UWC – Strategic Services on Unemployment & Workers’ Compensation submitted a comment letter to the U.S. Department of Labor regarding its proposed information collection request (OMB Control No. 1205-0527) for a pre‑implementation checklist to guide state workforce agencies in procuring modernized Unemployment Insurance (UI) systems. Click here to read UWC’s comments.
UWC’s comments emphasize the need for the checklist to reflect current operational realities, including the widespread use of third-party administrators and payroll providers for UI tax reporting and claims support. The letter recommends incorporating provisions for authorization frameworks such as Powers of Attorney (POAs) and Memoranda of Understanding (MOUs), while also addressing administrative burden, fraud prevention, and system integrity. Its comments focus on improving clarity, flexibility, and usability of the checklist to better support state agencies in procurement, implementation, and long-term system sustainability
Key recommendations include strengthening identity verification measures before payment of unemployment compensation, integrating critical crossmatches and reporting functions, leveraging tools such as SIDES, and ensuring alignment with federal programs and reporting requirements. UWC also underscores the importance of incorporating lessons learned from pandemic-era fraud, as documented by the GAO and DOL Office of Inspector General, to ensure modern systems are secure, efficient, and effective. The comments also highlight the importance of aligning federal guidance with practical state needs, promoting innovation, and ensuring systems are secure, scalable, and responsive to evolving workforce demands.
