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ETA grant fraud and abuse incident reporting
Summary ETA instructed grant recipients on reporting suspected fraud, program abuse, or criminal conduct involving ETA funds and attached incident reporting forms. It rescinded TEGL 6-84; TEGL 15-23 later rescinded this guidance.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
TEGL No. 2-12
Date issued
July 12, 2012
Status
Rescinded
TEGL 15-23 expressly rescinded TEGL 02-12, and ETA lists this advisory Rescinded as of 2026-10-24. Its own PDF prints Expiration Date: Continuing and rescinds TEGL 6-84.
Status last verified October 24, 2026
Is this still the rule?
This document has been rescinded. Ezel checks what federal law requires today, under current federal labor law, and answers your situation with citations.
About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2012/TEGL_2_12_acc.pdf
CLASSIFICATION
EMPLOYMENT AND TRAINING ADMINISTRATION Complaints
ADVISORY SYSTEM CORRESPONDENCE SYMBOL
U.S. DEPARTMENT OF LABOR TMG
Washington, D.C. 20210 DATE
July 12, 2012
ADVISORY: TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 2-12
TO: ETA GRANT RECIPIENTS
FROM: JANE OATES /s/
Assistant Secretary
SUBJECT: Employment and Training Administration (ETA) Grant Recipient
Responsibilities for Reporting Instances of Suspected Fraud, Program Abuse and
Criminal Conduct
1. Purpose. To transmit procedures to be used by all ETA grant recipients for reporting
allegations of fraud, program abuse or criminal conduct involving grantees or other entities
and subrecipients receiving Federal funds either directly or indirectly from ETA.
2. References.
• Workforce Investment Act of 1998, as amended (Pub. L. 105-220);
• 20 CFR 667.500, “What procedures apply to the resolution of findings arising from
audits, investigations, monitoring and oversight reviews”;
• 20 CFR 667.630, “How are complaints and reports of criminal fraud and abuse addressed
under WIA”;
• 29 CFR Part 0, “Ethics and Conduct of Department of Labor Employees”; and
• Employment and Training Order No. 1-10, Employment and Training Procedures for
Reporting and Acting on Instances of Suspected Fraud, Program Abuse, and Criminal
Conduct Involving Grantees and Contractors.
3. Background. The detection and prevention of fraud and abuse in programs authorized by
the Department of Labor (Department) are of the highest priority. Therefore, systematic
procedures for reporting instances of suspected or actual fraud, abuse or criminal conduct are
vital. States, local governments and grantees may become aware of actual, potential or
suspected fraud; gross mismanagement or misuse or program funds; conduct violations;
violations of regulations; and, abuse in ETA programs and operations provided by ETA
grantees. This Training and Employment Guidance Letter (TEGL) will provide the
Department’s policy and procedures for reporting and investigating allegations of
wrongdoing or misconduct to include allegations of suspected fraud, program abuse, and
criminal conduct involving grantees and other recipients or subrecipients of Federal funds
from ETA.
RESCISSIONS EXPIRATION DATE
TEGL 6-84 Continuing
The Incident Report (IR) form, Office of Inspector General (OIG) 1-156, is the official form
used within the Department for reporting allegations of criminal and other illegal or improper
activities in ETA funded programs. Allegations are reported to the OIG and, within ETA, to
the Office of Financial and Administrative Management (OFAM) and the Office of Regional
Management. Incidents reported using the IR form may involve allegations of fraud,
misfeasance, nonfeasance or malfeasance; allegations involving misapplication of funds;
allegations of gross mismanagement; allegations of employee/participant misconduct; and,
other potential or suspected criminal actions.
When the OIG receives an IR, they determine whether the allegations have merit and, when
appropriate, conduct or arrange for an investigation and/or audit. If the OIG determines that
the case does not have investigative or audit merit, the case is referred back to ETA for
resolution.
4. Scope and Application. This TEGL sets forth the procedures that ETA Grant Recipients
must follow for notifying the appropriate Administrators of known or suspected cases of
criminal and other illegal or improper activities involving grantees and other recipients or
subrecipients of Federal funds from ETA.
In addition to the ETA process set forth in this TEGL, the OIG operates a Hotline to receive
and process allegations of fraud, waste and abuse concerning Department grants programs
and operations. Allegations received directly through the Hotline, and written complaints
from the public pertaining to ETA, are referred by the OIG to OFAM, when appropriate.
5. Responsibilities. Grant recipients are responsible for following the procedures set forth in
this TEGL. Grant recipients must immediately document allegations, suspicions and
complaints involving possible fraud, program abuse and criminal misconduct using the IR
form. In addition, situations involving imminent health or safety concerns, or the imminent
loss of funds exceeding an amount larger than $50,000 (e.g. $500,000), are considered
emergencies and must immediately be reported to the OIG and OFAM by telephone and
followed up with a written report in the form of an IR, no later than one working day after the
telephone report.
6. Hotline Referrals. OFAM must screen and record all Hotline referrals from the OIG
pertaining to ETA and send the referrals to the appropriate Regional Administrator, Office of
Apprenticeship Regional Director or National Office Administrator (RA/RD/NOA) for
action. The RA/RD/NOA must send OFAM an initial response to all hotline referrals no
later than two weeks after receiving the referral, and must continue to provide updates in the
quarterly tracking report until the complaint is closed and a final response sent to OFAM.
No action of any kind will be taken against the complainant for providing information in
accordance with these procedures.
7. Prohibition and Reprisals. No action will be taken against any complainant for disclosing
information concerning criminal or improper activities or making a valid complaint to proper
authorities. Complainants may remain anonymous. If a complainant considers that his/her
position will be compromised by reporting information through the IR system, he/she may
send the report directly to the OIG or OFAM.
8. Action Requested. Grant recipients must be familiar with the content of this TEGL and
follow the procedures set forth herein for documenting, immediately reporting to the OIG,
and following-up on instances of alleged, suspected or known fraud, program abuse and
criminal misconduct involving grantees and other recipients or subrecipients of Federal funds
from ETA.
9. Inquiries. Questions concerning this TEGL may be directed to the Associate Deputy
Administrator for Office of Grants Management, Laura P. Watson, at (202) 693-3333.
10. Attachments.
• Attachment A - Definitions
• Attachment B - Glossary of Acronyms
• Attachment C - Incident Report Form OIG 1-156 and instructions
• Attachment D - OIG Contact Information
Attachment 1: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2012/TEGL_2_12_att_a.pdf
Attachment A
DEFINITIONS
The definitions of employee/participant misconduct; fraud, misfeasance or malfeasance; gross
mismanagement; and misapplication of funds included below were developed to provide
guidance for the purpose of this TEGL. These definitions are illustrative and are not intended to
be either fully inclusive or restrictive.
Emergency. A situation involving imminent health or safety concerns, or the imminent loss of
funds exceeding an amount much larger than $50,000 (e.g., $500,000).
Employee/Participant Misconduct. Actions occurring during or outside work hours that reflect
negatively on the Department or its mission including, but not limited to: conflict of interest or
the appearance of conflict of interest involving outside employment, business and professional
activities; the receipt or giving of gifts, fees, entertainment, and favors; misuse of Federal
property; and, misuse of official information and such other activities as might adversely affect
the confidence of the public in the integrity of the government (See 29 CFR Part 0; 5 CFR Parts
2635 and 5201) as well as serious violations of Federal and state laws.
Fraud, Misfeasance, Nonfeasance or Malfeasance. Any alleged deliberate action which may be
in violation of Federal statutes and regulations. This category includes, but is not limited to,
indications of bribery, forgery, extortion, embezzlement, theft of participant checks, kickbacks
from participants or contractors, intentional payments to a contractor without the expectation of
receiving services, payments to ghost enrollees, misuse of appropriated funds, and
misrepresenting information in official reports.
Gross Mismanagement. Actions or situations arising out of management ineptitude or oversight
and leading to a major violation of the legislative process, regulations, or contract/grant
provisions. Such actions or situations have the potential to severely hamper accomplishment of
program goals, waste government resources, and jeopardize future support for a particular
project. This category includes, but is not limited to, unauditable records, unsupported costs,
highly inaccurate fiscal reports or program reports, payroll discrepancies, payroll deductions not
paid to the Internal Revenue Service, and lack of good internal control procedures.
Incident Report (IR) (OIG 1-156). This is the primary form for reporting instances of fraud,
misapplication of funds, gross mismanagement, and any other incidents of known or suspected
criminal or other serious activities. The OIG 1-156 may also be used to provide interim and final
reports.
Misapplication of Funds. Any alleged deliberate use of funds, assets or property not authorized
or provided for by legislation or regulations, grants, or contracts. This category includes, but is
not limited to, nepotism, political patronage, use of participants for political activity, ineligible
enrollees, conflict of interest, failure to report income from Federal funds, violation of
contract/grant procedures, and the use of Federal funds for other than specified purposes. An
incident report should be filed when there appears to be an intent to misapply funds rather than
merely for a case of minor mismanagement. Indian and Native American programs are excluded
from the nepotism category, as cited in Section 632.118 of 20 CFR Part 632, Subpart F of the
WIA regulations.
OIG Hotline. The OIG operates this Hotline to receive and process allegations of fraud, waste,
and abuse concerning Department grants, contracts, programs and operations. The OIG also uses
the Hotline to address allegations of criminal activity and serious misconduct involving
Department employees. Hotline complaints can be sent directly to the Complaints Analysis
Office, Office of Inspector General, 200 Constitution Avenue, N.W., Room S-5506, Washington,
D.C. 20210. They can be telephoned to the OIG on the Toll Free Hotline at 1-800-347-3756 or
(202) 693-6999 (this is not a toll free number); or they can be emailed to [email protected].
The OIG Hotline should not be used for resolving employee grievances, Equal Employment
Opportunity complaints, labor disputes, or other personnel concerns.
OIG Hotline Referrals. The OIG prepares referrals of hotline allegations concerning problems in
ETA programs and transmits the referrals to OFAM. ETA uses the process outlined in this ETO
to follow-up on incidents included in these referrals.
Open IR. An IR is considered open until the originating or responsible ETA office determines
that it has been resolved and reports it as closed on the quarterly OFAM tracking report.
Attachment 2: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2012/TEGL_2_12_att_b.pdf
Attachment B
GLOSSARY OF ACRONYMS
DOL Department of Labor
ETA Employment and Training Administration
IR Incident Report
NOA National Office Administrator
OA Office of Apprenticeship
OFAM Office of Financial and Administrative Management
OIG Office of Inspector General
ORM Office of Regional Management
RA Regional Administrator
RD Office of Apprenticeship Regional Director
SAC Special Agent-In-Charge
Attachment 3: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2012/TEGL_2_12_att_c.pdf
U. S. DEPARTMENT OF LABOR
MANUAL SERIES Attachment C
DLMS – 8
AUDITS AND INVESTIGATIONS
Chapter 700 - Allegations of Wrongdoing or Misconduct, Incident Reporting, and
Whistleblower Protection
ETA INSTRUCTIONS FOR OIG 1-156 INCIDENT REPORT (IR)
1. Using the Incident Report Form: The OIG 1-156 Incident Report Form should be used for
filing:
(a) Initial Incident Report: Form OIG 1-156 is designed primarily as an initial report to
inform the Employment and Training Administration’s (ETA) Office of Financial and
Administrative Management (OFAM) and the Office of the Inspector General (OIG) that a
violation or apparent violation has occurred. It should also be used to inform OFAM and
OIG of cases involving ETA employees, programs, and operations being investigated by or
reported to other investigative agencies.
(b) Supplemental Incident Report: Once the initial Form OIG 1-156 has been filed Form
OIG 1-156 should be used:
(1) To provide supplemental information not available at the time of the
original report.
(2) If the matter cannot be resolved at the agency level and the case goes to
litigation or arbitration at another level, supplemental reports will be
submitted without awaiting results of adjudication or arbitration.
(c) Final Incident Report: Form OIG 1-156 should be used when:
(1) An incident is resolved, or otherwise settled.
(2) Adjudication and arbitration results are known and all requirements of
such adjudication or arbitration have been completed.
2. Completing the Incident Report Form:
The agency designation code requested in block 2 is assigned by the office preparing the form and
should include the fiscal year in which the report is being submitted, the agency acronym, and a
number to indicate the chronological sequence of the report (for example, 09-CHI-ETA-01 would
show that the report was submitted in Fiscal Year (FY) 2009, by Chicago, ETA, and was the first
report they submitted in FY 2009, and 09-OWI-ETA-02 would show that the report was submitted
in FY 2009 by the Office of Workforce Investment (OWI), ETA/NO, and was the second report
OWI submitted in FY 2009).
Block 16 should be signed on all copies by the responsible official for the office unless the
employee believes he/she should send the form directly to the OIG and OFAM.
Entries requiring additional space may be continued at the end of the synopsis entry in Block 14 or
on a separate sheet(s) of bond paper. Head each additional sheet “Continuation” and give the
Agency Identification Code from Block 2.
3. Transmitting the Completed Incident Report Form:
For IRs originating in a region or concerning a regional office (RO) program, the Regional
Administrator/Regional Apprenticeship Director (RA/RD) should send the original signed OIG 1-
156 via a transmittal memorandum to the Special Agent-In Charge (SAC) of the OIG’s Regional
Office of Labor Racketeering and Fraud Investigations within two days of discovery or receipt of
the incident report and simultaneously forward copies to OFAM and the Office of Regional
Management (ORM) or the Office of Apprenticeship (OA).
For IRs originating in the national office (NO) or concerning an NO program, the originating
office should send the original signed OIG 1-156 to OFAM within two days of discovery or receipt
of the incident report and simultaneously forward copies to ORM or OA. OFAM will send the
original IR to the OIG within two working days of receipt.
See Attachment E for SAC and other OIG addresses.
Mail ETA NO copies to:
Office of Financial and Administrative Management
200 Constitution Avenue, N.W., Room N-4653
Washington, D.C. 20210
ATTENTION: OGM
Office of Regional Management
200 Constitution Avenue, N.W., Room C-4517
Washington, D.C. 20210
or
Office of Apprenticeship
200 Constitution Avenue, N.W., Room N-5311
Washington, D.C. 20210
Note: If the report concerns Department of Labor staff, the copies for the ETA NO should be sent
in a sealed envelope addressed to the Administrator of OFAM with a notation on the envelope “TO
BE OPENED BY ADDRESSEE ONLY.”
Reset Form Fields
Incident Report U.S. Department of Labor
Office of Inspector General
For Official Use Only (When filled in) 1. Date of 2. Agency designation code 3. File Number
report (Yr.) (Agency) (Report No.) (For IG use)
4. Type of report
Initial Supplemental Final Other (Specify)
5. Type of incident
Conduct violation Criminal violation Program violation
6. Allegation against
DOL Employee Contractor Grantee Other (Specify)
Given name and position of employee(s), contractor(s), grantee, etc. List telephone number, OWCP or other Claim File Numbber, if applicable, and other
identifying data:
7. Location of incident (Give complete name(s) and addresses of organization(s) involved)
8. Date and time of incident/discovery
9. Source of complaint Public Contractor Grantee Program Audit
Participant
Invesstigative Law Enforcement Agency (Specify)
Other (Specify)
Give name and telephone number so additional information can be obtained.
10. Contacts with law enforcement agencies (Specify name(s) and agency contacted and results)
11. Expected concern to DOL
Local Regional National Media interest Executive GAO/Congressional interest
interest
Other (Specify)
12. DOL Agency involved
SECY ESA ETA ILAB LMSA MSHA OASAM OIG
OSHA SOL ASP BLS NCEP WB OIPA
Other (Specify)
Amount of grant or contract (If known) $ Amount of subgrant of $
subcontract (If known)
13. Persons who can provide additional information (Include custodian of records) Local Address (Street, City, &
State) or organization, if
employed and telephone number
Name Grade Position or Employment1
job title
1
Enter one of these codes:
U - Unemployed G-Grantee C-Contractor D - DOL F-Other Federal Employee P - Program Participant or
claimant
(Complete page 2 of this form) DL 1-156
8/83
For Official Use Only (When filled in)
14. Details of Incident (Describe the Incident)
If more room is needed attach additional sheets.
15. Typed name and title of DOL employee 16. Signature of DOL employee
17. Copies furnished to: 18. Attachments: (List)
Attachment 4: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2012/TEGL_2_12_att_d.pdf
Attachment D
CONTACT INFORMATION FOR THE OFFICE OF INSPECTOR GENERAL (OIG)
Main Address and Phone Number
Office of Inspector General
200 Constitution Avenue, NW
Room S-5502
Washington, DC 20210
Telephone: (202) 693-5100
OIG Complaints Analysis Office (Hotline)
200 Constitution Avenue, NW
Room S-5506
Washington, DC 20210
Telephone: (202) 693-6999 or 1-800-347-3756
Office of Audit
Assistant Inspector General
200 Constitution Avenue, NW
Room S-5512
Washington, D.C. 20210
Telephone: (202) 693-5170
Office of Labor Racketeering and Fraud Investigations
Assistant Inspector General
200 Constitution Avenue, NW
Room S-5014
Washington, DC 20210
Telephone: (202) 693-7034
New York Regional Office Chicago Regional Office
Special Agent-in-Charge Special Agent-in-Charge
201 Varick St. 230 South Dearborn St.
Room 891 Room 756
New York, NY 10014-4811 Chicago, IL 60604
Telephone: (646) 264-3550 Telephone: (312) 353-3342
Philadelphia Regional Office Dallas Regional Office
Special Agent-in-Charge Special Agent-in-Charge
150 South Independence Mall West Federal Office Building
Suite 1072 525 Griffin St., Room 414
Philadelphia, PA 19106 Dallas, TX 75202-9927
Telephone: (215) 446-3755 Telephone: (972) 850-4050
Washington, DC Regional Office Los Angeles Regional Office
Special Agent-in-Charge Special Agent-in-Charge
800 North Capital St. 100 North Barranca Street
Room 460 Suite 520
Washington, DC 20211 West Covina, CA 91791
Telephone: (202) 515-2600 Telephone: (626) 858-1728
Atlanta Regional Office
Special Agent-in-Charge
61 Forsyth St., SW
Room 6T1
Atlanta, GA 30303
Telephone: (404) 562-2367
Office of Legal Services
Counsel to the Inspector General
200 Constitution Avenue, NW
Room S-5506
Washington, DC 20210
Telephone: (202) 693-5116
Office of Inspections and Special Investigations
Assistant Inspector General
200 Constitution Avenue, NW
Room S-5021
Washington, DC 20210
Telephone: (202) 693-5124
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This guidance has been rescinded. Ezel checks current federal labor law as it stands now and answers your situation with citations.
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