ability to deploy the $1.5 billion provided to
the MEUC program. We contracted with the independent
certified public accounting firm of Regis & Associates,
PC (Regis) to conduct a performance audit to answer the
following question:
Did ETA ensure SWAs implemented the MEUC
program for the benefit of eligible unemployed
individuals, pursuant to the intent of the Continued
Assistance for Unemployed Workers Act of 2020
and the American Rescue Plan Act of 2021?
For this audit, Regis performed in-depth testing on 6 SWAs, surveyed an additional 24 SWAs,
reviewed policies and procedures, and interviewed ETA and SWA officials.
What OIG Found
Regis determined the six SWAs reviewed generally met the MEUC program requirements and used
the related funds as intended by pandemic-related legislation. However, Regis found ETA did not
ensure SWAs sufficiently implemented the MEUC program. Specifically, MEUC benefit payments
were significantly delayed, there was low participation in the program, and benefits did not reach a
large population.
34 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
For the six audited SWAs, some claimants waited as long as 8 months after the start of the program
for their first payment. The six SWAs took between 78 to 273 days to make their first MEUC payments
to claimants, and 79 percent of the surveyed SWAs took between 63 to 378 days. Regis determined
that the six SWAs paid only 707 claimants under MEUC, and two SWAs served only 21 claimants
each. Although the initial MEUC allotment for these SWAs totaled $79.3 million, as of September 6, 2021,
only about $1.4 million had been paid to the 707 claimants. Furthermore, despite discontinuing
their participation in the MEUC program in 2021, $1.3 million in MEUC funds remained available for
drawdown in these SWA accounts, as of September 30, 2023.
In addition, Regis noted that the funds obligated for MEUC were appropriated by Congress without
fiscal year limitation. This requires ETA to set aside pandemic funds to reimburse SWAs for eligible
MEUC claims years after the conclusion of the program.
The lack of time for ETA to develop and administer a new benefit payment program for mixed earners,
as well as competing priorities, resulted in the delayed payments and the underutilization of funds for
the six audited SWAs. The SWAs also experienced a lack of lead time for preparation, an inadequate
number of staff, IT constraints, and a lack of information on mixed earners. If these challenges are
left unresolved, ETA and SWAs may again struggle to provide timely and useful assistance to this
population during future emergencies.
What OIG Recommended
Regis made four recommendations to improve ETA’s and Congress’ knowledge of the mixed earners
population and to monitor SWAs’ levels of benefit payment activity to better meet the future needs of
mixed earners. ETA agreed to take corrective actions for three recommendations. ETA stated it would
be unable to address one recommendation due to current funding limitations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/19-24-005-03-315.pdf,
Report No. 19-24-005-03-315 (September 11, 2024).
Semiannual Report to Congress | April 1, 2024–September 30, 2024 35
Worker and Retiree Benefit Programs
Detroit Man Pled Guilty in $6 Million Unemployment Insurance Fraud Scheme
On May 2, 2024, David Davis pled guilty to one count of conspiracy to commit wire fraud for his role
in a UI fraud scheme that targeted multiple SWAs and resulted in the loss of more than $6 million in
UI benefits.
Between approximately April 2020 and August 2021, Davis and his co-conspirators defrauded the
federal government and multiple SWAs of funds that were earmarked for COVID-19 pandemic
relief. The scheme involved the filing of more than 700 fraudulent UI claims in eight states, including
Michigan, California, and Arizona. Davis and his co-conspirators used the stolen PII of identity theft
victims to file the fraudulent claims. Once processed, the UI funds were loaded onto pre-paid debit
cards that were mailed to addresses controlled by Davis and his co-conspirators. The funds were
later withdrawn at ATMs in Michigan and California.
As a result of their scheme, Davis and his co-conspirators fraudulently obtained more than $6 million.
This is a joint investigation with Homeland Security Investigations (HSI). United States v. Howard et
al. (E.D. Michigan)
Four Florida Men Convicted in Multi-Million Dollar Fraud Scheme
In April 2024, Tony Mertile, Junior Mertile, Allen Bien-Aime, and James Legerme pled guilty to wire
fraud and aggravated identity theft for their roles in a wide-ranging conspiracy to steal more than
$4.8 million by defrauding financial institutions and fraudulently obtaining UI benefits.
The four men participated in a conspiracy that used stolen PII to fraudulently open bank accounts and
obtain debit cards in the names of other persons. The defendants then used the accounts and cards
to receive, deposit, and transfer fraudulent benefits and payments from federal and state agencies,
including UI benefits.
As part of the scheme, the defendants submitted fraudulent applications to multiple SWAs, including
the Rhode Island Department of Labor and Training, for pandemic-related UI benefits made available
under the CARES Act and the Families First Coronavirus Response Act. The defendants also
submitted fraudulent applications in the names of identity theft victims to obtain tax refunds, stimulus
payments, and disaster relief funds.
The defendants each agreed to forfeit more than $1.2 million in funds that constitute the proceeds of
the conspiracy. They also agreed to forfeit valuable luxury watches and jewelry, as well as more than
$1.1 million in cash seized from the residences of Tony Mertile, Junior Mertile, and James Legerme
at the time of their arrests. In addition, each defendant is liable for approximately $4.8 million in
restitution to be paid to SWAs and financial institutions that were defrauded.
36 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
This is a joint investigation with the FBI, the Internal Revenue Service-Criminal Investigation (IRS-CI),
and the Rhode Island State Police. United States v. Allen Bien-Amie et al. (D. Rhode Island)
Michigan Fraudsters Sentenced in Multi-Million Dollar Fraud Scheme
In September 2024, Marcellus Dunham, Day’on Holt, Armani Haller, and Laron Stroud were
sentenced to 102 months, 32 months, 24 months, and 18 months in prison, respectively, for their
roles in a pandemic-related UI fraud scheme. The four defendants were also ordered to pay
restitution jointly and severally of more than $4.8 million to the SWAs of California, Michigan, Arizona,
Indiana, Maryland, and New York. Dunham was also ordered to pay restitution of more than $570,000
for his role in two additional financial fraud schemes.
From April 2020 to August 2021, the defendants and other co-conspirators colluded to submit nearly
700 fraudulent UI claims to more than nine states. The claims were filed using the stolen PII of
identity theft victims. Once the fraudulent claims were processed, the UI funds were loaded onto
pre-paid debit cards that were mailed to addresses controlled by the defendants. The defendants
and their other co-conspirators then made cash withdrawals at ATMs in Michigan and California. As a
result of their scheme, the defendants fraudulently obtained more than $4.8 million in UI benefits.
This is a joint investigation with the FBI. United States v. Marcellus Dunham et al. (E.D. Michigan)
Former Maryland Department of Labor Contractors Plead Guilty to
Pandemic-Related Unemployment Insurance Fraud Conspiracy of More Than
$3.5 Million
On June 3, 2024, and July 23, 2024, Bryan Ruffin and Kiara Smith, former contractors who provided
services directly to the Maryland Department of Labor (MD DOL), pled guilty, respectively, to
conspiracy to commit wire fraud and aggravated identity theft for their roles in defrauding the MD DOL
of more than $3.5 million.
From early 2021 through late 2022, Smith and Ruffin worked remotely as contractors for the MD
DOL. Initially, they handled customer service calls but were later promoted to work on MD DOL fraud
matters. Through their employment, Smith and Ruffin were issued laptops that allowed for remote
access to MD DOL servers, including the UI claims system. While handling fraud-related matters for
MD DOL, Smith was tasked with identifying fraudulent identification documents submitted in support
of UI claims, such as fake Social Security cards and driver’s licenses. MD DOL also gave Smith the
discretion to add or remove fraud flags in the system.
In early 2021, Smith provided her MD DOL-issued laptop to co-conspirators in exchange for money.
Throughout 2022, Ruffin provided his MD DOL-issued laptop to co-conspirators for the same purpose.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 37
Worker and Retiree Benefit Programs
The co-conspirators then used the laptops to access non-public UI data and databases maintained
by MD DOL to change information on existing UI claims, including contact email addresses, online
account passwords, and payment methods. They also made numerous false statements and
misrepresentations on UI applications, so the highest amount of available UI benefits would be paid.
As a result, the MD DOL disbursed UI benefits to bank accounts that were controlled by members of
the conspiracy.
Smith also fraudulently sought UI benefits for herself during the pandemic, including during periods
when she was employed.
In addition to providing her MD DOL issued laptop to her co-conspirators, Smith used her insider
access with MD-DOL to fraudulently process UI benefits. She changed the registered email accounts
associated with at least 20 UI claims to an email belonging to her. Smith then caused MD DOL to pay
UI benefits on these 20 claims to bank accounts she controlled.
Based on Smith and Ruffin’s activities, the members of the conspiracy fraudulently obtained more than
$3.5 million in pandemic-related UI benefits of which Smith personally obtained at least $275,000.
This investigation is being conducted as part of the Maryland COVID-19 Fraud Enforcement Strike Force
and is a joint investigation with the FBI. United States v. Lawrence Nathanial Harris et al. (D. Maryland)
Two Arkansas Men Convicted and Sentenced in Unemployment Insurance
Fraud Scheme
On July 11, 2024, and July 25, 2024, Khi Simms pled guilty to conspiracy to commit bank fraud and
aggravated identity theft and Deuntae Diggs was sentenced to 41 months in prison and ordered
to pay more than $874,000 in restitution, respectively. Along with other co-conspirators, both
Simms and Diggs participated in an UI fraud scheme that defrauded the federal government, the
California Employment Development Department (EDD), and a financial institution of funds that were
earmarked for COVID-19 pandemic relief.
From approximately January 2021 to August 2021, Simms and Diggs were involved in a conspiracy
whereby they obtained and made withdrawals from debit cards containing fraudulently obtained
UI benefits that a co-conspirator made available. The co-conspirator, who was hired by a financial
institution as a contract employee, then accessed bank systems without authorization to reissue
debit cards; remove fraud blocks; and add provisional credits to unemployment debit card accounts
from which Simms and Diggs later withdrew funds. Simms also recruited others to participate
in the conspiracy, often recruiting them via social media posts. Simms also sent messages to
co-conspirators to advise them on how to call the financial institution and pretend to be various
customers in order to have debit cards sent to their addresses.
38 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
In total, Simms and Diggs were responsible for approximately $2.7 million and $815,000, respectively,
in withdrawals of fraudulently obtained funds.
This is a joint investigation with the FBI. United States v. Khi Simms and Deuntae Diggs (E.D. Arkansas)
Virginia Man Sentenced to 84 Months in Prison for COVID-19 Pandemic Benefits
Fraud Scheme and for Defrauding Elderly Homeowners
On May 14, 2024, Howard Lee Stith, Jr. was sentenced to 84 months in prison and ordered to pay
restitution of more than $2.4 million for his role in multiple fraud schemes including pandemic-related
UI fraud, EIDL fraud, and filing a false tax return related to his failure to claim income from his
roofing business.
After the onset of the COVID-19 pandemic, Stith applied for and received pandemic relief funds
to which he was not entitled. First, he applied for multiple EIDLs on behalf of various businesses,
including a roofing business. These EIDL applications included materially false statements about the
gross income of each business, as well as the number of employees. Stith then submitted fraudulent
applications for UI benefits to the Virginia Employment Commission (VEC), in which he falsely
claimed that he was not working, not self-employed, and not receiving money from any source.
As a result, Stith fraudulently received UI benefits from the VEC to which he was not entitled. In
total, Stith received tens of thousands of dollars from homeowners during the period in which he
falsely claimed UI benefits. He also perpetrated a scheme to defraud elderly homeowners in the
Richmond, Virginia area by appearing at their homes and falsely claiming that their roofs needed
extensive repairs.
Thereafter, Stith purported to provide the promised repair services but performed minimal work of
poor quality, while charging homeowners exorbitant fees. To substantiate the excessive amounts
he charged, he created false invoices and misleading receipts, which he provided to various
homeowners. Stith fraudulently obtained at least $1.5 million from elderly homeowners in connection
with the scheme.
In addition, he failed to report to the IRS the income he obtained from the scheme by filing a false
tax return in 2018 and failing to file tax returns for the tax years 2019, 2020, and 2021. After learning
he was under federal investigation, Stith allegedly began directing homeowners to write personal
checks to others to further conceal his receipt of such payments. Through this conduct, he evaded the
assessment of income tax in the alleged amount of at least $575,000 for tax years 2018 through 2021.
This is a joint investigation with the FBI, the United States Secret Service (USSS), the IRS-CI, and
the SBA-OIG. United States v. Howard Lee Stith, Jr. (E.D. Virginia)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 39
Worker and Retiree Benefit Programs
Maryland Men Convicted and Sentenced to Prison for Roles in $2 Million
Pandemic-Related Unemployment Insurance Fraud Scheme
On April 11, 2024, and May 30, 2024, Christopher Yancy, aka “Lil Bhris” and “Lil Chris,” and Christian
Malik Adrea, aka “Leak” and “Lil Leak,” were sentenced to 63 months in prison and 3 months in
prison, respectively, for their roles in a pandemic-related UI fraud scheme and aggravated identity
theft conspiracy that defrauded multiple SWAs through the submission of fraudulent UI claims.
Yancy also pled guilty to and was sentenced for additional charges related to the illegal possession
of machine guns. Adrea and Yancy were ordered to pay more than $2 million in restitution, jointly
and severally with their other co-conspirators, to affected SWAs and forfeit more than $195,000 and
$280,000 in fraudulent proceeds, respectively, which each defendant received from their participation
in the scheme.
In addition, on August 15, 2024, Trez Anthony Hendy, aka “Torch”, pled guilty to conspiracy to commit
wire fraud, wire fraud, and aggravated identity theft for his role in the conspiracy.
Between March 2020 and October 2021, Adrea, Yancy, Hendy, and their other co-conspirators
impersonated identity theft victims to submit fraudulent UI claims in Maryland and California. As
part of the scheme, Adrea, Yancy and their co-conspirators used electronic messages, phone calls,
electronic mail and other means to aggregate and exchange the PII of identity theft victims. They
also created fictious email addresses and phone numbers for the victims and used the emails and
phone numbers on the fraudulent applications in furtherance of the scheme. Once Adrea, Yancy, and
their co-conspirators received the fraudulently obtained UI benefits on debit cards, they made cash
withdrawals and other transactions for their own financial benefit.
In October 2021, law enforcement executed a search warrant at the residence of Yancy and
recovered numerous weapons, including two classified under law as “machine guns,” upper and
lower firearms receivers, ammunition, gun part kits, a 3D printer, and other items used to assemble
and alter firearms.
This is a joint investigation with the United States Postal Inspection Service (USPIS), HSI, the Bureau
of Alcohol, Tobacco, Firearms and Explosives (ATF), the Maryland State Police, and the Anne Arundel
County (Maryland) Police Department. United States v. Michael Akame Ngwese Ay Makoge et al.
(D. Maryland)
California Man Sentenced to More Than 4.5 Years in Federal Prison for
Unemployment Insurance Fraud
On July 17, 2024, Kenneth Lathon was sentenced to 54 months in prison and ordered to pay
restitution of approximately $998,600 for his role in a scheme to fraudulently obtain UI benefits.
40 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
Lathon’s spouse, a co-conspirator in the scheme, operated at least three tax preparation businesses.
In that capacity, Lathon’s spouse was provided with PII, which included the names, dates of birth, and
Social Security numbers, of numerous individuals for tax filing purposes.
From February 2020 to March 2021, Lathon conspired with his spouse to submit fraudulent
applications to the California EDD for UI benefits using PII obtained from former clients of the
spouse’s tax preparation businesses. The PII was used without the permission of the former clients.
The PII as well as fictitious employment histories, mailing addresses, email accounts, and phone
numbers, were used to file fraudulent UI claims.
As a result, EDD authorized a financial institution to issue debit cards in the names of claimants. The
debit cards were then mailed to addresses that both Lathon and his spouse controlled. They then
used the debit cards to make purchases and cash withdrawals.
Lathon and his spouse caused at least 44 fraudulent UI claims to be filed, resulting in losses to EDD
of almost $1 million.
This is a joint investigation with HSI, the USPIS, the ATF, the DOL-EBSA, the Amtrak-OIG, and the
California EDD. United States v. Lathon (C.D. California)
Maryland Man Sentenced to 14 Years in Prison for Committing Pandemic-Related
Unemployment Insurance Fraud and Leading a Fentanyl Distribution Ring
On May 8, 2024, Collin Edwards was sentenced to 168 months in prison for using stolen PII to file
fraudulent pandemic-related UI claims and for leading a group involved in the manufacturing of
counterfeit oxycodone pills mixed with fentanyl.
In August 2021, law enforcement identified Edwards and others as participants in a drug trafficking
operation. This included running a fentanyl pill pressing operation in and around Washington, D.C.
and Maryland and renting apartments with stolen identities for the purpose of manufacturing and
distributing counterfeit pills. During the investigation, a search warrant was executed on a high-end
luxury apartment that Edwards and the group were renting using a fictitious identity. In addition to the
seizure of over 500 counterfeit pills and more than 76 grams of a mixture and substance containing
fentanyl, law enforcement seized Edwards’ cell phone. The phone contained numerous text message
conversations with other drug traffickers discussing pill sales, as well as text messages between
Edwards and others laying out a scheme involving pandemic-related UI fraud.
Edwards obtained database documents containing PII for hundreds of victims and subsequently used
the stolen PII to apply online for UI benefits in identity theft victims’ names. Due to the fraudulent
applications, debit cards pre-loaded with UI benefits were sent to the homes of Edwards’ associates
Semiannual Report to Congress | April 1, 2024–September 30, 2024 41
Worker and Retiree Benefit Programs
and family members. He then retrieved the cards and withdrew funds at ATMs around Washington,
D.C. Edwards admitted that he and other co-conspirators fraudulently obtained at least $250,000
through the UI fraud scheme.
This is a joint investigation with the FBI. United States v. Collin Edwards et al. (D. District of Columbia)
Former Social Security Administration Employee Sentenced to 36 Months in
Prison for Pandemic Unemployment Insurance Fraud Scheme
On April 2, 2024, Takiyah Gordon Austin was sentenced to 36 months in prison for her role in a
scheme to fraudulently obtain pandemic-related UI benefits. She was also ordered to pay restitution
totaling more than $288,000.
From approximately May 2020 through May 2021, while employed as a claims specialist with
the Social Security Administration (SSA), Austin filed pandemic-related UI claims for ineligible
recipients in exchange for payment from those individuals. In addition, she filed other claims for her
own benefit after accessing SSA databases to obtain PII from unsuspecting victims. Austin diverted
the UI benefits for those claims to addresses that she controlled to use the funds for her own
personal expenses.
This was a joint investigation with the SSA-OIG and the USPIS. United States v. Takiyah Gordon
Austin (M.D. Pennsylvania)
42 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
Office of Workers’ Compensation Programs
The Office of Workers’ Compensation Programs (OWCP) administers four major workers’
compensation programs: Federal Employees’ Compensation, Energy Employees Occupational
Illness Compensation (Energy), Coal Mine Workers’ Compensation (Black Lung Benefits), and
Longshore and Harbor Workers’ Compensation.
FECA is the largest of the programs and provides workers’ compensation coverage to millions
of federal, postal, and other employees for work-related injuries and illnesses. Benefits include
wage replacement, payment for medical care, vocational rehabilitation, and survivor benefits.
OWCP COULD IMPROVE ITS EXISTING GUIDELINES FOR
PROCESSING DEEOIC CLAIMS
Why OIG Conducted the Audit
The Division of Energy Employees Occupational Illness
Compensation (DEEOIC) within the DOL’s OWCP is
responsible for compensating individuals. These individuals
include current or former employees (or their survivors) of
the Department of Energy who developed illnesses as a
result of toxic exposure while employed at covered facilities
or a mining work environment. Coverage also includes
individuals at its predecessor agencies and certain
vendors, contractors, and subcontractors. From 2017 to
2019, we received hotline complaints alleging DEEOIC
was taking too long to issue claims decisions. In response
to these allegations, we conducted this audit to answer the
following question:
To what extent did OWCP’s DEEOIC ensure claims
followed appropriate guidelines?
We analyzed claim decision data and relevant
documentation; reviewed related statutes, policies, and
procedures; and interviewed DEEOIC staff. We focused on
general hotline complaint allegations that claims were not
processed timely.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 43
Worker and Retiree Benefit Programs
What OIG Found
Our work identified opportunities where DEEOIC could improve its existing guidelines for processing
claims. We found DEEOIC did not use complete information to measure and publicly report how long it
took to make claims decisions, from start to finish, which distorted the perception of how long claimants
waited for decisions. DEEOIC set a target of 170-average days to make claims decisions needed for
claimants to receive compensation and medical expense coverage. However, our analysis showed
DEEOIC took an average of 182 days to make 6,023 final decisions in FY 2018, compared to 207 days
for 4,910 final decisions in FY 2022. Wait times increased while the volume of final decisions dropped.
Figure 2: Average Number of Days to Issue Final Decisions
Final Decisions
Fiscal Year
Source: OIG analysis of DEEOIC claims adjudication data and DEEOIC’s reported results in its
Congressional Budget Justifications
We also found gaps in DEEOIC’s oversight of its decision-making processes that increased the risk of
errors. For example, review results were not documented consistently or aggregated to identify trends
or systemic problems, and error corrections were not documented and may not have been completed.
These gaps occurred because DEEOIC did not place sufficient management emphasis on its quality
controls over the claims process.
44 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
The lack of transparency in the claims process distorted the perception of how long claimants actually
waited for claims decisions. In addition, processing errors may not have been identified and corrected,
which could have resulted in delayed or incorrect claims decisions. These issues raised concerns that
workers who were injured or became ill on the job, or their survivors, may not be receiving timely and
accurate decisions on claims and prompt compensation and medical expense coverage.
What OIG Recommended
We made five recommendations to OWCP to improve timeliness performance metrics, oversight, and
the standardization of the claims adjudication process. OWCP agreed with our recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/09-24-001-04-437.pdf,
Report No. 09-24-001-04-437 (May 2, 2024).
Three Texas Defendants Sentenced in Healthcare Compounding Fraud Scheme
On July 10, July 12, and July 30, 2024, Dustin Rall, Quintan Cockerell, and Turner Luke Zeutzius
were sentenced to 24 months in prison, 29 months in prison, and time served, respectively. Rall,
Cockerell, and Zeutzius were also ordered to pay restitution, jointly and severally, of more than
$59 million for their roles in a wide-ranging healthcare fraud scheme.
Rall was the owner of the Medicine Store Pharmacy, Inc. and Halls IV & Institutional Pharmacy, Inc.,
aka Rxpress Pharmacy and Xpress Compounding (Rxpress/Xpress), which were both compounding
pharmacies. Both Cockerell and Zeutzius were marketers for the pharmacies. From May 2014 to
September 2016, Rxpress/Xpress formulated expensive compounded medications prescribed for
individuals, including members of the armed forces and injured federal workers. Rall and others
recruited a network of marketers, including Cockerell and Zeutzius, who, in turn, recruited doctors and
patients to obtain prescriptions for the compounded medications at Rxpress/Xpress. Rxpress/Xpress
then paid kickbacks to Cockerell and Zeutzius for their recruitment efforts.
In addition, Rxpress/Xpress paid kickbacks to doctors for writing prescriptions for compounded drugs.
In furtherance of the scheme, doctors were provided with lucrative entertainment and travel benefits to
ensure they continued to refer prescriptions to Rxpress/Xpress. These kickback schemes targeted the
billings to both private and federal health care programs, including DOL’s-OWCP’s FECA program.
This is a joint investigation with the FBI, the Defense Criminal Investigative Service, the U.S.
Department of Health and Human Services (HHS)-OIG, and the Veterans Affairs-OIG. United States
v. Hall et al. (N.D. Texas)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 45
Worker and Retiree Benefit Programs
Employee Benefit Plans
The Department’s Employee Benefits Security Administration (EBSA) is responsible for protecting
the security of retirement, health, and other private-sector employer-sponsored benefit plans
for America’s workers and retirees, and their families. EBSA is charged with protecting about
156 million workers, retirees, and family members who are covered by nearly 801,000 private
retirement plans, 2.6 million health plans, and 514,000 other welfare benefit plans that together
hold estimated assets of $13.6 trillion.
Argyle Fire Chief Sentenced to Prison and Ordered to Pay More Than $500,000
in Restitution
On August 1, 2024, Troy Hohenberger was sentenced to 50 months in prison and ordered to pay
approximately $509,000 in restitution and forfeit more than $28,000 for his misuse and theft of funds
from the Argyle Fire District, Inc. (AFD) operating account, and for making false statements to the DOL.
Hohenberger was formerly the chief firefighter and plan administrator of the AFD 401(k) Plan, that
qualified as an ERISA plan. From approximately 2018 to 2021, Hohenberger stole funds from the
AFD’s operating account, using more than $490,000 to pay personal credit card bills. The personal
credit card expenses included cash advances at casinos, payments related to a family member’s
business in Hawaii, and other personal uses. In addition, he failed to deposit more than $690,000 in
AFD retirement accounts in the time period required by federal regulations. Hohenberger also made
false statements related to the AFD 401(k) plan on a form submitted to the DOL.
This is a joint investigation with the FBI and the DOL-EBSA. United States v. Troy Mac Hohenberger
(E.D. Texas)
New York Man Pled Guilty to Theft from Union Health and Welfare Fund
On May 28, 2024, Ben Johnson pled guilty to a one-count information charging him with theft or
embezzlement in connection with health care due to his role in the theft of union benefit funds.
Between approximately August 2018 and January 2023, Johnson prepared multiple fraudulent dental
and health care receipts for himself and family members. He then used the receipts to prepare and
submit false claims for reimbursement to the Plasterers Local Union No. 9 Health and Welfare Fund.
Johnson received more than $60,000 in reimbursements from the Fund to which he was not entitled.
This is a joint investigation with the DOL-EBSA, the FBI, and the New York State Department of
Financial Services. United States v. Ben Johnson (W.D. New York)
46 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker and Retiree Benefit Programs
Office of Labor-Management Standards
The Office of Labor-Management Standards (OLMS) administers and enforces provisions of the
Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), as amended. OLMS also
administers provisions of the Civil Service Reform Act of 1978 (CSRA) relating to standards of
conduct for Federal employee organizations, which are comparable to LMRDA requirements.
These laws promote union democracy and financial responsibility in private and federal sector
labor unions.
OLMS CAN DO MORE TO PROTECT WORKERS’ RIGHTS TO UNIONIZE
THROUGH ENFORCING PERSUADER ACTIVITY DISCLOSURE
Why OIG Conducted the Audit
OLMS is responsible for enforcing requirements under the
Labor-Management Reporting and Disclosure Act of 1959 for
disclosing persuader activity when an employer hires someone to
influence an employee regarding unionization. OLMS obtains and
publicly releases persuader activity reports. Timely, complete, and
accurate receipt and subsequent disclosure of this information
enables employees to protect their rights and interests to unionize.
In Fall 2022, OLMS requested we review its efforts to enforce
these requirements and improve employers’ and consultants’
persuader activity reporting.
Given this request and the importance to workers, we conducted
this audit to determine:
To what extent did OLMS enforce the Labor-Management Reporting and disclosure Act’s
persuader activity requirements to protect workers’ rights to unionize?
Our audit included analysis of the tip line process and collaboration with the National Labor
Relations Board.
What OIG Found
We found OLMS did not effectively enforce persuader activity requirements to protect workers’ rights
to unionize. Specifically, OLMS did not effectively ensure required persuader activity reports were
Semiannual Report to Congress | April 1, 2024–September 30, 2024 47
Worker and Retiree Benefit Programs
filed and that employers and consultants that filed did so timely and accurately. During the more than
3-year period we reviewed, only 428 employers and 211 consultants reported persuader activity.
However, the National Labor Relations Board reported around 1,100 organizing campaigns in 2021,
and research indicates employers hired persuader consultants in about 825 of those campaigns,
raising concerns of significant underreporting. Further, our data analyses found that, of the reports
filed during the reviewed period, 49 percent of employer reports, 83 percent of consultant reports, and
47 percent of consultant financial reports were filed after the required filing dates (see Figure 3).
Figure 3: Percentages of Delinquent Persuader Activity Reports, Received
January 1, 2021–August 22, 2023
83%
49% 47%
Employee Consultant Consultant Financial
Reports Reports Reports
Source: OLMS Electronic Forms System
We also found OLMS did not ensure it addressed tips provided by the public. In addition, OLMS did
not effectively coordinate with the National Labor Relations Board to obtain information related to
persuader activities.
These issues occurred because OLMS: (1) had limited enforcement authority; (2) lacked sufficient
policies, procedures, and systems for monitoring reports and tips; and (3) did not fully implement
processes for sharing information and resources with the National Labor Relations Board. As a
result, missing, untimely, and inaccurate reports may have negatively impacted workers from making
informed decisions about unionization. In addition, missed tips as well as delayed responses may
have eroded or may in the future erode trust in the tip line and deter tipsters from providing helpful
information about persuader activities.
What OIG Recommended
We made six recommendations to OLMS to improve enforcement of persuader activity reporting.
OLMS generally agreed with our recommendations.
For more information, go to: https://www.oig.dol.gov/public/reports/oa/2024/09-24-002-16-001.pdf,
Report No. 09-24-002-16-001 (May 3, 2024).
48 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker Safety, Health,
and Workplace Rights
Occupational Safety and Health
Administration
Mine Safety and Health Administration
Wage and Hour Division
Worker Safety, Health, and Workplace Rights
Occupational Safety and Health Administration
The Occupational Safety and Health Administration's (OSHA) mission is to assure America’s
workers have safe and healthful working conditions free from unlawful retaliation. OSHA carries
out its mission by setting and enforcing standards; enforcing anti-retaliation provisions of the
OSH Act and other federal whistleblower laws; providing and supporting training, outreach,
education, and assistance; and ensuring state OSHA programs are at least as effective as
federal OSHA, furthering a national system of worker safety and health protections.
Construction Company Owner Pled Guilty to Making False Statement in Death of
Worker and Tax Crimes
On April 11, 2024, Mauricio Baiense, owner of Contract Framing Builders Inc., pled guilty to making a
false statement in a hearing before DOL’s OSHA and to an employment tax scheme that caused more
than $2 million loss to the IRS.
OSHA investigated the workplace death of an employee of Contract Framing Builders, Inc. While
under oath at a hearing, Baiense falsely claimed the deceased individual was not employed by
Contract Framing Builders at the time of the accident.
In addition, between approximately April 2013 and December 2017, Baiense operated an “off-the-books”
cash payroll for the company. To generate cash for the payroll, he wrote checks drawn on a company
bank account to purported subcontractors, who were, in fact, entities that he controlled. Baiense then
cashed or directed others to cash approximately $11 million in checks at a check cashing business.
A portion of the proceeds of the scheme was used to pay Contract Framing Builders’ employees.
Baiense did not report the cash wages to the IRS and did not withhold and remit required employment
taxes, causing a loss to the IRS of more than $2.8 million.
This is a joint investigation with the DOL-OSHA, the IRS-CI, and HSI. United States v. Mauricio
Baiense (D. Massachusetts)
50 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker Safety, Health, and Workplace Rights
New York Construction Company Employee Pled Guilty and Company Sentenced
after Worker Dies Due to Safety Violations
On July 9, 2024, Richard Zagger, a supervisor for Northridge Construction Corporation (Northridge),
which is located in New York, pled guilty to a charge of conspiracy and three charges of obstruction
related to a federal investigation into the death of a Northridge employee. On August 6, 2024,
Northridge was sentenced in federal court for violating a worker safety standard, which caused
the death of an employee, and for making two false statements that obstructed a federal agency’s
subsequent investigation. The company was ordered to pay a fine of $100,000 and serve a 5-year
term of probation, requiring among other conditions, increased employee safety training.
In December 2018, during the construction of a shed on Northridge’s property, an employee fell
from an improperly secured roof and died. Among other worker safety standards, DOL-OSHA
regulations require that the stability of a metal structure always be maintained during construction.
An investigation revealed that the company failed to adhere to the structural stability standard
and that Northridge employees, including Zagger, made false statements to obstruct the ensuing
federal inquiry.
This case was investigated by the DOL-OIG. United States v. Richard Zagger (E.D. New York) and
United States v. Northridge Construction Company (E.D. New York)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 51
Worker Safety, Health, and Workplace Rights
Mine Safety and Health Administration
The federal Mine Safety and Health Act of 1977, as amended by the Mine Improvement and
New Emergency Response Act of 2006, charges the Mine Safety and Health Administration
(MSHA) with setting and enforcing standards to protect the health and safety of approximately
324,000 men and women working in our nation’s mines.
MSHA GENERALLY PROVIDED ADEQUATE OVERSIGHT OF
MINER TRAINING, THOUGH OPPORTUNITIES TO STRENGTHEN
CONTROLS EXIST
Why OIG Conducted the Audit
MSHA’s mission is to prevent death, disease, and injury
from mining and to promote safe and healthful workplaces
for the nation’s miners. To assist in achieving this purpose,
MSHA reviews, approves, and monitors the implementation
of the health and safety training plans mandated by
Section 115 of the Federal Mine Safety and Health Act
of 1977 for each operator of a mine. The OIG previously
reported on the challenges MSHA experienced during
the COVID-19 pandemic, specifically from April 29, 2020,
through May 2020.
What OIG Did
We performed this audit to determine the following:
To what extent MSHA ensured adequate oversight
of miner training before and during the COVID-19
pandemic, and how has it ensured preparedness
for future crises?
Our work for this audit covered the period of October 1, 2017, through March 31, 2023, and focused
on the efforts of the Mine Safety and Health Enforcement program. We reviewed documentation,
laws, regulations, policies, and procedures related to miner training plans; interviewed key MSHA
52 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Worker Safety, Health, and Workplace Rights
headquarters, district, and field office officials; and determined if MSHA adequately monitored a
sample of Mandatory Safety and Health Inspections.
What OIG Found
MSHA districts and field offices generally displayed a consistent understanding of internal controls,
policies, and procedures and conducted oversight of miner training, including the review of the
training plans submitted by mine operators. Specifically, through the performance of safety and health
inspections, MSHA ensured training plans were submitted timely and generally complied with federal
laws and regulations. In addition, MSHA identified trends in miner accidents and fatalities and has
already started to mitigate risks and improve miner safety.
Furthermore, MSHA gained insight from the COVID-19 pandemic in the areas of communications,
training, operations, and staffing that should better prepare the agency for future crises. However, we
determined MSHA could enhance its internal controls over miner training by applying a tool already
used for Metal/Nonmetal inspections to its coal mine inspections.
What OIG Recommended
With the issuance of our memorandum, our audit objective is satisfied, and the audit is closed. We did
not issue recommendations to MSHA.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/19-24-004-06-001.pdf,
Report No. 19-24-004-06-001 (September 12, 2024).
Semiannual Report to Congress | April 1, 2024–September 30, 2024 53
Worker Safety, Health, and Workplace Rights
Wage and Hour Division
The Wage and Hour Division (WHD) enforces federal minimum wage, overtime pay,
recordkeeping, the Providing Urgent Maternal Protections (PUMP) for Nursing Mothers Act,
and child labor requirements of the Fair Labor Standards Act (FLSA). WHD also enforces the
Migrant and Seasonal Agricultural Worker Protection Act, the Employee Polygraph Protection
Act, the Family and Medical Leave Act, the wage garnishment provisions of the Consumer
Credit Protection Act, and a number of employment standards and worker protections as
provided in several immigration related statutes. Additionally, WHD administers and enforces
the prevailing wage requirements of the Davis-Bacon and Related Acts, the Service Contract
Act and other statutes applicable to federal contracts for construction and for the provision of
goods and services.
Federal Jury Convicts Owner of Massachusetts Pizzeria Chain of Forced Labor
and Attempted Forced Labor
On June 7, 2024, a federal jury found Stavros Papantoniadis, the owner and operator of a pizza
restaurant chain in Massachusetts, guilty of three counts of forced labor and three counts of
attempted forced labor.
Papantoniadis used threats of arrest, deportation, and physical violence to ensure that employees,
who were non-citizens, continued to work for him. He also thinly staffed his restaurants and purposely
employed workers who lacked legal immigration status, allowing him to require employees to work
for 14 or more hours per day and up to seven days per week. To maintain control of these workers,
Papantoniadis threatened to physically harm them or have them deported. He monitored the workers
with surveillance cameras and constantly demeaned, insulted, and harassed them.
When Papantoniadis became aware that a worker planned to quit, he violently choked the victim, who
managed to flee the restaurant. As others separately expressed their intentions to quit, he told one
victim he would kill him and call immigration authorities. Papantoniadis chased another worker, who
had also fled, and made a false report to the police to pressure the victim to return to work.
This is a joint investigation with HSI. United States v. Stavros Papantoniadis (D. Massachusetts)
54 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Employment and
Training Programs
Employment and Training Administration
Foreign Labor Certification Programs
Employment and Training Programs
Employment and Training Administration
The Employment and Training Administration administers federal workforce development
programs. This includes programs authorized by the Workforce Innovation and Opportunity
Act (WIOA) that provide employment assistance; labor market information; and job training for
adults, youth, dislocated workers, and other targeted populations. The WIOA aims to strengthen
the public workforce system and help get Americans—including youth and those with significant
barriers to employment—into high-quality jobs and careers. The WIOA also helps employers hire
and retain skilled workers.
Former Executive Director of Washington Tribal Non-Profit Sentenced
On May 30, 2024, Debbie Rawle, the former executive director of the Western Washington Indian
Employment Training Program (WWIETP), was sentenced to five months in prison and ordered to
pay restitution of more than $99,000 for embezzling from a federally funded program.
WWIETP received federal grant funds, including DOL funding, of more than $698,000 in 2018 and
more than $700,000 in 2019 to provide employment and training services for eligible tribal members.
In September 2019, the DOL-ETA, Division of Indian and Native American Programs uncovered
questionable personal expenditures made by Rawle on a WWIETP debit card. She used the
organization’s debit card for personal purchases, including various transactions at electronics stores,
a pool maintenance kit, $1000 in motorcycle accessories, a cedar pavilion, and an above-ground
swimming pool.
From approximately May 2018 through September 2019, the total loss attributable to Rawle’s
fraudulent misuse of a WWIETP debit card is more than $99,000.
This is a joint investigation with the FBI. United States v. Rawle (W.D. Washington)
56 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Employment and Training Programs
Foreign Labor Certification Programs
ETA administers a number of foreign labor certification (FLC) programs that allow U.S. employers to
employ foreign workers to meet domestic worker shortages: PERM, CW-1, H-1B, H-2A, and H-2B.
The PERM program allows an employer to hire foreign nationals to work in the United States on a
permanent basis while the CW-1, H-1B, H-2A, and H-2B programs are for temporary employment in
the United States. The CW-1 program allows employers to hire workers on a temporary basis in the
Commonwealth of the Northern Mariana Islands. The H-1B program allows employers to hire foreign
workers on a temporary basis in specialty occupations or as fashion models of distinguished merit
and ability. The H-2A program allows employers to hire foreign workers for temporary agricultural
jobs, in contrast to the H-2B program, which is for temporary non agricultural jobs. ETA ensures the
admission of foreign workers into the United States on a PERM, CW-1, H-2A, or H-2B visa will not
adversely affect job opportunities, wages, and working conditions of U.S. workers. The Department’s
Wage and Hour Division (WHD) has been delegated enforcement authority to ensure employers in
H-1B, H-2A, and H-2B programs are in compliance with labor certification requirements. The OIG
also investigates labor trafficking cases that involve fraud against FLC programs.
Idaho Foreman Pled Guilty to Extorting H-2A Visa Workers
On September 19, 2024, Ernesto Garibay Garza was sentenced to 27 months in federal prison for
extorting H-2A agricultural workers and filing a false tax return. Garza worked as a supervisor and foreman
of farm workers at F.D.C., an agricultural services company that operates farms throughout Idaho.
F.D.C. employed H-2A agricultural workers from approximately 2005 to 2019, specifically during the
months of March to November. During this time, Garza was responsible for preparing and submitting
payroll timesheets for H-2A workers based on the hours worked. He also assigned various tasks and
projects to the workers he supervised.
Between approximately 2014 and 2019, Garza charged certain H-2A agricultural workers $750 to
$2,500 to work at F.D.C. under the H-2A visa program. He charged the fees without F.D.C.’s knowledge
or approval. The H-2A workers paid the fees to Garza each year because they feared they would be
fired or prevented from returning to F.D.C. under the H-2A visa program in future years. Under H-2A
agricultural worker rules and regulations, Garza was not permitted to request or collect such fees.
Garza deposited more than $490,000 in unreported income into his personal bank accounts, a portion
of which came from the H-2A extortion scheme. Garza did not disclose the additional income on his
tax returns for tax years 2013 through 2019, which resulted in false Form 1040 tax returns being
prepared and filed.
This is a joint investigation with the IRS-CI. United States v. Garza (D. Idaho)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 57
Labor
Racketeering
Labor Racketeering
Labor Racketeering
Under the Inspector General Act of 1978, as amended, the OIG is responsible for investigating
labor racketeering and the influence of organized criminal enterprises involving unions, employee
benefit plans, and labor-management relations.
Labor racketeering refers to the infiltration, exploitation, or control of a union, employee benefit
plan, employer entity, or workforce, carried out through illegal, violent, or fraudulent means. OIG
labor racketeering investigations focus largely on individuals and organized criminal enterprises
engaged in embezzlement, extortion, violence against union members or employers, and other
related criminal activities.
Our investigations continue to identify fraudulent payments from employers to union
representatives in order to gain favorable labor agreements for the employer. Our investigations
have also identified complex financial and investment schemes used to defraud union affiliated
benefit plans, resulting in millions of dollars in losses to plan participants.
Connecticut Residents Sentenced for $40 Million Scheme to Steal Client Health
Care Funds and Defraud Lenders
On August 20, 2024, Anthony Riccardi was sentenced to 10 years in prison for conspiracy to commit
wire fraud and bank fraud. On September 12, 2024, Vanessa Battle, a co-conspirator, was sentenced
to 5 years of probation after she pled guilty to conspiracy to commit wire fraud and bank fraud. Both
Riccardi and Battle were ordered to pay more than $14.8 million in restitution, jointly and severally
with the other co-conspirators.
Riccardi was a co-owner and executive vice president of Employee Benefit Solutions (EBS), that,
among other things, provided third-party health care claims administration (TPA) services to clients
who elected to self-fund their employee health care plans. Battle was an EBS employee.
From 2015 to 2019, EBS served as a TPA for a company’s self-funded employee healthcare program
and generated bi-monthly invoices that were purportedly for healthcare expenses. During that
time, the company transferred approximately $26 million to EBS for payment of healthcare claims.
However, most of the funds were never used to pay the claims. Instead, approximately $17.87 million
in healthcare payments from the company were misappropriated with the overwhelming majority
transferred by EBS into its own operating account, which was used for non-health care expenses by
the managers and owners of EBS. This included home mortgages and personal credit card charges
relating to boating, luxury cars, and golf.
60 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Labor Racketeering
By 2017, as EBS buckled under mounting outstanding fiduciary obligations. Riccardi and Battle
falsified applications for various loans and merchant cash advances which were used, in part, to pay
various fiduciary obligations that EBS owed to their client company. As a result, EBS fraudulently
obtained millions of dollars in loans under the auspices of facilitating business for EBS.
This is a joint investigation with the DOL- EBSA, the United States Postal Inspection Service (USPIS),
and the USSS. United States v. Anthony Riccardi et al. (S.D. New York)
Former IBEW Local 98 Business Manager and Company Officials Sentenced for
Public Corruption and Embezzlement Convictions
On July 11, 2024, John Dougherty, former business manager of the International Brotherhood of
Electrical Workers Local Union 98 (Local 98), was sentenced to 72 months in prison and ordered to
forfeit approximately $350,000.
On September 11, 2024, Dougherty was ordered to pay more than $1.6 million in restitution, jointly and
severally with his co-conspirators, to Local 98 and approximately $126,000 to the IRS. On the same
date, Brian Burrows, former Local 98 president, was ordered to pay more than $925,000 in restitution,
jointly and severally with his co-conspirators, to Local 98 and approximately $10,000 to the IRS.
In January 2019, a federal grand jury indicted Dougherty, Burrows, and four other union employees
for multiple federal offenses connected to their illegal use of Local 98 funds for personal and other
unauthorized expenses. The use of union funds was contrary to the provisions of IBEW’s constitution,
the by-laws of Local 98, and the beneficial interests of Local 98 members. The indictment also
charged Dougherty and Burrows with concealing the embezzlement of Local 98’s funds by filing false
labor management reports with the DOL. They were also charged with tax fraud for failing to report
their personal use of the funds on their tax returns.
On December 7, 2023, a federal jury convicted Dougherty of 65 counts, including: conspiracy to
embezzle Local 98 funds; embezzlement; wire fraud; signing; and submitting false labor management
forms, and filing false federal income tax returns. The jury convicted Burrows of 20 counts, including:
embezzlement; signing and submitting false labor management forms; and filing false federal income
tax returns.
On November 15, 2021, during a separate trial for public corruption charges, Dougherty was
convicted of conspiracy to commit honest services fraud and honest services wire fraud.
This is a joint investigation with the FBI, the IRS-CI, the DOL-EBSA, the DOL-OLMS, and the
Pennsylvania State Police with assistance from the Pennsylvania Attorney General’s Office.
United States v. John Dougherty et al. (E.D. Pennsylvania)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 61
Departmental
Management
Departmental Management
Departmental Management
The OIG performs oversight work involving the Department’s operations, financial management,
and IT services.
THE U.S. DEPARTMENT OF LABOR DID NOT MEET THE
REQUIREMENTS FOR COMPLIANCE WITH THE PAYMENT INTEGRITY
INFORMATION ACT FOR FY 2023
Why OIG Conducted the Audit
The Payment Integrity Information Act of 2019 (PIIA) requires
federal agencies to identify programs susceptible to significant
improper payments, estimate the improper payments for
those programs, and report on actions to reduce the improper
payments in those programs.
What OIG Did
The OIG contracted with KPMG LLP (KPMG) to conduct a
performance audit related to DOL’s compliance with PIIA,
as defined in 31 U.S.C. § 3351(2), for the fiscal year ended
September 30, 2023. KPMG’s objective to evaluate DOL’s
compliance with PIIA included determining whether DOL met
six PIIA compliance requirements in relation to the UI, PUA, and
FECA programs.
What OIG Found
KPMG concluded DOL met five of the six requirements for compliance with PIIA for the UI program,35
three of the six requirements for the PUA program, and all six requirements for the FECA program.
35 As noted in the prior year report, DOL has continued to report the Federal State Unemployment Insurance
program, which includes the PEUC program and FPUC payment activity collectively as one program—the UI
program—based on OMB’s approval. This report, The U.S. Department of Labor Did Not Meet the Requirements for
Compliance with the Payment Integrity Information Act for FY 2022, Report No. 22-23-006-13-001 (June 9, 2023), is
available at: https://www.oig.dol.gov/public/reports/oa/2023/22-23-006-13-001.pdf.
64 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Departmental Management
See Table 2 for the requirements not met for UI and PUA.
Table 2: Criteria for PIIA Requirements Not Met for the UI Program and PUA
Program Requirement No. Criteria
Published improper payments information with the annual
financial statement of DOL for the most recent fiscal year,
PUA 1
and posted on the website of DOL that statement and any
accompanying materials required under guidance of OMB
Published improper payments reduction targets established
under section 3352(d) that DOL may have in the accompanying
PUA 5 materials to the financial statement for each program or activity
assessed to be at risk, and has demonstrated improvements and
developed a plan to meet the reduction targets
Reported an improper payment rate of less than 10 percent for
UI & PUA 6 each program and activity for which an estimate was published
under section 3352(c)
KPMG found requirements 1 and 5 were not met for the PUA program. DOL only reported PUA
program outlays from April 2020 until September 2021, when the program expired. Outlays reported
for that period were $121.2 billion. However, the PUA program has continued to have residual outlays
for eligible claims of $7.4 billion from its expiration through September 30, 2023. Additionally, DOL did
not report a reduction target for FY 2024 for the PUA program and did not publish a plan to meet a
reduction target. As a result, DOL was not in compliance with requirements 1 and 5 of PIIA.
KPMG also determined requirement 6 was not met for the UI or PUA programs because the
reported rates were above 10 percent. DOL reported a 14.83 percent improper payment rate and
an unknown36 payment rate of 1.64 percent, for a combined total rate of 16.47 percent, in FY 2023
for the UI program—compared to a combined total rate of 22.20 percent in FY 2022. For the PUA
program, DOL reported an 18.53 percent improper payment rate and an unknown payment rate of
17.40 percent for a combined total rate of 35.93 percent.
36 An unknown payment is defined as a payment that could be either proper or improper, but the agency is unable
to discern whether the payment was proper or improper as a result of insufficient or lack of documentation.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 65
Departmental Management
In addition, KPMG noted, during its review of the improper payment information reported through the
OMB data call, DOL management omitted $43.4 million in reported fraud for the FECA program and
excluded of $2.8 billion in established overpayments and $602.1 million in recoveries for the Federal
Pandemic Unemployment Compensation and PEUC programs. The errors occurred because DOL’s
review procedures were not designed at a level of precision to identify necessary changes to the
calculated formulas used within the supporting schedules for its OMB data call reporting.
What OIG Recommended
KPMG made three recommendations to DOL management to continue improvements needed
to meet PIIA thresholds, improve improper payments reporting, and improve completeness
of PUA reporting. DOL management agreed, in part, with two of the three recommendations.
However, DOL management did not concur with one finding regarding the PUA program’s
compliance with requirements 1 and 5 and the associated recommendation. KPMG reviewed
management’s response; however, management’s concerns did not result in any changes to
the finding or recommendation.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-007-13-001.pdf,
Report No. 22-24-007-13-001 (May 29, 2024).
DOL’s Purchase and Travel Card Risks Assessed as Low
The Government Charge Card Abuse Prevention Act of 2012 (Charge Card Act) was designed to
prevent recurring waste, fraud, and abuse of government-wide charge cards. We contracted with
KPMG to assist with the risk assessment of DOL’s purchase and travel card programs for the period
October 1, 2022, through September 30, 2023, pursuant to the Charge Card Act. To perform the risk
assessment, key program objectives were assessed for the purchase and travel card programs.
Various methods of review and analytical testing were used to assess the residual risks37 as of
September 30, 2023, assign a risk impact and risk likelihood level,38 and then assign a risk level
ranging from very low to very high. For the purchase card program, three objectives had a low risk
level and the other three had a very low risk level. For the travel card program, one objectives had a
moderate risk level, two had a low risk level, and three had a very low risk level (see Figure 4).
37 Residual risk is the exposure remaining from an inherent risk after action has been taken to manage it, using the
same assessment standards as the inherent assessment.
38 Risk impact is the likely magnitude that the risks would have on the key objective. Risk likelihood is the level of
possibility that a risk will occur that affects the key objective.
66 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Departmental Management
Figure 4: Definitions of Risk Impacts and Likelihoods
Risk
Risk Impact Definition Risk Likelihood Definition
Level
The degradation of an activity or role is severe, Risk event is almost certain
impacting the ability to meet one or more strategic to occur. Likelihood of
Very High
goals or objectives, produce key deliverables, or reach occurrence is 90-100 percent.
required levels of performance to meet the mission.
The degradation of an activity or role is major, Risk event is highly likely
requiring immediate escalation or management to occur. Likelihood of
High
intervention to reach required levels of performance of occurrence is 50-90 percent.
key functions.
The degradation of an activity or role is moderate withRisk event is possible
Moderate material impact on performance of key functions. to occur. Likelihood of
occurrence is 25-50 percent.
The degradation of an activity or role is minor. It is Risk event is unlikely
Low noticeable and may affect performance of key functions. to occur. Likelihood of
occurrence is 10-25 percent.
The degradation in activity or role is negligible and Risk event occurrence
Very Low is not expected to significantly affect performance of is remote. Likelihood of
key functions. occurrence is 0-10 percent.
Source: DOL OIG Framework for Enterprise Risk Management, Version 3.0, May 31, 2022
Based on the results of the assessment, the overall risk of illegal, improper, or erroneous use of
DOL’s purchase and travel cards is low. The detailed assessments of DOL’s purchase and travel card
programs were provided to DOL officials.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-006-50-598.pdf,
Report No. 22-24-006-50-598 (April 18, 2024).
District of Columbia Workmen’s Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report
The District of Columbia Workmen’s Compensation Act of 1928 Special Fund (DCCA Special Fund)
provides medical benefits, compensation for lost wages, and rehabilitation services for job-related
injuries, diseases, or death of certain private-sector workers in the District of Columbia. The DCCA
Special Fund also extends benefits to dependents if any injury resulted in the employee’s death.
The OIG contracted with public accounting firm KPMG to audit the financial statements of the DCCA
Special Fund as of September 30, 2023. KPMG issued an unmodified opinion, meaning the financial
statements presented fairly, in all material respects, the financial position of the DCCA Special Fund,
Semiannual Report to Congress | April 1, 2024–September 30, 2024 67
Departmental Management
and its net costs, changes in net position, and budgetary resources for the years then ended in
accordance with U.S. generally accepted accounting principles.
As part of its audit, KPMG also considered the DCCA Special Fund’s internal control over financial
reporting, but not for the purpose of expressing an opinion on the effectiveness of the DCCA Special
Fund’s internal control over financial reporting nor to identify all deficiencies that might be material
weaknesses or significant deficiencies. However, KPMG identified certain deficiencies in internal
control that it considers to be a material weakness.
The Office of Chief Financial Officer’s control for reviewing the District of Columbia Workmen’s
Compensation Act journal entries was not operating effectively. Specifically, the journal entry reviewer
did not identify the appropriate accounting entry associated with refunds of carrier assessments.
In addition, management omitted the impact of the refund of carrier assessments within financial
statement disclosures 6 and 7.
As part of obtaining reasonable assurance, KPMG also performed certain tests of the DCCA Special
Fund’s compliance with applicable laws and regulations, and its test results disclosed no instances of
noncompliance or other matters required to be reported under government auditing standards.
To address the deficiencies noted above, we recommend the Deputy Chief Financial Officer update
the journal entry review procedures to confirm it has all necessary information regarding a transaction
before the review and approval of journal entries.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-009-04-432.pdf,
Report No. 22-24-009-04-432 (July 17, 2024).
Longshore and Harbor Workers’ Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report
The Longshore and Harbor Workers’ Compensation Act Special Fund (Longshore Special Fund)
provides medical benefits, compensation for lost wages, and rehabilitation services for job-related
injuries and diseases sustained by private-sector workers in certain maritime and related employment.
The Longshore Special Fund also extends benefits to dependents if any injury results in the worker’s
death. The OIG contracted with public accounting firm KPMG to audit the financial statements of the
Longshore Special Fund as of September 30, 2023. KPMG issued an unmodified opinion, meaning
the financial statements presented fairly, in all material respects, the financial position of the Longshore
Special Fund, and its net costs, changes in net position, and budgetary resources for the years then
ended in accordance with U.S. generally accepted accounting principles.
As part of its audit, KPMG also considered the Longshore Special Fund’s internal control over
financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the
68 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Departmental Management
Longshore Special Fund’s internal control over financial reporting nor to identify all deficiencies
that might be material weaknesses or significant deficiencies. However, KPMG identified certain
deficiencies in internal control that it considers to be a material weakness.
The Office of Chief Financial Officer’s control for reviewing the Longshore and Harbor Workers’
Compensation Act journal entries was not operating effectively. Specifically, the journal entry reviewer
did not identify the appropriate accounting entry associated with refunds of carrier assessments.
In addition, management omitted the impact of the refund of carrier assessments within financial
statement disclosures 8 and 9.
As part of obtaining reasonable assurance, KPMG also performed certain tests of the Longshore Special
Fund’s compliance with applicable laws and regulations and its test results disclosed no instances of
noncompliance or other matters required to be reported under government auditing standards.
To address the deficiencies noted above, we recommend the Deputy Chief Financial Officer update
the journal entry review procedures to confirm it has all necessary information regarding a transaction
before the review and approval of journal entries.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-008-04-432.pdf,
Report No. 22-24-008-04-432 (July 17, 2024).
Service Auditors’ Report on the Integrated Federal Employees’ Compensation
System for the Period October 1, 2023, through June 30, 2024
The OIG contracted with the independent certified public accounting firm KPMG to perform an
examination of the Integrated Federal Employees’ Compensation System (iFECS) transaction
processing for application and general controls for the period October 1, 2023 through June 30,
2024. The examination was to determine if iFECS application and general controls, as described
in the report, were fairly presented, suitably designed, and effectively operating. The controls and
control objectives included in the description are those that the management of OWCP’s Division of
Federal Employees’ Longshore and Harbor Workers’ Compensation and the Office of the Assistant
Secretary for Administration and Management believe are likely to be internal controls for financial
reporting relevant to user entities of the FECA Special Fund and iFECS throughout the period.
KPMG examined the suitability of the design and operating effectiveness of the controls and control
objectives. KPMG concluded in all material respects that the description fairly presented the claims
processing system and that the related controls were suitably designed and operating with sufficient
effectiveness to provide reasonable, but not absolute, assurance that the control objectives were
achieved for the audit period.
This report, No. 22-24-010-04-431 (September 17, 2024), contains sensitive information and will not
be released publicly.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 69
Departmental Management
Single Audits
A single audit provides an organization-wide examination of an entity expending federal
assistance funds received for its operations. The audit is typically conducted annually by an
independent certified public accountant, and its objective is to provide assurance to the U.S.
government regarding the management and use of funds by recipients such as states, schools,
universities, and nonprofits.
Quality Control Review of Single Audits
Under OMB Uniform Guidance,39 cognizant federal agencies ensure the implementation of single
audit requirements. A nonfederal entity expending more than $50 million a year in federal awards has
a cognizant agency for audit.40 DOL is currently cognizant for 12 entities.
The OIG periodically performs Quality Control Reviews
(QCR) of single audits of entities over which DOL has
cognizance. During this reporting period, we conducted
three QCRs: (1) Quality Control Review of the Single
Audit of the Chicago Cook Workforce Partnership for the
Year Ended June 30, 2022; (2) Quality Control Review of
the Single Audit of Job Service North Dakota for the Year
Ended June 30, 2023; and (3) Quality Control Review
for the Single Audit of the County of Greenville, South
Carolina for the Fiscal Year Ended June 30, 2023.
Quality Control Review of the Single Audit of the Chicago Cook Workforce
Partnership for the Year Ended June 30, 2022
We performed a QCR of the independent certified public accounting firm Evolve Financial I’s single
audit of the Chicago Cook Workforce Partnership for the year ended June 30, 2022. Our QCR
covered the Workforce Innovation and Opportunity Act program cluster, which totaled $50.5 million
of DOL funds. We determined the single audit report and audit work performed by Evolve Financial
39 Uniform Guidance refers to 2 C.F.R. Part 200, OMB’s “Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards.”
40 According to Uniform Guidance, the designated cognizant agency for audit must be the federal awarding agency
that provides the predominant amount of funding directly to a nonfederal entity unless OMB designates a specific
cognizant agency for audit. Cognizant agencies for audit are the federal agencies designated to carry out the
responsibilities described in Uniform Guidance § 200.513(a).
70 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Departmental Management
I generally met the requirements of generally accepted government auditing standards, generally
accepted auditing standards, and the requirements of OMB Uniform Guidance. However, we found
Evolve Financial I needs to improve its maintenance of audit documentation and correctly report the
Type A/B Threshold on the data collection form. Since Evolve Financial I took corrective actions, our
report did not contain any recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/24-24-003-50-598.pdf,
Report No. 24-24-003-50-598 (May 16, 2024).
Quality Control Review of the Single Audit of Job Service North Dakota for the
Year Ended June 30, 2023
We performed a QCR of the independent certified public accounting firm Brady, Martz & Associates,
P.C.’s single audit of Job Service North Dakota for the year ended June 30, 2023. Our QCR
covered unemployment insurance and the employment service major program cluster, which totaled
$78.6 million of DOL funds. We determined the single audit report and audit work performed by
Brady, Martz & Associates, P.C. generally met the requirements of generally accepted government
auditing standards, generally accepted auditing standards, and the requirements of OMB Uniform
Guidance. However, we found Brady, Martz & Associates, P.C. needed to correctly report the Type
A/B Threshold. Since Brady, Martz & Associates, P.C. took corrective action, our report did not contain
any recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/24-24-004-50-598.pdf,
Report No. 24-24-004-50-598 (June 26, 2024).
Quality Control Review for the Single Audit of the County of Greenville, South
Carolina for the Fiscal Year Ended June 30, 2023
We performed a QCR of the independent certified public accounting firm Mauldin & Jenkins, LLC’s
single audit of the County of Greenville, South Carolina for the year ended June 30, 2023. Our QCR
covered the Workforce Innovation and Opportunity Act program cluster, which totaled $2.4 million of
DOL funds. We determined Mauldin & Jenkins, LLC’s audit work on the single audit was acceptable
and met the requirements of generally accepted government auditing standards, generally accepted
auditing standards, and OMB Uniform Guidance. Our report did not contain any recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/24-24-005-50-598.pdf,
Report No. 24-24-005-50-598 (September 4, 2024).
Semiannual Report to Congress | April 1, 2024–September 30, 2024 71
Employee Integrity
Investigations
Employee Integrity Investigations
Employee Integrity Investigations
The OIG is responsible for investigating possible misconduct or criminal activities involving DOL
employees or individuals providing services to the Department.
• The OIG conducted an investigation into allegations that the DOL overpaid for a contract for
scheduling internal DOL conference rooms. The investigation determined a new contract for
services was approved and was within the allocated funding for the project. No further action
was warranted.
• The OIG conducted an internal investigation into allegations that a senior management official
engaged in misconduct in their official position. The investigation determined there was no
evidence to support the allegations. No further action was warranted.
• The OIG conducted an internal investigation into allegations that a senior employee was
engaged in a personal business during duty hours. The investigation was referred for
prosecution but later declined and referred for administrative action. The employee resigned in
lieu of termination.
• The OIG conducted an internal investigation into allegations that a senior management official
misused official travel funds during overseas travel. The investigation determined there was no
evidence to support the allegation. No further action was warranted.
74 Semiannual Report to Congress | April 1, 2024–September 30, 2024
OIG Whistleblower
Activities
OIG Whistleblower Activities
OIG Whistleblower Activities
Whistleblower Protection Coordinator
DOL employees, contractors, subcontractors, and grantees perform an important service by
reporting evidence of wrongdoing, including misconduct, fraud, waste, and abuse, in DOL programs.
Whistleblowers should never be subjected to, or threatened with, retaliation for having engaged
in a protected communication or protected activity. The OIG plays a vital role in ensuring that
DOL employees and employees of DOL grantees and contractors are informed of their rights and
protections against retaliation for “blowing the whistle.” This work is done by the OIG Whistleblower
Protection Coordinator Program, housed in the OIG’s Office of Legal Services.
Pursuant to Section 2 of the Whistleblower Protection Coordination Act of 2018 (S.1869, June 25, 2018),
every Inspector General’s office is required to designate a Whistleblower Protection Coordinator.
According to Section 2, the Whistleblower Protection Coordinator:
1. educates agency employees about prohibitions against retaliation for protected disclosures;
2. educates agency employees who have made or are contemplating making a protected disclosure
about their rights and the remedies against retaliation for protected disclosures, including the
means by which employees may seek review of any allegation of reprisal, as well as about the
roles of the OIG, the Office of Special Counsel, the Merit Systems Protection Board, and any
other relevant entities; and
3. provides general information about the timeliness of such cases, the availability of any
alternative dispute mechanisms, and avenues for potential relief. Within the OIG, a Supervisory
Associate Counsel to the Inspector General has been designated to serve as the Whistleblower
Protection Coordinator.
Pursuant to this designation, the Whistleblower Protection Coordinator has:
• provided input into training that is required to be completed by all DOL employees, entitled
“Prohibited Personnel Practices, Whistleblower Protection”;
• provided input into training that is required to be completed by all DOL supervisors and
managers entitled “Responding to Whistleblower Retaliation Complaints/Overview of Prohibited
Personnel Practices – Annual Training” and provided live training to DOL supervisors and
managers in May 2024;
76 Semiannual Report to Congress | April 1, 2024–September 30, 2024
OIG Whistleblower Activities
• developed training for new employees titled “Whistleblower Rights and Protections for DOL
Employees” that is included in all DOL employees’ New Employee Orientation and regularly
provides this training live to Solicitor’s Office’s Honors Attorneys;
• updated the DOL-OIG public-facing website titled “Whistleblower Protection Coordinator,” which
is available to all DOL and OIG employees, to provide information on whistleblower protections
and options for DOL employees and employees of DOL contractors and grantees;
• established a dedicated e-mail address—OIGWhistleblower@oig.dol.gov—respond to
whistleblower-related inquiries from DOL employees and employees of DOL contractors
and grantees;
• obtained the OIG’s recertification of its 2302(c) program from the Office of Special Counsel (July 2023);
• monitored whistleblower retaliation complaints received by the OIG, as well as whistleblower
retaliation investigations conducted by the OIG;
• conducted training for various agencies within DOL upon request; and
• participated on the panel of Whistleblower Protection Coordinators for the Council of the
Inspectors General on Integrity and Efficiency Whistleblower Education Forum.
Whistleblower Retaliation Investigations
The OIG can initiate its own investigations into allegations of improper or illegal retaliation brought by
DOL employees or, on a discretionary basis, refer such allegations to the Office of Special Counsel
for review and investigation.
Further, pursuant to 41 U.S.C. § 4712, the OIG is required, with some exceptions, to investigate
whistleblower retaliation allegations made by employees of DOL contractors or grantees.
Table 3: Whistleblower Investigations, April 1, 2024-September 30, 2024
Investigation Type Number
Pending DOL employee complaint investigations 3
Reports related to DOL employee whistleblower retaliation complaints sent to the
1
appropriate agencies within the Department
Grantee/contractor employee complaints closed after preliminary inquiry 0
Pending grantee/contractor employee complaint investigations 2
Reports pending with DOL 2
Decision issued by the DOL Assistant Secretary for Administration and Management in
0
grantee/contractor employee complaints
Semiannual Report to Congress | April 1, 2024–September 30, 2024 77
Legislative
Recommendations
Legislative Recommendations
Legislative Recommendations
The Inspector General Act of 1978, as amended, requires the Office of Inspector General (OIG)
to review existing or proposed legislation and regulations and to make recommendations in the
Semiannual Report to Congress concerning their impact both on the economy and efficiency
of the Department’s programs and on the prevention of fraud, waste, and abuse. The OIG
continues to propose the following legislative actions to increase efficiency and protect the U.S.
Department of Labor’s (DOL or Department) programs.
Inspector General Larry D. Turner, in congressional testimonies and through other means, highlighted
four high-priority recommendations for congressional consideration:
1. Immediately extend the statute of limitations for fraud involving pandemic-related unemployment
insurance (UI) programs;
2. Ensure DOL and the OIG have ongoing, timely, and complete access to UI claimant data and
wage records;
3. Grant the OIG statutory authority to participate in asset forfeiture funds to combat UI fraud and
other crime; and
4. Ensure effective payment integrity controls to reduce improper payments in all UI programs,
including temporary ones, such as through broader requirements for mandatory cross-matching.
Details on these and other legislative recommendations follow.
Immediately Extend the Statute of Limitations Associated with Pandemic-Related
UI Fraud
Time is running out to extend the statute of limitations associated with pandemic-related UI fraud.
Unless Congress acts urgently, the statute of limitations for many of the OIG’s pandemic-related UI
fraud investigations will begin to expire in early 2025. This is our final Semiannual Report to Congress
before these statutes begin to expire, substantially restricting our ability to pursue justice in these
cases. Given that the statutes often used to prosecute UI fraud have a 5-year limitation, many groups
and individuals that have defrauded the UI program may escape justice.
Even with the OIG’s tireless efforts, a failure to extend the current statute of limitations associated
with UI fraud means federal law enforcement will have to stop short of fully investigating and
prosecuting some of the most egregious cases of pandemic UI fraud. This is particularly the case
80 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Legislative Recommendations
given the volume and complexity of UI fraud matters we investigate. This issue is further complicated
by our limited resources resulting from the expenditure of all supplemental funding provided to
conduct oversight of pandemic-related programs. The U.S. Small Business Administration faced a
similar issue regarding the statute of limitations for pandemic-related fraud in the Paycheck Protection
and Economic Injury Disaster Loan programs. To address those concerns, Congress passed
legislation to extend associated statutes of limitations.
Congress could likewise act to extend the statute of limitations for fraud associated with pandemic-
related UI programs. This would help ensure both investigators and prosecutors have time to
effectively pursue and hold accountable those who defrauded the UI programs during the pandemic.
With an extension of the statute of limitations, and appropriate resources, the OIG could continue to
vigorously pursue those who defrauded pandemic UI programs, particularly by means of large-scale
identity theft schemes.
Ensure DOL and OIG Access to UI Claimant Data and Wage Records
In addition to the authority provided by the Inspector General Act of 1978, as amended, Congress
should consider legislative action specifically authorizing DOL and the OIG to have ongoing, timely,
and complete access to State Workforce Agencies’ (SWA) UI claimant data and wage records for our
respective oversight responsibilities. The Department has stated that—outside of revising existing
regulations through notice and rulemaking—it lacks the authority to require SWAs to provide the OIG
with access to UI claimant data and wage records except when the OIG is investigating a particular
instance of suspected UI fraud.
DOL is in the process of amending the regulations to facilitate
Ongoing, timely, and
the OIG’s ongoing access to UI data. However, detriments to this
complete access to SWA
approach include potential gaps in data availability given how
UI claimant data and wage
long the rulemaking process can take. Furthermore, the OIG is
records would assist in
already authorized under the Inspector General Act of 1978, as
enabling the OIG to quickly
amended, to have timely access without constraints to this data
identify large-scale fraud
and needs access to all UI program data. Ongoing, timely, and
and expand its current
complete access to SWA UI claimant data and wage records
efforts to share emerging
would assist in enabling the OIG to quickly identify large-scale
fraud trends with the
fraud and expand its current efforts to share emerging fraud
Employment and Training
trends with the Employment and Training Administration (ETA)
Administration and states
and states to strengthen the UI program and deter fraud. Further,
to strengthen the UI
this action would assist the Department in its programmatic
program and deter fraud.
oversight responsibilities to identify weak controls and improper
payments in the UI program.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 81
Legislative Recommendations
To underscore this point, based on the data obtained by the OIG, our auditors, investigators, and data
scientists collaboratively identified $46.9 billion dollars in potential fraud paid in six specific high-risk
areas, such as multistate claimants and deceased persons.41 The OIG has shared its methodology
and underlying data for these six high-risk areas with DOL for further dissemination to SWAs. This
information allows the Department and SWAs to analyze concerning claims and to strengthen
controls to detect and deter future fraud. The OIG was further able to recommend the Department
make programmatic changes and put billions in federal funds to better use. If Congress provides the
OIG with the requested access, the OIG can: conduct data analytics; identify program weaknesses;
and recommend corrective actions that would improve the timeliness of UI benefit payments and the
integrity of the UI program.
Authorize OIG Participation in Asset Forfeiture Funds
Legislative authority in the area of asset forfeiture would increase the OIG’s ability to effectively and
efficiently investigate UI fraud and other crimes. Allowing the OIG to recover fraudulently obtained
funds would deprive criminals of their ill-gotten proceeds.42 Asset forfeiture is a critical legal tool that
serves a number of compelling law enforcement purposes. It is designed to deprive criminals of the
proceeds of their crimes, to break the financial backbone of organized criminal syndicates, and to
recover property that may be used to compensate victims and deter criminal activity.
While the OIG could make significant use of asset forfeiture in our UI fraud investigations, we could
also use that authority in other areas of our investigative jurisdiction, including labor trafficking
involving the Department’s foreign labor certification programs; Office of Workers Compensation
provider fraud matters; and labor racketeering matters involving labor unions and their affiliated
employee benefit plans. Currently, the OIG is not a participant in the U.S. Department of the Treasury
(Treasury) Forfeiture Fund or the U.S. Department of Justice (DOJ) Asset Forfeiture Fund. This lack
of authority to participate limits the OIG’s ability to effectively recover proceeds of UI fraud and other
crimes under the OIG’s jurisdiction. Statutory authority to seize and forfeit illicit funds would allow the
OIG to participate in the Treasury Forfeiture Fund and the DOJ Asset Forfeiture Fund, thus enabling
the OIG to better combat UI fraud and other crimes in the future.
41 Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to Improve Oversight of the
Unemployment Insurance Program, Report No. 19-23-012-03-315 (September 25, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-012-03-315.pdf
42 According to the FBI, “Asset forfeiture entails a legal process whereby the ownership of an asset is removed from
individuals because they used it illegally, received or derived it from illicit activity, or employed it to facilitate a crime.
The vesting of title with the government follows a civil, criminal, or administrative proceeding.” FBI, Law Enforcement
Bulletin, “Asset Seizure and Forfeiture: A Basic Guide,” (August 10, 2016), available at:
https://leb.fbi.gov/articles/featured-articles/asset-seizure-and-forfeiture-a-basic-guide
82 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Legislative Recommendations
Enact the UI Integrity Legislative Proposals
The OIG encourages Congress to consider and adopt key DOL proposals to aid the Department’s
efforts to combat improper payments in the UI program. In its Fiscal Year (FY) 2025 Congressional
Budget Justification,43 the Department proposed provisions designed to provide new and expanded
tools and controls for states to help ensure workers are properly paid and to prevent improper
payments, including fraud, in the UI system.
The Department stated the proposals collectively would
The OIG encourages Congress
result in savings of more than $3 billion over the 10-year
to consider and adopt key DOL
budget window. These are similar to DOL proposals
proposals to aid the Department’s
included in prior DOL budget requests that would help
efforts to combat improper
address UI program integrity and the high improper
payments in the UI program.
payment rates in the UI program. These proposals include
the following:
• require SWAs to cross-match UI claims against the National Directory of New Hires;
• require SWAs to cross-match UI claims with a system(s)…that contains information on individuals
who are incarcerated;
• require states to disclose information to the OIG;
• allow SWAs to retain up to 5 percent of recovered fraudulent UI overpayments for program
integrity use;
• require SWAs to use [UI] penalty and interest collections solely for UI administration; and
• permit the Department to collect and store states’ UI claimant data.
These legislative proposals are consistent with previous OIG reporting to improve the UI program. To
maintain UI program integrity, the OIG has recommended establishing legislation that requires SWAs
to cross-match high-risk areas, such as UI benefits paid to individuals with Social Security numbers
filed in multiple states and belonging to deceased persons.
Lack of Fiscal Year Limitations Hinders DOL’s Ability to Properly Manage
Temporary Emergency Program Funds
The OIG encourages Congress to implement a time limit for states’ acceptance of UI emergency
program benefit claims after the expiration of programs’ eligibility periods for current and future
temporary emergency benefit programs.
43 DOL FY 2025 Congressional Budget Justification, ETA, State Unemployment Insurance and Employment Service
Operations, available at: https://www.dol.gov/sites/dolgov/files/general/budget/2025/CBJ-2025-V1-07.pdf
Semiannual Report to Congress | April 1, 2024–September 30, 2024 83
Legislative Recommendations
During our audit of the Mixed Earners Unemployment Compensation (MEUC) program, we found
that, under the enacting law and agreements between the Department and SWAs, SWAs are entitled
to reimbursement of 100 percent of the cost of eligible benefits paid under the Mixed Earners
Unemployment Compensation program no matter when the claim is filed. Funds for this program, like
most pandemic-related UI programs, were appropriated by Congress without fiscal year limitation.
Because of this, the Employment and Training Administration (ETA) continues to set aside pandemic
funds to reimburse SWAs for eligible MEUC claims. The ETA must reimburse states until all eligible
claims from the program period have been administered—even if this requires the agency to do so
years after the conclusion of the program period in September 2021.
If the enacting law and subsequent agreements between DOL and the SWAs contained a termination
date by which all claims must be administered or returned to Treasury, remaining pandemic funds
could be returned to Treasury sooner and reprogrammed for more urgent needs of the American
taxpayer. The pandemic assistance funds, such as MEUC, were authorized to quickly meet the urgent
financial needs of American taxpayers during the pandemic. However, paying pandemic-related
claims long after the pandemic has ended and the U.S. economy has recovered, is counterproductive
to the original intent of the funds—even if claimants are eligible under the program period.
Provide Authority to Ensure the Integrity of the H-1B Program
If DOL is to have a meaningful role in the foreign labor certification process for H-1B specialty
occupation visas, it must have the statutory authority to ensure the integrity of that process. This
authority should include the ability to verify the accuracy of information provided on labor condition
applications and to initiate its own H-1B investigations more broadly.
Currently, unlike H-2A and H-2B investigations, DOL’s authority
to investigate H-1B employers is limited and typically requires
a complaint by an aggrieved party. In the absence of such a
complaint, with limited exceptions, DOL may only initiate its
own H-1B investigations if the Secretary (or Acting Secretary)
personally certifies there is reasonable cause to believe the
employer is not in compliance. Even assuming such personal
certification is obtained, the scope of Secretary-certified
investigations is limited. These investigations are restricted to
willful, pattern- or- practice, or substantial violations of the Labor
Condition Application requirements regarding prevailing wage
and benefits, working conditions, labor disputes, recruitment of
U.S. workers, and notification of applications.
Additionally, such an investigation must be conducted under specific procedures and may only be
initiated for reasons other than completeness and obvious inaccuracies by the employer in complying
84 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Legislative Recommendations
with H-1B requirements. In most circumstances, a notice also must be provided to the employer to
allow a rebuttal of the allegations before the investigation begins.
Our concern with the Department’s limited ability to ensure the integrity of the certification process
is heightened by the results of OIG audits and investigations showing the program is susceptible to
significant fraud and abuse, including by certain employers and attorneys. For example, some staffing
companies utilize the H-1B program without having scheduled jobs already lined up. Some employers
and attorneys misrepresent their need for workers to DOL, then reassign the extra workers to other
companies or require foreign workers to find their own work. There have also been instances when
companies illegally generated profits by requiring foreign workers to pay fees and recurring payments
to secure H-1B visas.
Without statutory authority, the Department generally cannot verify employers’ attestations to H-1B
certifications unless a complaint is filed or the Department utilizes a Secretary-certified investigation.
The Department can also initiate a random investigation of a willful violator within 5 years of the
violation being cited. As some foreign workers may be reluctant to file complaints for fear of retaliation
and losing their jobs, the Department’s process is unlikely to result in verification action being taken.
Amend Pension Protection Laws
Legislative changes to the Employment Retirement Income Security Act of 1974 (ERISA) and criminal
penalties for ERISA violations would enhance the protection of assets in pension plans. To this end,
the OIG continues to recommend the following legislative actions:
• Repeal ERISA’s limited-scope audit exemption. This exemption excludes pension plan
assets invested in financial institutions, such as banks and savings and loan firms, from audits of
employee benefit plans. Notwithstanding recent changes to auditing standards that strengthen
limited-scope audits, these audits prevent independent public accountants who are auditing
pension plans from rendering an opinion on the plans’ financial statements in accordance
with professional auditing standards. These “no opinion” audits offer weak assurance of asset
integrity either to plan participants or to the Department.
• Expand the authority of the Employee Benefits Security Administration to correct
substandard benefit plan audits and ensure that auditors with poor records do not
perform additional audits. Changes should include providing the Employee Benefits Security
Administration with greater enforcement authority over registration, suspension, and debarment
as well as the ability to levy civil penalties against employee benefit plan auditors. The ability to
correct substandard audits and take action against auditors is essential because benefit plan
audits help protect participants and beneficiaries by ensuring the proper valuation of plan assets
and computation of benefits.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 85
Legislative Recommendations
• Require direct reporting of ERISA violations to DOL. Under current law, a pension
plan auditor who finds a potential ERISA violation is responsible for reporting it to the plan
administrator, but not directly to DOL. To ensure improprieties are addressed, we recommend
plan administrators or auditors be required to report potential ERISA violations directly to DOL.
This change would ensure the timely reporting of violations and would more actively involve
auditors in safeguarding pension assets as a first line of defense against the abuse of workers’
pension plans.
• Strengthen criminal penalties in U.S.C. Title 18. Three sections of U.S.C. Title 18 serve
as the primary criminal enforcement tools for protecting pension plans covered by ERISA.
Section 664 sets penalties for embezzlement or theft from employee pension and welfare plans;
Section 1027 sets penalties for making false statements in documents required by ERISA; and
Section 1954 sets penalties for giving or accepting bribes related to the operation of ERISA-covered
plans. Sections 664 and 1027 subject violators to up to 5 years’ imprisonment while Section
1954 calls for up to 3 years’ imprisonment for violators. The OIG recommends raising the
maximum penalty up to 10 years for all three violations to correspond with the 10-year penalty
imposed by Section 669 (for theft from health care benefit programs). An increased penalty
would serve as a greater deterrent and, consequently, further protect employee pension plans.
Improve the Integrity of the FECA Program
Legislative reforms should be considered in the following areas to improve the effectiveness and
integrity of the Federal Employees’ Compensation Act (FECA) program:
• Provide statutory access to the National Directory of New Hires and Social Security wage
records. Currently, the Department has no direct access to the National Directory of New Hires
data and can access Social Security wage information only if the claimant gives it permission.
Granting the Department routine access to these databases would aid in detecting fraud
committed by individuals receiving FECA wage loss compensation but failing to report income
they have earned.
• Establish a 3-day waiting period at the beginning of the claims process. FECA legislation
provides for a 3-day waiting period, which is intended to discourage the filing of frivolous claims.
As currently written, however, the legislation places the waiting period at the end of the 45-day
continuation-of-pay period, thereby negating its purpose. Legislation that passed in 2006 placed
the waiting period for postal employees immediately after an employment-related injury. If the
intent of the law is to ensure a true waiting period before an employee applies for benefits, then
that period should likewise come immediately after an employment-related injury—for all federal
workers, not exclusively postal employees. This proposal was included in the President’s FY 2021
budget as part of the Office of Workers’ Compensation Programs’ (OWCP) FECA reform.
86 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Legislative Recommendations
• Allow the temporary suspension of medical providers pending the outcome of
criminal investigations. While FECA regulations allow OWCP to exclude a provider through
administrative means, OWCP must give notice to the provider and afford the provider an
opportunity for a hearing before DOL’s Office of Administrative Law Judges. This process and
the various procedures involved can be lengthy. Legislative changes are necessary to enable
DOL to immediately suspend all medical providers who have been indicted for fraudulent billing
practices from providing further medical services and receiving payments. This proposal was
included in the President’s FY 2021 budget as part of OWCP’s FECA reform.
Authorize and Increase Authority to Enforce Disclosure Requirements
The Office of Labor-Management Standards (OLMS) is responsible for enforcing requirements
under the Labor-Management Reporting and Disclosure Act of 1959 for disclosing persuader
activity when an employer hires someone to influence an employee regarding unionization.
OLMS promotes labor-management transparency by making available reports showing employers’
expenditures for their activities in persuading workers during union organizing campaigns. OLMS
obtains and publicly releases persuader activity reports. In May 2024, we reported that OLMS’ limited
enforcement authority, such as the ability to levy fines and penalties, gives employers and consultants
little incentive to comply with the requirements. The OIG recommends Congress work with OLMS to
take legislative action to increase OLMS’ enforcement authority.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 87
Appendices
Appendices
Reporting Requirements Under
the Following Acts
The Inspector General Act of 1978, as Amended
REPORTING REQUIREMENT PAGE
Recommendations on existing and proposed legislation and regulations relating to the
Section 4(a)(2) 79
programs and operations of DOL
Description of significant problems, abuses, and deficiencies relating to the administration
Section 5(a)(1) of programs and operations of the establishment and associated reports and All
recommendations for corrective action made by the Office
Identification of each recommendation made before the reporting period, for which
Section 5(a)(2) corrective action has not been completed, including the potential costs savings associated All
with the recommendation
Section 5(a)(3) Summary of significant investigations closed during the reporting period 36-61
Identification of the total number of convictions during the reporting period resulting from
Section 5(a)(4) 118
investigations
Information regarding each audit, inspection, or evaluation report issued during the
reporting period, including—
(A) a listing of each audit, inspection, or evaluation;
Section 5(a)(5) (B) if applicable, the total dollar value of questioned costs (including a separate category for 94
the dollar value of unsupported costs) and the dollar value of recommendations that funds
be put to better use, including whether a management decision had been made by the end
of the reporting period
Information regarding any management decision made during the reporting period with
Section 5(a)(6) 99
respect to any audit, inspection, or evaluation issued during a previous reporting period
Information from the Federal Financial Management Improvement Act Section 804(b) —
None to
Section 5(a) (7) instances in which an agency has not met intermediate target dates in a remediation plan,
report
and the reasons
Peer review reporting:
Section 5(a)(8) (A) results of any peer review conducted by another OIG, or 120
(B) a statement identifying the date of the last peer review conducted
continued on next page
90 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
None to
Section 5(a)(9) Outstanding peer review recommendations
report
Section 5(a) Peer reviews conducted by the OIG and recommendations outstanding or not fully None to
(10) implemented report
Statistical tables on investigative findings showing total number of:
(A) reports issued;
Section 5(a) (B) persons referred to the U.S. Department of Justice for prosecution;
118
(11) (C) persons referred to state and local prosecuting authorities; and
(D) indictments and criminal information that resulted from any prior referral to prosecuting
authorities
Section 5(a)
Metrics used for developing the data for the statistical tables 118
(12)
Summary of investigations of senior government employees where allegations of
Section 5(a)
misconduct were substantiated, including the facts, circumstances, status, and disposition 73
(13)
of the matter
Description of whistleblower retaliation cases including information about the official found
Section 5(a)
to have engaged in retaliation and what, if any, consequences that establishment imposed 75
(14)
to hold that official accountable
Information related to interference by the establishment, including—
(A) a detailed description of any attempt by the establishment to interfere with the
independence of the Office, including—
Section 5(a) (i) with budget ‑constraints designed to limit the capabilities of the Office; and
None to
(15) and (ii) incidents where the establishment has resisted or objected to oversight activities of the
report
Section 6(c)(2) Office or restricted or significantly delayed access to information,
including the justification of the establishment for such action; and
(B) a summary of each report made to the head of the establishment under section 6(c)(2)
during the reporting period
(A) Descriptions of inspections, evaluations, audits, and investigations that are closed and
Section 5(a) were not disclosed to the public; and None to
(16) (B) Descriptions of investigations conducted by the office involving a senior government report
employee that are closed and were not disclosed to the public
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
REPORTING REQUIREMENT PAGE
Section
Peer review reporting 120
989(C)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 91
Appendices
Funds Recommended for Better Use
Number Dollar Value
Funds Put to a Better Use Agreed to by DOL44
of Reports ($ millions)
For which no management decision had been made as of the commencement of the reporting
3 $30,97045
period
Issued during the reporting period 0 $0
Subtotal 3 $30,970
For which a management decision was made during the reporting period:
• Dollar value of recommendations that were agreed to by management
• Dollar value of recommendations that were not agreed to by management 0 $0
For which no management decision had been made as of the end of the reporting period 3 $30,970
Number Dollar Value
Funds Put to a Better Use Implemented by DOL
of Reports ($ millions)
For which final action had not been taken as of the commencement of the reporting period 4 $44,260
For which management or appeal decisions were made during the reporting period
Subtotal 4 $44,260
For which management decision was made during the reporting period:
• Dollar value of recommendations that were actually completed 1 $156
• Dollar value of recommendations that management has subsequently concluded should not or
0 $0
could not be implemented or completed
For which no final action had been taken by the end of the reporting period 3 $44,104
44 The term “recommendation that funds be put to better use” means a recommendation by the OIG that funds
could be used more efficiently or achieve greater program effectiveness if management took actions to implement
and complete the recommendation. This term is defined by the Inspector General Act of 1978, as amended, and
includes, among other things, reductions in future outlays; deobligation of funds from programs or operations;
costs not incurred in the future by implementing recommended improvements related to the operations of the
establishment, a contractor, or a grantee; and any other savings specifically identified, including reverting funds to
Treasury to be used for other purposes.
45 Due to the use of rounding methodology, the beginning balance shown differs from the ending balance reported
during the last SAR.
92 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Questioned Costs
Questioned
Number
Resolution Activity: Questioned Costs46 Costs
of Reports
($ millions)
For which no management decision had been made as of the commencement of the reporting
2 $426
period (as adjusted)
Issued during the reporting period 1 $130
Subtotal 3 $556
For which a management decision was made during the reporting period:
• Dollar value of disallowed costs
• Dollar value of costs not disallowed 0 $0
For which no management decision had been made as of the end of the reporting period 3 $556
For which no management decision had been made within six months of issuance 0 $0
Disallowed
Number
Closure Activity: Disallowed Costs47 Costs
of Reports
($ millions)
For which final action had not been taken as of the commencement of the reporting period
3 $173
(as adjusted)
For which management or appeal decisions were made during the reporting period 0 0
Subtotal 3 $173
For which final action was taken during the reporting period:
• Dollar value of disallowed costs that were recovered 0 $0
• Dollar value of disallowed costs that were written off 0 $0
• Dollar value of disallowed costs that entered appeal status 0 $0
For which no final action had been taken by the end of the reporting period 3 $173
46 As defined by the Inspector General Act of 1978, as amended, questioned costs include alleged violations of law,
regulations, contracts, grants, or agreements; costs not supported by adequate documentation; or the expenditure of
funds for an intended purpose that was unnecessary or unreasonable.
47 Disallowed costs are costs that the OIG questioned during an audit as unsupported or unallowable and that the
grant/contracting officer has determined the auditee should repay. The Department is responsible for collecting the
debts established. The amount collected may be less than the amount disallowed, and monies recovered usually
cannot be used to fund other program operations and are returned to Treasury.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 93
Appendices
Final Audit Reports Issued
Management Decision Made by
Number of Recommendations Funds Put To Better Use ($)
Questioned Costs ($)
Report Title; Report Number; Date Issued
End of Reporting Period
Employment and Training Administration
COVID-19: ETA’s Oversight of Short-Time Compensation Did
Not Detect $129.6 Million in Questioned Costs; 3 $129,565,581 $0 Yes
Report No. 19-24-003-03-315; 06/26/24
ETA Did Not Ensure States Sufficiently Implemented the
Mixed Earners Unemployment Compensation Program; 4 $0 $0 No
Report No. 19-24-005-03-315; 09/11/24
Total (2 Reports)
Mine Safety and Health Administration
MSHA Generally Provided Adequate Oversight of Miner No
Training, Though Opportunities to Strengthen Controls Exist; 0 $0 $0 Response
Report No. 19-24-004-06-001; 09/12/24 Required
Total (1 Report)
Office of Labor Management Standards
OLMS Can do More to Protect Workers’ Rights to Unionize
Through Enforcing Persuader Activity Disclosure; 6 $0 $0 Yes
Report No. 09-24-002-16-001; 05/03/24
Total (1 Report)
continued on next page
94 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Office of the Assistant Secretary for Administration and Management
U.S. Department of Labor’s Purchase and Travel Card Risk No
Assessed as Low; 0 $0 $0 Response
Report No. 22-24-006-50-598; 04/18/24 Required
DOL Implemented its Wireless Network Securely, Through
48
Security Gaps Exist in Testing, Updating, Patching, and
4 $0 $0 No
Continuous Review;
Report No. 23-24-003-07-720; 09/11/24
Total (2 Reports)
Office of the Chief Financial Officer
The U.S. Department of Labor Did Not Meet the
Requirements for Compliance with the Payment Integrity
3 $0 $0 Yes
Information Act for Fiscal Year 2023;
Report No. 22-24-007-13-001; 05/29/24
Total (1 Report)
Office of Workers’ Compensation Programs
Longshore and Harbor Workers’ Compensation Act Special
Fund Financial Statements and Independent Auditors’ Report
1 $0 $0 Yes
September 30, 2023, and 2022;
Report No. 22-24-008-04-432; 07/17/24
District of Columbia Workmen’s Compensation Act Special
Fund Financial Statements and Independent Auditors’
1 $0 $0 Yes
Report September 30, 2023, and 2022;
Report No. 22-24-009-04-432; 07/17/24
OWCP Could Improve Its Existing Guidelines for Processing
DEEOIC Claims; 5 $0 $0 Yes
Report No. 09-24-001-04-437; 05/02/24
Service Auditors’ Report on the Integrated Federal
49
Employees’ Compensation System, and
Service Auditors’ Report on the Optum Workers’ No
Compensation and Auto No-Fault's Retail Pharmacy Network 0 $0 $0 Response
Services System, and Service Auditors’ Report on the U.S. Required
Department of Labor Workers’ Compensation Medical Billing
Program System; Report No. 22-24-010-04-431; 09/17/24
Total (4 Reports)
Final Audit Total (11 Reports) 27 $129,565,581 $0
48 This report contains sensitive information and content was not posted for public viewing
49 This report contains sensitive information and content was not posted for public viewing.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 95
Appendices
Other Reports
Management Decision
Number of
Report Title; Report Number; Date Issued Made by End of
Recommendations
Reporting Period
Employment and Training Programs
Workforce Innovation and Opportunity Act
Quality Control Review of the Single Audit of the Chicago Cook Workforce
Partnership for the Year Ended June 30, 2022; 0 No Response Required
Report No. 24-24-003-50-598; 05/16/24
Quality Control Review of the Single Audit of Job Service North Dakota
for the Year Ended June 30, 2023; Report No. 24-24-004-50-598; 0 No Response Required
06/26/24
Quality Control Review for the Single Audit of the County of Greenville,
South Carolina for the Fiscal Year Ended June 30, 2023; 0 No Response Required
Report No. 24-24-005-50-598; 09/04/24
Total (3 Reports)
Other Reports Total (3 Reports) 0
96 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Unresolved Audit Reports Over 6 Months Old
Number of Unresolved
Questioned
Agency Report Title; Report Number; Date Issued
Recommendations
Costs ($)
Agency Management Decision or Grant/Contracting Officer’s Final Determination Did Not Resolve;
OIG Negotiating with Agency
COVID-19: More Can Be Done to Mitigate Risk to Unemployment
ETA Compensation Under the CARES Act; 1 $0
Report No. 19-20-008-03-315; 08/07/20
Alert Memorandum: The Employment and Training Administration Needs
to Issue Guidance to Ensure State Workforce Agencies Provide Requested
ETA 2 $0
Unemployment Insurance Data to the Office of Inspector General;
Report No. 19-21-005-03-315; 06/16/21
Unemployment Insurance Overpayments Related to Work Search
ETA Underscore the Need for More Consistent State Requirements; 1 $0
Report No. 04-21-001-03-315; 09/29/21
Alert Memorandum: Potentially Fraudulent Unemployment Insurance
ETA Payments in High Risk Areas Increased to $45.6 Billion; 2 $0
Report No. 19-22-005-03-315; 09/21/22
Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to
ETA Improve Oversight of the Unemployment Insurance Program; 2 $0
Report No. 19-23-012-03-315; 09/25/23
COVID-19: ETA Needs a Plan to Reconcile and Return to
the U.S. Treasury Nearly $5 Billion Unused by States for a
ETA 1 $105,100,000
Temporary Unemployment Insurance Program;
Report No. 19-23-015-03-315; 09/28/23
MSHA Needs to Provide Better Oversight of Emergency Response Plans;
MSHA 2 $0
Report No. 05-17-002-06-001; 03/31/17
COVID-19: MSHA Did Not Complete or Accurately Report Mandatory
MSHA Inspections; 7 $0
Report No. 19-24-001-06-001; 10/17/23
FISMA Fiscal Year 2015: Ongoing Security Deficiencies Exist;
OASAM 1 $0
Report No. 23-16-002-07-725; 09/30/16
DOL’s IT Governance Lacked the Framework Necessary to Support the
OSEC Overall Mission; 1 $0
Report No. 23‑21‑002-01-001; 09/30/21
COVID-19: OSHA Needs To Do More To Address High Injury Rates of
OSHA Warehouse Workers; 3 $0
Report No. 19-23-013-10-105; 09/27/23
continued on next page
Semiannual Report to Congress | April 1, 2024–September 30, 2024 97
Appendices
OWCP Did Not Ensure Best Prices and Allowed Inappropriate, Potentially
OWCP Lethal Prescriptions in the FECA Program; 2 $321,261,486
Report No. 03-23-001-04-431; 03/31/23
Agency Management Decision or Grant/Contracting Officer’s Final Determination Not Issued By Close of Period
Total Nonmonetary Recommendations and Questioned Costs 25 $426,361,486
Number of Funds Recommended for
Agency Report Title; Report Number; Date Issued
Better Use ($)
Recommendations
Agency Management Decision or Grant/Contracting Officer’s Final Determination Did Not Resolve;
OIG Negotiating with Agency
Alert Memorandum: Potentially Fraudulent Unemployment Insurance
ETA Payments in High Risk Areas Increased to $45.6 Billion; 1 $29,581,490,253
Report No. 19-22-005-03-315; 09/21/22
Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to
ETA Improve Oversight of the Unemployment Insurance Program; 1 $1,292,205,723
Report No. 19-23-012-03-315; 09/25/23
COVID-19: The Employment and Training Administration Needs to Improve
ETA Oversight of Grants Awarded in New Jersey; 1 $100,098,923
Report No. 19-23-016-03-391; 09/28/23
Total Funds Recommended for Better Use 3 $30,973,794,899
Total Audit Exceptions and Questioned Costs 25 $426,361,486
Total Funds Recommended for Better Use 3 $30,973,794,899
Total Audit Exceptions, Questioned Costs, and Funds Recommended for Better Use 28 $31,400,156,385
98 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Management Decision Made During this
Reporting Period on Audits, Inspections,
or Evaluations Issued during a Previous
Reporting Period: Final Audit Reports Issued
Number of Recommendations
Management Decision Made
Funds Put to Better Use ($)
Questioned Costs ($)
Report Title; Report Number; Date Issued
on Previously Issued Audits
Bureau of Labor Statistics
BLS Could Do More to Identify Data Limitations and Increase Transparency;
4 $0 $0 Yes
Report No. 17-24-001-11-001; 10/26/23
Total (1 Report)
Employment and Training Administration
A Review of Pandemic Unemployment Insurance Relief and Its Impact on Six Different
No Response
U.S. Communities; 0 $0 $0
Required
Report No. 19-24-002-03-315; 03/28/24
Total (1 Report)
Mine Safety and Health Administration
COVID-19: MSHA Did Not Complete or Accurately Report Mandatory Inspections;
11 $0 $0 Yes
Report No. 19-24-001-06-001; 10/17/23
Total (1 Report)
continued on next page
Semiannual Report to Congress | April 1, 2024–September 30, 2024 99
Appendices
Office of the Assistant Secretary for Administration and Management
Without an IT Modernization Framework, DOL Is Vulnerable to Inadequate Resource
Prioritization for Ensuring Security and Availability of DOL Systems; 3 $0 $0 Yes
Report No. 23-24-002-07-725; 11/17/23
FY 2023 FISMA DOL Information Security Report: Making Improvements Toward an
Effective Program; 3 $0 $0 Yes
Report No. 23-24-001-07-725; 12/06/23
Total (2 Reports)
Office of the Chief Financial Officer
FY 2023 Independent Auditors’ Report on DOL’s Consolidated Financial Statements;
3 $0 $0 Yes
Report No. 22-24-004-13-001; 11/14/23
Management Advisory Comments Identified in an Audit of the Consolidated Financial
Statements for the Year Ended September 30, 2023; 6 $0 $0 Yes
Report No. 22-24-005-13-001; 12/20/23
Total (2 Reports)
Office of Workers’ Compensation Programs
District of Columbia Workmen’s Compensation Act Special Fund Financial Statements
and Independent Auditors’ Report September 30, 2022, and 2021; 1 $0 $0 Yes
Report No. 22-24-002-04-432; 10/30/23
Longshore and Harbor Workers’ Compensation Act Special Fund Financial Statements
and Independent Auditors’ Report September 30, 2022, and 2021; 1 $0 $0 Yes
Report No. 22-24-001-04-432; 10/30/23
Special Report Relating to the Federal Employees’ Compensation Act Special Benefit
Fund September 30, 2023; No Response
0 $0 $0
Report No. 22-24-003-04-431; 11/01/23 Required
Total (3 Reports)
Final Audit Total (10 Reports) 32 $0 $0
100 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Management Decision Made During this
Reporting Period on Audits, Inspections,
or Evaluations Issued during a Previous
Reporting Period: Other Reports
Management Decision
Number of
Report Title; Report Number; Date Issued Made by End of
Recommendations
Reporting Period
Employment and Training Programs
Workforce Innovation and Opportunity Act
Quality Control Review for the Single Audit of the American Association
of Retired Persons (AARP) Foundation for the Fiscal Year Ended No Response
0
December 31, 2022; Required
Report No. 24-24-001-50-598; 01/24/24
Quality Control Review of the Single Audit of the State of New Mexico
Workforce Solutions Department for the Year Ended June 30, 2022; 1 Yes
Report No. 24-24-002-50-598; 03/12/24
Total (2 Reports)
Other Reports Total (2 Reports) 1
Semiannual Report to Congress | April 1, 2024–September 30, 2024 101
Appendices
Corrective Actions Taken by the Department
During this reporting period, we took final action to close recommendations within reports
based on corrective action taken by the Department. The following is a summary of the most
significant actions.
COVID-19: MSHA Did Not Complete or Accurately Report Mandatory Inspections;
Report No. 19-24-001-06-001; 10/17/23
The Federal Mine Safety and Health Act of 1977 requires each underground mine to be inspected in
its entirety at least four times a year and each surface mine in its entirety at least two times a year. The
OIG had long-standing concerns regarding MSHA’s operational risks associated with its mandatory
inspections program and how such risks impact MSHA’s mission to protect the lives of miners. Our audit
found that MSHA did not complete an estimated 1,589 mandatory mine inspections during Fiscal Year
2018 through Fiscal Year 2021 despite reporting a nearly 100 percent completion rate.
In response, MSHA completed work to address our audit recommendation to transparently report on
the number of idle mine visits and attempted inspections used to eliminate mandatory inspections
each fiscal year. Specifically, MSHA added a footnote to its Congressional Budget Justification to
clearly inform the reader that the completion percentage reported on mandatory inspections excludes
idle mine visits and attempted inspections.
COVID-19: OSHA Needs to Do More to Address High Injury Rates of Warehouse
Workers; Report No. 19-23-013-10-105; 09/27/23
Before and during the COVID-19 pandemic, rates of injuries and illnesses amongst warehouse
workers were consistently high, indicating that warehouses were and continued to be dangerous
places to work. Our audit found that, despite consistently high injury and illness rates, OSHA
conducted a limited number of warehouse inspections. Specifically, we found OSHA conducted a
total of 3,762 inspections, which amounts to an annual average of 4.1 percent of the establishments
self-classifying as warehouses. Further, we found OSHA’s recently established National Emphasis
Program (NEP) for warehouses, which mandated ergonomics training, did not describe the training
requirements as previously included with similar NEPs.
In response to our audit, OSHA recently published a recorded training webinar with experts from
OSHA’s Directorate of Enforcement Programs providing Compliance Safety and Health Officers
(CSHOs) information and guidance on conducting workplace inspections covered under the NEP. The
training covered ergonomic hazards, typical violations, and CSHO resources. Additionally, the training
provided information on other hazards encountered at these facilities, including material handling,
102 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
walking-working surfaces, electrical, and heat. OSHA reports that as of March 8, 2024, 550 learners
completed the webinar. Further, more learners continue to enroll in the recorded training, which is
available and accessible to all CSHOs.
COVID-19: ETA Can Improve Its Oversight to Ensure Integrity over CARES Act UI
Programs; Report No. 19-23-011-03-315; 09/22/23
In Fiscal Year 2023, we issued a memorandum to the Employment and Training Administration
(ETA) to alert management to three matters requiring attention relating to the National Association
of State Workforce Agencies (NASWA). These matters resulted from our audit of ETA’s oversight of
Unemployment Insurance (UI) integrity for three key Coronavirus, Aid, Relief, and Economic Security
(CARES) Act programs: Pandemic Unemployment Assistance, Pandemic Emergency Unemployment
Compensation, and Federal Pandemic Unemployment Compensation. We found that: (1) ETA did
not ensure an initial assessment of NASWA’s Integrity Data Hub (IDH) was performed in compliance
with federal requirements, (2) ETA did not provide documentation that it evaluated NASWA’s security
assessment reports, and (3) the IDH was less effective at identifying potentially improper multistate
claims when compared to the OIG’s data.
In response, ETA and the Department contracted with two vendors to conduct an exploratory
study of the IDH. The study aimed to help ETA better understand: (1) how selected states use the
IDH tool to detect and prevent fraud within their respective UI programs, (2) how effective states
consider the IDH to be in detecting and preventing fraud, and (3) what options are available to
inform continuous improvement and effectiveness of the IDH. At the end of March 2024, the team
finalized the study and held a briefing to discuss the results and recommendations. The team was
able to highlight some immediate areas for improvement and made recommendations for future
studies. ETA is using the results of the exploratory study and working with NASWA to implement
some of the study’s recommendations.
COVID-19: OSHA Needs to Strengthen Its Process for Awarding Future
Emergency Supplemental Funds to State Plans; Report No. 19-23-009-10-105;
08/30/23
On March 11, 2021, the President signed the American Rescue Plan Act of 2021 (ARPA) into law.
ARPA provided OSHA with no less than $100 million in additional funding, of which no less than
$5 million was allotted for worker protection activities related to COVID-19. A prior audit identified
concerns with the decreased level of COVID-19 inspections, leaving U.S. workers’ safety at increased
risk. We contracted with the independent certified public accounting firm of GenTech Associates, Inc.
(GenTech) to determine if OSHA appropriately budgeted and spent ARPA funds to carry out
COVID-19-related worker protection activities.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 103
Appendices
GenTech determined OSHA appropriately budgeted ARPA funds to carry out COVID-19-related
worker protection activities and, in general, OSHA appropriately expended ARPA funds. However,
OSHA did not effectively manage the awarding process to maximize coverage across State Plans and
had insufficient controls in place to expend funds designated for State Plan grants. Specifically, OSHA
neglected to adequately coordinate with the Departmental Budget Center on the time State Plans
needed to maximize their opportunity to meet the grant matching requirement. OSHA also awarded
$7.5 million to a grantee with known financial and reporting issues without establishing mitigating
controls to help ensure the appropriate use and reporting of funds. OSHA did not follow proper grant
application procedures to determine if the state’s financial system could track, account for, and report
on expenditures before awarding the funds.
In response to our audit, OSHA took action to address the first recommendation. Specifically, OSHA
developed a plan for future crises (e.g., pandemic) to coordinate with the Departmental Budget
Center on the time State Plans need to maximize their opportunity to receive appropriate federal
assistance to ensure workers’ safety.
MSHA Needs to Improve Efforts to Protect Coal Miners from Respirable
Crystalline Silica; Report No. 05-21-001-06-001; 10/30/20
Over the past four decades, various stakeholders have raised concerns about exposures to respirable
crystalline silica—a carcinogen and contributing cause of black lung disease—in coal mines. More
than three times as many coal miners were identified as having black lung disease from 2010 to 2014
compared to 1995 to 1999. Our audit found that MSHA had not sufficiently protected coal miners from
exposure to respirable crystalline silica. Specifically, MSHA’s silica exposure limit was out of date,
the agency could not cite and fine mine operators for excess silica exposures alone, and MSHA’s
sampling for silica was potentially too infrequent to be sufficiently protective.
To address our audit recommendation of adopting a lower legal exposure limit for silica in coal
mines, MSHA developed and issued a final rule in April 2024. The final rule lowered the permissible
exposure limit to 50 micrograms per cubic meter of air (µg/m3) for a full shift—calculated as an 8-hour
time-weighted average for all miners. This rule is designed to lower miners’ exposure to respirable
crystalline silica and improve respiratory protection. If a miner’s exposure exceeds the limit, the final
rule requires mine operators to take immediate corrective actions to come into compliance.
OSHA Procedures for Issuing Guidance Were Not Adequate and Mostly Not
Followed; Report No. 02-19-001-10-105; 03/28/19
In 2015, three events led us to question OSHA’s guidance issuance processes. First, the Government
Accountability Office reported stakeholder concerns that federal agencies inappropriately used
guidance in place of rules. Second, industry stakeholders challenged OSHA guidance documents,
104 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
alleging OSHA created new rules without going through the rulemaking process. Third, congressional
members expressed concerns over procedures OSHA used when issuing certain guidance
documents. Given these events, we conducted an audit and found that OSHA did not establish
adequate procedures for issuing guidance, and those procedures that were established were mostly
not followed. Specifically, OSHA lacked a procedure to determine the appropriateness of issuing a
document as guidance instead of a rule. Further, OSHA did not follow procedures for 80 percent of
sampled guidance.
In response to our audit, OSHA took additional steps to ensure guidance follow proper procedures. In
particular, OSHA maintained complete records to demonstrate compliance with criteria for issuance,
established and enforced a monitoring function, and trained officials and staff on their roles and
responsibilities for internal controls. These actions included: (1) issuing a revised directive requiring
the Solicitor’s Office to review guidance and policy documents and describing the requirements
for documentation and file retention, (2) establishing guidance for national office directorates and
regional offices responsible for monitoring and self-assessing the process and files for the directives,
and (3) developing and training staff on OSHA’s new guidance directive, OSHA Clearance Process
for NonPolicy and Policy Issuances.
ETA Violated the Bona Fide Needs Rule and Antideficiency Act;
Report No. 26-17-002-03-370; 9/21/2017
In 2015, Government Accountability Office (GAO) raised concerns that the Employment and Training
Administration (ETA) may have violated the bona fide needs rule by improperly using unexpended
funds for Program Years (PY) 2011, 2012, and 2013 for the needs of PYs 2012, 2013, and 2014,
respectively. The bona fide needs rule prohibits agencies from obligating funds for the purchase
of services delivered outside the time period for which the funds were originally designated. GAO
referred this matter to the U.S. Department of Labor Office of Inspector General (OIG). Our audit
found that ETA’s use of Job Corps’ operations funds for PYs 2012 and 2013 violated the bona fide
needs rule. ETA used $22.1 million in PYs 2012 and 2013 funds for services actually provided in
PYs 2013 and 2014 respectively. We did not find any bona fide needs rule violations for PY 2011.
These actions also violated the Antideficiency Act by improperly obligating the government to pay for
services provided in PYs 2013 and 2014 before those years’ funds were actually made available for
obligation by Congress. As a result, we recommended that ETA report, in accordance with 31 USC,
§1351, §1517(b), the Antideficiency Act violations caused by the bona fide needs rule violations
identified in this report.
In response to our audit, ETA stated that they did not incur obligations in excess of the amount of
the PY appropriation. Further, because 41 U.S.C. §3902 authorizes the use of current PY funds for
future needs, ETA was not required to charge the four contract modifications identified by the IG in
the Draft report to the subsequent PY. Accordingly, ETA did not violate the Antideficiency Act and will
Semiannual Report to Congress | April 1, 2024–September 30, 2024 105
Appendices
not implement the OIG’s recommendations rather ETA may seek a third-party determination regarding
the allowability of the Antideficiency Act and bona fide needs rule to the four contract modifications. In
ETA’s memorandum dated August 29, 2024, ETA provided evidence of its reengagement with Office
of Management and Budget (OMB) on June 21, 2024, to obtain the third-party opinion requested.
After reviewing the documentation ETA provided, OMB’s General Counsel rendered its opinion.
On August 13, 2024, OMB communicated this opinion to ETA, indicating that an Antideficiency Act
violation did not occur.
DOL ETA relied on 41 U.S.C. §3902 to justify entering into severable contracts that extended into
the next fiscal year, as long as the contracts do not exceed one calendar year. However, DOL-OIG
believed these modifications violated the bona fide needs rule (31 U.S.C. §1502) because they made
funds available for contracts starting in the next program year. DOL ETA argued that the language
in the modifications was defective, and the invoices showed that the obligations occurred within
the current program year. After reviewing the documentation, OMB agreed with DOL ETA, stating
“our office agrees with DOL ETA’s position that no ADA violations occurred, despite the defective
modification language. The important distinction we found is that the ADA specifically concerns when
obligations are made, and in this case, the actual obligations occurred in the current program year
and not the following program year. The actual date of obligation is controlling over the erroneous
date on the documentation.”
106 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Unimplemented Recommendations
During this reporting period, there was 1 instance of audits or evaluations provided to the Department
for comment that were not responded to within 60 days. Management decisions were received in
response to all audits and evaluations issued before the commencement of this reporting period.
From October 1, 2014, through March 31, 2024, the OIG made 1,116 audit recommendations,
of which 144 have not been fully implemented. These 144 recommendations include 84
recommendations resulting from audits issued since the end of FY 2021, and, in many cases, the
corrective action plans are in place.
RECOMMENDATIONS MADE PRIOR TO APRIL 1, 2024,
NOT YET IMPLEMENTED
Unimplemented Recommendations
Total Number of
Fiscal Year
Recommendations Made
Total Number Monetary Impact ($)
2014 128 1 $0
2015 163 0 $0
2016 100 1 $0
2017 112 7 $0
2018 98 1 $0
2019 84 9 $0
2020 105 8 $0
2021 133 33 $39,155,643,774
2022 67 11 $29,581,490,253
2023 93 48 $6,940,069,807
202450 33 25 $0
Total 1,116 144 $75,677,203,834
50 FY 2024 shows data for the first half of the fiscal year (October 1, 2023, to March 31, 2024)
Semiannual Report to Congress | April 1, 2024–September 30, 2024 107
Appendices
High-Priority Unimplemented Recommendations
The following table summarizes the unimplemented recommendations the OIG considers to be
the highest priorities for the Department.
Report Title; Report Number;
Unimplemented Recommendation(s)
Date Issued
Unemployment Insurance Benefits
COVID-19: More Can Be Done to Mitigate Risk to Issue guidance directing states to provide access to state UI claimant data to
Unemployment Compensation Under the CARES prevent and detect fraud.
Act; Report No. 19-20-008-03-315; 08/07/20
Alert Memorandum: The Employment and Training Establish effective controls, in collaboration with SWAs, to mitigate fraud and
Administration (ETA) Needs to Ensure State other improper payments to ineligible claimants, including the areas identified
Workforce Agencies (SWA) Implement Effective in the memorandum: UI benefits paid to multistate claimants, claimants who
Unemployment Insurance Program Fraud Controls used the Social Security numbers of deceased individuals, potentially ineligible
for High Risk Areas; federal inmates, and claimants with suspicious email accounts. Effective
Report No. 19-21-002-03-315; 02/22/21 controls will help prevent similar or greater amounts of fraud and allow those
funds to be put to better use;
Work with Congress to establish legislation requiring SWAs to cross-match
high-risk areas, including the four areas identified in the memorandum.
COVID-19: States Struggled to Implement CARES Continue to work with states to develop, operate, and maintain a modular
Act Unemployment Insurance Programs; set of technological capabilities to modernize the delivery of UI benefits that
Report No. 19-21-004-03-315; 05/28/21 is sufficient to manage and process sudden spikes in claims volume during
emergencies or high unemployment.
Alert Memorandum: The Employment and Training Amend 20 C.F.R. 603.5 and 603.6(a) through the rulemaking process
Administration Needs to Issue Guidance to Ensure to reinforce that UI information must be provided to DOL-OIG for all IG
State Workforce Agencies Provide Requested engagements authorized under the IG Act, including audits, evaluations, and
Unemployment Insurance Data to the Office of investigations.
Inspector General;
Report No. 19-21-005-03-315; 06/16/21
Alert Memorandum: Potentially Fraudulent Implement immediate measures to ensure SWAs are required to provide
Unemployment Insurance Payments in High-Risk ongoing access to the OIG by amending its current guidance to require
Areas Increased to $45.6 Billion; disclosures to the OIG for audits and investigations as necessary, mandatory,
Report No. 19-22-005-03-315; 9/21/22 and without time limitation for the proper oversight of the UI program;
Expedite OIG-related amendments to 20 C.F.R. § 603.6(a) to make ongoing
disclosures of UI information to DOL OIG mandatory by expressly adding the
U.S. Department of Labor, Office of Inspector General (including its agents and
contractors) to the list of required disclosures that are necessary for the proper
oversight of the UI program without distinction as to purpose (e.g., audits versus
investigations);
Expedite OIG-related amendments to 20 C.F.R. § 603.5(i) to expressly make
disclosures of UI information to federal officials for oversight, audits, and
investigations of federal programs mandatory.
continued on next page
108 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
COVID-19: ETA and States Did Not Protect Use data collected from monitoring and BAM reports to identify the areas of
Pandemic-Related UI Funds from Improper highest improper payments including fraud and create a plan to prevent similar
Payments Including Fraud or from Payment issues in future temporary UI benefit programs;
Delays; Work with NASWA to update the IDH Participant Agreement to require state to
Report No. 19-22-006-03-315; 09/30/22 submit the results of their UI fraud investigations;
Work with NASWA to ensure the IDH cross matches are effective at preventing
the types of fraud that were detected during the pandemic and regularly update
using the results of state fraud investigations.
ETA Did Not Provide Adequate Oversight of Specify within its policy the information states must include in their
Emergency Administrative Grants; documentation to support compliance with the requirements to receive grant
Report No. 19-23-006-03-315; 07/27/23 funds prior to disbursement of the funds;
Remedy the $136,353,568 in questioned costs.
COVID-19: Unemployment Relief for Governmental Obtain evidence from the states that ensures all EURGENO refunds and credits
Entities and Nonprofit Organizations Should Have to which reimbursing employers are entitled have been provided;
Been Better Managed; Work with states to reconcile remaining balances.
Report No. 19-23-010-03-315; 09/21/23
Alert Memorandum: ETA Needs to Incorporate Obtain direct access to unemployment insurance claims data from all State
Data Analytics Capability to Improve Oversight of Workforce Agencies; Create an integrity program that incorporates a data
the Unemployment Insurance Program; analytics capability and regularly monitors state unemployment insurance claims
Report No. 19-23-012-03-315; 09/25/23 data to detect and prevent improper payments, including fraudulent payments,
and to identify trends and emerging issues that could negatively impact the
unemployment insurance program.
COVID-19: ETA Needs a Plan to Reconcile and Work with Oregon, Louisiana, Delaware, and Mississippi to ensure the
Return to the U.S. Treasury Nearly $5 Billion appropriate return of approximately $105.1 million in TFFF reimbursements for
Unused by States for a Temporary Unemployment first-week regular UI compensation paid that were associated with ineligible
Insurance Program; weeks;
Report No. 19-23-015-03-315; 09/28/23 Establish a deadline by which states are required to perform a timely review of
past drawdowns and provide evidence that drawdowns were for reimbursement
of eligible first-week regular UI compensation paid by the state for claim weeks
that fell within the TFFF program period;
Ensure that any state drawdowns of the remaining almost $5 billion in TFFF
funds are only for the reimbursement of first-week regular UI compensation paid
by the state that fall within the TFFF program period (March 27, 2020, through
September 6, 2021);
Establish written procedures and deadlines for the timely return of funding for
TFFF and future similar programs and consult with OMB and Treasury officials to
execute the proper return of unused funds that remain within states’ accounts.
COVID-19: ETA’s Oversight of Short-Time Establish policies and procedures for monitoring, using lessons learned from
Compensation Did Not Detect $129.6 Million in the Short-Time Compensation (STC) program during the pandemic, that ensure
Questioned Costs; states meet requirements for similar future temporary unemployment insurance
Report No. 19-24-003-03-315; 06/26/24 programs that provide federal reimbursements to states;
Review states’ compliance with STC eligibility requirements and require all
states with STC agreements to return federal funds used for reimbursements of
STC benefit payments for weeks of unemployment beginning before March 27,
2020, and ending after September 6, 2021, as well as for reimbursements that
exceeded benefits paid;
Monitor states administering unemployment insurance programs subsidized with
federal funds, including temporary programs such as STC, to ensure compliance
with the 3-year records retention requirements established in the Code of
Federal Regulations (2 C.F.R. § 200.334).
continued on next page
Semiannual Report to Congress | April 1, 2024–September 30, 2024 109
Appendices
ETA Did Not Ensure States Sufficiently Perform an assessment of previous emergency UI programs and the pandemic-
Implemented The Mixed Earners related UI programs to determine an appropriate historically-based time limit for
Unemployment Compensation Program; states’ acceptance of emergency program benefit claims after the expiration of
Report No. 19-24-005-03-315; 09/11/24 the UI programs’ eligibility periods and consider making a legislative proposal to
Congress to use the determined time limit on future emergency programs.
Worker Safety
MSHA Needs to Provide Better Oversight of Clarify mine operators’ responsibilities for local coordination under the
Emergency Response Plans; Mine Improvement and New Emergency Response (MINER) Act, including
Report No. 05-17-002-06-001; 03/31/17 coordination and communication between the operator, mine rescue teams, and
local emergency response personnel, and familiarizing local rescue personnel
with surface functions that may be required in the course of mine rescue work.
MSHA Needs to Improve Efforts to Protect Coal Enhance its sampling program to increase the frequency of inspector samples
Miners from Respirable Crystalline Silica; where needed (e.g., by implementing a risk-based approach).
Report No. 05-21-001-06-001; 11/12/20
OSHA’s Diminished Enforcement Left More Implement a policy for future emphasis programs that minimizes the lapse in
Workers at Risk for Exposure to Silica; enforcement between canceled, revised, or new programs;
Report No. 02-21-003-10-105; 09/29/21 Establish meaningful goals and processes to assess whether OSHA’s outreach
events are achieving the desired results in reaching a targeted number of
workers at risk of exposure to silica.
COVID-19: To Protect Mission Critical Workers, Develop an OSHA outreach plan to be activated during a large-scale safety and
OSHA Could Leverage Inspection Collaboration health crises such as the COVID-19 pandemic that (a) identifies external federal
Opportunities with External Federal Agencies; agencies with enforcement or oversight personnel who are active on worksites and
Report No. 19-22-003-10-105; 03/31/22 (b) defines how OSHA will collaborate with those agencies. OSHA should consider
incorporating into the plan: a process to identify and document highly visible safety
and health hazards for large-scale safety and health crises; a plan for how OSHA
will conduct related outreach and training on those hazards and how to refer them to
OSHA; and a tracking system for agency referrals and outcomes of those referrals,
using that information to periodically inform the outreach plan on areas and types of
guidance and training the agencies’ oversight and enforcement personnel need;
Explore mechanisms to enhance collaboration, such as memorandums of
understanding or other written agreements using GAO’s seven key features for
collaboration, and incorporate a process to utilize those mechanisms into the
outreach plan.
COVID-19: OSHA’S Enforcement Activities Did As part of OSHA’s rulemaking on infectious diseases, require employers to
Not Sufficiently Protect Workers from Pandemic notify all employees of all known positive cases of infectious diseases at the
Health Hazards; worksite;
Report No. 19-23-001-10-105; 10/31/22 Develop and implement a tracking tool to ensure OSHA receives and reviews all
items CSHOs request during inspections to ensure alleged hazards have been
mitigated.
OSHA Needs to Better Address Complaints and Modify the Field Operations Manual to include a policy for mandatory interviews
Referrals for Increased Worker Safety; of complainants and witnesses or document the rationale for lack thereof and
Report No. 02-23-001-10-105; 03/06/23 provide training to Compliance Safety and Health Officers on the updated
requirements.
COVID-19: OSHA Needs to do More to Address Develop specific, measurable inspection goals for the Site-Specific Targeting
High Injury Rates of Warehouse Workers; program, including a baseline for the number of inspections in each Site-specific
Report No. 19-23-013-10-105; 09/27/23 Targeting category, and periodically monitor progress toward those goals;
Develop a more effective enforcement strategy to improve employer Form 300A
compliance;
Assess Form 300A data categories and gather more specific supporting
information about injuries to better identify the count and type of injuries
reported, such as musculoskeletal disorders;
Develop specific measurable inspection goals for the warehousing National
Emphasis Program, including a baseline for the number of inspections
continued to page
on next
complete and periodically monitor progress toward those goals. Ensure the
goals contain metrics that demonstrate the outcomes of the program.
continued on next page
110 Semiannual Report to Congress | April 1, 2024–September 30, 2024
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Employee Benefits
EBSA Did Not Have the Ability to Protect the Reduce or eliminate exemption thresholds for small plans.
Estimated 79 Million Plan Participants in Self
Insured Health Plans from Improper Denials of
Health Claims;
Report No. 05-17-001-12-121; 11/18/16
OWCP Did Not Ensure Best Prices and Allowed Implement a process to ensure competitive prices for the FECA program by
Inappropriate, Potentially Lethal Prescriptions in regularly evaluating alternate pricing methodologies and other sources—
the FECA Program; including publicly available benchmark price lists, state fee schedules, market
Report No. 03-23-001-04-431; 3/31/23 research, and comparable payers—and updating its pricing methodology as
appropriate;
Implement a technology solution to perform ongoing prescription-claim-level
reviews in near real-time.
OLMS Can Do More to Protect Workers’ Rights Outline requirements needed to strengthen enforcement authority to align with
to Unionize Through Enforcing Persuader Activity the Labor-Management Reporting and Disclosure Act of 1959’s intentions to
Disclosure; protect workers’ rights and interests to unionize by recommending rule changes
Report No. 09-24-002-16-001; 05/03/24 or legislative changes to increase employer and consultant compliance.
Departmental Management
FISMA Fiscal Year 2015: Ongoing Security Realign the organizational structure as it relates to the Chief Information Officer
Deficiencies Exist; to address organizational independence issues.
Report No. 23-16-002-07-725; 09/30/16
FY 2019 FISMA DOL Information Security Report: Implement improvements in DOL’s information security program for the following
Implementation of Security Tools Hindered by areas: configuration management, and access control technologies.
Insufficient Planning;
Report No. 23-20-002-07-725; 12/23/19
DOL Needs to Do More to Secure Employees’ Establish and implement procedures to ensure E2 Solutions (E2) account
Personally Identifiable Information in the Travel management practices enforce DOL’s security policies;
Management System; Establish and implement procedures to ensure E2 is managed in compliance
Report No. 23-20-003-13-001; 09/10/20 with contractual security requirements and DOL computer security policies for
contracted information systems.
FY 2020 FISMA DOL Information Security Report: Implement a process for approving deviations from established configuration
Progress Needed to Improve Risk Management settings.
and Continuous Monitoring Information Security
Controls;
Report No. 23-21-001-07-725; 12/22/20
DOL’s IT Governance Lacked the Framework Reorganize the Chief Information Officer position to have a direct reporting
Necessary to Support the Overall Mission Report; relationship to the Deputy Secretary and independent of ASAM;
Report No. 23-21-002-01-001; 09/30/21 Ensure the Chief Information Officer is a lead member with voting rights of
DOL’s executive strategy and management boards and committees, including
but not limited to the Management Review Board, Enterprise Shared Services
Governance Board, COVID-19 Coordination team, and Enterprise Risk
Management Council; Establish an MOU or other agreement between the Office
of the Chief Information Officer and all departmental agencies to establish
and state the roles and responsibilities of IT between each set of respective
agencies;
Reassess the incorporation of BLS and OCFO as part of IT Shared Services
within 2021, and document the reasoning for the decisioncontinued
reached;on next page
Codify
the policies and procedures that define IT governance and key supporting IT
elements.
FY 2022 FISMA DOL Information Security Update DOL entity-wide and system-level security policies, procedures, and
Report: DOL’s Information Security Program Not plans to comply with NIST SP 800-53, Rev. 5;
Remaining Current with Security Requirements; Implement data loss prevention tools and alerts based on the results of
Report No. 23-23-001-07-725; 02/10/23 agencies’ data exfiltration tests.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 111
Appendices
Summary of Reports with Unimplemented
Recommendations with Cost Savings / Funds
Put to Better Use
Funds Put to Better Use
Number of
Report Title; Report Number; Date Issued Unimplemented
Recommendations ($)
Employment and Training Administration
Alert Memorandum: The Employment and Training Administration (ETA) Needs to Ensure
State Workforce Agencies (SWA) Implement Effective Unemployment Insurance Program
Fraud Controls for High-Risk Areas; Report No. 19-21-002-03-315; 02/22/21
Establish effective controls, in collaboration with SWAs, to mitigate fraud and other improper
1 $5,409,966,198
payments to ineligible claimants, including the areas identified in the memorandum: UI
benefits paid to multistate claimants, claimants who used the Social Security numbers of
deceased individuals, potentially ineligible federal inmates, and claimants with suspicious
email accounts. Effective controls will help prevent similar or greater amounts of fraud and
allow those funds to be put to better use.
COVID-19: States Struggled to Implement CARES Act Unemployment Insurance
Programs; Report No. 19-21-004-03-315; 05/28/21
Continue to work with states to develop, operate, and maintain a modular set of 1 $33,745,677,576
technological capabilities to modernize the delivery of UI benefits that is sufficient to
manage and process sudden spikes in claims volume during emergencies or high
unemployment.
Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments in High-
Risk Areas Increased to $45.6 Billion; Report No. 19-22-005-03-315; 09/21/22
Expedite OIG-related amendments to 20 C.F.R. § 603.6(a) to make ongoing disclosures
1 $29,581,490,253
of UI information to DOL OIG mandatory by expressly adding the U.S. Department
of Labor, Office of Inspector General (including its agents and contractors) to the list
of required disclosures that are necessary for the proper oversight of the UI program
without distinction as to purpose (e.g., audits versus investigations).
Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to Improve
Oversight of the Unemployment Insurance Program;
Report No. 19-23-012-03-315; 09/25/23
1 $1,292,205,723
Establish effective controls, in collaboration with State Workforce Agencies, to mitigate
fraud and other improper payments to ineligible claimants in high-risk age categories.
continued on next page
112 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
COVID-19: ETA Needs a Plan to Reconcile and Return to the U.S. Treasury Nearly
$5 Billion Unused by States for a Temporary Unemployment Insurance Program;
Report No. 19-23-015-03-315; 09/28/23
1 $4,948,811,006
Establish written procedures and deadlines for the timely return of funding for TFFF and
future similar programs and consult with OMB and Treasury officials to execute the proper
return of unused funds that remain within states’ accounts.
COVID-19: The Employment and Training Administration Needs to Improve Oversight of
Grants Awarded in New Jersey; Report No. 19-23-016-03-391; 09/28/23
1 $100,098,923
Develop and implement risk tolerance for the amount of participants being served under the
WIOA Adult, Youth, and Dislocated Workers program.
Total 6 $75,078,249,679
Semiannual Report to Congress | April 1, 2024–September 30, 2024 113
Appendices
Reports with Unimplemented
Recommendations for Management
Improvement or Disallowed Costs Owed
The following table lists all OIG reports issued prior to this semiannual reporting period with
recommendations that have not yet been fully implemented (as of September 30, 2024). For
identification of each recommendation made before September 30, 2024, visit our online
Recommendation Dashboard.
Number of Unimplemented or
Report Title; Report Number; Date Issued Unimplemented Disallowed Costs
Recommendations Owed
Bureau of Labor Statistics
BLS Could Do More to Identify Data Limitations and Increase Transparency;
4 $0
Report No. 17-24-001-11-001;10/26/23
Employee Benefits Security Administration
Limited-Scope Audits Provide Inadequate Protections to Retirement Plan
1 $0
Participants; Report No. 05-14-005-12-121; 09/30/14
EBSA Did Not Have the Ability to Protect the Estimated 79 Million Plan
Participants in Self-Insured Health Plans from Improper Denials of Health 1 $0
Claims; Report No. 05-17-001-12-121; 11/18/16
Employment and Training Administration
COVID-19: More Can Be Done to Mitigate Risk to Unemployment Compensation
1 $0
Under the CARES Act; Report No. 19-20-008-03-315; 08/07/20
Alert Memorandum: The Employment and Training Administration (ETA) Needs
to Ensure State Workforce Agencies (SWA) Implement Effective Unemployment
1 $0
Insurance Program Fraud Controls for High-Risk Areas;
Report No. 19-21-002-03-315; 02/22/21
COVID-19: States Struggled to Implement CARES Act Unemployment Insurance
1 $0
Programs; Report No. 19-21-004-03-315; 05/28/21
Alert Memorandum: The Employment and Training Administration Needs
to Issue Guidance to Ensure State Workforce Agencies Provide Requested
3 $0
Unemployment Insurance Data to the Office of Inspector General;
Report No. 19-21-005-03-315; 06/16/21
continued on next page
114 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Unemployment Insurance Overpayments Related to Work Search Underscore the
Need for More Consistent State Requirements; 3 $0
Report No. 04-21-001-03-315; 09/29/21
ETA Did Not Sufficiently Plan and Execute the American Apprenticeship Initiative
2 $0
Grant Program; Report No. 05-21-004-03-375; 09/30/21
COVID-19: Safety and Remote Learning Challenges Continue for Job Corps;
1 $0
Report No. 19-22-001-03-370; 11/12/21
Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments
in High-Risk Areas Increased to $45.6 Billion; Report No. 19-22-005-03-315; 2 $0
09/21/22
COVID-19: ETA and States Did Not Protect PandemicRelated UI Funds from
Improper Payments, Including Fraud or from Payment Delays; 3 $0
Report No. 19-22-006-03-315; 09/30/22
Quality Control Review of South Carolina Department of Employment Workforce’s
7 $0
Single Audit; Report No. 24-23-003-50-598; 09/26/2351
ETA Did Not Provide Adequate Oversight of Emergency Administrative Grants;
2 $136,353,568
Report No. 19-23-006-03-315; 07/27/23
COVID-19: Unemployment Relief for Governmental Entities and Nonprofit
Organizations Should Have Been Better Managed; 3 $29,074,061
Report No. 19-23-010-03-315; 09/21/23
COVID-19: ETA Can Improve Its Oversight to Ensure Integrity over CARES Act UI
1 $0
Programs; Report No. 19-23-011-03-315; 09/22/23
Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to
Improve Oversight of the Unemployment Insurance Program; 2 $0
Report No. 19-23-012-03-315; 09/25/23
COVID-19: Pandemic Unemployment Assistance for Non-Traditional Claimants
Weakened by Billions in Overpayments, Including Fraud; 1 $0
Report No. 19-23-014-03-315; 09/27/23
COVID-19: ETA Needs a Plan to Reconcile and Return to the U.S. Treasury
Nearly $5 Billion Unused by States for a Temporary Unemployment Insurance 6 $105,100,000
Program; Report No. 19-23-015-03-315; 09/28/23
COVID-19: The Employment and Training Administration Needs to Improve
Oversight of Grants Awarded in New Jersey; Report No. 19-23-016-03-391; 4 $7,165,040
09/28/23
continued on next page
51 The QCR Single Audit Report recommendations are addressed to the accounting firm; however, ETA funds the
grant and are copied during report issuance. Hence the addition to the ETA section of the table. The accounting firm
will address the recommendations.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 115
Appendices
Mine Safety and Health Administration
MSHA Needs to Provide Better Oversight of Emergency Response Plans;
6 $0
Report No. 05-17-002-06-001; 03/31/17
MSHA Can Improve Its Pre-Assessment Conferencing Program;
9 $0
Report No. 05-19-001-06-001; 09/23/19
MSHA Needs to Improve Efforts to Protect Coal Miners from Respirable
1 $0
Crystalline Silica; Report No. 05-21-001-06-001; 11/12/20
MSHA Can Improve How Violations Are Issued, Terminated, Modified, and
9 $0
Vacated; Report No. 05-21-002-06-001; 03/31/21
COVID-19: MSHA Did Not Complete or Accurately Report Mandatory Inspections;
9 $0
Report No. 19-24-001-06-001; 10/17/23
Office of the Assistant Secretary for Administration and Management
FISMA Fiscal Year 2015: Ongoing Security Deficiencies Exist;
1 $0
Report No. 23-16-002-07-725; 09/30/16
FY 2019 FISMA DOL Information Security Report: Implementation of Security
3 $0
Tools Hindered by Insufficient Planning; Report No. 23-20-002-07-725; 12/23/19
FY 2020 FISMA DOL Information Security Report: Progress Needed to Improve
Risk Management and Continuous Monitoring Information Security Controls; 1 $0
Report No. 23-21-001-07-725; 12/22/20
FY 2021 FISMA DOL Information Security Report: Information Security
Continuous Monitoring Controls Remain Deficient; 2 $0
Report No. 23-22-001-07-725; 01/28/22
FY 2022 FISMA DOL Information Security Report: DOL’s Information Security
Program Not Remaining Current with Security Requirements; 2 $0
Report No. 23-23-001-07-725; 02/10/23
Without an IT Modernization Framework, DOL Is Vulnerable to Inadequate
Resource Prioritization for Ensuring Security and Availability of DOL Systems; 3 $0
Report No. 23-24-002-07-725; 11/17/23
Office of the Chief Financial Officer
DOL Needs To Do More to Secure Employees’ Personally Identifiable Information
2 $0
in the Travel Management System; Report No. 23-20-003-13-001; 09/10/20
FY 2023 Independent Auditors’ Report on DOL’s Consolidated Financial
3 $0
Statements; Report No. 22-24-004-13-001; 11/14/23
Management Advisory Comments Identified in an Audit of the Consolidated
Financial Statements, for the Year Ended September 30, 2023; 6 $0
Report No. 22-24-005-13-001; 12/20/23
continued on next page
116 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Office of Federal Contract Compliance Programs
OFCCP Did Not Show It Adequately Enforced EEO Requirements on Federal
1 $0
Construction Contracts; Report No. 04-20-001-14-001; 03/27/20
Office of the Secretary
DOL’s IT Governance Lacked the Framework Necessary to Support the Overall
5 $0
Mission; Report No. 23-21-002-01-001; 09/30/21
Occupational Safety and Health Administration
OSHA Needs to Improve the Guidance for Its Fatality and Severe Injury Reporting
1 $0
Program to Better Protect Workers; Report No. 02-18-203-10-105; 09/13/18
Review of the Occupational Safety and Health Administration’s Referral to and
Reclamation of Debt from the U.S. Department of the Treasury; 1 $0
Report No. 22-20-006-10-001; 03/16/20
COVID-19: Increased Worksite Complaints and Reduced OSHA Inspections
Leave U.S. Workers’ Safety at Increased Risk; 1 $0
Report No. 19-21-003-10-105; 02/25/21
OSHA’s Diminished Enforcement Left More Workers at Risk for Exposure to
2 $0
Silica; Report No. 02-21-003-10-105; 09/29/21
COVID-19: To Protect Mission Critical Workers, OSHA Could Leverage Inspection
Collaboration Opportunities with External Federal Agencies; 2 $0
Report No. 19-22-003-10-105; 03/31/22
COVID-19: OSHA’s Enforcement Activities Did Not Sufficiently Protect Workers
4 $0
from Pandemic Health Hazards; Report No. 19-23-001-10-105; 10/31/22
OSHA Needs to Better Address Complaints and Referrals for Increased Worker
3 $0
Safety; Report No. 02-23-001-10-105; 03/06/23
OSHA Needs to Strengthen Its Process for Awarding Future Emergency
1 $0
Supplemental Funds to State Plans; Report No. 19-23-009-10-105; 08/30/23
COVID-19: OSHA Needs To Do More To Address High Injury Rates Of
6 $0
Warehouse Workers; Report No. 19-23-013-10-105; 09/27/23
Office of Workers’ Compensation Programs
OWCP Did Not Ensure Best Prices and Allowed Inappropriate, Potentially Lethal
3 $321,261,486
Prescriptions in the FECA Program; Report No. 03-23-001-04-431; 03/31/23
Wage and Hour Division
COVID-19: The Pandemic Highlighted the Need to Strengthen Wage and Hour
2 $0
Division’s Enforcement Controls; Report No. 19-21-008-15-001; 09/30/21
Totals 138 $598,954,155
Semiannual Report to Congress | April 1, 2024–September 30, 2024 117
Appendices
Investigative Statistics
Division
Total
Totals
Investigative Reports Issued / Cases Closed (includes investigative reports issued, case closing
291
reports, and matters referred for possible civil and/or administrative action):
Program Fraud 265
Labor Racketeering 26
Cases Opened: 137
Program Fraud 131
Labor Racketeering 6
Cases Referred for Prosecution (each case is measured as a singular statistic and may include more
95
than one person or business entity):
Program Fraud 91
Labor Racketeering 4
Cases Referred for Administrative/Civil Action (each case is measured as a singular statistic and
87
may include more than one person or business entity):
Program Fraud 85
Labor Racketeering 2
Persons Referred to the Department of Justice for Criminal Prosecution (includes the number of
147
individuals and business entities referred for prosecution):
Program Fraud 143
Labor Racketeering 4
Persons Referred to State and Local Prosecuting Authorities for Criminal Prosecution (includes
48
the number of individuals and business entities referred for prosecution):
Program Fraud 27
Labor Racketeering 21
Indictments and Criminal Informations That Resulted from Any Prior Referral to Prosecuting
253
Authorities (includes sealed and unsealed indictments):
Program Fraud 239
Labor Racketeering 14
Indictments (includes sealed and unsealed indictments): 253
Program Fraud 239
Labor Racketeering 14
Convictions: 249
Program Fraud 237
Labor Racketeering 12
Statutory Debarments: 2
Program Fraud 0
Labor Racketeering 2
continued on next page
118 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Recoveries, Cost-Efficiencies, Restitutions, Fines/Penalties,
$60,377,230.65
Forfeitures, and Civil Monetary Actions:
Program Fraud $58,690,188.39
Labor Racketeering $1,687,042.26
Recoveries (the dollar amount/value of an agency’s action to recover or to reprogram
$748,109.37
funds or to make other adjustments in response to OIG investigations):
Cost-Efficiencies (the one-time or per annum dollar amount/value of management’s
commitment, in response to OIG investigations, to utilize the government’s resources $746,024.54
more efficiently):
Restitutions/Forfeitures (the dollar amount/value of restitutions and forfeitures
$56,488,383.74
resulting from OIG criminal investigations):
Fines/Penalties (the dollar amount/value of fines, assessments, seizures, investigative/
$0.00
court costs, and other penalties resulting from OIG criminal investigations):
Civil Monetary Actions (the dollar amount/value of forfeitures, settlements, damages,
$2,394,713.00
judgments, court costs, and other penalties resulting from OIG criminal investigations):
Total $60,377,230.65
No-Knock Entries In accordance with the Executive Order on Advancing Effective,
Accountable Policing and Criminal Justice Practices to Enhance Public Trust and Public
Safety (EO 14074, May 25, 2022), federal law enforcement agencies are required to
report on the use of no-knock entries. For FY 2024, the OIG reports the following:
Number of no-knock entries that occurred pursuant to judicial authorization 0
Number of no-knock entries that occurred pursuant to exigent circumstances 0
Law Enforcement Officers or other persons injured in the course of no-knock
0
entries
Semiannual Report to Congress | April 1, 2024–September 30, 2024 119
Appendices
Peer Review Reporting
The following meets the requirement of the Inspector General Act of 1978, as amended that the
Inspectors General include their peer review results as an appendix to each semiannual report.
Peer Review of the Office of Personnel Management Office Inspector General
Audit Organization
DOL-OIG conducted a peer review of the Office of Personnel Management Office of Inspector
General audit organization’s system of quality control for the period ending March 31, 2024.
The peer review report issued on September 4, 2024, resulted in an opinion that the system
of quality control was suitably designed and complied with to provide the DOL-OIG with
reasonable assurance of performing and reporting conformity with applicable professional
standards and applicable legal and regulatory requirements in all material respects.
Peer Review of DOL-OIG Inspection and Evaluation Function
The Federal Housing Finance Agency OIG conducted an external peer review to assess the
extent to which the DOL-OIG met seven standards in the Council of the Inspectors General on
Integrity and Efficiency’s Quality Standards for Inspection and Evaluation (Blue Book), issued
January 2012. The peer review report, issued on April 25, 2023, concluded that the DOL-OIG’s
policies and procedures and the three reviewed reports were consistent with and complied
with the covered Blue Book standards for the period ended September 30, 2022. The report
contained no recommendations.
Peer Review of DOL-OIG Audit Function
The U.S. Department of Health and Human Services OIG conducted a peer review of the
system of quality control for DOL-OIG’s audit function for the period ending September 2021.
The peer review report, which was issued on September 15, 2022, resulted in an opinion that
the system of quality control was suitably designed and provided reasonable assurance of
DOL-OIG’s conforming to professional standards in the conduct of audits. The peer review
covered audit work performed during the unprecedented COVID-19 pandemic, and the DOL-OIG
received a clean report with a rating of pass with no recommendations.
120 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Peer Review of DOL-OIG Investigative Function
The United States Postal Service-OIG conducted a peer review of the system of quality
control for DOL-OIG’s investigative function for the period ending November 1, 2019. The peer
review report, which was issued on December 2, 2019, resulted in an opinion that the system
of quality control was suitably designed and provided reasonable assurance of DOL-OIG’s
conforming to professional standards in conduct of investigations. The peer review did not find
any reportable findings.
Semiannual Report to Congress | April 1, 2024–September 30, 2024 121
Appendices
OIG Hotline
The OIG Hotline provides a communication link between the OIG and persons who want to
report alleged violations of laws, rules, and regulations; mismanagement; waste of funds; abuse
of authority; or danger to public health and safety. During the reporting period April 1, 2024,
through September 30, 2024, a total of 2,240 complaints were opened in the OIG Hotline’s
complaint management system. A significant number of these complaints involve concerns
regarding COVID-19-related unemployment benefits. Effective the previous SAR period, the OIG
suspended the referral of pandemic UI matters to State Workforce Agencies due to resource
issues. During this reporting period, the OIG Hotline received additional complaints that are
awaiting processing.
Complaints Received (by method reported) Totals
Telephone 2
E-mail/Internet 2,197
Mail 41
Fax 0
Walk-In 0
Total 2,240
Contacts Received (by source) Totals
Complaints from Individuals or Non-Governmental Organizations 1,160
Complaints/Inquiries from Congress 0
Referrals from GAO 4
Complaints from Other DOL Agencies 12
Complaints from Other (non-DOL) Government Agencies 1,064
Total 2,240
Disposition of Complaints Reviewed and Processed Totals
Referred to OIG Components for Further Review and/or Action 135
Referred to DOL Program Management for Further Review and/or Action 135
Referred to Non-DOL Agencies/Organizations 99
No Referral Required/Informational Contact 636
Total 1,005
122 Semiannual Report to Congress | April 1, 2024–September 30, 2024
Appendices
Acronyms and Abbreviations
AI Artificial Intelligence FY Fiscal Year/fiscal year PEUC Pandemic Emergency
Unemployment
ATF Bureau of Alcohol, Tobacco, H-1B visa program for workers in
Compensation
Firearms and Explosives specialty occupations
PII personally identifiable
CARES Act H-2A visa program for
information
Coronavirus Aid, Relief, and agricultural workers
Economic Security Act PIIA Payment Integrity
H-2B visa program for
Information Act of 2019
CIO Chief Information Officer non-agricultural
workers PUA Pandemic Unemployment
DCCA Special Fund
Assistance
District of Columbia HHS U.S. Department of Health
Workmen’s Compensation and Human Services PPP Paycheck Protection
Act of 1928 Special Fund Program
IRS Internal Revenue Service
Department or DOL SBA Small Business
IT information technology
U.S. Department of Labor Administration
KPMG KPMG LLP
DOJ U.S. Department of Justice SSA Social Security
Longshore Special Fund Administration
EBSA Employee Benefits Security
Longshore and Harbor
Administration SWA State Workforce Agency
Workers’ Compensation Act
EDD Employment Development Special Fund TFFF Temporary Full Federal
Department Funding of the First Week
MSHA Mine Safety and Health
of Compensable Regular
EIDL Economic Injury Disaster Administration
Unemployment for States
Loan
NLRB National Labor Relations with No Waiting Week
Energy Energy Employees Board
Treasury
Occupational Illness
OCFO Office of Chief Financial U.S. Department of the
Compensation Program
Officer Treasury
ERISA Employment Retirement
OCIO Office of Chief Information Trust Fund
Income Security Act of 1974
Officer Black Lung Disability Trust
ETA Employment and Training Fund
OIG Office of Inspector General
Administration
TSP Thrift Savings Plan
OLMS Office of Labor-Management
EURGENO
Standards UI unemployment insurance
Emergency Unemployment
Relief for Governmental OMB Office of Management and USPIS United States Postal
Entities and Nonprofit Budget Inspection Service
Organizations
OSHA Occupational Safety and USSS United States Secret
FBI Federal Bureau of Health Administration Service
Investigation
OWCP Office of Workers’ WHD Wage and Hour Division
FECA Federal Employees’ Compensation Programs
WIOA Workforce Innovation and
Compensation Act
PERM permanent employment Opportunity Act
FLC Foreign Labor Certification certification program
Semiannual Report to Congress | April 1, 2024–September 30, 2024 123
Office of Inspector General, U.S. Department of Labor
200 Constitution Avenue, NW
Room S-5506
Washington, DC 20210
To learn more about the Office of Inspector General’s current and planned work,
please visit www.oig.dol.gov.
Office of Inspector General
United States Department of Labor
Report Fraud, Waste, and Abuse
Contact the Hotline
202.693.6999 or 800.347.3756
Fax: 202.693.7020
www.oig.dol.gov
The OIG Hotline is open to the public and to federal employees
24 hours a day, 7 days a week, to receive allegations of fraud, waste,
and abuse concerning Department of Labor programs and operations.
OIG Hotline
U.S. Department of Labor
Office of Inspector General
200 Constitution Avenue, NW
Room S-5506
Washington, DC 20210
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