Semiannual Report to Congress, Office of Inspector General for the U.S. Department of Labor, Volume 93 (October 1, 2024–March 31, 2025)
Summary
Volume 93 of the Department of Labor Office of Inspector General's Semiannual Report to Congress covers October 1, 2024 to March 31, 2025. Acting Inspector General Luiz A. Santos warns that the statute of limitations for pandemic-era unemployment insurance (UI) fraud has begun to lapse, and that with reduced funding the OIG has begun scaling back new pandemic UI fraud investigations. Since April 2020, the message says, the OIG has secured more than 2,000 indictments or initial charges, 1,500 convictions and $1.1 billion in investigative monetary outcomes associated with UI fraud. In the period it issued 15 audit reports with 65 recommendations and reports 131 investigations completed, 202 indictments, 287 convictions and more than $185 million in monetary accomplishments.
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Volume 93 October 1, 2024–March 31, 2025
Semiannual Report
to Congress
Office of Inspector General for the U.S. Department of Labor
A Message from the Acting Inspector General
I am honored to submit our Semiannual Report
to Congress, summarizing the activities and
accomplishments of the U.S. Department of Labor
(DOL), Office of Inspector General (OIG), for the
six-month period ending March 31, 2025.
The OIG remains committed to conducting independent
and objective oversight to assess the effectiveness,
efficiency, and integrity of DOL programs and operations.
As outlined in this report, we continue to identify key
challenges and risks through our audits and investigations.
Statute of Limitations
The OIG remains deeply concerned about the ongoing
expiration of the statute of limitations for fraud related
to pandemic-era unemployment insurance (UI) programs. For many cases, that period has
already begun to lapse, making this the final opportunity to highlight the issue in a Semiannual
Report before our ability to pursue justice in these cases is significantly diminished.
Since April 2020, the OIG has secured more than 2,000 indictments or initial charges,
1,500 convictions, 39,000 months of incarceration, and $1.1 billion in investigative
monetary outcomes associated with UI fraud. While we will continue to pursue existing
cases for as long as the law permits, the expiration of these statute of limitations—along
with reduced funding—means we have begun scaling back on launching new investigations
into pandemic-related UI fraud. Without an extension of the statute of limitations, fraudsters
involved in some of the most egregious pandemic UI fraud cases will escape justice and the
government will be unable to recoup stolen taxpayer funds.
OIG Accomplishments
OIG staff continue to deliver impressive results through their audit and investigative work,
helping to safeguard federal programs and promote accountability. During this reporting
period, the OIG issued 15 audit reports with 65 recommendations. Key findings include:
• H-2A Program Oversight: While the Employment and Training Administration
(ETA) generally ensured compliance with core requirements of the H-2A program,
further improvements are needed to ensure accurate wage payments and consistent
post-adjudication review.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 1
• Mental Health Parity Enforcement: The Employee Benefits Security Administration lacked
critical tools to effectively enforce mental health parity rules and did not fully utilize the tools
it did have. Some reviews took up to three years to complete.
• Data Sharing to Combat Fraud: A joint audit with the Small Business Administration (SBA)
OIG found that better data sharing between DOL’s ETA and SBA could reduce fraud. The
OIG identified over $1.3 billion in potentially fraudulent UI and Economic Injury Disaster
Loan payments to the same likely fraudsters.
• Job Corps Drug Control Activities: While Job Corps supported federal drug control
priorities, it did not adequately measure or report on the impact of its activities, limiting the
ability to demonstrate effectiveness.
Our investigative work also produced impressive results, with a total of 131
investigations completed, 202 indictments, 287 convictions, and more than $185 million
in monetary accomplishments. Notable cases include:
• A Texas pharmacist and his business partner were sentenced to more than 15 years in
prison and ordered to forfeit more than $400 million for defrauding the Office of Workers’
Compensation Programs;
• A Detroit man was sentenced to nearly 8 years in prison for a $6.3 million identity theft UI
fraud scheme that targeted multiple State Workforce Agencies;
• A former employee of the California Employment Development Department pled guilty for
her role in an $800,000 UI fraud conspiracy;
• An Iowa farmer was sentenced to more than 15 years in prison for cattle theft, bankruptcy
fraud, and a foreign labor certification fraud scheme that involved forced labor;
• A Boston pizzeria owner was sentenced to more than 8 years in prison for his role in
forced labor and pandemic fraud schemes.
These significant results reflect the sustained efforts of our staff, and I want to take a moment
to recognize their work. The professionalism and dedication shown by OIG personnel have
been essential to our oversight mission, particularly in navigating complex cases and evolving
oversight priorities.
2 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Looking Ahead
As we continue our oversight work, we will maintain our focus on high-impact audits and
investigations that promote accountability and transparency in DOL programs. Our oversight
efforts will remain centered on protecting taxpayer dollars and supporting the Department’s
mission on behalf of American workers.
We are also closely monitoring recent changes within DOL resulting from broader
government restructuring efforts. While the audits and investigations summarized in this
report were largely conducted prior to these developments, we will continue to assess their
impact in the months ahead. The OIG will incorporate these developments into our risk
assessments and oversight planning, and we will provide timely updates to Congress and the
Department should critical risks or operational concerns arise.
In closing, I would like to thank Congress and the Department for their support of our work to
improve DOL programs and operations and protect the interests and benefits of the nation’s
workers and retirees.
Luiz A. Santos
Acting Inspector General
Semiannual Report to Congress | October 1, 2024–March 31, 2025 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 | October 1, 2024–March 31, 2025
Contents
Selected Statistics . . . . . . . . . . . . . . . . . . . . 6 Appendices . . . . . . . . . . . . . . . . . . . . . . . 101
Reporting Requirements Under the
Significant Concerns . . . . . . . . . . . . . . . . . . 8 Following Acts . . . . . . . . . . . . . . . . . . . . 102
Funds Recommended for Better Use . . . . 104
Worker and Retiree Benefit Programs . . . . 33
Questioned Costs. . . . . . . . . . . . . . . . . . . . 105
Unemployment Insurance Programs . . . . 34
Final Audit Reports Issued . . . . . . . . . . . . . 106
Office of Workers’ Compensation
Other Reports. . . . . . . . . . . . . . . . . . . . . . . 108
Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Unresolved Audit Reports Over
Employee Benefit Plans . . . . . . . . . . . . . . 53 6 Months Old . . . . . . . . . . . . . . . . . . . . . . . 109
Management Decision Made During this
Worker Safety, Health, and Reporting Period on Audits, Inspections,
Workplace Rights . . . . . . . . . . . . . . . . . . . . 57 or Evaluations Issued during a Previous
Occupational Safety and Health Reporting Period: Final Audit Reports
Administration . . . . . . . . . . . . . . . . . . . . . 58 Issued . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .111
Management Decision Made During This
Mine Safety and Health Administration . . 59
Reporting Period on Audits, Inspections,
or Evaluations Issued During a Previous
Employment and Training Programs . . . . . 61 Reporting Period: Other Reports . . . . . . . . .114
Workforce Development Programs . . . . . 62 Corrective Actions Taken by
the Department . . . . . . . . . . . . . . . . . . . . . .115
Job Corps . . . . . . . . . . . . . . . . . . . . . . . . 64
Unimplemented Recommendations. . . . . . .117
Foreign Labor Certification Programs . . . 66
High-Priority Unimplemented
Recommendations . . . . . . . . . . . . . . . . . . . .118
Labor Racketeering . . . . . . . . . . . . . . . . . . 73
Summary of Reports with Unimplemented
Recommendations with Cost Savings / Funds
Departmental Management . . . . . . . . . . . . 75 Put to Better Use . . . . . . . . . . . . . . . . . . . . 123
Single Audits . . . . . . . . . . . . . . . . . . . . . . 84 Reports with Unimplemented
Recommendations for Management
Improvement or Disallowed Costs Owed. . 125
Employee Integrity Investigations . . . . . . . 85
Investigative Statistics . . . . . . . . . . . . . . . . 129
OIG Whistleblower Activities . . . . . . . . . . 87 Peer Review Reporting . . . . . . . . . . . . . . . 131
OIG Hotline. . . . . . . . . . . . . . . . . . . . . . . . . 133
Legislative Recommendations . . . . . . . . . . 91 Acronyms and Abbreviations . . . . . . . . . . . 134
Audit Statistics
15 65 $926,513
Audits and Recommendations for Questioned Costs
Other Reports Issued Corrective Action
OIG Unimplemented Recommendations
OIG recommendations not fully implemented as of March 31, 2025
BLS 2
EBSA 2
ETA 42
MSHA 29
OASAM 14
OCFO 7
OLMS 3
OSEC 1
OSHA 21
WHD 1
0 10 20 30 40 50
6 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Investigative Statistics
Investigative Results Labor Racketeering 102/131
Program Fraud
287
202
131
102
64 59
102 investigative
2 cases opened and
131 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: $1,200,071
Recoveries
Cost-Efficiencies
Restitutions
Fines/Penalties
Forfeitures
Civil Monetary Actions
$184,748,446
$185,948,517
Total Labor Racketeering
Program Fraud
Semiannual Report to Congress | October 1, 2024–March 31, 2025 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
Deploying Unemployment
Insurance Benefits Maintaining the
Expeditiously and Integrity of Foreign
Efficiently While Reducing Labor Certification
Improper Payments, Programs
including Fraud
Providing the OIG Managing Medical
Access to UI Claimant Benefits in the
Data and Wage Records Protecting the Safety and Office of Workers’
Health of Workers Compensation
Programs
Risk of Unused Funds
in State UI Accounts
Not Being Returned to Protecting the Safety Ensuring the Solvency
the U .S . Department of and Health of Miners of the Black Lung
the Treasury Disability Trust Fund
Ensuring Reliable Improving the
Estimates for Ensuring the
Performance
Unemployment Trust Fund Safety of Students
Accountability of
Amounts Reported in the and Staff at Job
Workforce Development
Consolidated Financial Corps Centers
Programs
Statements
Protecting the Managing and
Curtailing Child Security of Securing Data and
Labor Law Violations Employee Benefit Information Systems
Plan Assets
8 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 urgently to extend the criminal statute of
limitations for fraud associated with pandemic-related unemployment insurance (UI) programs, many
groups and individuals who have defrauded the UI program may escape justice. As it stands, the statute
of limitations for many pandemic-related UI fraud cases has begun to expire, as the statutes most often
used to prosecute UI fraud have five-year limitations. This is the final Semiannual Report to Congress
in which we plan to highlight this issue before the statute of limitations significantly impairs our ability to
pursue justice in these cases.
During the pandemic, the OIG was responsible for
Notwithstanding the OIG’s
investigating an exceptional volume of complex
tireless efforts, a failure to
pandemic-related UI fraud cases that increased a
extend the current statute
thousandfold compared to pre-pandemic levels. Since
of limitations associated
April 2020, the OIG has opened more than 209,000
with UI fraud means federal
investigative matters involving the UI program. We
law enforcement will
continue to receive up to 100 new UI fraud complaints
have to stop short of fully
each week. Notwithstanding the OIG’s tireless efforts,
investigating and prosecuting
a failure to extend the current statute of limitations
some of the most egregious
associated with UI fraud means federal law enforcement
cases of UI fraud .
will have to stop short of fully investigating and
prosecuting some of 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.
These investigations require significant resources and time. Supplemental pandemic funding from
Congress allowed the OIG to hire more criminal investigators and significantly expand the number of
staff reviewing UI fraud matters. As a result, the OIG has secured more than 2,000 indictments or initial
charges, 1,500 convictions, 39,000 months of incarceration, and $1.1 billion in investigative monetary
outcomes associated with UI fraud since April 2020. These resources also supported the issuance of
58 audit reports, which included 169 recommendations for corrective action by the Department of Labor
(DOL). In addition, the OIG identified more than $75 billion in funds for better use and $407 million in
questioned costs related to DOL’s pandemic-related programs and operations (see Table 1).
Semiannual Report to Congress | October 1, 2024–March 31, 2025 9
Significant Concerns
Table 1: DOL-OIG’s Cumulative Pandemic-Related Results,
April 2020–March 2025
Audit Reports 58
Recommendations 169
Funds Identified for Better Use $75 billion+
Questioned Costs $407 million+
Indictments/Initial Charges 2,000+
Convictions 1,500+
Months of Incarceration Ordered 39,000+
Investigative Monetary Results1 $1.1 billion+
The OIG remains committed to investigating open pandemic-related UI fraud matters for as long as
the statute of limitations allows. However, the exhaustion of supplemental funding and other budget
limitations have forced the OIG to reduce staffing to well below pre-pandemic levels. That, combined
with the ongoing expiration of the statute of limitations, has caused the OIG to begin pivoting away from
opening new pandemic UI fraud investigations. As a result, we have significantly curtailed the opening
of any new pandemic UI fraud investigations. Furthermore, 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.
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 program (EIDL). Congress should likewise consider immediately extending the statute
of limitations for existing laws in cases where pandemic-related UI programs have been defrauded.
The expansion of the statute of limitations would provide investigators and prosecutors with the time to
pursue and hold accountable those who defrauded the UI program and victimized the American people
during the pandemic.
Deploying Unemployment Insurance Benefits Expeditiously and Efficiently While
Reducing Improper Payments, Including Fraud
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
1 Investigative Monetary Results include recoveries, cost-efficiencies, restitutions, fines/penalties, forfeitures, and
civil monetary actions.
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.
10 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
and adequate oversight. Since the onset of the
COVID-19 pandemic, these concerns have grown.
Workers faced delays in receiving UI benefits,
WHAT IS AN IMPROPER PAYMENT?
improper payments soared, and our audit and
investigative work found program weaknesses
persisted during the pandemic and beyond— A payment is improper if it
vulnerabilities that criminal organizations continue should not have been made or
to exploit. We remain particularly concerned was to the wrong recipient.
about the deployment of UI benefits in response
*
to future emergencies, including natural disasters
Examples include overpayments
and economic downturns, as well as an immediate
and underpayments.
need to improve internal controls against fraud.3
*
At the start of the pandemic, we identified An improper payment can be
critical issues, such as staffing shortages and unintentional or intentional.
outdated system capabilities, for DOL and states
*
to address while implementing the Coronavirus
Aid, Relief, and Economic Security (CARES) Act Intentional improper payments are more
programs. While the Employment and Training commonly referred to as financial fraud.
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 pandemic,4 only 34 percent of reporting states were paying regular UI
claimants on time in January 2025, 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, including those using sophisticated and ever-evolving fraud schemes. For
3 Fraud is a type of improper payment. The Office of Management and Budget (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.
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 ETA’s public reporting on States’ UI Benefit Timeliness and Quality, available at:
https://oui.doleta.gov/unemploy/btq.asp.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 11
Significant Concerns
example, the estimated UI benefit fraud rates for FY 2024 in New York and Rhode Island exceeded
20 percent.6 This means more than $1 in every $5 dollars paid out in UI benefits in those states
went to criminals instead of legitimate claimants.
While the Department and states have implemented multiple tools and measures to prevent fraud, both
foreign and domestic criminal organizations continue to exploit 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 manipulating vulnerabilities
in state UI websites to identify valid Social Security numbers—which they then used to file fake UI
claims. 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 risk of financial loss.
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 18 of the last 21 years,7 the reported
estimated improper payment rate for the regular UI program has exceeded 10 percent.8
Over the last 4 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 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 programs.9 Although the FY 2024 estimated improper payment rate was reported as
14.41 percent, this rate still exceeds pre-pandemic levels and fails to meet federal requirements.
In February 2023,10 then 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
6 Based on ETA’s publicly reported data for the 2024 Improper Payments 1-Year Data, available at:
https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/data
7 UI improper payments data from FY 2004 through FY 2024 as reported to OMB.
8 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.
9 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.
10 “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
12 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
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 period in which a state is authorized 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 unable 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-enabled11 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.
Our investigators have identified extensive criminal activity linked to UI fraud, both domestically and
internationally. Since April 1, 2020, this has included over 2,000 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. Our investigators,
11 Per Executive Order 13984, issued January 19, 2021, “the term ‘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.”
Semiannual Report to Congress | October 1, 2024–March 31, 2025 13
Significant Concerns
auditors, and data scientists collaboratively identified12 $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.
We continue to detect and advise states on advanced fraud schemes and techniques. For example, bad
actors have used overseas-hosted websites to impersonate state unemployment login pages. These
fraudulent websites trick legitimate claimants into providing usernames and passwords to criminals, who
change bank account routing information and divert UI benefits into accounts they control.
Furthermore, UI funds are being stolen by dangerous domestic criminals. In one OIG investigation, a
criminal group engaged in large-scale drug manufacturing used stolen identities to file fraudulent UI claims
and rent properties for their operations. The group produced counterfeit oxycodone pills laced with fentanyl
in Maryland and Washington, DC. Members of the group admitted to obtaining at least $250,000 through a
UI fraud scheme, and one suspect was ultimately arrested following a high-speed car chase.
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 claimant data and wage records from SWAs for both Barriers to the OIG’s ongoing,
regular and emergency UI programs remain a significant timely, and complete access
concern. This situation adversely impacts the OIG’s ability to UI claimant data and wage
to provide independent oversight, to combat fraud, waste, records from SWAs for both
and abuse, and to otherwise help DOL improve the integrity regular and emergency UI
of the UI program. The primary barrier to such access is programs remain a significant
from DOL’s interpretation of its own regulations, including concern .
a historical view that such access be restricted to specific
12 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
14 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
suspected instances of fraud. This interpretation and subsequent guidance to SWAs contradicts
the Inspector General Act of 1978, as amended, 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.
However, in our September 2022 alert memorandum,13 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 to this data and these
records without constraints. Ongoing, timely, and complete access to SWA UI claimant data and wage
records further enables 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.
In March 2025, the White House released Executive Order 14243 entitled “Stopping Waste, Fraud,
and Abuse by Eliminating Information Silos.” The Executive Order requires agency heads to ensure
the federal government has unfettered access to comprehensive data from all state programs that
receive federal funding, including, as appropriate, data generated by those programs but maintained
in third-party databases. Furthermore, the Executive Order requires the Secretary of Labor and the
Secretary’s designees to receive “…unfettered access to all unemployment data and related payment
records, including all such data and records currently available to the Department of Labor’s Office of
Inspector General.” In alignment with the intent of this Executive Order, DOL should collect ongoing
state UI records directly from SWAs moving forward, in which case the OIG will obtain the data directly
from ETA.
Risk of Unused Funds in State UI Accounts Not Being Returned to the U .S .
Department of the 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)
13 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
Semiannual Report to Congress | October 1, 2024–March 31, 2025 15
Significant Concerns
and Emergency Unemployment Relief for Governmental Entities and Nonprofit Organizations
(EURGENO)—we identified the need for reconciliation of more than $5 billion.14
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.15 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 Department
needs to ensure that states reconcile and close out these accounts and return the funds to the U.S.
Department of the Treasury (Treasury). According to ETA, as of April 11, 2025, 21 of the 53 SWAs
had completed the reconciliation process and had their state subaccounts de-allotted. Further, ETA
confirmed that 16 of the 21 SWAs had returned $1.4 billion to the Treasury. ETA stated they will provide
additional information when the reconciliation and recovery is completed for the remaining SWAs.
Furthermore, during our audit of EURGENO, we identified that the Department made approximately
$6.3 billion of relief funds available to the 53 SWAs’ UI trust funds. We found that, 16 months after
EURGENO ended,16 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. As a result, we recommended ETA reconcile the accounts of
states with remaining balances and return $29 million to Treasury. As of March 7, 2025, ETA stated it is in the
early implementation phase and has not provided evidence that any funds have been returned to Treasury.
Ensuring Reliable Estimates for Unemployment Trust Fund Amounts Reported in
the Consolidated Financial Statements
In November 2024, DOL received its fourth consecutive qualified opinion and material
weakness on its consolidated financial statements. This happened due to DOL’s inability to
14 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
15 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 the first week regular UI compensation was 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 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.
16 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
provide sufficient appropriate audit evidence about
the methodology and underlying assumptions used The OIG is concerned DOL has
to estimate certain pandemic-related UI amounts. been unable to remediate its
Although the UI pandemic programs expired at the material weakness over estimates
end of FY 2021, there continues to be UI benefit for certain reported Unemployment
disbursement and related activities reported in DOL’s Trust Fund amounts, hampering
financial statements. As of September 30, 2024, its ability to obtain an unqualified
the financial statements included estimates of opinion on the consolidated
$7 billion in Unemployment Trust Fund obligations financial statements.
of COVID-19 funding and $10 billion in COVID-19
benefit overpayment receivables. The OIG is concerned DOL has been unable to remediate its
material weakness over the 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 the 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 unemployment weeks that occurred prior to the expiration
of the UI 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
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 as well as 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 the health, wellbeing, or educational opportunities for minors. 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 2024, DOL concluded 736 investigations that identified child labor violations. Specifically, DOL
found 4,030 children employed in violation of the law, a 31 percent increase since 2019. In addition,
DOL assessed more than $15.1 million in related penalties, which was an 89 percent increase from
the previous year. Notably, this increase in child labor law violations since 2019 is occurring while
WHD struggles to retain investigators. To address the increase in violations, DOL has spearheaded
Semiannual Report to Congress | October 1, 2024–March 31, 2025 17
Significant Concerns
an interagency task force to combat child labor exploitation, launched a National Child Labor Strategic
Enforcement Initiative, and engaged in other federal and local collaboration efforts 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.
Finally, while WHD does not have explicit authority to investigate labor trafficking, WHD investigators
are in a unique position to detect potential labor trafficking indicators during the normal course of
an investigation. As such, the OIG is concerned with WHD’s handling of labor trafficking victims,
particularly minors, when they are encountered in the field by WHD personnel. The OIG is currently
conducting an audit to identify high-risk child labor concerns for additional oversight in FY 2025
and beyond.
Protecting the Safety and Health of Workers
The Occupational Safety and Health Administration
The OIG remains concerned
(OSHA) assures the safety and health of
about OSHA’s ability to target its
approximately 130 million workers employed at more
enforcement activities
than 8 million worksites by enforcing standards;
to areas where it can have the
working collaboratively with states; and providing for
greatest impact .
research, information, education, and training. Failure
to keep workplaces free of known safety and health
hazards can lead to fatalities, injuries, illnesses,
and serious legal consequences. The OIG remains concerned about OSHA’s ability to target its
enforcement activities to areas where it can have the greatest impact.
OSHA carries out its enforcement responsibilities through a combination of self-initiated
inspections and those resulting from complaints and referrals. For FY 2024, OSHA conducted
38,182 inspections, including 18,540 unprogrammed inspections, which resulted from employee
complaints, injuries/fatalities, and referrals. OSHA continues to be challenged with reaching the
number of worksites for which it is responsible and has seen an 11 percent reduction in its number
of inspectors over the past 12 months—from 846 to 755.
18 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
Workplaces with high injury and illness rates should be a crucial target for directing OSHA’s
limited enforcement resources. However, as we reported in 2023,17 OSHA’s targeting programs
that were specifically designed to reach workplaces with high rates of serious injuries targeted
a very small percentage of these workplaces, and, of those targeted, fewer inspections actually
occurred, leaving workers vulnerable to continuously high rates of injury and illness.
Furthermore, OSHA’s ability to target enforcement is also impacted by its limited visibility into
the numbers and types of injuries and illnesses occurring in warehouses, including those
classified as online retailers. We found, on average, between 2016 and 2020, 59 percent of
establishments in all industries failed to submit their mandatory annual injury and illness reports
to OSHA. Additionally, OSHA could not 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 every surface mine at least two times per year. A 2023 OIG audit18 found MSHA
did not complete an estimated 1,589 mandatory inspections for a period of four fiscal years from
FY 2018 through FY 2021 despite reporting a nearly 100 percent completion rate. In addition,
in November 2024, the OIG issued an alert memorandum19 notifying leadership that MSHA
17 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
18 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
19 Alert Memorandum: Urgent Concerns for Miner Safety and Health in At Least Three U.S. Territories: MSHA Has
Never Conducted Mandatory Inspections and Conducted Inappropriate Oversight of Mines in the Pacific Territories,
Report No. 05-25-002-06-001 (November 12, 2024), available at:
https://www.oig.dol.gov/public/reports/oa/2025/05-25-002-06-001.pdf
Semiannual Report to Congress | October 1, 2024–March 31, 2025 19
Significant Concerns
has failed to sufficiently identify its own jurisdiction and has never conducted mandatory mine
inspections in at least three U.S. territories20 where mining activity has occurred.
While MSHA has not provided the OIG with its planned corrective actions in response to our alert
memorandum, MSHA has started taking actions in response to our 2023 audit. 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. Furthermore, agency data contains inaccurate operating statuses for some mines.
Inaccurate operating statuses are of serious concern because they 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 audit21 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 failure to implement six of 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.22
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 miner fatalities for 7 years.
20 The three territories are American Samoa, Guam, and the Commonwealth of the Mariana Islands (Northern Mariana
Islands) (collectively, the Pacific Territories).
21 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
22 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 | October 1, 2024–March 31, 2025
Significant Concerns
Figure 1: Number and Percentage of Top 8 Classes of Mining Fatalities,
Calendar Years 2018–2024
Powered Haulage 70 32%
Machinery 58 26%
Slip or Fall of Person 18 8%
Other 16 7%
Fall of Roof or Back 12 5%
Electrical 12 5%
Fall of Face/Rib/Pillar/Side/
10 5%
Highwall
Falling/Sliding/Rolling
8 4%
Materials
0 10 20 30 40 50 60 70 80
Source: MSHA’s Accident Injuries public dataset, as of March 14, 2025
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. While we saw a decrease
in machinery fatalities in 2024 from 2023, the powered haulage fatalities remained steady. 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 by mine operators, 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 | October 1, 2024–March 31, 2025 21
Significant Concerns
In our November 2020 audit report,23 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 centers—which are mostly
residential, with students living on-campus—continues to be a concern of the OIG’s due to
ongoing issues with on-campus violence. In Program Year 2023, Job Corps centers reported
1,693 on-campus assaults. Preventing on-campus violence and other potential criminal behavior
remains a challenge for Job 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, six Job Corps students died of suspected
unintentional drug overdoses, with three occurring on campus. Our analysis of Job Corps data for
Program Year 2022 also identified five students and one staff member 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 students24 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.
23 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
24 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 | October 1, 2024–March 31, 2025
Significant Concerns
Protecting the Security of Employee Benefit Plan Assets
The OIG remains concerned about the Employee
The OIG remains concerned about
Benefits Security Administration’s (EBSA) ability to
EBSA’s ability to protect the
protect the integrity of pension, health, and other benefit
integrity of pension, health, and
plans of more than 156 million workers, retirees, and
other benefit plans of more than
their families under the Employee Retirement Income
156 million workers, retirees, and
Security Act of 1974 (ERISA). In particular, the OIG is
their families under ERISA .
concerned about the statutory limitations on EBSA’s
oversight authority and inadequate resources to conduct
compliance and enforcement. From FY 2018 to FY 2025, EBSA’s resources dropped 35 percent from
404 to 261 frontline staff.25 Taking into consideration the 801,000 private retirement plans and 514,000
other welfare benefit plans with the 2.6 million health plans EBSA has jurisdiction over, this equates
to 1 investigator for roughly every 15,000 plans. 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 further 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 work26 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,27 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.
25 EBSA’s frontline staff includes investigators, auditors, and senior investigators who are responsible for detecting
and correcting any and all ERISA violations.
26 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
27 Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA,
Statement on Auditing Standards No. 136 (July 2019), available at:
https://www.aicpa-cima.com/resources/download/aicpa-statement-on-auditing-standards-no-136
Semiannual Report to Congress | October 1, 2024–March 31, 2025 23
Significant Concerns
Furthermore, 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.28 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 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 also potentially place trillions of dollars in other
ERISA-covered retirement plan assets at risk.
Complicating the cyber landscape, EBSA has been cautioning investors about the volatility and
instability of cryptocurrencies; expressed custodial, recordkeeping, and valuation concerns; and has
indicated that these investments are subject to significant risks of fraud, theft, and loss. In March
2022, EBSA issued a Compliance Assistance Release29 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. To address these challenges, 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 2024,30 we reported OLMS did not effectively enforce persuader activity requirements to
protect workers’ rights to unionize. Specifically, OLMS did not effectively ensure required persuader
28 The total value of TSP assets fluctuates over time and is affected by market volatility.
29 U.S. Department of Labor, Employee Benefits Security Administration, Compliance Assistance Release
No. 2022-01: 401(k) Plan Investments in “Cryptocurrencies” (March 10, 2022), last accessed March 26, 2025, available
at: https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/compliance-
assistance-releases/2022-01.
30 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 | October 1, 2024–March 31, 2025
Significant Concerns
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 the NLRB.
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’s limited enforcement authority, which
lacks 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’
Allows U.S.
jobs, wages, and working conditions. DOL’s administration employers to hire
of FLC programs under current laws has been a concern PERM immigrant workers
VISA for permanent jobs
for the OIG for decades. Our work has shown these visa
programs—particularly 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 Allows U.S. employers
enterprises. to hire nonimmigrant
workers for temporary
H-1B specialty jobs
VISA
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
Allows U.S. employers
ability to deny H-1B applications and to investigate potential to hire nonimmigrant
violations. Specifically, DOL may only deny incomplete and workers for temporary
H-2A or seasonal
obviously inaccurate H-1B applications and has only limited VISA agricultural jobs
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 Allows U.S. employers
utilizes a Secretary-certified investigation. As some foreign to hire nonimmigrant
workers for temporary
workers may be reluctant to file complaints for fear of H-2B or seasonal
non-agricultural jobs
retaliation and losing their jobs, the Department’s process is VISA
unlikely to result in verification action being taken.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 25
Significant Concerns
Some employers exploit FLC program vulnerabilities to facilitate labor trafficking—a type of
human trafficking—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,31 16 individuals have pled guilty
and 15 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 has previously identified concerns with OWCP’s management
of pharmaceuticals. In our most recent report, issued March 2023,32 we found OWCP did not
effectively manage pharmaceutical spending in the FECA program from FY 2015 through FY 2020.
31 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
32 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 | October 1, 2024–March 31, 2025
Significant Concerns
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 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 recommendations, OWCP implemented a pharmacy
benefit manager33 responsible for FECA pharmaceutical transactions, including pricing for prescription
drugs. In addition, OWCP expanded pharmacy benefit manager coverage to the Energy and Black
Lung Benefits programs. While OWCP has addressed all of our pharmaceutical recommendations
and significantly reduced pharmaceutical spending in the FECA program, OWCP needs to continue
to ensure it provides adequate oversight over the pharmacy benefit manager to ensure the
pharmaceutical benefits it provides are safe, effective, medically necessary, and economical.
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 approximately $1.6 billion in FY 2024 (see Figure 2). 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.
Figure 2: Home Health Care Costs in the Energy Program,
Fiscal Year 2010–2024
$1,800
$1,600 $1,600
•
$1,400
Cost (in millions)
$1,200
$1,000
•
$860
$800 • •
$675
$600 $541
• •
$391
•
$400 • •
$219
•
$251
• •
$200 • •
• $100
$0
2010 2012 2014 2016 2018 2020 2022 2024
Source: Home health care cost data provided by OWCP.
33 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.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 27
Significant Concerns
In May 2024,34 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.
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
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 $6.6 billion deficit balance, which is projected to
grow to $14.4 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 four key areas: (1) awarding
grants, (2) reviewing grant recipients’ use of funds, (3) determining participant eligibility, and (4)
measuring program performance. ETA must ensure it focuses on these areas to improve the
accountability of the Department’s workforce development programs.
34 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
28 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
The OIG’s September 2021 audit 35 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
$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 sub-recipients spend funds can improve
performance accountability in DOL workforce development programs. In September 2023, we
reported36 ETA needs to improve its oversight of grant recipients and sub-recipients37 in 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.
In our work on ETA’s administration of the Disaster National Dislocated Worker Grants (DWG)
published in October 2024, we reported on the $50 million38 DWG awarded under the Additional
Supplemental Appropriations for Disaster Relief Act, 2019 for necessary expenses directly related to
the consequences of multiple natural disasters. We found ETA did not establish written interagency
agreements with the Federal Emergency Management Agency (FEMA) to formalize collaboration efforts
in disaster recovery. ETA needs to strengthen its controls over how grant recipients and sub-recipients:
(1) coordinate with FEMA, (2) document participant eligibility, (3) receive timely grant funds to prevent
future work stoppages, and (4) use grant funds. In total, we identified questioned costs of $926,513
consisting of $909,240 for ineligible participants and $17,273 in costs not allocable to the grant.
ETA recently released Training and Employment Guidance Letter No. 09-2439 to update the guidance
for the DWG program. The update allows self-attestation in disaster situations without the need for
35 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
36 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
37 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.
38 Of the $50 million, $500,000 was transferred to the OIG for oversight of activities responding to the covered
disasters or emergencies.
39 TEGL No. 09-24, Updated National Dislocated Worker Grant Program Guidance and Application Information,
issued December 17, 2024, last accessed on March 12, 2025, and available at:
https://www.dol.gov/agencies/eta/advisories/tegl-09-24
Semiannual Report to Congress | October 1, 2024–March 31, 2025 29
Significant Concerns
additional documentation. Previously, ETA guidance40 required states to collect all documentation
necessary to demonstrate that each participant is eligible. With the update, the Department must also
obtain appropriate, accurate, and reliable data to measure, assess, and make decisions regarding
the performance of its workforce development programs. In 2020, an audit 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 personally identifiable information 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. The OIG
also continues 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
We continue to identify recurring
DOL’s efforts to manage and implement security
deficiencies in DOL’s efforts to
controls throughout its information security program.
manage and implement security
The Department has not adequately implemented
controls throughout its information
information security controls and technology
security program .
tools required to manage and monitor IT security.
Furthermore, we are still concerned the 30 percent of
systems outside the Office of the Assistant Secretary
for Administration and Management’s (OASAM) 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.
40 TEGL No. 12-19, National Dislocated Worker Grant Program Guidance, issued March 18, 2020, last accessed on
March 12, 2025, and available at:
https://www.dol.gov/agencies/eta/advisories/training-and-employment-guidance-letter-no-12-19
30 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Significant Concerns
Additionally, we are concerned about DOL’s oversight of the rapidly expanding use of AI across
agencies. In developing its AI capabilities, DOL instituted an AI Governance Board, appointed specific
agency AI Points of Contact, developed a process for evaluating new AI use cases, and created
an inventory of DOL’s current AI use cases. Our concerns involve the current vacancies in the AI
Governance Board positions and the 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 Chief Information Officer 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.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 31
Worker and Retiree
Benefit Programs
Unemployment Insurance Programs
Office of Workers’ Compensation
Programs
Employee Benefit Plans
Worker and Retiree Benefit Programs
Unemployment Insurance Programs
Enacted more than 80 years ago as a federal-state partnership, the unemployment insurance
(UI) 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. Within the UI program umbrella are other programs such as State UI,
Unemployment Compensation for Federal Employees, and Unemployment Compensation for
Ex-Servicemembers. The UI program is generally administered by states with oversight from
DOL’s Employment and Training Administration.
The UI program has experienced some of the highest improper payment rates across the federal
government, generally exceeding 10 percent for the last two decades.
Joint Report to U .S . Department of Labor, Employment and Training Administration and the
U.S. Small Business Administration, Office of Capital Access
COVID-19: DATA SHARING PROJECT FINDS BILLIONS PAID TO SAME
LIKELY FRAUDSTERS UNDER BOTH THE UNEMPLOYMENT
INSURANCE AND ECONOMIC INJURY DISASTER LOAN PROGRAMS
Why We Conducted the Joint Project
The UI and EIDL programs provide eligible people and
businesses with needed relief in the face of crises. However,
both programs are at risk of ineligible individuals attempting to
obtain benefits. In 2020, soon after Congress expanded both
programs in response to the adverse economic effects caused
by the COVID-19 pandemic, both DOL-OIG and SBA-OIG
respectively began reporting on heightened risks of fraud and
found similar fraud indicators.
Given the similarities in potential fraud indicators in both
programs, DOL and SBA OIGs conducted a joint project to
answer the following question:
Could data sharing between the ETA and SBA mitigate
the risk of fraudulent UI benefit payments and SBA
disaster program disbursements?
34 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
To answer this question, the two OIGs entered into a data use agreement to share respective
pandemic-related data to perform data matching analyses.
What We Found
We found data sharing and matching between ETA and SBA could mitigate the risk of fraudulent
UI benefit payments and SBA disbursements. Both OIGs found data matching worked as a tool to
identify potential fraud. DOL-OIG identified more than $1.3 billion in potentially fraudulent UI and
EIDL payments made to the same likely fraudsters. Matching to a larger dataset, SBA-OIG identified
over $2.25 billion in potentially fraudulent EIDLs disbursed, including nearly $1.4 billion in EIDL
disbursements not previously identified by SBA-OIG or SBA.
People may be both employed and operating a small business, so they may be eligible to receive
assistance from both programs. However, during the pandemic, no data sharing mechanism on
potential fraud for UI and COVID EIDLs existed between ETA and SBA. If data sharing and matching
had existed, the agencies could have conducted a higher level of review by matching applicants
across both programs to mitigate fraudulent payments. The implications of fraud impacting more than
one agency extends beyond significant monetary losses, potentially impacting expeditious, efficient
deployment of assistance and decreasing public trust.
What We Recommended
We made a total of five recommendations: four to facilitate improved fraud controls via collaboration
and one (for SBA) to reevaluate eligibility. Specifically, we recommended DOL and SBA collaborate
to evaluate their authorities on data sharing and to develop further fraud prevention resources. ETA
stated agreement with one of its two recommendations. DOL-OIG will monitor ETA’s corrective action
plans to resolve the recommendations. SBA agreed with its three recommendations, and SBA-OIG
assesses its planned actions will resolve those recommendations.
For more information, go to: https://www.oig.dol.gov/public/reports/oa/2025/19-25-001-03-315.pdf,
Report No. 19-25-001-03-315 (December 5, 2024).
Semiannual Report to Congress | October 1, 2024–March 31, 2025 35
Worker and Retiree Benefit Programs
COVID-19: ETA COULD HAVE DONE MORE TO ENSURE STATES
HAD SUFFICIENT STAFFING TO DELIVER TIMELY PANDEMIC
UNEMPLOYMENT BENEFITS
Why OIG Conducted the Audit
On March 27, 2020, Congress passed the CARES Act,
which provided expanded UI benefits to workers unable
to work due to the COVID-19 pandemic. Section 2106 of
the CARES Act provided emergency hiring flexibility and
other temporary actions to process unemployment claims
quickly.
Our prior audit work found states’ staffing was a concern
in implementing emergency UI programs. Based on
these risks, we contracted with GenTech Associates, Inc.
(GenTech) to answer the following question:
Did the ETA ensure states’ staffing supported the
implementation of UI programs under the CARES
Act and its amendments?
To answer this question, GenTech assessed ETA’s
oversight, performed in-depth testing of 6 OIG-selected
states, and surveyed an additional 47 state workforce
agencies.
What OIG Found
GenTech found ETA took several actions toward ensuring states’ staffing supported the
implementation of CARES Act UI programs. However, more actions were needed to ensure staffing
levels were sufficient to afford timely benefits to eligible claimants. Specifically, ETA:
• provided states funding that could be used to improve staffing levels, but did not measure the
impact of that funding nor determine the sufficiency of increased staffing levels in implementing
the new UI programs;
• issued guidance for monitoring states’ staffing support, but did not do so until October 2020,
6 months after Congress passed the CARES Act;
36 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
• monitored states’ UI program performance, but did not recommend corrective actions to address
states’ staffing issues; and
• allowed states the flexibility to reassign Benefit Accuracy Measurement staff to claims
processing, but did not evaluate the resulting impairments to measuring improper payments.
These deficiencies occurred because ETA did not prioritize the oversight of states’ staffing during
the COVID-19 emergency. Specifically, ETA: (1) did not establish a benefit payment timeliness
standard for CARES Act UI programs; (2) did not recognize the need for urgency in issuing
monitoring guidance for the temporary programs; (3) allowed monitoring personnel the discretion
to classify staffing as an area of concern rather than a compliance issue requiring corrective action;
and (4) prioritized processing the volume of UI claims over measuring the accuracy of UI payments,
specifically improper payments when suspending the Benefit Accuracy Measurement program as a
strategy to address states’ staffing needs.
As a result, from April 2020 through September 2021, the 6 states were only able to pay 70 percent
of initial claims (3.6 million of 5.2 million) within 21 days, compared to the 87 percent standard ETA
applies to regular UI. The quarterly percentage of claims paid within 21 days ranged from 51 percent
to 81 percent. Furthermore, ETA’s suspension of the Benefit Accuracy Measurement program
impaired ETA’s ability to assess the integrity of the new UI programs with respect to improper
payments, including fraud.
What OIG Recommended
GenTech made four recommendations to ETA to improve its oversight and support of states’ staffing
needs during an emergency event. ETA did not agree with the four recommendations; however, ETA’s
proposed corrective action met the intent of one recommendation.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/19-25-002-03-315.pdf,
Report No. 19-25-002-03-315 (November 22, 2024).
California Resident Pled Guilty to Fraudulently Obtaining $59 Million in Public
Benefits and Laundering Proceeds to China
On January 29, 2025, Bruce Jin pled guilty to one count of conspiracy to commit wire fraud and one
count of conspiracy to launder monetary instruments in the amount of approximately $59 million in a
scheme to fraudulently obtain UI benefits in multiple states.
Jin and his co-conspirators entered into a series of agreements to make it appear as if they were
operating legitimate businesses that sold masks and other COVID-19 pandemic personal protective
equipment. In reality, the funds that he and others obtained and laundered through the companies
Semiannual Report to Congress | October 1, 2024–March 31, 2025 37
Worker and Retiree Benefit Programs
and banks were fraudulently obtained UI benefits from Pennsylvania and other states. Additionally,
the conspirators also fraudulently obtained Economic Impact Payments issued by the Internal
Revenue Service (IRS).
Jin and co-conspirators established various companies and subsequently opened bank accounts
associated with the companies. Unnamed members of the conspiracy, including some believed to
reside in China, utilized the stolen PII of thousands of identity theft victims to establish bank accounts
across the United States. The co-conspirators, who were believed to be in China, filed false UI claims
that were then paid into the fraudulently established bank accounts. Members of the conspiracy
initially transferred millions in UI benefits from the accounts in the names of identity theft victims to
companies that Jin and a co-conspirator controlled. They also transferred funds via ACH processing
or international wire transfers to bank accounts associated with other co-conspirators. Some of the
identified co-conspirators reside in China.
This is a joint investigation with the FBI. United States v. Bruce Jin (M.D. Pennsylvania)
Georgia Woman Sentenced to 144 Months in Prison for $30 Million
Pandemic-Related Unemployment Insurance Fraud Scheme and Firearms
Charge
On October 24, 2024, Tyshion Hicks was sentenced to 144 months in prison for her role in a
scheme to defraud the Georgia Department of Labor (GA DOL) of tens of millions of dollars in
pandemic-related UI benefits and for illegal possession of a machine gun.
From March 2020 through November 2022, Hicks and her co-conspirators caused more than 5,000
fraudulent UI claims to be filed with GA DOL, resulting in the disbursement of at least $30 million in
stolen benefits. To execute the scheme, she and her co-conspirators created fictitious employers
and lists of purported employees by using the PII of thousands of identity theft victims. They then
used the stolen PII and fictitious companies to file fraudulent UI claims on the GA DOL website.
The co-conspirators obtained the PII from a variety of sources, including by paying an employee
of a Georgia-based health care and hospital network to steal patients’ PII from hospital databases
and by purchasing PII from online sources. In addition, Hicks paid a U.S. Postal Service (USPS)
carrier to unlawfully divert mail containing debit cards loaded with more than $512,000 in UI fraud
proceeds to her.
This is a joint investigation with the United States Secret Service, Homeland Security Investigations
(HSI), the U.S. Department of Homeland Security (DHS)-OIG, the Internal Revenue Service-Criminal
Investigation (IRS-CI), the United States Postal Inspection Service (USPIS), and the USPS-OIG.
United States v. Tyshion Hicks (M.D. Georgia)
38 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
Detroit Man Sentenced to 94 Months in Prison for Role in Unemployment
Insurance Fraud Scheme
On March 13, 2025, Kenny Howard was sentenced to 94 months in prison and ordered to pay more
than $6.3 million in joint and several restitution after he pled guilty to one count of conspiracy to
commit wire fraud and one count of aggravated identity theft for his role in a scheme to defraud SWAs
during the COVID-19 pandemic.
Between approximately April 2020 and August 2021, Howard 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 with more than five
states, primarily Michigan, California, and Arizona. Howard and his co-conspirators used the stolen
PII of identity theft victims to file the UI claims. As a result, the co-conspirators fraudulently obtained
UI benefits that were loaded onto pre-paid debit cards and mailed to addresses controlled by the
defendants. To access the stolen funds, the co-conspirators made cash withdrawals at ATMs in
Michigan and California.
Approximately sixty percent of the fraudulent claims related to the scheme were successful, resulting
in a loss of more than $6.3 million to SWAs. If all the fraudulent claims had been approved, the
resulting loss would have been more than $11 million.
This is a joint investigation with HSI. United States v. Howard et al. (E.D. Michigan)
Detroit Resident Sentenced in CARES Act Fraud Scheme
On March 13, 2025, Maurice Brown-Portwood was sentenced to 22 months in prison and ordered to pay
more than $600,000 in restitution for his role in a multi-million dollar CARES Act fraud scheme.
On November 20, 2024, and November 25, 2024, Brown Portwood’s co-defendants Christopher Lindsay,
Deangelo Jackson Portwood, Anton Greenwood, Adartha Tillman, and Taurean Davis pled guilty to
conspiracy to commit wire fraud for their respective roles in the fraud scheme. Jackson-Portwood also
pled guilty to aggravated identity theft.
Between February 2020 and May 2021, Brown-Portwood and his co-conspirators obtained the PII of
identity theft victims, without their knowledge or consent. They then used the PII to file fraudulent claims
in various states for Pandemic Unemployment Assistance (PUA) benefits, PPP loans, and EIDL funds.
In other instances, the co-conspirators used their own identities to submit fraudulent PPP and EIDL
applications in the names of businesses that were fictitious or dormant. The PUA benefits were often
deposited onto debit cards that were sent to addresses controlled by the defendants.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 39
Worker and Retiree Benefit Programs
As a result of the schemes, they falsely obtained more than $6 million in PUA benefits, PPP loans, and
EIDL funds.
This is a joint investigation with the FBI and the SBA-OIG. United States v. Deangelo Jackson-Portwood
et al. (E.D. Michigan)
Michigan Fraudsters Sentenced for Conspiracy to Steal Pandemic
Unemployment Insurance Benefits
On December 3, 2024, Daniel Holt was sentenced to 24 months in prison for his involvement in a
pandemic-related UI fraud scheme. In October 2024, co-conspirators Jaylin Qualls, Daveontae White,
and Cheikh Sene were sentenced to 12 months, 24 months, and 36 months in prison, respectively. All
four defendants were ordered to pay restitution, jointly and severally, of more than $4.8 million.
Between approximately April 2020 and August 2021, Holt, Qualls, White, Sene, and their
co-conspirators filed nearly 700 fraudulent UI claims in more than nine states—primarily Michigan,
California, and Arizona. They used the stolen PII of identity theft victims to file the UI claims. As a
result, the co-conspirators fraudulently obtained more than $4.8 million in UI benefits that were loaded
onto pre-paid debit cards and mailed to addresses controlled by the defendants. To access the stolen
funds, the co-conspirators made cash withdrawals at ATMs in Michigan and California.
This is a joint investigation with the FBI. United States v. Marcellus Dunham et al. (E.D. Michigan)
Two Miami Men Sentenced for Conspiracy to Fraudulently Obtain More Than
$4 .4 Million in Pandemic-Related Unemployment Insurance Benefits
On February 25, 2025, Kenneth Dikari Stevens Jr and Giovanni K. Matthews were sentenced to 36
and 32 months in prison, followed by 60 months of supervised release, respectively. Stevens was
also ordered to pay a total of $3.8 million in restitution and Matthews was ordered to pay a total of
$337,000 in restitution.
Stevens and Matthews were previously convicted of conspiracy to commit bank fraud, wire fraud,
and mail fraud for their roles in a scheme to defraud the California Employment Development
Department (California EDD) of COVID-19 pandemic-related UI benefits.
Between approximately August 2020 and January 2022, Stevens, Matthews, and their
co-conspirators used the PII of identity theft victims to submit fraudulent UI applications to the
California EDD. To successfully file a claim with California EDD, applicants had to pass an identity
verification process, which required them to upload a driver’s license, among other steps. The
photo of Stevens’ face was on 262 falsified driver’s licenses used to obtain the stolen benefits.
40 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
Of the 262 claims, the California EDD approved 220 and disbursed more than $4.4 million in UI
benefits.
This is a joint investigation with the DHS-OIG, the USPIS, and the FBI as part of the Southern
District of Florida Miami COVID-19 Strike Force. United States v. Kenneth Dikari Stevens, Jr.,
United States v. Giovanni Kymani Paul Matthews (S.D. Florida)
Maryland Man Pled Guilty to Role in $3 .5 Million Pandemic-Related
Unemployment Insurance Fraud Conspiracy
On January 21, 2025, Ahmed Hussain pled guilty to conspiracy to commit wire fraud and aggravated
identity theft, for his role in a $3.5 million pandemic-related UI fraud scheme. He also pled guilty
to additional counts of felon in possession of a firearm and possession with intent to distribute a
controlled substance.
Between approximately 2021 and 2022, Hussain conspired with other co-defendants, including
former contractors who provided services directly to the Maryland Department of Labor (MD DOL) to
defraud the UI program. The contractors were issued laptop computers that allowed remote access to
MD DOL systems, such as the UI claims system. Hussain and his co-conspirators 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. Hussain and his co-conspirators uploaded and
approved documents required by MD DOL to support UI claims, removed fraud holds on UI claims,
and certified weeks of unemployment for payment in the MD DOL system. They also engaged in other
actions to facilitate the payment of the fraudulent benefits, such as using the PII of multiple identity
theft victims to make changes in the MD DOL system.
Based on Ahmed Hussain’s activities, the members of the conspiracy fraudulently obtained more
than $3.5 million in pandemic-related UI benefits of which Hussain personally obtained more than
$550,000.
On November 16, 2022, in an unrelated matter, a residential search warrant was executed at
Hussain’s shared Maryland residence. In his room, law enforcement discovered a stolen handgun,
firearm ammunition, Glock magazines, 60 pounds of marijuana, more than $5,000 in cash, and drug
paraphernalia. Hussain had been previously convicted of an offense punishable by more than one
year in prison and was therefore prohibited from possessing a firearm or ammunition.
This is a joint investigation with the FBI as part of the Maryland COVID-19 Fraud Enforcement Strike
Force. United States v. Ahmed Hussain (D. Maryland)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 41
Worker and Retiree Benefit Programs
Miami Man Sentenced for Role in Conspiracy to Fraudulently Obtain More Than
$3 Million in COVID-19 Unemployment Benefits
On January 16, 2025, Harold Eugene Eubanks was sentenced to 63 months in prison and ordered to
pay more than $3.2 million in restitution after he previously pled guilty to conspiracy to commit bank
fraud, wire fraud, and mail fraud.
Between approximately August 2020 and April 2022, Eubanks and his co-conspirators submitted
more than 270 false UI applications to the California EDD. To successfully file a claim, applicants
had to pass an identity verification process. To that end, Eubanks submitted photographs of his face
to support each claim. California EDD approved at least 155 of the claims submitted containing
photographs of his face, resulting in the disbursement of more than $3.2 million in UI benefits.
This is a joint investigation with the DHS-OIG, the USPIS, and the FBI as part of the Southern District
of Florida Miami COVID-19 Strike Force. United States v. Harold Eubanks et al. (S.D. Florida)
Maryland Defendants Pled Guilty to Roles in $3 .2 Million Pandemic-Related
Unemployment Insurance Fraud Conspiracy
On November 13, 2024, and January 13, 2025, Tiia Woods and Devante Smith pled guilty,
respectively, to conspiracy to commit wire fraud and aggravated identity theft for their roles in a
scheme to defraud the MD DOL that resulted in more than $3.2 million in actual losses to the UI
program.
From June 2020 through approximately May 2021, Woods, Smith and their co-conspirators submitted
to MD DOL fraudulent UI applications that contained the addresses, employment status, work
history, occupation, and benefit eligibility of unsuspecting identity theft victims. Using email and
other electronic communications, Woods, Smith, and others fraudulently applied for UI benefits
and checked the status of the fraudulent claims. Woods also modified UI claims within the MD DOL
online system. Once MD DOL disbursed the UI benefits via pre-paid debit cards, Woods, Smith and
others used various financial transactions, including cash withdrawals at ATMs and point-of-sale
transactions, to obtain the ill-gotten funds.
In total, Woods, Smith and other co-conspirators submitted at least 150 fraudulent UI claim
applications, which resulted in a loss of more than $3.2 million.
This is a joint investigation with the FBI. United States v. Tiia Woods; United States v. Devante Smith
(D. Maryland)
42 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
State of Arizona Employees Convicted and Sentenced for Receiving Bribes to
Approve Jobless Benefits
On February 4, 2025, Jacqueline Espino pled guilty to one count of bribery concerning a program
that receives federal funds. On January 21, 2025, Brandilyn Lorenzen was sentenced to 30 months
in prison and ordered to pay more than $2.9 million in restitution. Both Espino and Lorenzen were
Arizona Department of Economic Security (AZ DES) employees involved in a scheme to accept
bribes in exchange for improperly approving claims for COVID-19 pandemic-related benefits.
Both Espino and Lorenzen were employed by DES as adjudicators who evaluated claims for both the
regular UI and PUA programs. Between 2020 and 2022, when AZ DES was facing a higher volume of
UI and PUA claims due to the COVID-19 pandemic, Espino and Lorenzen accepted bribes to approve
UI and PUA claims for individuals who were not entitled to receive such benefits. In addition, they
both admitted that they embezzled large sums of money from AZ DES for their own benefit and for
the benefit of others.
This is a joint investigation with the DHS-OIG and the AZ DES. United States v. Jacqueline Espino;
United States v. Brandilyn Lorenzen (D. Arizona)
Maryland Defendant Sentenced to More Than 8 Years in Prison for Scheme to
Fraudulently Obtain $1 .9 Million in Unemployment Insurance Benefits
On October 1, 2024, Jonathan Henry was sentenced to 97 months in prison and ordered to pay
restitution of almost $1.9 million for his role in a scheme to fraudulently obtain pandemic-related UI
benefits.
From March 2020 through approximately June 2021, Henry and two other convicted
co-conspirators were inmates at the Federal Correctional Institution in Fort Dix, New Jersey.
Henry and his co-conspirators submitted fraudulent online applications for UI benefits to Maryland
and other states. They used the PII of identity theft victims in many of the applications. Based on
the information provided in the fraudulent applications, the MD DOL issued pre-paid debit cards
in the names of the applicants and mailed them to addresses that the conspirators controlled.
Henry’s co-conspirators then used the pre-paid debit cards to make cash withdrawals at ATMs and
retail purchases.
Henry used the PII of identity theft victims to submit approximately 191 fraudulent claims, primarily
in Maryland, but also in Washington, D.C., Virginia, and North Carolina. Of the fraudulent claims
submitted, 152 were paid, resulting in an actual loss of approximately $1.9 million to the UI program.
This is a joint investigation with the USPIS. United States v. Jonathan Henry et al. (D. Maryland)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 43
Worker and Retiree Benefit Programs
Scranton Man Sentenced to 41 Months in Prison for Scheme to Fraudulently
Obtain Pandemic Benefits
On February 28, 2025, James G. Miller Jr. was sentenced to 41 months in prison and ordered to pay
restitution of more than $1.5 million after he pled guilty to one count of wire fraud.
Between February 2020 and January 2022, Miller assisted co-conspirators in transferring more than
$1.5 million in fraudulently obtained PUA benefits, Lost Wage Assistance payments, and PPP loans
through various bank accounts, cryptocurrency transactions, and mailings. He acted as a money
mule, receiving small sums of money in exchange for using his mailing address and bank accounts to
transfer the fraudulently obtained funds to overseas counterparts.
This is a joint investigation with HSI, the USPIS, the DHS-OIG, and the Social Security
Administration-OIG. United States v. James G. Miller Jr. (M.D. Pennsylvania)
Nigerian Foreign National Sentenced to 4 .5 Years in Prison for Defrauding
Unemployment Program
On January 28, 2025, Fatiu Lawal, a Nigerian foreign national, was sentenced to 54 months in prison
and ordered to pay more than $1.3 million in restitution.
Lawal and co-defendant Sakiru Ambali used the stolen identities of thousands of workers to submit more
than 1,700 claims for pandemic-related UI benefits to more than 25 different states. In total, the claims
sought approximately $25 million in benefits, but the defendants were only able to fraudulently obtain
approximately $2.7 million, primarily from pandemic-related UI programs intended to assist struggling
unemployed American workers. Lawal personally submitted more than $1.3 million in fraudulent claims.
Lawal and Ambali directed the fraud proceeds to cash cards and money mules who transferred the
funds according to instructions from the co-conspirators. They also allegedly used stolen PII to open
bank accounts to collect the fraudulently obtained funds for their personal use.
This is a joint investigation with the FBI, the USPIS, the Washington Employment Security Division,
the IRS-CI, the SBA-OIG, and the U.S. Department of Justice-Office of International Affairs. United
States v. Fatiu Lawal et al. (W.D. Washington)
Former State of Michigan Employee Pled Guilty for Role in Multiple Fraud Schemes
On February 4, 2025, Danielle Moore, a former Michigan Unemployment Insurance Agency (MUIA)
employee, pled guilty to conspiracy to commit wire fraud for her involvement in a COVID-19 pandemic
UI fraud scheme.
44 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
From 2020 through 2021, Moore was employed as a claims examiner with the MUIA. She abused her
access to MUIA records to advance multiple fraud schemes. One scheme involved the filing of fraudulent
UI claims in the names of more than 40 incarcerated individuals. At the direction of her co-conspirator,
Moore took steps to process the fraudulent claims, resulting in the disbursement of approximately
$282,000. She subsequently received a portion of the stolen proceeds from her co-conspirator.
A review of Moore’s cell phone revealed that she possessed the PII and UI claims data for at least
188 individuals. It was later determined that she accessed more than 160 claims and altered more
than 85 of them, resulting in a loss of approximately $1.2 million to the UI program.
In total, Michigan disbursed approximately $1.5 million in fraudulent UI benefits related to claims that
were altered by Moore.
This is a joint investigation with the FBI and the MUIA. United States v. Danielle Moore (E.D. Michigan)
Detroit Man Sentenced to More Than 4 Years in Prison for Involvement in
Multi-State Unemployment Insurance Fraud Scheme
On February 19, 2025, Tracey Dotson was sentenced to 51 months in prison and ordered to pay
more than $930,000 in joint and several restitution for his role in an UI fraud scheme targeting
multiple states.
Between April and December 2020, Dotson and his co-conspirators used stolen PII to file hundreds
of fraudulent UI claims with SWAs in Michigan, Pennsylvania, and Maryland. The defendants
subsequently received hundreds of pre-paid debit cards in the names of other individuals loaded
with approximately $1 million in PUA funds. The debit cards were sent to addresses in Michigan and
Pennsylvania. Dotson and his co-conspirators then withdrew more than $930,000 from the UI debit
cards via cash withdrawals at ATMs and retail purchases.
This is a joint investigation with the FBI, the IRS, and the MUIA. United States v. Dotson et al.
(E.D. Michigan)
Houston Woman Sentenced for $800,000 COVID-19 Fraud Scheme
On January 22, 2025, Prayshana Washington was sentenced to 37 months in prison and ordered to
pay restitution of more than $835,000 for her role in a COVID-19 pandemic UI fraud scheme.
Between May 2020 and June 2021, Washington filed approximately 38 fraudulent claims for UI
benefits using the stolen PII of individuals in Missouri and other states. These individuals were not
eligible to receive enhanced unemployment benefits made available under the CARES Act. She
Semiannual Report to Congress | October 1, 2024–March 31, 2025 45
Worker and Retiree Benefit Programs
carried out the year-long scheme by making repeated false statements to the Missouri Department of
Employment Services.
This was a joint investigation with the DHS-OIG. United States v. Prayshana Washington (W.D. Missouri)
Tuskegee Resident Pleads Guilty to Mail Fraud Conspiracy Related to
Unemployment Fraud Scheme
On January 23, 2025, Brandon Carter pled guilty to one count of mail fraud conspiracy for his role
in submitting fraudulent UI claims to the Alabama Department of Labor (ADOL) which resulted in a
potential loss of more than $800,000.
Between approximately March 2020 and September 2020, Carter and his co-conspirators submitted
fraudulent UI claims to ADOL by using fabricated PII, including dates of birth and Social Security numbers.
As a result, ADOL disbursed UI benefits to him and his co-conspirators, including direct deposits of the
funds into bank accounts they controlled. In addition, UI benefits were also mailed to addresses, including
an abandoned apartment complex, where Carter and his co-conspirators had set up mailboxes to receive
the funds. In total, the scheme caused a loss of more than $800,000 to the UI program.
This is a joint investigation with the USPIS, the Alabama DOT, and the Alabama State Bureau of
Investigations. United States v. Brandon Cody Carter (M.D. Alabama)
Former California Employment Development Department Employee Pled Guilty
in Unemployment Insurance Fraud Scheme
On November 5, 2024, Regina Brice, a former program representative for the California EDD, pled
guilty to mail fraud charges for her role in an UI fraud scheme.
From July 2020 to May 2021, Brice used her insider access at the California EDD to manipulate and
file fraudulent UI claims on behalf of her co-conspirators. As a result, she caused a financial institution
to mail California EDD debit cards loaded with UI benefits to her co-conspirators, who then withdrew
the stolen proceeds. In furtherance of the scheme, Brice instructed her co-conspirators as to how
they could withdraw the proceeds slowly and in such a way that it would not trigger a flag in the UI
system or otherwise lock the account associated with the fraudulent claim. Brice then charged her
co-conspirators thousands of dollars for her help in filing the false UI applications.
Through their scheme, Brice and her co-conspirators caused a loss of more than $800,000.
This is a joint investigation with the California EDD, the DHS-OIG, the USPIS, and the California
Department of Corrections and Rehabilitation. United States v. Regina Brice (S.D. California)
46 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
Former State of California Employee and Boyfriend Convicted of Stealing
Unemployment Benefits
On January 8, 2025, Phyllis Stitt, a former California EDD employee, and her boyfriend, Kenneth
Riley, each pled guilty to one count of conspiracy to commit mail fraud and bank fraud for their roles in
an UI fraud scheme that caused a loss of more than $750,000.
From March 2020 through September 2021, while using her insider access and information available
while working at California EDD, Stitt acquired the names, dates of birth, Social Security numbers,
and other PII of victims. She then filed fraudulent applications for UI benefits using the stolen
PII without the victims’ knowledge or consent. In furtherance of the scheme, Stitt backdated the
fraudulent claims to maximize the amount of UI benefits that would be paid out.
Stitt certified fraudulent applications that stated the victims submitted their employment history and
driver’s license information, and confirmed they were unemployed because of the pandemic and
actively searching for work. Many of the victims were ineligible to receive these benefits, because
they were actively employed or deceased.
As a result of the fraudulent applications, Stitt and Riley received debit cards that were loaded with UI
benefits which were mailed to addresses they controlled. To access the stolen funds, Riley and others
made cash withdrawals, bank transfers, and retail purchases.
Through the scheme, they fraudulently obtained more than $750,000 in UI benefits.
This is a joint investigation with the FBI and the California EDD. United States v. Phyllis Stitt et al.
(C.D. California)
Arkansas Man Sentenced to More Than 4 Years in Prison for Operating an Illegal
Money Transmitting Business Using Pandemic Funds
On February 20, 2025, Richard Stone was sentenced to 51 months in prison and ordered to pay
more than $725,000 in restitution. On November 19, 2024, Stone pled guilty to a criminal information
charging him with conducting an unlicensed money transmitting business in Arkansas.
Stone was the president or chief officer of numerous businesses registered with the Arkansas
Secretary of State. The advertised purpose of these businesses was to develop technology and
facilities to repurpose waste materials, such as tires, into useable fuel sources. However, none of
these businesses were registered with Arkansas as a money transmitting business, as required by
state law.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 47
Worker and Retiree Benefit Programs
Between November 2020 and March 2021, Stone received more than $600,000 in deposits into
various bank accounts associated with the businesses and other accounts under his control. The
deposited funds were from applications made on behalf of unwitting victims for PUA benefits, PPP
loans, and EIDL funds. After receiving the funds, he immediately transferred most of the money by
wire transfer to parties in the United States, Switzerland, England, and India.
This is a joint investigation with the FBI and the IRS-CI. United States v. Richard Stone (W.D. Arkansas)
Two Orlando Men Sentenced for Fraudulently Obtaining More Than $650,000 in
COVID-19 Unemployment Benefits
On January 3 and 6, 2025, respectively, Franklin Luma and Anderson Coulanges were sentenced
after having pled guilty to one count of conspiracy to commit access device fraud and one count of
aggravated identity theft. Coulanges also pled guilty to one count of access device fraud – specifically
the unlawful possession of 15 or more access devices. Coulanges was sentenced to 48 months in
prison, and Luma was sentenced to 36 months in prison. Both men were ordered to pay restitution of
more than $650,000 to the California EDD.
Beginning in approximately August 2020, Coulanges and Luma submitted false UI benefit claims
to the California EDD by using the PII of more than 30 identity theft victims. As a result of the false
claims, the California EDD issued approximately $650,000 in UI benefits on pre-paid debit cards.
Luma maintained images of these debit cards on his cell phone and made cash withdrawals at ATMs
in multiple states.
This is a joint investigation with HSI. United States v. Anderson Coulanges; United States v. Franklin
Luma (S.D. Florida)
Wisconsin Fraudster Sentenced in Unemployment Insurance Fraud Scheme
On November 12, 2024, Marcus Malbro was sentenced to 33 months in prison and ordered to pay
more than $594,000 in restitution for his involvement in a conspiracy to defraud pandemic-related UI
programs in multiple states.
Malbro was a member of the “Wild 100s,” a street gang based in Milwaukee, Wisconsin. The gang
members regularly engaged in various criminal activities, including: violent crime; illegal firearms
possession; drug distribution; conspiracy; and fraud.
Between approximately August 2020 and February 2022, Malbro and other co-conspirators paid a
fee to use the PII of third parties, as well as the PII of identity theft victims, to file fraudulent UI claims
in various states. As a result, several states provided debit cards loaded with fraudulently obtained
48 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
UI funds to the defendants. They then made cash withdrawals from ATMs to purchase, among other
things, firearms, controlled substances, jewelry, clothing, vacations, and to solicit murder for hire.
This is a joint investigation with the FBI and the Bureau of Alcohol, Tobacco, Firearms, and
Explosives. United States v. Ronnell Bowman et al. (E.D. Wisconsin)
New Jersey Man Sentenced to 40 Months in Prison for Stealing COVID-19
Unemployment Benefits
On March 4, 2025, Jose Tavares was sentenced to 40 months in prison and ordered to pay more
than $570,000 in restitution for his role in a conspiracy to fraudulently obtain COVID-19 pandemic UI
benefits. In October 2024, Tavares was convicted of one count of conspiracy to commit wire fraud
after a five-day jury trial.
From July 2020 through February 2021, Tavares and his co-conspirators submitted fraudulent
applications for UI benefits to the New York State Department of Labor (NYSDOL) by using fictitious
online profiles that they created with stolen PII, including the names, dates of birth, and Social
Security numbers of identity theft victims. Once the NYSDOL processed and approved the fraudulent
applications, he and his co-conspirators obtained debit cards loaded with fraudulently obtained
funds totaling more than $570,000. They then used the stolen funds for their personal financial gain,
including vacations, luxury retail purchases, and cosmetic surgeries.
This is a joint investigation with HSI and the USPIS. United States v. Jose Tavares (D. New Jersey)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 49
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.
The Federal Employees' Compensation Act (FECA) program 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.
Special Report Relating to the Federal Employees’ Compensation Act Special
Benefit Fund
The OIG contracted with KPMG LLP (KPMG) to audit the FECA Special Benefit Fund’s Schedule of
Actuarial Liability, Net Intra-Governmental Accounts Receivable, and Benefit Expense Fund as of, and
for the year ended, September 30, 2024. KPMG issued an unmodified opinion, meaning the schedule
was presented fairly in all material respects and in conformity with U.S. generally accepted accounting
principles. KPMG also performed certain tests of controls and compliance with laws and regulations
related to the fund. Its testing of controls found no deficiencies in internal control over financial reporting
that it considered to be significant deficiencies and/or material weaknesses. Its testing of compliance
found no instances of noncompliance or reportable conditions. KPMG also performed agreed-upon
procedures and identified certain differences as a result of performing the procedures over the actuarial
liability and the benefit expense.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/22-25-001-04-431.pdf,
Report No. 22-25-001-04-431 (October 31, 2024).
Texas Pharmacist and Business Partner Both Sentenced to More Than 15 Years
in Prison and Ordered to Forfeit More Than $400 Million in Assets for Defrauding
the Department of Labor
On February 21, 2025, and March 19, 2025, respectively, Texas pharmacy owners Dehshid “David”
Nourian and Christopher Rydberg, were sentenced for their roles in a $145 million scheme to defraud
DOL’s OWCP through the submission of fraudulent claims for prescription compound creams.
Nourian was sentenced to 210 months in prison and Rydberg was sentenced to 180 months in prison.
Both were ordered to pay restitution of more than $115 million jointly and severally. Additionally, the
50 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
court ordered Nourian and Rydberg to forfeit $405 million in assets tied to their fraud and money
laundering schemes.
Nourian, Rydberg, and others conspired to pay doctors to prescribe medically unnecessary compound
creams to injured federal workers. Nourian and others owned and operated three pharmacies located
in Texas. During the scheme, they paid doctors millions of dollars in illegal bribes and kickbacks for
expensive compound medications filled by those pharmacies. For instance, from May 2014 to March
2017, the pharmacies billed OWCP and a private health insurance company more than $145 million
and were paid over $90 million for unnecessary prescriptions that were received in exchange for illegal
bribes and kickbacks.
Trial evidence showed the compound creams were being mixed in the back rooms of the pharmacies by
untrained teenagers at a cost to the defendants of around $15 per prescription and then billed to OWCP
for as much as $16,000 per prescription. Patients who received the creams testified to the creams’
ineffectiveness and that using the creams sometimes resulted in painful, irritating skin rashes.
This is a joint investigation with the USPS-OIG, the U.S. Department of Veterans Affairs (VA)-OIG, and
the IRS-CI. United States v. Dehshid Nourian (N.D. Texas)
Knoxville Nurse Pled Guilty to Home Health Care Fraud Scheme
On November 8, 2024, Lois Hamby pled guilty to one count of health care fraud for her role in
submitting false claims to the DOL-Division of Energy Employees Occupational Illness Compensation
(DEEOIC), which resulted in a loss of more than $480,000 in DEEOIC benefits.
Hamby, who was a licensed practical nurse in Tennessee, had a DOL provider number that allowed her
to submit payment claims directly to DOL. While caring for an approved DEEOIC beneficiary, Hamby
prepared false nursing assessments documenting that she provided nursing services to the beneficiary
in his home when in fact, she had not provided such care. She then used the false assessments to
support fraudulent payment claims. Due to the claims, DOL paid Hamby more than $480,000.
Hamby also provided nursing care to DEEOIC beneficiaries while employed by Camm Care, LLC. She
submitted false nursing assessments claiming she provided in-home nursing services while she was
on vacation, traveling out of state, or otherwise not at the patient’s home. Camm Care used these false
assessments to request and receive payment from DOL.
This is a joint investigation with the FBI. United States v. Lois Hamby (E.D. Tennessee)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 51
Worker and Retiree Benefit Programs
VA Firefighter Pled Guilty in Scheme to Commit Workers' Compensation Fraud
On March 5, 2025, Richard Hyland, a VA firefighter, pled guilty to one count of workers’ compensation
fraud.
In 2014, Hyland suffered a back injury and began receiving federal workers’ compensation benefits
through DOL’s OWCP. To continue receiving benefits, Hyland certified annually to OWCP that he was
not working or volunteering anywhere. However, these certifications were false. As early as March
2017, Hyland worked as a tow truck driver, a long-haul truck driver, and volunteered at his local fire
department. From March 2017 through December 2024, Hyland fraudulently received more than
$479,000 in OWCP benefits.
This is a joint investigation with the VA-OIG. United States v. Richard Hyland (D. New Jersey)
52 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 $14 trillion.
EBSA FACED CHALLENGES ENFORCING COMPLIANCE WITH
MENTAL HEALTH PARITY LAWS AND REQUIREMENTS
Why OIG Conducted the Audit
In accordance with Title I of ERISA, EBSA is responsible for
protecting workers’ access to mental health and substance use
disorder (mental health) benefits. This includes ensuring there
is parity between mental health benefits and medical/surgical
benefits.
EBSA enforces compliance with non-quantitative treatment
limitation (NQTL) laws and requirements. However, in 2022 and
2023, EBSA reported that health plans and health insurance
issuers were unprepared or provided insufficient information
when EBSA requested a comparative analysis for review. EBSA
also raised concerns about the complexity and challenges
involved in its NQTL enforcement work.
Given these concerns, we performed an audit to answer the following question:
To what extent did EBSA enforce compliance with mental health parity NQTL laws and
requirements?
To answer our objective, we reviewed EBSA’s NQTL comparative analysis review data. We also
interviewed staff and surveyed stakeholders nationwide.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 53
Worker and Retiree Benefit Programs
What OIG Found
Our audit identified challenges that limited EBSA’s efforts to enforce compliance with mental health
parity NQTL laws and requirements. Specifically, we found EBSA lacked critical tools to enforce
compliance and deter parity violations, such as the ability to assess civil monetary penalties or bring
actions against all responsible parties. EBSA did not use many of the enforcement tools within its
authority to ensure health plans’ compliance. It also took up to 3 years to complete NQTL comparative
analysis reviews.
Many of these issues occurred because ERISA does not provide EBSA with the authority to assess
and collect civil monetary penalties for parity violations or to bring enforcement actions against
all responsible parties. EBSA also did not use many of its enforcement tools because it did not
have a process to do so, or limitations deterred it from using them. The lack of statutory timeline
requirements and diminishing resources, including staff, contributed to lengthy NQTL comparative
analysis reviews (see Figure 3).
Figure 3: EBSA Frontline Staff Compared to Health Plans Subject to the Mental
Health Parity and Addiction Equity Act
450 2,500,000
404
400 • 376
• 366
• 353
• 338
• 326 2,000,000
• •
350 326
300
1,500,000
250
1,888,461 1,979,322 2,129,516 2,021,808
1,824,585 1,898,298
200
1,608,646
1,000,000
150
100 500,000
50
0 -
FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 FY 2024
Fiscal Year
Number of Health Plans • Number of Frontline Staff
Source: OIG analysis of data provided by EBSA
EBSA’s ability to enforce compliance with NQTL parity rules is diminished, which increases the risk of
plan participants and beneficiaries paying expenses out-of-pocket for mental health treatments that
should have been covered or not receiving these treatments altogether—treatments that are legally
afforded to them.
54 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Worker and Retiree Benefit Programs
What OIG Recommended
We made five recommendations for EBSA to pursue crucial legislative changes to increase authority,
develop a referral process to help levy the excise tax, and provide NQTL guidance. EBSA largely
agreed with and provided corrective actions in response to our five recommendations.
For more information, go to: https://www.oig.dol.gov/public/reports/oa/2025/09-25-001-12-001.pdf,
Report No. 09-25-001-12-001 (February 19, 2025).
Semiannual Report to Congress | October 1, 2024–March 31, 2025 55
Worker Safety, Health,
and Workplace Rights
Occupational Safety and Health
Administration
Mine Safety and Health Administration
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 Sentenced for Making False Statement in Death of
Worker and Tax Crimes
On December 10, 2024, Mauricio Baiense, owner of Contract Framing Builders Inc., was sentenced
to 18 months in prison. He previously pled guilty to making a false statement in a hearing before
DOL’s OSHA and to an employment tax scheme that caused a more than $2 million loss to the IRS.
Baiense was also ordered to pay more than $2.8 million in restitution to the federal government.
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 the
company 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. In order to generate cash for the payroll, Baiense
wrote checks drawn on a company bank account to purported subcontractors, who were entities that
he controlled. He 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 or remit
required employment taxes, causing a loss to the IRS of more than $2.8 million.
This is a joint investigation with DOL-OSHA, the IRS-CI, and HSI. United States v. Mauricio Baiense
(D. Massachusetts)
58 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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
327,000 men and women working in our nation’s mines.
ALERT MEMORANDUM: URGENT CONCERNS FOR MINER SAFETY
AND HEALTH IN AT LEAST THREE U .S . TERRITORIES: MSHA
HAS NEVER CONDUCTED MANDATORY INSPECTIONS AND
CONDUCTED INAPPROPRIATE OVERSIGHT OF MINES IN THE
PACIFIC TERRITORIES
Why OIG Conducted the Audit
The OIG’s long-standing concern about the risks of the MSHA not completing all mandatory mine
inspections was further heightened upon receipt of an April 2024 referral from the Office of Special
Counsel. The referral alleged MSHA had failed to conduct required inspections of mines in the Pacific
Territories and MSHA officials had falsely designated mines in these areas as “abandoned” despite
evidence of ongoing and active operations. We undertook a brief analysis to determine if—and, if so,
why—MSHA was not adequately protecting miners in the Pacific Territories and other locations listed
in the Federal Mine Safety and Health Act of 1977 (Mine Act).
What OIG Found
As alleged, we found MSHA did not conduct mandatory inspections in at least the three Pacific
Territories in which it knew miners were working: American Samoa, Guam, and the Northern Mariana
Islands. For decades spanning numerous administrations, MSHA has failed to sufficiently identify
its own jurisdiction related to mines outside the continental United States. According to MSHA, not
knowing this jurisdiction contributed to its failure to perform any oversight of mines in the Pacific
Territories until 2014. Even with this knowledge, 10 years later, MSHA still has neither sufficiently
identified its jurisdiction nor completed sufficient oversight to protect miners.
In addition, we found MSHA took no action despite knowledge of hazards since at least 2016.
Evidence of hazards at mines in the Pacific Territories had been available to MSHA, including through
MSHA’s public “Accident Injuries” dataset, compliance assistance visit notices, and MSHA escalation
reports. During our interviews, a former MSHA supervisor told us the conditions these miners were
Semiannual Report to Congress | October 1, 2024–March 31, 2025 59
Worker Safety, Health, and Workplace Rights
being subjected to were the worst they had seen in 19 years with MSHA. The former supervisor said
the miners needed MSHA’s help and had asked the MSHA inspectors for help to get a safer and
healthier work environment, but, the former supervisor said, “we abandoned [th]em.”
We also found MSHA personnel engaged in inappropriate and misleading actions, such as changing
mine statuses rather than transparently reporting any issues that led to the lack of mandatory
inspections performed. Importantly, MSHA using incorrect mine statuses for mines or changing them
inappropriately is more than an administrative matter because such actions also enable MSHA to
inaccurately report a 100 percent completion rate for its mandatory mine inspections as it did in
FY 2023. Various stakeholders depend on MSHA reporting, including the U.S. Secretary of Labor,
Congress, and the public. Also, since MSHA has linked mine statuses to the number of required
inspections, it can authorize statuses or status changes that result in an operational mine receiving no
mandatory inspections, thereby ignoring the miners’ safety and health.
MSHA’s actions, or lack thereof, put the safety and health of miners under MSHA jurisdiction at
risk and are inconsistent with MSHA’s mission to prevent death, illness, and injury from mining and
promote safe and healthful workplaces for all miners. According to the Mine Act, Congress declared
“the first priority and concern of all in the coal or other mining industry must be the health and safety
of its most precious resource—the miner.”
What OIG Recommended
We made 11 recommendations to MSHA for urgent oversight of mines in the U.S. territories and
to otherwise enforce the Mine Act to protect miners. Specifically, those recommendations include
identifying and publishing jurisdiction, revising and implementing Mine Act enforcement plans,
verifying employment data, and updating mine statuses.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/05-25-002-06-001.pdf,
Report No. 05-25-002-06-001 (November 12, 2024).
60 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Employment and
Training Programs
Workforce Development Programs
Job Corps
Foreign Labor Certification Programs
Employment and Training Programs
Workforce Development Programs
The Employment and Training Administration (ETA) administers federal workforce development
programs. This includes programs authorized by the Workforce Innovation and Opportunity
Act (WIOA) to help job seekers access employment, education, training, and support services
to succeed in the labor market and to match employers with the skilled workers they need to
compete in the global economy. The WIOA also helps employers hire and retain skilled workers.
ETA NEEDS TO IMPROVE OVERSIGHT OF DISASTER DISLOCATED
WORKER GRANTS
Why OIG Conducted the Audit
Public Law 116-20, Additional Supplemental Appropriations
for Disaster Relief Act, 2019 (Act), provided the ETA with
$50 million for the dislocated workers assistance national
reserve for necessary expenses directly related to the
consequences of multiple natural disasters occurring in 2018
and 2019.
Of the $50 million, $500,000 was transferred to the OIG for
oversight of activities responding to covered disasters or
emergencies. ETA awarded the remaining
$49.5 million in DWGs to 6 grant recipients.
Based on our concerns from prior DWG audits, and in
accordance with the Act, we performed an audit to answer
the following question:
To what extent did ETA properly administer
Public Law 116-20, Additional Supplemental
Appropriations for Disaster Relief Act, 2019, to
provide dislocated worker assistance?
We judgmentally selected a sample of three grant recipients—Florida, Ohio, and North Carolina—and
two sub-recipients from each grant recipient for review.
62 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Employment and Training Programs
What OIG Found
We found ETA needs to improve its oversight of the DWG program. First, DWG recipients generally
did not coordinate with FEMA, and ETA’s failure to facilitate such coordination may have decreased
the effectiveness and timeliness of DWG disaster recovery assistance. Specifically, ETA did not
establish written interagency agreements with FEMA that defined how ETA and grant recipients were
to coordinate with FEMA for disaster recovery.
Second, after awarding the DWG in March 2020, ETA issued guidance to update the documents grant
recipients need to collect and maintain to support eligibility for DWG participants. We found, despite
ETA updating its guidance, Ohio, a grant recipient, still failed to collect the required documentation
to demonstrate participant eligibility. This occurred because: (1) sub-recipients relied on participant
self-certifications for determining eligibility and did not have a system in place to eventually collect
additional documentation necessary to demonstrate each participant’s eligibility, and (2) ETA performed
limited monitoring of participant eligibility. As a result, a grant recipient and its sub-recipients did not
demonstrate they served eligible participants. We questioned costs of $909,240 associated with 30
participants served in Ohio for whom the recipient lacked adequate documentation of eligibility.
Third, a two-week work stoppage at a Florida sub-recipient impacted disaster recovery efforts. The
sub-recipient experienced funding delays due to a 41-day grant modification approval process, which
was not in compliance with the OMB's 30-day requirement to approve or inform the recipient when they
may expect the decision. Lastly, we questioned financial transactions of another Florida sub-recipient
totaling $17,273 charged to the DWG that did not comply with federal requirements.
These issues occurred, in part, because of ETA’s lack of written interagency agreements with FEMA
and lengthy DWG administration processes. Further, ETA had weak controls over DWG recipients’:
(1) coordination with FEMA, (2) documentation of participant eligibility, and (3) use of grant funds.
As a result, we questioned $926,513 in costs. Ensuring the effectiveness and efficiency of the DWG
program is crucial to helping local areas recover from the aftermath of a disaster.
What OIG Recommended
We made eight recommendations to ETA to improve its DWG oversight. Specifically, we
recommended ETA develop written interagency agreements with FEMA, enhance monitoring of
and strengthen guidance for DWG recipients, recover $926,513 in questioned costs, and improve
DWG administration processes to prevent funding delays. ETA agreed or partially agreed with three
recommendations. ETA disagreed with five of the eight recommendations but will take alternative
action to address them.
For more information, go to: https://www.oig.dol.gov/public/reports/oa/2025/02-25-001-03-391.pdf,
Report No. 02-25-001-03-391 (October 24, 2024).
Semiannual Report to Congress | October 1, 2024–March 31, 2025 63
Employment and Training Programs
Job Corps
Administered by ETA, Job Corps is the largest nationwide residential career training program
in the country and has been operating for more than 50 years. The $1.6 billion program helps
eligible young people ages 16 through 24 complete their high school education, trains them
for meaningful careers, and assists them with obtaining employment. Job Corps also provides
transitional support services, such as help finding employment, housing, child care, and
transportation.
JOB CORPS NEEDS TO REVISE HOW IT MEASURES AND REPORTS
ON ITS ACTIVITIES SUPPORTING THE PRESIDENT’S NATIONAL DRUG
CONTROL STRATEGY
Why OIG Conducted the Audit
To ensure the health and safety of Job Corps’ student population and prevent overdose deaths, it is
vital that Job Corps’ drug control activities are effective in maintaining a drug-free environment. In
Program Year 2022, six Job Corps students died of suspected unintentional drug overdoses, including
three on center. In FY 2023, Job Corps requested $6 million for drug control activities, comprising
$0.7 million for student drug testing and $5.3 million for the Trainee Employee Assistance Program
(TEAP), its core drug control activity.41
Since 1999, drug overdoses have killed more than 1 million Americans. The President’s Strategy, released
by President Biden in 2022, is a plan to address addiction and the overdose epidemic. The Office of
National Drug Control Policy (ONDCP) is responsible for implementation of the President’s Strategy
across the federal government, coordinating across 19 agencies—including DOL—and overseeing an
approximately $44 billion budget as part of a whole-of-government approach to address addiction and
the overdose epidemic. Each year, ONDCP is required to publish the National Drug Control Assessment,
an update of the agencies’ progress in achieving the President’s Strategy’s goals and objectives. After
an ONDCP review of FY 2023 data identified three performance measures for which Job Corps reported
inconclusive data, ONDCP requested the OIG conduct an audit. In response to the request, we initiated
a performance audit to determine whether Job Corps was effectively measuring and reporting the
performance of its drug control activities in support of the President’s Strategy.
41 TEAP provides intervention services designed to help students address their substance use issues, if possible,
before starting academic and career technical training coursework in Job Corps. TEAP’s general focus is on
prevention, education, identification of substance use problems, relapse prevention, and supportive services to
enhance students’ health, wellbeing, and access to quality employment.
64 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Employment and Training Programs
What OIG Found
While we found Job Corps’ drug control activities supported the President’s Strategy, Job Corps was
not effectively measuring and reporting the performance of those activities as required by ONDCP.
First, Job Corps has not developed or identified performance measures that accurately reflect the
performance of its activities supporting the President’s Strategy with respect to TEAP. As such,
Job Corps also did not comply with ONDCP’s criteria for evaluating the performance of its drug
control activities. This occurred because Job Corps relied on its mandated Workforce Innovation
and Opportunity Act performance measures, which report overall program outcomes, rather than
developing or identifying appropriate measures to evaluate the specific performance of TEAP.
Second, Job Corps reported untimely data to ONDCP. This occurred because Job Corps chose to
report two performance measures for which data was unavailable in the reporting timeframe required
by ONDCP. Third, Job Corps did not establish targets for three of its four current performance
measures. As a result, Job Corps cannot demonstrate the effectiveness of its drug control activities
nor the extent of its contributions to the President’s Strategy and the overall goal of reducing and
preventing drug use and overdose deaths. In addition to our findings, we also noticed the 2023 and
2024 National Drug Control Assessments contained inaccurate Job Corps information and data.
What OIG Recommended
We made three recommendations to ETA to examine existing Job Corps data regarding its drug
control activities, coordinate with OASAM and ONDCP to establish reporting timelines for any
performance measures that cannot be submitted before the reporting deadline, and establish targets
for all performance measures reported by Job Corps in the National Drug Control Assessment.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/03-25-001-03-370.pdf,
Report No. 03-25-001-03-370 (November 22, 2024).
Semiannual Report to Congress | October 1, 2024–March 31, 2025 65
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, including: 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. 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.
ETA CAN IMPROVE ITS MANAGEMENT OF THE H-2A PROGRAM
Why OIG Conducted the Audit
The ETA Office of Foreign Labor Certification is responsible
for administering DOL’s H-2A Temporary Agricultural
Program, including reviewing applications and issuing
temporary labor certifications. The program allows
agricultural employers who anticipate a shortage of domestic
workers to bring nonimmigrant foreign workers to the United
States (U.S.) to perform agricultural labor or services of a
temporary or seasonal nature.
Based on 20 C.F.R. Part 655 and Departmental regulations
that provide worker protections and employer requirements
concerning wages and working conditions, we performed an
audit to answer the following question:
Did ETA’s management of the H-2A program ensure
employers properly recruited U .S . workers, paid the
prevailing wage, and provided proper housing to
foreign workers?
66 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Employment and Training Programs
What OIG Found
We found, based on our review of sampled H-2A applications, that ETA’s management of the H-2A
program generally ensured applications were in compliance with 20 C.F.R. Part 655 for properly
recruiting U.S. workers, paying the prevailing wages,42 and providing proper housing to foreign
workers. However, improvements can be made to ensure prevailing wages are correctly paid and
sufficient post adjudication reviews are completed.
Our audit found 5 of the 45 (11 percent) certified H-2A applications reviewed were certified with the
incorrect prevailing wage at the time of certification. ETA’s decision to not require the employer to
modify the application to the correct prevailing wage creates the risk that foreign workers may not be
paid correctly and fails to capture the correct wage as part of the certified case file.
Furthermore, our audit concluded that the number of post adjudication audits performed represented
a small portion of the universe of applications certified during the period of January 1, 2022, through
March 31, 2023. While ETA conducts these audits to enhance the integrity of its program, the agency
had not properly updated its formal methodology or process for establishing the number of post
adjudication audits to perform based on a determination of risk.
For the post adjudication audits reviewed, we identified ETA did not obtain sufficient documentation
from employers. In 5 of the 6 (83 percent) post adjudication audits we reviewed, employers did not
provide sufficient documentation to determine whether employees were properly compensated for
wages earned and other expenses.
Additionally, we found analysts did not provide a rationale or evidence to document how they
determined employers’ compliance with program requirements reviewed. ETA has no specific and
standardized guidelines that an analyst must follow. As a result, ETA may face a higher likelihood of
program non-compliance and may be unable to verify if employers properly recruited U.S. workers,
paid the prevailing wage, and provided proper housing to foreign workers.
What OIG Recommended
We made four recommendations to ETA to improve program integrity by enhancing and implementing
written procedures to ensure: (1) H-2A applications have the correct wage information when certified
42 For purposes of this report, the term “prevailing wage” is used to describe the offered wage rate,
which is at or above the highest of these five rates: Adverse Effect Wage Rate (AEWR), a
prevailing wage rate, the agreed-upon collective bargaining wage, the federal minimum wage, the
state minimum wage, or any other wage rate the employer intends to pay.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 67
Employment and Training Programs
by analysts, (2) post adjudication audits target a representative number of applications for the
level of risk in its application process, (3) analysts obtain sufficient evidence of payment of wages
and expenses, and (4) analysts provide a rationale and obtain evidence to document how they
determine employers’ compliance with the program requirements reviewed. ETA agreed with two
recommendations and partially agreed with the other two recommendations. We will monitor ETA’s
corrective action plans to resolve the recommendations.
For more information, go to: https://www.oig.dol.gov/public/reports/oa/2025/06-25-001-03-321.pdf,
Report No. 06-25-001-03-321 (February 25, 2025).
Mexican Nationals Admit Roles in Smuggling and Labor Trafficking Scheme
On October 4, October 24, and November 22, 2024, Porfiria Maribel Ramos Sanchez, Maria Del
Carmen Sanchez Potrero, and Apolinar Francisco Paredes Espinoza pled guilty, respectively, to
charges stemming from their involvement in a scheme to smuggle undocumented workers into
the United States, harbor them at Connecticut residences, and threaten to harm them if they
failed to pay exorbitant fees, interest, and living expenses. Ramos, Sanchez, and Paredes forced
the undocumented individuals to work in circumvention of DOL’s H-2B visa program. As part of
their pleas, they agreed to pay restitution of more than $490,000. On March 7, 2025, Ramos was
sentenced to 36 months in prison and ordered to pay more than $574,000 in restitution.
The defendants arranged to cross the border into the United States with various undocumented
workers for fees of between $15,000 and $20,000 per migrant. In most cases, the undocumented
workers were required to turn over a property deed as collateral before leaving Mexico. After the
undocumented workers arrived in Connecticut, they were told they owed $30,000 plus interest. They
were also forced to pay Ramos, Sanchez, and Paredes for their rent, food, gas, and utilities. The
defendants created false identity documents for the undocumented workers and helped the workers
find employment. In addition to their jobs, some undocumented workers were required to perform—
without compensation or a debt reduction—housework and yardwork. To date, the investigation has
identified 18 trafficked undocumented workers.
This is a joint investigation with the FBI, U.S. Customs and Border Protection, the U.S. Citizenship
and Immigration Services, U.S. Immigration and Customs Enforcement, and the Hartford Police
Department. United States v. Maria Del Carmen Sanchez-Potrero; United States v. Apolinar Francisco
Paredes-Espinoza; United States v. Porfiria Maribel Ramos Sanchez (D. Connecticut)
68 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Employment and Training Programs
Iowa Farmer Sentenced to More Than 15 Years in Cattle Theft, Bankruptcy Fraud,
and Foreign Labor Scheme
On October 10, 2024, Michael Butikofer was sentenced to serve 188 months in prison, pay restitution of
more than $5.7 million, forfeit approximately $500,000, and repay approximately $5,000 in attorney fees.
Between 2018 and 2023, Butikofer was involved in various schemes to defraud several government
programs. The fraud schemes targeted DOL’s H-2A visa program; the U.S. Department of
Agriculture’s (USDA) Packers and Stockyard Act of 1921 (P&S Act) as well as the Coronavirus Food
Assistance Program; and the SBA’s EIDL program.
Butikofer, who operated a large farm in northeast Iowa, employed and recruited H-2A agricultural
workers from South Africa. The H-2A workers raised and cared for cattle owned by investors and
other individuals at Butikofer’s cattle-feeding business. The cattle would subsequently be sold to a
Wisconsin slaughterhouse. At no time was Butikofer or his farm registered with the USDA as a dealer
under the P&S Act.
In 2018, Butikofer used forced labor for his own financial gain. He assaulted workers, pushing one
worker towards a corn auger and tying the hands of another worker with cable ties. In 2020, three
H-2A workers obtained a civil judgment in federal court of approximately $247,000 against Butikofer for
violations of the Fair Labor Standards Act and the Trafficking Victims Protective Reauthorization Act.
Between July 2020 and February 2022, Butikofer converted the proceeds of investor-owned cattle
sales, totaling more than $2.5 million, for his own use. In July 2020 and August 2020, he defrauded
the USDA of more than $1.2 million in emergency assistance funds intended to assist livestock
producers during the COVID-19 pandemic. In February 2022, Butikofer also received more than
$1.5 million from the SBA as part of an EIDL application in which he made false representations
about his financial condition and intended use of the SBA loan funds.
As a part of his plea agreement, Butikofer agreed to voluntarily terminate and cease any current or
future participation in DOL Foreign Labor Certification programs.
This is a joint investigation with HSI, the SBA-OIG, the USDA-OIG, and the Federal Deposit
Insurance Corporation-OIG. United States v. Michael Wayne Butikofer (N.D. Iowa)
Owner of Boston Pizzeria Chain Sentenced to More Than 8 Years in Prison for
Forced Labor and Pled Guilty to Pandemic Loan Fraud
On October 25, 2024, Stavros Papantoniadis was sentenced to 102 months in prison and ordered
to pay a $35,000 fine after being convicted at trial of three counts of forced labor and three counts of
Semiannual Report to Congress | October 1, 2024–March 31, 2025 69
Employment and Training Programs
attempted forced labor. On February 25, 2025, Papantoniadis pled guilty to one count of making false
statements in relation to a fraudulent $500,0000 EIDL he received for a business he no longer owned
or operated.
Papantoniadis, the owner and operator of a pizza restaurant chain in Massachusetts, forced or
attempted to force at least five men and one woman to work for him through violent physical abuse,
threats of abuse, and repeated threats of deportation. He also understaffed his pizza shops 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 workers, Papantoniadis threatened to physically harm them or have them
deported. For example, when he became aware that a worker planned to quit, he violently choked
the worker. In another instance, Papantoniadis chased an employee out of the restaurant and made
a false report to the police to pressure the victim to return to work. Papantoniadis also monitored
workers with surveillance cameras, which he accessed from his cell phone, and constantly
demeaned, insulted, and harassed the victims.
In November 2021, Papantoniadis submitted an EIDL application for a business he had previously
sold. On the application, he requested a loan of more than $986,000. He stated that the business was
a pizza company with 18 employees, which he falsely certified was correct. As such, he received loan
proceeds of almost $500,000.
This is a joint investigation with HSI. United States v. Stavros Papantoniadis (D. Massachusetts)
Massachusetts Men Pled Guilty to Migrant Smuggling Conspiracy and Pandemic
Unemployment Assistance Fraud
On November 14, 2024, Jesse James Moraes and Hugo Giovanni Moraes pled guilty to conspiracy to
encourage and induce an undocumented worker to come to, enter, and reside in the United States for
commercial advantage or private financial gain in circumvention of DOL’s H-2B visa program. Jesse
Moraes also pled guilty to conspiracy for his role in laundering the proceeds of the migrant smuggling
conspiracy. Additionally, on February 13, 2025, Julio Roncaly Morais, a relative of the Moraeses, pled
guilty to one count of making false statements in connection with a PUA claim.
The conspiracy involved the recruitment of undocumented migrants in Brazil to enter the United
States through Mexico for fees of between $12,000 and $22,000 per person. The migrants were
encouraged to make fraudulent claims of asylum as well as familial relationships in the United States.
The migrants were also given fraudulent information about points of contact in the United States to
provide to immigration authorities if they were caught.
70 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Employment and Training Programs
Once migrants were in the United States, Jesse Moraes and Hugo Moraes helped them secure long-term
housing, including apartments owned by Hugo Moraes’ relatives. The defendants also arranged for some
of the migrants to work at restaurants they owned. Jesse Moraes and Hugo Moraes paid the migrants
either entirely or partly in cash until the migrants obtained identification documents, at which point they
would be paid at least in part by check. The defendants encouraged the migrants working for them to
obtain false identification documents and referred them to a co-defendant to obtain such false documents.
The co-conspirators allowed some of the migrants to pay off part of their smuggling fee once they reached
the United States. The smuggling fees were collected via direct payment, by withholding wages, or by
collection by relatives and other associates within and outside the United States.
The money laundering conspiracy, to which Jesse Moraes pled guilty, involved transferring funds
into and out of the United States with the intent to promote the migrant smuggling conspiracy and
conduct financial transactions with the proceeds of the smuggling conspiracy designed to conceal the
ownership and control of the proceeds.
In June 2020, Morais filed a PUA claim in Massachusetts for a co-conspirator who was living in Brazil.
He certified under penalty of perjury that the co-conspirator was a resident of Massachusetts and was
able and available to work. As a result of the claim, the Massachusetts Department of Unemployment
Assistance paid out more than $5,000 in benefits before suspending payments.
This is a joint investigation with HSI, the IRS-CI, and the Woburn Police Department. United States v.
Jesse James Moraes et al.; United States v. Julio Roncaly Morais (D. Massachusetts)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 71
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.
General President of International Union of Operating Engineers Pled Guilty and
Agreed to Resign
On January 29, 2025, James T. Callahan, the former general president of the International Union of
Operating Engineers (IUOE), pled guilty to knowingly filing false annual reports with the DOL. LM-30
annual reports are required by law and must be complete and truthful.
IUOE represents nearly 400,000 heavy machinery operators on construction and industrial sites
throughout the United States and Canada. Starting in 2011, Callahan served as the IUOE General
President at its headquarters in Washington, DC. Between 2015 and 2023, he requested and
received free tickets and hospitality packages to nearly 100 events from an advertising firm retained
by IUOE. The tickets and amenities were worth at least $315,000 and properly belonged to IUOE.
Callahan did not reveal the existence of the tickets and did not obtain IUOE Executive Board
authorization to use them. He personally used many of the tickets and provided other tickets to family
members and other individuals who were not union members.
As part of his plea agreement, Callahan agreed to pay restitution of $315,000 to IUOE for the cost of
the tickets. In addition, he resigned as IUOE General President.
This is a joint investigation with the DOL-OLMS. United States v. James Callahan (D. District of
Columbia)
74 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Departmental
Management
Departmental Management
Single Audits
Departmental Management
Departmental Management
The OIG performs oversight work involving the Department’s operations, financial management,
and IT services.
U.S. Department of Labor’s Purchase and Travel Card Risks Assessed as Very
Low and Low, Respectively
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, 2023, through September 30, 2024, 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 risks43 as of
September 30, 2024, assign a risk impact and risk likelihood level,44 and then assign a risk level
ranging from very low to very high (see Figure 4). For the purchase card program, one objective
had a low risk level and the other five had a very low risk level. For the travel card program, three
objectives had a low risk level and three had a very low risk level.
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.
43 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.
44 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.
76 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Departmental Management
The degradation of an activity or role is moderate with Risk 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 was determined to be very low and low, respectively. 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/2025/22-25-004-50-598.pdf,
Report No. 22-25-004-50-598 (March 25, 2025).
Management Alert Memorandum: The Majority of DOL Nondisclosure
Agreements Do Not Include Required Anti-Gag Language
Upon receipt of a Congressional request, the OIG requested each DOL agency to provide copies
of “all nondisclosure policies, forms, and other agreements” specific to DOL to determine if they
include the anti-gag language required by law.45 The required anti-gag language was codified in the
Whistleblower Protection Enhancement Act of 2012. The OIG reviewed 28 responsive documents
provided by 7 DOL agencies. Based on this review, we determined that the Department was not
in compliance with the Whistleblower Protection Enhancement Act of 2012 because 71 percent of
the responsive nondisclosure agreements the OIG reviewed did not include the required anti-gag
provision.
In 2013, DOL agency heads and all DOL employees received direction from the Office of the
Assistant Secretary for Administration and Management regarding the requirement to add the anti-
gag language to nondisclosure agreements. However, when the OIG requested from 21 separate
DOL agencies “copies of all non-disclosure policies, forms, or other agreements that contain
confidentiality clauses executed since January 1, 2021…that have been signed by DOL employees,”
45 5 U.S.C. § 2302(b)(13)(A)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 77
Departmental Management
only 7 agencies produced responsive documents.46 The OIG reviewed 28 documents,47 and only 8
contained the required language.
The OIG made three recommendations to the Acting Secretary to ensure the required anti-gag
provision is included in all nondisclosure policies, forms, and other agreements, and to rectify the fact
that the anti-gag provision had not consistently been included in NDAs. The Department agreed with
the recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/09-25-0001-MA-01-001.pdf,
Report No. 09-25-0001-MA-01-001 (January 14, 2025).
Management Advisory Comments Identified in an Audit of the Consolidated
Financial Statements for the Year Ended September 30, 2024
In a separate Management Advisory Comments report, KPMG provided additional information to DOL
management on issues identified during the OIG-contracted financial statement audit that did not rise
to the level of significant deficiencies. The additional information represented opportunities for DOL to
improve internal controls or achieve other operating efficiencies. KPMG identified six new comments
and one prior year comment still present in FY 2024. KPMG also noted the closure of three prior year
comments in FY 2024.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/22-25-003-13-001.pdf,
Report No. 22-25-003-13-001 (December 18, 2024).
46 The other agencies informed the OIG they had no documents responsive to the request.
47 The 7 agencies produced a total of 42 discrete documents for review. Of the 42 documents provided to the OIG,
14 were prepared by another federal agency or a private entity and deemed to be not included in the request.
78 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Departmental Management
FY 2024 FISMA DOL INFORMATION SECURITY REPORT: CONTINUED
IMPROVEMENT OF INFORMATION SYSTEM SECURITY PROGRAM
Why OIG Conducted the Audit
Under the Federal Information Security Modernization Act of
2014 (FISMA), the DOL-OIG is required to perform annual
independent evaluations of the Department’s information
security program and practices.
This effort assesses the effectiveness of information security
controls over information resources that support federal
operations and assets, and it also provides a mechanism
for improved oversight of information security programs.
This includes assessing the risk and magnitude of the harm
that could result from unauthorized access, use, disclosure,
disruption, modification, or destruction of such information or
information systems.
We contracted with KPMG to conduct an independent
performance audit on DOL’s FY 2024 information security
program for the period October 1, 2023, through June 30,
2024. To determine the effectiveness of the program, KPMG
evaluated and tested security controls in accordance with
applicable legislation, guidelines, directives, and other documentation.
What OIG Found
DOL’s information security program continues to mature and improve; however, certain Cybersecurity
Framework Functions are preventing DOL from maintaining an effective information security program.
KPMG reported eight findings for DOL’s information security program. The findings were identified in
two of five FISMA Cybersecurity Framework Functions and in four of the nine FISMA Metric Domains.
As a result, DOL’s information security program was determined to be not effective, according to the
Office of Management and Budget’s guidance.
A security program is considered effective if the calculated score of the Cybersecurity Framework
Functions is at least Managed and Measurable (Level 4). However, KPMG found weaknesses that
demonstrated the information security program had not achieved a maturity rating of Managed
and Measurable (Level 4) in three of the five FISMA Cybersecurity Framework Functions: Identify,
Semiannual Report to Congress | October 1, 2024–March 31, 2025 79
Departmental Management
Protect, and Recover. Specifically, KPMG identified deficiencies in the monitoring of DOL cloud
service providers, multi-factor authentication enforcement, security training compliance, and the
implementation of privacy-focused role-based training.
In addition, DOL’s information security program did not fully adhere to applicable FISMA
requirements, Office of Management and Budget policy and guidance, and National Institute of
Standards and Technology (NIST) standards and guidelines. For example, DOL’s system-level
security policies have not been updated to comply with NIST Special Publication 800-53, Revision
5.1, Release 5.1.1, Security and Privacy Controls for Information System and Organization. The
OIG remains concerned that this prior year finding of compliance with the NIST publication remains
outstanding. By not updating DOL’s policies and procedures to be compliant, the Chief Information
Officer is not taking necessary steps in mitigating IT risk for DOL.
What OIG Recommended
KPMG made seven new recommendations to strengthen DOL’s information security program.
KPMG also determined 10 prior year recommendations were closed, 2 remain open, and 7 were not
submitted for closure. DOL management generally concurred with the findings and recommendations;
however, management disagreed with KPMG’s conclusion that DOL’s information security program
was ineffective.
For more information, go to: https://www.oig.dol.gov/public/reports/oa/2025/23-25-002-07-725.pdf,
Report No. 23-25-002-07-725 (December 10, 2024).
FY 2024 Independent Auditor’s Report on the DOL Financial Statements
The OIG contracted with the independent certified public accounting firm of KPMG to audit DOL’s
annual financial statements, which comprise the consolidated financial statements and sustainability
financial statements, as of and for the fiscal year ended September 30, 2024. KPMG concluded that
DOL complied, in all material respects, with the requirements of the Federal Financial Management
Improvement Act of 1996 as of September 30, 2024. However, KPMG issued a qualified opinion on
the consolidated financial statements and identified one material weakness on internal control over
financial reporting.
Also, KPMG found the sustainability financial statements presented fairly, in all material respects,
DOL’s social insurance48 information as of September 30, 2024, 2023, 2022, 2021, and 2020, and
48 Social insurance is defined as income transfer programs financed by compulsory earmarked taxes. DOL
operates the Black Lung Benefits program, which is classified as a social insurance program and is reported in its
sustainability financial statements.
80 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Departmental Management
its changes in social insurance amounts for the years ended September 30, 2024, and 2023, in
accordance with U.S. generally accepted accounting principles.
KPMG issued a qualified opinion because it was unable to obtain sufficient appropriate audit
evidence about the methodology and underlying assumptions used to estimate certain unemployment
insurance balances in FY 2024 and 2023.
In addition, KPMG identified certain deficiencies in internal control that it considered to be a material
weakness and determined improvements were needed in controls over financial reporting related to
unemployment trust fund balances and activity. To address these deficiencies, KPMG provided three
recommendations to the Deputy Chief Financial Officer and the Assistant Secretary for Employment
and Training.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/22-25-002-13-001.pdf,
Report No. 22-25-002-13-001 (November 14, 2024).
DOL CONTINUES TO MAKE PROGRESS TOWARD COMPLIANCE WITH
THE GEOSPATIAL DATA ACT OF 2018
Why OIG Conducted the Audit
The Geospatial Data Act of 2018 (GDA) was signed into law on
October 5, 2018, to foster efficient management of geospatial
data, technologies, and infrastructure through enhanced
coordination among federal, state, local, and tribal governments,
along with the private sector and academia. According to the
GDA, the Inspectors General must complete an audit every 2
years regarding their agencies’ progress toward implementing
GDA requirements. To what extent did OWCP’s DEEOIC
ensure claims followed appropriate guidelines?
To address this mandatory audit requirement, we performed an
audit to answer the following question:
To what extent has the DOL fulfilled the requirements
of the GDA to date?
We assessed the status of DOL’s implementation efforts by
conducting interviews and analyzing evidence provided.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 81
Departmental Management
What OIG Found
DOL made progress in addressing the 13 specific GDA requirements; however, more remains to be
done. Of the 13 requirements, we determined DOL initiated action and made progress on 6 of the
requirements, completed or met 5, and made no progress to date on the remaining 2.
In the following table (see Table 2), the red hexagon means no progress or requirements not met,
the yellow triangle means limited progress or requirements partially met, and the green star means
requirements met.
Table 2: OIG Assessment of DOL’s Implementation of GDA Requirements
Requirement 2020 2022 2024
1. Strategy
2. Support Data Sharing
3. Promote Data Integration
4. Agency Record Schedules
5. Allocation of Resources
6. Use Data Standards
7. Coordination and Partnerships
8. Promote Application of Geospatial Data Assets
9. Protection of Privacy and Confidentiality
10. Declassified Data
11. Non-Duplication of Data
12. Ensuring High-Quality Data
13. Appointment of Contact
Source: OIG analysis from our Fiscal Year 2020, 2022, and 2024 geospatial audits
DOL’s progress in addressing GDA requirements has been impaired by multiple factors. Although
DOL has a geospatial data strategy, the policy was not adequately disseminated to agencies.
Many agencies remained unaware there was a policy, and some did not understand their roles,
responsibilities, and obligations. Furthermore, DOL had an incomplete and inaccurate geospatial
data inventory. DOL also had no plans for long-term funding or allocations for geospatial projects or
to purchase data quality standards. Finally, DOL continued to be hindered by lead agencies’ delays in
providing data standards and regulations needed by covered agencies.
82 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Departmental Management
What OIG Recommended
We made three recommendations to improve DOL’s compliance with the GDA. We recommended the
Chief Data Officer (CDO) create a documented process to improve data accuracy and quality, provide
training to agencies, and create a plan to acquire sufficient funding for GDA work. The CDO agreed
with our recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2025/23-25-001-01-001.pdf,
Report No. 23-25-001-01-001 (October 3, 2024).
Semiannual Report to Congress | October 1, 2024–March 31, 2025 83
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,49 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.50 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 the following QCR: Quality Control
Review for the Single Audit of the Commonwealth of Puerto Rico Department of Labor and Human
Resources for the Fiscal Year Ended June 30, 2022
Quality Control Review for the Single Audit of the Commonwealth of Puerto Rico
Department of Labor and Human Resources for the Fiscal Year Ended
June 30, 2022
We performed a QCR of the independent certified public accounting firm López-Vega, CPA, PSC’s
single audit of the Commonwealth of Puerto Rico Department of Labor and Human Resources for
the fiscal year ended June 30, 2022. Our QCR covered the regular and COVID-19 unemployment
insurance programs and the employment service program cluster, which totaled $1.16 billion of DOL
funds. We determined the audit work of López-Vega, CPA, PSC 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/2025/24-25-001-50-598.pdf,
Report No. 24-25-001-50-598 (January 17, 2025).
49 Uniform Guidance refers to 2 C.F.R. Part 200, OMB’s “Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards.”
50 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).
84 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 internal investigation into allegations that a senior DOL management
official had engaged in misconduct involving the use of their official position for personal gain.
The investigation was referred for prosecution but was declined in lieu of administrative action
within DOL. The senior management official received a counseling memorandum from DOL.
• The OIG conducted an internal investigation on an allegation referred by the Secretary of Labor
and the Office of Special Counsel indicating that a senior DOL management official violated
ethics by purchasing stock in a company that does business with DOL. The investigation
confirmed that the senior management official did own the stock. The final investigative report
was referred to the Secretary of Labor and the Office of Special Counsel.
• The OIG conducted an internal investigation into allegations that a senior DOL management
official had changed information on official documents related to an ongoing OIG audit. The
investigation determined that although the information was altered from the original document,
the information was only condensed and the substance was not changed. No further action was
warranted.
86 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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.”
88 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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—to receive and
respond to whistleblower-related inquiries from DOL employees and employees of DOL
contractors and grantees;
• monitored whistleblower retaliation complaints received by the OIG, as well as whistleblower
retaliation investigations conducted by the OIG; and
• conducted training for various agencies within DOL upon request.
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, October 1, 2024 – March 31, 2025
Investigation Type Number
Pending DOL employee complaint investigations 2
Reports related to DOL employee whistleblower retaliation complaints sent to the
0
appropriate agencies within the Department
Grantee/contractor employee complaints closed after preliminary inquiry 1
Pending grantee/contractor employee complaint investigations 2
Reports pending with DOL 2
Decision issued by the DOL Assistant Secretary for Administration and Management in
1
grantee/contractor employee complaints
Semiannual Report to Congress | October 1, 2024–March 31, 2025 89
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 U.S. Department of Labor’s (DOL or Department) 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 Department’s programs.
The Office of Inspector General, in congressional testimonies and through other means, has
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
The statute of limitations for many of the OIG’s pandemic-related UI fraud investigations is now
starting to expire. Unless Congress acts urgently, the opportunity to extend the statute of limitations
associated with pandemic-related UI fraud will soon be lost entirely. This is our first Semiannual
Report to Congress after the statute has begun to expire, 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
92 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 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 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 UI claimant data and wage records of state workforce agencies (SWA) and
unemployment insurance-administering agencies in U.S. Territories51 for our respective oversight
responsibilities. The Department has stated that—until it revises its existing regulations through notice
and comment 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 the OIG’s ongoing access to UI data.
However, detriments to this approach include potential gaps in data availability given how long
the rulemaking process can take. Furthermore, the OIG is already authorized under the Inspector
General Act of 1978, as amended, to have timely access without constraints to this data and needs
access to all UI program data. Ongoing, timely, and complete access to SWA UI claimant data and
wage records would assist in enabling the OIG to quickly identify large-scale fraud and expand its
current efforts to share emerging fraud trends with the Employment and Training Administration
(ETA) and states to strengthen the UI program and deter fraud. This access would also further assist
the Department in its programmatic oversight responsibilities to identify weak controls and improper
payments in the UI program.
51 Fifty states, as well as the U.S. Virgin Islands, the Commonwealth of Puerto Rico, and the District of Columbia,
administer UI through a SWA. In addition, U.S. Territories that administer UI include American Samoa, the
Commonwealth of the Northern Mariana Islands, the Federated States of Micronesia, Guam, the Marshall Islands,
and the Republic of Palau.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 93
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.52 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 through its independent oversight activities that would help to
improve the timeliness of UI benefit payments and the integrity of the UI program. Furthermore,
ensuring DOL has access to all UI program claimant and wage records would enable the Department
to provide sufficient oversight of the program, establish a data analytics capability at the federal
level, and proactively monitor and analyze UI claims data across states to detect high-risk areas and
emerging fraud trends before they escalate.
In March 2025, the White House released Executive Order 14243, Stopping Waste, Fraud,
and Abuse by Eliminating Information Silos,53 which underscores the current Administration’s
commitment to eliminating barriers that hinder federal oversight efforts. The order emphasizes
that removing unnecessary restrictions on data access and enhancing interagency data sharing
are critical to reducing bureaucratic inefficiencies and strengthening the government’s ability to
detect overpayments and fraud. To support these efforts, the order directs agency heads to take all
necessary steps, to the maximum extent consistent with law, to ensure the federal government has
unfettered access to comprehensive data from all state programs receiving federal funding, including
data maintained in third-party databases where applicable. Ensuring the OIG and DOL have statutory
access to UI claimant data and wage records aligns with this directive and is essential to preventing
fraud, safeguarding program integrity, and strengthening oversight of UI program funds.
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
52 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
53 Executive Order 14243, Stopping Waste, Fraud, and Abuse by Eliminating Information Silos, issued March 20,
2025, available at: https://www.whitehouse.gov/presidential-actions/2025/03/stopping-waste-fraud-and-abuse-by-
eliminating-information-silos/
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Legislative Recommendations
funds would deprive criminals of their ill-gotten proceeds.54 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; the Office of Workers’ Compensation
Programs’ (OWCP) 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) Assets 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. Allowing the OIG to participate in the Treasury
Forfeiture Fund or the DOJ Assets Forfeiture Fund would allow the OIG to better combat UI fraud and
other crimes in the future.
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,55 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 result in savings of more than $3 billion
over the 10-year budget window. These are similar to DOL proposals included in prior DOL budget
requests that would help address UI program integrity and the high improper 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;
54 According to the Federal Bureau of Investigation, “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, “Asset Seizure and Forfeiture: A Basic Guide,” law enforcement bulletin (August 10, 2016),
available at: https://leb.fbi.gov/articles/featured-articles/asset-seizure-and-forfeiture-a-basic-guide
55 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 | October 1, 2024–March 31, 2025 95
Legislative Recommendations
• 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’ administration of UI emergency
program benefit claims after the expiration of programs’ eligibility periods for current and future
temporary emergency benefit programs.
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 MEUC program no
matter when the claim is processed. Funds for this program, like most pandemic-related UI programs,
were appropriated by Congress without fiscal year limitation. Because of this, ETA continues to set
aside pandemic funds to reimburse SWAs for eligible MEUC claims. 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.
96 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Legislative Recommendations
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 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
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 except in limited circumstances, including when an aggrieved person or organization
files a complaint. 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 Employee 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.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 97
Legislative Recommendations
• 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.
• 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 the
income they have earned.
98 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Legislative Recommendations
• 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 OWCP’s FECA reform.
• Allow the temporary suspension of medical providers pending the outcome of criminal
investigations . While FECA regulations allow OWCP to automatically exclude a provider who
has been convicted of fraud from participating in the FECA program, it cannot automatically
suspend payments to a provider who has been criminally indicted for alleged fraudulent billing
practices. OWCP can pursue a government-wide non-procurement suspension, but this process
and the various procedures involved can be lengthy and relies on the Department’s Suspension
and Debarment Official, delaying OWCP’s ability to protect the FECA program from medical
providers alleged to have engaged in fraudulent billing practices. Legislative changes are
necessary to enable DOL to automatically suspend all medical providers who have been indicted
for alleged fraudulent billing practices from providing further medical services and receiving
payments from the program until the indictment is resolved.
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, which lacks 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 | October 1, 2024–March 31, 2025 99
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) 91
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 37-74
Identification of the total number of convictions during the reporting period resulting from
Section 5(a)(4) 129
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 106
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) 111
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 131
(B) a statement identifying the date of the last peer review conducted
continued on next page
102 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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;
129
(11) (C) persons referred to state and local prosecuting authorities; and
(D) indictments and criminal informations that resulted from any prior referral to prosecuting
authorities
Section 5(a)
Metrics used for developing the data for the statistical tables 129
(12)
Summary of investigations of senior government employees where allegations of
Section 5(a)
misconduct were substantiated, including the facts, circumstances, status, and disposition 85
(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 87
(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 131
989(C)
Semiannual Report to Congress | October 1, 2024–March 31, 2025 103
Appendices
Funds Recommended for Better Use
Number Dollar Value
Funds Put to a Better Use Agreed to by DOL56
of Reports ($ millions)
For which no management decision had been made as of the commencement of the reporting
3 $30,970
period
Issued during the reporting period $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 1 $29,580
• 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 2 $1,390
Number Dollar Value
Funds Put to a Better Use Implemented by DOL
of Reports ($ millions)
For which final action had not been taken as of the commencement of the reporting period 3 $44,104
For which management or appeal decisions were made during the reporting period 1 $29,581
Subtotal 4 $73,685
For which management decision was made during the reporting period:
• Dollar value of recommendations that were actually completed
• 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 4 $73,685
56 The term “recommendation that funds be put to better use” means a recommendation by the OIG that funds
could be used more efficiently or achieve greater program effectiveness if management took actions to implement
and complete the recommendation. This term is defined by the Inspector General Act of 1978, as amended, and
includes, among other things, reductions in future outlays; deobligation of funds from programs or operations;
costs not incurred in the future by implementing recommended improvements related to the operations of the
establishment, a contractor, or a grantee; and any other savings specifically identified, including reverting funds to
Treasury to be used for other purposes.
104 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
Questioned Costs
Questioned
Number
Resolution Activity: Questioned Costs57 Costs
of Reports
($ millions)
For which no management decision had been made as of the commencement of the reporting
3 $556
period (as adjusted)
Issued during the reporting period 1 $0.9
Subtotal 4 $557
For which a management decision was made during the reporting period:
• Dollar value of disallowed costs
• Dollar value of costs not disallowed 3 $452
For which no management decision had been made as of the end of the reporting period 1 $105
For which no management decision had been made within six months of issuance 1 $105
Disallowed
Number
Closure Activity: Disallowed Costs58 Costs
of Reports
($ 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 3 $451
Subtotal 6 $624
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 1 $321
• 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 5 $303
57 As defined by the Inspector General Act of 1978, as amended, questioned costs include alleged violations of law,
regulations, contracts, grants, or agreements; costs not supported by adequate documentation; or the expenditure of
funds for an intended purpose that was unnecessary or unreasonable.
58 Disallowed costs are costs that the OIG questioned during an audit as unsupported or unallowable and that the
grant/contracting officer has determined the auditee should repay. The Department is responsible for collecting the
debts established. The amount collected may be less than the amount disallowed, and monies recovered usually
cannot be used to fund other program operations and are returned to Treasury.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 105
Appendices
Final Audit Reports Issued
Management Decision Made by
Number of Recommendations Funds Put To Better Use ($)
Questioned Costs ($)
Report Title; Report Number; Date Issued
End of Reporting Period
Employment and Training Administration
ETA Needs to Improve Oversight of Disaster Dislocated
Worker Grants; 8 $926,513 $0 Yes
Report No. 02-25-001-03-391; 10/24/24
COVID-19: ETA Could Have Done More to Ensure States
Had Sufficient Staffing to Deliver Timely Pandemic
4 $0 $0 No
Unemployment Benefits;
Report No. 19-25-002-03-315; 11/22/24
Job Corps Needs to Revise How It Measures and Reports on
Its Activities Supporting the President’s National Drug Control
3 $0 $0 No
Strategy;
Report No. 03-25-001-03-370; 11/22/24
COVID-19: Data Sharing Project Finds Billions Paid to Same
Likely Fraudsters Under Both the Unemployment Insurance
2 $0 $0 No
and Economic Injury Disaster Loan Programs;
Report No. 19-25-001-03-315; 12/05/24
ETA Can Improve Its Management of the H-2A Program;
4 $0 $0 No
Report No. 06-25-001-03-321; 02/25/25
Total (5 Reports)
Employee Benefits Security Administration
EBSA Faced Challenges Enforcing Compliance with Mental
Health Parity Laws and Requirements; 5 $0 $0 No
Report No. 09-25-001-12-001; 02/19/25
Total (1 Report)
continued on next page
106 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
Mine Safety and Health Administration
Alert Memorandum: Urgent Concerns for Miner Safety
and Health in At Least Three U.S. Territories: MSHA Has
Never Conducted Mandatory Inspections and Conducted 11 $0 $0 No
Inappropriate Oversight of Mine in the Pacific Territories;
Report No. 05-25-002-06-001; 11/12/24
Total (1 Report)
Office of the Assistant Secretary for Administration and Management
FY 2024 FISMA DOL Information Security Report: Continued
Improvement of Information System Security Program; 7 $0 $0 Yes
Report No. 23-25-002-07-725; 12/10/24
U.S. Department of Labor’s Purchase and Travel Card Risk No
Assessed as Very Low and Low, Respectively; 0 $0 $0 Response
Report No. 22-25-004-50-598; 03/25/25 Required
Total (2 Reports)
Office of the Assistant Secretary for Policy
DOL Continues to Make Progress Toward Compliance with
the Geospatial Data Act of 2018; 3 $0 $0 Yes
Report No. 23-25-001-01-001; 10/03/24
Total (1 Report)
Office of the Chief Financial Officer
FY 2024 Independent Auditors’ Report on DOL’s
Consolidated Financial Statements; 3 $0 $0 Yes
Report No. 22-25-002-13-001; 11/14/24
Management Advisory Comments Identified in an Audit of
the Consolidated Financial Statements for the Year Ended
12 $0 $0 Yes
September 30, 2024;
Report No. 22-25-003-13-001; 12/18/24
Total (2 Reports)
Office of the Secretary
Management Alert Memorandum: The Majority of DOL
Nondisclosure Agreements Do Not Include Required Anti-
3 $0 $0 No
Gag Language;
Report No. 09-25-0001-MA-01-001; 01/14/25
Total (1 Report)
continued on next page
Semiannual Report to Congress | October 1, 2024–March 31, 2025 107
Appendices
Office of Workers’ Compensation Programs
Special Report Relating to the Federal Employees’
No
Compensation Act Special Benefit Fund
0 $0 $0 Response
September 30, 2024;
Required
Report No. 22-25-001-04-431; 10/31/24
Total (1 Report)
Final Audit Total (14 Reports) 65 $926,513 $0
Other Reports
Management Decision
Number of
Report Title; Report Number; Date Issued Made by End of
Recommendations
Reporting Period
Employment and Training Programs
Workforce Innovation and Opportunity Act
Quality Control Review of the Single Audit of the Commonwealth of
Puerto Rico Department of Labor and Human Resources for the Fiscal 0 No Response Required
Year Ended June 30, 2022; Report No. 24-25-001-50-598; 01/17/25
Total (1 Report)
Other Reports Total (1 Report) 0
108 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
Unresolved Audit Reports Over 6 Months Old
Number of Unresolved
Questioned
Agency Report Title; Report Number; Date Issued
Recommendations
Costs ($)
Agency Management Decision or Grant/Contracting Officer’s Final Determination Did Not Resolve;
OIG Negotiating with Agency
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: 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 Temporary Unemployment
ETA 1 $105,100,000
Insurance Program;
Report No. 19-23-015-03-315; 09/28/23
ETA Did Not Ensure States Sufficiently Implemented the Mixed Earners
ETA Unemployment Compensation Program; 1 $0
Report No. 19-24-005-03-315; 09/11/24
MSHA Needs to Provide Better Oversight of Emergency Response Plans;
MSHA 2 $0
Report No. 05-7-002-06-001; 03/31/17
COVID-19: MSHA Did Not Complete or Accurately Report
MSHA Mandatory Inspections; 7 $0
Report No. 19-24-001-06-001; 10/17/23
DOL Implemented Its Wireless Network Securely, Through Security Gaps
59
OASAM Exist in Testing, Updating, Patching, and Continuous Review; 2 $0
Report No. 23-24-003-07-720; 09/11/24
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
Agency Management Decision or Grant/Contracting Officer’s Final Determination Not Issued By Close of Period
Total Nonmonetary Recommendations and Questioned Costs 20 $105,100,000
59 This report contains sensitive information, and content was not posted for public viewing.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 109
Appendices
Number of Funds Recommended for
Agency Report Title; Report Number; Date Issued
Better Use ($)
Recommendations
Agency Management Decision or Grant/Contracting Officer’s Final Determination Did Not Resolve;
OIG Negotiating with Agency
Alert Memorandum: 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 2 $1,392,304,646
Total Audit Exceptions and Questioned Costs 20 $105,100,000
Total Funds Recommended for Better Use 2 $1,392,304,646
Total Audit Exceptions, Questioned Costs, and Funds Recommended for Better Use 22 $1,497,404,646
110 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
Management Decision Made During this
Reporting Period on Audits, Inspections,
or Evaluations Issued during a Previous
Reporting Period: Final Audit Reports Issued
Number of Recommendations
Management Decision Made
Funds Put to Better Use ($)
Questioned Costs ($)
Report Title; Report Number; Date Issued
on Previously Issued Audits
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 Yes
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 Training, Though
No Response
Opportunities to Strengthen Controls Exist; 0 $0 $0
Required
Report No. 19-24-004-06-001; 09/12/24
Total (1 Report)
continued on next page
Semiannual Report to Congress | October 1, 2024–March 31, 2025 111
Appendices
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)
Office of the Assistant Secretary for Administration and Management
U.S. Department of Labor’s Purchase and Travel Card Risks Assessed as Low; No Response
0 $0 $0
Report No. 22-24-006-50-598; 04/18/24 Required
DOL Implemented Its Wireless Network Securely, Through Security Gaps
60
Exist in Testing, Updating, Patching, and Continuous Review; 4 $0 $0 Yes
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 Information Act for Fiscal Year 2023; 3 $0 $0 Yes
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 September 30, 2023 and 2022; 1 $0 $0 Yes
Report No. 22-24-008-04-432; 07/17/24
District of Columbia Workmen’s Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report September 30, 2023 and 2022; 1 $0 $0 Yes
Report No. 22-24-009-04-432; 07/17/24
continued on next page
60 This report contains sensitive information, and content was not posted for public viewing.
112 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
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 Employees’ Compensation
61
System and Service Auditors’ Report on the Optum Workers’ Compensation
No Response
and Auto No-Fault’s Retail Pharmacy Network Services System; and Service 0 $0 $0
Required
Auditors’ Report on the U.S. 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
61 This report contains sensitive information, and content was not posted for public viewing.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 113
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 of the Single Audit of the Chicago Cook
No Response
Workforce Partnership for the Year Ended June 30, 2022; 0
Required
Report No. 24-24-003-50-598; 05/16/24
Quality Control Review of the Single Audit of Job Service North Dakota
No Response
for the Year Ended June 30, 2023; 0
Required
Report No. 24-24-004-50-598; 06/26/24
Quality Control Review for the Single Audit of the County of Greenville,
No Response
South Carolina for the Fiscal Year Ended June 30, 2023; 0
Required
Report No. 24-24-005-50-598; 09/04/24
Total (3 Reports)
Other Reports Total (3 Reports) 0
114 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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.
MSHA Can Improve Its Pre-Assessment Conferencing Program;
Report No . 05-19-001-06-001; 09/23/19
During an inspection, MSHA can issue violations to mine operators that can be challenged in court. To
help avoid the court system, MSHA created a pre-assessment conferencing program allowing operators
an opportunity to present evidence to MSHA challenging a violation in an informal setting to reach
a conference decision that modifies or vacates the violation. The OIG had received several hotline
complaints alleging that the conferencing program was not working as intended. Our audit found MSHA
did not consistently document specific reasons for conference decisions in which it modified or vacated
a violation, and it did not consistently provide feedback to its inspectors regarding conference decisions.
In response to our audit, MSHA transitioned the conferencing program to a system documentation
process that requires personnel to document the reason for a modified, vacated, or upheld decision. In
addition, MSHA updated its guidance instructing personnel to provide feedback in a non-judgmental or
accusatory manner when discussing modified or vacated violations with inspectors. Finally, the Office
of the Solicitor provided training to MSHA personnel on how to improve communications with inspectors
when providing feedback on conference decisions.
MSHA Can Improve How Violations Are Issued, Terminated, Modified, and
Vacated; Report No . 05-21-002-06-001; 03/31/21
MSHA inspects mines to ensure they are safe for miners. The Federal Mine Safety and Health Act
(Mine Act) gives MSHA the authority to issue notices, safeguards, citations, and orders (“violations”
is the blanket term used by MSHA) to mine operators who do not comply with the health and safety
standards or the Mine Act. Our audit found thousands of violations written by MSHA inspectors did
not comply with the Mine Act and MSHA Handbook requirements. Errors make violations subject to
court challenges and inaccurate penalty assessments and can jeopardize miner safety.
In response to our audit, MSHA provided refresher training to inspectors addressing issues
identified during the audit. In addition, MSHA provided a handout to the inspectors to aid in their
comprehension.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 115
Appendices
OWCP Did Not Ensure Best Prices and Allowed Inappropriate, Potentially Lethal
Prescriptions in the FECA Program; Report No . 03-23-001-04-431; 03/31/23
OWCP provides workers’ compensation coverage to approximately 2.6 million federal and
postal workers through the FECA program. Our audit found OWCP did not effectively manage
pharmaceutical spending in the FECA program from FY 2015 through FY 2020. OWCP paid
significantly higher prices for certain prescription drugs because it did not have a process to ensure
its pricing was competitive with other comparable payers in the industry. In addition, OWCP did
not take advantage of manufacturer rebates even though this could have resulted in substantial
savings. By failing to ensure competitive pricing in the FECA pharmaceutical program, we found
OWCP did not realize up to $321.26 million in savings of taxpayer dollars during the audit period.
We also found OWCP did not ensure policy changes were implemented as intended, failed to
timely identify and address emerging issues, and lacked sufficient clinical expertise and guidelines
to ensure appropriate pharmaceutical decisions.
In response to our audit, OWCP performed an analysis of pricing methodologies used by other
government entities that pay pharmacy benefits. The resulting “Medication Pricing Strategy
Analysis” report outlined OWCP’s findings and included recommendations for the pricing policy to
be used for the next pharmacy benefit manager contract (scheduled for award in FY 2025). The
recommendations included discounting its pricing benchmark by a certain percentage necessary to
approximate National Average Drug Acquisition Cost pricing; using a pass-through pricing structure
where the government pays the pharmacy benefit manager the direct drug cost paid to the
pharmacy plus a service fee; collecting rebates as “locked dollar” amounts per transaction at the
point of sale; and including contract incentives such as a premium on generic drug prices in return
for improvements in clinical outcomes and program administration.
OWCP established procedures to perform a pricing strategy review at least 12 months before the
start of the procurement process for a new pharmacy benefit manager contract, or every 4 years,
whichever is less. As part of this review, OWCP will evaluate pricing benchmarks to assess their
suitability for subsequent pharmacy benefit manager contracts. It will also examine how rebates are
being incorporated into pricing strategies by industry and other government entities.
Additionally, OWCP is performing post-implementation reviews to ensure policy changes are
working as intended and reviewing pharmaceutical data to identify issues with drug utilization, drug
trends and outliers, and pricing. OWCP has also replaced its treatment suites with a formulary
based on nationally recognized guidelines; expanded the number of clinical staff in OWCP; and
established a team of physicians, pharmacists, and data scientists responsible for developing policy
and providing oversight of the FECA pharmaceutical program.
116 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
Unimplemented Recommendations
During this reporting period, there were 5 instances of audits or evaluations provided to the
Department for comments that were not responded to within 60 days. We are still yet to receive
management decisions in response to these audits and evaluations at the commencement of this
reporting period.
From October 1, 2014, through September 30, 2024, the OIG made 1,143 audit recommendations,
of which 128 have not been fully implemented. These 128 recommendations include 106
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 OCTOBER 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 0 $0
2017 112 7 $0
2018 98 1 $0
2019 84 6 $0
2020 105 7 $0
2021 133 26 $39,155,643,774
2022 67 10 $29,581,490,253
2023 93 38 $6,618,808,321
2024 60 32 $129,565,581
Total 1,143 128 $75,485,507,929
Semiannual Report to Congress | October 1, 2024–March 31, 2025 117
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 Issue guidance directing states to provide access to state UI claimant data to
to Unemployment Compensation Under the prevent and detect fraud.
CARES Act;
Report No. 19-20-008-03-315; 08/07/20
Alert Memorandum: The Employment and Establish effective controls, in collaboration with SWAs, to mitigate fraud and
Training Administration (ETA) Needs to Ensure other improper payments to ineligible claimants, including the areas identified
State Workforce Agencies (SWA) Implement in the memorandum: UI benefits paid to multistate claimants, claimants who
Effective Unemployment Insurance Program used the Social Security numbers of deceased individuals, potentially ineligible
Fraud Controls 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 Continue to work with states to develop, operate, and maintain a modular
CARES 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 Amend 20 C.F.R. 603.5 and 603.6(a) through the rulemaking process
Training Administration Needs to Issue Guidance to reinforce that UI information must be provided to DOL-OIG for all IG
to Ensure State Workforce Agencies Provide engagements authorized under the IG Act, including audits, evaluations, and
Requested Unemployment Insurance Data to the investigations.
Office of 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
118 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 Obtain evidence from the states that ensures all EURGENO refunds and
Governmental Entities and Nonprofit credits to which reimbursing employers are entitled have been provided;
Organizations Should Have Been Better Work with states to reconcile remaining balances;
Managed; Determine the proper disposition of excess funds and take necessary actions,
Report No. 19-23-010-03-315; 09/21/23 including the recovery of questioned costs.
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;
the Unemployment Insurance Program; Create an integrity program that incorporates a data analytics capability and
Report No. 19-23-012-03-315; 09/25/23 regularly monitors state unemployment insurance claims 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 Work with Oregon, Louisiana, Delaware, and Mississippi to ensure the appropriate
and Return to the U.S. Treasury Nearly $5 return of approximately $105.1 million in TFFF reimbursements for first-week
Billion Unused by States for a Temporary regular UI compensation paid that were associated with ineligible weeks;
Unemployment Insurance Program; Establish a deadline by which states are required to perform a timely
Report No. 19-23-015-03-315; 09/28/23 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
Questioned Costs; ensure states meet requirements for similar future temporary unemployment
Report No. 19-24-003-03-315; 06/26/24 insurance 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 | October 1, 2024–March 31, 2025 119
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.
ETA Needs to Improve Oversight of Recover costs of $909,240 for participants served that lacked adequate
Disaster Dislocated Worker Grants; documentation to support eligibility.
Report No. 02-25-001-03-391; 10/24/24
COVID-19: ETA Could Have Done More to Develop performance standards for prompt payment of UI benefits under
Ensure States Had Sufficient Staffing to Deliver temporary UI programs using lessons learned from the pandemic;
Timely Pandemic Unemployment Benefits; Establish policy that requires officials to issue guidance timely for ETA regional
Report No. 19-25-002-03-315; 11/22/24 offices to monitor and measure the effectiveness of states’ use of staffing to
support the implementation of temporary UI programs;
Establish policy that requires states to develop corrective action plans to address
staffing insufficiencies that negatively impact permanent and temporary UI
programs, as identified by regional offices during monitoring reviews;
Establish policy that requires ETA officials to develop a business case analysis
and supporting justification when considering suspension of any UI program
integrity functions.
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
Alert Memorandum: Urgent Concerns for Clearly identify and publicly publish MSHA’s jurisdiction, including obtaining any
Miner Safety and Health in At Least Three needed legal opinion from the U.S. Department of Labor Office of the Solicitor
U.S. Territories: MSHA Has Never Conducted on the U.S. territories and the Federated States of Micronesia, the Republic
Mandatory Inspections and Conducted of the Marshall Islands, and the Republic of Palau, requesting any needed
Inappropriate Oversight of Mines in the Pacific legislative changes;
Territories; Revise MSHA’s implementation plan for when it will begin inspecting mines
Report Number: 05-25-002-06-001; 11/12/24 within American Samoa, Guam, and the Commonwealth of the Northern
Mariana Islands and begin implementing the plan. The revised plan should
address: (1) when enforcement of the Mine Act and MSHA regulations will
begin; (2) how inspections will occur in future years (e.g., travel from a specific
MSHA district or setting up a field office nearby); (3) whether additional training
will occur and how (e.g., in-person, virtual, hybrid, via grants, et cetera); and (4)
how funding will be obtained to conduct required MSHA activities in FY 2025;
Develop and implement a plan to enforce the Mine Act in the Federated
States of Micronesia, the Republic of the Marshall Islands, and the Republic
of Palau, having first obtained legal authority verifying they are still under
MSHA’s jurisdiction. If the legal authority opines MSHA has jurisdiction over
them, MSHA’s plan should address: (1) whether future legislative changes to
the Mine Act are needed and requests to Congress; (2) when enforcement of
the Mine Act and MSHA regulations will begin; (3) how inspections will occur in
future years (e.g., travel from a specific MSHA district or setting up a field office
nearby); (4) whether additional training will occur and how (e.g., in-person,
virtual, hybrid, via grants, et cetera); and (5) how funding will be obtained to
conduct MSHA activities in FY 2025 and beyond.
continued on next page
120 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
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
Report No. 19-22-003-10-105; 03/31/22 and (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 memoranda 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 Compliance Safety and Health Officers (CSHO) 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
Referrals for Increased Worker Safety; interviews of complainants and witnesses or document the rationale for lack
Report No. 02-23-001-10-105; 03/06/23 thereof and provide training to CSHOs 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 to
complete and periodically monitor progress toward those goals. Ensure the
goals contain metrics that demonstrate the outcomes of the program.
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
OLMS Can Do More to Protect Workers’ Rights Outline requirements needed to strengthen enforcement authority to align
to Unionize Through Enforcing Persuader Activity with the Labor-Management Reporting and Disclosure Act of 1959’s intentions
Disclosure; to protect workers’ rights and interests to unionize by recommending
Report No. 09-24-002-16-001; 05/03/24 rule changes or legislative changes to increase employer and consultant
compliance.
continued on next page
Semiannual Report to Congress | October 1, 2024–March 31, 2025 121
Appendices
Departmental Management
FY 2019 FISMA DOL Information Security Implement improvements in DOL’s information security program for the
Report: Implementation of Security Tools following areas: configuration management and access control technologies.
Hindered by 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 Implement a process for approving deviations from established configuration
Report: Progress Needed to Improve Risk settings.
Management and Continuous Monitoring
Information Security Controls;
Report No. 23-21-001-07-725; 12/22/20
DOL’s IT Governance Lacked the Framework Ensure the Chief Information Officer is a lead member with voting rights of
Necessary to Support the Overall Mission; DOL’s executive strategy and management boards and committees, including
Report No. 23-21-002-01-001; 09/30/21 but not limited to the Management Review Board, Enterprise Shared Services
Governance Board, COVID-19 Coordination team, and Enterprise Risk
Management Council.
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 National Institute of Standards and Technology Special
Remaining Current with Security Requirements; Publication 800-53, Revision 5;
Report No. 23-23-001-07-725; 02/10/23 Implement data loss prevention tools and alerts based on the results of
agencies’ data exfiltration tests.
Management Alert Memorandum: The Majority of Send an updated memorandum to all DOL agency heads reminding them of
DOL Nondisclosure Agreements Do Not Include the requirement to include the anti-gag provision in all nondisclosure forms,
Required Anti-Gag Language; agreements, and related documents;
Report No. 09-25-0001-MA-01; 01/14/25 Send an email to all DOL employees providing the required anti-gag language
and informing all DOL employees that such language should be read as
incorporated into any nondisclosure agreement (an agreement requiring an
employee not to disclose certain governmental information) they may have
signed since November 27, 2012, that did not include the required language;
Revise all existing nondisclosure agreement forms or templates to include the
required anti-gag language.
122 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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
1 $5,409,966,198
improper 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
Semiannual Report to Congress | October 1, 2024–March 31, 2025 123
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.62
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
62 To date, ETA has completed the reconciliation process in accordance with Unemployment Insurance Program
Letter No. 20-20, Change 1, for 16 states and facilitated the return of $1,412,852,802.35. This recommendation will
be closed once reconciliation is completed for the remaining 37 states, and the funds returned.
124 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 March 31, 2025). For identification
of each recommendation made before March 31, 2025, 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;
2 $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
Semiannual Report to Congress | October 1, 2024–March 31, 2025 125
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
Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments
in High-Risk Areas Increased to $45.6 Billion; 2 $0
Report No. 19-22-005-03-315; 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
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
1 $0
UI 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; 4 $7,165,040
Report No. 19-23-016-03-391; 09/28/23
COVID-19: ETA’s Oversight of Short-Time Compensation Did Not Detect $129.6
3 $129,565,581
Million in Questioned Costs; Report No. 19-24-003-03-315; 06/26/24
ETA Did Not Ensure States Sufficiently Implemented the Mixed Earners
4 $0
Unemployment Compensation Program; Report No. 19-24-005-03-315; 09/11/24
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
continued on next page
126 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
MSHA Can Improve Its Pre-Assessment Conferencing Program;
6 $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
7 $0
Vacated; Report No. 05-21-002-06-001; 03/31/21
COVID-19: MSHA Did Not Complete or Accurately Report Mandatory
9 $0
Inspections; Report No. 19-24-001-06-001; 10/17/23
Office of the Assistant Secretary for Administration and Management
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; 2 $0
Report No. 23-24-002-07-725; 11/17/23
DOL Implemented Its Wireless Network Securely, Though Security Gaps Exist in
Testing, Updating, Patching, and Continuous Review; 4 $0
Report No. 23-24-003-07-720; 09/11/24
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
The U.S. Department of Labor Did Not Meet the Requirements for Compliance
with the Payment Integrity Information Act for FY 2023; 3 $0
Report No. 22-24-007-13-001; 05/29/24
Longshore and Harbor Workers’ Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report September 30, 2023 and 2022; 1 $0
Report No. 22-24-008-04-432; 07/17/24
District of Columbia Workmen’s Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report September 30, 2023 and 2022; 1 $0
Report No. 22-24-009-04-432; 07/17/24
continued on next page
Semiannual Report to Congress | October 1, 2024–March 31, 2025 127
Appendices
Office of Labor-Management Standards
OLMS Can Do More to Protect Workers’ Rights to Unionize Through Enforcing
3 $0
Persuader Activity Disclosure; Report No. 09-24-002-16-001; 05/03/24
Office of the Secretary
DOL’s IT Governance Lacked the Framework Necessary to Support the Overall
1 $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 Program to Better Protect Workers; 1 $0
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 Warehouse
6 $0
Workers; Report No. 19-23-013-10-105; 09/27/23
Wage and Hour Division
COVID-19: The Pandemic Highlighted the Need to Strengthen Wage and Hour
1 $0
Division’s Enforcement Controls; Report No. 19-21-008-15-001; 09/30/21
Totals 122 $407,258,250
128 Semiannual Report to Congress | October 1, 2024–March 31, 2025
Appendices
Investigative Statistics
Division
Total
Totals
Investigative Reports Issued / Cases Closed (includes investigative reports issued, case closing
131
reports, and matters referred for possible civil and/or administrative action):
Program Fraud 121
Labor Racketeering 10
Cases Opened: 102
Program Fraud 99
Labor Racketeering 3
Cases Referred for Prosecution (each case is measured as a singular statistic and may include more
64
than one person or business entity):
Program Fraud 62
Labor Racketeering 2
Cases Referred for Administrative/Civil Action (each case is measured as a singular statistic and
59
may include more than one person or business entity):
Program Fraud 57
Labor Racketeering 2
Persons Referred to the Department of Justice for Criminal Prosecution (includes the number of
94
individuals and business entities referred for prosecution):
Program Fraud 93
Labor Racketeering 1
Persons Referred to State and Local Prosecuting Authorities for Criminal Prosecution (includes
6
the number of individuals and business entities referred for prosecution):
Program Fraud 5
Labor Racketeering 1
Indictments and Criminal Informations That Resulted from Any Prior Referral to Prosecuting
202
Authorities (includes sealed and unsealed indictments):
Program Fraud 190
Labor Racketeering 12
Indictments (includes sealed and unsealed indictments): 202
Program Fraud 190
Labor Racketeering 12
Convictions: 287
Program Fraud 272
Labor Racketeering 15
Statutory Debarments: 2
Program Fraud 2
Labor Racketeering 0
continued on next page
Semiannual Report to Congress | October 1, 2024–March 31, 2025 129
Appendices
Recoveries, Cost-Efficiencies, Restitutions, Fines/Penalties,
$185,948,517.50
Forfeitures, and Civil Monetary Actions:
Program Fraud $184,748,446.13
Labor Racketeering $1,200,071.37
Recoveries (the dollar amount/value of an agency’s action to recover or to reprogram
$12,712,971.48
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 $1,965,727.84
more efficiently):
Restitutions/Forfeitures (the dollar amount/value of restitutions and forfeitures
$167,771,720.59
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,
$3,498,097.59
judgments, court costs, and other penalties resulting from OIG criminal investigations):
Total $185,948,517 .50
130 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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-OIG 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 DOL-OIG
received a clean report with a rating of pass with no recommendations.
Semiannual Report to Congress | October 1, 2024–March 31, 2025 131
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.
132 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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 October 1, 2024,
through March 31, 2025, a total of 1,556 complaints were opened in the OIG Hotline’s complaint
management system.
Complaints Received (complaints opened by method reported): Totals
Telephone 0
E-mail/Internet 1,506
Mail 50
Fax 0
Walk-In 0
Total 1,556
Contacts Received (complaints opened by source): Totals
Complaints from Individuals or Non-Governmental Organizations 909
Complaints/Inquiries from Congress 3
Referrals from GAO 0
Complaints from Other DOL Agencies 13
Complaints from Other (non-DOL) Government Agencies 631
Total 1,556
Disposition of Complaints Reviewed and Processed: Totals
Referred to OIG Components for Further Review and/or Action 142
Referred to DOL Program Management for Further Review and/or Action 141
Referred to Non-DOL Agencies/Organizations 82
No Referral Required/Informational Contact 1,074
Total 1,439
Semiannual Report to Congress | October 1, 2024–March 31, 2025 133
Appendices
Acronyms and Abbreviations
AI Artificial Intelligence FLC Foreign Labor Certification PEUC Pandemic Emergency
CARES Act FY Fiscal Year/fiscal year Unemployment
Coronavirus Aid, Relief, and Compensation
GDA Geospatial Data Act of 2018
Economic Security Act PII personally identifiable
GenTech information
CIO Chief Information Officer GenTech Associates, Inc.
DEEOIC Division of Energy PUA Pandemic Unemployment
H-1B visa program for workers in Assistance
Employees Occupational specialty occupations
Illness Compensation PPP Paycheck Protection
H-2A visa program for Program
Department or DOL agricultural workers
U.S. Department of Labor SBA Small Business
H-2B visa program for Administration
DHS U.S. Department of non-agricultural
Homeland Security workers SWA State Workforce Agency
DOJ U.S. Department of Justice HHS U.S. Department of Health TEAP Trainee Employee
DWG Dislocated Worker Grants and Human Services Assistance Program
EBSA Employee Benefits Security HSI Homeland Security TFFF Temporary Full Federal
Administration Investigations Funding of the First Week
of Compensable Regular
EDD Employment Development IRS Internal Revenue Service Unemployment for States
Department IT information technology with No Waiting Week
EIDL Economic Injury Disaster KPMG KPMG LLP Treasury
Loan U.S. Department of the
MSHA Mine Safety and Health
Energy Energy Employees Treasury
Administration
Occupational Illness TSP Thrift Savings Plan
Compensation Program NLRB National Labor Relations
Board UI unemployment insurance
ERISA Employment Retirement
Income Security Act of 1974 NQTL non-quantitative treatment USDA U.S. Department of
limitation Agriculture
ETA Employment and Training
Administration OASAM Office of the Assistant USPIS United States Postal
Secretary for Administration Inspection Service
EURGENO and Management
Emergency Unemployment USPS United States Postal
Relief for Governmental OIG Office of Inspector General Service
Entities and Nonprofit OLMS Office of Labor- VA U.S. Department of
Organizations Management Standards Veterans Affairs
FBI Federal Bureau of ONDCP Office of National Drug WHD Wage and Hour Division
Investigation Control Policy WIOA Workforce Innovation and
FECA Federal Employees’ OSHA Occupational Safety and Opportunity Act
Compensation Act Health Administration WHD Wage and Hour Division
FEMA Federal Emergency OWCP Office of Workers’ WIOA Workforce Innovation and
Management Agency Compensation Programs Opportunity Act
FISMA Federal Information PERM permanent employment
Security Management certification program
134 Semiannual Report to Congress | October 1, 2024–March 31, 2025
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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