Semiannual Report to Congress, Office of Inspector General for the U.S. Department of Labor, Volume 91 (October 1, 2023–March 31, 2024)
Summary
Volume 91 of the Department of Labor Office of Inspector General's Semiannual Report to Congress covers October 1, 2023 to March 31, 2024. Inspector General Larry D. Turner writes that lower appropriations for FY 2023 and FY 2024 and the depletion of supplemental pandemic oversight funds forced the OIG to wind down pandemic oversight, including canceling 10 pandemic-related audits in FY 2023 and halting new pandemic UI fraud investigations. The message notes that the statute of limitations for many pandemic UI fraud cases will begin to expire in early 2025. In the period the OIG issued 12 audit reports with 33 recommendations, among them that the Mine Safety and Health Administration did not complete an estimated 1,589 mandatory inspections, and reports 275 indictments and 242 convictions.
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Volume 91 October 1, 2023–March 31, 2024
Semiannual Report
to Congress
Office of Inspector General for the U.S. Department of Labor
A Message from the Inspector General
I am pleased to submit our Semiannual Report to
Congress summarizing the activities of the U.S.
Department of Labor (DOL or Department), Office of
Inspector General (OIG), for the 6-month period ending
March 31, 2024.
As reflected in our semiannual report, my office continues
to highlight the major issues facing DOL identified through
the OIG’s independent audits and investigations. The
OIG remains committed to conducting independent and
objective oversight to improve DOL programs relied upon
by millions of Americans.
The OIG has pivoted our post-pandemic oversight
to focus on priority areas such as: (1) worker benefit
programs, including unemployment insurance (UI) and
workers’ compensation; (2) worker safety and health, including occupational and miner
safety and health and workplace rights; and (3) employment and training programs, including
grants and the Job Corps program. However, the integrity of DOL’s UI program continues to
be threatened by ongoing fraudulent activity and programmatic weaknesses that preceded
and were exacerbated by the pandemic.
Resource Limitations
Current resource limitations have hampered the OIG’s ability to meet our core mission
while also addressing the challenges that remain with pandemic-related oversight.
Lower-than-expected appropriation levels for Fiscal Year (FY) 2023 and FY 2024, along
with the depletion of supplemental pandemic oversight funds in FY 2024, has resulted
in insufficient funding necessary to conduct oversight work of pandemic-related DOL
programs and operations at the same level we have in the past. As a result, the OIG has
been forced to wind down its pandemic oversight work.
In FY 2023, the OIG addressed the funding shortfall by, among other actions, implementing
a hiring freeze and canceling 10 pandemic-related audits. We are taking additional actions
in FY 2024, including halting the initiation of new pandemic UI fraud investigations,
refocusing our pandemic-related UI proactive fraud data analytics program, and canceling
certain pandemic-related audits, including certain Phase 4 work within our Pandemic
Work Plan. In addition, we are curtailing our participation in U.S. Department of Justice
pandemic-related task forces.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 1
I remain concerned that these actions will have detrimental results, thus leading to fewer OIG
audits and recommendations, lost opportunities to hold fraudsters accountable, and hundreds
of millions of taxpayer dollars left unrecovered.
Statute of Limitations
Currently, the statute of limitations for many pandemic-related UI fraud cases will begin to expire
in early 2025 as the statutes most often used to prosecute UI fraud have 5-year limitations.
Absent congressional action to extend the statute of limitations for fraud associated with
pandemic-related UI programs, those who have defrauded the UI program may escape
justice. Due to the pending expiration of the statute of limitations, as well as the lack of
resources, the OIG will significantly curtail the opening of any new pandemic UI fraud
investigations and will assess ongoing investigations for potential termination.
OIG Accomplishments
Despite these challenges, OIG staff continues to deliver high-quality oversight. In total, during
this reporting period, the OIG issued 12 audit reports with 33 recommendations. Among our
many significant findings, we reported:
• The Mine Safety and Health Administration did not complete an estimated 1,589
mandatory safety and health mine inspections before and during the COVID-19 pandemic;
• While the Bureau of Labor Statistics has taken actions to address challenges posed by
declining survey response rates, they could do more to identify potential data limitations
in their economic information and increase the transparency of those limitations;
• Although DOL established and maintained its information security program, our
audit found weaknesses that demonstrated the information security program had
not achieved a maturity rating of Managed and Measurable in three of the five
Cybersecurity Framework Functions: Identify, Protect, and Recover; and
• The Department has not developed a formal, documented information technology
(IT) modernization framework. While the Chief Information Officer has developed
several elements that could become part of an IT modernization framework, we
found those elements are not linked to one another nor documented as part of a
larger, formalized process.
2 Semiannual Report to Congress | October 1, 2023–March 31, 2024
The OIG’s investigative work also continued to yield impressive results, with a total of 190
investigative reports issued/cases closed, 275 indictments, 242 convictions, and more than
$78 million in monetary accomplishments. Highlights of this work follow:
• A Washington woman was sentenced to 5 years in prison and ordered to pay more than
$2 million in restitution for orchestrating a wide-ranging fraud scheme which involved the
theft of more than $3.3 million from federally funded pandemic assistance programs;
• A Maryland man was sentenced to 41 months in prison and ordered to pay restitution of
more than $2 million for his role in defrauding multiple State Workforce Agencies and the
U.S. Small Business Administration (SBA) of federal pandemic relief programs, including
the UI program and SBA’s Economic Injury Disaster Loan program;
• A medical marketer was convicted for his role in a $55 million compounding fraud
scheme; and
• A Colombo crime family captain was sentenced to 51 months in prison for his participation
in the long-running extortion of a senior official of a New York-based labor union and other
criminal schemes.
While OIG staff members faced significant challenges during this reporting period,
these outstanding accomplishments reflect their continued dedication and commitment
to our mission.
In closing, I would like to thank Congress and the Department for their support of our work
to identify improvements to DOL programs and operations and to protect the interests and
benefits of the nation’s workers and retirees.
Larry D. Turner
Inspector General
Semiannual Report to Congress | October 1, 2023–March 31, 2024 3
OIG Fiscal Year 2022–2026 Strategic Plan
OIG Mission
We serve the American people, DOL, and Congress by providing independent and
objective oversight of Departmental programs through audits and investigations,
and by combatting the influence of labor racketeering in the workplace.
Core Values
Excellence
We deliver relevant, quality, timely, high-impact products and services, through a
workforce committed to accountability and the highest professional standards.
Integrity
We adhere to the highest ethical principles and perform our work in an honest and
trustworthy manner.
Independence
We are committed to being free of conflicts of interest through objectivity and impartiality.
Service
We are a unified team, vigilant to duty through dedicated public service.
Transparency
We promote an environment of open communication through information sharing,
accountability, and accurate reporting.
Strategic Goals
Goal 1: Deliver timely, relevant, and high-impact results.
Goal 2: Foster an internal OIG culture that drives high performance and engagement.
Goal 3: Promote responsible stewardship of OIG financial and non-financial resources.
4 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Contents
Selected Statistics . . . . . . . . . . . . . . . . . . . . 6 Appendices . . . . . . . . . . . . . . . . . . . . . . . . 89
Funds Recommended for Better Use . . . 92
Significant Concerns . . . . . . . . . . . . . . . . . . 8
Questioned Costs . . . . . . . . . . . . . . . . . . 93
Worker and Retiree Benefit Programs . . . 33 Final Audit Reports Issued . . . . . . . . . . . 94
Unemployment Insurance Programs . . . . 34 Other Reports . . . . . . . . . . . . . . . . . . . . . 96
Office of Workers’ Compensation Unresolved Audit Reports Over
Programs . . . . . . . . . . . . . . . . . . . . . . . . 43 6 Months Old . . . . . . . . . . . . . . . . . . . . . 97
Worker Safety, Health, and Workplace Management Decision Made During this
Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 Reporting Period on Audits, Inspections, or
Evaluations Issued during a Previous Reporting
Mine Safety and Health Administration . . 48 Period Final Audit Reports Issued . . . . . . . 100
Management Decision Made During this
Employment and Training Programs . . . . 51
Reporting Period on Audits, Inspections,
Employment and Training Administration or Evaluations Issued during a Previous
Programs . . . . . . . . . . . . . . . . . . . . . . . . 52 Reporting Period Other Reports Issued . . 103
Bureau of Labor Statistics . . . . . . . . . . . . 54 Corrective Actions Taken by the
Department . . . . . . . . . . . . . . . . . . . . . . 104
Labor Racketeering . . . . . . . . . . . . . . . . . . 57 Unimplemented Recommendations . . . . 108
Departmental Management . . . . . . . . . . . . 61 High-Priority Unimplemented
Recommendations . . . . . . . . . . . . . . . . 109
Single Audits . . . . . . . . . . . . . . . . . . . . . . 70
Summary of Reports with Unimplemented
Recommendations with Cost Savings /
Employee Integrity Investigations . . . . . . 73 Funds Put to Better Use . . . . . . . . . . . . . 118
OIG Whistleblower Activities . . . . . . . . . . 75 Reports with Unimplemented
Recommendations for Management
Improvement or Disallowed Costs Owed . 121
Legislative Recommendations . . . . . . . . . 79
Investigative Statistics . . . . . . . . . . . . . . . 127
Peer Review Reporting . . . . . . . . . . . . . . 129
OIG Hotline . . . . . . . . . . . . . . . . . . . . . . . 131
Acronyms and Abbreviations . . . . . . . . . . 132
Audit Statistics
12 33
Audits and Other Reports Issued Recommendations for Corrective Action
OIG Unimplemented Recommendations
OIG recommendations not fully implemented as of March 31, 2024
EBSA 2
ETA 64
MSHA 27
OASAM 27
OCFO 5
OFCCP 1
OSEC 5
OSHA 27
OWCP 8
WHD 3
0 10 20 30 40 50 60 70
6 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Investigative Statistics
Investigative Results Labor Racketeering
Program Fraud
170/190
275
242
190
170
120
64
170 investigative
1 cases opened and
190 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: $1,264,504
Recoveries
Cost-Efficiencies
Restitutions
Fines/Penalties
Forfeitures
Civil Monetary Actions
$77,149,020
$78,413,524
Total Labor Racketeering
Program Fraud
Semiannual Report to Congress | October 1, 2023–March 31, 2024 7
Significant Concerns
Significant Concerns
The Office of Inspector General (OIG) has identified the following areas of significant concern that cause
the U.S. Department of Labor (DOL or Department) to be at particular risk for fraud, mismanagement,
waste, abuse, or other deficiencies. The identified areas of concern reflect continuing matters as well as
emerging issues. Many of these issues are detailed in our annual Top Management and Performance
Challenges report, which can be found in its entirety at www.oig.dol.gov.
Deploying Unemployment
Insurance Benefits Protecting the Security
Expeditiously and Efficiently of Employee Benefit
While Reducing Improper Plan Assets
Payments
Extending the Statute
of Limitations Associated Maintaining the
with Pandemic-Related Integrity of Foreign Labor
Unemployment Insurance Certification Programs
Fraud
OIG Winding Down
Pandemic Unemployment Improving the Performance
Insurance Oversight Work Accountability of Workforce
Due to the Expiration of the Development Programs
Statute of Limitations and
Resource Constraints
Ensuring the Safety
Providing the OIG Access of Students and Staff
to UI Claimant Data and at Job Corps Centers
Wage Records
Returning Unused Managing Medical Benefits
Funds in State UI in the Office of Workers’
Accounts to the Federal Compensation Programs
Government
Ensuring the Solvency
Curtailing Child Labor of the Black Lung Disability
Law Violations Trust Fund
Managing and
Protecting the Safety and Protecting the Safety and
Securing Data and
Health of Workers Health of Miners
Information Systems
8 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
Deploying Unemployment Insurance Benefits Expeditiously and Efficiently While
Reducing Improper Payments
The OIG has long reported significant concerns with the Department and state workforce agencies’
(SWA)1 ability to deploy unemployment insurance (UI) program benefits expeditiously and efficiently
while ensuring integrity and adequate oversight. In the more than 4 years since the onset of the
COVID-19 pandemic, our concern has grown as workers waited for UI benefits, improper payments
soared, and our audit and investigative work found program weaknesses and related criminal activity
persisted throughout and after the pandemic. We remain particularly concerned about deployment
of UI benefits in response to future emergencies, including natural disasters and economic
downturns. Unless more is done now at the federal and state levels to increase systemic integrity in
the UI program, the program’s weaknesses will continue to negatively impact American taxpayers
and workers both under current conditions and in the face of the next emergency.
Our April 2020 advisory report outlined areas of concern
Moreover, the COVID-19
that the Department and states should consider as they
pandemic exposed
implemented UI provisions of the Coronavirus Aid, Relief, and
weaknesses in the UI
Economic Security (CARES) Act. One of these areas was state
program that led to even
preparedness, specifically, the issues of staffing and system
higher levels of improper
capabilities. For example, many states had not developed or
payments, including fraud.
implemented UI information technology (IT) modernization
plans to improve the timeliness and accuracy of UI benefits
processing.2 These challenges continue to persist beyond the pandemic period. Specifically,
in January 2024, only 28 percent of reporting states were paying regular UI claimants timely
versus 75 percent before the pandemic started.3 According to ETA officials, there has been an
improvement in payment timeliness post-pandemic; however, further improvement is needed, as
payments to claimants have been slowed down by the implementation of new identity verification
processes. Moreover, the COVID-19 pandemic exposed weaknesses in the UI program that led to
even higher levels of improper payments, including fraud.
1 When referring to UI, this Semiannual Report to Congress uses “state” or “SWA” to refer to the administrative
body that administers the program within the state, district, or territory. For the 50 states, as well as the U.S. Virgin
Islands, the Commonwealth of Puerto Rico, and the District of Columbia, that administrative body is a SWA. There
are, therefore, 53 SWAs. The CARES Act also provided certain UI benefits to American Samoa, the Commonwealth
of the Northern Mariana Islands, the Federated States of Micronesia, Guam, the Marshall Islands, and the Republic
of Palau, provided they signed an agreement with the Department.
2 COVID-19: Audit of State Workforce Agencies’ Information Technology Systems Capability in Processing
Unemployment Insurance Claims, Report No. 19-23-008-03-315 (September 19, 2023), available at:
https://www.oig.dol.gov/public/reports/oa/2023/19-23-008-03-315.pdf
3 Based on OIG analysis of data on the Employment and Training Administration’s public reporting on States’ UI
Benefit Timeliness and Quality, available at: https://oui.doleta.gov/unemploy/btq.asp.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 9
Significant Concerns
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.
The reported improper payment rate estimate
for the regular UI program has been above
10 percent4 for 17 of the last 20 years.5
Over the last 3 years, the Department has
reported historically high rates of improper
payments, including fraud, in the UI program.
Specifically, the Department reported an
estimated improper payment rate of 18.71
percent for Fiscal Year (FY) 2021 and
21.52 percent for FY 2022. Based on our audit
and investigative work, the actual improper
payment rate for these periods, including the
pandemic program period,6 was likely higher.
For example, the Department reported an
improper payment rate of 35.9 percent for the
Pandemic Unemployment Assistance (PUA) program. Although the improper payment rate for FY
2023 has been reduced to 14.83 percent7, this rate still exceeds prepandemic levels and fails to
meet federal requirements.
4 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.
5 UI improper payments data for FY 2004 through FY 2022 as reported to the Office of Management and
Budget (OMB).
6 With the exception of PUA, for which claims could be backdated to January 27, 2020, we define the UI
pandemic period as March 27, 2020, through September 6, 2021.
7 At the time of the publication of this Semiannual Report to Congress, the OIG has not audited the reported
improper payment rate. The OIG will assess that rate’s compliance with the Payment Integrity Information
Act of 2019 for FY 2023. That audit report will be available in Summer 2024.
10 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
In February 2023,8 Inspector General Larry D. Turner testified before Congress that more
than $888 billion in total federal and state UI benefits were paid for benefit weeks during the
UI pandemic period. Applying the FY 2022 estimated 21.52 percent improper payment rate to
the approximate $888 billion in pandemic UI expenditures, at least $191 billion in pandemic UI
payments could have been improperly paid, with a significant portion attributable to fraud.9 The
potential loss of $191 billion of taxpayer money highlights the need for systemic improvements.
To recover the improperly paid benefits and mitigate the impact of these losses, collaboration
between the Department and states is vital.
As previously mentioned, in December 2023, the Department’s Employment and Training
Administration (ETA) issued Unemployment Insurance Program Letter 05-24, allowing states to
apply their finality laws to pandemic-related UI programs. This guidance limits the time period
in which a state is required to take any action with regard to pandemic UI claims, which raises
concerns about the incentives for states to identify and recover improper payments, including fraud.
The application of state finality laws, alongside the allowance of waivers (permission to waive the
recovery of overpayments in certain situations), may result in an increase in unrecovered improper
payments. Furthermore, if state agencies are not required to investigate cases beyond the finality
period, many fraud cases might go undetected and unprosecuted.
Combatting Large-Scale Fraud
According to Department and state officials, the pandemic turned the UI program into an attractive
target for fraud, a trend that persists today. Organized criminal groups continue to target the UI program,
adapting to countermeasures and shifting tactics and locations to exploit systemic weaknesses.
Inspector General Larry D. Turner, during his March 2022 congressional testimony,10 reported
that the unprecedented infusion of federal funds into the UI program—combined with continuing
program weaknesses and easily attainable stolen personally identifiable information (PII)—
8 “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
9 Fraud is a type of improper payment. OMB explains that, at a high level, a payment is “improper” if made in
an incorrect amount or to the wrong recipient. Improper payments can result in a money loss that was either
unintentional (accidental) or intentional (fraud). For more information, see OMB, Appendix C to OMB Circular A-123,
Requirements for Payment Integrity Improvement, Memorandum (March 5, 2021), last accessed September 27, 2022,
available at: https://www.whitehouse.gov/wp-content/uploads/2021/03/M-21-19.pdf.
10 “Pandemic Response and Accountability: Reducing Fraud and Expanding Access to COVID-19 Relief through
Effective Oversight,” Hearing, Statement for the Record of Larry D. Turner, Inspector General, U.S. Department of
Labor; Senate Committee on Homeland Security and Governmental Affairs (March 17, 2022), available at:
https://www.oig.dol.gov/public/testimony/20220317.pdf
Semiannual Report to Congress | October 1, 2023–March 31, 2024 11
Significant Concerns
provided a high-value target for fraudsters to exploit. For example, an individual could make a
fraudulent claim with relatively low risk of being caught and, as time went on, one fraudster could
have been issued several UI debit cards, with tens of thousands of dollars on each card. In fact,
in 2023, the Government Accountability Office (GAO) estimated pandemic-related fraud in the UI
program to be as high as $135 billion.11
Our investigators have identified crimes related to UI fraud committed by bad actors both in the
United States and abroad. Specifically, our work has resulted in the indictment/initial charging of
over 1,700 criminals. These criminals include organized groups whose members and associates
engaged in acts involving murder, assault, narcotics trafficking, identity theft, and other crimes.
When the OIG identifies anti-fraud measures that may help the program, we share them with the
Department and SWAs, as appropriate. For example, our investigators, auditors, and data scientists
collaboratively identified12 $46.9 billion in potentially fraudulent UI benefits paid in six high-risk areas,
to individuals with Social Security numbers:
1. filed in multiple states,
2. of federal prisoners,
3. used to file for UI claims with suspicious email accounts,
4. of deceased persons,
5. belonging to individuals under 14 years of age, and
6. belonging to individuals 100 years of age or older.
We recommended states establish effective controls to mitigate fraud and other improper payments
to ineligible claimants and are examining whether states took effective measures to address the
initial four high-risk areas.13 Additionally, in Spring 2023, we started assessing the effects of waivers
and blanket waivers on the recovery of UI overpayments, including fraud. While DOL provided
guidance correctly stating that recovery of fraudulent payments may not be waived, we remain
concerned that states may have unintentionally waived or will waive fraudulent payments. Further, in
December 2023, ETA revised its guidance, allowing states to apply their finality laws for pandemic
UI programs. The OIG is concerned that the application of finality laws may have a negative impact
on the detection and collection of fraudulent pandemic UI claims.
11 GAO, Unemployment Insurance: Estimated Amount of Fraud during Pandemic Likely between $100 Billion and
$135 Billion, GAO-23-106696 (September 2023), available at: https://www.gao.gov/assets/gao-23-106696.pdf
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
13 Previously, we have reported on four high-risk areas; we added two areas: individuals with Social Security
numbers belonging to persons under 14 and over 100 years of age.
12 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
Extending the Statute of Limitations Associated with Pandemic-Related
Unemployment Insurance Fraud
We are extremely concerned that, unless Congress acts urgently
As of March 31, 2024,
to extend the statute of limitations for fraud associated with
OIG investigations have
pandemic-related UI programs, many groups and individuals that
resulted in more than
have defrauded the UI program may escape justice. As the primary
1,700 individuals being
federal law enforcement agency responsible for providing oversight
charged with crimes
of the UI program, the OIG has vigorously pursued pandemic-related
involving UI fraud since
UI fraud. As of March 31, 2024, OIG investigations have resulted in
April 2020.
more than 1,700 individuals being charged with crimes involving UI
fraud since April 2020.14
The OIG was tasked with investigating an exceptional volume of complex pandemic-related UI
fraud cases. Despite the OIG’s tireless efforts, the current statute of limitations associated with UI
fraud means federal law enforcement will fall short in fully investigating and prosecuting the most
egregious cases of UI fraud. Currently, the statute of limitations for many of these cases will begin to
expire in early 2025 as the statutes most often used to prosecute UI fraud have 5-year limitations.
Specifically, the volume of the OIG’s UI investigative matters increased a thousandfold during the
pandemic. Previously, the OIG opened approximately 100 UI fraud investigative matters each year.
As of March 2024, the OIG has opened more than 207,000 investigative matters related to the
pandemic. We continue to receive, on average, 100 new UI fraud complaints each week.
As a direct result of the exponential increase in pandemic-related UI fraud referrals, OIG
investigators continue to carry the largest case inventory in the OIG’s history. We are still dedicating
the majority of our investigative resources to addressing pandemic-related UI fraud matters. This
issue is further exacerbated by the OIG’s significant reduction in the number of investigators
onboard due to the near exhaustion of supplemental pandemic funding, resulting in a substantial
decrease in investigative capacity.
Pandemic-related UI fraud referrals that we receive often include complex schemes involving criminal
enterprises and bad actors who use sophisticated techniques to maintain their anonymity. As such,
these investigations require significant resources and time. We leverage additional resources by
partnering with SWAs, the U.S. Department of Justice (DOJ), and other federal law enforcement
agencies on the National Unemployment Insurance Task Force, the COVID-19 Fraud Enforcement Task
Force, and the COVID-19 Fraud Enforcement Strike Force teams to investigate and prosecute UI fraud.
14 For more details about OIG investigations, visit our Pandemic Response Portal at:
https://www.oig.dol.gov/OIG_Pandemic_Response_Portal.htm.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 13
Significant Concerns
While these investigative resources helped us address the incredible volume of UI fraud matters,
the process of collecting and cleaning15 the SWA data required a significant amount of time. We
leveraged the UI data we were able to collect to identify those matters that posed the greatest risk to
the UI program. However, as a result of the lack of resources and pending expiration of the statute
of limitations, the OIG has begun to pivot away from pandemic UI investigations.
Supplemental pandemic resources from Congress allowed the OIG to hire more criminal investigators
and significantly expand the number of staff reviewing UI fraud matters. Unfortunately, the OIG is
in the process of reducing staffing to below pre-pandemic levels due to the near exhaustion of the
supplemental funding provided by Congress. In late FY 2023, we eliminated all of the approximately 20
contract staff we had been using to triage the approximately 205,000 UI fraud complaints we received
during the pandemic. Despite our dwindling resources, the OIG anticipates continuing the investigation
of already open pandemic-related UI fraud matters until the statute of limitations expires. However,
due to the lack of resources and impending expiration of the statute of limitations, we will significantly
curtail the opening of any new pandemic UI fraud investigations. Further, we will continue the pause
in reviewing the approximately 150,000 open UI fraud complaints we currently have awaiting review.
Absent congressional action, the statute of limitations will begin to expire in early 2025.
In August 2022, an extension of the statute of limitations was implemented for crimes involving the
U.S. Small Business Administration’s (SBA) Paycheck Protection Program (PPP) and Economic Injury
Disaster Loan (EIDL) program. Congress should likewise consider extending the statute of limitations
for existing laws when pandemic-related UI programs are defrauded. The expansion of the statute of
limitations would provide investigators and prosecutors time to pursue and hold accountable those
who defrauded the UI program and victimized the American people during the pandemic.
OIG Winding Down Pandemic Unemployment Insurance Oversight Work Due to
the Expiration of the Statute of Limitations and Resource Constraints
The OIG received $38.5 million under the CARES Act and the American Rescue Plan Act to oversee
DOL’s pandemic-related programs and operations, with an emphasis on combatting the unprecedented
levels of fraud in the UI programs. These funds were instrumental in the OIG being able to secure, thus
far, more than 1,700 indictments or initial charges; 1,150 convictions; 26,000 months of incarceration;
and $1 billion in investigative monetary outcomes associated with pandemic-related UI fraud.
These funds also allowed the OIG to issue 50 audit reports that included 150 recommendations for
corrective action by DOL, as well as more than $75 billion in funds put to better use and $277 million in
questioned costs related to DOL’s pandemic-related programs and operations (see Table 1).
15 SWA data “cleaning” involves verifying data to ensure it is complete, consistent, and in a common format to
analyze and identify potential fraud and programmatic weaknesses.
14 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
Table 1: DOL OIG’s Cumulative Pandemic-Related Results, as of March 31, 2024
Results
Audit Reports 50
Recommendations 150
Funds Identified for Better Use $75 billion+
Questioned Costs $277 million+
Indictments/Initial Charges 1,700+
Convictions 1,150+
Months of Incarceration Ordered 26,000+
Investigative Monetary Results $1 billion+
However, these funds will be completely expended in FY 2024. The expenditure of the supplemental
pandemic oversight funds—combined with appropriation levels that were lower than expected for
FY 2023 and FY 2024 and the impending expiration of the statute of limitations associated with
pandemic-related UI fraud—is forcing the OIG to wind down its pandemic oversight work.
In FY 2023, we took the following actions to reduce our pandemic oversight work:
• implemented a hiring freeze,
• canceled 10 pandemic-related audit performance contracts, and
• terminated the hotline triage contract that processed pandemic-related complaints.
In FY 2024, the OIG is taking the following additional actions:
• stopping initiation of new pandemic UI fraud investigations,
• assessing ongoing investigations for potential termination due to resource constraints and the
expiration of the statute of limitations in early 2025,
• discontinuing our pandemic-related UI proactive fraud data analytics program and refocusing our
analytics program on post-pandemic programs across DOL,
• reducing our participation on the DOJ National UI Fraud Taskforce and COVID-19 Fraud
Enforcement Taskforce, and
• canceling certain pandemic-related audits, including Phase 4 work within the OIG’s Pandemic
Work Plan.
Considering the significance of our resource constraints, the OIG will also need to suspend certain
non-pandemic discretionary audits included in our FY 2024 Audit Work Plan. This will ensure we
can operate within the FY 2024 funding levels and complete ongoing pandemic-related work.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 15
Significant Concerns
We remain concerned that these actions will have detrimental results, including fewer audits that
identify much-needed improvements in DOL programs and operations, lost opportunities to hold
fraudsters accountable, and hundreds of millions of taxpayer dollars that could be left unrecovered.
The OIG is committed to serving the American
We remain concerned that these
people, DOL, and Congress by providing
actions will have detrimental results,
independent and objective oversight of
including fewer audits that identify
Departmental programs through audits and
much-needed improvements in
investigations, and by combatting the influence
DOL programs and operations, lost
of labor racketeering in the workplace. However,
opportunities to hold fraudsters
absent dedicated funds for overseeing
accountable, and hundreds of
pandemic-related programs and operations, the
millions of taxpayer dollars that
OIG must pivot away from pandemic-related UI
could be left unrecovered.
oversight and provide more balanced oversight
of all DOL programs and operations. The OIG
will continue using our existing resources efficiently and effectively by applying our risk assessment
process. This process will help us determine how to best focus our available resources to provide
impactful audit and investigative oversight across all DOL agencies and programs.
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 remains a significant concern. This deficiency directly and adversely impacts the OIG’s
ability to provide independent oversight and combat fraud, waste, and abuse to help DOL improve
the integrity of the UI program. Access to UI claimant data and wage records would permit the OIG
to leverage the power of predictive analytics to continuously monitor DOL programs and operations
to detect and investigate fraud. Continuous monitoring serves as a deterrent to fraud, allows the OIG
to promptly discover areas of weakness, and enables DOL management to timely correct problems.
To effectively address the challenges posed by the pandemic, we took a proactive stance,
employing data analytics at both national and state levels to identify high-risk areas within the UI
program. However, the OIG’s ability to proactively detect UI fraud continues to be impacted by DOL’s
interpretation that the OIG’s ongoing, timely, and complete access to UI claimant data and wage
records was limited to the pandemic period and related grants.
Prior to and during most of the pandemic period, DOL maintained that, under its regulations, SWAs
were only required to disclose UI data to the OIG for specific fraud investigations. DOL asserted
it lacked the authority—outside of revising the existing regulations through notice and comment
rulemaking—to require SWAs to provide UI data to the OIG for audits and investigations, despite
the Inspector General Act of 1978, as amended, authorizing the Inspector General’s access for such
16 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
purposes. As a result, the OIG took the unprecedented step of using Inspector General subpoenas
to obtain this critical data.
DOL continues to interpret regulations at 20 C.F.R. Part 603 as prohibiting ETA from requiring
SWAs to provide UI data to the OIG for all audit purposes and for investigative purposes other than
those involving specific instances of suspected 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.16 In our June 2021 alert memorandum,17 we
recommended ETA amend its regulations to reinforce that SWAs’ UI information must be provided to
the OIG for all engagements authorized under the Inspector General Act of 1978, as amended.
To date, the Department has only implemented temporary solutions that are not sufficient to resolve
the OIG’s recommendation or concerns. The Department has required sharing of state UI data as a
condition of several recent grants, including fraud prevention and IT modernization grants, to provide
such access through 2028.
ETA announced its intent to amend its regulations to facilitate the OIG’s ongoing access. Also,
in July 2023, ETA requested public comment on potential revisions that would require states to
disclose unemployment compensation data to the OIG for oversight, including audits. Until DOL
implements a permanent solution ensuring the OIG’s complete and timely access to UI program
data and information, the Department’s interpretation of its regulations may renew impediments to
the OIG’s access experienced prior to and during the pandemic.
In an alert memorandum issued September 21, 2022,18 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 that they must timely provide UI data 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 that the OIG has identified,
including potential fraud, support the conclusion that the OIG’s continued access to state UI data
is imperative.
16 Further, only a federal statute, not DOL’s regulations, can supersede the Inspector General’s access authority,
and only if it expressly states that it limits the Inspector General’s authority.
17 Alert Memorandum: The Employment and Training Administration Needs to Issue Guidance to Ensure State
Workforce Agencies Provide Requested Unemployment Insurance Data to the Office of the Inspector General,
Report No. 19-21-005-03-315 (June 16, 2021), available at:
https://www.oig.dol.gov/public/reports/oa/2021/19-21-005-03-315.pdf
18 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, 2023–March 31, 2024 17
Significant Concerns
In addition to the Inspector General Act of 1978, as amended, Congress should consider legislative
action that would specifically authorize DOL and the OIG to have ongoing, timely, and complete
access to UI claimant data and wage records for our oversight responsibilities. Ongoing, timely,
and complete access to SWA UI claimant data and wage records would further enable the OIG to
quickly identify largescale fraud and expand its current efforts to share emerging fraud trends with
ETA and states to strengthen the UI program and deter fraud.
Returning Unused Funds in State UI Accounts to the Federal Government
As a result of recent work, we are concerned that a significant amount of pandemic-related federal
funding remains in state UI accounts. For example, in two CARES Act UI programs—Temporary
Full Federal Funding of the First Week of Compensable Regular Unemployment for States with
No Waiting Week (TFFF) and Emergency Unemployment Relief for Governmental Entities and
Nonprofit Organizations (EURGENO)19 —recent work has identified the need for reconciliation of
more than $5 billion20. These programs made funding available to SWAs through reimbursements
that states drew down from state UI accounts. The programs ended in September 2021; however,
some of the remaining funds may be attributable to claim adjustments that SWAs still need to make.
The Department and SWAs need to perform reconciliations to determine exactly how much money
needs to be deobligated and returned to the U.S. Department of the Treasury (Treasury).
During our audit of TFFF, we identified that the Department made approximately $12.5 billion of
funding available in the 53 SWAs’ invested Federal Unemployment Accounts.21 The SWAs accessed
the funds as reimbursement of 100 percent22 of benefits paid to claimants for their first week of regular
UI compensation. Overall, the 53 states 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,
19 In Unemployment Insurance Program Letter 18-20, EURGENO is identified as the “Emergency Unemployment
Relief for State and Local Governmental Entities, Certain Nonprofit Organizations, and Federally-Recognized
Indian Tribes.”
20 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
21 Treasury transfers funds from the general fund to the Federal Unemployment Account in amounts estimated by
the Department to be necessary to reimburse the states for first week regular UI compensation paid. The Federal
Unemployment Account is an account within the federal UI trust fund that pays for the costs to administer the UI
program, emergency benefits, loans to state trust funds, and program expansions like the CARES Act.
22 Although this amount was temporarily reduced to 50 percent from January through mid-March of 2021, it was
retroactively restored to 100 percent for that period through the program’s expiration in September 2021.
18 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
waste, and abuse, the Department needs for states to reconcile and close out these accounts and
return the funds to Treasury.
During our audit of EURGENO, we identified that the Department The Department and
made approximately $6.3 billion of relief funds available to the SWAs need to perform
53 SWAs’ UI trust funds. EURGENO was designed to mitigate reconciliations to determine
the effects of the pandemic on employers that reimburse SWAs exactly how much money
for eligible UI benefits paid (reimbursing employers). The SWAs needs to be deobligated and
accessed relief funds to provide refunds to reimbursing employers
returned to the Treasury.
or to fund credits extended to these employers—amounting to
50 percent23 or 75 percent24 of the employers’ cost of UI benefits.
However, the audit identified that, 16 months after EURGENO ended,25 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 needs to be returned to the federal government. As
previously stated, the Department and SWAs need to perform reconciliations to determine exactly how
much money needs to be deobligated and returned to the Treasury.
Curtailing Child Labor Law Violations
Collectively, U.S. labor laws cover most private, state, and local government employment and protect
more than 165 million of America’s workers in more than 11 million workplaces. The Fair Labor
Standards Act of 1938 sets standards for minimum wage and overtime, among others, including
youth employment. Enforced by DOL’s Wage and Hour Division (WHD), the standards for youth
employment are commonly known as child labor laws and are meant to ensure youth employment
is safe, appropriate, and does not jeopardize youth health, well-being, or educational opportunities.
We are concerned about the rise in child labor law violations and the recent reductions in state child
labor protections with additional proposals pending.
In FY 2023, DOL concluded 955 investigations that found child labor violations—a 14 percent
increase from the previous year. DOL found nearly 5,800 children employed in violation of the law—
23 Under the CARES Act provisions, reimbursing employers were eligible to receive relief through refunds after they
paid their bills in full. On August 3, 2020, the Protecting Nonprofits from Catastrophic Cash Flow Strain Act of 2020
became law, which required states to provide reimbursing employers with 50 percent relief through credits.
24 On March 11, 2021, the American Rescue Plan Act of 2021 was signed into law, which increased the relief
percentage from 50 percent to 75 percent, beginning after March 31, 2021. According to Departmental guidance,
this effectively increased the rate by the week ending April 11, 2021.
25 The EURGENO program ended on September 6, 2021. As of February 1, 2023, the total balance for the 32
states remained at approximately $844.1 million.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 19
Significant Concerns
an 88 percent increase within the last 5 years. In addition, DOL assessed more than $8 million in
related penalties—an 83 percent increase from the previous year. Notably, this increase in child
labor law violations is occurring while the WHD struggles to retain investigators.
Further complicating the issue, two laws recently passed in Arkansas and Iowa to weaken child
labor protections. Similarly, in 2023, multiple bills to weaken child labor protections were introduced
in Minnesota, Missouri, Nebraska, Ohio, and South Dakota. We are currently examining the WHD’s
efforts to curtail child labor law violations and are attempting to determine the cause for the rise of
these violations.
Protecting the Safety and Health of Workers
Responsible for the safety and health of approximately 130 million workers employed at more than 8 million
worksites, the Occupational Safety and Health Administration (OSHA) must ensure employers are providing
the level of protection required under relevant laws and policies. Federal law entitles U.S. workers to a safe
and healthful workplace. Failure to keep workplaces free of known safety and health hazards can lead to
serious legal consequences, injuries, illnesses, and fatalities. The OIG remains concerned about OSHA’s
ability to target its compliance activities to areas where it can have the greatest impact.
OSHA carries out its compliance responsibilities through a combination of self-initiated inspections
and those resulting from complaints and referrals. For FY 2023, OSHA reported conducting 34,273
inspections, including 17,480 unprogrammed inspections. Unprogrammed inspections result from
employee complaints, injuries/fatalities, and referrals. OSHA must target the most egregious or
persistent violators to protect the most vulnerable worker populations. OSHA has since increased its
number of inspectors—from 750 in 2021, to 846 as of February 29, 2024. However, OSHA continues
to be challenged with reaching the number of worksites for which it is responsible.
The OIG also found26 OSHA’s Site-Specific Targeting programs—which were specifically designed
to reach establishments with high rates of serious injuries—had limited controls in place to ensure
an adequate number of targeted Site-Specific Targeting program inspections occurred. It also did
not timely monitor program activity to determine how many of the proposed inspections actually
occurred until after the programs ended. Very few inspections of targeted establishments meant
workers remained vulnerable to continuously high rates of injury and illness.
Further, OSHA’s ability to target enforcement is also impacted by its limited visibility into the
numbers and types of injuries and illnesses occurring in warehouses, including those classified as
26 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
20 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
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. An OIG audit27 found MSHA did not complete an
estimated 1,589 mandatory inspections during FY 2018 through FY 2021 despite reporting a nearly
100 percent completion rate. Subsequently, MSHA agreed to transparently report each year the
number of attempted inspections caused by either a mine not operating at the time of the inspector’s
visit or a mine operator denying an MSHA inspector entry to the mine. However, accurate reporting
will remain a concern for the OIG until we can verify MSHA’s reporting changes. In addition, MSHA’s
completion of mandatory inspections remains a concern until the agency sufficiently implements
corrective actions for all of the report’s recommendations.
Further, the agency is challenged with verifying the operating status of mines and identifying when
mines need a change in status in its system. Discrepancies in a mine’s status can create issues
because the status factors into how many inspections MSHA is required to conduct at the mine.
MSHA’s failure to maintain accurate mine statuses in its system has also led to other significant issues.
For instance, MSHA may be unaware of a mine shifting to abandoned status. Abandoned mines must
be sealed in accordance with the Federal Mine Safety and Health Act of 1977 to avoid presenting
a danger to the public. Also, the elimination of inspection requirements due to idle mine visits has
contributed to MSHA’s challenge of not conducting mandatory inspections. Specifically, MSHA
eliminated mandatory mine inspection requirements by instead counting inspectors’ visits to mines that
were not operating at the time of the visit, thus reducing the overall number of mines inspected.
27 COVID-19: MSHA Did Not Complete or Accurately Report Mandatory Inspections, Report No. 19-24-0 01-06-001
(October 17, 2023), available at: https://www.oig.dol.gov/public/reports/oa/2024/19-24-001-06-001.pdf
Semiannual Report to Congress | October 1, 2023–March 31, 2024 21
Significant Concerns
Second, we are concerned about MSHA’s ability to write violations for hazards that it identifies
during inspections. An OIG audit 28 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 issues with MSHA’s pre-assessment
conferencing program, in which operators can challenge violations they feel MSHA inspectors
did not write correctly. MSHA has not successfully implemented corrective actions for all nine
recommendations we issued in 2019 regarding its pre-assessment conferencing program.29
Third, we are concerned about the high 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). Together, they accounted for more than half of all mine fatalities during 2022 through 2023.
Figure 1: Number and Percentage of Top 8 Classes of Mining Fatalities,
Calendar Years 2018–2023
Powered Haulage 59 31%
Machinery 54 28%
Slip or Fall of Person 16 8%
Other 13 7%
Electrical 10 5%
Fall of Roof or Back 9 5%
Fall of Face/Rib/Pillar/Side/Highwall 9 5%
Falling/Sliding/Rolling Materials 8 4%
0 10 20 30 40 50 60
Source: MSHA’s Accident Injuries public dataset, as of March 8, 2024
28 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
29 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
22 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
On January 19, 2024, MSHA’s final rule for the Safety
Program for Surface Mobile Equipment became
effective. The rule requires mine operators to develop,
implement, and update written safety programs
describing the actions it will take to identify hazards
and risks to reduce accidents, injuries, and fatalities
related to surface mobile equipment. This final rule
is a positive mitigating step in conjunction with the
performance of other prevention outreach. However,
we remain concerned with the high number of powered
haulage and machinery fatalities until the data shows a
consistent decline in these incidents.
MSHA published a final rule on April 18, 2024,
lowering the permissible exposure limit for respirable
crystalline silica for all miners. This rule also includes
other requirements to protect miner health, such as
exposure sampling, corrective actions to be taken when a miner’s exposure exceeds the permissible
exposure limit, and medical surveillance for metal and nonmetal mines. While this rule should
help reduce occupational disease in miners and improve respiratory protection against airborne
contaminants, the frequency of sampling performed by inspectors must be sufficient to address
higher risk levels at mines.
In our November 2020 audit report30, we noted that 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.
Protecting the Security of Employee Benefit Plan Assets
The OIG remains concerned about the Employee Benefits Security Administration’s (EBSA) ability
to protect the integrity of pension, health, and other benefit plans of more than 153 million workers,
30 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
Semiannual Report to Congress | October 1, 2023–March 31, 2024 23
Significant Concerns
retirees, and their families under the Employee Retirement Income Security Act of 1974 (ERISA).
In particular, the OIG is concerned about the statutory limitations on EBSA’s oversight authority
and inadequate resources to conduct compliance and enforcement.
A decades-long challenge to EBSA’s compliance program, ERISA
A decades-long
provisions allow billions of dollars in pension assets to escape full
challenge to EBSA’s
audit scrutiny. The Act generally requires every employee benefit
compliance program,
plan with more than 100 participants to obtain an audit of the plan’s
ERISA provisions
financial statements each year. However, an exemption in the law
allow billions of dollars
allowed auditors to perform “limited-scope audits.” These audits
in pension assets
excluded pension plan assets already certified by certain banks or
to escape full audit
insurance carriers and provided little to no confirmation regarding
scrutiny.
the actual existence or value of the assets.
In 2013 and 2014, we reported that as much as $3 trillion in pension assets—including an estimated
$800 billion in hard-to-value alternative investments held in otherwise regulated entities such as
banks—received limited-scope audits that provided weak assurance to participants regarding
the financial health of their plans. In 2019, the American Institute of Certified Public Accountants
updated its accounting standards related to these types of audits. The new standards replaced
limited-scope audits with audits from ERISA Section 103(a)(3)(C) and imposed new performance
requirements on plan management and auditors. In FY 2024, we plan to follow up on our previous
work on EBSA’s oversight of limited-scope audits.
Further, EBSA lacks the authority under the Federal Employees’ Retirement System Act to
effectively oversee hundreds of billions of dollars in federal employee Thrift Savings Plan
(TSP) assets.31 The Federal Employees’ Retirement System Act requires EBSA to conduct
regular compliance audits to determine whether the Federal Retirement Thrift Investment
Board, an independent agency, is fulfilling its fiduciary duties and properly safeguarding TSP
participants’ assets. However, 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 potentially
place at risk trillions of dollars in other ERISA-covered retirement plan assets.
Regarding resource constraints, EBSA needs to focus its limited available resources on
investigations that are most likely to result in the prevention, detection, and correction of ERISA
31 The total value of TSP assets fluctuates over time and is affected by market volatility.
24 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
violations. This is particularly important given the number of benefit plans EBSA oversees
relative to the number of investigators it employs.
Maintaining the Integrity of Foreign Labor Certification Programs
The DOL foreign labor certification (FLC) programs are intended to permit U.S. employers to
hire foreign workers to meet their workforce needs while protecting U.S. workers’ jobs, wages,
and working conditions. DOL’s administration of FLC programs under current laws has been a
concern for the OIG for decades. Our work has shown these visa programs—in particular the
H-1B program for workers in specialty occupations—to be susceptible to significant fraud and
abuse from perpetrators, including immigration agents, attorneys, labor brokers, employers, and
organized criminal enterprises. Over the last decade, the OIG, along with federal partners, has
conducted approximately 160 criminal investigations related to fraud in FLC programs. Of particular
concern, OIG investigations have uncovered criminal misuse of FLC programs to engage in human
trafficking—with victims being exploited for economic gain.
As we have reported since 2003,32 DOL continues to have limited authority over the H-1B program
and permanent employment certification program (PERM), which challenges the goal of protecting
the welfare of the nation’s workforce. The statute limits DOL’s ability to deny H-1B applications
and to investigate potential violations. Specifically, DOL may only deny incomplete and obviously
inaccurate H-1B applications and has only limited authority to conduct H-1B investigations in
the absence of a complaint. Without statutory authority, the Department generally cannot verify
employers’ attestations to the H-1B certifications unless a complaint is filed or the Department
utilizes a Secretary-initiated investigation.
As foreign workers are generally 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. The PERM
program itself is persistently vulnerable to employers not complying with its qualifying criteria.
Therefore, both the PERM and H-1B programs remain prone to fraud. With various new DOL rules
going into effect since 2003, including implementing employer self-attestation programs, there
have been opportunities for the PERM, H-2A, and H-2B visa programs to change. However, DOL
has identified instances in which employers are not complying with the conditions of employment,
thereby reinforcing how susceptible these programs are to fraud.
32 Overview and Assessment of Vulnerabilities in the Department of Labor’s Alien Labor Certification Programs,
Report No. 06-03-007-03-321 (September 30, 2003), available at:
https://www.oig.dol.gov/public/reports/oa/2003/06-03-007-03-321.pdf; and Overview of Vulnerabilities and
Challenges in Foreign Labor Certification Programs, Report No. 06-21-001-03-321 (November 13, 2020), available
at: https://www.oig.dol.gov/public/reports/oa/2021/06-21-001-03-321.pdf
Semiannual Report to Congress | October 1, 2023–March 31, 2024 25
Significant Concerns
FLC vulnerabilities have also been exploited
to facilitate labor trafficking, a type of human
trafficking. For example, in an ongoing OIG
investigation33, 15 individuals have pled guilty
and 8 individuals have been sentenced to date
as part of a federal racketeering conspiracy,
which victimized Mexican agricultural workers
admitted to the United States under the H-2A
temporary visa program. The investigation
revealed the conspirators committed multiple
offenses, including subjecting H-2A workers to
forced labor, harboring and concealing workers,
visa fraud, and fraud in foreign labor contracting.
The conspirators used coercive means to obtain
thousands of hours of physically demanding
agricultural labor from the victimized H-2A
workers, all for lesser pay. The coercive
means used included confiscating the workers’
passports; subjecting the workers to crowded,
unsanitary, and degrading living conditions;
isolating the workers and limiting their ability to
interact with anyone other than employees; and
subjecting workers to debt manipulation.
In some instances, employers commit FLC fraud
to engage in forced labor or labor trafficking.
Engaging in the FLC process allows prospective
employers to recruit 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
33 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
26 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
control/compel labor and services by: holding their 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. Often, the goal is to use the exploited
work force to increase employer wealth. These case examples illustrate how criminals exploit
weaknesses in the FLC programs to commit even more serious crimes, such as forced labor and
labor trafficking. Therefore, it is crucial that the Department do all it can to ensure the integrity of
these programs.
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. The pandemic’s impact on the workforce highlighted the
importance of these programs in assisting job seekers and employers in finding and filling available
jobs and assisting workers in developing the right skills to fill new job openings. The Department’s
ability to obtain accurate and reliable data to measure, assess, and make decisions regarding the
performance of grant recipients, contractors, and states in meeting the programs’ goals is critical.
Our audit report from September 2020 found that, although ETA had data to determine whether or
not participants were employed after exiting grant-funded training programs, ETA 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.
As expressed in a March 2022 advisory report, the OIG continues to be concerned about three
areas in particular where our body of work has identified weaknesses: (1) awarding grants,
(2) reviewing grant recipients’ use of funds, and (3) measuring grant recipient performance.
While ETA took action to address many prior years’ findings and recommendations related to
eligibility, effectiveness, and compliance and monitoring, it must also proactively monitor key
areas and continue to assess for these weaknesses to ensure they do not reoccur.
In September 2023, we reported34 ETA needs to improve its oversight of grant recipients and
sub-recipients35 in the State of New Jersey to ensure that grant funds serve their intended
34 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
35 A sub-recipient is a non-federal entity that receives a sub-award from a pass-through entity to carry out part of a
federal program. It does not include an individual who is a beneficiary of the program.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 27
Significant Concerns
purposes. We found ETA did not ensure recipients effectively: (1) used over $100 million to serve
the intended population; (2) enrolled eligible individuals in the grant programs, costing $96,580 in
training services; and (3) complied with federal requirements when paying $168,460 in services.
We also questioned $6.9 million in grant funding because the sub-recipients could not show how
these funds were used.
The OIG is also concerned about the Department’s ability to ensure its investments into Registered
Apprenticeships develop new pathways to good-quality jobs. DOL received an estimated $285 million
for FY 2024 and requested $335 million for the Registered Apprenticeship Program in FY 2025.
However, a September 2021 audit of the American Apprenticeship Initiative Grant Program—
which aimed in part to expand Registered Apprenticeships—found systemic weaknesses in the
execution of the grants, as well as in the planning and awarding processes. The OIG continues to be
concerned that challenges exist within the Registered Apprenticeship Program.
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 due to ongoing issues with
on-campus violence. In Program Year 2022, Job Corps centers reported almost 1,300 on-campus
assaults. Preventing on-campus violence and other potentially 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, is also an emerging concern within the Job Corps
program. In May 2023, Job Corps reported that 6 of 11 student deaths in Program Year 2022 to
date were suspected unintentional drug overdoses, with 2 occurring on campus. Job Corps also
reported 64 positive drug tests for fentanyl during the first 9 months of Program Year 2022, up
significantly from 4 years earlier when there were only 11 positive drug tests for fentanyl despite a
higher student population. Our analysis of Job Corps data for Program Year 2022 also identified
5 students and 1 staff who were administered Narcan36 after being found unresponsive and who
subsequently recovered from a suspected drug overdose. In addition, we identified 6 students who
were caught in possession of fentanyl.
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.
In that audit, we found that center personnel frequently attributed student and staff safety concerns
to mental health or substance abuse, or both.
36 Narcan (generic Naloxone) is a lifesaving emergency treatment that can reverse the effects of an opioid overdose
if administered quickly.
28 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
OIG audits from 2015 and 2017 found that some Job Corps centers failed to report and investigate
serious misconduct, such as drug abuse and assaults. The audits also determined that some Job
Corps centers downgraded incidents of violence to lesser infractions, creating an unsafe environment
for students and staff. The follow-up work we completed in December 2017 and our review of Job
Corps’ corrective actions showed Job Corps has taken steps to improve center safety and security
by establishing stronger internal controls and security measures, including the installation of security
cameras, perimeter fencing, and better lighting at centers. However, concerns continue.
Job Corps’ participants can range in age from 16 to 27 years old.37
The OIG also
The significant age range poses a number of challenges. Given the
continues to monitor
occurrence of sexual assaults and harassment on center campuses,
various safety
there is an inherent risk with having adults cohabitate with minors.
initiatives and actions
The OIG will soon resume an audit focused on whether Job Corps
taken by Job Corps
ensured the safety of and mitigated program disruptions involving
to keep students and
its minor students. The OIG also continues to monitor various safety
staff safe.
initiatives and actions taken by Job Corps to keep students and staff safe.
Managing Medical Benefits in the Office of Workers’ Compensation Programs
The OIG has concerns about the Office of Workers’ Compensation Programs’ (OWCP) ability to
effectively manage the use and cost of pharmaceuticals in the Federal Employees’ Compensation
Act (FECA) program and about rising home health care costs in the Energy Employees
Occupational Illness Compensation Program Act (Energy) program. The Department needs to
ensure the medical benefits it provides to FECA claimants and energy workers are safe, effective,
medically necessary, and economical.
Our audit work in the FECA program continues to identify concerns with OWCP’s management of
pharmaceuticals. In March 2023,38 we reported OWCP did not effectively manage pharmaceutical
spending in the FECA program from FY 2015 through FY 2020. Specifically, OWCP did not pay the
best available prices for prescription drugs resulting in up to $321 million in excess spending during
the audit period. OWCP also did not effectively monitor pharmaceutical policy changes to ensure
implementation, which resulted in claimants receiving thousands of inappropriate prescriptions and
potentially lethal drugs, including 1,330 prescriptions for fast-acting fentanyl after issuing a policy
that restricted its use. We also found OWCP failed to timely identify and address emerging issues
37 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.
38 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
Semiannual Report to Congress | October 1, 2023–March 31, 2024 29
Significant Concerns
and did not perform sufficient oversight of prescription drugs that are highly scrutinized and rarely
covered in workers’ compensation programs.
To strengthen its management of FECA’s pharmaceutical program, OWCP needs to implement
processes that ensure competitive prices for prescription drugs (see Figure 2), improve its
monitoring of pharmaceutical policy changes, and proactively identify emerging issues before they
become critical problems.
Figure 2: Tools to Ensure Competitive Prices for Prescription Drugs
Source: OIG graphic representation of Harper, Rains, Knight & Company, P.A. analysis
In March 2021, consistent with our prior audit recommendations, OWCP implemented a pharmacy
benefit manager39 responsible for FECA pharmaceutical transactions, including pricing for
prescription drugs. In addition, OWCP is in the process of expanding pharmacy benefit manager
coverage to the Energy and Black Lung Benefits programs. While using a pharmacy benefit
manager may improve OWCP’s management of pharmaceuticals, it does not relieve OWCP from
its management responsibilities. OWCP needs to provide adequate oversight over the pharmacy
benefit manager to ensure the pharmaceutical benefits it provides are safe, effective, medically
39 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.
30 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Significant Concerns
necessary, and economical. We plan to conduct follow-up work focusing on how effectively
OWCP’s pharmacy benefit manager reduced opioid-related risks, pharmaceutical costs, and fraud.
In the Energy program, with an aging claimant population and an increased demand for home health
care services, there is a risk of providers exploiting these benefits through unethical practices. Since
2010, home and residential health care costs paid by the Energy program have grown from almost
$100 million to more than $860 million, representing approximately 82 percent of total medical
benefits paid by the program in FY 2022. OWCP needs to continue its efforts to analyze home
health care billing for abusive practices and to identify and refer allegations involving potential fraud
or abuse to the OIG for further investigation.
Ensuring the Solvency of the Black Lung Disability Trust Fund
Miners and their dependent survivors receive lifetime benefits when awarded under the Black
Lung Benefits Act. Mine operators pay these benefits when possible, and the Black Lung
Disability Trust 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 2023 Agency Financial Report, the Trust Fund had to borrow approximately $2.73 billion to cover
its expenditures, which included debt and interest payments. As of September 30, 2023, the Trust
Fund was carrying close to a $6.36 billion deficit balance, which is projected to grow to $12.64 billion
(in constant dollars) by September 30, 2048.
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.
Managing and Securing Data and Information Systems
We remain concerned about the Department’s ability to manage and secure its data and information
systems. The Department and its program agencies depend on reliable and secure IT systems
to perform their mission critical functions. In carrying out their missions, the agencies obtain and
create vast amounts of information and data. Included in these data are the PII and personal health
information of the public, including federal employees. The Department moved to an IT shared
Semiannual Report to Congress | October 1, 2023–March 31, 2024 31
Significant Concerns
services model that centralized IT for approximately 70 percent of its information systems under
the Office of the Assistant Secretary for Administration and Management. While we have seen
some improvements in the Department’s IT management, we continue to have concerns with its
governance structure and information security program.
Fundamentally, we continue to be concerned that DOL has not fully empowered the Chief
Information Officer (CIO) position to ensure the Department’s IT governance is effectively
implemented. Specifically, the CIO’s authority is limited by both structural design and lack of
representation in enterprise level discussions. DOL’s CIO reports to the Assistant Secretary for
Administration and Management—not the Secretary or Deputy Secretary as required by law—and
does not have sufficient authority or representation on key senior level management boards.
In addition, we continue to have concerns with the Department’s information security program in the
following areas:
• cybersecurity oversight,
• supply chain,
• cloud/third-party,
• end user/remote security, and
• emerging technology and security requirements, such as Artificial Intelligence and zero trust
architecture.
Securing the Department’s information systems remains a concern as we continue to identify
recurring deficiencies in the Department’s efforts to manage and implement security controls
throughout its information security program.40 While the Department has moved information
systems to its IT shared services model to improve management and security of the systems, the
Department has not adequately implemented information security controls and technology tools
required to manage and monitor IT security. Further, we are still concerned that the remaining
systems that are not part of the IT shared services environment are not receiving the governance
and oversight required to sufficiently secure all of DOL’s data and information systems.
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.
40 Under the Federal Information Security Modernization Act of 2014, the OIG is required to perform annual
independent evaluations of the Department’s information security program and practices. These annual reports
have consistently identified such deficiencies. For the most recent, see: FY 2023 FISMA DOL Information Security
Report: Making Improvements Toward an Effective Program, Report No. 23-24-001-07-725 (December 06, 2023),
available at: https://www.oig.dol.gov/public/reports/oa/2024/23-24-001-07-725.pdf.
32 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree
Benefit Programs
Unemployment Insurance Programs
Office of Workers’ Compensation Programs
Worker and Retiree Benefit Programs
Unemployment Insurance Programs
Enacted more than 80 years ago as a federal-state partnership, the unemployment insurance program
is the Department’s largest income-maintenance program. This multi-billion-dollar program provides
unemployment benefits to eligible workers who become unemployed through no fault of their own.
The program is generally administered by states with oversight from DOL’s Employment and Training
Administration (ETA).
A Review of Pandemic Unemployment Insurance Relief and Its Impact on Six
Different U.S. Communities
The Pandemic Response Accountability Committee (PRAC) led a two-phased review to identify
the federal funds distributed to local communities41 across the United States in response to the
COVID-19 pandemic as of September 30, 2021, and to determine if the spending aligned with
program goals. In support of this review, the OIG conducted an evaluation of DOL’s UI response to
the COVID-19 pandemic.
We specifically evaluated the DOL programs that expanded UI benefits for workers impacted
by the pandemic and assessed the recipients’ experiences. From March 27, 2020, to
September 6, 2021, we identified over 33,400 UI beneficiaries across the six communities.
Collectively, they received over $516 million from the following three key CARES Act UI programs:
PUA, Federal Pandemic Unemployment Compensation (FPUC), and Pandemic Emergency
Unemployment Compensation (PEUC).
To assess benefit recipients’ experiences with the CARES Act UI programs, OIG investigators
traveled to the six communities and surveyed a sample of claimants. We found satisfaction with
the CARES Act UI programs was high, claimants also generally felt the pandemic programs had a
positive impact on their ability to meet their needs, were sufficient to pay for basic necessities, and
were fair and reasonable.
However, we found claimants did experience challenges accessing regional UI offices for questions
and assistance. They also encountered various difficulties throughout the process, including claim
denials, issues with the certification process, completing the application, and confusion regarding
program eligibility and weekly certifications.
41 The PRAC selected six locations for review across three types of geographic areas (two small-to-medium
sized cities, two rural counties, and two tribal areas). The following six locations were selected: Springfield,
Massachusetts; Coeur d’Alene, Idaho; Marion County, Georgia; Sheridan County, Nebraska; White Earth
Reservation in Minnesota; and Jicarilla Apache Reservation in New Mexico.
34 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree Benefit Programs
In addition, at the time we conducted the surveys, some claimants reported they still experienced
difficulty in the labor market, with 21 percent of claimants reporting they were not currently working
for pay, and 37 percent reporting they were unable to find employment before benefits ran out.
With the passage of the CARES Act and subsequent pandemic
We identified 7.6 percent of
legislation, pandemic-related UI programs became a target
the claims submitted to the
for fraud. During our review of the benefits paid in the six
OIG for the six communities
communities and our analyses of fraud indicators, we identified
as potentially fraudulent,
7.6 percent of the claims submitted to the OIG for the six
totaling approximately
communities as potentially fraudulent, totaling approximately
$46.4 million.
$46.4 million.42
For more information, go https://www.oig.dol.gov/public/reports/oa/2024/19-24-002-03-315.pdf,
Report No. 19-24-002-03-315 (March 28, 2024).
Washington Woman Sentenced to 5 Years in Prison for CARES Act Fraud
On March 5, 2024, Paradise Williams was sentenced to 5 years in prison and ordered to pay more
than $2 million in restitution for orchestrating a wide-ranging fraud scheme which involved the theft
of more than $3.3 million from federally funded pandemic assistance programs.
From June 2020 to February 2022, Williams personally submitted more than 125 fraudulent
applications for CARES Act unemployment benefits, U.S. Department of Treasury Emergency
Rental Assistance Program (ERAP) funds, SBA’s PPP loans, and SBA EIDL. She enlisted more
than 50 associates, including her five co-defendants, to obtain more than $3.3 million by posing
as fake tenants, landlords, and small business owners in need of assistance. In submitting these
applications to federally funded pandemic assistance programs, Williams, among other actions,
created falsified bank statements, tenant ledgers, and landlord attestations.
Upon receipt of the fraudulently obtained funds, Williams and her associates methodically laundered
the funds through cash withdrawals, wire transfers, and expensive luxury purchases. She personally
received more than $2 million in fraudulent proceeds and spent the money on luxury cars, lavish
trips, cosmetic surgery, jewelry, and designer goods. In addition to fraudulently obtaining over
$700,000 directly from her submission of ERAP applications, Williams also received more than
$1.2 million in kickback payments that she demanded from her associates for facilitating the various
fraudulent schemes.
42 Prior to the release of this report, the potentially fraudulent claims were referred to the OIG’s Office of
Investigations to assess and determine if the claims warrant investigation. If the claims did not warrant investigation,
we referred the claims to the appropriate SWA.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 35
Worker and Retiree Benefit Programs
Overall, the fraud ring sought to steal more than $6.8 million in pandemic benefits from nearly every
major pandemic assistance program
This is a joint investigation with the FBI and the SBA-OIG. United States v. Williams et al.
(W.D. Washington)
California Defendants Sentenced to 86 Months in Prison and Ordered to Pay in
Excess of $2 Million in Unemployment Insurance Fraud Scheme
On October 16, 2023, Robert Campbell Jr. was sentenced to 68 months in federal prison and
ordered to pay more than $2.1 million in restitution for orchestrating a pandemic-related UI scheme.
Simone Gueringer, a co-conspirator, was sentenced on October 2, 2023, to 18 months in prison and
ordered to pay approximately $204,000 in restitution.
From March 2020 to July 2021, Campbell, Gueringer, and other co-conspirators used the PII of
others to include names, dates of birth, and Social Security numbers in an effort to file fraudulent UI
applications with the California Employment Development Department (EDD), which receives federal
funding and administers the state’s UI program.
Many of the fraudulent claims were made on behalf of ineligible out-of-state claimants and on behalf
of people ineligible for benefits because they were in prison.
The fraudulent applications falsely stated the claimants had prior annual incomes of $42,000 and
were self-employed individuals whose jobs were adversely impacted when salons and barbershops
closed during the COVID-19 pandemic. The applications listed mailing addresses with locations
chosen and controlled by Campbell, Gueringer and their co-conspirators. Once the applications
were approved, debit cards were mailed to those addresses.
In total, Campbell, Gueringer, and others caused 174 fraudulent applications to be filed with EDD,
125 of which were paid, resulting in total losses of more than $2.1 million.
This is a joint investigation with Homeland Security Investigations (HSI), the United States Secret
Service, the United States Postal Inspection Service (USPIS), the California Department of
Corrections and Rehabilitation’s Special Services Unit, and the California EDD. United States v.
Campbell Jr. et al. (C.D. California)
Detroit Men Sentenced in Pandemic Unemployment Insurance Fraud and Drug
Distribution Scheme
On January 24, 2024, Robert Lampkin was sentenced to 180 months in prison and ordered to pay
36 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree Benefit Programs
more than $2.1 million in restitution, joint and several with his co-conspirator, for his role in an UI and
drug distribution scheme.
On January 16, 2024, Brenden Lockridge was sentenced to 72 months in prison and ordered to pay
more than $2.1 million in restitution, joint and several with a co-conspirator, for his role in a UI fraud
and drug distribution scheme.
From March 2020 and continuing through April 2021, Lockridge and Lampkin engaged in a
conspiracy to file fraudulent UI claims in several states. Using stolen PII from various victims,
Lockridge and Lampkin filed fraudulent UI claims and received benefits to which they were not
entitled. At least $2.1 million of UI benefits were fraudulently received by both individuals involved in
the scheme.
In April 2021, in a separate scheme, Lockridge and Lampkin possessed with intent to distribute
more than 50 grams of methamphetamine.
This is a joint investigation with the Drug Enforcement Agency (DEA). United States v. Lampkin et al.
(E.D. Michigan)
Maryland Man Sentenced to 41 Months in Prison for Fraudulently Obtaining More
Than $2 Million in COVID-19 Pandemic Relief Funds
On December 14, 2023, Mohamed Kamara was sentenced to 41 months in prison and ordered
to pay restitution of more than $2 million for his role in defrauding multiple SWAs and the SBA of
federal pandemic relief programs, including the UI program and SBA’s EIDL program.
Between January and September 2020, Kamara submitted numerous fraudulent applications to
New Jersey and six other states for UI benefits by using the identities and PII of individuals and
entities without their knowledge or consent. As a result, the SWAs deposited more than $1 million in
fraudulently obtained UI benefits into a bank account he controlled.
Kamara also submitted fraudulent EIDL applications to the SBA by using the identities of individuals
and entities without their knowledge and consent. Kamara caused the SBA to approve the
fraudulent applications and sent the proceeds to fraudulent bank accounts he opened. Once the
proceeds were received, he deposited or attempted to deposit checks from the fraudulent accounts
into accounts in his name. In total, Kamara and his co-conspirators caused the SBA to provide more
than $750,000 in fraudulent EIDLs.
This is a joint investigation with the FBI. United States v. Mohamed Kamara (D. New Jersey)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 37
Worker and Retiree Benefit Programs
Michigan State Employee Sentenced in Unemployment Insurance Fraud Scheme
On February 6, 2024, Antonia Brown, a former State of Michigan Unemployment Insurance Agency
(MUIA) employee, was sentenced to 21 months in prison for her role in an UI fraud scheme. She
was also sentenced to 36 months of supervised release following her prison sentence and was
ordered to pay more than $549,200 in restitution for her involvement in a multimillion-dollar scheme
to defraud the federal government and the State of Michigan. Brown is the first of three individuals
sentenced in this case.
Beginning in May 2020 and continuing through at least September 2021, Brown and her co-
conspirators, Angela Johnson and Kiannia Mitchell, collectively conspired to defraud the federal
government and State of Michigan through the facilitation of numerous UI claims. Brown took
actions on numerous fraudulent claims that were accessed and/or filed by Johnson and Mitchell,
which resulted in unauthorized payments of those claims. The investigation found that Brown
received financial kickbacks for those actions from Johnson and Mitchell as well as from some of
the claimants themselves. Evidence obtained during the course of the investigation revealed that
Brown tried to conceal those payments as jewelry payments to her side business. The investigation
also showed that the scheme involved approximately 123 UI claims totaling more than $3 million
dollars in benefits paid, $1.6 million of which was paid after Brown’s unauthorized actions. Per a plea
agreement between Brown and the U.S. Attorney’s Office, Brown was held accountable for more
than $549,250 in unauthorized and fraudulent UI payments.
This was a joint investigation with the U.S. Department of Homeland Security-Office of Inspector
General (DHS-OIG), the FBI, and the MUIA. United States v. Antonia Brown et al. (E.D. Michigan)
Several Maryland Residents Convicted and Sentenced in $1.5 Million Pandemic
Unemployment Insurance Fraud Scheme
Between November 2023 and March 2024, five defendants pled guilty and several defendants were
sentenced for their roles in a pandemic-related UI fraud scheme that defrauded multiple SWAs out
of more than $1.5 million in COVID-19 UI benefits through the submission of fraudulent claims.
During this period, the following actions occurred:
• Michael Akame Ngwese Ay Makoge, aka “Hype” and “2Hype,” pled guilty on November 14,
2023, to conspiracy to commit wire fraud and aggravated identity theft for his involvement in the
fraud scheme. Makoge was sentenced on February 29, 2024, to 53 months in federal prison and
ordered to pay more than $2 million in restitution, jointly and severally with his co-conspirators, to
affected SWAs and individually forfeit more than $297,000 in fraudulent proceeds.
38 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree Benefit Programs
• Dementrous Von Smith, aka “Meecho” and “El Meecho,” was sentenced on December 14, 2023,
to 53 months in federal prison and ordered to pay more than $2 million in restitution, jointly and
severally with his co-conspirators, to affected SWAs and individually forfeit more than $345,000
in fraudulent proceeds.
• Christopher Yancy, aka “Lil Bhris” and “Lil Chris,” and Stephawn Watson, aka “O-Dawg”, both
pled guilty on January 4, 2024, to conspiracy to commit wire fraud, wire fraud, aggravated
identity theft, as well as illegal possession of machine guns and illegal receipt of a firearm by a
person under indictment, respectively, for their involvement in the criminal activity.
• Christian Malik Adrea, aka “Leak” and “Lil Leak,” pled guilty on February 2, 2024, to conspiracy
to commit wire fraud, wire fraud, and aggravated identity theft for his role in the fraud scheme.
• Nadine Mahoro Mwamikazi pled guilty on March 5, 2024, to conspiracy to commit wire fraud for
her role in the fraud scheme.
From March 2020 to October 2021, Makoge
and his co-conspirators impersonated victims
to submit fraudulent UI claims to the SWAs in
Maryland and California. As part of the scheme,
Makoge and his co-conspirators obtained the
PII of numerous victims, which they then used
to prepare and submit fraudulent applications for
UI benefits. The fraudulent applications caused
financial institutions to load UI benefits onto debit
cards and mail the cards to physical addresses,
which were provided and monitored by Makoge
and the co-conspirators.
The investigation further revealed numerous
text messages between Makoge and his co-
conspirators exchanging the PII of victims and
discussing the execution of the UI fraud scheme.
Further, Makoge and his co-conspirators made OIG agents and our law enforcement partners
numerous ATM withdrawals using the fraudulently recovered, among other items, more than $9,000 in
obtained debit cards. cash during the execution of a UI fraud search warrant.
This is a joint investigation with the USPIS, HSI, the Bureau of Alcohol, Tobacco, Firearms and
Explosives, the Maryland State Police, and the Anne Arundel County (Maryland) Police Department.
United States v. Michael Akame Ngwese Ay Makoge et al. (D. Maryland)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 39
Worker and Retiree Benefit Programs
Two Nigerian Nationals Sentenced for Stealing Unemployment Insurance Benefits
On October 10, 2023, Nigerian nationals Quazeem Owolabi Adeyinka and Ayodeji Jonathan
Sangode were sentenced to 26 months and 14 months in prison, respectively, for their roles in a UI
fraud conspiracy.
Between June 2020 and July 2021, Adeyinka, Sangode, and others participated in a conspiracy to
submit fraudulent UI and PUA claims to the State of California. More than 200 individual applications
were filed with the California EDD indicating that the claimants’ address was a Maryland apartment
that the co-defendants shared.
During the scheme, the conspirators obtained the PII of persons who were ineligible for UI or PUA
benefits or who did not authorize the conspirators to act on their behalf with respect to applying
for such benefits. The PII included names, dates of birth, and Social Security numbers. The
conspirators used the PII to submit dozens of fraudulent UI and PUA claims to EDD under the
claimants’ identities without the claimants’ authorization.
Adeyinka was personally involved in approximately $793,000 in attempted losses while Sangode
was linked to approximately $752,000 in attempted losses.
This is a joint investigation with the DHS-OIG, the FBI, and the California EDD. United States v.
Adeyinka et al. (E.D. California)
Three Florida Individuals Sentenced for Conspiracy to Commit Bank Fraud, Wire
Fraud, and Mail Fraud
In January and February 2024, Franklin Brown, Malik Wright, and Samuel Bush III were sentenced
after they pled guilty for their roles in defrauding the SWAs of California and Massachusetts through
a PUA fraud scheme with losses totaling more than $1.1 million. Wright was sentenced to 41 months
in prison, while Brown and Bush were sentenced to 33 months in prison. In addition, they were
ordered to pay joint restitution of more than $643,000, with Bush ordered to pay $6,000 individually.
As part of the conspiracy, the three defendants submitted false and fraudulent applications to the
SWAs causing them to issue UI benefit payments in the form of pre-paid debit cards. The cards
were then mailed to a Florida address belonging to Brown. Bush III then made telephone calls
to financial institutions pretending to be the real cardholders in order to activate the fraudulently
obtained debit cards. Bush III subsequently used the proceeds to purchase goods and services for
his own benefit while Wright and Brown used the fraudulently obtained pre-paid debit cards to make
multiple cash withdrawals at ATMs in South Florida.
40 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree Benefit Programs
Over the course of the conspiracy, the SWAs approved at least 92 fraudulent UI claims resulting in
the disbursement of more than $1.1 million.
This investigation is being worked jointly as part of the Miami COVID-19 Strike Force with the
DHS-OIG, the FBI, and the USPIS. United States v. Travis Wright et al. (S.D. Florida)
Nevada Man Sentenced to Nearly 5 Years in Prison for Unemployment
Insurance Fraud
On December 12, 2023, Terence Aubrey Larker was sentenced to 4 years and 10 months in prison
for mail fraud and aggravated identity theft for his role in a scheme to defraud the UI program during
the COVID-19 pandemic.
Beginning in April 2020 and continuing through at least October 2020, Larker perpetrated a mail
fraud and identity theft scheme that targeted the UI program administered by the California’s
EDD. Under the CARES Act, the EDD was responsible for administering UI benefits for qualifying
residents who were unemployed due to the COVID-19 pandemic. Larker obtained the PII of more
than 80 individuals and filed fraudulent UI claims in their names. EDD approved many of these
applications and mailed benefits in the form of pre-paid debit cards to addresses under Larker’s
control, including at least 24 debit cards to his home address. Once received in the mail, Larker
activated the cards and spent the benefits on himself, often appearing in ATM surveillance footage
while withdrawing large amounts of cash from these cards. In total, Larker’s conduct resulted in the
EDD and U.S. government paying out more than $1.1 million in fraudulent claims.
This was a joint investigation with the FBI, the California EDD, and the DHS-OIG. United States v.
Terence Aubrey Larker (E.D. California)
Michigan Woman Sentenced in Unemployment Insurance Fraud Scheme
On December 1, 2023, Francisca Juarez was sentenced to 63 months in prison and ordered to pay
more than $1 million in restitution, joint and several with her co-conspirators, for her role in an UI
fraud scheme. Juarez is the last of three individuals sentenced in this case.
Between 2020 and 2022, Francisca Juarez and her co-conspirators participated in a scheme to file
fraudulent UI claims in Michigan and elsewhere. The fraudulent UI claims were filed for individuals
ineligible to receive benefits. The co-conspirators notified Francisca Juarez that the claims needed
approval, and Francisca Juarez then requested that her mother, co-defendant Adelita Juarez, who
was a UI examiner for the State of Michigan, process the fraudulent claims to ensure they were
paid. Francisca Juarez received kickback payments from her co-conspirators in connection with
each fraudulent claim.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 41
Worker and Retiree Benefit Programs
This is a joint investigation with the FBI, the MUIA, and the DHS-OIG. United States v. Juarez et al.
(W.D. Michigan)
Two Virginia Women Sentenced for Roles in Pandemic Unemployment Insurance
Fraud Conspiracy
In November 2023, two defendants were sentenced for their roles in a conspiracy to fraudulently obtain
pandemic-related UI benefits by using the PII belonging to both Virginia Department of Corrections
(VA DOC) inmates and identity theft victims. During this period, the following actions occurred:
• Jenyce Williams was sentenced on November 9, 2023, to 120 months in prison and ordered to
pay more than $802,000 in restitution to the Virginia Employment Commission (VEC), jointly and
severally with her co-defendants;
• Darla Dickens was sentenced on November 17, 2023, to 45 months in prison and ordered to pay
restitution to VEC of approximately $260,000, jointly and severally with her co-defendants.
From approximately May 2020 through November 2020, Williams, Dickens and Alisha Mayfield, a third
co-defendant, conspired to use the PII (including names, dates of birth, and Social Security numbers)
belonging to others to file fraudulent UI claims with VEC during the COVID-19 pandemic. Williams’
role in the conspiracy was to submit fraudulent UI applications and complete weekly certifications
using PII of either VA DOC inmates or out-of-state individuals who did not authorize the filings and had
no knowledge of the fraud scheme. Dickens’ role in the conspiracy was to provide the PII of various
VA DOC inmates, who she or others had recruited into the scheme, to her co-conspirators so that
they could file fraudulent UI claims in the inmates’ names. In order for the fraudulent UI claims to be
approved, Williams and Mayfield entered false information on fraudulent UI applications. On a weekly
basis, Williams and Mayfield submitted false certifications to ensure UI benefits would continue to be
paid. Williams elected for most of the UI benefits to be paid through prepaid debit cards, which were
mailed to her address, Mayfield’s address, or other residences specifically selected to avoid raising
suspicion from having multiple debit cards mailed to any one address.
As a result of the conspiracy, VEC approved the payment of approximately $479,000 in UI benefits
on behalf of individuals who were not entitled to receive such benefits, including VA DOC inmates
and non-inmates.
This is a joint investigation with the DHS-OIG and the USPIS. United States v. Alisha Mayfield et al.
(E.D. Virginia)
42 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree Benefit Programs
Office of Workers’ Compensation Programs
The Office of Workers’ Compensation Programs (OWCP) administers four major workers’ compensation
programs: Federal Employees’ Compensation, Energy Employees Occupational Illness Compensation
(Energy), Coal Mine Workers’ Compensation (Black Lung Benefits), and Longshore and Harbor Workers’
Compensation.
FECA is the largest of the programs and provides workers’ compensation coverage to millions of federal,
postal, and other employees for work-related injuries and illnesses. Benefits include wage replacement,
payment for medical care, vocational rehabilitation, and survivor benefits.
Medical Marketer Convicted for His Role in a $55 Million Compounding
Fraud Scheme
On October 26, 2023, at the conclusion of a two-week trial, a federal jury in the Northern District
of Texas convicted Quintan Cockerell of one count of conspiracy to defraud the United States, one
count of receiving unlawful kickbacks, and one count of money laundering. Cockerell was a medical
marketer who participated in a $55 million fraud conspiracy involving federal health care programs.
Cockerell worked with others to create and market
expensive, custom-tailored, compounded medications
for individual patient needs. Instead of customizing the
medications based on the needs of the patient, a local
pharmacy designed formulations to maximize health care
program reimbursements from various federal programs,
including FECA, regardless of patient need or medical
efficacy. Cockerell received illegal kickback payments
from pharmacy owners and others who both recruited
area doctors to write prescriptions for the expensive
compounded medications and created opportunities for
doctors who wrote the prescriptions to the pharmacy to
profit from the pharmacy’s operations. Cockerell spent
the proceeds of the scheme on expensive vacations, trips
on private jets, and a yacht charter.
This is a joint investigation with the FBI, the Defense Criminal Investigative Service (DCIS), the
U.S. Department of Health and Human Services (HHS)-OIG, and the U.S. Department of Veterans
Affairs (VA)-OIG. United States v. Hall et al. (N.D. Texas)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 43
Worker and Retiree Benefit Programs
Former Pharmacy Owner Sentenced to Prison and Ordered to Pay More Than
$6.4 Million in Restitution
On October 4, 2023, Christopher R. Parks, former owner of compounding pharmacies OK
Compounding, LLC and One Stop RX, LLC, in Oklahoma, was sentenced to 18 months in
prison and ordered to pay more than $6.4 million in restitution, with more than $700,000
payable to the OWCP.
From November 2012 through June 2019, Parks paid physicians kickbacks to refer their patients’
compounding prescriptions to his pharmacies. He was aware that federal health care programs, to
include the FECA program, paid for some of the compounding prescriptions. In furtherance of the
scheme, Parks paid the prescribing physicians through bank accounts he controlled and attempted
to disguise the kickback payments by entering into agreements with the physicians for purported
medical studies.
This is a joint investigation with the FBI, the DCIS, the Internal Revenue Service-Criminal
Investigation (IRS-CI), the U.S. Postal Service (USPS)-OIG, the VA-OIG, and the HHS-OIG.
United States v. Christopher R. Parks (N.D. Oklahoma)
Several Individuals Convicted and Sentenced in Health Care Fraud Scheme
Involving Kickbacks
Between December 2023 and March 2024, two defendants pled guilty and three others were
sentenced for their roles in a health-care fraud kickback scheme involving prescriptions made under
federal healthcare programs, including DOL’s OWCP.
During this period, the following actions occurred:
• On December 26, 2023, Mark Schneider, co-owner of Medoc Health Services (Medoc) pled
guilty to one count of conspiracy to solicit and receive kickbacks from pharmacies.
• On January 18, 2024, Cuong “Michael” Nguyen was sentenced to 10 months in prison
and ordered to pay more than $590,000 in restitution to the U.S. Government, including
approximately $286,000 to OWCP.
• On February 13, 2024, Michael Schneider pled guilty to one count of conspiracy to solicit
and receive kickbacks involving federal healthcare programs including the OWCP, TRICARE,
and Medicare.
44 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker and Retiree Benefit Programs
• On February 28, 2024, Kevin Kuykendall was sentenced to 36 months in prison while Sabrina
Kuykendall was sentenced to serve probation for 36 months. Both Kuykendalls were ordered to
pay restitution of approximately $4.4 million jointly and severally with other defendants, including
more than $2.4 million to OWCP.
From approximately March 2015 to October 2015, Mark Schneider, Michael Schneider, Kevin
Kuykendall and Sabrina Kuykendall engaged in a conspiracy to commit healthcare fraud by
knowingly soliciting and receiving kickbacks in exchange for referrals of prescriptions under
federal healthcare programs. Medoc, owned by Mark Schneider and Kevin Kuykendall, entered
into relationships with doctors who wrote prescriptions for various medications, often including
compound pain creams that were sent to Total RX pharmacy, owned by Nguyen, for fulfillment
at Medoc’s direction. Nguyen allowed Michael Schneider to receive a purported salary and
commission on all prescriptions sent by Medoc to Total RX, which were paid for under federal
healthcare programs, including those administered by OWCP, as well as TRICARE and Medicare.
In furtherance of the scheme, the Schneiders and Kevin Kuykendall entered into operating and
contracting agreements in order to provide cover for the kickbacks and divert portions of money
paid to Michael Schneider as salary from Total RX. The money was later disbursed to Sabrina
Kuykendall and other co-conspirators of the scheme. Those agreements were intended to provide
a “cover” for funds Mark Schneider illegally obtained and shared with others through the kickback
scheme. Mark Schneider created fictitious entities and opened bank accounts to hide the illegal
kickbacks between Total RX and Medoc as salary payments to Michael Schneider.
Before claiming Michael Schneider as an employee, Nguyen turned over 50% control of Total RX
to the individuals who owned and controlled Medoc to maintain their lucrative business relationship.
This control provided Medoc with 75% of the net revenue from Total RX.
The various schemes perpetrated by the co-conspirators and Schneider caused a loss to federal
healthcare programs of more than $4 million.
This is a joint investigation with the FBI, the DCIS, the USPS-OIG, the HHS-OIG, U.S. Office of
Personnel Management-OIG, and the DOL-EBSA. United States v. Kuykendall et al. (N.D. Tex)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 45
Worker Safety, Health,
and Workplace Rights
Mine Safety and Health Administration
Worker Safety, Health, and Workplace Rights
Mine Safety and Health Administration
The federal Mine Safety and Health Act of 1977, as amended by the Mine Improvement and New
Emergency Response Act of 2006, charges the Mine Safety and Health Administration (MSHA) with
setting and enforcing standards to protect the health and safety of approximately 324,000 men and
women working in our nation’s mines.
COVID-19: MSHA DID NOT COMPLETE OR ACCURATELY REPORT
MANDATORY INSPECTIONS
Why OIG Conducted the Audit
The Federal Mine Safety and Health Act of 1977 requires
each underground mine to be inspected in its entirety at
least four times a year and each surface mine in its entirety
at least two times a year. On behalf of the U.S. Secretary of
Labor, MSHA conducts mandatory inspections to prevent
death, illness, and injury at mines and promote safe and
healthy work environments for miners.
The OIG has long-standing concerns regarding MSHA’s
operational risks associated with its mandatory inspections
program and how such risks impact MSHA’s mission to
protect the lives of miners.
What OIG Did
Based on these concerns, we performed this audit to determine the following:
Did MSHA complete mandatory safety and health mine inspections before and during the
COVID-19 pandemic?
We interviewed MSHA personnel, reviewed MSHA policies, analyzed 78,598 mandatory inspections
ending in FY 2018 through FY 2021, and evaluated MSHA’s inspection completion data.
48 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Worker Safety, Health, and Workplace Rights
What OIG Found
MSHA did not complete an estimated 1,589 mandatory safety and health mine inspections before
and during the COVID-19 pandemic. Specifically:
MSHA did not complete an estimated 1,589 mandatory mine inspections during FY 2018
through FY 2021 although it reported a nearly 100 percent completion rate. These were
largely due to inspections eliminated from idle mine visits and errors in accounting for the types
of activities performed. This occurred because MSHA had not effectively improved the design or
execution of its internal control system since a 2011 OIG audit found similar internal control issues
with the mandatory inspections program. This led to missed opportunities to protect miners by
identifying hazards to miners and requiring corrections.
Weaknesses in MSHA’s ability to accurately determine a mine’s status increased the risk
of MSHA not completing mandatory inspections. We identified weaknesses related to seven
areas that generally affected when or how often to conduct a mine status verification, what aspects
to check, and what tools to use. Breakdowns in MSHA’s internal control system created these
weaknesses, and increased the risk of MSHA incorrectly calculating inspections required and not
completing inspections.
Other issues affected MSHA’s ability to accurately calculate and report completed
mandatory inspections. The issues included inaccurate or incomplete data, ineffective
communication, and missing policies. These increased the likelihood of MSHA incorrectly reporting
to Congress and the public how many inspections it completed. This led to MSHA incorrectly
reporting for fiscal years 2019, 2020, and 2021. As a result, Congress was unaware of the increased
risk to miners given the lower number of inspections MSHA had performed.
What OIG Recommended
We made 11 recommendations to improve the policies, processes, and system data for the
mandatory inspections program. MSHA generally agreed with our recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/19-24-001-06-001.pdf,
Report No. 19-24-001-06-001 (October 17, 2023).
Semiannual Report to Congress | October 1, 2023–March 31, 2024 49
Employment and
Training Programs
Employment and Training
Administration Programs
Bureau of Labor Statistics
Employment and Training Programs
Employment and Training Administration
Programs
The Employment and Training Administration (ETA) administers federal government job training
and worker dislocation programs. This includes programs authorized by the Workforce Innovation
and Opportunity Act (WIOA) that provide employment assistance; labor market information; and
job training for adults, youth, dislocated workers, and other targeted populations. The WIOA aims
to strengthen the public workforce system and help get Americans—including youth and those
with significant barriers to employment—into high-quality jobs and careers. The WIOA also helps
employers hire and retain skilled workers.
Los Angeles Nonprofit Chief Sentenced for Embezzling Job Training Funds and
Cheating on Taxes
On December 12, 2023, Howard Dixon Slingerland, the former president and CEO of a Los
Angeles-based anti-poverty nonprofit agency, was sentenced to 6 months in prison for embezzling
money from the nonprofit for his personal benefit, failing to report those funds on his tax returns,
and intentionally misapplying more than $600,000 in grant money to pay for unauthorized expenses.
He was also ordered to serve 6 months of home confinement, pay a fine of $10,000, pay more than
$750,000 in restitution, and perform 200 hours of community service.
From 1996 until he was fired in September 2019, Slingerland worked for the Youth Policy Institute
Inc. (YPI), a nonprofit agency, eventually becoming president and CEO. YPI worked to eradicate
poverty in Los Angeles with a comprehensive approach addressing education, youth development,
safety, job training, and health and wellness. As the head of YPI, Slingerland had check-signing
authority over YPI’s bank accounts and was the personal guarantor of YPI’s credit card.
From January 2015 to February 2019, Slingerland caused at least $71,000 of YPI funds to be spent
on unauthorized expenditures, including his personal property tax bill that exceeded $14,000; a
family dinner that cost more than $6,000; private tutoring costing nearly $11,000; and a home
computer and software valued at nearly $2,000.
Slingerland also caused federal grant money YPI had received under the WIOA, which is
administered by the DOL, to be used for unauthorized purposes. The grant was awarded to support
YPI education and training programs designed to prepare young adults in Los Angeles for jobs in
growing industries. Instead, in July 2019, he caused approximately $401,000 of these funds to be
used for the unauthorized payment of YPI payroll. That same month, he caused another $201,000
of the federal grant money to be illegally used to pay off YPI’s credit card bill, including expenses
incurred in his personal capacity.
52 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Employment and Training Programs
Slingerland underreported
on his personal federal
income tax returns more than
$100,000 in income each year
for the tax years 2015 through
2018. He did not report the
money he obtained from YPI
through the embezzlement
or the value of benefits he
received from YPI, including
retirement plan contributions,
a housing allowance, and a
vehicle allowance. Slingerland
admitted to owing the U.S.
Treasury more than $147,000
in unpaid taxes, not including
penalties and interest, for
these years.
This is a joint investigation with the FBI, the DOJ-OIG, the U.S Department of Education-OIG,
the IRS-CI, and the Los Angeles County Unified School District. United States v. Howard Dixon
Slingerland (C.D. California)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 53
Employment and Training Programs
Bureau of Labor Statistics
The Bureau of Labor Statistics (BLS) is responsible for measuring labor market activity, working
conditions, and price changes in the economy. BLS collects, analyzes, and disseminates economic
information to support public and private decision making.
BLS COULD DO MORE TO IDENTIFY DATA LIMITATIONS AND
INCREASE TRANSPARENCY
Why OIG Conducted the Audit
BLS is one of the principal federal statistical agencies
responsible for measuring labor market activity, working
conditions, and price changes in the nation’s economy.
Federal policymakers, public institutions, and private citizens
use this essential economic information to guide and support
decision-making.
BLS collects data from both households and establishments
using voluntary surveys; however, response rates for these
surveys have steadily declined over the past 10 years.
What OIG Did
We conducted this audit to answer the following question:
How has BLS addressed challenges posed by declining statistical survey response
rates, and what was the impact of the declining response rates on the reliability and
costs of economic information developed by BLS?
To answer this question, we examined three BLS surveys: the Current Population Survey, the
Consumer Price Index, and the Import and Export Price Indexes. We interviewed BLS program
officials and representatives from other federal statistical agencies; analyzed BLS survey data,
54 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Employment and Training Programs
guidance, methodologies, and publication criteria; and reviewed public laws and OMB policies. We
focused on improvements needed in ensuring the transparency of potential survey data limitations to
users of BLS data. However, we do not make determinations or provide conclusions on the reliability
of the three indexes that we reviewed.
What OIG Found
BLS has taken actions to address challenges posed by declining survey response rates.
However, BLS could do more to identify potential data limitations in its economic information and
increase the transparency of those limitations. We were unable to identify a correlation between
costs and declining survey response rates. To reduce the impact of missing data caused by
declining survey response rates, BLS increased the use of imputations in its survey data, which are
essentially replacement data inferred from relevant information available. Although imputations are
a standard practice among federal statistical agencies, BLS could be more transparent regarding its
increased use of imputations to facilitate accurate interpretation of its survey data.
During the COVID-19 pandemic, BLS bypassed controls in place to ensure the reliability of its
economic information in 10 percent of published indexes for Import and Export Price Indexes.
Further, BLS did not ensure transparency regarding exceptions to survey publication criteria.
Increased transparency with regard to potential data limitations is needed to ensure BLS survey
users draw correct conclusions from the data when making critical decisions, such as policy
changes that affect the American people.
What OIG Recommended
We made four recommendations to BLS to improve the transparency and clarity surrounding
the use of imputations and published survey data. BLS agreed to take corrective actions for all
four recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/17-24-001-11-001.pdf,
Report No. 17-24-001-11-001 (October 26, 2023).
Semiannual Report to Congress | October 1, 2023–March 31, 2024 55
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.
Colombo Crime Family Captain Sentenced to 51 Months in Prison
On February 28, 2024, Vincent Ricciardo, aka “Vinny Unions,” was sentenced to 51 months in
prison for his participation in the long-running extortion of a senior official of a New York-based
labor union and other criminal schemes he carried out as a captain in the Colombo crime family
of La Cosa Nostra. He was also ordered to forfeit $350,000 and pay approximately $280,000 in
restitution. In July 2023, Ricciardo pled guilty to racketeering and admitted to his participation
in the extortion of the labor union official and various conspiracies to commit money laundering,
loansharking, and fraud in connection with workplace safety certificates.
Ricciardo and his co-conspirators committed a variety of crimes including extortion, loansharking,
fraud, and drug-trafficking to enrich themselves and promote the continued operation of the
Colombo crime family. The Colombo crime family, including Ricciardo, agreed to the use of
extortionate means, including threats of bodily harm, to force a senior union official to give over a
portion of his salary, as well as make decisions that would financially benefit the Colombo crime
family’s administration. Ricciardo and his co-conspirators pressured the trustees of the union’s
associated healthcare benefit fund to select vendors who were associated with the Colombo crime
family. The defendants sought to divert more than $10,000 per month from the health fund’s assets.
Ricciardo also threatened to kill the senior union official, stating in a consensually recorded phone
call that the official would obey him because he knew Ricciardo would “put him in the ground right in
front of his wife and kids.”
This is a joint investigation with the FBI and DOL-EBSA. United States v. Vincent Ricciardo (E.D. New York)
58 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Labor Racketeering
Federal Jury Convicts Former IBEW Local 98 Business Manager John Dougherty
and Former Local 98 President Brian Burrows of Conspiracy, Embezzlement of
Union Funds, and Tax Fraud
On December 7, 2023, John Dougherty and Brian Burrows were convicted by a federal jury of
numerous charges related to their embezzlement of funds belonging to Local 98 of the International
Brotherhood of Electrical Workers (“Local 98”).
John Dougherty was the former business manager of Local 98 and Brian Burrows was the former
president. In January 2019, a federal grand jury indicted Dougherty, Burrows, and four other union
employees. They were charged with multiple federal offenses connected to their illegal use of Local
98 funds for personal and other unauthorized expenses. This illegal use of union funds was contrary
to the provisions of IBEW’s constitution, the by-laws of Local 98, and the beneficial interests of
Local 98’s members. The indictment also charged Dougherty and Burrows with concealing the
embezzlement of Local 98’s funds by filing false labor management reports with the DOL and with
tax fraud by failing to report their personal use of the funds on their tax returns.
The federal jury convicted Dougherty of 65 counts including conspiracy to embezzle the funds
of Local 98, embezzlement, wire fraud, signing and submitting false labor management forms,
and filing false federal income tax returns. The jury convicted Burrows of 20 counts, including
embezzlement, signing and submitting false labor management forms, and filing false federal
income tax returns.
Dougherty and a co-defendant were also charged with depriving the City of Philadelphia and its
citizens of the right to honest services through fraudulent means. These charges were severed,
and in November 2021, a federal jury convicted Dougherty of conspiracy to commit honest
services fraud and honest services wire fraud. He is currently awaiting sentencing related to
these convictions.
This is a joint investigation with the FBI, the IRS, the DOL-EBSA, and the DOL-Office of Labor-
Management Standards. United States v. John Dougherty (E.D. Pennsylvania)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 59
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.
FY 2023 FISMA DOL INFORMATION SECURITY REPORT: MAKING
IMPROVEMENTS TOWARD AN EFFECTIVE PROGRAM
Why OIG Conducted the Audit
Under the Federal Information Security Modernization Act
of 2014 (FISMA), the 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.
What OIG Did
We contracted with KPMG LLP (KPMG) to conduct an independent performance audit on DOL’s
FY 2023 information security program for the period October 1, 2022, through June 30, 2023.
To determine the effectiveness of the program, we evaluated security controls in accordance
with applicable legislation, guidelines, directives, and other documentation. Findings were also
based on testing relevant security controls and targeted penetration tests.
62 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Departmental Management
What OIG Found
KPMG reported seven findings for DOL’s information security program within two of five
Cybersecurity Framework Functions and four of nine FISMA Metric Domains, which resulted in
determining DOL’s information security program was not effective, according to guidance from OMB.
Although DOL established and maintained its information security program, 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 Cybersecurity Framework Functions:
Identify, Protect, and Recover. A security program is only considered effective if the calculated score
of the Cybersecurity Framework Functions is rated at least Managed and Measurable (Level 4).
While the Office of Chief Information Officer (OCIO) has made improvements in its information
security program from previous years, we identified areas of improvement required to reach a
Managed and Measurable, or effective, program. DOL’s information security program did not fully
adhere to applicable FISMA requirements and other guidance, and KPMG noted further deficiencies
in the development and implementation of supply chain risk management security controls, Plan
of Action and Milestones reviews, configuration management controls, and the enforcement of
rules of behavior acknowledgement. Based on these issues, we continue to be concerned about
the remaining corrections needed in OCIO’s oversight and accountability over DOL’s information
security control environment.
What OIG Recommended
KPMG made three new recommendations to strengthen DOL’s information security program.
Based on our testing, we determined that 38 prior year recommendations were closed, and 31
recommendations remained open.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/23-24-001-07-725.pdf,
Report No. 23-24-001-07-725 (December 6, 2023).
Semiannual Report to Congress | October 1, 2023–March 31, 2024 63
Departmental Management
WITHOUT AN IT MODERNIZATION FRAMEWORK, DOL IS
VULNERABLE TO INADEQUATE RESOURCE PRIORITIZATION FOR
ENSURING SECURITY AND AVAILABILITY OF DOL SYSTEMS
Why OIG Conducted the Audit
IT modernization refers to an organization’s efforts to
prevent IT systems from becoming outdated, which can
lead to poor performance and security concerns. DOL IT
systems support DOL programs in ensuring the health
and safety of American workers—including miners and
unemployed workers—and provide timely economic
indicators that are vital for the country.
DOL’s CIO has responsibility and oversight for over 65
major information systems as well as enterprise IT initiatives
across DOL. This responsibility includes overseeing the
organization’s efforts to upgrade IT systems and to ensure
that existing IT systems do not become outdated due to
lifecycle, technical, or business reasons. It is a tremendous
responsibility to ensure the IT posture remains secure and
technologically able to support DOL’s mission.
What OIG Did
Given these risks, the OIG conducted a performance audit to determine:
Has the Department developed an IT modernization framework and what is its current
and future state?
To answer this question, we interviewed personnel and reviewed DOL’s IT modernization activities
from January 2022 through August 2022, including analysis of documentation and funding
mechanisms.
64 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Departmental Management
What OIG Found
We found the Department has not developed a formal, documented IT modernization framework.
While the CIO has developed several elements that could become part of an IT modernization
framework, we found those elements are not linked to one another nor documented as part of a
larger, formalized process. The CIO’s reason for lack of a documented framework was to keep the
approach dynamic. However, a documented framework would ensure consistency going forward
rather than leaving DOL’s IT modernization efforts open to interpretation and subject to changes
in personnel.
Also, we found that at least two of the elements could be improved. First, the agency updated
documents that the CIO uses to monitor IT modernization projects are incomplete and also agency-
curated, instead of being based on the full picture. Second, the inventory of IT systems used to
prioritize IT modernization efforts is a spreadsheet that has to be manually updated and does not
link to the other elements.
These issues lead to gaps in the CIO’s visibility of the current and future states of DOL’s IT
modernization. As a result, DOL is vulnerable to spending valuable time and resources on IT projects
that are not the highest priorities for ensuring the security and availability of vital DOL systems.
What OIG Recommended
We made three recommendations to the CIO to improve IT modernization, including documenting a
framework. The CIO agreed with the three recommendations.
For more information, go to, https://www.oig.dol.gov/public/reports/oa/2024/23-24-002-07-725.pdf,
Report No. 23-24-002-07-725 (November 17, 2023).
Semiannual Report to Congress | October 1, 2023–March 31, 2024 65
Departmental Management
Management Advisory Comments Identified in an Audit of the Consolidated
Financial Statements for the Year Ended September 30, 2023
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 two
new comments and two prior-year comments still present in FY 2023 and noted the resolution of six
prior-year comments closed in FY 2023.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-005-13-001.pdf,
Report No. 22-24-005-13-001 (December 20, 2023).
FY 2023 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, 2023. 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, 2023. 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 insurance43 information as of
September 30, 2023, 2022, 2021, 2020, and 2019, and its changes in social insurance amounts
for the years ended September 30, 2023, and 2022 in accordance with U.S. generally accepted
accounting principles.
43 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.
66 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Departmental Management
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 2023 and 2022.
In addition, KPMG identified certain deficiencies in internal control that they 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 Principal Deputy
Assistant Secretary for Employment and Training.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-004-13-001.pdf,
Report No. 22-24-004-13-001 (November 14, 2023).
Special Report Relating to the Federal Employees’ Compensation Act Special
Benefit Fund
The OIG contracted with 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, 2023. 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. 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/2024/22-24-003-04-431.pdf,
Report No. 22-24-003-04-431 (November 1, 2023).
Longshore and Harbor Workers’ Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report
The Longshore and Harbor Workers’ Compensation Act Special Fund (Longshore Special Fund)
provides medical benefits, compensation for lost wages, and rehabilitation services for job-related
injuries and diseases sustained by private-sector workers in certain maritime and related
employment. The Longshore Special Fund also extends benefits to dependents if any injury results
in the worker’s death. The OIG contracted with KPMG to audit the financial statements of the
Longshore Special Fund as of September 30, 2022. KPMG issued an unmodified opinion, meaning
the financial statements presented fairly, in all material respects, the financial position of the
Semiannual Report to Congress | October 1, 2023–March 31, 2024 67
Departmental Management
Longshore Special Fund, and its net costs, changes in net position, and budgetary resources for
the years then ended in accordance with U.S. generally accepted accounting principles.
As part of its audit, KPMG also considered the Longshore Special Fund’s internal control over
financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the
Longshore Special Fund’s internal control over financial reporting nor to identify all deficiencies
that might be material weaknesses or significant deficiencies. However, KPMG identified certain
deficiencies in internal control that we consider to be a material weakness.
First, the Office of Chief Financial Officer’s (OCFO) control for preparing and reviewing the Longshore
Special Fund financial statements was not properly designed and implemented. In addition,
Management’s review of the financial statements and related disclosures did not consider the elevated
risks associated with determining the impact of prior year ontop adjustments to ensure that the correct
adjustments were included in the current year financial statements. Lastly, some allowance amounts
reported in the Accounts Receivable footnote were incorrect.
As part of obtaining reasonable
assurance, KPMG also performed certain
tests of the Longshore Special Fund’s
compliance with applicable laws and
regulations and its test results disclosed
no instances of noncompliance or other
matters required to be reported under
government auditing standards.
To address the deficiencies noted above,
we recommended that the Deputy Chief
Financial Officer consider an additional
reviewer and/or additional review procedures
for nonroutine adjustments and accurate
presentation of the financial statements and
related footnote disclosures.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-001-04-432.pdf,
Report No. 22-24-001-04-432 (October 30, 2023).
68 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Departmental Management
District of Columbia Workmen’s Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report
The District of Columbia Workmen’s Compensation Act of 1928 Special Fund (DCCA Special Fund)
provides medical benefits, compensation for lost wages, and rehabilitation services for job-related
injuries, diseases, or death of certain private-sector workers in the District of Columbia. The DCCA
Special Fund also extends benefits to dependents if any injury resulted in the employee’s death.
The OIG contracted with KPMG to audit the financial statements of the DCCA Special Fund as
of September 30, 2022. KPMG issued an unmodified opinion, meaning the financial statements
presented fairly, in all material respects, the financial position of the DCCA Special Fund, and its net
costs, changes in net position, and budgetary resources for the years then ended in accordance
with U.S. generally accepted accounting principles.
As part of its audit, KPMG also considered the DCCA Special Fund’s internal control over financial
reporting, but not for the purpose of expressing an opinion on the effectiveness of the DCCA Special
Fund’s internal control over financial reporting nor to identify all deficiencies that might be material
weaknesses or significant deficiencies. However, KPMG identified certain deficiencies in internal
control that we consider to be a material weakness.
First, the OCFO control for preparing and reviewing the
First, the OCFO control for
DCCA Special Fund financial statements was not properly
preparing and reviewing the
designed and implemented. In addition, management’s review
DCCA Special Fund financial
of the financial statements did not consider the elevated risks
statements was not properly
associated with determining the impact of prior year on-top
designed and implemented.
adjustments to ensure that the correct adjustments were
included in the current year financial statements.
As part of obtaining reasonable assurance, KPMG also performed certain tests of the DCCA Special
Fund’s compliance with applicable laws and regulations, and its test results disclosed no instances
of noncompliance or other matters required to be reported under government auditing standards.
To address the deficiencies noted above, we recommended that the Deputy Chief Financial Officer
consider an additional reviewer and/or additional review procedures for nonroutine adjustments and
accurate presentation of the financial statements.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/22-24-002-04-432.pdf,
Report No. 22-24-002-04-432 (October 30, 2023).
Semiannual Report to Congress | October 1, 2023–March 31, 2024 69
Departmental Management
Single Audits
A single audit provides an organization-wide examination of an entity expending federal assistance funds
received for its operations. The audit is typically conducted annually by an independent certified public
accountant, and its objective is to provide assurance to the U.S. government regarding the management
and use of funds by recipients such as states, schools, universities, and nonprofits.
Quality Control Review of Single Audits
Under OMB Uniform Guidance,44 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.45 DOL is currently cognizant for 12 entities.
The OIG periodically performs QCRs of single audits of entities over which DOL has cognizance.
During this reporting period, we conducted two QCRs: (1) Quality Control Review of the Single
Audit of the American Association of Retired Persons (AARP) Foundation for the Year Ended
December 31, 2022; and (2) Quality Control Review on the Single Audit of the State of New Mexico
Workforce Solutions Department for the Year Ended June 30, 2022.
Quality Control Review of the Single Audit of the AARP Foundation for the Year
Ended December 31, 2022
We performed a QCR of the independent certified public accounting firm Grant Thornton LLP’s
single audit of the AARP Foundation for the Year Ended December 31, 2022. Our QCR covered
the Senior Community Service Employment Program, which totaled $83.7 million of DOL funds.
We determined Grant Thornton LLP’s audit work on the single audit was acceptable and met the
requirements of government auditing standards, generally accepted auditing standards, and OMB
Uniform Guidance. Our report did not contain any recommendations.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/24-24-001-50-598.pdf,
Report No. 24-24-001-50-598 (January 24, 2024).
44 Uniform Guidance refers to 2 C.F.R. Part 200, OMB’s “Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards.”
45 According to Uniform Guidance, the designated cognizant agency for audit must be the federal awarding agency
that provides the predominant amount of funding directly to a nonfederal entity unless OMB designates a specific
cognizant agency for audit. Cognizant agencies for audit are the federal agencies designated to carry out the
responsibilities described in Uniform Guidance § 200.513(a).
70 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Departmental Management
Quality Control Review on the Single Audit of the State of New Mexico Workforce
Solutions Department for the Year Ended June 30, 2022
We performed a QCR of the independent certified public accounting firm Moss Adams LLP’s single
audit of the State of New Mexico Workforce Solutions Department for the year ended June 30, 2022.
Our QCR covered the Unemployment Insurance and Employment Service Cluster programs, which
totaled $459.5 million of DOL funds. We determined Moss Adams LLP’s audit work on the single
audit generally met the requirements of government auditing standards, generally accepted auditing
standards, and OMB Uniform Guidance. However, we found nonunemployment insurance programs
and expenditures were incorrectly included in the Schedule of Expenditures of Federal Awards
(SEFA) unemployment insurance total. We made one recommendation to Moss Adams LLP to work
with the State of New Mexico Workforce Solutions Department to revise and reissue the single audit
report to ensure non-unemployment insurance programs and expenditures are not included on the
SEFA unemployment insurance total.
For more information, go to https://www.oig.dol.gov/public/reports/oa/2024/24-24-002-50-598.pdf,
Report No. 24-24-002-50-598 (March 12, 2024).
Semiannual Report to Congress | October 1, 2023–March 31, 2024 71
Employee Integrity
Investigations
Employee Integrity Investigations
Employee Integrity Investigations
The OIG is responsible for investigating possible misconduct or criminal activities involving senior DOL
employees or individuals providing services to the Department.
The OIG conducted an internal investigation into an allegation that a senior OIG employee had
mismanaged COVID-19 audit contracts. There was no evidence to support the allegations and no
further action was warranted.
74 Semiannual Report to Congress | October 1, 2023–March 31, 2024
OIG Whistleblower
Activities
OIG Whistleblower Activities
OIG Whistleblower Activities
Whistleblower Protection Coordinator
DOL employees, contractors, subcontractors, and grantees perform an important service by
reporting evidence of wrongdoing, including misconduct, fraud, waste, and abuse, in DOL programs.
Whistleblowers should never be subjected to, or threatened with, retaliation for having engaged
in a protected communication or protected activity. The OIG plays a vital role in ensuring that
DOL employees and employees of DOL grantees and contractors are informed of their rights and
protections against retaliation for “blowing the whistle.” This work is done by the OIG Whistleblower
Protection Coordinator Program, housed in the OIG’s Office of Legal Services.
Pursuant to Section 2 of the Whistleblower Protection Coordination Act of 2018 (S.1869, June 25, 2018),
every Inspector General’s office is required to designate a Whistleblower Protection Coordinator. According
to Section 2, the Whistleblower Protection Coordinator:
1. educates agency employees about prohibitions against retaliation for protected disclosures;
2. educates agency employees who have made or are contemplating making a protected disclosure about
their rights and the remedies against retaliation for protected disclosures, including the means by which
employees may seek review of any allegation of reprisal, as well as about the roles of the OIG, the
Office of Special Counsel, the Merit Systems Protection Board, and any other relevant entities; and
3. provides general information about the timeliness of such cases, the availability of any
alternative dispute mechanisms, and avenues for potential relief. Within the OIG, a Supervisory
Associate Counsel to the Inspector General has been designated to serve as the Whistleblower
Protection Coordinator.
Pursuant to this designation, the Whistleblower Protection Coordinator has:
• provided input into training that is required to be completed by all DOL employees, entitled
“Prohibited Personnel Practices, Whistleblower Protection”;
• provided input into training that is required to be completed by all DOL supervisors and
managers entitled “Responding to Whistleblower Retaliation Complaints/Overview of Prohibited
Personnel Practices – Annual Training”;
• 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;
76 Semiannual Report to Congress | October 1, 2023–March 31, 2024
OIG Whistleblower Activities
• 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;
• provided live training to all OIG employees on “Whistleblower Rights and Protections for OIG Employees;”
• 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;
• obtained the OIG’s recertification of its 2302(c) program from the Office of Special Counsel (July 2023);
• monitored whistleblower retaliation complaints received by the OIG, as well as whistleblower
retaliation investigations conducted by the OIG;
• conducted training for a DOL agency district office on Whistleblower Rights and Protections for
DOL Employees; and
• participated on the panel of Whistleblower Protection Coordinators for the Council of the
Inspectors General on Integrity and Efficiency Whistleblower Education Forum.
Whistleblower Retaliation Investigations
The OIG can initiate its own investigations into allegations of improper or illegal retaliation brought
by DOL employees or, on a discretionary basis, refer such allegations to the Office of Special
Counsel for review and investigation.
Further, pursuant to 41 U.S.C. § 4712, the OIG is required, with some exceptions, to investigate
whistleblower retaliation allegations made by employees of DOL contractors or grantees.
Table 2: Whistleblower Investigations, October 1, 2023–March 31, 2024
Investigation Type Number
Pending DOL employee complaint investigations 4
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 0
Pending grantee/contractor employee complaint investigations 3
Reports pending with DOL 0
Decision issued by the DOL Assistant Secretary for Administration and Management 1
Semiannual Report to Congress | October 1, 2023–March 31, 2024 77
Legislative
Recommendations
Legislative Recommendations
Legislative Recommendations
The Inspector General Act of 1978, as amended, requires the Office of Inspector General (OIG) to review
existing or proposed legislation and regulations and to make recommendations in the Semiannual Report
to Congress concerning their impact both on the economy and efficiency of the Department’s programs
and on the prevention of fraud, waste, and abuse. The OIG continues to propose the following legislative
actions to increase efficiency and protect the U.S. Department of Labor’s (DOL or Department) programs.
Inspector General Larry D. Turner, in congressional testimonies and through other means,
highlighted four high-priority recommendations for congressional consideration:
1. 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.
Extend the Statute of Limitations Associated with Pandemic-Related UI Fraud
Unless Congress acts urgently, the statute of limitations for many of the OIG’s pandemic-related
UI fraud investigations will begin to expire in early 2025. Because the statutes most 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, the current statute of limitations
associated with UI fraud means federal law enforcement will still fall short in fully investigating
and prosecuting some of the most egregious cases of UI fraud. This is particularly the case given
the volume and complexity of UI fraud matters we are tasked to investigate. This issue is further
complicated by our limited resources. The U.S. Small Business Administration faced a similar issue
regarding the statute of limitations for pandemic-related fraud in the Paycheck Protection Program
and Economic Injury Disaster Loan programs. To address those concerns, Congress passed
legislation to extend associated statutes of limitations.
Congress could likewise act to extend the statute of limitations for fraud associated with
pandemic-related UI programs to help ensure investigators and prosecutors have time to effectively
pursue and hold accountable those who defrauded the UI programs during the pandemic. To do so,
80 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Legislative Recommendations
Congress would likely have to extend the applicable statute of limitations for those pandemic-related UI
programs that have been defrauded before it expires. 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.
Allow DOL and the OIG Access to UI Claimant Data and Wage Records
In addition to the authority provided by the Inspector
In addition to the authority
General Act of 1978, as amended, Congress should
provided by the Inspector
consider legislative action that would specifically
General Act of 1978, as
authorize DOL and the OIG to have ongoing, timely, and
amended, Congress should
complete access to State Workforce Agencies’ (SWA)
consider legislative action that
UI claimant data and wage records for our respective
would specifically authorize DOL
oversight responsibilities. The Department has stated
and the OIG to have ongoing,
that—outside of revising the existing regulations through
timely, and complete access
notice and comment rulemaking—it lacks the authority
to State Workforce Agencies’
to require SWAs to provide the OIG with access to UI
(SWA) UI claimant data and
claimant data and wage records except when the OIG is
wage records for our respective
conducting an investigation into a particular instance of
oversight responsibilities.
suspected UI fraud.
The Inspector General Act of 1978, as amended, authorizes the Inspector General’s access to
information related to the Department’s programs and operations, unless Congress enacts a law
that expressly refers to the Inspector General and limits the Inspector General’s right of access.
Despite the OIG’s statutory authority to access all information available to the Department, the
Department has taken the position that—outside of revising the existing regulations through notice
and comment rulemaking—it lacked the authority to require SWAs to provide UI data to the OIG for
all purposes authorized under the Inspector General Act of 1978. The Department has not provided
the OIG support for their position that the Inspector General’s access is limited in this manner.
Furthermore, in our June 2021 alert memorandum,46 we recommended that the Employment and
Training Administration (ETA) amend its regulations47 to reinforce that SWAs’ UI information must be
provided to the OIG for all Inspector General engagements authorized under the Inspector General
Act of 1978, as amended, including audits, evaluations, and investigations.
46 Alert Memorandum: The Employment and Training Administration Needs to Issue Guidance to Ensure State
Workforce Agencies Provide Requested Unemployment Insurance Data to the Office of Inspector General, Report
No. 19-21-005-03-315 (June 16, 2021), available at:
https://www.oig.dol.gov/public/reports/oa/2021/19-21-005-03-315.pdf
47 20 C.F.R. § 603.5 and 603.6(a)
Semiannual Report to Congress | October 1, 2023–March 31, 2024 81
Legislative Recommendations
These barriers to the OIG’s ongoing, timely, and complete access to data have severely hampered
the OIG’s ability to oversee the UI program. To overcome this and effectively oversee UI benefits
provided in response to the pandemic, the OIG issued multiple Inspector General subpoenas to all
SWAs seeking UI claimant data. OIG data scientists then had to ensure the data was complete,
consistent, and in a common format to analyze and identify potential fraud and programmatic
weaknesses. The repeated use of Inspector General subpoenas to obtain UI data on a recurring
basis was time-consuming and inefficient. Ongoing, timely, and complete access for all OIG
engagements would alleviate that time and resource burden and align with the Inspector General
Act of 1978, as amended.
In support of the OIG’s oversight activities, the OIG needs access to UI claimant data and wage
records from SWAs to verify claimants’ eligibility for UI benefits, including both initial eligibility (and
amounts) and continuing eligibility. Timely access to these records will facilitate the OIG’s efforts to
identify claimants who are part of large-scale fraud schemes or are receiving benefits improperly
due to systemic program weaknesses.
To date, ETA has implemented only
temporary solutions. In August 2021,
ETA issued guidance requiring SWAs
to disclose UI data to the OIG for audits
and investigations for the duration of
pandemic UI programs. ETA has also
required sharing of state UI data with the
OIG as a condition of fraud prevention
grants. These grants provided access
through 2023. Further, according to
guidance issued in July 2023, additional
grants under the American Rescue
Plan Act of 2021 are expected to
provide access for the next 2 to 5 years.
According to ETA, 52 of 53 SWAs
received grants.
Congress should consider legislative action that would specifically authorize DOL and the OIG to
have ongoing, timely, and complete access to UI claimant data and wage records for our oversight
responsibilities. Ongoing, timely, and complete access to SWA UI claimant data and wage records
would further enable the OIG to quickly identify largescale fraud and expand its current efforts to
share emerging fraud trends with ETA and states to strengthen the UI program and deter fraud.
Further, this action would assist the Department in its programmatic oversight responsibilities to
identify weak controls and improper payments in the UI program.
82 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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 to children under 14 and deceased persons.48 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 programmatic changes to
put billions in federal funds to better use. Conducting data analytics from such access would further
enable our auditors to identify program weaknesses and recommend corrective actions that would
improve the timeliness of UI benefit payments and the integrity of the UI program.
Authorize OIG Participation in Asset Forfeiture Funds to Combat UI Fraud and
Other Crimes
Legislative authority in the area of asset forfeiture would increase the OIG’s ability to effectively and
efficiently investigate UI fraud and other crimes and to recover fraudulently obtained funds.49 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.
Currently, the OIG is not a participant in the U.S. Department of the Treasury Forfeiture Fund or
the U.S. Department of Justice (DOJ) Asset Forfeiture Fund. The lack of authority to participate
limits the OIG’s ability to effectively recover proceeds of UI fraud and other crimes under the OIG’s
jurisdiction. Statutory authority to seize and forfeit illicit funds would allow the OIG to participate
in the U.S. Department of the Treasury Forfeiture Fund and the DOJ Asset Forfeiture Fund, thus
enabling the OIG to better combat UI fraud and other crimes in the future.
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
48 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
49 According to the FBI, “Asset forfeiture entails a legal process whereby the ownership of an asset is removed from
individuals because they used it illegally, received or derived it from illicit activity, or employed it to facilitate a crime.
The vesting of title with the government follows a civil, criminal, or administrative proceeding.” FBI, Law Enforcement
Bulletin, “Asset Seizure and Forfeiture: A Basic Guide,” (August 10, 2016), available at:
https://leb.fbi.gov/articles/featured-articles/asset-seizure-and-forfeiture-a-basic-guide
Semiannual Report to Congress | October 1, 2023–March 31, 2024 83
Legislative Recommendations
Budget Justification,50 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 that 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;
• 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.
Provide Authority to Ensure the Integrity of the H-1B Program
If DOL is to have a meaningful role in the foreign labor certification process for H-1B specialty
occupation visas, it must have the statutory authority to ensure the integrity of that process. This
authority should include the ability to verify the accuracy of information provided on labor condition
applications and to initiate its own H-1B investigations more broadly.
Currently, unlike H-2A and H-2B investigations, DOL’s authority to investigate H-1B employers
is limited and typically requires a complaint by an aggrieved party. In the absence of such
a complaint, with limited exceptions, DOL may only initiate its own H1B investigations if the
Secretary (or Acting Secretary) personally certifies there is reasonable cause to believe the
employer is not in compliance. Even assuming that 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
50 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
84 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Legislative Recommendations
requirements regarding prevailing wage and benefits, working conditions, labor disputes, 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. 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
Some employers and attorneys
the integrity of the certification process is heightened by
misrepresent their need for
the results of OIG audits and investigations showing that
workers to DOL, then reassign
the program is susceptible to significant fraud and abuse,
the extra workers to other
particularly by employers and attorneys. For example, some
companies or require foreign
staffing companies utilize the H-1B program without having
workers to find their own work.
scheduled jobs already lined up. Some employers and
There have also been instances
attorneys misrepresent their need for workers to DOL, then
when companies illegally
reassign the extra workers to other companies or require
generated profits by requiring
foreign workers to find their own work. There have also
foreign workers to pay fees and
been instances when companies illegally generated profits
recurring payments to secure
by requiring foreign workers to pay fees and recurring
H-1B visas.
payments to secure H-1B visas.
Without statutory authority, the Department generally cannot verify employers’ attestations to H-1B
certifications unless a complaint is filed or the Department utilizes a Secretary-initiated investigation.
As foreign workers are generally reluctant to file complaints for fear of retaliation and losing their
jobs, the Department’s process is unlikely to result in verification action being taken.
Amend Pension Protection Laws
Legislative changes to the Employment Retirement Income Security Act of 1974 (ERISA) and
criminal penalties for ERISA violations would enhance the protection of assets in pension plans.
To this end, the OIG continues to recommend the following legislative actions:
• Repeal ERISA’s limited-scope audit exemption. This exemption excludes pension plan
assets invested in financial institutions, such as banks and savings and loan firms, from audits of
employee benefit plans. Notwithstanding recent changes to auditing standards that strengthen
limited-scope audits, these audits prevent independent public accountants who are auditing
pension plans from rendering an opinion on the plans’ financial statements in accordance
with professional auditing standards. These “no opinion” audits offer weak assurance of asset
integrity either to plan participants or to the Department.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 85
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 that improprieties
are addressed, we recommend that
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.
86 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Legislative Recommendations
Improve the Integrity of the FECA Program
Legislative reforms should be considered in the following areas to improve the effectiveness and
integrity of the Federal Employees’ Compensation Act (FECA) program:
• Provide statutory access to the National Directory of New Hires and Social Security wage
records. Currently, the Department has no direct access to the National Directory of New Hires
data and can access Social Security wage information only if the claimant gives it permission.
Granting the Department routine access to these databases would aid in detecting fraud
committed by individuals receiving FECA wage loss compensation but failing to report income
they have earned.
• Establish a 3-day waiting period at the beginning of the claims process. FECA legislation
provides for a 3-day waiting period, which is intended to discourage the filing of frivolous claims.
As currently written, however, the legislation places the waiting period at the end of the 45-day
continuation-of-pay period, thereby negating its purpose. Legislation that passed in 2006 placed
the waiting period for postal employees immediately after an employment-related injury. If the
intent of the law is to ensure a true waiting period before an employee applies for benefits, then
that period should likewise come immediately after an employment-related injury—for all federal
workers, not exclusively postal employees. This proposal was included in the President’s FY
2021 budget as part of the Office of Workers’ Compensation Programs’ (OWCP) FECA reform.
• Allow the temporary suspension of medical providers pending the outcome of
criminal investigations. While FECA regulations allow OWCP to exclude a provider through
administrative means, OWCP must give notice to the provider and afford the provider an
opportunity for a hearing before DOL’s Office of Administrative Law Judges. This process and
the various procedures involved can be lengthy. Legislative changes are necessary to enable
DOL to immediately suspend all medical providers who have been indicted for fraudulent billing
practices from providing further medical services and receiving payments. This proposal was
included in the President’s FY 2021 budget as part of OWCP’s FECA reform.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 87
Appendices
Appendices
Reporting Requirements Under
the Following Acts
The Inspector General Act of 1978, as Amended
REPORTING REQUIREMENT PAGE
Recommendations on existing and proposed legislation and regulations
Section 4(a)(2) 79
relating to the programs and operations of DOL
Description of significant problems, abuses, and deficiencies relating to
the administration of programs and operations of the establishment and
Section 5(a)(1) All
associated reports and recommendations for corrective action made by
the Office
Identification of each recommendation made before the reporting
Section 5(a)(2) period, for which corrective action has not been completed, including the All
potential costs savings associated with the recommendation
Section 5(a)(3) Summary of significant investigations closed during the reporting period 35-59
Identification of the total number of convictions during the reporting
Section 5(a)(4) 127
period resulting from investigations
Information regarding each audit, inspection, or evaluation report issued
during the reporting period, including—
(A) a listing of each audit, inspection, or evaluation;
(B) if applicable, the total dollar value of questioned costs (including
Section 5(a)(5) 94
a separate category for 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
Section 5(a)(6) reporting period with respect to any audit, inspection, or evaluation 100
issued during a previous reporting period
Information from the Federal Financial Management Improvement
Section 5(a) None to
Act Section 804(b) — instances in which an agency has not met
(7) report
intermediate target dates in a remediation plan, and the reasons
Peer review reporting:
Section 5(a)(8) (A) results of any peer review conducted by another OIG, or 129
(B) a statement identifying the date of the last peer review conducted
None to
Section 5(a)(9) Outstanding peer review recommendations
report
continued on next page
90 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Section 5(a) Peer reviews conducted by the OIG and recommendations outstanding
129
(10) or not fully implemented
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;
127
(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 127
(12)
Summary of investigations of senior government employees where
Section 5(a)
allegations of misconduct were substantiated, including the facts, 74
(13)
circumstances, status, and disposition of the matter
Description of whistleblower retaliation cases including information
Section 5(a) about the official found to have engaged in retaliation and what, if
75
(14) any, consequences that establishment imposed 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—
(i) with budget constraints designed to limit the capabilities of the Office;
Section 5(a) and
None to
(15) and (ii) incidents where the establishment has resisted or objected to
report
Section 6(c)(2) oversight activities of the 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 were not disclosed to the public; and
Section 5(a) None to
(B) Descriptions of investigations conducted by the office involving a
(16) report
senior government 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 989(C) Peer review reporting 129
Semiannual Report to Congress | October 1, 2023–March 31, 2024 91
Appendices
Funds Recommended for Better Use
Funds Put to a Better Use Agreed to by DOL51
Dollar
Number
Value ($
of Reports
millions)
For which no management decision had been made as of the
4 $35,900
commencement of the reporting period
Issued during the reporting period $0
Subtotal 4 $35,900
For which a management decision was made during the reporting period:
• Dollar value of recommendations that were agreed to by management 1 $4,950
• 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
3 $30,950
reporting period
Funds Put to a Better Use Implemented by DOL
Dollar
Number
Value ($
of Reports
millions)
For which final action had not been taken as of the commencement of the
3 $39,310
reporting period
For which management or appeal decisions were made during the
1 $4,950
reporting period
Subtotal 4 $44,260
For which management decision was made during the reporting period:
• Dollar value of recommendations that were actually completed 0 $0
• Dollar value of recommendations that management has subsequently
0 $0
concluded should not or could not be implemented or completed
For which no final action had been taken by the end of the reporting period 4 $44,260
51 The term “recommendation that funds be put to better use” means a recommendation by the OIG that funds
could be used more efficiently or achieve greater program effectiveness if management took actions to implement
and complete the recommendation. This term is defined by the Inspector General Act of 1978, as amended, and
includes, among other things, reductions in future outlays; deobligation of funds from programs or operations;
costs not incurred in the future by implementing recommended improvements related to the operations of the
establishment, a contractor, or a grantee; and any other savings specifically identified, including reverting funds to
Treasury to be used for other purposes.
92 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Questioned Costs
Resolution Activity: Questioned Costs52
Questioned
Number
Costs
of Reports
($ millions)
For which no management decision had been made as of the
5 $599
commencement of the reporting period (as adjusted)
Issued during the reporting period 0 $0
Subtotal 5 $599
For which a management decision was made during the reporting period:
• Dollar value of disallowed costs
• Dollar value of costs not disallowed 3 $172.6
For which no management decision had been made as of the end of the
2 $426.4
reporting period
For which no management decision had been made within six months of
0 $0
issuance
Closure Activity: Disallowed Costs53
Disallowed
Number
Costs
of Reports
($ millions)
For which final action had not been taken as of the commencement of
0 $0
the reporting period (as adjusted)
For which management or appeal decisions were made during the
3 $172.6
reporting period
Subtotal 3 $172.6
For which final action was taken during the reporting period:
• Dollar value of disallowed costs that were recovered 0 $0
• Dollar value of disallowed costs that were written off 0 $0
• Dollar value of disallowed costs that entered appeal status 0 $0
For which no final action had been taken by the end of the reporting period 3 $172.6
52 As defined by the Inspector General Act of 1978, as amended, questioned costs include alleged violations of law,
regulations, contracts, grants, or agreements; costs not supported by adequate documentation; or the expenditure of
funds for an intended purpose that was unnecessary or unreasonable.
53 Disallowed costs are costs that the OIG questioned during an audit as unsupported or unallowable and that the
grant/contracting officer has determined the auditee should repay. The Department is responsible for collecting the
debts established. The amount collected may be less than the amount disallowed, and monies recovered usually
cannot be used to fund other program operations and are returned to Treasury.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 93
Appendices
Final Audit Reports Issued
Management Decision
Questioned Costs ($)
Number of Funds Put To Better
Report Title; Report Number; Date Issued Made by End of
Recommendations Use ($)
Reporting Period
Bureau of Labor Statistics
BLS Could Do More to Identify Data Limitations
and Increase Transparency; 4 $0 $0 Yes
Report No. 17-24-001-11-001; 10/26/23
Total (1 Report)
Employment and Training Administration
A Review of Pandemic Unemployment
No
Insurance Relief and Its Impact on Six Different
0 $0 $0 Response
U.S. Communities;
Required
Report No. 19-24-002-03-315; 03/28/24
Total (1 Report)
Mine Safety and Health Administration
COVID-19: MSHA Did Not Complete or
Accurately Report Mandatory Inspections; 11 $0 $0 Yes
Report No. 19-24-001-06-001; 10/17/23
Total (1 Report)
continued on next page
94 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Office of the Assistant Secretary for Administration and Management
Without an IT Modernization Framework,
DOL Is Vulnerable to Inadequate Resource
Prioritization for Ensuring Security and 3 $0 $0 No
Availability of DOL Systems;
Report No. 23-24-002-07-725; 11/17/23
FY 2023 FISMA DOL Information Security
Report: Making Improvements Toward an
3 $0 $0 Yes
Effective Program;
Report No. 23-24-001-07-725; 12/06/23
Total (2 Reports)
Office of the Chief Financial Officer
FY 2023 Independent Auditors’ Report on
DOL’s Consolidated Financial Statements; 3 $0 $0 Yes
Report No. 22-24-004-13-001; 11/14/23
Management Advisory Comments
Identified in an Audit of the Consolidated
Financial Statements for the Year Ended 6 $0 $0 Yes
September 30, 2023;
Report No. 22-24-005-13-001; 12/20/23
Total (2 Reports)
Office of Workers’ Compensation Programs
District of Columbia Workmen’s
Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report 1 $0 $0 Yes
September 30, 2022, and 2021;
Report No. 22-24-002-04-432; 10/30/23
Longshore and Harbor Workers’
Compensation Act Special Fund Financial
Statements and Independent Auditors’ Report 1 $0 $0 Yes
September 30, 2022, and 2021;
Report No. 22-24-001-04-432; 10/30/23
Special Report Relating to the Federal
No
Employees’ Compensation Act Special Benefit
0 $0 $0 Response
Fund September 30, 2023;
Required
Report No. 22-24-003-04-431; 11/01/23
Total (3 Reports)
Final Audit Total (10 Reports) 32 $0 $0
Semiannual Report to Congress | October 1, 2023–March 31, 2024 95
Appendices
Other Reports
Management
Number of Decision Made by
Report Title; Report Number; Date Issued
Recommendations End of Reporting
Period
Employment and Training Programs
Workforce Innovation and Opportunity Act
Quality Control Review for the Single Audit of
the American Association of Retired Persons
No Response
(AARP) Foundation for the Fiscal Year Ended 0
Required
December 31, 2022;
Report No. 24-24-001-50-598; 01/24/24
Quality Control Review on the Single Audit of the State
of New Mexico Workforce Solutions Department for the
1 Yes
Year Ended June 30, 2022;
Report No. 24-24-002-50-598; 03/12/24
Total (2 Reports)
Other Reports Total (2 Reports) 1
96 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Unresolved Audit Reports Over 6 Months Old
Number of
Questioned
Agency Report Title; Report Number; Date Issued Unresolved
Costs ($)
Recommendations
Agency Management Decision or Grant/Contracting Officer’s Final Determination Did Not
Resolve; OIG Negotiating with Agency
COVID-19: More Can Be Done to Mitigate Risk to
ETA Unemployment Compensation Under the CARES Act; 1 $0
Report No. 19-20-008-03-315; 08/07/20
Alert Memorandum: The Employment and Training
Administration Needs to Issue Guidance to Ensure State
ETA Workforce Agencies Provide Requested Unemployment 2 $0
Insurance Data to the Office of Inspector General;
Report No. 19-21-005-03-315; 06/16/21
Unemployment Insurance Overpayments Related to Work
Search Underscore the Need for More Consistent State
ETA 1 $0
Requirements;
Report No. 04-21-001-03-315; 09/29/21
Alert Memorandum: Potentially Fraudulent
Unemployment Insurance Payments in High Risk
ETA 2 $0
Areas Increased to $45.6 Billion;
Report No. 19-22-005-03-315; 09/21/22
Alert Memorandum: ETA Needs to Incorporate Data
Analytics Capability to Improve Oversight of the
ETA 2 $0
Unemployment Insurance Program;
Report No. 19-23-012-03-315; 09/25/23
COVID-19: Pandemic Unemployment
Assistance for Non-Traditional Claimants
ETA Weakened by Billions in Overpayments, 1 $0
Including Fraud;
Report No. 19-23-014-03-315; 09/27/23
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 97
Appendices
COVID-19: ETA Needs a Plan to Reconcile and Return to
the U.S. Treasury Nearly $5 Billion Unused by States for
ETA 1 $105,100,000
a Temporary Unemployment Insurance Program;
Report No. 19-23-015-03-315; 09/28/23
MSHA Needs to Provide Better Oversight of Emergency
MSHA Response Plans; 2 $0
Report No. 05-17-002-06-001; 03/31/17
FISMA Fiscal Year 2015: Ongoing Security Deficiencies
OASAM 1 $0
Exist; Report No. 23-16-002-07-725; 09/30/16
OFCCP Did Not Show It Adequately Enforced EEO
OFCCP Requirements on Federal Construction Contracts; 1 $0
Report No. 04-20-001-14-001; 03/27/20
DOL’s IT Governance Lacked the Framework Necessary
OSEC to Support the Overall Mission; 1 $0
Report No. 23-21-002-01-001; 09/30/21
COVID-19: OSHA Needs To Do More To Address High
OSHA Injury Rates of Warehouse Workers; 3 $0
Report No. 19-23-013-10-105; 09/27/23
OWCP Did Not Ensure Best Prices and Allowed
OWCP Inappropriate, Potentially Lethal Prescriptions in the 3 $321,261,486
FECA Program; Report No. 03-23-001-04-431; 03/31/23
Agency Management Decision or Grant/Contracting Officer’s Final Determination Not Issued
By Close of Period
Total Nonmonetary Recommendations and Questioned Costs 21 $426,361,486
continued on next page
98 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Number of
Funds
Agency Report Title; Report Number; Date Issued Recommended for
Recommendations Better Use ($)
Agency Management Decision or Grant/Contracting Officer’s Final Determination Did Not
Resolve; OIG Negotiating with Agency
Alert Memorandum: Potentially Fraudulent
Unemployment Insurance Payments in High Risk Areas
ETA 1 $29,581,490,253
Increased to $45.6 Billion; Report No. 19-22-005-03-315;
09/21/22
Alert Memorandum: ETA Needs to Incorporate Data
Analytics Capability to Improve Oversight of the
ETA 1 $1,292,205,723
Unemployment Insurance Program;
Report No. 19-23-012-03-315; 09/25/23
COVID-19: The Employment and Training Administration
ETA Needs to Improve Oversight of Grants Awarded in New 1 $100,098,923
Jersey; Report No. 19-23-016-03-391; 09/28/23
Total Funds Recommended for Better Use 3 $30,973,794,899
Total Audit Exceptions and Questioned Costs 21 $426,361,486
Total Funds Recommended for Better Use 3 $30,973,794,899
Total Audit Exceptions, Questioned Costs, and Funds Recommended for
24 $31,400,156,385
Better Use
Semiannual Report to Congress | October 1, 2023–March 31, 2024 99
Appendices
Management Decision Made During this
Reporting Period on Audits, Inspections,
or Evaluations Issued during a Previous
Reporting Period: Final Audit Reports Issued
Management Decision
Questioned Costs ($)
Number of Funds Put to Better
Report Title; Report Number; Date Issued Made on Previously
Recommendations Use ($)
Issued Audits
Employment and Training Administration
Tracking the Department of Labor’s
No
Unemployment Insurance Response to
0 $0 $0 Response
Local Communities During the Pandemic;
Required
Report No. 19-23-007-03-315; 07/10/23
ETA Did Not Provide Adequate Oversight of
Emergency Administrative Grants; 3 $136,353,568 $0 Yes
Report No. 19-23-006-03-315; 07/27/23
COVID-19: Audit of State Workforce
Agencies’ Information Technology Systems No
Capability in Processing Unemployment 0 $0 $0 Response
Insurance Claims; Required
Report No. 19-23-008-03-315; 09/19/23
COVID-19: Unemployment Relief for
Governmental Entities and Nonprofit
Organizations Should Have Been Better 3 $29,074,061 $0 Yes
Managed;
Report No. 19-23-010-03-315; 09/21/23
continued on next page
100 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
COVID-19: ETA Can Improve Its Oversight
to Ensure Integrity over CARES Act UI
3 $0 $0 Yes
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 3 $0 $1,292,205,723 Yes
Insurance Program;
Report No. 19-23-012-03-315; 09/25/23
COVID-19: Pandemic Unemployment
Assistance for Non-Traditional Claimants
Weakened by Billions in Overpayments, 3 $0 $0 Yes
Including Fraud;
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 8 $105,100,000 $4,948,811,006 Yes
Unemployment Insurance Program;
Report No. 19-23-015-03-315; 09/28/23
COVID-19: The Employment and Training
Administration Needs to Improve Oversight
7 $7,165,040 $100,098,923 Yes
of Grants Awarded in New Jersey;
Report No. 19-23-016-03-391; 09/28/23
Total (9 Reports)
Occupational Safety and Health Administration
COVID-19: OSHA Needs to Strengthen Its
Process for Awarding Future Emergency
2 $0 $0 Yes
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
7 $0 $0 Yes
Workers;
Report No. 19-23-013-10-105; 09/27/23
Total (2 Reports)
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 101
Appendices
Office of the Assistant Secretary for Administration and Management
Memorandum: U.S. Department of Labor’s
No
Purchase and Travel Card Risks Assessed
0 $0 $0 Required
as Low and Moderate;
Response
Report No. 22-23-007-50-598; 08/30/23
Total (1 Report)
Office of the Chief Financial Officer
The U.S. Department of Labor Did Not Meet
the Requirement for Compliance with the
Payment Integrity Information Act for Fiscal 3 $0 $0 Yes
Year 2022; Report No. 22-23-006-13-001;
6/9/23
Total (1 Report)
Office of Workers’ Compensation Programs
Service Auditors’ Report on the Integrated
Federal Employees’ Compensation
System; Service Auditors’ Report on Optum
Workers’ Compensation and Auto No-
Fault Retail Pharmacy Network Services No
System; and Service Auditors’ Report on 0 $0 $0 Response
the U.S. Department of Labor Workers’ Required
Compensation Medical Bill Processing
System;
Report No. 22-23-008-04-431; 09/20/23
Total (1 Report)
Final Audit Total (14 Reports) 42 $277,692,669 $6,341,115,652
102 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Management Decision Made During this
Reporting Period on Audits, Inspections,
or Evaluations Issued during a Previous
Reporting Period: Other Reports Issued
Management
Number of Decision Made by
Report Title; Report Number; Date Issued
Recommendations End of Reporting
Period
Employment and Training Programs
Workforce Innovation and Opportunity Act
Quality Control Review for the Single Audit of the
Puerto Rico Department of Economic Development and No Response
0
Commerce for the Fiscal Year Ended June 30, 2021; Required
Report No. 24-23-004-50-598; 09/19/23
Quality Control Review for the Single Audit of South
Carolina Department of Employment Workforce for the
7 Yes
Year Ended June 30, 2021;
Report No. 24-23-003-50-598; 09/26/23
Quality Control Review for the Single Audit of the Center
No Response
for Workforce Inclusion, Inc., for the Fiscal Year Ended 0
Required
June 30, 2022; Report No. 24-23-005-50-598; 09/27/23
Total (3 Reports)
Other Reports Total (3 Reports) 7
Semiannual Report to Congress | October 1, 2023–March 31, 2024 103
Appendices
Corrective Actions Taken by the Department
During this reporting period, we took final action to close recommendations within reports based on
corrective action taken by the Department. The following is a summary of the most significant actions.
COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds from
Improper Payments Including Fraud or From Payment Delays;
Report No. 19-22-006-03-315; 09/30/22
On March 27, 2020, under the CARES Act, Congress provided expanded UI benefits to workers who
were unable to work as a direct result of the COVID-19 pandemic. The expanded benefits required
ETA to oversee states’ implementation of major changes to the UI system. Our audit found that
states prioritized expediency over safeguards. For example, four states we sampled did not perform
required procedures to determine eligibility.
These four states were not alone in suspending eligibility and payment controls. In our survey,
77 percent of responding states indicated they had used benefit payment control staff to process
payments, and 54 percent of responding states indicated they had temporarily suspended payment
integrity functions to pay claimants faster. We determined that states not performing eligibility testing
was one of four causes attributing to states paying historic levels of improper payments. As a result,
we recommended that ETA54 require states to have written policies and procedures, which apply
lessons learned during the COVID-19 pandemic, to ensure eligibility testing and Benefit Payment
Control procedures continue during emergencies or other times of increased claims volume.
In response to our audit, ETA issued Unemployment Insurance Program Letter No. 1123 on
July 13, 2023, stating that required program integrity functions cannot be suspended in future
mass layoff events without explicit statutory authorization. Furthermore, ETA reiterated to the
states the importance of conducting these program integrity functions.
COVID-19: Pandemic Unemployment Assistance for Non-Traditional Claimants
Weakened by Billions in Overpayments, Including Fraud;
Report No. 19-23-014-03-315; 09/27/23
The PUA program extended UI benefits to individuals who were not traditionally eligible, including
self-employed workers, independent contractors, those with limited work history, and others. ETA is
54 ETA refers to either the former Assistant Secretary, Principal Deputy Assistant Secretary, or Acting
Assistant Secretary.
104 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
responsible for providing direction and oversight of the UI program. Prior to the COVID-19 pandemic,
little was known about the effectiveness of states in providing assistance to non-traditional UI
claimants. Our audit found that 10.8 percent of PUA claims submitted by states to the OIG exhibited
potentially fraudulent activity, including instances of benefits paid to individuals with Social Security
numbers used to file UI claims in multiple states or of deceased persons. While these indicators do
not measure the full extent of PUA fraud, they indicate the program’s vulnerability. Consequently,
we recommended that ETA55 issue guidance to states on the criminal statute of limitations for
pandemic-related UI fraud, urging prompt referral of cases for investigation and emphasizing the
importance of cooperation between states and law enforcement agencies.
In response to our audit, ETA published Training and Employment Notice 12-23 on December 1, 2023,
to remind states of the statute of limitations for federal prosecution of UI fraud and to encourage
states to submit timely referrals of COVID-19 pandemic era UI fraud cases to the OIG.
Memorandum — COVID-19: ETA Can Improve its Oversight to Ensure Integrity
over CARES Act UI Programs; Report No. 19-23-011-03-315; 09/22/23
The memorandum alerted ETA management to three matters relating to the National Association
of State Workforce Agencies (NASWA) that required attention. These matters resulted from our
audit of ETA’s oversight of UI integrity for three key CARES Act programs: PUA, FPUC, and PEUC.
ETA needed to improve its oversight of NASWA’s Integrity Data Hub (IDH), a centralized platform
that brings state workforce agencies together to compare and analyze UI claims data for enhanced
detection and prevention of UI fraud and improper payments.
First, we found that ETA did not ensure that an initial assessment of NASWA’s IDH was performed
in compliance with federal requirements. Second, we found ETA did not provide documentation
it evaluated NASWA’s security assessment reports. Last, we found the IDH was less effective at
identifying potentially improper multistate claims when compared to the OIG’s data. Consequently,
we recommended the Acting Assistant Secretary for Employment and Training determine the best
threshold for flagging multistate claims in conjunction with NASWA.
In response to the last matter raised in our memorandum, ETA, in collaboration with NASWA,
determined the best threshold for flagging multistate claims. Specifically, ETA worked with the UI
Integrity Center to expand IDH’s capabilities to identify and flag multistate claims using a threshold
that reduces potential false positives and ranks the multistate claims as high priority.
55 ETA refers to either the former Assistant Secretary, Principal Deputy Assistant Secretary, or Acting
Assistant Secretary.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 105
Appendices
COVID-19: States Struggled to Implement CARES Act Unemployment Insurance
Programs; Report No. 19-21-004-03-315; 05/28/21
DOL and states struggled to implement three key new UI programs that posed the greatest risk for
fraud, waste, and abuse: PUA, FPUC, and PEUC under the CARES Act. The expanded UI benefits
required ETA to implement major changes to the existing UI system. Our audit found states with
updated IT systems implemented CARES Act UI programs more efficiently than states without
modernized IT systems. Consequently, we recommended ETA56 assess the technological needs of
the UI programs. Specifically, we recommended an assessment to determine the: (1) capabilities
that need to be upgraded or replaced, (2) features necessary to effectively respond to rapid
changes in the volume of claims in times of emergency or high unemployment, (3) capabilities
needed to ensure effective and equitable delivery of benefits, and (4) capabilities to minimize
fraudulent activities.
In response to our audit, ETA engaged the U.S. Digital Service to work with states on an
assessment initiative to inform future IT improvements with an initial meeting held in June 2021.
As of November 2023, 36 states had participated in the Department’s Tiger Teams initiative.
According to ETA, Tiger Team analyses of states’ systems and processes resulted in a better
understanding of common processes and technological opportunities and trends. Findings included
the need for: enhancing mobile-friendly technology, leveraging the use of dynamic fact-finding tools,
implementing Robotic Process Automation and Optical Character Recognition, improving claims
status tracking, and ensuring both in person and online identity-proofing solutions. In turn, these
findings directly informed the Department’s Office of Unemployment Insurance Modernization’s IT
modernization strategies.
COVID-19: More Can Be Done to Mitigate Risk to Unemployment Compensation
Under the CARES Act; Report No. 19-20-008-03-315; 08/07/20
Past audits of expansion of the UI program revealed that ETA did not adequately ensure proper
controls were in place to protect funds and ensure they were paid to eligible claimants. More than
$888 billion in total federal and state UI benefits were paid for benefit weeks during the UI pandemic
period. With the historic increase in costs for the program, ETA’s oversight was critical to ensure that
funds were protected from fraud, waste, or abuse.
Our audit found that, despite OMB Circular A-123 requiring the inclusion of all payments in improper
payment estimates, ETA did not measure the accuracy of payments in the CARES Act UI programs.
By excluding these temporary programs from its Benefit Accuracy Measurement (BAM) program,
56 ETA refers to either the former Assistant Secretary, Principal Deputy Assistant Secretary, or Acting
Assistant Secretary.
106 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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ETA risked materially underestimating UI improper payments for fiscal years 2020 and 2021. As a
result, we recommended that ETA57 include CARES Act UI transactions in the BAM or develop an
alternative methodology to reliably estimate improper payments for those programs.
In response to our audit, ETA estimated improper payments for CARES Act UI programs. In December
2021, ETA applied the BAM improper payment rate estimates from its permanent UI programs to the
temporary FPUC and PEUC programs because, according to ETA officials, the programs’ claims
processes and eligibility requirements were similar. For the PUA program, ETA designed an alternate
methodology to BAM by testing 2,540 sampled cases from 26 states to develop a national improper
payment rate. On August 21, 2023, ETA published its PUA Improper Payment Report, which cited a
PUA improper payment rate estimate of 35.9 percent. Although not yet verified, ETA’s development of
a PUA improper payment rate addressed a crucial OIG recommendation.
COVID-19: OSHA’s Enforcement Activities Did Not Sufficiently Protect Workers
from Pandemic Health Hazards; Report No. 19-23-001-10-105; 10/31/22
The COVID-19 pandemic presented OSHA with significant worksite enforcement and inspection
challenges in its operations and efforts to safeguard workers. We found OSHA’s enforcement activities
did not sufficiently protect workers from COVID-19 health hazards because OSHA: (1) did not issue
citations to enforce the standard for recording and reporting occupational injuries and illnesses in
15 percent of sampled fatality inspections, (2) lacked complete information on COVID-19 infection
rates at worksites, and (3) closed inspections without ensuring it had received and reviewed all items
requested from employers to demonstrate alleged COVID-19 health hazards had been mitigated.
These issues occurred because OSHA had not established controls to ensure citations were
issued or to document the rationale; did not require employers to report all COVID-19 cases among
workers; and did not have a tool to ensure it received and reviewed all requested documentation
prior to closing inspections. As a result, there was a heightened risk that workers suffered
unnecessary exposure to the virus. Consequently, we recommended that the Assistant Secretary
for Occupational Safety and Health provide additional training to Compliance Safety and Health
Officers to enforce the recording and reporting standard for fatalities.
In response to our audit, OSHA’s Directorate of Technical Support and Emergency Management and
Office of Training and Education developed Course 1908 - OSHA Recordkeeping for Compliance
Officers. The course is a recordkeeping and reporting webinar to train Compliance Safety and Health
Officers on OSHA’s requirements for the recording of work-related fatalities, injuries, and illnesses that
meet its recording criteria. The webinar also covers OSHA’s reporting requirements for work-related fatalities,
in-patient hospitalizations, amputations, losses of eye, and infectious diseases such as tuberculosis.
57 ETA refers to either the former Assistant Secretary, Principal Deputy Assistant Secretary, or Acting
Assistant Secretary.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 107
Appendices
Unimplemented Recommendations
During this reporting period, there were 8 instances of audits or evaluations provided to the Department for
comment that were not responded to within 60 days. Management decisions were received in response to
all audits and evaluations issued before the commencement of this reporting period.
From October 1, 2011, through September 30, 2023, the OIG made 1,810 audit recommendations, of which
169 have not been fully implemented. These 169 recommendations include 136 recommendations resulting
from audits issued since the end of FY 2020, and, in many cases, the corrective action plans are in place.
RECOMMENDATIONS MADE PRIOR TO OCTOBER 1, 2023, NOT YET
IMPLEMENTED
Total Number of Unimplemented Recommendations
Fiscal Year Recommendations
Made Total Number Monetary Impact ($)
2011 319 6 $0
2012 213 0 $0
2013 195 0 $0
2014 128 1 $0
2015 163 1 $0
2016 100 1 $0
2017 112 8 $0
2018 98 1 $0
2019 84 15 $0
2020 105 10 $0
2021 133 40 $39,311,226,638
2022 67 22 $29,581,490,253
2023 93 64 $6,940,069,807
Total 1,810 169 $75,832,786,698
108 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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 Issue guidance directing states to provide access to state UI
Done to Mitigate Risk to claimant data to prevent and detect fraud.
Unemployment Compensation
Under the CARES Act;
Report No. 19-20-008-03-315;
08/07/20
Alert Memorandum: The Establish effective controls, in collaboration with SWAs, to mitigate
Employment and Training fraud and other improper payments to ineligible claimants,
Administration (ETA) Needs including the areas identified in the memorandum: UI benefits paid
to Ensure State Workforce to multistate claimants, claimants who used the Social Security
Agencies (SWA) Implement numbers of deceased individuals, potentially ineligible federal
Effective Unemployment inmates, and claimants with suspicious email accounts. Effective
Insurance Program Fraud controls will help prevent similar or greater amounts of fraud and
Controls for High Risk Areas; allow those funds to be put to better use;
Report No. 19-21-002-03-315; Work with Congress to establish legislation requiring SWAs to
02/22/21 cross-match high-risk areas, including the four areas identified in
the memorandum.
COVID-19: States Struggled Continue to work with states to develop, operate, and maintain
to Implement CARES Act a modular set of technological capabilities to modernize the
Unemployment Insurance delivery of UI benefits that is sufficient to manage and process
Programs; sudden spikes in claims volume during emergencies or high
Report No. 19-21-004-03-315; unemployment.
05/28/21
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Semiannual Report to Congress | October 1, 2023–March 31, 2024 109
Appendices
Alert Memorandum: The Amend 20 C.F.R. 603.5 and 603.6(a) through the rulemaking
Employment and Training process to reinforce that UI information must be provided to DOL
Administration Needs to Issue OIG for all IG engagements authorized under the IG Act, including
Guidance to Ensure State audits, evaluations, and investigations.
Workforce Agencies Provide
Requested Unemployment
Insurance Data to the Office of
Inspector General;
Report No. 19-21-005-03-315;
06/16/21
Alert Memorandum: The Take immediate action to require the National Association of State
Employment and Training Workforce Agencies to refer information to ETA and the OIG on
Administration Does Not suspected fraud, waste, abuse, mismanagement, or misconduct,
Require the National per Department of Labor Manual Series (DLMS) 8-106(D)(3).
Association of State Workforce Such actions could include modification of ETA’s grant award or
Agencies to Report Suspected issuance of unemployment insurance program policy guidance to
Unemployment Insurance ensure ETA complies with the notice requirement and its grantees
Fraud Data to the Office of comply with the reporting requirements of the DLMS.
Inspector General or the
Employment and Training
Administration;
Report No. 19-21-006-03-315;
07/01/21
Alert Memorandum: The Continue to identify states that have not complied with ETA’s
Employment and Training reporting requirements for CARES Act UI programs and work with
Administration Needs to them to ensure missing reports and information are submitted
Ensure State Workforce before commencement of the Department’s FY 2022 financial
Agencies Report Activities statement audit;
Related to CARES Act Verify the accuracy of reports that cite no activity and ensure
Unemployment Insurance corrections are made where warranted.
Programs;
Report No. 19-22-004-03-315;
08/02/22
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110 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Alert Memorandum: Implement immediate measures to ensure SWAs are required
Potentially Fraudulent to provide ongoing access to the OIG by amending its current
Unemployment Insurance guidance to require disclosures to the OIG for audits and
Payments in High-Risk Areas investigations as necessary, mandatory, and without time limitation
Increased to $45.6 Billion; for the proper oversight of the UI program;
Report No. 19-22-005-03-315; Expedite OIG-related amendments to 20 C.F.R. § 603.6(a) to make
9/21/22 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.
COVID-19: ETA and States Did Use data collected from monitoring and BAM reports to identify
Not Protect Pandemic-Related the areas of highest improper payments including fraud and create
UI Funds from Improper a plan to prevent similar issues in future temporary UI benefit
Payments Including Fraud or programs;
from Payment Delays; Work with NASWA to update the IDH Participant Agreement to
Report No. 19-22-006-03-315; require state to submit the results of their UI fraud investigations;
09/30/22 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;
Work with the OIG and states to recover the greatest practicable
amount of the $7,092,604 paid to claimants connected to likely
fraudulent claims.
ETA Did Not Provide Adequate Specify within its policy the information states must include in their
Oversight of Emergency documentation to support compliance with the requirements to
Administrative Grants; receive grant funds prior to disbursement of the funds;
Report No. 19-23-006-03-315; Propose to the Office of Management and Budget an amendment
07/27/23 to the annually updated Compliance Supplement for single audits
to also disclose if states used the emergency administrative grant
funds in accordance with applicable requirements in the single audit
report; Remedy the $136,353,568 in questioned costs.
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 111
Appendices
COVID-19: Unemployment Obtain evidence from the states to ensure all refunds and credits
Relief for Governmental under the EURGENO program have been provided to entitled
Entities and Nonprofit employers; Work with states to reconcile remaining funds in
Organizations Should Have state accounts; Determine the proper disposition of excess funds
Been Better Managed; provided to states under the EURGENO program; and Take
Report No. 19-23-010-03-315; necessary actions, including the recovery of questioned costs.
09/21/23
Alert Memorandum: ETA Needs Obtain direct access to unemployment insurance claims data from
to Incorporate Data Analytics all State Workforce Agencies; Create an integrity program that
Capability to Improve Oversight incorporates a data analytics capability and regularly monitors
of the Unemployment state unemployment insurance claims data to detect and prevent
Insurance Program; improper payments, including fraudulent payments, and to identify
Report No. 19-23-012-03-315; trends and emerging issues that could negatively impact the
09/25/23 unemployment insurance program.
COVID-19: Pandemic Work with Congressional stakeholders to inform them of the
Unemployment Assistance urgency of the statute of limitations concerning pandemic-related UI
for Non-Traditional Claimants fraud.
Weakened by Billions in
Overpayments Including Fraud;
Report No. 19-23-014-03-315;
09/27/23
COVID-19: ETA Needs Work with Oregon, Louisiana, Delaware, and Mississippi to
a Plan to Reconcile and ensure the appropriate return of approximately $105.1 million in
Return to the U.S. Treasury TFFF reimbursements for first-week regular UI compensation
Nearly $5 Billion Unused paid that were associated with ineligible weeks; Establish a
by States for a Temporary deadline by which states are required to perform a timely review
Unemployment Insurance of past drawdowns and provide evidence that drawdowns were
Program; for reimbursement of eligible first-week regular UI compensation
Report No. 19-23-015-03-315; paid by the state for claim weeks that fell within the TFFF program
09/28/23 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.
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112 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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Worker Safety
MSHA Needs to Provide Clarify mine operators’ responsibilities for local coordination
Better Oversight of Emergency under the Mine Improvement and New Emergency Response
Response Plans; (MINER) Act, including coordination and communication between
Report No. 05-17-002-06-001; the operator, mine rescue teams, and local emergency response
03/31/17 personnel, and familiarizing local rescue personnel with surface
functions that may be required in the course of mine rescue work.
MSHA Needs to Improve Adopt a lower legal exposure limit for silica in coal mines based on
Efforts to Protect Coal Miners recent scientific evidence; Establish a separate standard for silica
from Respirable Crystalline that allows MSHA to issue citations and monetary penalty when
Silica; violations of its silica exposure limit occur; Enhance its sampling
Report No. 05-21-001-06-001; program to increase the frequency of inspector samples where
11/12/20 needed (e.g., by implementing a risk-based approach).
OSHA’s Diminished Implement a policy for future emphasis programs that minimizes the
Enforcement Left More lapse in enforcement between canceled, revised, or new programs;
Workers at Risk for Exposure Establish meaningful goals and processes to assess whether
to Silica; OSHA’s outreach events are achieving the desired results in
Report No. 02-21-003-10-105; reaching a targeted number of workers at risk of exposure to silica.
09/29/21
COVID-19: To Protect Mission Develop an OSHA outreach plan to be activated during a large-scale
Critical Workers, OSHA safety and health crises such as the COVID-19 pandemic that (a)
Could Leverage Inspection identifies external federal agencies with enforcement or oversight
Collaboration Opportunities personnel who are active on worksites and (b) defines how OSHA will
with External Federal Agencies; collaborate with those agencies. OSHA should consider incorporating
Report No. 19-22-003-10-105; into the plan: a process to identify and document highly visible safety
03/31/22 and health hazards for large-scale safety and health crises; a plan
for how OSHA will conduct related outreach and training on those
hazards and how to refer them to OSHA; and a tracking system
for agency referrals and outcomes of those referrals, using that
information to periodically inform the outreach plan on areas and types
of guidance and training the agencies’ oversight and enforcement
personnel need; Explore mechanisms to enhance collaboration, such
as memorandums of understanding or other written agreements using
GAO’s seven key features for collaboration, and incorporate a process
to utilize those mechanisms into the outreach plan.
continued on next page
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Appendices
COVID-19: OSHA’S As part of OSHA’s rulemaking on infectious diseases, require
Enforcement Activities Did Not employers to notify all employees of all known positive cases of
Sufficiently Protect Workers infectious diseases at the worksite;
from Pandemic Health Develop and implement a tracking tool to ensure OSHA receives
Hazards; and reviews all items CSHOs request during inspections to ensure
Report No. 19-23-001-10-105; alleged hazards have been mitigated.
10/31/22
OSHA Needs to Better Modify the Field Operations Manual to include a policy for
Address Complaints and mandatory interviews of complainants and witnesses or document
Referrals for Increased Worker the rationale for lack thereof and provide training to Compliance
Safety; Safety and Health Officers on the updated requirements.
Report No. 02-23-001-10-105;
03/06/23
COVID-19: OSHA Needs to do Develop specific, measurable inspection goals for the Site-
More to Address High Injury Specific Targeting program, including a baseline for the number
Rates of Warehouse Workers; of inspections in each Site-Specific Targeting category, and
Report No. 19-23-013-10-105; periodically monitor progress toward those goals;
09/27/23 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.
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114 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Employment and Training Programs
ETA Did Not Sufficiently Plan Improve funding opportunity announcements (FOA) for
and Execute the American discretionary grant programs by:
Apprenticeship Initiative Grant (a) evaluating program goals using the SMART concept or a similar
Program; approach, and including required metrics that directly measure the
Report No. 05-21-004-03-375; success of each program goal, are clear, and are easily verifiable;
09/30/21 (b) having a scoring element covering completeness of applicant
proposals for items requested in the announcement that reduces
in points when the proposal is missing an element(s), significantly
changes the wording of an element(s), or incorrectly addresses
an element(s); and (c) identifying targeted occupations in the
FOA language and/or scoring elements, or requiring submission
of the career pathway to an H-1B occupation as support during
apprenticeship program registrations or apprentice registrations.
Employee Benefits
EBSA Did Not Have the Ability Reduce or eliminate exemption thresholds for small plans.
to Protect the 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
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Semiannual Report to Congress | October 1, 2023–March 31, 2024 115
Appendices
OWCP Did Not Ensure Implement a process to ensure competitive prices for the FECA
Best Prices and Allowed program by regularly evaluating alternate pricing methodologies
Inappropriate, Potentially and other sources—including publicly available benchmark price
Lethal Prescriptions in the lists, state fee schedules, market research, and comparable
FECA Program; payers—and updating its pricing methodology as appropriate;
Report No. 03-23-001-04-431; Implement a process to review the effectiveness of policy
3/31/23 changes, including: (a) documented assessment of prescription
information after any changes in the authorization, approval, and/
or adjudication process; and (b) documented solutions for any
performance gaps identified during the review, including follow-
up testing; Implement an ongoing pharmaceutical monitoring and
alert program to identify and closely monitor significant changes
in costs, prescribing patterns, utilization, sources, and new and
novel prescription drugs; Establish internal controls that identify
prescription drugs payment and management issues in near-
real-time; Implement a technology solution to perform ongoing
prescription-claim-level reviews in near-real-time; Develop
and deliver ongoing formal training for staff involved in making
pharmaceutical decisions.
Departmental Management
FISMA Fiscal Year 2015: Realign the organizational structure as it relates to the Chief
Ongoing Security Deficiencies Information Officer to address organizational independence issues.
Exist;
Report No. 23-16-002-07-725;
09/30/16
FY 2019 FISMA DOL Implement improvements in DOL’s information security program
Information Security Report: for the following areas: Configuration Management, and Access
Implementation of Security Management, Data Protection and Privacy.
Tools Hindered by Insufficient
Planning;
Report No. 23-20-002-07-725;
12/23/19
DOL Needs to Do More to Establish and implement procedures to ensure E2 Solutions (E2)
Secure Employees’ Personally account management practices enforce DOL’s security policies;
Identifiable Information in the Establish and implement procedures to ensure E2 is managed
Travel Management System; in compliance with contractual security requirements and DOL
Report No. 23-20-003-13-001; computer security policies for contracted information systems.
09/10/20
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116 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
FY 2020 FISMA DOL Implement a process for approving deviations from established
Information Security Report: configuration settings.
Progress Needed to Improve
Risk Management and
Continuous Monitoring
Information Security Controls;
Report No. 23-21-001-07-725;
12/22/20
DOL’s IT Governance Lacked Reorganize the Chief Information Officer position to have a direct
the Framework Necessary to reporting relationship to the Deputy Secretary and independent of
Support the Overall Mission ASAM;
Report; Ensure the Chief Information Officer is a lead member with voting
Report No. 23-21-002-01-001; rights of DOL’s executive strategy and management boards and
09/30/21 committees, including but not limited to the Management Review
Board, Enterprise Shared Services Governance Board, COVID-19
Coordination team, and Enterprise Risk Management Council;
Establish an MOU or other agreement between the Office of
the Chief Information Officer and all departmental agencies to
establish and state the roles and responsibilities of IT between
each set of respective agencies; Reassess the incorporation
of BLS and OCFO as part of IT Shared Services within 2021,
and document the reasoning for the decision reached; Codify
the policies and procedures that define IT governance and key
supporting IT elements.
FY 2022 FISMA DOL Update DOL entity-wide and system-level security policies,
Information Security Report: procedures, and plans to comply with NIST SP 800-53, Rev. 5;
DOL’s Information Security Implement proper quality control to ensure change management
Program Not Remaining processes are being performed for all systems and equipment on
Current with Security the DOL network; Implement data loss prevention tools and alerts
Requirements; based on the results of agencies’ data exfiltration tests; Verify if
Report No. 23-23-001-07-725; systems have been appropriately authorized in accordance with
02/10/23 DOL’s policy.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 117
Appendices
Summary of Reports with Unimplemented
Recommendations with Cost Savings / Funds
Put to Better Use
Number of
Funds Put to
Report Title; Report Number; Date Issued Unimplemented
Better Use ($)
Recommendations
Employment and Training Administration
Alert Memorandum: The Employment and Training Administration
(ETA) Needs to Ensure State Workforce Agencies (SWA) Implement
Effective Unemployment Insurance Program Fraud Controls for High
Risk Areas; Report No. 19-21-002-03-315; 02/22/21
Establish effective controls, in collaboration with SWAs, to mitigate
fraud and other improper payments to ineligible claimants, 1 $5,409,966,198
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
1 $33,745,677,576
Continue to work with states to develop, operate, and maintain a
modular set of 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.
continued on next page
118 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
ETA Did Not Sufficiently Plan and Execute the American
Apprenticeship Initiative Grant Program;
Report No. 05-21-004-03-375; 09/30/21
Improve funding opportunity announcements for discretionary
grant programs by conducting the following: Evaluate program
goals using the SMART concept or a similar approach, and
include required metrics that directly measure the success of
each program goal, are clear, and are easily verifiable; have a 1 $155,582,864
scoring element covering completeness of applicant proposals for
items requested in the announcement that reduces in points when
the proposal is missing an element(s), significantly changes the
wording of an element(s), or incorrectly addresses an element(s);
and identify targeted occupations in the FOA language and/or
scoring elements, or require submission of the career pathway
to an H-1B occupation as support during apprenticeship program
registrations or apprentice registrations
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 of UI information to DOL OIG mandatory by 1 $29,581,490,253
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, 2023–March 31, 2024 119
Appendices
COVID-19: ETA Needs a Plan to Reconcile and Return to the
U.S. Treasury Nearly $5 Billion Unused by States for a Temporary
Unemployment Insurance Program;
Report No. 19-23-015-03-315; 09/28/23
1 $4,948,811,006
Establish written procedures and deadlines for the timely return of
funding for TFFF and future similar programs and consult with OMB
and Treasury officials to execute the proper return of unused funds
that remain within states’ accounts.
COVID-19: The Employment and Training Administration Needs to
Improve Oversight of Grants Awarded in New Jersey;
Report No. 19-23-016-03-391; 09/28/23
1 $100,098,923
Develop and implement risk tolerance for the amount of participants
being served under the WIOA Adult, Youth, and Dislocated Workers
program.
Total 7 $75,233,832,543
120 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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, 2024). For identification of
each recommendation made before March 31, 2024, visit our online Recommendation Dashboard.
Number of Unimplemented or
Report Title; Report Number; Date Issued Unimplemented Disallowed Costs
Recommendations Owed
Employee Benefits Security Administration
Limited-Scope Audits Provide Inadequate Protections to Retirement
1 $0
Plan 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 1 $0
of Health Claims; Report No. 05-17-001-12-121; 11/18/16
Employment and Training Administration
Investigative Advisory Report – Weaknesses Contributing to Fraud in
the Unemployment Insurance Program; Report No. 50-15-001-03-315; 1 $0
07/24/15
ETA Violated the Bona Fide Needs Rule and the Antideficiency Act;
1 $0
Report No. 26-17-002-03-370; 09/21/17
COVID-19: More Can Be Done to Mitigate Risk to Unemployment
Compensation Under the CARES Act; Report No. 19-20-008-03-315; 1 $0
08/07/20
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 121
Appendices
Alert Memorandum: The Employment and Training Administration
(ETA) Needs to Ensure State Workforce Agencies (SWA) Implement
1 $0
Effective Unemployment 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
1 $0
Insurance 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
3 $0
Provide Requested Unemployment Insurance Data to the Office of
Inspector General; Report No. 19-21-005-03-315; 06/16/21
Alert Memorandum: The Employment and Training Administration
Does Not Require the National Association of State Workforce
Agencies to Report Suspected Unemployment Insurance Fraud Data 1 $0
to the Office of Inspector General or the Employment and Training
Administration; Report No. 19-21-006-03-315; 07/01/21
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
3 $0
Initiative Grant Program; Report No. 05-21-004-03-375; 09/30/21
COVID-19: Safety and Remote Learning Challenges Continue for Job
1 $0
Corps; Report No. 19-22-001-03-370; 11/12/21
Alert Memorandum: The ETA Needs to Ensure SWAs Report Activities
Related to CARES Act UI Programs; Report No. 19-22-004-03-315; 2 $0
08/02/22
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 Pandemic Related UI
Funds from Improper Payments, Including Fraud or from Payment 4 $0
Delays; Report No. 19-22-006-03-315; 09/30/22
continued on next page
122 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Quality Control Review: Single Audit of AARP Foundation for the Year
2 $0
Ended December 31, 2021; Report No. 24-22-004-50-598; 09/30/2258
Quality Control Review of the Single Audit of State of New Mexico
Workforce Solutions Department for the Year Ended June 30, 2021; 2 $0
Report No. 24-23-001-50-598; 03/07/2358
Quality Control Review of South Carolina Department of Employment
7 $0
Workforce's Single Audit; Report No. 24-23-003-50-598; 09/26/2358
ETA Did Not Provide Adequate Oversight of Emergency
3 $136,353,568
Administrative Grants; 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
2 $0
CARES Act 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 2 $0
Program; 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; 2 $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
6 $105,100,000
Unemployment Insurance 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
continued on next page
58 The QCR Single Audit Report recommendations are addressed to the accounting firm; however, ETA funds the
grant and are copied during report issuance. Hence the addition to the ETA section of the table. The accounting firm
will address the recommendations.
Semiannual Report to Congress | October 1, 2023–March 31, 2024 123
Appendices
Mine Safety and Health Administration
MSHA Needs to Provide Better Oversight of Emergency Response
6 $0
Plans; Report No. 05-17-002-06-001; 03/31/17
MSHA Can Improve Its Pre-Assessment Conferencing Program;
9 $0
Report No. 05-19-001-06-001; 09/23/19
MSHA Needs to Improve Efforts to Protect Coal Miners from
3 $0
Respirable Crystalline Silica; Report No. 05-21-001-06-001; 11/12/20
MSHA Can Improve How Violations Are Issued, Terminated, Modified,
9 $0
and Vacated; Report No. 05-21-002-06-001; 03/31/21
Office of the Assistant Secretary for Administration and Management
Ineffective Accounting for Sensitive Information Technology Hardware
and Software Assets Places DOL at Significant Risk; 6 $0
Report No. 23-11-001-07-001; 03/31/11
FISMA Fiscal Year 2015: Ongoing Security Deficiencies Exist; Report
1 $0
No. 23-16-002-07-725; 09/30/16
Alert Memorandum: Security Vulnerability Relating to DOL Information
2 $0
Security Property; Report No. 50-19-002-07-725; 06/17/19
FY 2019 FISMA DOL Information Security Report: Implementation of
Security Tools Hindered by Insufficient Planning; 5 $0
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 2 $0
Security Controls; Report No. 23-21-001-07-725; 12/22/20
FY 2021 FISMA DOL Information Security Report: Information
Security Continuous Monitoring Controls Remain Deficient; 5 $0
Report No. 23-22-001-07-725; 01/28/22
FY 2022 DOL Made Progress in Implementing Geospatial Data Act
Requirements, But More Needs to Be Done; 3 $0
Report No. 23-22-003-01-001; 09/30/22
FY 2022 FISMA DOL Information Security Report: DOL’s
Information Security Program Not Remaining Current with Security 3 $0
Requirements; Report No. 23-23-001-07-725; 02/10/23
continued on next page
124 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Office of the Chief Financial Officer
DOL Needs To Do More to Secure Employees’ Personally Identifiable
Information in the Travel Management System; 2 $0
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 2022; 3 $0
Report No. 22-23-006-13-001; 06/09/23
Office of Federal Contract Compliance Programs
OFCCP Did Not Show It Adequately Enforced EEO Requirements
on Federal Construction Contracts; Report No. 04-20-001-14-001; 1 $0
03/27/20
Office of the Secretary
DOL’s IT Governance Lacked the Framework Necessary to Support
5 $0
the Overall 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
OSHA Procedures for Issuing Guidance Were Not Adequate and
4 $0
Mostly Not Followed; Report No. 02-19-001-10-105; 03/28/19
Review of the Occupational Safety and Health Administration’s
Referral to and Reclamation of Debt from the U.S. Department of the 1 $0
Treasury; 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
2 $0
Exposure to Silica; Report No. 02-21-003-10-105; 09/29/21
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 125
Appendices
COVID-19: To Protect Mission Critical Workers, OSHA Could
Leverage Inspection Collaboration Opportunities with External 2 $0
Federal Agencies; Report No. 19-22-003-10-105; 03/31/22
COVID-19: OSHA’s Enforcement Activities Did Not Sufficiently
Protect Workers from Pandemic Health Hazards; 4 $0
Report No. 19-23-001-10-105; 10/31/22
OSHA Needs to Better Address Complaints and Referrals for
3 $0
Increased Worker Safety; Report No. 02-23-001-10-105; 03/06/23
OSHA Needs to Strengthen Its Process for Awarding Future
Emergency Supplemental Funds to State Plans; 2 $0
Report No. 19-23-009-10-105; 08/30/23
COVID-19: OSHA Needs To Do More To Address High Injury Rates
7 $0
Of Warehouse Workers; Report No. 19-23-013-10-105; 09/27/23
Office of Workers’ Compensation Programs
OWCP Did Not Ensure Best Prices and Allowed Inappropriate,
Potentially Lethal Prescriptions in the FECA Program; 8 $321,261,486
Report No. 03-23-001-04-431; 03/31/23
Wage and Hour Division
COVID-19: The Pandemic Highlighted the Need to Strengthen Wage
and Hour Division’s Enforcement Controls; 3 $0
Report No. 19-21-008-15-001; 09/30/21
Totals 162 $598,954,155
126 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Investigative Statistics
Division
Total
Totals
Investigative Reports Issued / Cases Closed (includes investigative reports
issued, case closing reports, and matters referred for possible civil and/or 190
administrative action):
Program Fraud 173
Labor Racketeering 17
Cases Opened: 170
Program Fraud 160
Labor Racketeering 10
Cases Referred for Prosecution (each case is measured as a singular
120
statistic and may include more than one person or business entity):
Program Fraud 108
Labor Racketeering 12
Cases Referred for Administrative/Civil Action (each case is measured as
64
a singular statistic and may include more than one person or business entity):
Program Fraud 64
Labor Racketeering 0
Persons Referred to the Department of Justice for Criminal Prosecution
(includes the number of individuals and business entities referred for 197
prosecution):
Program Fraud 187
Labor Racketeering 10
Persons Referred to State and Local Prosecuting Authorities for Criminal
Prosecution (includes the number of individuals and business entities 36
referred for prosecution):
Program Fraud 32
Labor Racketeering 4
Indictments and Criminal Informations That Resulted from Any Prior
Referral to Prosecuting Authorities (includes sealed and unsealed 275
indictments):
Program Fraud 258
Labor Racketeering 17
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 127
Appendices
Indictments (includes sealed and unsealed indictments): 275
Program Fraud 258
Labor Racketeering 17
Convictions: 242
Program Fraud 219
Labor Racketeering 23
Statutory Debarments: 1
Program Fraud 1
Labor Racketeering 0
Recoveries, Cost-Efficiencies, Restitutions, Fines/
$78,413,524.24
Penalties, Forfeitures, and Civil Monetary Actions:
Program Fraud $77,149,020.51
Labor Racketeering $1,264,503.73
Recoveries (the dollar amount/value of an agency’s action to
recover or to reprogram funds or to make other adjustments in $1,240,423.48
response to OIG investigations):
Cost-Efficiencies (the one-time or per annum dollar amount/
value of management’s commitment, in response to OIG
$1,107,017.72
investigations, to utilize the government’s resources
more efficiently):
Restitutions/Forfeitures (the dollar amount/value of restitutions
$59,328,686.68
and forfeitures resulting from OIG criminal investigations):
Fines/Penalties (the dollar amount/value of fines, assessments,
seizures, investigative/court costs, and other penalties resulting $0
from OIG criminal investigations):
Civil Monetary Actions (the dollar amount/value of forfeitures,
settlements, damages, judgments, court costs, and other $16,737,396.36
penalties resulting from OIG criminal investigations):
Total $78,413,524.24
128 Semiannual Report to Congress | October 1, 2023–March 31, 2024
Appendices
Peer Review Reporting
The following meets the requirement under Section 5(1)(14)(A)–(B) of the Inspector General Act of
1978, as amended, and Section 989C of the Dodd-Frank Wall Street Reform and Consumer Protection
Act (P.L. 111–203) that the Inspectors General include their peer review results as an appendix to each
semiannual report.
Peer Review of the Treasury Inspector General for Tax Administration Inspection
and Evaluation Function
DOL-OIG conducted a peer review of the Treasury Inspector General for Tax Administration
(TIGTA) inspection and evaluation’s internal policies and procedures and whether reviewed
reports generally complied with professional standards for the period ending September 30,
2023. The peer review report issued on March 28, 2024, resulted in an opinion that TIGTA’s
policies and procedures, including reviewed reports, generally complied with the seven
professional standards reviewed in the conduct of inspections and evaluations.
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.
continued on next page
Semiannual Report to Congress | October 1, 2023–March 31, 2024 129
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.
130 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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, 2023, through March 31, 2024, a
total of 2,349 complaints were opened in the OIG Hotline’s complaint management system. A significant
number of these complaints involve concerns regarding COVID-19-related unemployment benefits.
Effective this SAR period, the OIG has suspended the referral of pandemic UI matters to State Workforce
Agencies due to resource issues. During this reporting period, the OIG Hotline received additional
complaints that are awaiting processing.
Complaints Received (by method reported) Totals
Telephone 3
E-mail/Internet 2,293
Mail 53
Fax 0
Walk-In 0
Total 2,349
Contacts Received (by source) Totals
Complaints from Individuals or Non-Governmental Organizations 1,076
Complaints/Inquiries from Congress 2
Referrals from GAO 13
Complaints from Other DOL Agencies 13
Complaints from Other (non-DOL) Government Agencies 1,245
Total 2,349
Disposition of Complaints Reviewed and Processed Totals
Referred to OIG Components for Further Review and/or Action 80
Referred to DOL Program Management for Further Review and/or Action 136
Referred to Non-DOL Agencies/Organizations 59
No Referral Required/Informational Contact 617
Total 892
Semiannual Report to Congress | October 1, 2023–March 31, 2024 131
Appendices
Acronyms and Abbreviations
AARP American Association of FECA Federal Employees’ OSHA Occupational Safety and
Retired Persons Compensation Act Health Administration
BAM Benefit Accuracy FISMA Federal Information OWCP Office of Workers’
Measurement Security Modernization Act Compensation Programs
BLS Bureau of Labor Statistics of 2014
CARES Act FLC Foreign Labor Certification PERM permanent employment
Coronavirus Aid, Relief, and FPUC Federal Pandemic certification program
Economic Security Act Unemployment PEUC Pandemic Emergency
C.F.R Code of Federal Compensation Unemployment
Regulations FY Fiscal Year/fiscal year Compensation
CIO Chief Information Officer GAO Government Accountability PII personally identifiable
DCCA Special Fund Office information
District of Columbia H-1B visa program for workers in PPP Paycheck Protection
Workmen’s Compensation specialty occupations Program
Act of 1928 H-2A visa program for agricultural PRAC Pandemic Response
Special Fund workers Accountability Committee
DCIS Defense Criminal H 2B visa program for non- PUA Pandemic Unemployment
Investigative Service agricultural workers Assistance
DEA Drug Enforcement HHS Department of Health and SBA Small Business
Administration Human Services Administration
Department or DOL HSI Homeland Security SWA State Workforce Agency
U.S. Department of Labor Investigations TFFF Temporary Full Federal
DHS Department of Homeland IDH Integrity Data Hub Funding of the First Week
Security IRS-CI Internal Revenue Service- of Compensable Regular
DOJ U.S. Department of Justice Criminal Investigation Unemployment for States
EBSA Employee Benefits Security IT information technology with No Waiting Week
Administration KPMG KPMG LLP TSP Thrift Savings Plan
EDD Employment Development Longshore Special Fund Treasury
Department Longshore and Harbor U.S. Department of the
EIDL Economic Injury Disaster Workers’ Compensation Act Treasury
Loan Special Fund TIGTA Treasury Inspector General
Energy Energy Employees MSHA Mine Safety and Health for Tax Administration
Occupational Illness Administration Trust Fund
Compensation Program MUIA Michigan Unemployment Black Lung Disability Trust
ERAP Emergency Rental Insurance Agency Fund
Assistance Program NASWA National Association of VA Department of Veterans
ERISA Employment Retirement State Workforce Agencies Affairs
Income Security Act of 1974 OCFO Office of Chief Financial UI unemployment insurance
ETA Employment and Training Officer USPIS United States Postal
Administration OCIO Office of Chief Information Inspection Service
EURGENO Officer USPS United States Postal
Emergency Unemployment OIG Office of Inspector General Service
Relief for Governmental OMB Office of Management and WHD Wage and Hour Division
Entities and Nonprofit Budget WIOA Workforce Innovation and
Organizations Opportunity Act
132 Semiannual Report to Congress | October 1, 2023–March 31, 2024
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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