On April 27, 2023, the U.S. Department of Labor Employment and Training Administration (ETA) announced the availability of $200 million in grant funds to states to address Integrity and Equity issues. The funds are part of those provided under the American Rescue Plan Act (ARPA). The UI-PL provides detailed guidance with respect to the requirements of grant proposals, recommendations and amounts available for each state. Additional American Rescue Plan Act (ARPA) Funding and Support for States to Strengthen Unemployment Insurance (UI) Program Integrity, including Identity (ID) Verification, Fraud Prevention and Detection, and Overpayment Recovery Efforts in All Unemployment Compensation (UC) Programs and Required and Strongly Recommended Strategies, Tools, and Services for UI Fraud Risk Mitigation and Improper Payment Reduction (dol.gov)

Requirements include:

Required Fraud Prevention and Detection Activities. States must use, operate, and maintain the following integrity controls to prevent and detect fraud

  • ID Verification (Section 1137(a)(1) of the Social Security Act and UIPL No. 35-95) including proper notification and adjudication when an eligibility issue arises (UIPL No. 16-21);
  • National Directory of New Hires crossmatch (UIPL Nos. 13-19 and 19- 11, TEN No. 05-20);
  • Quarterly Wage Records crossmatch (20 C.F.R. 603.23);
  • Systematic Alien Verification for Entitlement (SAVE) (Section 1137(d) of the Social Security Act (42 U.S.C. §1320b-7); and
  • Referral of allegations reasonably believed to constitute UC fraud, waste, abuse, mismanagement, or misconduct to DOL-OIG (UIPL No. 04-17, Change 1).

Required Overpayment Recovery Activities.

States must implement, use, and maintain the following activities to recover overpayments:

  • Benefit Offsets (Title II, Subtitle A of the Middle-Class Tax Relief and Job Creation Act of 2012, UIPL No. 05-13, and Section 5 of UIPL No. 13- 20, Change 2);
  • Treasury Offset Program (TOP) for applicable covered debt (Bipartisan Budget Act of 2013, UIPL Nos. 02-19, 12-14, and 04-20);
  • Cross Program Offset Recovery Agreement (CPORA) (UIPL No. 05-13); and
  • Interstate Reciprocal Offset Recovery Arrangement (IRORA) (UIPL No. 05-13).

In addition to the specified requirements, the UI -PL provides a series of recommendations to states and continued access to US DOL Tiger Teams for expert consultation.

Grants are available to each state in amounts ranging from $1.7 million to over $6.9 million, depending on the size of the state.

UWC supported the inclusion of funding in the ARPA. We encourage states to consider applying for these grant funds and to work with employers in the development of improved systems to avoid fraud and identity theft while assuring proper payment to eligible unemployed workers.

The deadline for states to submit grant applications is July 26, 2023. We plan to discuss this UI Pl and best practices at our National UI Issues Conference June 28 -30, 2023 in Memphis, Tennessee. The conference details are available at https://www.uwcstrategy.org/conferences/

Doug