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UI modernization grants and national identity verification offering
Summary ETA announced grants for state unemployment insurance integrity, technology modernization and support from expert teams. Initial applications for those grants were due August 18, 2023. States interested in its online or in person identity verification services were asked to express nonbinding interest by that date. UIPL No. 11-23, Change 1 later extended expected transaction cost coverage and set a data sharing agreement deadline.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 11-23
Date issued
July 13, 2023
Status
Active
The letter states that it rescinds nothing and has a Continuing expiration designation. UIPL No. 11-23, Change 1 later extended expected federal coverage of identity verification transaction costs and set a June 28, 2024 data sharing agreement deadline.
Status last verified October 24, 2026
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CLASSIFICATION
EMPLOYMENT AND TRAINING ADMINISTRATION Unemployment Insurance
ADVISORY SYSTEM CORRESPONDENCE SYMBOL
U.S. DEPARTMENT OF LABOR OUI/DPM
Washington, D.C. 20210 DATE
July 13, 2023
ADVISORY: UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 11-23
TO: STATE WORKFORCE AGENCIES
FROM: BRENT PARTON
Acting Assistant Secretary
SUBJECT: Announcement of Grant Opportunities and National Identity (ID) Verification
Offering under the American Rescue Plan Act (ARPA)
1. Purpose. To announce a comprehensive and strategic approach to deploying remaining
Unemployment Insurance (UI) modernization funds to strengthen the integrity of the UI
system. This Unemployment Insurance Program Letter (UIPL) announces three new funding
opportunities to strengthen program integrity and resiliency, as well as an opportunity for
states to participate in a National ID Verification Offering for both online and in-person ID
verification services.
2. Action Requested. The U.S. Department of Labor’s (Department) Employment and
Training Administration (ETA) requests that State Workforce Agency Administrators:
• Review the opportunity to participate in the National ID Verification Offering
described in Section 4.c. of this UIPL and contact their appropriate ETA Regional
Office to express interest by August 18, 2023 in the online or in-person services, or
both. These non-binding notifications will help inform the Department’s planning for
the designation of resources to support implementation activities.
• Review the funding opportunities described in Sections 4.b. for Integrity, 4.d. for
Information Technology (IT) Modernization, and 4.e. for Tiger Teams of this UIPL.
• Coordinate with appropriate state staff to develop Initial Applications for
opportunities the state wishes to apply for, as described in Sections 4.b.vi.C.2.,
4.d.iv.B., and 4.e.ii.B. of this UIPL.
• Submit all Initial Application materials under Sections 4.b., 4.d., and 4.e.
electronically to https://www.grants.gov/ no later than 11:59 pm Eastern Time on
August 18, 2023. Note that grants provided under the IT Modernization funding
opportunity will be awarded to states that submit complete and responsive
applications in the order such applications were received as long as funding remains
available, as described in more detail under Section 4.d.iv.B. of this UIPL.
RESCISSIONS EXPIRATION DATE
None Continuing
3. Summary and Background.
a. Summary – The Fiscal Responsibility Act of 2023 (FRA), enacted on June 2, 2023,
reduced total funding provided by Section 2118(a) of the Coronavirus Aid, Relief, and
Economic Security (CARES) Act, as amended by Section 9032 of ARPA, for
modernization of the UI program from $2 to $1 billion, leaving approximately $500
million in unobligated funds available to the Department and its state partners to pursue
the three goals under ARPA: (1) preventing and detecting fraud; (2) promoting equitable
access; and (3) ensuring the timely payment of benefits concerning the UI program.
During the COVID-19 pandemic, Congress expanded the UI system to enable it to
quickly deliver additional aid that supported millions of Americans and spurred the
economic recovery from the pandemic. The pandemic also revealed deep vulnerabilities
resulting from years of underinvestment in the system. State UI agencies entered the
COVID-19 pandemic after experiencing the lowest claims workload in 50 years, and thus
the lowest administrative funding, which significantly impacted resources and staffing
levels available to the states to manage the huge influx of claims. To add further
complication to state unemployment compensation (UC) program operations, the
frequency and complexity of fraud attacks against state UC programs increased
significantly during the pandemic. States were forced to respond to and address
relentless and sophisticated fraud attacks that continued to evolve to circumvent the
prevention and detection tools and strategies states had in place.
The Department remains committed to leveraging the remaining funds to support
meaningful transformation in the UI system so workers and the economy can continue to
rely on it to deliver benefits and protect taxpayer dollars. The Department is deploying
the remaining funds in concert with a government-wide focus on combating identity
fraud in government programs, which intensified during the pandemic and continues.
This UIPL represents a key component of the Department’s response to the report1 by the
U.S. Government Accountability Office (GAO) in June 2022, that designated the UI
program as High Risk, and called for the Department to act to transform the program in
areas of fraud prevention, infrastructure, and service delivery. In line with GAO
recommendations, this UIPL unveils a comprehensive, strategic approach to deploying
remaining UI modernization funds to improve the future integrity of the UI system—
directing the available funds and Department-provided supports to states to address fraud
prevention and system modernization.
The vulnerability of the UI system to fraud is a symptom of systemic challenges,
especially the condition and design of IT systems, which were unable to fully respond to
the huge increase in claims and exponential growth in complex fraud attacks during the
pandemic. The development of resilient IT systems that can continuously adapt to
changing conditions and integrate evolving fraud prevention technologies needed to
GAO-22-105162, Unemployment Insurance: Transformation Needed to Address Program Design, Infrastructure,
and Integrity Risks, published June 2022, https://www.gao.gov/assets/gao-22-105162.pdf.
protect the program is a critical component of a comprehensive program integrity
strategy. Such investments in IT infrastructure protect the system from fraud, while also
providing a mechanism to promote equitable access, increase timely access to benefits
and deliver improved customer experience. These IT investments complement targeted
antifraud strategies like ID verification, data analytics, and cross-matching that will also
be expanded through the funding in this UIPL—including a new national offering of
government-operated ID verification services through Login.gov and the U.S. Postal
Service (USPS) to states.
The Department is excited to partner with states to maximize the impact of these funding
opportunities to support transformations in the UI program. The systematic challenges
exposed by the pandemic evolved over decades and will take years to remedy, but the
investments outlined in this UIPL, in addition to the related funding provided in previous
UIPLs,2 mark one of the most ambitious efforts to date to drive such change.
UIPL Structure. This UIPL includes subsections for Integrity grants, a National ID
Verification Offering, IT Modernization grants, and Tiger Team grants. To aid states in
navigating this UIPL, Attachment XVI provides section references and page numbers.
By packaging these opportunities together, the Department seeks to establish a
coordinated approach nationally and among the states.
States should leverage these funding opportunities to develop multi-faceted, state-specific
antifraud and UI modernization strategies, and request grant funding for a spectrum of
projects that complement and strengthen each other.
• Integrity Grants. Section 4.b. of this UIPL announces up to $100 million in grants to
states to take immediate steps to protect the UI program from fraudulent activity and
to increase resources dedicated to overpayment recovery, by strengthening ID
verification and implementing recommended and required fraud prevention and
overpayment recovery strategies. Attachments I, II, and III to this UIPL provide
supporting information.
• National ID Verification Offering. The Department is providing online and in-
person opportunities to strengthen ID verification now and into the future. Over the
On August 11, 2021, the Department issued UIPL No. 22-21, which provided states with $140 million in ARPA
funding for fraud detection and prevention, including ID verification and overpayment recovery activities, in all UC
programs. The Department also made available up to $525 million in CARES Act funding to assist states with
efforts to prevent and detect fraud and to recover fraud overpayments in certain CARES Act UC programs. See
UIPL Nos. 28-20; 28-20, Change 1; 28-20, Change 2; and 28-20, Change 4. Additionally, UIPL No. 23-21 provided
up to $260 million in funding to assist states with activities that promote equitable access to all UC programs.
Under UIPL No. 11-22, ETA awarded grant funding to selected states to participate in the ARPA UI Navigator
Program which helps workers learn about, apply for, and, if eligible, receive UI benefits and related services (i.e.,
navigate the UI program) and supports state agencies in delivering timely benefits to workers—especially
individuals in groups that are historically underserved, marginalized, and adversely affected by persistent poverty
and inequality. UIPL No. 02-22, provided up to $200 million in funding to support states with implementation of
recommendations made following a Tiger Team consultative assessment for fraud prevention and detection,
promoting equitable access, and ensuring the timely payment of benefits, including backlog reduction, for all UC
programs.
next two (2) years, subject to the availability of funding and necessary agreements
being in place, the Department will use ARPA funds to make available to states
government-operated ID verification systems developed by the U.S. General Services
Administration (GSA) to verify identities online through Login.gov and by the USPS
to verify identities in person at participating USPS retail locations nationwide, as
described in Section 4.c. of this UIPL. The Department will cover the transaction
costs for ID verification for participating states during this process. This partnership
will further inform whether there is a need for standardized mechanisms for ID
verification within the UI system as a potential long-term, federally supported
sustainable public offering to states.
States may use Integrity Grant funding under Section 4.b. of this UIPL to offset the
costs of integrating these Department-funded services with their state operations –
including online ID verification services, in-person ID verification services, or both.
Attachment V to this UIPL provides supporting information.
• IT Modernization Grants. The condition of state UI technologies was a key reason
that state UI systems were overwhelmed by the surge of claims at the start of the
pandemic and were unable to more fully protect against fraud while implementing
Congress’s temporary extension of unemployment benefits to additional populations.
As described in Section 4.d. of this UIPL, the Department is investing funds to help
states adopt new strategies to modernize and rearchitect their UI programs to better
defend against fraud threats now and prepare for challenges in the future.
Attachments VI, VII, VIII, IX, and XV to this UIPL provide supporting information.
• Tiger Team Grants. Fraud prevention can and must be achieved while providing
equitable access to benefits and delivering timely payment of benefits. For example,
about two-thirds of all Tiger Team recommendations to date either directly or
indirectly support program integrity. Many equitable access improvements already
supported by the UI modernization work, like the conversion of UI forms into plain
language, make it easier for individuals to accurately file UI applications and reduce
improper payments. To further support these activities, the Department will provide
approximately $77 million dollars in funding for states (in addition to the $37.8
million already obligated) to implement the negotiated recommendations that states
have developed in partnership with the Department’s multi-disciplinary Tiger Team
initiative. These negotiated recommendations directly and indirectly address fraud
prevention, as well as timely payment of benefits and equitable access to benefits.
Moreover, these recommendations promote technology changes that will improve
customer experience in navigating applications and required online interactions
between workers, employers, and states–changes that fulfill all three ARPA goals.
Attachment X to this UIPL provides updated allocation amounts by state.
States may use information in Attachments XI, XII, and XIII to this UIPL to support
completion of grant applications across multiple sections of the UIPL. Attachment XIV
to this UIPL identifies additional resources, strategies, tools, and services available for
states.
Two-step application process. The grant application and award process for all funding
opportunities announced with this UIPL will be completed in two stages, an Initial
Application and a later Full Project Plan. To receive funding, the state must complete an
Initial Application for each funding opportunity it is pursuing as described in the
respective subsections of this UIPL. To facilitate a coordinated approach at the national
level, the Department has set the same deadline for all of the Initial Applications
contained in this UIPL, August 18, 2023.
Upon receipt and processing of an approvable Initial Application, a Notice of Award
(NOA) for the applicable funding opportunity will be sent to the state with a condition of
award restricting access to the funds until the grant is amended to include a Full Project
Plan. To draw down these funds, the state must subsequently submit the Full Project
Plan for each NOA to resolve the condition of award, as described in the respective
subsections of this UIPL.
Grant terms and conditions. The funding opportunities described in Sections 4.b. for
Integrity Grants, 4.d. for IT Modernization Grants, and 4.e. for Tiger Team Grants of this
UIPL are separate and distinct, with each requiring a separate two-step application
process and specific reporting requirements. The periods of performance for each
funding opportunity are described in the respective subsections of this UIPL.
Additionally, states choosing to participate in any of the grant opportunities announced in
this UIPL must agree to share confidential UC data with the Department of Labor’s
Office of Inspector General (DOL-OIG) for the purposes of both audits and fraud
investigations. The collaboration between the Department, states, and the DOL-OIG has
led to successful collaboration with law enforcement (including the National
Unemployment Insurance Fraud Task Force within the U.S. Department of Justice)3 and
the prosecution of criminals who perpetrated fraud against pandemic UI programs.
b. Background – On March 11, 2021, the President signed ARPA into law (Public Law
(Pub. L.) 117-2). Section 9032, ARPA, created a new Section 2118 of the CARES Act
and provided for a $2,000,000,000 appropriation to the Secretary of Labor (Secretary) to:
(1) detect and prevent fraud, (2) to promote equitable access, and (3) to ensure timely
payment of benefits to eligible workers with respect to UC programs. ARPA describes
allowable uses of these funds, including awarding grants for such purposes to states and
territories administering UC programs and for systemwide infrastructure investment and
development.
On June 3, 2023, the President signed the FRA into law (Pub. L. 118-5). Section 24 of
Title I of division B of FRA permanently rescinds $1,000,000,000 of the unobligated
balances of amounts made available by section 2118(a) of Title II of Division A of the
CARES Act, as added by Section 9032 of ARPA. UIPL No. 10-23 was published on
U.S. Department of Justice, “National Unemployment Insurance Fraud Task Force,”
https://www.justice.gov/coronavirus/national-unemployment-insurance-fraud-task-force.
July 13, 2023, and rescinded previous funding opportunity announcements which were
impacted by the statutory funding rescission.4
The DOL-OIG issued two alert memorandums,5 identifying potentially fraudulent UI
benefits paid in four specific high-risk areas, which included individuals with Social
Security Numbers (SSNs): (1) filed in multiple states, (2) of deceased persons, (3) used to
file UI claims with suspicious email accounts, and (4) of federal prisoners. The
Department has taken action to support states in actively and aggressively addressing UI
fraud and reducing improper payments and many actions have targeted the specific types
of fraud identified by the DOL-OIG. In addition to adding the UI program to its High
Risk list in June 2022, GAO issued two reports6 recommending the Department assess
fraud risks to the UI program in alignment with GAO’s Fraud Risk Framework.7 The
Department is actively working to enhance its existing UI fraud risk management
processes, to align with leading practices as provided in the GAO’s Fraud Risk
Framework, and will continue to identify, evaluate, and address UI fraud risks.
Fraud prevention cannot be accomplished through any single strategy, but rather requires
a combination of immediate, intermediate, and long-term changes in systems and
processes. ETA’s efforts to address fraud risks and improve integrity in the UC programs
includes providing guidance, technical assistance, and funding to states to combat fraud
and reduce improper payments and requiring states to submit an Integrity Action Plan
(IAP) as part of its State Quality Service Plan (SQSP). ETA is also investing in
developing new and enhancing existing tools, datasets, and resources and making them
available to aid states in more quickly identifying potential improper payments and fraud.
The UC program is a vital safety net for unemployed workers and an economic stabilizer
for communities impacted by unemployment events. At the most fundamental level,
equity within the UC program means the provision of UC payments to eligible workers,
regardless of one’s background, in a timely and fair manner, with an application process
that is readily accessible to all workers. Specifically, equity within the UC program
UIPL No. 10-23 cancels UIPL No. 22-21, Change 2; UIPL No. 23-21, Change 5; UIPL No. 02-22, Change 3; and
UIPL No. 07-23. Additionally, it announces that any further pending applications under UIPL No. 23-21 will not be
processed.
Report No. 19-21-002-03-315, 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, published February 22, 2021, https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-
315.pdf and Report No. 19-22-005-03-315, Alert Memorandum: Potentially Fraudulent Unemployment Insurance
Payments in High-Risk Areas Increased to $45.6 Billion, published September 21, 2022,
https://www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-315.pdf.
GAO-22-105051, Additional Actions Needed to Improve Accountability and Program Effectiveness of Federal
Response, published October 2021, https://www.gao.gov/assets/gao-22-105051.pdf and GAO-23-105523,
Unemployment Insurance: Data Indicate Substantial Levels of Fraud during the Pandemic; DOL Should Implement
an Antifraud Strategy, published December 2022, https://www.gao.gov/assets/gao-23-105523.pdf.
GAO-15-593SP, A Framework for Managing Fraud Risks in Federal Programs, published July 2015,
https://www.gao.gov/assets/gao-15-593sp.pdf.
includes a wide variety of factors such as eliminating administrative barriers to benefit
receipt for eligible individuals, reducing workload backlogs, improving the timeliness
and accuracy of UC payments, and ensuring equity in fraud prevention, detection, and
recovery activities.
On January 20, 2021, the President issued Executive Order (EO) 13985 concerning
advancing racial equity and support for underserved communities. This EO articulates
the importance of advancing equity for all, including people of color and others who have
been historically underserved, marginalized, and adversely affected by persistent poverty
and inequality. This includes addressing disparities in accessing government programs
facing individuals and communities including, but not limited to, low-wage workers,
Black and Hispanic/Latinx workers, individuals with disabilities, individuals with limited
English proficiency, women, and individuals living in rural areas. Advancing equity
requires a systematic approach to embedding fairness in decision making processes and
eliminating barriers to access. Public programs must be designed to serve all individuals.
For this reason, the Federal Government should, consistent with applicable law, allocate
resources to address the historic failure to ensure equitable access to individuals in
underserved communities along with the individuals from those communities. Ensuring
access to UC is a longstanding priority of the Department. On October 1, 2015, UIPL
No. 02-16 was issued, which articulates the applicable access requirements under federal
law and provides states guidance to assist with their compliance with these requirements.
Change 1 to UIPL No. 02-16, which was issued on May 11, 2020, highlights additional
state responsibilities regarding access to UC.
4. Guidance.
a. Relationship Between Grants. With previous funding opportunities and other
assistance under ARPA, the Department has provided states with multiple resources to
protect the system from fraud while preserving equitable access to benefits. The
additional funding opportunities described in this UIPL are designed to complement these
efforts, either by funding new activities or by expanding on, accelerating, or enhancing
existing efforts. As each state considers where to focus their immediate attention across
these funding opportunities, it should consider the purpose of the grants, the periods of
performance, and the capacity and priority of state operations. It is the collective
responsibility of the Department and states to use these investments strategically and to
demonstrate meaningful improvements that drive longer-term investment and more
sustained results.
As noted throughout this UIPL, the Department is deploying a two-step application
process. At the time of preparing a Full Project Plan (as described in more detail below),
the state will have the opportunity to propose an amended period of performance to
account for the time needed to appropriately execute the full scope of these grant
projects.
If the sum of all complete and responsive applications submitted under a specific funding
opportunity under Sections 4.b., 4.d., and 4.e. of this UIPL is less than the available funds
available under that funding opportunity, the Department may use the remaining
unobligated balance to increase the funding for awards under one or more of the other
funding opportunities contained in this UIPL. Final award amounts will be determined
subject to the availability of funds.
b. Strengthening Integrity in the UI System. This section of the UIPL provides states
with information on both required and strongly recommended strategies, tools, and
services for UI fraud risk mitigation, improper payment reduction, and overpayment
recovery; and announces the availability of up to $100 million to strengthen UI program
integrity, including ID verification, fraud prevention and detection, and overpayment
recovery efforts in all UC programs.
UI program integrity includes ID verification, fraud prevention and detection, improper
payment reduction, fraud risk mitigation, the recovery of overpayments, the prevention of
underpayments, the timely and accurate payment of benefits, and ensuring equitable
access in all UC programs. ETA continuously develops and oversees implementation of
integrity strategies that target the root causes of improper payments. The Department
regularly evaluates and updates its antifraud strategies and is committed to ensuring its
UI fraud risk management activities are conducted in alignment with GAO’s Fraud Risk
Framework. GAO’s Fraud Risk Framework calls for a strategic approach for assessing
and managing fraud risks. Since the UI program is a federal-state partnership, which
means both the Department and state UI agencies are responsible for ensuring UI
program integrity, states must also evaluate UI fraud risks and implement and maintain
sufficient controls to effectively prevent fraud and reduce improper payments.
i. ID Verification in UC programs. Section 1137(a)(1), of the Social Security Act
(SSA), provides for states to require that individuals furnish their SSN as a condition
of eligibility for benefits. As noted in Section 3.A.(1) of UIPL No. 35-95, any system
planned or implemented to provide ease and convenience for filing claims must
provide safeguards, including a way to ensure that the name and SSN used to
establish eligibility for UC belongs to the individual filing the claim. Therefore, this
provision of the SSA requires that states verify an individual’s identity to ensure that
the individual filing the claim is the owner of the name and SSN used when
establishing eligibility. The strongest method by which states can ensure the name
and SSN belong to the individual applying for UC is by conducting evidence-based
ID verification. Evidence-based ID verification includes activities such as an
individual presenting ID documents (i.e., official government-issued documentation,
control over a device, account or address known to be associated with an identity, or
biometric information) at a physical location, through a virtual platform, or through
other state-developed processes or procedures that validate or verify an individual’s
identity.
Evidence-based ID verification is most effective at preventing ID fraud:
• During the UC application process,
• Immediately following the completion of an initial claim,
• During any break in the claim series (e.g., additional and reopened claims), or
• When a claim is prioritized for investigation based on results of cross-
matching or data analytics and evidence-based ID verification has not already
been completed.
The Department encourages states to employ different fraud prevention and ID
verification strategies at different points throughout the life of the claim. At a
minimum, states must use a risk-based approach to determine which claims should be
subject to evidence-based ID verification. A risk-based approach involves states
using cross-matches and data analytics to identify suspicious activity that may be
indicative of fraud. States must prioritize the investigation of claims having the
greatest risks, and where appropriate, require the completion of evidence-based ID
verification.
Cross-matching and data analytics are most effective when conducted in real-time
during the UC application and/or initial claims process. Cross-matching and data
analytics should also be conducted when a state identifies a change to key user data
(e.g., bank account or mailing address information) on an existing claim, which may
raise suspicion of “claim hijacking” or “claim or account takeover”. The state should
immediately take action by flagging the claim for investigation and conducting
account verification services (AVS)/bank account verification (BAV) and/or other
data analysis to ensure the change was made by the legitimate owner of the claim.
As workloads fluctuate and fraud schemes evolve, the Department expects states to
continuously monitor their fraud management operations and collective ID
verification efforts for effectiveness and adaptation.
A Note on ID Proofing. As defined by the National Institute of Standards and
Technology (NIST),8 ID proofing is the process by which a credentialed service
provider (CSP)9 collects, validates, and verifies information about a person to
establish that an individual is who they claim to be. ID proofing is one of many
options states may use to conduct evidence-based ID verification.
States implementing ID proofing in their UC programs must implement
solutions/services that balance equitable access with alignment to NIST digital
identity guidelines. For example, states that utilize ID proofing are required to
provide a non-digital alternative ID verification option(s) such as in-person ID
verification at locations like participating USPS retail locations or American Job
Centers. States are encouraged to continue to refine and expand non-digital ID
verification option(s) with funds from this opportunity, leveraging resources in their
states where individuals can go or have gone to have their identity proofed.
NIST Special Publication (SP) 800-63 provides technical requirements for implementing digital identity services.
The publication includes: an overview of identity frameworks; using authenticators, credentials, and assertions in a
digital system; and a risk-based process to select assurance levels at https://pages.nist.gov/800-63-3/sp800-63-
3.html.
NIST SP 800-63 defines a CSP, as a trusted entity that issues or registers subscriber authenticators and issues
electronic credentials to subscribers. A CSP may be an independent third-party or issue credentials for its own use.
ii. Fraud Prevention and Detection Activities. An antifraud strategy describes existing
fraud control activities as well as any new control activities a program may adopt to
address residual fraud risks. ETA issued UIPL No. 23-20, on May 11, 2020,
reminding states of required and recommended program integrity functions for the
UC programs. In this subsection, ETA is consolidating and clarifying these activities
and expanding the recommended program integrity functions as outlined below. ETA
reiterates the importance of conducting the required program integrity functions and
encourages states to incorporate all recommended functions into a state’s fraud
management operations. States must continue to use, operate, and maintain the
required integrity controls and the required overpayment recovery activities discussed
below at all times, including during times of mass unemployment events, absent
specific statutory authorization allowing suspension of such controls or activities.
ETA also strongly encourages states to use, operate, and maintain the recommended
integrity controls and recommended overpayment recovery activities discussed below
during such periods.
In accordance with UIPL Nos. 02-16 and 02-16, Change 1, states must ensure that the
fraud prevention and detection technologies/strategies they use do not create barriers
that prevent or limit access for some individuals in violation of applicable federal
equal opportunity or nondiscrimination laws. This may include identifying potential
barriers that may impact historically underserved and marginalized populations when
making design decisions and training team members on equity-related issues and
processes.
States should continuously evaluate their fraud prevention and detection activities
from the perspective of equitable access (see Section 4.b.iv. for more information on
evaluating data to ensure effectiveness and equity in ID verification and fraud
prevention and detection).
A. 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 cross-match (UIPL Nos. 13-19 and 19-
11, Training and Employment Notice (TEN) No. 05-20);
• Quarterly Wage Records cross-match (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).
B. Recommended Fraud Prevention and Detection Activities. ETA strongly
recommends states implement, use, operate, and maintain the following
integrity controls.
• UI Integrity Center’s Integrity Data Hub (IDH) (see Attachment XIV of
this UIPL for details on IDH functionalities/resources);
• Digital Authentication, such as Multifactor Authentication (MFA);
• Device Fingerprint/Reputation Management, which establishes a
combination of inputs (i.e., digital identity) to assist in the authentication
of a user’s identity during ongoing use of online state UI systems;
• Fraud Risk Scoring (i.e., Case Management Prioritization), which includes
using sophisticated risk analytics to assign a risk-based score to claims to
detect suspicious activity early in the claims process, as well as minimize
the number of false positives to protect legitimate individuals from being
flagged for suspected fraud and avoid disproportionately assigning high
risk scores to particular groups of individuals;
• Comparisons and cross-matches that detect shared characteristics (e.g.,
phone numbers, mailing addresses, email addresses, and banking
information) on multiple claims;
• Social Security Administration cross-matches (i.e., Unemployment
Insurance Query (UIQ), Prisoner Update Processing System (PUPS),
Death Master File) (see Attachment XIV of this UIPL for details regarding
PUPS);
• Federal, state, and local incarceration cross-matches;10
• Deceased Records cross-matches;
• Vital Statistics cross-matches;
• State Directory of New Hires cross-match;
• Department of Motor Vehicle cross-match;
• Interstate Benefits (IB) cross-match;
• State Identification Inquiry (SID) and IB8606 enhancements made to the
Interstate Connection (ICON) network cross-match to prevent concurrent
claim filing in multiple states;
• State Information Data Exchange System (SIDES) (TEN No. 12-16) (see
Attachment XIV of this UIPL for details regarding SIDES);
• Use of a unique identifier to identify individuals instead of using the full
SSN;
• Fictitious employer cross-matches;
• Periodic IT security assessments and audits consistent with NIST-
compliant IT security guidelines (UIPL No. 04-21);
Data sets from jails and prisons may not be updated in real time and therefore may lag in the reported
incarceration entrance and/or release dates. Additionally, data sets may contain unreliable identity information.
ETA reminds states to factor these things in when reviewing incarceration data cross-match results. After receiving
incarceration cross-match information, states must conduct appropriate investigations to determine eligibility. See
UIPL No. 01-22.
• Adequate internal controls to protect the integrity and security of state
assets (UIPL No. 14-17); and
• Implement a cross-functional integrity task force to develop and
implement state-specific action plans to reduce UI improper payments
(UIPL No. 19-11).
C. Effectively Conducting Fraud Prevention and Detection Activities. Simply
deploying a fraud prevention and detection tool, implementing an ID
verification/proofing solution, or adding a new cross-match is not the most
effective strategy for fraud prevention and ID verification. To effectively
prevent and detect fraud, states should consider where in the UI process every
tool, solution, and resource is best used and how investigations are prioritized
to prevent fraud and reduce improper payments.
States should think strategically about how cross-match results are triaged and
prioritize claims for investigation that have a higher probability of fraud or the
potential to result in large improper payments. States should be judicious in
deciding which cross-matches trigger an immediate hold on benefits, and
which require further investigation before a payment series is stopped. ID
verification investigations are time sensitive, especially in situations where
payment has already been made on a claim and the individual fails to respond
by the deadline. After the response deadline passes and no response is
received, states should act quickly to stop future payments from occurring by
issuing an immediate failure to respond denial (see Section 4 of UIPL No. 16-
21).
Further, states should consider the frequency of cross-matches within the life
of the claim – some are more effective when run often and continuously
throughout the claim lifecycle. For example, a multi-state cross-match may
be most effective if conducted during the initial claim application or
immediately following the initial claim and prior to issuing payment. Vital
statistics, deceased records, and incarceration cross-matches are critical
activities that are effective if conducted during the initial claim process, and
prior to issuing first payment, and may also be highly effective at continuing
to confirm UI eligibility throughout the life of the claim. Other activities,
such as a suspicious email domain cross-match or AVS/BAV may be
appropriate to run once or on an ad hoc basis when an email address or bank
account is suspect, updated, or changed on a claim.
States should take the following three actions to strengthen fraud prevention
and detection using the IDH:
1. Take advantage of, and use, all IDH functionality;
2. Implement IDH web service/real-time connectivity, if possible; and
3. Submit all UC initial and continued claims to the IDH in real-time, or
daily, at minimum.
iii. Overpayment Recovery Activities. UIPL No. 23-20 also reminded states of required
and recommended overpayment recovery activities.11 Overpayment recovery is
critical to protect both state UI trust funds and federal funds and must be given the
same priority as fraud prevention and detection activities.
A. 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);12
• Cross Program Offset Recovery Agreement (CPORA) (UIPL No. 05-13);
and
• Interstate Reciprocal Offset Recovery Arrangement (IRORA) (UIPL No.
05-13).
B. Recommended Overpayment Recovery Activities. ETA strongly recommends
that states implement, use, and maintain the following activities to recover
overpayments.
• Negotiating repayment plans;
• Accepting repayments through various methods (e.g., online, via
debit/credit card);
• State Income Tax Offset Program;
• Wage garnishments;
• Property liens and assessments;
• Offsets of lottery winnings, homestead exemptions, and other benefits;
• Active participation in probate and/or bankruptcy proceedings regarding
an individual with an outstanding overpayment;
• Skip tracing;
• Work proactively and collaboratively with banks and financial institutions
to detect suspicious activity, ensure that accounts are not unduly
suspended, and recover overpayments (UIPL No. 19-21);
• Civil actions;
• Credit bureau referrals;
• State/federal prosecution;
States may, under limited circumstances, elect to waive recovery of certain established non-fraud overpayments.
For overpayments in the regular UI program, these circumstances are defined in state law. For overpayments under
the temporary pandemic-related UC programs, refer to UIPL Nos. 20-21 and 20-21, Change 1.
Covered debt includes past-due debts that are the result of claimant fraud or unreported earnings, uncollected
employer contributions, and any penalties and interest assessed on such debt (26 U.S.C. § 6402(f)(4)).
• Penalties and interest on overpayments in compliance with state and
federal law;
• Collection agency referrals when state staff is limited, or debt is
uncollectable by other means;13
• Implementing a voluntary fraud self-disclosure program (see Section
4.b.iii.C. of this UIPL for more details); and
• Other recovery methods as determined by state law or policy.
C. Effectively Conducting Overpayment Recovery Activities. States may
consider implementing a voluntary fraud self-disclosure program, which may
help increase the recovery of UI fraud overpayments. Voluntary fraud self-
disclosure programs may provide benefits to states such as revealing
previously unknown fraud, waste, and abuse; reducing a state’s time and
resources spent on data analytics and investigations; and enabling a state to
identity, establish, and collect overpaid benefits.
In establishing a voluntary fraud self-disclosure program, states may consider
such actions as reducing overpayment penalties (monetary14 or penalty weeks)
and/or forgoing or reducing civil/criminal actions for individuals who
voluntarily self-report their fraudulent activity involving the UI program.
While state law will ultimately control what, if anything, a state can modify
with respect to these activities, ETA encourages states to work with
stakeholders to determine if a voluntary fraud self-disclosure program could
be a beneficial added component to the state’s UI overpayment recovery
efforts.
ETA also suggests that states consider an escalated approach to claimant
communications for overpayment recovery activities. For example, an
individual with a non-fraud overpayment may successfully resolve their
overpayment after receiving clear communication with instructions on how to
establish a repayment plan and a clear explanation regarding any overpayment
waiver processes. Only if the non-fraud overpayment is not waived and an
individual fails to establish or comply with a repayment plan after a period of
time that the state deems appropriate, should the state send an escalating
notice for further recovery activities. See the UI Modernization website
located at https://www.dol.gov/agencies/eta/ui-modernization, specifically
information provided at https://www.dol.gov/agencies/eta/ui-
modernization/language-portfolio for support with plain language conversions
to simplify terminology complexity when communicating with claimants.
The immediate deposit and withdrawal standards prohibit states from paying third-party collection agencies out of
a recovered overpayment. See 3304(a)(3), FUTA; 303(a)(4), SSA; 3304(a)(4), FUTA, 303(a)(5), SSA.
The Trade Adjustment Assistance Extension Act of 2011 (TAAEA) amended sections 303 and 453A of the SSA
and Sections 3303, 3304, and 3309 of FUTA to require states to impose a monetary penalty (an amount not less than
15 percent of the erroneous payment) on claimants whose fraudulent acts resulted in overpayments (see UIPL No.
02-12). States may not waive or reduce this penalty assessed on fraud overpayments below the mandatory 15
percent.
Attachment IV to this UIPL provides considerations for states in providing
individual notifications and processing refunds under the CARES Act UC
programs that states are encouraged to consider expanding to the regular UI
program as well. As provided in UIPL No. 20-21, Change 1, the Department
strongly encourages states to waive the recovery of overpaid benefits in
qualifying cases under the CARES Act UC programs. Given the scale of the
challenge of implementing state UI and CARES Act UC programs accurately,
many individuals received an overpayment of benefits due to no fault of their
own. The CARES Act, as amended, provides that states may waive recovery
for overpayments under the CARES Act UC programs when two conditions
are met: (1) when the claimant was without fault in creation of the
overpayment and (2) recovery of overpayment would be against equity and
good conscience. Under no circumstances may a state waive recovery of an
overpayment that is fraudulent.
iv. Evaluating Data to Ensure Effectiveness and Equity. A critical part of fraud risk
management includes evaluating outcomes using a risk-based approach and adapting
activities to improve fraud risk management. States should monitor and evaluate the
effectiveness of fraud prevention and improper payment reduction activities, to adapt
to changing risks and continuously improve the effectiveness of their fraud
management operations. This includes collecting and analyzing data for fraud trends
and identifying potential control deficiencies. Effective monitoring and evaluation
focuses on measuring outcomes and progress toward the achievement of objectives,
rather than simply reviewing outputs and progress in implementing control activities.
Results of the monitoring and evaluations should be used to improve the design and
implementation of fraud risk management activities.
As states are implementing and refining processes for digital authentication, ID
verification, cross-matching, data analytics, and other fraud prevention and detection
activities, states must consider and address any equitable access impacts. One of the
most common barriers to equitable access is an ID verification process that is difficult
to complete. Examples of difficulty in completing ID verification processes may
involve individuals with limited English proficiency; individuals with limited access
to, or understanding of, technology; or instructions that are unclear or cumbersome.
Another common barrier is states erroneously flagging legitimate claim activity as
suspicious. This can result in delays for eligible individuals to receive UI benefits – a
matter which is further exacerbated when states are experiencing high workload
volumes, making it difficult for individuals to contact the state unemployment
agency. States must ensure there is at least one timely, effective, and accessible non-
digital alternative to online ID verification. This non-digital option should not be
overly burdensome on applicants, limit access to public benefits programs or the
timely receipt of benefits, or stigmatize members of the public in any way.
ETA strongly recommends that states implement data collection and analysis to
review their fraud prevention and detection activities – monitoring for barriers to
equitable access and taking swift action to mitigate such barriers.15 The data for this
analysis may come from system datapoints, customer surveys, periodic user
interviews, and case samples. States should work with their service providers or with
their in-house fraud management operations to identify and resolve any barriers or
equitable access impacts resulting from ID verification practices and data analytics
and cross-matching services.
When using a CSP for ID proofing or a third-party ID verification solution, ETA
recommends that states establish, within their contracts, a process to receive
Personally Identifiable Information (PII) and data on an individual’s ID verification
status (i.e., verified, not verified, pending, inconclusive) within a service provider’s
system or solution. To be able to properly respond to customer inquiries, states
should have access to such information in real-time (if possible), but no later than 24
hours after an individual started the ID verification process and whenever there is a
change in the ID verification status. By knowing the individual’s ID verification
status, the state can also ensure that appropriate instructions and next steps are
provided to the individual. The Department outlined stringent technical, service
level, business performance, and equity requirements in its solicitation for ID
verification/proofing services described in TEN No. 06-21. ETA recommends that
states incorporate similar provisions in their ID verification solicitations and contracts
with service providers. Attachment III to this UIPL describes recommended contract
provisions for ID verification/proofing services and solutions.
DOL-OIG recently issued an Alert Memorandum16 highlighting concerns about
states’ use of ID verification service providers, specifically those employing the use
of facial recognition technology, and the impact these ID verification/proofing
services may have on equitable and secure access to UI benefits. ETA strongly
encourages states to carefully review ID verification/proofing solutions that use
biometrics such as facial recognition. While these solutions may help to reduce ID
fraud, they may have negative implications for or lead to violations of states’
nondiscrimination obligations under Section 188 of Workforce Innovation and
Opportunity Act (WIOA). States are reminded that a non-digital alternative option
for ID verification must be available and not require substantially more time,
hardship, or delay to complete. Furthermore, states using ID verification/proofing
solutions that employ the use of facial recognition technology, must test the system
for biases and work with the service provider to identify and resolve any biases or
barriers to equitable access resulting from the ID verification process.
As described in UIPL No. 11-14, the Department’s regulations also require state compliance with the U.S. Office
of Management and Budget (OMB) guidelines on the collection of data based on race or ethnicity. See 29 CFR §
38.41(d). States must provide information about the reasons for a data request, and the ways in which the data may
be used before asking about a claimant’s race/ethnicity, sex, age, or disability status.
Report No. 19-23-005-03-315, Alert Memorandum: ETA and States Need to Ensure the Use of Identity
Verification Service Contractors Results in Equitable Access to UI Benefits and Secure Biometric Data, published
March 31, 2023, https://www.oig.dol.gov/public/reports/oa/2023/19-23-005-03-315.pdf.
Below are a few examples of data points and information that can be used to conduct
meaningful analysis, monitor equity outcomes, and make necessary changes to ensure
equitable access.
• PII and data on an individual’s ID verification status (i.e., verified, not
verified, pending, inconclusive) within a service provider’s system or
solution to identify any disparate results amongst demographic groups or
specific friction points within the ID verification process, such as:
o Data from individuals who successfully verify through alternative
method(s) after failing initial screenings, including appeals data;
o Number of ID verification attempts each user is making;
o Time spent in the system at each identification step;
o Wait time for customer service requests related to ID verification;
o Location, device type, and connection type;
o The strength of the identification match; and
o System, monitoring, and incident reports.
• How many individuals used a non-digital option to verify their ID
including:
o what caused them to be unable to access the technology (if
applicable);
o what caused them to be denied by the technology (if applicable);
and
o which alternative access option was used.
• Which claims were flagged as suspicious and warranting further
investigation, including:
o the length of time to resolve these investigations; and
o the outcome of these investigations, such as whether they resulted
in a fraudulent overpayment, non-fraudulent overpayment,
suspected/confirmed ID fraud, claim abandoned during the ID
verification process, or a non-issue (i.e., “false positive”), by
demographic group.
Additionally, ETA strongly recommends conducting root cause analysis to identify
the source of specific instances where legitimate individuals have been adversely
affected by UI program integrity measures (i.e., fraud risk scoring, fraud prevention
and detection activities, ID verification/proofing systems or solutions). State root
cause analysis should seek to identify issues that may exist at larger scale and may
merit more systemic modifications to the state’s overall fraud risk mitigation and
improper payment reductions strategies, including ID verification and fraud
prevention and detection activities.
v. Protecting Victims of UI ID Fraud. States must provide individuals who suspect
that they are victims of UI ID fraud with options to report such activity and, once
fraud has been confirmed, states must take actions to protect the UI ID fraud victim.
To meet these requirements, ETA strongly recommends that states provide a
reporting mechanism for UI ID fraud on their websites, communicate status updates
for such investigations, and take action to protect the victim when the state
determines that UI ID fraud has occurred.
A. Providing a reporting mechanism for UI ID fraud on state websites. As
described in Section 5 of UIPL No. 16-21, states must provide individuals
who suspect that their ID has been stolen with easily accessible options to
report such theft or fraudulent activity. This may include dedicated phone
options, email addresses, or an online portal by which individuals can notify
the state agency. States may also provide links to resources from other
agencies that specialize in protecting consumers and their PII, such as the
Federal Trade Commission’s Consumer website at
https://www.identitytheft.gov/#/.
In December 2022, the Department published updated website content on the
UI ID fraud reporting website at www.dol.gov/fraud. ETA issued TEN No.
14-22, strongly encouraging states to align their website content and
communications for individuals who experience UI ID fraud with the new
content, resources, and reporting requirements outlined at www.dol.gov/fraud.
B. Communicating status updates. ETA strongly recommends that states clearly
communicate their UI fraud reporting requirements on their state website(s)
and have in place established processes and procedures for assisting
individuals who have experienced UI ID fraud. To reduce confusion and
anxiety for a victim of UI ID fraud, states should provide updates throughout
the process once a report of UI ID fraud has been received. This may include,
but is not limited to:
• Providing confirmation to the submitter that the fraud report was received;
• Clearly defining expectations and outlining next steps;
• Providing ongoing updates to the submitter and/or SSN owner (if known)
throughout the investigation; and
• Notifying the submitter and/or SSN owner (if known) once the
investigation is complete.
C. Protecting victims. When a state determines that UI ID fraud has occurred the
state must take actions to protect the rights of the UI ID fraud victim. As
discussed in UIPL No. 20-21, Change 1, once the state issues a fraud
determination, one option states can use to mitigate negative impacts on the
UI ID fraud victim is to establish a pseudo claim record and transfer all claim
information regarding the fraudulent activity to the pseudo claim. This
removes the fraudulent activity from the victim's SSN and/or UI account,
which should remove barriers the victim may encounter if they need to file for
UI in the future. This solution also applies to “claim hijacking” (also known
as “claim or account takeover”). On hijacked claims, any weeks that were
fraudulently redirected must be removed from the legitimate UI claim and the
weeks must be immediately repaid to the rightful owner of the claim if
eligibility for those weeks is determined. In the case of hijacked claims, the
state should employ ID verification as part of its investigation to verify the
legitimate individual’s identity prior to repaying the weeks.
States are also strongly encouraged to use the UI Integrity Center’s IDH BAV
service to authenticate new bank account information provided on all claims
prior to issuing payments, including verifying bank account information on
claims that have been determined to be hijacked, prior to reissuing any
payments. The IDH’s BAV service validates the status of the bank account
(e.g., account is open or closed) and provides a level of assurance that the
individual identified as the UI claimant is the bank account owner and/or
authorized user.
States that may not have the current administrative capability to move such
activity to a pseudo claim may choose to temporarily mark the overpayment
as “uncollectible.” This ensures that UI ID fraud victims are not negatively
impacted while the state develops a process to disassociate the fraudulent
activity from the victim’s SSN. Below are other actions the state may take to
mitigate the negative consequences for the UI ID fraud victim:
• Ensure that if a future claim is filed under the victim’s SSN, the claimant
undergoes a secondary ID verification process (e.g., include an in-person
reporting requirement or other expanded ID verification alternatives).
However, states should try to minimize the burden on the victim as much
as possible when verifying identity.
• Ensure that the owner of the SSN is not held responsible for any
overpayment and, whenever possible, is not issued a Form 1099G at the
end of the year.
• Exclude the overpayment from TOP and suspend any overpayment
collection activity for the actual owner of the SSN.
• Do not initiate any legal actions against the actual owner of the SSN.
vi. Integrity Grant to States. The Department is providing up to $100 million in
additional funding to states to strengthen UI program integrity, including ID
verification, fraud prevention and detection, and overpayment recovery efforts in all
UC programs.
A. Amount per State.17 The methodology for state funding levels is based on size
of UI covered employment in the state. For purposes of this methodology,
states are assigned to four groups (Small, Medium, Large, and Extra-Large)
Since Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, the Federated States of
Micronesia, the Republic of the Marshall Islands, and the Republic of Palau do not operate regular UC programs,
this grant opportunity is not being made available to these jurisdictions.
based on the 12-month average of UI covered employment for the four
quarters in calendar year 2022 reported on the ES 202 (Employment, Wages
and Contributions) report. States are assigned to the size groups as follows:
• Small: covered employment under 1 million employees
• Medium: covered employment between 1 million and 2 million employees
• Large: covered employment between 2 million and 7 million employees
• Extra Large: covered employment greater than 7 million employees
Attachment I to this UIPL provides the funding available for each state.
B. Allowable Uses. States must use the funds made available under this UIPL to
strengthen ID verification and other fraud prevention and detection and
overpayment recovery efforts in all UC programs. Types of costs may include
any costs associated with the procurement and/or implementation of ID
verification, fraud prevention, and overpayment recovery tools, solutions, and
services, which includes any costs related to the state’s integration with the
Department’s National ID Verification Offering (see Section 4.c. of this
UIPL); payment of subscription costs to operate new and/or maintain existing
services/solutions; and hiring of staff18 to conduct data analysis,
investigations, collections, recovery, or other integrity-related duties.
Examples of permissible uses of these funds include, but are not limited to,
the activities listed below. The term “effectiveness” refers to a state’s ability
to properly detect suspicious activity, investigate in a timely manner, and
mitigate barriers to equitable access.
• Establishing and refining the state’s risk-based approach to determine
which claims are subject to evidence-based ID verification as described in
Section 4.b.i. of this UIPL;
• Covering costs of integrating state operations with the Department-funded
National ID Verification Offering as described in Section 4.c. of this
UIPL, as well as any costs associated with participation in the voluntary
enhanced data analysis described in Section 4.c.iii.C. of this UIPL;
• Implementing new and/or maintaining/enhancing existing ID verification
solutions and/or procedures to verify the identity of individuals filing for
UC;
• Strengthening the effectiveness of how the state uses required fraud
prevention and detection activities and required overpayment recovery
activities as described in Sections 4.b.ii. and 4.b.iii. of this UIPL;
• Implementing new and/or strengthening the effectiveness of how states
use recommended fraud prevention and detection activities and
States are reminded of the ability to exercise flexibility in staffing models for the performance of certain UC
administrative activities, as described in UIPL No. 12-01, Change 2.
recommended overpayment recovery activities, as described in Sections
4.b.ii. and 4.b.iii. of this UIPL;
• Establishing and refining the state’s use of data, including through the use
of activities such as filing metrics and customer surveys, to monitor and
adapt the effectiveness of tools used to combat UI ID fraud and other
improper payments as described in Section 4.b.iv. of this UIPL;
• Establishing and refining external communication protocols when states
receive reports of UI ID fraud as described in Section 4.b.v. of this UIPL;
• Establishing and refining protections for victims of UI ID fraud as
described in Section 4.b.v. of this UIPL; and
• States may also use the funds made available under Section 4.b.vi. of this
UIPL for the same activities described in Section 5.b. of UIPL No. 22-21.
C. Application Instructions. The grant application and award process for funding
under this subsection will be completed in two stages. To receive funding, the
state must agree to the conditions described in Section 4.b.vi.C.1. of this UIPL
and complete an Initial Application as described in Section 4.b.vi.C.2. of this
UIPL. Upon receipt and processing of an approvable Initial Application, a
NOA will be sent to the state. To drawdown funds from this NOA, the state
must submit a Full Project Plan, as described in Section 4.b.vi.C.3. of this
UIPL.
1. Conditions of receiving grant funding. By submitting an Initial
Application to receive funds under this subsection, the state must agree
to the following conditions.
• Disclosure to DOL-OIG. The state will disclose confidential UC
information to DOL-OIG. As discussed in UIPL No. 04-17,
Change 1, states must refer allegations that they reasonably believe
constitute UC fraud, waste, abuse, mismanagement, or misconduct
to the DOL-OIG. As a condition of receiving a grant under this
subsection, the state agrees to provide all confidential UC
information to DOL-OIG for purposes of investigating fraud and
performing audits through weeks of unemployment ending on or
before the end of the period of performance as described in Section
4.b.vi.D. of this UIPL.
• Submission of a Full Project Plan. The state will submit a Full
Project Plan to the appropriate ETA Regional Office, as described
in Section 4.b.vi.C.3 of this UIPL within 60 calendar days after
receiving the NOA.
2. Initial Application. The Grant Application to receive any new or
additional funds must be submitted electronically via
https://www.grants.gov/, with an electronic copy to the appropriate
ETA Regional Office, as soon as possible and no later than 11:59 pm
Eastern Time on August 18, 2023. The Grant Application package
consists of a completed SF-424 (as described in Attachment XI of this
UIPL) to reflect up to the full amount of the state’s allocation (see
Attachment I to this UIPL).
To demonstrate that the state agrees to comply with the conditions
described in Section 4.b.vi.C.1. of this UIPL, when completing the SF-
424, the state must check the “I AGREE” box under Item 21 and
include the appropriate language in Item 15. States should maintain
any supporting documentation that serves as evidence for meeting the
required conditions.
Upon receipt and processing of the SF-424, the state will receive a
NOA. These grants are subject to the requirements of 2 CFR Parts 200
and 2900, Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards.
3. Full Project Plan. As noted in Section 4.b.vi.C.1. of this UIPL, the
Full Project Plan must be submitted to the appropriate ETA Regional
Office, as soon as possible and by no later than 60 calendar days upon
receipt of the NOA. The Full Project Plan package must include:
• A copy of the completed SF-424 from the Initial Application;
• A completed SF-424A;
• If indirect cost is indicated on the SF-424A, then a Negotiated
Indirect Cost Rate Agreement (NICRA); and
• A completed Full Project Plan Template (as described in
Attachment II to this UIPL).
The submission of the required documents does not constitute
approval by the Department. Upon receipt of the Full Project Plan, the
Department will review and work with the state to approve the
proposal. Once approved by the Grant Officer, the Full Project Plan
will be an official amendment to the initial NOA, and the condition of
the award that previously restricted access to the additional funds will
be resolved.
D. Period of Performance. Funds awarded under this subsection will have a
period of performance which begins April 1, 2023, and ends on December 31,
2025. States must fully obligate all funds one quarter before the period of
performance ends and must liquidate all funds within 90 days thereafter.
Funding for state staff costs may not be obligated for use at a future date and
the obligation may only occur at the time the staff performs services on the
project/activity.
Grant funds may only be used for costs of activities incurred no earlier than
the beginning of the calendar quarter preceding the calendar quarter upon
execution of the award.
E. Reporting Requirements. For the grant awarded under this subsection, states
must provide:
1. ETA 9178-ARPA – a quarterly narrative progress report containing
updates on the implementation and progress of each grant
project/activity. The form ETA 9178-ARPA is provided as
Attachment XIII to this UIPL.
2. ETA 9130 (OMB Control No. 1205-0461 Expiration Date:
01/31/2025) – a quarterly financial report.
c. National ID Verification Offering. The Department is providing government-operated
ID verification systems to states that support online verification services through
partnership with GSA’s Login.gov and in-person verification services through
partnership with USPS. These offerings are being made available by the Department
using ARPA funds to directly cover at least two (2) years of transaction costs19, subject to
the availability of funding and necessary agreements being in place. Available funding
will be dependent on state uptake, usage, and claims volume.
As previously noted, fraud prevention and detection activities are strongest when states
employ a variety of tools, strategies, and resources. States are reminded that they must
ensure there is at least one timely, effective, and accessible non-digital alternative to
online ID verification (see Section 4.b.i. and 4.b.iv. of this UIPL). USPS in-person ID
verification services can be used to satisfy the requirement to provide a non-digital option
for ID verification.
i. GSA’s Login.gov Online and USPS In-person.
A. Login.gov. Operated by GSA, Login.gov is the federal government’s secure
sign-in service used by the public to access participating government
agencies’ web services and conduct ID verification. Participating state UI
agencies will ask the individual applying for and/or receiving UC to create a
Login.gov account to securely access their information on the state’s UI
system. The individual can use the same username and password to access
any state or federal agency that partners with Login.gov. This streamlines the
process and eliminates the need to remember multiple usernames and
passwords.
The Department will cover costs calculated based on volume of ID verification transactions through GSA’s
Login.gov online services and USPS’s in-person services, subject to available funding. States will be responsible
for costs incurred to integrate state operations with these services. Such costs are allowable uses under the Integrity
Grants described in Section 4.b. of this UIPL.
How Does it Work. Participating agencies use Login.gov to help protect their
users (e.g., claimants, applicants, beneficiaries). When an individual signs in
to a participating UI state agency website, they will be prompted to sign in or
create an account with Login.gov, if the individual has not used the service
before.
• Individuals must establish a Login.gov account with an email address,
password, and multi-factor authentication.
• While signed into the Login.gov application, the individual will be
prompted to verify their identity through uploading their government-
issued ID, providing their SSN, and verifying their PII.
o The individual will have to provide a phone number with their
name associated to the phone plan or receive a letter at an
address known to be associated with them. The individual
does not need to be the primary account holder.
• Once the ID verification is complete, the individual must agree to
share information with the Department.
• The individual can seek help from the Login.gov 24/7 Call Center if
they are having issues navigating within the application.
B. USPS. USPS offers in-person ID verification services at participating USPS
retail locations nationwide for government customers. In-person ID
verification allows federal and state agencies to securely verify an individual’s
identity in-person to provide access to services when an identity cannot be
substantiated through a technology-based solution. In-person ID verification
also provides an alternative for individuals who are unable to or prefer not to
be verified through an online solution.
How Does it Work. In-person ID verification can be completed at
participating USPS retail locations when an individual is required to complete
in-person ID verification. In-person ID verification may be necessary in the
event an individual is unable to complete an online ID verification process
(e.g., digital ID verification, technology-based solution) or does not have the
means by which to complete the process (e.g., lack of bandwidth,
technologically challenged, no computer access, disability).
• Individuals receive an enrollment barcode or enrollment code
provided by the service.
• Individuals must present the enrollment barcode or enrollment code
to any participating USPS retail location.
o No appointment time is needed.
o No fee is collected from the individual verifying their identity.
• Individuals must present certain original and non-expired government
identification documents (e.g., state-issued driver’s license or
identification card, passport, etc.).
• Once the verification process is complete, the USPS retail location
will pass the results to the Department.
o The Department will notify the state of the in-person ID
verification results to enable the state to determine next steps.
ii. Roles and Responsibilities for the State and Department. The Department and
participating state(s) will enter into a Data Sharing Agreement (DSA) which will
include provisions necessary to comply with the requirements of 20 C.F.R. Part 603.
Following execution of the DSA, the Department and participating state(s) will enter
into a Partnership Addendum (PA), which will be attached to the DSA and will
memorialize the specific requirements, terms, and obligations of the Department and
participating state(s) for implementation of the National ID Verification Offering, as
well as the obligation to provide certain confidential UC information to the
Department to allow the Department to assess the efficacy and equity of the offerings.
See Attachment V to this UIPL for additional detail. States will not enter into a
relationship with Login.gov or USPS directly.
iii. Collection and Evaluation of Data to Ensure Effectiveness and Equity. For states
participating in this offering, the Department will require states to disclose certain
data to the Department and the Department will store that data for the purpose of
assessing the effectiveness and equity of ID verification at the point of delivery.
Login.gov and USPS do not collect the data required for detailed equity analyses for
its participants; therefore, the Department will require states to provide individual-
level data. Collecting this information will provide the Department with improved
information about the impact of ID verification tools across participating states and
the UI system.
A. Purpose for Collecting Individual-Level Data. The Department will use this
data to assess the number of individuals initiating the ID verification process
through this National ID Verification Offering, the number of individuals
completing ID verification across the Login.gov and USPS services, as well as
the number of individuals that are not verified and referred back to states for
additional follow-up action. The Department will also use this information to
compile equity data with respect to ID verification technologies, including
assessing whether there are different verification success rates through the
offering(s) for different demographic groups (e.g., race, ethnicity, disability,
and age), and whether there are differences in ID verification success rates
among those with different educational levels, and among rural and urban
workers.
B. Required Individual-Level Data for States to Report. States will be required
to submit the following individual-level data elements to the Department on a
quarterly basis for equity analysis, for those individuals who engage with the
ID verification options provided by the Department:
• State-specific unique identifier (e.g., Claim ID number; not SSN);
• Zip code;
• Gender;
• Age;
• Race and Ethnicity;
• Education Level;
• Industry & Occupation;
• Disability (if identified); and
• Language Preference.
C. Option for States to Participate in More In-Depth Analysis. To better
understand success rates for ID verification and the impact on fraud
prevention, equitable access, and timeliness of ID verification efforts, the
Department requests that states, as available, volunteer to participate in a more
in-depth data exchange. When a state agrees to participate in this more in-
depth analysis, the Department will collect additional data elements to carry
out this analysis. The additional individual-level data elements may include
information such as claims disposition and comparative data on UI claims
before and after the implementation of the National ID Verification Offering.
The state may use Integrity Grant funding provided in Section 4.b. of this
UIPL for additional expenses incurred by the state in this additional data
collection. States can express interest in participation through their
appropriate ETA Regional Office.
D. Data Protections. The Department will protect all data in accordance with the
Privacy Act of 1974, Federal regulations at 20 CFR Part 603, and all other
requirements related to confidentiality and disclosure avoidance that will be
described in the DSA’s PA. See Attachment V to this UIPL for Roles and
Responsibilities of the State and Department. Upon receipt, all data acquired
from states will be treated as if it has, at a minimum, protection at the
appropriate risk level in accordance with the NIST Federal Information
Processing Standards (FIPS) 200 and Special Publication 800-60.
iv. State Request for Intent to Participate. States should contact their appropriate ETA
Regional Office to express interest by August 18, 2023. These non-binding
notifications will help inform the Department’s planning for the designation of
resources to support implementation activities. The ETA Regional Office will
facilitate discussion(s) with the state to discuss the Login.gov and USPS offerings to
identify the best fit for the state. Once the state affirmatively decides to participate in
one or both of the government-operated ID verification systems, they will be asked to
sign a DSA and PA with the Department (see Section 4.c.ii. of this UIPL).
d. IT Modernization Grants. The Department is providing approximately $200 million
for individual states to receive up to $11.25 million to invest in IT project(s) that address
at least one of the following categories that support modular and evidence-driven
approaches to modernization that increase the agility and resiliency of UI systems. Each
of these categories are described in more detail in Attachment VI to this UIPL.
Attachment VII to this UIPL describes promising practices and sample projects and
measures of success that align with these categories.
• Cloud migration;
• Modular and Application Programming Interface (API)-driven approaches;
and
• Measurably improving the customer experience (CX).
Funds will be awarded to states that submit complete and responsive Initial Applications
in the order received by the Department, as long as funding remains available.
i. Vision for Creating More Resilient and Responsive IT Systems. An effective
approach to modernization starts with the understanding that technology is always
evolving and that state systems must be responsive to changing needs. It is critical
for all states to develop a system architecture that can scale to meet increases in
demand, which often occur at the same time states need to adapt to new federal
programs and changing fraud threats.
Many states struggle to adapt their systems due in part to how the systems were
designed and the constraints that accompany legacy technology. The resulting
inflexibility and brittleness of these systems means that even relatively “simple”
changes can be prohibitively costly, time-consuming, and risky. Addressing these
challenges will help systems to scale up when unemployment increases, while
mitigating additional exposure to criminal actors, and making it easier for states to
effectively integrate technologies that stop fraudulent claims before they are paid.
Instead of monolithic system architectures, the Department encourages states to
pursue modular and incremental approaches when modernizing their systems. This
approach involves “breaking down” complex monoliths into smaller, more
interchangeable components (i.e., modules) that are easier to change and maintain.
Modular approaches also make it easier for states to integrate new technologies and
may be accomplished using a wide range of tactics, including using standard
interfaces, leveraging APIs, adopting cloud technology, using open-source software,
and adopting user-centric and agile development practices.
ii. Amount per State. Each state,20 regardless of size, that submits a complete and
responsive application may receive up to $11.25 million for these purposes, unless
and until funding for this grant opportunity is fully obligated. Funds will be awarded
to states that submit complete and responsive Initial Applications in the order
received by the Department, as long as funding remains available.
Since Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, the Federated States of
Micronesia, the Republic of the Marshall Islands, and the Republic of Palau do not operate regular UC programs,
this grant opportunity is not being made available to these jurisdictions.
iii. Allowable Uses. States may use the funds awarded under this granted opportunity to
cover costs associated with the activities in the categories listed above and described
in Attachment VI to this UIPL.
iv. Application Instructions. The grant application and award process under this
subsection will be completed in two stages. In the first stage, the state must agree to
the conditions and complete an Initial Application as described below. Upon receipt
and processing of an approvable Initial Application, a NOA will be issued to the state.
in the second stage and prior to any drawdown of funds from this NOA, the state
must submit a Full Project Plan, also described below.
A. Conditions of Receiving Grant Funding. As part of submitting an Initial
Application to receive funds under this subsection, the state must agree to the
following conditions.
1. Disclosure to DOL-OIG. The state will disclose UC information to
DOL-OIG. As discussed in UIPL No. 04-17, Change 1, states must
refer allegations that they reasonably believe constitute UC fraud,
waste, abuse, mismanagement, or misconduct to the DOL-OIG. As a
condition of receiving a grant under this subsection, the state agrees to
provide all confidential UC information to DOL-OIG for purposes of
investigating fraud and performing audits through weeks of
unemployment ending on or before the end of the period of
performance as described in Section 4.d.v. of this UIPL.
2. Submission of a Full Project Plan. The state will submit a Full Project
Plan to the appropriate ETA Regional Office, as described in Section
4.d.iv.C. of this UIPL within 90 calendar days after receiving the
NOA, and acknowledges that no drawdown of funds may occur until
the Full Project Plan has been approved by the Grant Officer.
3. Sharing Regular Report Outcomes. The state agrees to report on one
or more of the desired outcome metrics in Attachment VI to this UIPL
through the form ETA 9178-ARPA process.
4. Making software and related artifacts produced by these grants
available under an open license, where required, or participating in
communities of practice. In addition to the intellectual property rights
requirements for grants and cooperative agreements published at 2
CFR 200.315(d), Department grant regulations at 2 CFR 2900.13
require that intellectual property developed under a discretionary
federal award process must be licensed under an open license, which
allows subsequent users to copy, distribute, transmit, and adapt the
copyrighted work and attribute the work in the manner specified by the
recipient.
This requirement applies to situations where states develop new
intellectual property using grant funds. However, this requirement
does not apply to all potential uses of grant funds, such as hiring staff
to improve customer experiences, and does not require that a state
make existing vendor solutions and intellectual property purchased or
licensed through a discretionary grant available under an open license.
It does apply to situations where states use the funds to develop new
intellectual property that is considered separate from existing vendor
solutions.
In cases where the open-source requirement does not apply, states
must agree to participate in a Department-sponsored community of
practice. These community(ies) will convene participating states at
least once every fiscal year (FY) during the period of performance
beginning in FY 2024. Such community(ies) will share and document
promising practices and examples of impact from states across these
funding areas.
B. Initial Application. To receive consideration the state must submit an Initial
Application (as detailed below) electronically via https://www.grants.gov/,
with an electronic copy to the appropriate ETA Regional Office, as soon as
possible and no later than 11:59 pm Eastern Time on August 18, 2023. Funds
will be awarded in the order that completed Initial Applications are received,
as long as funding remains available.
The Initial Application package consists of a completed SF-424 (as described
in Attachment XI of this UIPL), and a completed Project Abstract (following
the template provided in Attachment VIII to this UIPL). To be considered
responsive and complete, states must submit the project abstract template
committing to UI IT modernization activities that correspond to at least one of
the three categories listed above (and described in Attachment VI to this
UIPL) and complete all required certifications. States are encouraged to
review Attachments VI and VII to this UIPL for more information on these
program areas and examples of eligible projects.
These grants are subject to the requirements of 2 CFR Parts 200 and 2900,
Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards.
C. Full Project Plan. As noted in Section 4.d.iv.A.2. of this UIPL, the Full
Project Plan must be submitted to the appropriate ETA Regional Office, as
soon as possible and by no later than 90 calendar days of receiving the NOA.
The Full Project Plan package must include:
• A copy of the completed SF-424 from the Initial Application;
• A completed SF-424A;
• If indirect cost is indicated on the SF-424A, then a NICRA; and
• A completed Project Plan Template (as described in Attachment
IX to this UIPL).
The submission of the required documents does not constitute approval by the
Department. Upon receipt of the Full Project Plan, the Department will
review and work with the state to approve the proposal. Once approved by
the Grant Officer, the Full Project Plan will be an official amendment to the
initial NOA, and the condition of the award that previously restricted access to
the additional funds will be resolved.
v. Period of Performance. Funds awarded under this subsection will have a five-year
period of performance that begins on the date the award is executed (i.e., the date of
the NOA). States must fully obligate all funds one quarter before the period of
performance ends and must liquidate all funds within 90 days thereafter. Funding for
state staff costs may not be obligated for use at a future date and the obligation may
only occur at the time the staff performs services on the project/activity.
Grant funds may only be used for costs of activities incurred no earlier than the
beginning of the calendar quarter preceding the calendar quarter upon execution of
the award.
vi. Reporting Requirements. For the grant awarded under this subsection, states must
provide:
A. ETA 9178-ARPA – a quarterly narrative progress report containing updates
on the implementation and progress of each grant project/activity. The form
ETA 9178-ARPA is provided as Attachment XIII to this UIPL.
B. ETA 9130 (OMB Control No. 1205-0461 Expiration Date: 01/31/2025) – a
quarterly financial report.
C. A Note on the UI IT Modernization Pre-Implementation Planning Checklist
(OMB Control No. 1205-0527 Expiration Date: 06/30/2023). The
Department published UIPL No. 11-18, Change 1, announcing revisions to
ETA 9177, UI IT Modernization Pre-Implementation Planning Checklist
Report. The information gathered in the ETA 9177 Report must be used by
states to prepare for the implementation of new UI IT systems and to ensure
the availability of mission-critical functions. The ETA 9177 Report is
required when a state is modernizing a major component of a UI IT system or
systems. A major component can be a full benefits or tax system, or it can be
a significant component subset, such as continued claims certification or
adjudication. An ETA 9177 Report submission is not necessary when a state
is merely upgrading subcomponents of a system, such as enhancing the front-
end interface for claims intake. Other instances where a state is not required
to submit an ETA 9177 Report include ongoing maintenance activities:
database upgrade, IT server upgrades, replacing obsolete hardware/software,
etc. When proceeding with approved activities for the State UI IT
Modernization Grants, states should review the ETA 9177 Report and
associated UIPL to determine what, if any, reporting may be required under
ETA 9177.
e. Tiger Team Grants. Following a Tiger Team consultative assessment under UIPL No.
02-22, eligible states (as described below) may receive grant funds to support
implementation of negotiated recommendations to enhance their UC systems and
business processes to address the three goals of ARPA: (1) prevent and detect fraudulent
activity, and to recover funds from fraud; (2) promote equitable access; and (3) ensure
timely payment of benefits and reduce backlogs across all UC programs.
i. Updated Allocations for States. As part of the Department’s deliberative approach in
investing the funds remaining after enactment of the FRA, the Department is making
the following modifications. Attachment X to this UIPL provides the updated
allocation amount by state.
A. States that Have Begun the Tiger Team Consultative Assessment. States that
have begun the consultative assessment21 by June 30, 2023, and received less
than 85 percent of their funding allocation described in Attachment I to UIPL
No. 02-22 may receive up to 85 percent of that original allocation. States that
have already been awarded more than 85 percent of their original allocation
may not apply for additional funds and will not be required to return any
funds.
B. States that Did Not Begin the Tiger Team Consultative Assessment. States
that expressed interest prior to the March 31, 2023 deadline (as announced in
UIPL No. 02-22, Change 2) and did not begin the Tiger Team Consultative
Assessment as of June 30, 2023 are not eligible for implementation grant
funds.
ii. Updated Application Instructions. The grant application and award process for
funding under this subsection will be completed in two stages. To receive funding,
the state must agree to the conditions described in Section 4.e.ii.A. of this UIPL and
complete an Initial Application as described in Section 4.e.ii.B. of this UIPL. Upon
receipt and processing of the Initial Application, a NOA will be sent to the state. To
draw down funds from this NOA, the state must submit a Full Project Plan, as
described in Section 4.e.ii.C. of this UIPL.
This table summarizes the deadline for each group of states and more detail is found
in the sections below.
This includes states that have received their negotiated recommendations, as well as states that have participated
in a kick-off meeting and are in the process of developing their negotiated recommendations with the Department.
Group Deadline for New Grant Deadline for Full Project
Application/Initial Plan
Application
Group 1: States that have Initial Application to request Due within 60 calendar days of
completed the Tiger Team any additional funds due issuance of the NOA
consultative assessment and electronically by 11:59 pm
not yet received all funding Eastern Time on August 18,
provided in Attachment X to 2023.
this UIPL
Group 2: States that have N/A – no further funding N/A
completed the Tiger Team available
consultative assessment and
received all funding provided
in Attachment X to this UIPL
Group 3: States that began the Initial Application due Due within 60 calendar days of
Tiger Team consultative electronically by 11:59 pm the state receiving negotiated
assessment by June 30, 2023 Eastern Time on August 18, recommendations
but have not yet received their 2023.
negotiated recommendations
A. Conditions of Receiving Grant Funding. By submitting an Initial Application
to receive any funds under this subsection, the state must agree to the
following conditions.
1. Disclosure to DOL-OIG. The state will disclose UC information to
DOL-OIG. As discussed in UIPL No. 04-17, Change 1, states must
refer allegations that they reasonably believe constitute UC fraud,
waste, abuse, mismanagement, or misconduct to the DOL-OIG. As a
condition of receiving a grant under this subsection, the state agrees to
provide all confidential UC information to DOL-OIG for purposes of
investigating fraud and performing audits through weeks of
unemployment ending on or before the end of the period of
performance as described in Section 4.e.iv. of this UIPL. Any funds
awarded to states in Group 1 will include an amendment to the award
of any previous funds to incorporate this new condition.
2. Complete the Tiger Team Consultative Process. For states in Group 3,
the state will complete the Tiger Team consultative assessment,
including receipt of the negotiated recommendations.
3. Submission of a Full Project Plan. The state will submit a Full Project
Amendment to the appropriate ETA Regional Office, as described in
Section 4.e.ii.C. of this UIPL. States in Groups 1 must submit this
Full Project Amendment within 60 calendar days of receiving the
NOA. States in Group 3 must submit within 60 calendar days of the
state receiving their negotiated recommendations.
States who anticipate significant challenges with meeting the
timeframe for submitting a Full Project Amendment may request an
extension. ETA expects that requests for an extension will be rare, and
approvals must be provided by the Grant Officer.
B. Initial Application. The Grant Application to receive any new or additional
funds must be submitted electronically via https://www.grants.gov/, with an
electronic copy to the appropriate ETA Regional Office, as soon as possible
and no later than 11:59 pm Eastern Time on August 18, 2023. The Grant
Application package consists of a completed SF-424 (as described in
Attachment XI of this UIPL) to reflect any new or additional amount
requested, up to the full amount of the new allocation (see Attachment X to
this UIPL).
To demonstrate that the state agrees to comply with the conditions described
in Section 4.e.ii.A.1. of this UIPL, when completing the SF-424, the state
must check the “I AGREE” box under Item 21 and include the appropriate
language in Item 15. States should maintain any supporting documentation
that serves as evidence for meeting the required conditions.
Upon receipt and processing of the SF-424, the state will receive a NOA.
These grants are subject to the requirements of 2 CFR Parts 200 and 2900,
Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards.
C. Full Project Plan. As noted in Section 4.e.ii.A.3. of this UIPL, the Full Project
Plan must be submitted to the appropriate ETA Regional Office. States in
Group 1 must submit this Full Project Amendment within 60 calendar days of
receiving the NOA. States in Group 3 must submit within 60 calendar days of
the state receiving their negotiated recommendations. The Full Project Plan
package must include:
• A copy of the completed SF-424 from the Initial Application;
• A completed SF-424A;
• If indirect cost is indicated on the SF-424A, then a NICRA; and
• A Project Synopsis for each of the negotiated recommendations (as
described in Attachment III to UIPL No. 02-22).
The submission of the required documents does not constitute approval by the
Department. Upon receipt of the Full Project Plan, the Department will
review and work with the state to approve the proposal. Once approved by
the Grant Officer, the Full Project Plan will be an official amendment to the
initial NOA, and the condition of the award that previously restricted access to
the additional funds will be resolved.
iii. Possible Changes to Original Negotiated Recommendations. Recognizing that
circumstances may have evolved since the state originally received their negotiated
recommendations, the Department may consider changes to the original negotiated
recommendations. The Department will consider state project ideas that revise or
expand from the negotiated recommendations, address the purposes articulated in
Section 9032 of ARPA, and enhance the state’s UC system and business processes.
States that are interested in pursuing this option should contact their appropriate ETA
Regional Office to discuss.
iv. Period of Performance. As noted in Section 4.a. of UIPL No. 02-22, Change 2, the
period of performance of grants awarded for implementing the negotiated
recommendations is two years from the start date of the award (i.e., the date of the
NOA). Funds awarded under this subsection will have a period of performance
which begins April 1, 2023, and ends on December 31, 2025.
v. All other terms and conditions remain in place. Except as explicitly noted in this
UIPL, all other guidance from UIPL Nos. 02-22 and 02-22, Change 2, remain the
same.
f. OMB Information Collection Statement. In general, under the Paperwork Reduction
Act of 1995 (PRA), no person is required to respond to a collection of information unless
such collection displays a valid OMB control number. However, Section 2116 of the
CARES Act provides that the PRA does not apply to Subtitle A of Title II of Division A
of the CARES Act. ARPA amended Subtitle A of Title II of Division A of the CARES
Act by adding Section 2118, which provides funding and authority for these grants to
states. Thus, the PRA does not apply to information collections required for these grants.
5. Inquiries. Please direct inquiries to the appropriate ETA Regional Office.
6. References.
• Division B, Title I, Section 24, of the Fiscal Responsibility Act of 2023 (Pub. L. 118-5);
• American Rescue Plan Act of 2021 (ARPA), including Title IX, Subtitle A, Crisis
Support for Unemployed Workers (Pub. L. 117-2);
• Consolidated Appropriations Act, 2021, including Division N, Title II, Subtitle A, the
Continued Assistance for Unemployed Workers Act of 2020 (Pub. L. 116-260);
• Coronavirus Aid, Relief, and Economic Security (CARES) Act, Title II, Subtitle A –
Relief for Workers Affected by Coronavirus Act (Pub. L. 116-136);
• Section 188 of the Workforce Innovation and Opportunity Act (WIOA), 29 U.S.C. §
3248;
• Section 302(a) and 303 of the Social Security Act (SSA), 42 U.S.C. §§ 502(a), 503;
• Section 1137 SSA, 42 U.S.C. § 1320b-7;
• Section 3304 of the Federal Unemployment Tax Act (FUTA), 26 U.S.C. § 3304;
• Section 6402(f) of the Internal Revenue Code (IRC), 26 U.S.C. § 6402(f);
• 2 C.F.R. Parts 200 and 2900, Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards;
• 20 C.F.R. Part 603;
• 29 C.F.R. Part 38;
• Executive Order 13985 of January 20, 2021; 86 FR 7009, page 7009-7013,
https://www.federalregister.gov/documents/2021/01/25/2021-01753/advancing-racial-
equity-and-support-for-underserved-communities-through-the-federal-government;
• UIPL No. 10-23, Cancellation of American Rescue Plan Act (ARPA) Related Guidance,
including Unemployment Insurance Program Letter (UIPL) No. 22-21, Change 2; UIPL
No. 23-21, Change 5; UIPL No. 02-22, Change 3; and UIPL No. 07-23, issued July 13,
2023;
• UIPL No. 09-23, Additional Planning Guidance for the Fiscal Year (FY) 2024
Unemployment Insurance (UI) State Quality Service Plan (SQSP), issued June 30, 2023,
https://www.dol.gov/agencies/eta/advisories/UIPL0923;
• UIPL No. 03-23, Availability of U.S. Department of Labor (Department) Funded
Resources and Services to State American Rescue Plan Act (ARPA) Grantees, issued
March 6, 2023, https://www.dol.gov/agencies/eta/advisories/uipl-03-23;
• UIPL No. 11-22, Grant Opportunity for States to Participate in the American Rescue
Plan Act (ARPA) Unemployment Insurance (UI) Navigator Program, issued January 31,
2022, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-
letter-no-11-22;
• UIPL No. 02-22, Change 2, Extension of Time for States to Express Interest in the Grant
Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No. 02-22,
to Support States Following a Consultative Assessment for Fraud Detection and
Prevention, Promoting Equitable Access, and Ensuring the Timely Payment of Benefits,
including Backlog Reduction, for all Unemployment Compensation (UC) Programs,
issued September 19, 2022, https://www.dol.gov/agencies/eta/advisories/uipl-02-22-
change-2;
• UIPL No. 02-22, Change 1, Extension of Time for States to Express Interest in the Grant
Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No. 2-22 to
Support States Following a Consultative Assessment for Fraud Detection and Prevention,
Promoting Equitable Access, and Ensuring the Timely Payment of Benefits, including
Backlog Reduction, for all Unemployment Compensation (UC) Programs, issued
February 16, 2022, https://www.dol.gov/agencies/eta/advisories/unemployment-
insurance-program-letter-no-02-22-change-1;
• UIPL No. 02-22, Grant Opportunity to Support States Following a Consultative
Assessment for Fraud Detection and Prevention, Promoting Equitable Access, and
Ensuring the Timely Payment of Benefits, including Backlog Reduction, for all
Unemployment Compensation (UC) Programs, issued November 2, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-22;
• UIPL No. 01-22, Announcing the Availability of an Incarceration Data Exchange and
Instructions to Access the Data Exchange between the Unemployment Insurance (UI)
Interstate Connection Network (ICON) and the Social Security Administration (SSA)
Prisoner Update Processing System (PUPS), issued October 29, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
01-22;
• UIPL No. 23-21, Grant Opportunity for Promoting Equitable Access to Unemployment
Compensation (UC) Programs, issued August 17, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
23-21;
• UIPL No. 22-21, Change 1, Extension of Time to Submit Request for Funding under
Grant Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No.
22-21, issued September 17, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
22-21-change-1;
• UIPL No. 22-21, Grant Opportunity to Support States with Fraud Detection and
Prevention, Including Identity Verification and Overpayment Recovery Activities, in All
Unemployment Compensation (UC) Programs, issued August 11, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
22-21;
• UIPL No. 20-21, Change 1, Additional State Instructions for Processing Waivers of
Recovery of Overpayments under the Coronavirus Aid, Relief, and Economic Security
(CARES) Act, as Amended, issued February 07, 2022,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
20-21-change-1;
• UIPL No. 20-21, State Instructions for Assessing Fraud Penalties and Processing
Overpayment Waivers under the Coronavirus Aid, Relief, and Economic Security
(CARES) Act, as Amended, issued May 5, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
20-21;
• UIPL No. 19-21, Benefits Held by Banks and Financial Institutions as a Result of
Suspicious and/or Potentially Fraudulent Activity and the Proportional Distribution
Methodology Required for Recovering/Returning Federally Funded Unemployment
Compensation (UC) Program Funds, issued May 04, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
19-21;
• UIPL No. 16-21, Identity Verification for Unemployment Insurance (UI) Claims, issued
April 13, 2021, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-
program-letter-no-16-21;
• UIPL No. 04-21, Unemployment Insurance (UI) Information Technology (IT) Security –
Additional Information, issued November 2, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-21;
• UIPL No. 28-20, Change 5, Extension of Time to Submit Request for Funding under
Grant Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No.
28-20, Change 4, issued October 17, 2022,
https://www.dol.gov/agencies/eta/advisories/uipl-28-20-change-5;
• UIPL No. 28-20, Change 4, Support for States to Resolve Outstanding Items from the
Expired Coronavirus Aid, Relief, and Economic Security (CARES) Act Unemployment
Compensation (UC) Programs, Including Additional Funding to Assist States with
Reporting and Detection and Recovery of Overpayments, issued July 22, 2022,
https://www.dol.gov/agencies/eta/advisories/uipl-no-28-20-change-4;
• UIPL No. 28-20, Change 3, Extension of Time to Submit Request for Funding under
Grant Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No.
28-20, Change 2, issued September 17, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20-change-3;
• UIPL No. 28-20, Change 2, Additional Funding to Assist with Strengthening Fraud
Detection and Prevention Efforts and the Recovery of Overpayments in the Pandemic
Unemployment Assistance (PUA) and Pandemic Emergency Unemployment
Compensation (PEUC) Programs, as well as Guidance on Processes for Combatting
Identity Fraud, issued August 11, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20-change-2;
• UIPL No. 28-20, Change 1, Additional Funding for Identity Verification or Verification
of Pandemic Unemployment Assistance (PUA) Claimants and Funding to Assist with
Efforts to Prevent and Detect Fraud and Identity Theft as well as Recover Fraud
Overpayments in the PUA and Pandemic Emergency Unemployment Compensation
(PEUC) Programs, issued January 15, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20-change-1;
• UIPL No. 28-20, Addressing Fraud in the Unemployment Insurance (UI) System and
Providing States with Funding to Assist with Efforts to Prevent and Detect Fraud and
Identity Theft and Recover Fraud Overpayments in the Pandemic Unemployment
Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC)
Programs, issued August 31, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20;
• UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program and
the UI Programs Authorized by the Coronavirus Aid, Relief, and Economic Security
(CARES) Act of 2020 – Federal Pandemic Unemployment Compensation (FPUC),
Pandemic Unemployment Assistance (PUA), and Pandemic Emergency Unemployment
Compensation (PEUC) Programs, issued May 11, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
23-20;
• UIPL No. 13-20, Change 2, Families First Coronavirus Response Act, Division D
Emergency Unemployment Insurance Stabilization and Access Act of 2020 (EUISAA) –
Review of State Compliance for Receipt of Emergency Administrative Grants and
Clarification on Benefit Offset Requirements, issued June 3, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
13-20-change-2;
• UIPL No. 04-20, Treasury Offset Program (TOP) Revised and Clarified Requirements
for Referring Unemployment Compensation (UC) Debts for Recovery through Federal
Tax Refund Offset, issued December 16, 2019,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-20;
• UIPL No. 13-19, National Directory of New Hires (NDNH) and State Directory of New
Hires (SDNH) Guidance and Best Practices, issued June 7, 2019,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
13-19;
• UIPL No. 02-19, Recovery of Certain Unemployment Compensation Debts under the
Treasury Offset Program, issued December 12, 2018,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-19;
• UIPL No. 11-18, Change 1, Employment and Training Administration (ETA) 9177 Report
– Pre-Implementation Planning Checklist Report for State Unemployment Insurance (UI)
Information Technology (IT) Modernization Projects – Additional Updates to the ETA
9177 Report and Reporting Instructions, issued on July 16, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
11-18-change-1;
• UIPL No. 14-17, States’ Responsibilities for Internal Security in the Unemployment
Insurance Program, issued March 23, 2017,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
14-17;
• UIPL No. 04-17, Change 1, Requirement for States to Refer Allegations of
Unemployment Compensation (UC) Fraud, Waste, Abuse, Mismanagement, or
Misconduct to the Department of Labor’s (Department) Office of Inspector General’s
(DOL-OIG) and to Disclose Information Related to the Coronavirus Aid, Relief, and
Economic Security (CARES) Act to DOL-OIG for Purposes of UC Fraud Investigation
and Audits, issued August 3, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-17-change-1;
• UIPL No. 02-16, Change 1, State Responsibilities for Ensuring Access to Unemployment
Insurance Benefits, Services, and Information, issued May 11, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-16-change-1;
• UIPL No. 02-16, State Responsibilities for Ensuring Access to Unemployment Insurance
Benefits, issued October 1, 2015,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-16;
• UIPL No. 01-16, Change 1, Federal Requirements to Protect Claimant Rights in State
Unemployment Compensation Overpayment Prevention and Recovery Procedures –
Questions and Answers, issued January 13, 2017,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
01-16-change-1;
• UIPL No. 01-16, Federal Requirements to Protect Individual Rights in State
Unemployment Compensation Overpayment Prevention and Recovery Procedures, issued
October 1, 2015, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-
program-letter-no-01-16;
• UIPL No. 12-14, Required Use of the Treasury Offset Program to Collect Covered
Unemployment Compensation Debt, issued May 20, 2014,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-
no12-14;
• UIPL No. 11-14, Collection and Analysis of Claimant Demographic Data, issued May
15, 2014, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-
program-letter-no11-14;
• UIPL No. 05-13, Work Search and Overpayment Offset Provisions Added to Permanent
Federal Unemployment Compensation Law by Title II, Subtitle A of the Middle Class Tax
Relief and Job Creation Act of 2012, issued January 10, 2013,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
05-13;
• UIPL No. 19-11, National Effort to Reduce Improper Payments in the Unemployment
Insurance (UI) Program, issued June 10, 2011,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
19-11;
• UIPL No. 12-01, Change 2, States’ Ability to Exercise Flexibility in Staffing Models for
the Performance of Certain Unemployment Compensation (UC) Administrative
Activities, issued January 8, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
12-01-change-2;
• UIPL No. 04-01, Payment of Compensation and Timeliness of Determinations during a
Continued Claims Series, issued October 27, 2000,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-01;
• UIPL No. 35-95, The Department of Labor’s Position on Issues and Concerns Associated
with the Utilization of Telephone and Other Electronic Methods in the Unemployment
Insurance (UI) Program, issued June 28, 1995,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
35-95;22
• TEN No. 14-22, Updated Unemployment Insurance (UI) Identity (ID) Fraud Reporting
Website Content, issued January 4, 2023,
https://www.dol.gov/agencies/eta/advisories/ten-14-22;
• TEN No. 05-22, Authority of the U.S. Department of Labor’s (Department) Office of
Inspector General (DOL-OIG) to Receive Confidential Unemployment Compensation
(UC) Data, issued September 15, 2022,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-05-22;
• TEN No. 24-21, Encouragement for States to Use the Integrity Data Hub (IDH)
available through the Unemployment Insurance (UI) Integrity Center, issued May 5,
2022, https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-
24-21;
• TEN No. 16-21, Announcing Grant Awards Made to States Selected to Participate in the
Unemployment Insurance (UI) Information Technology (IT) Modernization Project –
Claimant Experience Pilot, issued December 2, 2021,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-16-21;
• TEN No. 15-21, Announcing the National Association of State Workforce Agencies
(NASWA) Unemployment Insurance (UI) Integrity Center’s Behavioral Insights Toolkit,
issued November 17, 2021, https://www.dol.gov/agencies/eta/advisories/training-and-
employment-notice-no-15-21;
Although this UIPL shows an expiration date of June 30, 1996, TEN No. 26-21 (published May 24, 2022)
confirms that it is still active.
• TEN No. 06-21, Accessing Unemployment Insurance (UI) Identity Verification and
Fraud Protection (Identity Proofing) Services using the U.S. Department of Labor’s
(Department) Blanket Purchase Agreements (BPA), issued September 15, 2021,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-06-21;
• TEN No. 05-20, National Directory of New Hires (NDNH), State Directory of New Hires
(SDNH), and Other Improper Payment Prevention and Detection Resources, Tools, and
Services Available to States, issued September 24, 2020,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-05-20;
• TEN No. 04-20, Encouragement for States to Use the Integrity Data Hub (IDH)
available through the Unemployment Insurance (UI) Integrity Center, issued August 31,
2020, https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-
04-20;
• TEN No. 03-20, Unemployment Insurance (UI) Integrity Center’s Integrity Data Hub
(IDH) Fraud Alert System, issued August 31, 2020,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-03-20;
• TEN 14-19, Importance of Including Labor Market Information Stakeholders in Planning
and Implementation for Unemployment Insurance (UI) Information Technology
Modernization Projects, issued January 13, 2020,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-14-19;
• TEN No. 12-16, Unemployment Insurance (UI) State Information Data Exchange
Systems (SIDES), issued September 27, 2016,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-12-16;
and
• Employment Security Manual, Section 7511, The Secretary’s Interpretation of Federal
Law Requirements, available at 20 C.F.R. Part 614, Appendix C, Standard for Fraud and
Overpayment Detection.
7. Attachment(s).
• Attachment I: Integrity Grants – State Size and Amount
• Attachment II: Integrity Grants – Full Project Plan Template
• Attachment III: Identity (ID) Verification/Proofing Services and Solutions Recommended
Contract Provisions
• Attachment IV: Considerations in Providing Individual Notifications under CARES Act
UC Programs with Possible Applicability to the Regular UC Program
• Attachment V: National Identity (ID) Verification Offering – Roles and Responsibilities
• Attachment VI: IT Modernization Grants – Categories and Outcome Metrics
• Attachment VII: IT Modernization Grants – Promising Practices and Sample Projects
• Attachment VIII: IT Modernization Grants – Initial Application Project Abstract
Template
• Attachment IX: IT Modernization Grants – Full Project Plan Template
• Attachment X: Tiger Team Grants – Updated Funding Allocations by State
• Attachment XI: Instructions for Completing the SF-424 and SF-424A
• Attachment XII: Instructions for Budget Information Narrative
• Attachment XIII: Form ETA 9178-ARPA
• Attachment XIV: Important Resources, Strategies, Tools, and Services for States
• Attachment XV: Glossary of Key Terms for IT Modernization
• Attachment XVI: Summary of UIPL Contents
Attachment I to UIPL No. 11-23
Integrity Grants – State Size and Amount
State Size Classifications and Funding Allocation to Support States in Strengthening
Identity (ID) Verification and Improving Fraud Prevention, Detection, and Overpayment
Recovery Efforts in All Unemployment Compensation (UC) Programs
State Size Classification UC Integrity Funding Allotment
Alabama Medium $1,739,000
Alaska Small $869,000
Arizona Large $2,609,000
Arkansas Medium $1,739,000
California Extra Large $3,479,750
Colorado Large $2,609,000
Connecticut Medium $1,739,000
Delaware Small $869,000
District of Columbia Small $869,000
Florida Extra Large $3,479,750
Georgia Large $2,609,000
Hawaii Small $869,000
Idaho Small $869,000
Illinois Large $2,609,000
Indiana Large $2,609,000
Iowa Medium $1,739,000
Kansas Medium $1,739,000
Kentucky Medium $1,739,000
Louisiana Medium $1,739,000
Maine Small $869,000
Maryland Large $2,609,000
Massachusetts Large $2,609,000
Michigan Large $2,609,000
Minnesota Large $2,609,000
Mississippi Medium $1,739,000
Missouri Large $2,609,000
Montana Small $869,000
Nebraska Small $869,000
Nevada Medium $1,739,000
New Hampshire Small $869,000
New Jersey Large $2,609,000
New Mexico Small $869,000
New York Extra Large $3,479,750
North Carolina Large $2,609,000
North Dakota Small $869,000
Ohio Large $2,609,000
Oklahoma Medium $1,739,000
Oregon Medium $1,739,000
Pennsylvania Large $2,609,000
Puerto Rico Small $869,000
Rhode Island Small $869,000
South Carolina Large $2,609,000
South Dakota Small $869,000
Tennessee Large $2,609,000
Texas Extra Large $3,479,750
Utah Medium $1,739,000
Vermont Small $869,000
Virgin Islands Small $869,000
Virginia Large $2,609,000
Washington Large $2,609,000
West Virginia Small $869,000
Wisconsin Large $2,609,000
Wyoming Small $869,000
U.S. TOTAL $100,000,000
Attachment II to UIPL No. 11-23
Integrity Grants – Full Project Plan Template
Instructions: States must complete the application using the suggested format and
instructions below for the projects/activities for which the state is seeking funding. This
application is to be combined with a completed SF-424, a SF-424A, and Budget Narrative
covering all projects/activities (see Section 4.b.vi.C.3. of this UIPL).
Grant funding for Strengthening Identity (ID) Verification and Improving Fraud
Prevention, Detection, and Overpayment Recovery Efforts in All Unemployment
Compensation (UC) Programs
State Name:
Total Funds Requested:
Name, Title, and Address of Grant Notification Contact (Typically the State Workforce
Agency Administrator)
Name:
Title:
Address:
Name, E-Mail Address, and Phone Number of Grant Project or Fiscal Manager
Name:
E-Mail Address:
Telephone Number:
Provide the following information for each project (add additional rows as needed)
Individual Workload Total Cost of Workload Proposed Completion Date
Project/Activity Name Project/Activity
Name of Funding Activity or Activities
Amount of Funding Request for the Activity or Each Activity
State Contact
Name:
E-Mail Address:
Telephone Number:
Description of Activity or Activities
Project Timeline for Each Activity
Description of Costs:
State Agency Staff Costs:
Type of Position Total Hours Cost Per Hour Total
Contract Staff Costs:
Type of Position Total Hours Cost Per Hour Total
Hardware, Software and Telecommunications Equipment:
Item Description Cost Per Item Quantity Total
Other Costs:
Item Cost Explanation
Strategic Design
Application Instructions
Name of Funding Activity or Activities: Provide the name of the proposed integrity
project/activity to be carried out. If the state is submitting requests to fund more than one
project/activity, each project/activity should be identified by a different name that describes each
project/activity. The state must provide a separate Grant Project Application for each
project/activity they are seeking to have funded by the grant (the applications should match the
projects in the Request Abstract).
Amount of Funding Requested for the Activity or Each Activity: Provide the total amount of
funds requested in this individual project/activity.
State Contact: Provide name, telephone number, and e-mail address of the individual who can
answer any questions relating to the proposal.
Description of Activity or Activities: Provide a brief description of the integrity
project/activity for which the state is seeking funding and explain how the project/activity will
support strengthening the integrity of UC programs for the participating state.
Project Timeline for Each Activity: Provide a list of the dates and the milestones for each
project/activity. The timeline should include the completion of the work, the designation of
specific tasks to appropriate parties, the issuance of a request for proposal, if appropriate, the
projected start date, the proposed dates to begin and complete testing (if necessary), and the
proposed date for full implementation of the project/activity. These milestones and dates will be
used to monitor the implementation of the project/activity. Any additional work needed to
identify and provide progress on the identified outcome metric should be included in this
project/activity timeline.
Description of Costs: Provide an explanation of all costs included in the project/activity.
1. State Agency Staff Costs: Use the table format provided in this attachment to request
state staff to support project/activity implementation.
2. Contract Staff Costs: Use the table format provided in this attachment to request
contract staff to support project/activity implementation.
3. Hardware, Software, and Telecommunications Equipment: Provide an itemized list
of hardware, software, and telecommunications equipment including the cost per item
and the number of each item requested. A description of each item must provide any
information needed to identify the specific item and a description of the size and capacity
of each item if applicable.
4. Other Costs: Identify each item of cost not covered elsewhere and provide the expected
cost per item. The need for each item must be explained.
Strategic Design: The strategic design of the integrity project/activity should provide
evidence of a thorough analysis of current operations and include information supporting
how the use of these funds will provide a return on investment with regards to
strengthening UI program integrity in the UC programs. All projects/activities funded
under this UIPL must be complementary rather than duplicative of projects/activities
funded under other grant opportunities.
Attachment III to UIPL No. 11-23
Identity (ID) Verification/Proofing Services and Solutions Recommended Contract
Provisions
In evaluating potential service providers to deliver a solution for ID verification/proofing, states
should consider including the following recommended contract provisions.
Recommended Technical Provisions
1. Digital ID Verification/Proofing
2. Data Privacy & Sharing
3. Data Access & Ownership
4. Audit Trail
5. Performance, Scalability & Availability
6. Support & Training
7. Service Level Provisions
8. General Provisions – Section 508 Compliance
Recommended Business Provisions
1. Business Performance Provisions (Timeliness and Transparency)
2. Equity Provisions
More detail on each recommended provision, including the specific recommendation, its
purpose, and sample contract language is included in the table below. The state is responsible
for ensuring that any sample contract language it uses is in compliance with state law and
adequately ensures that the state’s contract needs and technical requirements are met.
Digital ID Verification/Proofing
Recommended Provision Purpose Sample Contract Language
Implement ID verification/proofing Improves speed of delivery of • Solution incorporates best practices from NIST
that balances equitable access with benefit payments by establishing Special Publication (SP) 800-63-3 guidelines while
alignment to National Institute of high confidence in the individual’s ensuring equitable access.
Standards and Technology’s identity. Reduces workload on • Solution provides configurable and accessible User
(NIST)’s digital identity guidelines. state staff by assisting on ID Interfaces/User Experience (UX) flow that is
(See verification. Reduces online mobile-responsive and compatible with multiple
https://csrc.nist.gov/publications/deta fraud, including ID theft and ID browsers and device types as per industry standards.
il/sp/800-63a/final). Section 4.4 fraud. • Solution provides verified, not verified, and
pages 8-11. pending outcomes along with configurable data
associated back to calling systems for continuation
CAUTION: Carefully review of adjudication and processing of claims or other
solutions that use biometrics such as related activities.
facial recognition. While these
solutions may help to reduce ID
fraud, they may have negative
implications for equity or lead to
violations of states’
nondiscrimination obligations under
Section 188 of Workforce Innovation
and Opportunity Act (WIOA).
Digital ID Verification/Proofing
Recommended Provision Purpose Sample Contract Language
Implement authentication to online Reduces fraud and online “claims • Solution incorporates best practices from the NIST
systems incorporating best practices hijacking” also known as “claims SP 800-63-3 AAL2 standard.
from NIST’s Authenticator or account takeover” by • Solution provides configurable and accessible User
Assurance Level (AAL) 2 standard establishing stronger Interfaces/UX flow that is mobile-responsive and
definition. (See authentication/verification of an compatible with multiple browsers and device types
https://csrc.nist.gov/publications/deta individual’s online identities when as per industry standards.
il/sp/800-63b/final). Section 4.2 accessing systems to change
pages 6-8. contact information, address
information, and bank account
CAUTION: NIST SP 800-63-3 information.
AAL2 recommends very strict
session timeouts that may be
burdensome to some applicants,
particularly to those less familiar with
multi-factor authentication (MFA).
States are encouraged to balance
these factors and exercise judgment
when instituting secure
authentication.
Data Privacy and Sharing
Recommended Provision Purpose Sample Contract Language
Require Data Privacy & Data Sharing Protects user data from • Disclose all uses of user data including data sharing
Provisions. unauthorized disclosure, with third parties and how they mitigate potential
particularly Personally Identifiable third-party service bad actors or negligent actors to
Information (PII) and sensitive ensure the protection of user data, especially PII and
information. sensitive information.
• The service provider shall protect all data disclosed
to them in accordance with Federal and state
Unemployment Compensation (UC) law, including
the Federal regulations at 20 CFR Part 603, and all
other requirements related to confidentiality and
disclosure avoidance.
• Support supply chain audits as requested by state
and must comply with the provisions of the Privacy
Act of 1974. All personnel assigned to this contract
are required to take proper precautions to protect the
information from disclosure. The service provider
must not release, publish, or disclose sensitive
information to unauthorized personnel, and must
protect such information following provisions of the
following laws and any other pertinent laws and
regulations governing the confidentiality of sensitive
information: 18 U.S.C. 641 (Criminal Code: Public
Money, Property or Records).
Prohibit Personal Data Resale or To prevent the resale or • Prohibition on Personal Data Resale or Commercial
Commercial Use. commercial use of person’s or Use: The service provider is prohibited from
state data. reselling or using for any commercial purpose,
whether individually or in aggregate, any person’s or
state data collected in the execution of the contract
or subsequent orders. Sharing of data other than for
the express purpose of ID verification for UC claims
is strictly prohibited.
Data Access & Ownership
Recommended Provision Purpose Sample Contract Language
Preserve State Access to and To preserve a state’s ability to At a minimum, the solution must support the following
Ownership of Government Data. create, maintain, and modify the Data ownership requirements inclusive and not limited
Government Data included within to:
the solution. • Machine-Readable Exports: Solution must support
creating a digital, reusable copy of the Government
Data, in whole and parts, as a platform-independent
and machine-readable file.
• Use of Government Data: Solution’s copyright,
patent, or intellectual property considerations must
not restrict state use of the solution to create,
maintain, and modify the Government Data. The
solution must not make use of the Government Data
for any commercial purpose or any purpose not
specified in this agreement, whether to the benefit
of the solution’s service provider or a third-party.
Audit Trail
Recommended Provision Purpose Sample Contract Language
Provide a comprehensive audit trail The selected service provider must • Audit reports must have comprehensive audit trail
(See: NIST SP 800-53 Rev 5.0). provide a thorough and capability to collectively provide documentary
comprehensive audit trail. It is evidence of the processing used to aid in tracing
important to have a full accounting from original transactions forward to related records
of who applied for benefits, what and reports, and/or backwards from records and
the decision was, etc. This will reports to their component source transactions. The
assist with required compliance Audit trail must comply with NIST SP 800-53 Rev
reporting, as well as provide 5.0 controls contained in the Audit and
documentation on state decisions Accountability family. The solution must provide
should the state face legal reporting for compliance with the Federal
challenges. Information Security Modernization Act of 2014
(FISMA) and NIST SP 800-53 (as amended).
Performance, Scalability & Availability
Recommended Provision Purpose Sample Contract Language
Ensure system’s capability to scale It is crucial that the supplied • System’s capability to handle an increasing number
up quickly and effectively to handle solution be able to scale up of users or an increase in requests (e.g., more than
increased caseloads. quickly and efficiently, should 500,000 ID verification/proofing requests per week)
there be a surge in UI claims, so without adversely affecting response time and
that response time and throughput throughput. The uptime guarantee for production
are not negatively impacted. instances must be 99.95% to prevent the impact on
the UI programs.
Support & Training
Recommended Provision Purpose Sample Contract Language
Provide robust training and support The selected service provider must • The service provider must provide customer support
network for both program staff and provide a robust training and for state client bases, including, but not limited to,
UI applicants. support network to support both system owners and managers, as required.
program staff and UI applicants. • Support state technical staff to create stable
integration architecture.
This training should include, at a • Call center support for all login, ID
minimum, an online repository of verification/proofing, MFA help desk tickets.
help guides and videos. Support • Support for individuals whose ID
should include, at a minimum, a verification/proofing is pending or is in failed status
call center to assist with login, ID while attempting to obtain verification.
verification/proofing, and MFA • Provide prioritized integration/implementation,
help desk tickets. architecture, and solutions support.
• Training support such as conducting webinars,
online videos, and other documentations as needed.
• Online technical and user documentation
(architecture, help guides, videos, runbooks, etc.).
Service Level
Recommended Provision Purpose Sample Contract Language
Provide rapid response times for ID The selected service provider In additional general service/support activities, the
verification. should prioritize rapid response service provider must comply with the following:
times for ID verification. The • Supervised remote ID verification must not exceed
target should be to provide a 48 hours to provide a decision outcome.
decision for supervised remote ID • Unsupervised ID verification must not exceed 5
verification in no more than 48 minutes to provide a decision outcome.
hours and for unsupervised ID • Average response times for page loads must not
verification in no more than 5 exceed 5 seconds.
minutes. Likewise, average page • Priority 1 helpdesk and product/technical support
load times should not exceed 5 tickets must be processed in 2 hours.
seconds. This will ensure • Priority 2 product/technical support tickets must be
customer satisfaction and an processed in 24 hours.
efficient and effective ID • All other product/technical support tickets must be
verification process. processed in 72 hours.
• Authentication and ID verification error rates (false
positives or false negatives) must not exceed 1%.
General
Recommended Provision Purpose Sample Contract Language
Meet state-specific security and To ensure that the content is • The selected service provider must ensure
Section 508 Compliance standards. accessible to people with compliance with state-specific security standards
disabilities. as well as Section 508 of the Rehabilitation Act, to
ensure that the content is accessible to people with
disabilities.
• The Section 508 standards incorporate by reference
the Web Content Accessibility Guidelines
developed by the Web Accessibility Initiative to
make web pages as accessible as possible to the
widest range of users, including users with
disabilities.
Business Performance
Recommended Provision Purpose Sample Contract Language
Timely communication of ID Timeliness and transparency are Timeliness:
verification decisions to the state UI important pieces of the service • The service provider’s ID verification system
agency. provider’s ID verification system. must be able to provide notification to the state
It is important to ensure that the UI agency whether an individual’s identity has
service providers’ ID verification been verified, not verified, or is pending, if
system communicates the decision possible, in real-time, but no later than 24 hours
made on an individual’s identity after the individual started the ID
(e.g., verified, not verified, verification/proofing process.
pending) to the state UI agency. • As requested by the state UI agency, the service
These decisions should be provider must notify the individual of whether
communicated in real-time, if their identity has been verified, not verified, or is
possible, but no later than 24 hours pending, if possible, in real-time, but no later
after the individual begins the ID than 24 hours after the individual started the ID
verification process. The service verification/proofing process.
provider should also notify the
individual of the decision within
the same timeline discussed above.
Equity Provisions
Recommended Provision Purpose Sample Contract Language
Ensure equitable access. The service provider selected to Unemployment Insurance Program Letter (UIPL) No.
provide ID verification services 02-16 (published October 1, 2015) and UIPL No. 02-
should have a plan to ensure 16, Change 1 (published May 11, 2020), provide State
equitable access to ID verification Responsibilities for Ensuring Access to Unemployment
services, including for individuals Insurance Benefits, Services, and Information.
with disabilities, individuals with Consistent with these requirements, the Department
Limited English Proficiency requires the service provider to provide the following.
(LEP), older individuals, and those • The service provider must provide an efficient
unable to access or use a web- alternative access method for individuals who are
based system. To ensure equity, unable to complete ID verification through
the service provider should electronic or self-service means. This includes
provide alternative access methods individuals with barriers to access, such as
that are readily available, timely, individuals with disabilities, LEP individuals,
and of no-cost to the individual. older individuals, individuals who experience
challenges with technology, and individuals who
experience challenges with literacy. This also
includes individuals who need support
troubleshooting.
• The alternative access methods must: (1) ensure
meaningful access to LEP individuals so that
they are effectively informed about and/or able to
participate in ID verification. Language
assistance services must be accurate, provided in
a timely manner, and free of charge to the
individual; and (2) be advertised on the service
provider’s application and include information
about how an individual who has difficulty using
the site or service can get assistance to access the
site or service.
Attachment IV to UIPL No. 11-23
Considerations in Providing Individual Notifications under CARES Act UC Programs with
Possible Applicability to the Regular UC Program
As described in Section 4.b.iii.C. of this Unemployment Insurance Program Letter (UIPL), while
conducting overpayment recovery activities, states are encouraged to consider the contents of
this attachment when providing individual waiver notifications and processing refunds under the
Coronavirus Aid, Relief, and Economic Security (CARES) Act unemployment compensation
(UC) programs as well as for the regular Unemployment Insurance (UI) program.
Notification for individuals with non-fault overpayments when the state allows for individual
waiver requests. Within the context of CARES Act UC programs, when states require
individuals to submit a request for waiver consideration, as described in Option #2 under Section
4.c.iii.A. of UIPL No. 20-21, Change 1, the state must notify all individuals with a non-fault
overpayment of their ability to request a waiver.
In addition to the requirement for individual notices and given the time lapse that can occur
between the payment of benefits and the resolution of overpayment cases that continues today,
the Department recommends that states also post notice of the availability of waiver requests on
the state’s UI website and within the claimant portal, including links to instructions on how to
request a waiver. Attachment IV to UIPL No. 20-21, Change 1, provides sample language that
states may consider for their UI websites.
Notification for individuals when an overpayment is approved for waiver of recovery. Within
the context of the CARES Act UC programs, when the state determines, through the blanket
waiver process, that an overpayment is eligible for a waiver of recovery, as described in Option
#1 under Section 4.c.iii.A. of UIPL No. 20-21, Change 1, the state must also notify each
individual in writing that a waiver of recovery has been granted. When the state determines, on
an individual-case-by-case basis, that an overpayment to an individual is eligible for waiver of
recovery, as described in Option #2 under Section 4.c.iii.A. of UIPL No. 20-21, Change 1, the
state must also notify that individual of the outcome in writing. The required contents of this
notification are described on page 17 of that UIPL.
Where applicable, the Department encourages states to use the sample language provided in
Attachment III to UIPL No. 20-21, Change 1, for these individual notifications. It is written with
the assumption that a state has previously sent a determination establishing the overpayment.
Specifically, when the state identifies an overpayment that is eligible for waiver of recovery at
the same time the overpayment is established, sample language is provided on page 15 of that
UIPL.
Processing Refunds for Collections Occurring Prior to Waiver of Recovery Being Approved. As
described in Section 4.d.iv.B. of UIPL No. 20-21 and reiterated in UIPL No. 20-21, Change 1, if
recovery of an overpayment under the CARES Act UC programs is waived, the state must refund
any amounts that were collected prior to the determination of the waiver for the applicable
overpayment. Individuals may be wary of depositing refund checks, so it is especially important
that these notifications include an explanation. When at all possible, the Department encourages
states to process refunds through the same method used to originally pay the individual (e.g.,
direct deposit, debit card, mailed check).
Attachment V to UIPL No. 11-23
National Identity (ID) Verification Offering – Roles and Responsibilities
This list, though not exhaustive, describes some of the key roles and responsibilities of
participating states and the Department when implementing the National ID Verification
Offering.
Role of State UI Agencies Participating in National ID Verification Offering. The state
Unemployment Insurance (UI) agency will, as needed:
• Assign a state UI agency staff member with decision-making authority for the state UI
agency.
• Assign a state UI agency staff member responsible for day-to-day operations who will be
available, as needed, to respond to issues that arise.
• Provide appropriate additional information technology (IT) staff support to maintain
functionality.
• Provide the Department direct access to the state UI agency senior stakeholders across
appropriate state UI agency components, as well as state UI agency staff who are
knowledgeable in UI claims processing.
• Provide the Department with necessary state UI agency credentials, building and systems
access (in adherence to the safeguards described in the data sharing agreement (DSA)), and
IT resources.
• Provide the Department with access to necessary information related to the work the
Department will perform, to include all relevant project materials, internal meetings, standard
operating procedures, and other resources.
• Process claims that originate through participation with this offering and support individuals
applying for and/or receiving unemployment compensation (UC), making any necessary
adjustments to existing systems and processes and in adherence to merit staffing23 principles
set forth at Section 303(a)(1) of the Social Security Act and Departmental guidance.
• Collect sufficient information from individuals to facilitate ID verification and comply with
Unemployment Insurance Program Letter (UIPL) No. 16-21, and any subsequent changes
published by the Employment and Training Administration (ETA), for any individual that
does not complete or fails to complete verification.
• Disclose individual-level data to the Department for purposes of assessing the effectiveness
of ID verification (as described in Section 4.c.iii. of this UIPL).
• Provide feedback on the effectiveness of the experience, which may include collecting and
sharing relevant program metrics and responding through surveys.
• For any materials that the state chooses to publish on their website, ensure that confidential
UC information is redacted.
Use of one or both of the National ID Verification Offering products does not alter the state's obligation to employ
merit staffing principles throughout the claim cycle for eligibility determinations, as set forth in Section 303(a)(1) of
the Social Security Act and related Department guidance.
Role of the Department Assisting Participating State UI Agencies with National ID
Verification Offering. The Department will, as needed:
• Provide government-operated ID verification systems to states that support online ID
verification services through partnership with General Services Administration’s Login.gov
and in-person ID verification services through partnership with the U.S. Postal Service,
subject to the availability of funding and necessary agreements being in place.
• Support the state UI agency to set priorities, resolve issues, and ensure the design and
delivery of digital services to the state UI agency and the individuals it serves.
• Support and promote the use of agile methodologies and modern technology infrastructure to
deliver the scope of the offering.
• Give advice and technical assistance to the state UI agency on digital service solutions,
information technology needs, business processes, and policy.
• Assist and conduct research with state UI agency customers and internal users to evaluate the
offering and to determine how the services can be improved.
• As necessary, coordinate IT program activities with stakeholders endeavoring to achieve
seamless integration of program elements with ongoing policy, leadership, and service
delivery operations.
• As necessary, maintain responsibility for communication and outreach with appropriate
stakeholders.
Attachment VI to UIPL No. 11-23
IT Modernization Grants – Categories and Outcome Metrics
States may receive up to $11.25 million each24 to implement project(s) within at least one of the
Unemployment Insurance (UI) IT Modernization categories described below. Refer to Section
4.d. of this UIPL.
Category #1: Cloud Migration.
Description: State migration from legacy platforms, such as mainframes, to cloud-based
technology that will measurably improve the flexibility and security of IT systems compared to
existing metrics or conditions.
The objective of a cloud-based migration is not only to move data securely from mainframes to
a cloud-based system (e.g., “lift and shift”), but to use that transformation to improve the
architecture of the data so that systems are ultimately more resilient and responsive to changing
needs.
Examples of Desired Outcome Metrics. More easily scale resources to meet changing demands
and/or more quickly deploy new IT applications or enhancements such as:
1. Reduction in hardware and infrastructure costs: States can evaluate the cost savings
resulting from reduced hardware and infrastructure costs associated with the migration
to cloud-based technology. This can be measured by comparing the cost of maintaining
legacy platforms with the cost of using cloud-based technology.
2. Improved system performance: States can measure the improvement in system
performance resulting from the migration to cloud-based technology. This can be
evaluated through metrics such as system uptime, response time, and user satisfaction.
3. Faster deployment of new applications: States can measure the time it takes to deploy
new applications, enhancements, and or more easily respond to new federal program
requirements after the migration to cloud-based technology. This can be evaluated by
comparing the time it takes to deploy applications using legacy platforms with the time it
takes using cloud-based technology.
4. Increased system availability: States can measure the increased system availability
resulting from the migration to cloud-based technology. This can be evaluated by
comparing the downtime of legacy platforms with the downtime of cloud-based
technology.
5. Improved scalability: States can measure the improved scalability resulting from the
migration to cloud-based technology. This can be evaluated by comparing the ability of
Funds will be awarded to states that submit complete and responsive applications in the order received by the
Department, as long as funding remains available.
legacy platforms to scale resources to meet changing demands with the ability of cloud-
based technology to scale resources.
Category #2: Modular and Application Programming Interface (API)-driven Approaches.
Description: Improve the flexibility of IT systems by breaking down complex “monolithic”
systems into smaller, more manageable components.
Monolithic refers to a legacy software design pattern where all (or many) components are
tightly integrated and dependent on each other, making even simple IT changes costly, time-
intensive, and risky. Instead, a modular approach allows for changes to be made to a single
component more easily than if those same changes were applied to the system as a whole.
In addition, the use of API-driven approaches can further enhance flexibility by promoting
greater interoperability between systems, including vendor solutions, by enabling these systems
to communicate and exchange data more easily.
Overall, a modular approach provides many benefits, including easier maintenance, testing,
scaling, and/or modification of the IT system, by allowing more targeted software changes and
enabling modules to be replaced more easily.
Examples of Desired Outcome Metrics.
1. Time and cost savings: Measure the time and cost savings achieved by implementing a
modular approach and compare it with the time and costs required to make similar
changes and or maintain legacy system components.
System uptime & performance: Measure the system uptime and performance after
implementing a modular approach to determine if the system is more reliable and stable,
especially during periods of peak workload or demand. System uptime refers to the
period during which a computer system, application, or service is operational and
available for use by its intended users and is an indicator of overall system reliability and
performance. Similarly, a more performant system can scale to meet new demands, such
as an increased volume of transactions without sacrificing availability or incurring
significant new costs.
2. Improved adoption of agile software development practices: Show how a modular
approach allows for the adoption of agile software development methodologies and
related practices, like DevOps and Continuous Integration/Continuous Deployment
(CI/CD), enable teams to deliver working software in shorter development cycles and
with fewer defects compared to baseline approaches.
3. System performance: Measure the performance of the new modular system compared
to the legacy system to determine if the system is more efficient and scalable.
Category #3: Measurably Improving the Customer Experience (CX).
Description: Establish baseline metrics for the CX for any website or portal where customers
can access information, services, or resources related to state programs and services and engage
in activities that will measurably improve at least one of those metrics.
In December 2021, the President’s Executive Order on Transforming Customer Experience and
Service Delivery25 directed federal agencies, as well as federal programs administered at a state
or local level, to improve the CX associated with how those services are delivered. The
Department recognizes that effective CX for the UI program spans both online and in-person
channels and defines an “effective digital experience” as one that enables workers to complete
tasks, like filing a claim, quickly, accurately, and with minimal intervention from state staff.
Additionally, strong customer experiences can result in greater self-service opportunities for
individuals and lower call center volume, more accurate and complete filings, and greater
efficiency for state workforce agencies. In working to measurably improve customer
experiences, it is important that states show how they will center technology choices around the
actual needs of individuals and employers and leverage an agile, or iterative, approach to shape
and validate solutions based on user feedback.
Examples of Desired Outcome Metrics.
1. Time and accuracy of task completion: Measure the average median time it takes for
individuals to complete specific tasks on the portal, such as filing a new claim or
submitting weekly certifications and how better experiences can improve accuracy,
drive faster payments, and reduce improper payments.
2. Abandonment rate: Measure the percentage of individuals who start a task on the portal
but abandon it before completing it. This can indicate that the task is too complex, or
which specific aspects of the experience are difficult to complete and why.
3. Click-through rate: Measure the percentage of users who click on links or buttons on
the portal that lead to other pages or tasks. A low click-through rate may indicate that the
design or layout of the portal is confusing or difficult to navigate.
4. Error rate: Measure the percentage of users who encounter errors while using the portal,
such as system downtime or technical errors. This can indicate areas for improvement in
the portal’s infrastructure.
5. Ease of use: Conduct surveys or collect feedback from individuals about their experience
using the portal. Ask about their overall satisfaction, ease of use, and any suggestions for
improvement.
Executive Order 14058, Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in
Government, issued December 13, 2021, https://www.federalregister.gov/documents/2021/12/16/2021-
27380/transforming-federal-customer-experience-and-service-delivery-to-rebuild-trust-in-government.
Attachment VII to UIPL No. 11-23
IT Modernization Grants – Promising Practices and Sample Projects
The Department has identified the following promising practices for states to consider when
developing their Full Project Plans as described in Section 4.d.iv.C. of this Unemployment
Insurance Program Letter (UIPL).
• Targeted and High-Value Changes: The funds should be utilized for specific
improvements that enhance the flexibility and performance of state systems in measurable
ways. It is important to focus on making incremental and high-value changes rather than
complete system overhauls.
• Software Reuse and Collaboration: Given the goals of this UIPL and the Department’s
vision for an Unemployment Insurance (UI) technical ecosystem built around open and
modular solutions, states are encouraged to consider using open-source software produced by
other states through this grant opportunity, or through other means. Additionally, the
Department encourages states to consult with each other on which open-source components
they plan to build, or invest in, to maximize the potential for software reuse across states.
• Agile and Human-Centered Approach: States should adopt agile software development
methodologies, including DevOps and Continuous Integration & Continuous Deployment
(CI/CD), and prioritize a human-centered approach. This means delivering software in
iterative and incremental cycles, seeking early and frequent feedback from users and other
stakeholders, and using that feedback to inform the evolution of solutions. Together, these
approaches help ensure that user needs are met effectively, and that software can be delivered
more efficiently, with fewer defects and less risk.
• Continual Process of Modernization: Modernization is an ongoing process that involves
changes to technology, people, and processes. States should consider how new technologies
will require corresponding process changes and evaluate the need for new or different skills
to fully support the modernized systems.
• Augmenting, not Replacing, Staff with Technology: When considering the use of
technology to streamline or automate functions, states should prioritize augmenting current
staff rather than replacing them. They should carefully evaluate how to implement
appropriate safeguards and controls to ensure the effective, accurate, and ethical deployment
of technology.26
Reference UIPL No. 12-01, Change 2, for the Department’s latest guidance on merit staffing principles.
In support of these promising practices, the following table describes an array of sample projects
in line with the categories described in Section 4.d. and Attachment VI to this UIPL.
Sample Project Associated Activity
States may choose to migrate systems, or specific applications, from legacy hosting Cloud Migration
platforms to the cloud. By doing so states can realize several benefits, including
reduced infrastructure costs, improved scalability, and improved performance,
particularly during periods of high claims volume, as well as improved security,
accessibility, and collaboration between agencies.
States may choose to decouple system components, like claimant portals from Modular & API-driven
mainframes, so that those new components can be managed independently and are Approaches
easier to maintain and change.
States may choose to implement application programming interfaces (APIs) to enable Modular & API-driven
more seamless integration and interoperability between different systems and Approaches
platforms, including new components that may interface with existing vendor or
home-grown solutions.
States may choose to adopt DevOps, a software development approach that Modular & API-driven
emphasizes collaboration, communication, and automation between software and Approaches
business teams, to drive faster and more frequent software releases with fewer defects.
Adopting a practice like DevOps requires new skillsets and cultural shifts, but also
automating processes and tools, such as automating builds, tests, and deployments,
implementing continuous integration and continuous deployment (CI/CD) pipelines,
and embracing infrastructure as code that allows for infrastructure to be managed and
scaled programmatically.
States may choose to implement robust error handling mechanisms and improved data Modular & API-driven
validation to measurably reduce error rates. approaches
States may use funds to hire technologists, or other staff, that enable an iterative and Improving the
data-driven approach to improving the customer experience. This staff could work on Customer Experience
efforts that span digital and non-digital channels, including how call centers and in-
person experiences affect the overall customer experience; however, in all cases, these
projects must involve collecting and leveraging feedback from individuals and
employers to shape solutions.
Some examples of the types of roles states may choose to invest in include product
managers, user researchers, service-designers, and content designers.
States may choose to update legacy code to comply with accessibility standards, such Improving the
as Web Content Accessibility Guidelines (WCAG) to improve access for individuals Customer Experience
with varying needs, such as visually-impaired individuals who require screen-readers
to access the web.
States may choose to invest in a content management system (CMS) that allow staff to Improving the
make public-facing content changes more quickly and easily. Customer Experience
Attachment VIII to UIPL No. 11-23
IT Modernization Grants – Initial Application Project Abstract Template
As described in Section 4.d.iv.B. of this Unemployment Insurance Program Letter (UIPL), the
Initial Application package consists of a completed SF-424 (as described in Attachment XI of
this UIPL) and a completed Project Abstract, as provided below. To be considered complete,
states will need to complete the application template below and submit alongside the SF-424.
Failure to submit a complete project template, including agreement to the conditions in items 1, 4
5, 6, and 7 below, will result in the application being deemed non-responsive and not considered
for funding. Funds will be awarded in the order that completed Initial Applications are
received, as long as funding remains available.
Application for IT Modernization Project
State:
Applicant Name:
Project Title:
Funding Request: $
Enter an amount up to $11.25 million. This
must align with the amount requested on the
corresponding SF-424.
☐ YES
1. Has the state consulted its state IT
Department about this project?1
☐ NO
2. UI IT Modernization Categories that ☐ Cloud Migration
will be Pursued (check all that apply):
☐ Modular and API-Driven Approaches
☐ Measurable Customer Experience (CX)
3. Project Abstract (limit to 900
characters): Briefly describe the goals of
your project and how it aligns with the
vision and goals outlined in this UIPL to
support modular and evidence-driven
approaches to modernization and
corresponds to the categories checked
above. Include additional pages, as needed.
4. Does the State agree to disclose
☐ YES
confidential UC information to DOL-OIG
for the purposes of both audit and fraud
investigations throughout the period of
☐ NO
performance?
5. Does the State agree to submit a Full ☐ YES
Project Plan as described in Attachment IX
to this UIPL within 90 calendar days after
receiving the Notice of Award (NOA)? ☐ NO
6. Does the state commit to identifying at ☐ YES
least one measurable outcome as described
in Attachment VI to this UIPL and
reporting on this regularly through the
form ETA 9178-ARPA process? ☐ NO
7. Does the state commit to making
software or artifacts produced through this ☐ YES
grant available under an open license,
where required, and participating in a
community of practice, as described in
Section 4.d.iv.A.4. of this UIPL, where the ☐ NO
requirement is not applicable?
If there is a department other than your UI agency that must approve major state IT projects, please indicate if
they have been consulted. If not, please certify that the decision-maker within your agency or department has
been consulted.
Attachment IX to UIPL No. 11-23
IT Modernization Grants – Full Project Plan Template
Instructions: States must complete the application using the suggested format and instructions
below for the projects/activities for which the state is seeking funding. This application is to be
combined with a completed SF-424, a SF-424A, and Budget Narrative covering all
projects/activities (see Section 4.d.iv.C. of this UIPL).
Grant Funding for Unemployment Insurance (UI) IT Modernization
State Name:
Total Funds Requested:
Name, Title, and Address of Grant Notification Contact (Typically the State Workforce
Agency Administrator)
Name:
Title:
Address:
Name, E-Mail Address, and Phone Number of Grant Project or Fiscal Manager
Name:
E-Mail Address:
Telephone Number:
Applicable UI IT Modernization Categories for this Grant (check all that apply)
Cloud Migration ☐
Modular and API-driven approaches ☐
Measurably Improving Customer Experience ☐
Provide the following information for each project (add additional rows as needed)
Corresponding UI
Individual Activity Total Cost of Proposed
IT Modernization
Name Activity Completion Date
Category
State Contact
Name:
E-Mail Address:
Telephone Number:
Description of Current State IT Modernization Efforts
Summary of Planned IT Modernization Activities
Description of Activity
Provide the following information for each Activity (add additional pages as needed).
Individual Activity Name
Corresponding UI IT Modernization
Category
Key Milestones and approximate dates for
reaching milestones
Action Needed to Accomplish the Key
Milestones
Risk Mitigation
Outcome Metrics
Method for Sharing Lessons Learned
Requested Assistance from the Department
Description of Costs:
State Agency Staff Costs:
Type of Position Total Hours Cost Per Hour Total
Contract Staff Costs:
Type of Position Total Hours Cost Per Hour Total
Hardware, Software and Telecommunications Equipment:
Item Description Cost Per Item Quantity Total
Other Costs:
Item Cost Explanation
Instructions:
Applicable UI IT Modernization Categories for this Grant: Check the applicable categories
as described in Section 4.d. of this UIPL.
Individual Activity Name: Provide the name of the proposed IT modernization project/activity
to be carried out and its corresponding UI IT Modernization Category. If the state is submitting
requests to fund more than one project/activity, each project/activity should be identified by a
different name that describes each project/activity. The state must provide detail for each
project/activity they are seeking to have funded by the grant (the applications should match the
projects in the Project Abstract).
State Contact: Provide a name, telephone number, and e-mail address of the individual who
can answer any questions relating to the proposal.
Description of Current State IT Modernization Efforts: Include, if applicable, modernization
efforts your state agency has engaged in previously or is currently engaged in, as well as key
dates for any active modernization efforts and what vendor you use (if applicable). Also, if
applicable, mention any Tiger Team recommendations that are being implemented in relation to
IT.
Summary of Planned IT Modernization Activities: Provide a high-level description of the
work you plan to accomplish with the funds, including your goals, the problem(s) you will solve,
and if applicable, how it will expand on any current or planned modernization. Describe any
possible synergies between this project, and other American Rescue Plan Act (ARPA) funded
activities related to fraud prevention, equitable access to benefits, and timeliness/backlog
reduction.
Description of Activity: Provide a brief description of the IT Modernization project/activity
under this grant opportunity and explain how the project/activity will support the modernization
of unemployment compensation (UC) programs for the participating state. This section must be
completed for each Individual Activity identified on the first page of the template.
Key Milestones (for each Activity): Provide a list of the dates and the milestones for each
project/activity. The timeline should include the completion of the work, the designation of
specific tasks to appropriate parties, the issuance of a request for proposal (if appropriate), the
projected start date, the proposed dates to begin and complete testing (if necessary), and the
proposed date for full implementation of the project/activity. These milestones and dates will be
used to monitor the implementation of the project/activity. Any additional work needed to
identify and provide progress on the identified outcome metric should be included in this
project/activity timeline.
Action Needed to Accomplish the Key Milestones (for each Activity): Information in this
section should, at a minimum, answer the following questions.
• Describe what needs to happen in terms of agency adoption or customer adoption to
ensure your project is successful.
• Describe the team members who are already staffed and the team members you will need
to hire.
• Explain any vendors, software, and/or other solutions you plan to use, including
necessary procurement activities (as applicable).
Risk Mitigation (for each Activity): Information in this section should, at a minimum, answer
the following questions.
• Describe any identified or predicted risks for this activity.
• Any technical dependencies.
• How do you plan to monitor these risks or dependencies?
• How will you plan to mitigate these risks or dependencies?
Outcome Metrics: Identify the qualitative and quantitative metrics you will use to track
progress and measure success. One of the conditions for this grant funding (as described in
Section 4.d.iv.A.3. of this UIPL) is to report regularly on these metrics through the state’s
submission of the form ETA 9178-ARPA. This must, at a minimum, include outcome metrics
that are consistent with the examples in Attachment VI to this UIPL. States are encouraged to
include metrics in addition to those identified in this UIPL.
Method for Sharing Lessons Learned: One of the conditions for this grant funding (as
described in Section 4.d.iv.A.4. of this UIPL) is to make software or artifacts produced through
this grant available under an open license, where required, and participate in a community of
practice where this requirement is not applicable. Describe how you intend to fulfill this grant
condition.
Requested Assistance from the Department: Describe what, if any, additional assistance you
request from the Department to support successful implementation of these activities. The
Department will support these requests to the extent that resources and funding allow.
Description of Costs: Provide an explanation of all costs included in the project/activity.
1. State Agency Staff Costs: Use the table format provided in this attachment to request
state staff to support project/activity implementation.
2. Contract Staff Costs: Use the table format provided in this attachment to request
contract staff to support project/activity implementation.
3. Hardware, Software, and Telecommunications Equipment: Provide an itemized list
of hardware, software, and telecommunications equipment including the cost per item
and the number of each item requested. A description of each item must provide any
information needed to identify the specific item and a description of the size and capacity
of each item if applicable.
4. Other Costs: Identify each item of cost not covered elsewhere and provide the expected
cost per item. The need for each item must be explained.
Attachment X to UIPL No. 11-23
Tiger Team Grants – Updated Funding Allocations by State
Updated Tiger Team Grand
State Size Classification
Funding Allotment
Alabama Medium $2,981,800
Alaska Small $1,491,750
Arizona Large $4,473,550
California Extra Large $5,965,300
Colorado Large $4,473,550
Connecticut Medium $2,981,800
Delaware Small $1,755,000
Georgia Large $4,473,550
Hawaii Small $1,491,750
Idaho Small $1,491,750
Illinois Large $4,473,550
Indiana Large $4,473,550
Iowa Medium $2,981,800
Kansas Medium $3,508,000
Kentucky Medium $2,981,800
Maine Small $1,491,750
Maryland Large $4,473,550
Michigan Large $4,473,550
Mississippi Medium $2,981,800
Missouri Large $4,473,550
Nebraska Small $1,491,750
Nevada Medium $2,981,800
New Hampshire Small $1,491,750
New Mexico Small $1,491,750
North Carolina Large $4,473,550
Ohio Large $4,473,550
Oklahoma Medium $2,981,800
Oregon Medium $2,981,800
Pennsylvania Large $4,473,550
Rhode Island Small $1,491,750
Virgin Islands Small $1,491,750
Virginia Large $4,473,550
Washington Large $4,473,550
West Virginia Small $1,491,750
Wisconsin Large $4,473,550
Wyoming Small $1,491,750
Attachment XI to UIPL No. 11-23
Instructions for Completing the SF-424 and SF-424A
Application for Federal Assistance (SF-424)
States must submit a separate SF-424 and SF-424A form for each grant opportunity
contained within this UIPL.
Use the current version of the form for submission. Expired forms will not be accepted. SF-424,
Expiration Date 11/30/2025, Office of Management and Budget (OMB) Control No. 4040-0004
(Grants.gov).
Section # 8, APPLICANT INFORMATION:
• Legal Name: The legal name must match the name submitted with the System for
Award Management (SAM). Please refer to instructions at https://sam.gov/SAM/.
• Employer/Tax Identification Number (EIN/TIN): Input your correct 9-digit EIN
and ensure that it is recorded within SAM.
• Unique Entity Identifier (UEI): On April 4, 2022, the DUNS Number was
replaced by the Unique Entity Identifier (UEI), or the Entity ID, a non-proprietary
identifier requested in and assigned by the SAM at SAM.gov. Before submitting,
a state must also ensure its registration with SAM.gov is current. (SAM replaced
the Central Contractor Registry.) States can find instructions for registering with
SAM at https://sam.gov/content/entity-registration. An awardee must maintain an
active SAM registration with current information at all times during which it has
an active Federal award or an application under consideration. To remain
registered in the SAM database after the initial registration, states must review
and update the registration at least every 12 months from the date of initial
registration. Failure to register with SAM and maintain an active account will
result in a rejection of your submission.
• Address: Input your complete address including Zipcode+4; Example: 20110-
0831. For lookup, use the link at
https://tools.usps.com/go/ZipLookupAction_input.
• Organizational Unit: Input appropriate Department Name and Division Name, if
applicable.
• Name and contact information of person to be contacted on matters involving this
application: Provide complete and accurate contact information including
telephone number and email address for the point of contact.
Section # 9, Type of Applicant 1: Select Applicant Type: Input “State Government”
Section # 10, Name of the Federal Agency: Input “Employment and Training
Administration”
Section # 11, Catalog of Federal Domestic Assistance Number: Input “17.225”;
CFDA Title: Input “Unemployment Insurance”
Section # 12, Funding Opportunity Number and Title: Input UIPL number and grant
name as the following:
“UIPL No. 11-23 Integrity Grant 2023”; or
“UIPL No. 11-23 UI IT Modernization Grant 2023”; or
“UIPL No. 11-23 Tiger Team Grant”.
Section # 13, Competition Identification Number: Leave Blank.
Section # 14, Areas Affected by Project: Input the place of performance for the project
implementation; Example “NY” for New York. This should be in the form of an attached
document or PDF or entered into the field manually; it cannot be blank.
Section # 15, Descriptive Title of Applicant’s Project:
• Input the same UIPL number and grant name provided in Section # 12.
• Input: “State acknowledges and agrees that, prior to accessing any funding under
this grant award and within the timeframe described in UIPL No. 11-23, State
must submit the required amendments to the award, including all the components
described as part of the Full Project Plan, cooperate in the resolution of any
issues, and obtain final approval of the modified grant provided by the Grant
Officer”.
• Additionally, input: “State acknowledges and agrees to provide all confidential
UC information to DOL-OIG for purposes of investigating fraud and performing
audits through weeks of unemployment ending on or before the end of the period
of performance”.
Section # 16, Congressional Districts of
a. Applicant: Input the Congressional District of your home office. For lookup, use
link at www.house.gov with Zip code + 4.
b. Program/Project: Input the Congressional District where the project work is
performed. If it is the same place as your home office, input the congressional
district for your home office. For lookup, use link at www.house.gov with
Zipcode+4.
Section # 17, Proposed Project Dates.
a. Start Date: Input a valid start date for the project (earliest start date will be April
1, 2023 for all three grant opportunities).
b. End Date: Input a valid end date for the project (Integrity Grant 2023 and Tiger
Team Grant will be December 31, 2025; IT Modernization Grant will be
September 30, 2028).
Section # 18, Estimated Funding ($): Input the applicable funding allotment as listed for
your application.
Section #s 19 – 20: Complete as per instructions for Form SF-424.
Section # 21, Authorized Representative: Please select the “I AGREE” check box and
provide complete information for your authorized signatory including contact
information such as telephone number and email address. If your Authorized
Representative has changed from your previous application submission for this program,
please include a letter from higher-level leadership authorizing the new signatory for the
application submission.
Remember to have the SF-424 signed and dated by the Authorized Representative.
Budget Information - Non-Construction Programs (SF-424A)
• Use the current version of the form for the submission. Expired forms will not be
accepted. SF 424A, Expiration Date 02/28/2025, OMB Control No. 4040-0006
https://apply07.grants.gov/apply/forms/sample/SF424A-V1.0.pdf.
• Section B – Budget Categories: Ensure that TOTALS in Section 6, Object Class
Categories matches the Estimated Funding requested in the SF-424.
• If indirect charges are specified in Section 6, Object Class Categories, then include
either:
a) The approved indirect cost rate with a copy of the Negotiated Indirect Cost
Rate Agreement (NICRA), a description of the base used to calculate indirect
costs along with the amount of the base, and the total indirect costs requested;
OR
b) For those applicant states that meet the requirements to use the 10 percent de
minimis rate as described in 2 C.F.R. 200.414(f), a description of the modified
total direct cost base (see 2 C.F.R. 200.1 for definition) used in the calculation
along with the amount of the base, and the total indirect costs requested based
on the 10 percent de minimis rate.
Attachment XII to UIPL No. 11-23
Instructions for Budget Information Narrative
The Budget Information Narrative must include the following information:
• Each line item on the SF‐424A must list a cost and be explained. Each line item on the
SF‐424A pertains to projected costs at the recipient level, except for the Contractual line
item. Contractual should include costs at the project operator level.
• The total for each line item on the Budget Information Narrative must match the total for
each line item on the SF‐424A.
• If a grant modification requests realignments within the budget, the narrative must
address the reason for the change in each affected line item.
1. Personnel – List all staff positions by title. State the annual salary of each person, the
percentage of each person’s time devoted to the project, the amount of each person’s salary
funded by the grant, and the total personnel cost for the period of performance.
2. Fringe Benefits – Provide the overall fringe benefit percentage which reflects the recipient’s
organizational fringe, and list the components included, such as health insurance, FICA,
retirement, etc. Provide the fringe benefit calculation for each staff position listed under the
Personnel line item.
3. Travel – Specify the type and purpose of the travel, the number of travelers, approximate
mileage, per diem rates, estimated number of trips, and other associated travel costs.
4. Equipment – Identify each item of equipment to be purchased. Equipment has an estimated
acquisition cost per unit of $5,000 or more, and a useful life of one year or more. List the
quantity and unit cost per item. Items with a unit cost of less than $5,000 are classified as
supplies.
5. Supplies – Supplies include all tangible personal property other than “equipment”. Identify
supply categories (e.g., office supplies, cell phones, personal tools for disaster clean‐up, etc.).
List the cost associated with each category.
6. Contractual –
• Identify each project operator and the funding allocation made to the organization.
• Provide total projected costs (NOT for each project operator but as a lump sum) for each
of the following categories: Administrative Costs, Career Services, Supportive Services,
Training (itemize work-based training and classroom training), and Other Costs
(itemized).
7. Construction – Construction costs are not allowable costs, so this line must be left as zero.
Minor alterations to adjust an existing space for grant activities (such as a classroom
alteration), which the Department does not consider construction may be allowable; such
minor alteration costs must be shown on other appropriate lines such as Contractual.
8. Other – List each item in sufficient detail for the Department to determine whether the costs
are reasonable or allowable. Costs included under Other should not fit into any other line-
item category.
9. Indirect Charges – If charging indirect costs to the grant, this line item must be populated.
Include the current approved Negotiated Indirect Cost Rate Agreement (NICRA), signed by
the Federal cognizant agency, as an attachment. Include either the approved indirect cost rate
with a copy of the NICRA, a description of the base used to calculate indirect costs along
with the amount of the base, and the total indirect costs requested; OR For those applicant
states that meet the requirements to use the 10 percent de minimis rate as described in 2 CFR
200.414(f), a description of the modified total direct cost base (see 2 CFR 200.1 for
definition) used in the calculation along with the amount of the base, and the total indirect
costs requested based on the 10 percent de minimis rate.
Attachment XIII to UIPL No. 11-23
Form ETA 9178-ARPA
U.S. Department of Labor (DOL) OMB No. N/A27
Employment and Training Administration Expiration Date: N/A
Form ETA 9178-ARPA
Quarterly Narrative Progress Report
American Rescue Plan Act (ARPA) Grants
General Information
Report Quarter Date of
State Name: Grant Number:
Ending: Submission:
Project Name: UIPL Number:
Project Contact Information
Name: Agency:
Title Address:
Phone: Ext: City:
E-Mail: State: Zip Code:
Project Report
A. Summary of Project
Please limit your response to 1000 characters or less.
States must use this section to provide a detailed executive summary of the project/activity/solution (project).
Each funded project will have its own separate quarterly progress report (ETA 9178-ARPA) through the quarter
the project ends. States must use this section to provide a short summary of the project’s purpose. This summary
should only change during the life of the grant if the state has received an approved modification. Modifications
only apply to grants that require a full application.
B. Timeline for Grant Activities and Milestones or Deliverables
Please limit your response to 1000 characters or less.
States must use this section to provide the timelines for and the progress in completing grant activities, key
milestones, and deliverables for this quarter. A timeline must still be developed for all project activities. The
timeline must provide a project flow that includes start and end dates, schedule of activities, and projected
outcomes. In order to reap the most benefit from the timeline, the timeline must be updated each quarter noting
the actual date of completion as each activity is accomplished. Items to incorporate in the timeline include: project
goals, milestones, special events, important deadlines and deliverables.
Refer to section 2116(a) of P.L. 116-136, the Coronavirus Aid, Relief, and Economic Security Act, March 27,
2020.
C. Project Implementation and Funding Status
Please limit your response to 1000 characters or less.
States must use this section to provide a description of the implementation of key activities and/or project status
for the current quarter. Place an ‘X’ in one of the four checkboxes provided below to provide an assessment of
implementation progress. The assessment must be supported by the status narrative noting if the project is on
schedule, behind schedule, ahead of schedule, or complete this quarter. Once the project is marked as complete
this quarter, the state is no longer required to submit an ETA 9178-ARPA report for the project. In addition,
please provide the funding status for this project for the end of the quarter, including the total project funding,
total obligated, funding balance, and time remaining to expend funds/expenditure target.
Behind Complete this
State Self- On Schedule Ahead of Schedule
Schedule Quarter
Assessment:
Total Project Funding Total Obligated Funding Balance Expenditure Target
D. Project Challenges, Risk Mitigation Efforts/Modification Requests, and Technical Assistance
Needs
Please limit your response to 1000 characters or less.
States must use this section to summarize any significant challenges to project implementation encountered during
the quarter, and describe any risk mitigation efforts or actions taken to address the identified challenges. In
addition, a status update must be provided on the resolution of challenges identified in previous quarters. This
section should also include any questions you have for DOL and note any identified needs for technical assistance
from DOL or others. The narrative must also indicate whether the grantee is requesting a modification to any
project strategies and how the modification request changes the original project proposal. If a modification has
been requested, the narrative must also indicate the status of the modification request. Modifications only apply to
grants that require a full application. If states have nothing to report, that should be specified.
E. Best Practices, Promising New Strategies and Success Stories
Please limit your response to 1000 characters or less.
States must use this section to describe promising approaches, innovative processes, or grant success stories.
States must also describe any lessons learned and how those lessons learned will be implemented. Throughout the
implementation of the project, states may discover new strategies that emerge as a result of data-driven continuous
improvement. As progress is made with a new and promising strategy, or as data is gathered to support it, states
must document the progress and data each quarter. If states have nothing to report, that must be specified.
F. Additional Outcome Information
Please limit your response to 1000 characters or less.
This section requires states to report grant-specific outcomes not captured in other sections of the quarterly
narrative progress report, including, but not limited to, outcomes measuring equitable service delivery, outcomes
measuring fraud detection and prevention, outcomes measuring backlog reduction, specific outcomes included in
the grant application.
Certification
Name of Grantee Certifying Official:
Phone:
E-Mail Address:
Instructions to Complete ETA 9178-ARPA
Contact Information:
This section is to provide the contact information (i.e., Name, Title, Address, etc.) for the state
official who is responsible for the day-to-day operation and implementation of the project. This
may be a different person that the certifying official.
Certification:
• Name of Certifying Official
Use this section to provide the name of the state official who is certifying submission of
the report to the U.S. Department of Labor (Department).
• Telephone Number
Provide the area code and telephone number ((###) ###-####) of the authorized state
official.
• Email Address
Provide the email address of the authorized state official.
General Instructions
States receiving ARPA Grant Funds are required to submit quarterly progress reports to the
Department’s Employment and Training Administration (ETA) in order to comply with the
reporting and record keeping requirements of these funds. Each state recipient of funds must
submit a narrative Quarterly Progress Report (QPR) containing updates on the progress and
implementation of the project(s) undertaken as a result of the funding.
Report Form and Instructions
The QPR provides narrative updates on the implementation of project(s) undertaken as a result of
the funding and the status of each project per quarter.
Due Dates
All quarterly reports are due to ETA no later than 45 days after the end of each reporting quarter.
The table below shows the expected due dates for each reporting quarter.
Reporting Quarters Due Dates
October 1st – December 31st February 14th
January 1st – March 31st May 15th
April 1st – June 30th August 14th
July 1ST – September 30th November 14th
Should the due date of the report fall on a Saturday, Sunday, or holiday, the report is due the
previous business day.
Submission Procedures
Information contained in the quarterly report (ETA 9178-ARPA) must be submitted by email
directly to the ETA Regional Office. An ETA Federal Project Officer will review and accept the
report within 30 days of receipt.
OMB Approval. Section 2116(a) of the CARES Act, 5 U.S.C. 9032(a), states that “Chapter
35 of Title 44, United States Code, (commonly referred to as the ‘Paperwork Reduction Act
of 1995’) shall not apply to the provisions of, and the amendments made by, this subtitle.”
As the OMB approval process is waived for these reporting instructions, these instructions
should be considered final.
Attachment XIV to UIPL No. 11-23
Important Resources, Strategies, Tools, and Services for States
As noted throughout this Unemployment Insurance Program Letter (UIPL), fraud prevention and
detection activities, as well as overpayment recovery activities, are strongest when states employ
a variety of tools, strategies, and resources. The Employment and Training Administration
(ETA) reminds states of the many other resources available to support states with identity (ID)
verification, fraud prevention and detection, and overpayments recovery.
ETA’s Regional Offices. ETA’s Regional Offices are available to provide states with ongoing
technical assistance regarding integrity strategies, tools, and services and to connect states with
such resources supported and funded by the Department. States are encouraged to work closely
with ETA’s Regional Offices to address root causes of fraud and improper payments and in
developing Integrity Action Plans (IAPs) and any needed corrective action plans.
Tiger Teams. The Department’s multidisciplinary technical assistance teams (known as Tiger
Teams) work with states to conduct consultative assessments to address state-specific, unique
challenges and/or collect best practices to prevent and detect fraud, promote equitable access,
reduce backlogs, and ensure timely payment of benefits. Tiger Teams work with states to
identify immediate needs and issues focused on near-term improvements in customer
experiences and improved operational processes, while also proposing grant funded
recommendations to address fraud and support more equitable access for legitimate individuals.
The Department engaged with 24 states for the Tiger Team initiative in Year 1 (July 2021 - June
2022) of the project and continues to finalize and deliver recommendations to states based on
Tiger Team consultative assessments. Trends from Tiger Team recommendations are available
at https://oui.doleta.gov/unemploy/pdf/TigerTeamCohortTrendsJanuary2023.pdf. See UIPL
Nos. 02-22 and UIPL 02-22 Change 2.
UI Integrity Center. Established and funded by the Department and operated by the National
Association of State Workforce Agencies (NASWA) Center for Employment Security Education
and Research (CESER), the Unemployment Insurance (UI) Integrity Center is designed to assist
states in their efforts to prevent, detect, and recover improper and fraudulent payments and
improve program integrity by developing and promoting innovative program strategies. The UI
Integrity Center supports the needs of states in adopting and implementing strategies to ensure
program integrity, to reduce the UI improper payment rate, and to address fraud in
unemployment compensation (UC) programs. The following resources and tools are available
through the UI Integrity Center at no costs to states.
• State Services – supports states in assessing business processes and provides
recommendations for adoption of effective strategies for combatting fraud, reducing a state’s
improper payment rate, enhancing overpayment recovery, and improving UI program
integrity (see https://www.naswa.org/integrity-center/state-services).
• UI Integrity Knowledge Exchange Library (Library) – provides an online, searchable,
knowledge-sharing platform with a repository containing thousands of UI technical resources
to strengthen UI program integrity (see https://library.naswa.org/). The Library also contains
the Behavioral Insights (BI) Toolkit – a collection of resources, articles, templates, and how-
to information developed to help state UI agencies apply the learnings of BI to address
program compliance challenges and improve UI program integrity (see Training and
Employment Notice (TEN) No. 15-21 and https://library.naswa.org/bitoolkit).
• UI National Integrity Academy (Academy) – provides no-cost interrelated certificates that
offer program integrity trainings for state staff via online, eLearning modules and Virtual
Instructor Led Training. The Academy’s Learning Management System provides states with
access to self-paced, on-demand training available at any time and a searchable online
catalog with over 120 lessons available for state UI staff in the areas of Program Leadership,
UI Operations Integrity, Fraud Investigations, Tax Integrity, Data Analysis, and Behavioral
Insights (see https://www.naswa.org/learning).
• Integrity Data Hub (IDH) – a secure, robust, centralized, multi-state data system that allows
participating states to cross-match, compare, and analyze state UC claims data against a
variety of datasets (see TEN No. 24-21 and https://www.naswa.org/integrity-center/integrity-
data-hub). Current IDH datasets and functionality includes:
o Suspicious Actor Repository (SAR) – allows states to match UI claims against other
states’ known suspicious claims data. This tool allows each state to benefit from the
investigative work of all states as claims data associated with known or probable UI fraud
is submitted and stored in the SAR for cross-matching purposes.
o Suspicious E-Mail Domains and Patterns – allows states to cross-match their claims
against a database of suspicious e-mail domains and detects suspicious email patterns,
that have been associated with fraudulent activity, and flags claims with these domains
and/or patterns for further investigation by the submitting state.
o Foreign Internet Protocol (IP) address detection – allows states to receive flags on UI
claims filed from IP addresses outside of the U.S.
o Multi-State Cross-Match (MSCM) – states can submit current UI claims for cross-
matching and receive notifications when potentially fraudulent claims are filed in
multiple states.
o Identity Verification (IDV) Solution – provides states with a centralized, front-end ID
verification tool by returning identity scoring information, including flagging of false and
synthetic identities, to help states prioritize investigations involving questionable
identities. The IDV solution includes a cross-match to the Social Security
Administration’s (SSA) Death Master File to identify claims filed using identities of
deceased individuals.
o Bank Account Verification (BAV) Service – allows states to proactively identify and
authenticate bank account information on the UI claim by validating the status of the
bank account (e.g., account is open or closed) and providing a level of assurance that the
individual identified as the claimant is the bank account owner and/or authorized user
prior to initiating the UI benefit payment.
o Fraud Alert System – allows states to share and receive fraud alerts with each other and
the Department of Labor’s Office of Inspector General (DOL-OIG), ensuring as
emerging fraud schemes are identified they are shared broadly within the UI community
and with federal law enforcement.
o Additionally, new IDH enhancements, such as IDH Results Prioritization and Results
Sorting, Filtering, and Outcomes, allow states to prioritize, analyze, and manage IDH
results quickly and easily, and help states identify why a claim warrants further
investigations.
Office of Unemployment Insurance Modernization (OUIM). OUIM, located within the
Department’s Office of the Secretary, is developing services to assist states with equitable
practices that reduce claimant errors which contribute to improper payments. These services
include plain language conversions, evaluation of customer experiences, and assistance with
design of digital experiences that minimize friction for users. States are encouraged to contact
their ETA Regional Office to inquire about technical assistance and participation in OUIM
modernization activities. States may also visit OUIM’s reference site where promising practices
and materials related to information technology (IT) modernization and updates from
Department-sponsored engagements are housed. The reference site is located at
https://www.dol.gov/agencies/eta/ui-modernization.
UI Information Technology Support Center (UI ITSC). ETA created UI ITSC in 1994 through
a cooperative agreement with the State of Maryland to develop products and services and to
support state UI agencies in the use of IT for efficient administration of the UI program. Since
2009, NASWA CESER has operated the UI ITSC. UI ITSC’s activities involve providing
information, technical assistance, products, and services to states in support of the modernization
of IT systems used to administer the UI program. For more information on UI ITSC visit
http://www.itsc.org/.
State Information Data Exchange System (SIDES). State implementation and employers’ use
of SIDES should be an integral part of a state’s IAP (see TEN No. 12-16 and information
available at https://www.naswa.org/uisides). States should view SIDES as a critical part of their
UI integrity efforts and are encouraged to connect to all available SIDES Exchanges (see UIPL
No. 09-23 for details on the SIDES Exchanges).
Prisoner Update Processing System (PUPS). To be eligible for UI benefits, an individual must
be able, available, and actively seeking work. Incarcerated individuals do not typically meet the
eligibility requirements to receive UI benefit payments. ETA worked in partnership with SSA to
establish a secure data exchange between ICON and the SSA’s PUPS to provide states with the
ability to cross-match UI claims data with incarceration records to assist states in making
accurate UI eligibility determinations (see UIPL No. 01-22). States are strongly encouraged to
cross-match all UC claims against incarceration datasets, including PUPS and/or other federal,
state, and local incarceration records.
DOL-OIG. ETA recommends states build a strong partnership with their DOL-OIG offices.
ETA encourages all states to collaborate with their ETA Regional Offices and DOL-OIG to share
fraud trends and analysis, discuss recommendations and effective strategies for responding to
emerging fraud schemes, receive updates on prosecution efforts, and facilitate sharing of UI
fraud and integrity-related challenges and best practices among states.
Attachment XV to UIPL No. 11-23
Glossary of Key Terms for IT Modernization
Note: This is not an exhaustive list; if you have questions about any of the terms used in this Unemployment
Insurance Program Letter (UIPL) please reach out to the appropriate Employment and Training Administration
(ETA) Regional Office.
An approach to software development that emphasizes collaboration, flexibility, and
Agile the ability to adapt to change and develop software incrementally, usually known as
sprints.
Application Programming Functionality that enables different software applications (or modules) to talk to each
Interface (API) other and exchange data.
A way of hosting and accessing an application over the internet, rather than on local
Cloud Technology
computers or servers, like mainframes.
Content Management Software that allows users to create, manage, and publish digital content, such as web
System (CMS) pages, without needing to know how to code or program.
Continuous Integration &
A set of practices that automate the testing, building, and deployment of software to
Continuous Deployment
make it easier and faster to release updates.
(CI/CD)
The time, effort, and resources required to make changes to a system, including
Cost of Change
procurement, development, testing, and deployment.
The overall, end to end experience a customer has when interacting with a product,
Customer Experience (CX)
service, or organization.
A set of agile practices that combine software development and IT operations to
DevOps
improve the speed and reliability of software delivery.
A process of making changes to a system gradually, one step at a time, rather than all
Incremental
at once.
Legacy Technology / Older technology or systems that are no longer widely used or supported but may still
Systems be in use by some organizations.
A continual process of addressing unmet needs through technology and process
Modernization
improvements
An approach that involves breaking down a system into smaller, independent parts,
Modular which can be developed and tested separately. This makes it easier to make changes
and updates without affecting the whole system.
A large, complex system, where all parts are tightly connected and changing one part
Monolith
can have unintended consequences for the rest of the system.
Software that is developed and distributed by a community of developers and made
Open-Source Software
available to use, modify, and distribute.
A design approach that focuses on the needs and preferences of users, with the goal of
User-centered
creating products and services that are easy to use and provide a good user experience.
Attachment XVI to UIPL No. 11-23
Summary of UIPL Contents
Title UIPL Description Amount to States Initial Application Full Project Plan
Section
Relationship Sec. 4.a. Policy guidance & N/A N/A N/A
Between Grants technical assistance
Start page 7
Strengthening Sec. 4.b. Policy guidance & N/A N/A N/A
Integrity in the technical assistance
UI System Start page 8
Integrity Grants Sec. 4.b.vi. Funding opportunity State allocation based on size Due by 11:59 pm Eastern Due within 60 days of NOA
Time on August 18, 2023
Start page Sec. 4.b.vi.A. (page 19) and Sec. 4.b.vi.C.3. (page 22)
19 Attachment I for state Sec. 4.b.vi.C.2. (page 21) and Attachment II
allocations
National ID Sec. 4.c. State participation Transaction costs covered by N/A N/A
Verification solicitation Department for up to 2 years.
Offering Start page See “State Request for Intent
23 States may use Integrity to Participate” under Sec.
Grants to fund integration 4.c.iv. (page 26)
costs.
Sec. 4.c. (page 23)
IT Modernization Sec. 4.d. Funding opportunity Up to $11.25M for each Due by 11:59 pm Eastern Due within 90 days of NOA
Grants selected state Time on August 18, 2023.
Start page Awarded to complete and Section 4.d.iv.C. (page 29)
26 Section 4.d.ii. (page 27) responsive applications in and Attachment IX
the order received while
funding remains available.
Section 4.d.iv.B. (page 29)
and Attachment VIII
Tiger Team Sec. 4.e. Technical assistance and State allocation based on size Due by 11:59 pm Eastern Due within 60 days of NOA
Grants funding opportunity Time on August 18, 2023 or state receiving
Start page Section 4.e.i. (page 31) and recommendation
31 Attachment X for state Section 4.e.ii.B. (page 33)
allocations Section 4.e.ii.C. (page 33)
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