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Fiscal year 2026 state unemployment insurance quality service plans

Summary ETA tells state unemployment agencies how to prepare their fiscal year 2026 State Quality Service Plans. It sets priorities for timely and accurate benefits, preventing improper payments and fraud, reemployment services and reliable reports. Regional offices set submission deadlines, and the letter asks states to keep plans private because they may reveal sensitive integrity controls. The full guidance includes performance measures and planning attachments.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 14-25
Date issued
July 24, 2025
Status
Active
The letter states that it rescinds nothing and expires December 30, 2026. It concerns FY 2026 state plans; ETA's later UIPL No. 14-26 gives FY 2027 planning guidance.
Status last verified October 24, 2026

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About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                Unemployment Insurance
               ADVISORY SYSTEM                           CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                       OUI/DPM
             Washington, D.C. 20210                      DATE
                                                         July 24, 2025


ADVISORY:       UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 14-25

TO:             STATE WORKFORCE AGENCIES

FROM:           LORI FRAZIER BEARDEN
                Acting Assistant Secretary

SUBJECT:        Additional Planning Guidance for the Fiscal Year (FY) 2026 Unemployment
                Insurance (UI) State Quality Service Plan (SQSP)


1. Purpose. To initiate the FY 2026 SQSP process and define additional requirements relevant
   to the FY.

2. Action Requested. The Employment and Training Administration (ETA) requests State
   Administrators to:

   •   Make this information available to appropriate staff;
   •   Prepare their state’s SQSP in accordance with planning and reporting instructions
       contained in Employment and Training (ET) Handbook No. 336, 18th Edition, Change 4
       (SQSP Handbook) and additional instructions in this Unemployment Insurance Program
       Letter (UIPL);
   •   Coordinate specifics, as appropriate, with the ETA Regional Office (RO) for electronic
       submission of the SQSP; and
   •   Submit the FY 2026 SQSP to the appropriate RO by the deadline set by the RO.

3. Summary and Background.

   a. Summary – The SQSP Handbook provides planning and reporting instructions for the
      SQSP process. This UIPL provides additional guidance relevant to the SQSP process for
      FY 2026, designates dates applicable to the FY, outlines national priorities and Federal
      program emphasis, and identifies special planning requirements for the FY.

   b. Background – The SQSP is the state’s UI performance management and service plan. It
      represents an approach to the UI performance management and planning process that
      allows for an exchange of information between Federal and state partners to enhance the
      UI program’s ability to reflect their joint commitment to performance excellence and
      customer-centered services. As part of UI Performs, the comprehensive performance
      management system for the UI program, the SQSP is the principal vehicle that state UI
      programs use to plan, record, and manage improvement efforts as they strive for

  RESCISSIONS                                             EXPIRATION DATE
  None                                                    December 30, 2026

       excellence in service. Title III of the Social Security Act (SSA) authorizes the Secretary
       of Labor (Secretary) to provide funds to states to administer the UI program and governs
       the expenditure of those funds. The SQSP is a part of the process by which states receive
       Federal UI administrative grants.

       The SQSP Handbook contains general instructions for the SQSP. It is designed as a
       permanent guide for the planning and budget process and provides states with planning
       guidelines and instructions for reporting UI financial and staff year information. The
       SQSP Handbook notes that ETA will issue a SQSP UIPL each year with additional
       planning guidance that supplements the SQSP Handbook and provides direction and
       instructions specific to the upcoming FY. The SQSP Handbook is approved under the
       Office of Management and Budget (OMB) No. 1205-0132. The current approval expires
       on June 30, 2027.

       Though this UIPL providing additional planning guidance is similar to the guidance
       issued in previous years, there are changes relevant to the FY 2026 SQSP; therefore,
       please review this guidance carefully.

       ***Note: Due to the sensitivity of information about integrity controls and certain other
       UI operational matters, states should not make their SQSP publicly available.
4. For FY 2026, ETA will continue to strive to make the SQSP process a meaningful
   management tool and a strategic road map to improve program administration, strengthen
   program integrity, and ensure quality service delivery. The SQSP process focuses on
   promoting state performance and integrity by aligning state UI administration and operations
   with national priorities, paying benefits accurately and timely, and connecting unemployment
   compensation (UC) claimants with needed reemployment services. This section highlights
   the major areas that states are to use in developing their FY 2026 SQSPs.

   a. FY 2026 National Priorities and Federal Program Emphasis

       National Priorities

       The Department of Labor’s (Department) Employment and Training Administration
       (ETA) urges each state to focus its SQSP narrative on building a strategic plan and vision
       for UI operational excellence in the state. Each year, ETA establishes national priorities
       for the UI program. The following national priorities are provided for FY 2026 to assist
       states in their development of the SQSP. States should also establish additional state-level
       priorities for their UI program.

       The Department suggests a state plan focusing on strategies to:

       1) Improve Program Performance and Operate the UI Program Effectively (see
          Attachment I);
       2) Proactively Identify and Prevent Improper Payments and Fraud (see Attachment II);
       3) Strengthening Reemployment Services (see Attachment III); and

        4) Ensure Accurate and Complete Submission of ETA UI Required Reports (see
           Attachment IV).

        ETA also recommends that states identify the potential barriers and threats to success in
        their strategic plans as well as technical assistance needs.

        Federal Program Emphasis

        In FY 2026, ETA will continue to work with states to rebuild performance with particular
        attention on the goals specified in the Government Performance and Results Act of 1993
        (GPRA)1 – targets that the UI system, as a whole, is expected to meet. Individual states
        should continue to strive to meet and exceed these GPRA goals and targets. States are to
        describe in the SQSP Narrative the steps they will take to achieve these goals and targets.

                           Goal                                                   Target
          Percent of Intrastate                87 percent of intrastate first payments for full weeks of UC
          Payments Made Timely                 will be made within 14/21 days from the week ending date of
          (Make Timely Benefit                 the first compensable week.
          Payments)
          Detection of Recoverable             Overpayments established at a rate that is at least 57.5
          Overpayments (Detect                 percent of the estimated detectable, recoverable
          Benefit Overpayments)                overpayments.
           Percent of Employer Tax              90 percent of status determinations for new employers will
           Liability Determinations             be made within 90 days of the end of the first quarter in
           Made Timely (Establish               which liability occurred.
           Tax Accounts Promptly)


    b. Program Performance

        The Department’s strategic approach to UI Performs is to focus efforts on improving
        performance and promoting overall excellence. States are expected to address
        performance that does not meet established performance levels for the SQSP
        measurement period.

        Corrective Action Plans (CAPs) are expected whenever a state’s performance is below
        established performance levels for the SQSP measurement period. The measurement
        period for the FY 2026 SQSP is April 1, 2024 – March 31, 2025, unless otherwise
        indicated (see Attachment V).

 GPRA was designed to improve program management throughout the Federal government. Under this Act, federal
agencies are required to develop a strategic plan outlining its mission, long-term goals for the agency's major
functions, performance measures, and reporting results.

c. UI Performance Criteria

   Attachment V lists the Core Measures, Secretary’s Standards, and UI Programs and the
   established performance levels where CAPs and/or Narratives may be expected if annual
   performance is below these established performance levels for the measurement period.

   i. Core Measures are critical indicators of the overall performance of the UI program.
      Performance below the accepted level of performance (ALP) for Core Measures is
      expected to be addressed in a CAP unless otherwise indicated.

      Additional instructions for Core Measures are as follows:

      •   The Detection of Overpayments Measure. This measure is the percentage of
          detectable/recoverable overpayments estimated by the Benefit Accuracy
          Measurement (BAM) survey that was established for recovery through regular UI
          Benefit Payment Control (BPC) program operations. For this Program Integrity
          Measure, the acceptable level of performance is a range of >50% and <95%. Any
          state reporting an overpayment detection rate below 50 percent is expected to
          address the deficiency in a CAP. In addition, because it is challenging for most
          states to cost-effectively detect and establish more than 90 percent of estimated
          overpayments, the upper limit of 95 percent was established. If an overpayment
          detection rate is above 95 percent and is found to be the result of improper
          administration of BAM or BPC activities or misreporting of data on the ETA 227
          (Overpayment Detection and Recovery Activities) report, the state is expected to
          submit a CAP (for BAM/Overpayment Detection or BPC/Overpayment Detection
          or address reporting 227 issues) to address the deficiency. (See UIPL No. 14-05,
          Change 1, Section 5.c.) The performance period for the BPC component is the
          three-year period ending March 31, 2025. The performance period for the BAM
          component is the three-year period ending September 30, 2024.

      •   Effective Audit Measure. The Effective Audit Measure, as noted in UIPL No.
          03-11, is a blended measure of the following four factors: 1) Percentage of
          Contributory Employers Audited Annually; 2) Percentage of Total Wages
          Changed as a Result of Audit; 3) Percentage of Total Wages Audited; and 4)
          Average Number of Misclassifications Detected Per Audit. Each of the four
          factors has a minimum standard score that states are expected to meet to pass the
          Effective Audit Measure as well as an overall combined score that is expected to
          be achieved. The measure also instructs each state to direct additional emphasis to
          the factor(s) that state personnel deem important. An additional two points must
          be earned among any of the four factors to attain the overall passing score of at
          least 7.0. A CAP is expected for states that do not meet the measure based on
          calendar year 2024 data.

      •   Improper Payments Measure. The Improper Payments Measure is defined as UC
          overpaid plus UC underpaid divided by the total amount of UC paid. It is based
          on estimates from the results of the BAM survey of paid UC claims in the State
          UI, Unemployment Compensation for Federal Employees, and Unemployment

    Compensation for Ex-Servicemembers programs. The Payment Integrity
    Information Act (PIIA) of 2019, codified in 31 U.S.C. 3351 et seq., requires
    agencies to examine the risk of erroneous payments in all programs and activities
    they administer. PIIA also requires Federal programs to report an annual improper
    payment rate and include all identified improper payments in the reported
    estimate, regardless of whether the improper payment in question has been or is
    being recovered (see UIPL No. 09-13 for ETA’s approved improper payment rate
    computation methodology). Corrective actions and Integrity Action Plan (IAP)
    root causes for FY 2026 are based on ETA’s approved computation methodology.
    PIIA, in 31 U.S.C. 3351(4), defines the term “improper payment” as:

         (A) …any payment that should not have been made or that was made in an
             incorrect amount, including an overpayment or underpayment, under a
             statutory, contractual, administrative, or other legally applicable
             requirement; and

         (B) includes—(i) any payment to an ineligible recipient; (ii) any payment
             for an ineligible good or service; (iii) any duplicate payment; (iv) any
             payment for a good or service not received, except for those payments
             where authorized by law; and (v) any payment that does not account
             for credit for applicable discounts.

    In accordance with the PIIA, under the compliance requirements in 31 U.S.C.
    3351(2), an ALP of less than 10 percent has been established for the Improper
    Payments Measure. States are expected to maintain an improper payment rate of
    less than 10 percent for covered UI programs. This ALP is applicable to the 2024
    PIIA performance period (July 1, 2023, to June 30, 2024). A state failing to meet
    the ALP for the 2024 PIIA performance period will be expected to develop a CAP
    as part of the FY 2026 SQSP.

•   UI Overpayment Recovery Measure. As explained in UIPL No. 09-13, the
    recovery rate is “the amount of improper overpayments recovered divided by the
    amount of improper overpayments identified.” The ALP for the recovery rate
    measure is 68 percent for the 2024 PIIA performance period. The Department will
    compute future recovery targets based on the most recent recovery and other
    performance data available.

    The performance period will be based on data from the ETA 227 report,
    Overpayment Detection and Recovery Activity (Regular), and ETA 227 report,
    Overpayment Detection and Recovery Activity (Emergency Unemployment
    Compensation) (EUC), for the PIIA 2024 performance period (July 1, 2023, to
    June 30, 2024). Pursuant to the UI Reports Handbook (ET Handbook No. 401, 5th
    edition), the June quarter ETA 227 reports are due August 1 each year. A state
    failing to meet the ALP for the 2024 PIIA performance period will be expected to
    develop a CAP as part of the FY 2026 SQSP.

ii.    Secretary’s Standards are established in regulations at 20 CFR Parts 640 and 650.
       Like Core Measures, Secretary’s Standards are indicators of state performance of
       significant UI activities and procedures. A state experiencing performance below the
       criteria for the Secretary’s Standards is required to address the performance issues in
       a CAP.

iii.   UI Programs

       States must address the following UI Programs as described below:

       •   State Directory of New Hires (SDNH)/National Directory of New Hires
           (NDNH)

           State BAM operations that, based on the BAM Administrative Determination, are
           not compliant with the NDNH matching requirements in ET Handbook No. 395,
           5th Edition, Chapter VI, UIPL No. 03-07, and UIPL No. 03-07, Change 1, must
           address the deficiency in a CAP for FY 2026.

       •   Benefit Accuracy Measurement (BAM)

           State BAM operations or operational components that are not compliant with
           investigative and/or methods and procedures requirements established in ET
           Handbook No. 395, 5th Edition, and through findings established through ET
           Handbook No. 396, 4th Edition monitoring reviews (based on the annual
           determination letter issued on or before May 1, 2025), must address this non-
           compliance in a CAP. This includes paid and denied claim population variances
           outside established control limits.

       •   Tax Performance System (TPS)

           To ensure that UI tax operations are in compliance with Federal reporting and
           oversight requirements, a state’s failure to conduct one or more TPS sample
           reviews will be subject to a CAP. Additionally, a tax function that is not sampled
           will be included in the number of total failing functions as measured by Tax
           Quality Part A (no more than three tax functions may fail TPS review) and Part B
           (a tax function cannot fail for three consecutive years). Exceptions include
           universes that are too small to support a sample (“S”), an Experience Rate sample
           that was not scheduled for review during the performance year (“E”), or the
           granting of a temporary waiver (“W”) by the Regional Office (RO). States should
           note exceptions, if any, on their Program Review Findings screens in the
           Unemployment Insurance Reporting System, accordingly.

       •   Data Validation (DV)

           The deadline for submitting DV results for Validation Year (VY) 2025 was June
           10, 2025. The VY coincides with the SQSP performance year. It covers data of
           any reporting period during the twelve months, beginning April 1st and ending

          the following March 31st. DV items that fail to pass validation, or were due but
          not submitted, are expected to be addressed in the state’s FY 2026 SQSP. Non-
          submitted items also include failure to certify that the state specific instructions in
          the Module 3 for Benefits and Tax are current and accurate during the April 1 –
          June 10, 2025, certification window.

          Any DV items due for Validation Year 2025 that did not pass or were not
          submitted by the deadline (June 10, 2025) are expected to be addressed in a CAP
          for FY 2026.

          ROs will monitor states every three years on cycles coinciding with the Data
          Validation Years. ROs will assess the accuracy of the states’ DV results
          considered passing at the time of the monitoring review to verify that the states
          are properly implementing the DV program according to the program handbooks.
          DV items submitted as passing, but which a monitoring review determined to
          have failed are also expected to be addressed in the SQSP. All subsequent SQSP
          cycles will address items changed from pass to fail in the previous year’s
          monitoring review.

iv.   Other UI Performance

      States are expected to address the following performance deficiencies in the SQSP
      State Plan Narrative, unless otherwise indicated.

      •   Failure to meet reporting requirements for federally required reports.

      •   Invalid recording of the Issue Detection Date (IDD) and Determination Date
          (DD). The validity of the UI Performs nonmonetary determination timeliness
          measure depends on the accuracy of the state’s IDD and DD data. IDD and DD
          data are considered accurate if dates were correct in at least 95 percent of the
          nonmonetary determinations evaluated in the quarterly quality samples (obtained
          from the ETA 9056 report for the measurement period (see Attachment I)). Since
          the accuracy of IDD and DD data is based on sample results, sampling variation
          will be taken into account in setting the percentage below which a state’s data will
          be considered inaccurate. States with invalid IDD or DD data are expected to
          address the steps they will take to record the IDD and DD correctly in the SQSP
          Narrative.

v.    Future Performance Requirements

      UIPL No. 07-21, published in FY 2021, announced, for states with Reemployment
      Services and Eligibility Assessment (RESEA) programs, a new reemployment core
      measure: Reemployment Rate in the 2nd Quarter after Program Exit for RESEA
      Participants. This core measure is designed to focus on RESEA program
      performance, given that the RESEA program is now permanently authorized within
      the context of the broader workforce development system. This measure aligns with
      the Working for a Stronger America Act’s primary indicators of performance and will

      utilize data that states already report for Employment Service programs. This will
      enable ETA to assess state performance related to the employment outcomes of
      RESEA participants.

      Performance data will be used to review performance trends and to establish baseline
      state RESEA performance. States that do not meet performance criteria for both of
      these periods will be expected to submit CAPs for the FY 2026 SQSPs.

      UIPL No. 07-21 also announced two new program performance measures that are
      meant to assist states in managing reemployment performance, but these measures are
      not core measures and do not have associated ALPs.

d. UI Program Integrity and the Integrity Action Plan (IAP)

   The purpose of the IAP is for the state to provide a comprehensive and detailed plan
   outlining the agency's UI integrity and anti-fraud strategies. States will use the IAP
   template (Word document) to develop their FY 2026 IAPs. The template provides states
   with a format that is conducive for developing a comprehensive, detailed, and actionable
   IAP, and offers flexibility to clearly articulate state integrity plans and anti-fraud
   strategies. States are expected to report their planned actions and activities to prevent,
   detect, reduce, and recover fraudulent and other UI improper payments in their IAPs,
   which are submitted each year as part of the annual SQSP submission.

   A critical part of fraud risk management includes evaluating outcomes using a risk-based
   approach and adapting activities to improve fraud risk management strategies. To
   effectively manage fraud risks, each state should develop and document an anti-fraud
   strategy that describes the state’s approach for addressing fraud risks.

   For FY 2026, ETA is highlighting the following specific topics that states must
   incorporate into the SQSP IAPs as part of the FY 2026 SQSP submission. States should
   use the IAP template as a guide to develop their IAPs and ensure all key IAP topics
   (outlined below) are addressed.

   • (Topic #1:) – Ensuring UI program integrity by assessing and evaluating fraud risks,
     and implementing and maintaining an array of sufficient controls to effectively
     mitigate the likelihood and impact of fraud, and reducing improper payments:

      o    State actions to evaluate UI fraud risks and implement and maintain sufficient
           controls to effectively prevent fraud and reduce improper payments, including
           state progress in developing the state’s own state-specific anti-fraud strategy.

      o    State use of tools, services, strategies, process improvements, and/or procedural
           changes adopted by the state to combat fraud, verify identities, and enhance
           recovery efforts. States must identify which tools, solutions, and service
           provider(s) are used in the state’s fraud management operations including, but
           not limited to, the following areas: data analysis, risk-based identity (ID)
           verification, fraud prevention and detection, and cybersecurity.

    o   State use of UI Integrity Center resources, with a particular focus on state
        connection to the Integrity Data Hub (IDH) and use of its datasets to cross-match
        UC claims and aid in the prevention and detection of fraud and improper
        payments (see Training and Employment Notice (TEN) No. 24-21).

    o   State use of required and recommended integrity controls and overpayment
        recovery activities as outlined in sections 4.b.ii and 4.b.iii. of UIPL No. 11-23,
        including any additional effective cross-matching and overpayment recovery
        activities and identified best practices.

    o   State use and employer participation in the State Information Data Exchange
        System (SIDES) (see Section 5 of TEN No. 12-16).

•   (Topic #2) – State plans and actions to address the state's top three improper payment
    root causes in the PIIA 2024 performance period.

•   (Topic #3) – State coordination and collaboration with Department’s Office of
    Inspecter General (DOL-OIG) and other state and Federal law enforcement agencies
    to investigate and prosecute UI fraud and recover overpayments. The response should
    also include information on the state’s plans to continue providing all confidential UC
    information to DOL-OIG for purposes of both investigating fraud and performing
    audits.

•   (Topic #4) – State plans to strengthen program integrity in UI tax operations,
    including current activities and plans to identify and prevent worker misclassification,
    State Unemployment Tax Act (SUTA) Dumping, fictitious employer schemes, and
    development/use of effective employer audit strategies (i.e., use of remote audits).

•   (Topic #5) – State plans and actions to strengthen internal security and ensure that all
    appropriate internal controls and processes are in place and are adequate to assess
    internal risks and threats, ensure program integrity, and minimize program
    vulnerabilities (see UIPL No. 14-17).

•   (Topic #6) – State plans and actions to evaluate the effectiveness of fraud prevention
    and detection, ID verification, and improper payment reduction activities. The state
    should include strategies to ensure that processes used to detect and prevent fraud are
    effective, and do not limit the ability for a legitimate claimant to apply for and, if
    eligible, receive UC. States implementing or using facial recognition technology in
    their ID proofing processes must also report findings from bias testing and provide
    updates on efforts to mitigate biases or barriers in this section of the IAP.

•   (Topic #7) – State plans and actions to mitigate negative consequences for victims of
    UI ID fraud, including ensuring simplified processes to remove the victim’s liability
    for overpayments resulting from ID fraud.

    •   (Topic #8) – If the state has not provided complete and accurate overpayment
        reporting on the ETA 227 series of reports (Overpayment Detection and Recovery
        Activities), and the ETA 902P report (Pandemic Unemployment Assistance
        Activities), the state must provide information on plans for improvement, including
        timeframes and milestones, for addressing the issue and ensuring complete, accurate,
        and timely reporting in FY 2026.

    States are required to provide a six-month update to the IAP, covering the first two
    quarters of the FY (October – March) when submitting the SQSP quarterly update for the
    quarter ending March 31. The purpose of the six-month update is for a state to provide a
    progress report on the integrity and anti-fraud strategies outlined in the IAP. The update
    must include details on any new strategies, solutions, and/or activities; changes to
    existing strategies; planning or strategy delays and/or challenges in implementing the
    IAP; positive outcomes (e.g., progress toward the achievement of objectives); and
    identified successes.

    ETA will continue to provide technical assistance to states to support their integrity
    activities through guidance, webinars, individual state technical assistance, and in
    partnership with the many available resources to support states with strengthening UI
    program integrity (see Section 4.H. of this UIPL for UI Technical Assistance Resources).

e. Planning Requirements for FY 2026

  i.    SQSP Submittal Cycle

        The SQSP process provides a 24-month window for states to adequately plan and
        implement performance improvement efforts. The process provides for two types of
        submittals: a Formal two-year (Biennial) plan, and an Alternate Year plan.
        Descriptions of the Biennial and Alternate Year SQSP submittals, significant
        activities, and dates relating to the submittal and approval of the SQSP are outlined in
        the SQSP Handbook and this UIPL. For FY 2026, all states will submit an Alternate
        year SQSP.

 ii.    SQSP Preparation

        States must use the Excel CAP Workbook to develop their CAPs for the SQSP
        submissions. States must also use the Excel CAP Workbook for reporting updates to
        specific CAP milestones and CAP performance each quarter. States must also use the
        IAP template to develop the IAP and provide IAP updates. The ROs will provide
        states with the Excel Workbook and IAP template with specific instructions relevant
        to this Alternate year SQSP submittal.

 iii.   SQSP Assurances and Approval

        By signing the SQSP Signature Page, a state certifies that it will comply with the
        assurances listed in ET Handbook No. 336, 18th Edition, Change 4, and will institute
        plans or measures to comply with the requirements for each of the assurances. States

       must also comply with the Assurance of Disaster Unemployment Assistance as
       described below:

       Assurance of Disaster Unemployment Assistance (DUA)

       Each state must ensure that it will conduct annual training for DUA staff and develop
       and maintain a Standard Operating Procedures manual for DUA. States are
       encouraged to use the DUA training modules available on the National Association of
       State Workforce Agencies (NASWA) learning platform at
       https://www.naswa.org/learning.

       Each state must:

       •   Indicate that it has conducted training and provide the date(s) of the training; and

       •   Indicate that it has developed and/or maintained DUA Standard Operating
           Procedures for use during a major disaster declaration.

       States may contact the RO for a copy of a DUA Standard Operating Procedure
       Template. ROs will also obtain an initial copy from each state for the Department’s
       record. See TEN No. 13-21 for additional information.

f. Coordination with DOL-OIG. States are reminded of their obligation to report alleged
   or suspected UI fraud to the DOL-OIG as outlined 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. States are also required to disclose
   confidential UC information related to the CARES Act, as amended, to the DOL-OIG for
   the purpose of UC fraud investigations and audits for the entire pandemic relief period
   (see UIPL No. 04-17, Change 1). Additionally, TEN No. 05-22 reminded states of the
   DOL-OIG’s authority under the Inspector General Act and strongly encouraged states to
   comply with data requests made by DOL-OIG. States are also strongly encouraged to
   report suspected UI fraud to the IDH by creating fraud alerts and submitting all
   suspicious claims data for cross-matching. Providing suspicious claims data to the IDH
   gives each state the ability to analyze state claims data against known suspicious activity
   in other states, which offers a mechanism to quickly identify potential fraud across the UI
   system. States needing assistance with the IDH, or to learn more about how the IDH can
   help states’ fraud prevention and detection efforts, can reach out to the IDH Team at
   [email protected] for more information.

g. WIOA Combined State Plans. WIOA provides the option for states to submit a
   Combined State Plan that includes program plans for mandatory one-stop partners and
   other programs. Given that the UI program is a mandatory one-stop partner under WIOA,
   states have the option of including the UI program as part of the Combined State Plan.
   However, each state must participate in the UI Performs SQSP process whether or not the
   state decides to include the UI program as part of its Combined State Plan.

   If a state chooses to submit a WIOA Combined State Plan with UI as a required partner,
   the state must incorporate SQSP into the Combined State Plan via the WIOA State Plan
   Portal at https://wioaplans.ed.gov/. Those states must incorporate only the allowable
   documents for FY 2026 into the Combined State Plan upon ETA’s approval of the SQSP,
   but no later than October 31, 2025.

   Because of the sensitive nature of some SQSP documents, only the following SQSP
   documents are allowed to be included in the WIOA Combined State Plan:

   •   Transmittal Letter
   •   A list of CAPs (the Alternate year SQSP Overview Page from the SQSP CAPs and
       Quarterly Reporting Workbook)
   •   Budget Worksheets/Forms
   •   Organization Chart
   •   SQSP Signature Page

h. UI Technical Assistance Resources. The following resources provide states with
   information and support for UI program activities.

   •   ETA’s Regional Offices. ETA’s ROs are available to provide states with ongoing
       technical assistance regarding UI program administration and operations, integrity
       strategies, and to connect states with resources supported and funded by the
       Department. States are encouraged to work closely with ROs in developing the SQSP
       and IAP, and any needed CAPS.

   •   Office of Unemployment Insurance website. https://www.dol.gov/agencies/eta/ui-
       modernization.

   •   UI Integrity Center. In FY 2012, ETA created the UI Integrity Center of Excellence
       (UI Integrity Center) to support the needs of the 53 SWAs in implementing strategies
       to ensure program integrity by preventing, detecting, and recovering improper
       payments, and reducing fraud in the UI programs. The NASWA Center for
       Employment Security Education and Research, Inc. (CESER) operates the UI
       Integrity Center through a cooperative agreement with ETA.

   •   DOL-OIG. ETA recommends states build a strong partnership with DOL-OIG.
       States are encouraged to collaborate with their respective ROs 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.

   •   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. The 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.

       •   Online Training Resources. ETA has a cooperative agreement with the State of
           Utah to invest in the development of online training modules for state UI staff. These
           resources are located at https://www.naswa.org/learning.

   i. Funding Period. The Department’s proposed FY 2026 appropriation language for State
      UI and Employment Service Operations allows for obligation of UI allocations by states
      through December 31, 2026, with 90 additional days to liquidate the obligations and
      complete the expenditure of funds. In addition, this proposed language (which mirrors the
      language of recent-year appropriation acts) allows states to obligate FY 2026 UI funds
      through September 30, 2028, if such obligations are for automation, competitive grants
      awarded to states for improved operations, or for conducting in-person reemployment and
      eligibility assessments and improper payment reviews, and providing reemployment
      services and referrals to training, as appropriate. The grant management resources and
      information, including grant terms and conditions, are available at
      https://www.dol.gov/agencies/eta/grants/resources. Please note that FY 2026 grant terms
      and conditions are not available at this time. This information will be provided through
      ROs at a later date and also posted at the webpage indicated above.

   j. Data Availability. ROs will provide states with data showing their performance
      measured against the Core Measures, Secretary’s Standards, and other information
      relevant to the SQSP (e.g., reporting deficiencies).

   k. SQSP Submittal Deadlines. Each RO will set a date and inform states of the deadline to
      submit their SQSPs for FY 2026.

   l. Electronic Submission of the SQSP. States must submit the SQSPs electronically and
      should contact their respective RO SQSP Coordinators before submittal to coordinate
      specific details. Standard forms required as part of the budget reporting process (Chapter II
      of ET Handbook No. 336, 18th Edition, Change 4) are available in PDF and may be
      downloaded from the OMB website at: grants.gov/forms/forms-repository/sf-424-family.

       States may submit the SQSP Signature Page electronically if the state law permits. States
       that do not submit the signature page electronically (which includes by fax or scan) must
       submit the signature page by mail by the deadline set by the RO.

5. Inquiries. Please direct inquiries to the appropriate ETA RO.

6. References.
   • Social Security Act (SSA), sections 303(a)(1) and 306 (42 U.S.C. 503(a)(1) and 506);
   • Government Performance and Results Act (GPRA) of 1993, Pub. L. 103-62, as amended
      by GPRA Modernization Act of 2010, Pub. L. 111-352;

•   Payment Integrity Information Act of 2019 (PIIA), Pub. L. 116-117
    https://www.congress.gov/116/plaws/publ117/PLAW-116publ117.pdf;
•   Workforce Innovation and Opportunity Act (WIOA), Pub. L. 113-128, 29 USC 3101 note
    and Title I;
•   Wagner-Peyser Act, 29 U.S.C. Sec. 49 et seq., as amended by Title III of WIOA;
•   Trade Act of 1974, Pub. L. 93-618, as amended;
•   Bipartisan Budget Act of 2013, Pub. L. 113-67;
•   Bipartisan Budget Act of 2018, Pub. L. 115-123;
•   20 CFR Parts 601, 640, 650, 652, and 660;
•   2 CFR Part 200, Subpart F, The Uniform Administrative Requirements, Cost Principles,
    and Audit Requirements for Federal Awards at 2 CFR Parts 200 and 2900;
•   Appendix C to Office of Management and Budget (OMB) Circular A123, Requirements
    for Payment Integrity Improvement;
•   UIPL No. 12-25, Fiscal Year (FY) 2025 Funding Allotments and Operating Guidance for
    Unemployment Insurance (UI) Reemployment Services and Eligibility Assessments
    (RESEA) Grants, issued June 10, 2025, UNEMPLOYMENT INSURANCE PROGRAM
    LETTER No. 12-25 | U.S. Department of Labor;
•   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,
    UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 01-22 | U.S. Department
    of Labor;
•   UIPL No. 07-21, Performance Measures for Reemployment Services and Eligibility
    Assessments (RESEA) and Unemployment Insurance (UI) participants, issued December
    17, 2020, UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 07-21 | U.S.
    Department of Labor;
•   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, UNEMPLOYMENT
    INSURANCE PROGRAM LETTER No. 13-19 | U.S. Department of Labor;
•   UIPL No. 14-17, States' Responsibilities for Internal Security in the Unemployment
    Insurance Program, issued March 23, 2017, UNEMPLOYMENT INSURANCE
    PROGRAM LETTER No. 14-17 | U.S. Department of Labor;
•   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, UNEMPLOYMENT INSURANCE PROGRAM
    LETTER No. 04-17, Change 1 | U.S. Department of Labor;
•   UIPL No. 17-16, Reengineering Unemployment Insurance (UI) Benefits Program
    Accountability Process: High Priority Designation of States with Sustained Poor
    Performance, issued July 13, 2016, UNEMPLOYMENT INSURANCE PROGRAM
    LETTER No. 17-16 | U.S. Department of Labor;

•   UIPL No. 02-16, Change 1, State Responsibilities for Ensuring Access to Unemployment
    Insurance Benefits, Services, and Information, issued May 11, 2020,
    UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 02-16, Change 1 | U.S.
    Department of Labor;
•   UIPL No. 02-16, State Responsibilities for Ensuring Access to Unemployment Insurance
    Benefits, issued October 1, 2015, UNEMPLOYMENT INSURANCE PROGRAM
    LETTER No. 02-16 | U.S. Department of Labor;
•   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, UNEMPLOYMENT INSURANCE
    PROGRAM LETTER No. 01-16, Change 1 | U.S. Department of Labor;
•   UIPL No. 01-16, Federal Requirements to Protect Individual Rights in State
    Unemployment Compensation Overpayment Prevention and Recovery Procedures, issued
    October 1, 2015, UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 01-16 |
    U.S. Department of Labor;
•   UIPL No. 17-14, Revised Employment and Training (ET) Handbook No. 336, 18th
    Edition: “Unemployment Insurance (UI) State Quality Service Plan (SQSP) Planning
    and Reporting Guidelines”, issued July 7, 2014, UNEMPLOYMENT INSURANCE
    PROGRAM LETTER No. 17-14 | U.S. Department of Labor;
•   UIPL No, 09-13, Change 1, Integrity Performance Measure for Unemployment
    Insurance, issued January 27, 2015, UNEMPLOYMENT INSURANCE PROGRAM
    LETTER No. 09-13, Change 1 | U.S. Department of Labor;
•   UIPL No. 09-13, Integrity Performance Measures for Unemployment Insurance (UI),
    issued January 29, 2013, UNEMPLOYMENT INSURANCE PROGRAM LETTER No.
    09-13 | U.S. Department of Labor;
•   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, UNEMPLOYMENT
    INSURANCE PROGRAM LETTER No. 05-13 | U.S. Department of Labor;
•   UIPL No. 03-11, Implementation of the Effective Audit Measure, issued December 30,
    2010, UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 03-11 | U.S.
    Department of Labor;
•   UIPL No. 03-07, Change 1, Use of National Directory of New Hires (NDNH) in
    Unemployment Insurance (UI) Benefit Accuracy Measurement (BAM) Audits, issued
    February 27, 2008, UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 03-07,
    Change 1 | U.S. Department of Labor;
•   UIPL No. 03-07, Use of National Directory of New Hires (NDNH) in Unemployment
    Insurance (UI) Benefit Accuracy Measurement (BAM) Audits, issued October 31, 2006,
    UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 03-07 | U.S. Department
    of Labor;
•   UIPL No. 14-05, Change 3, Acceptable Levels of Performance (ALP) Criteria for
    Appeals Case Aging Measures and Nonmonetary Determination Quality Review, issued
    April 16, 2008, UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 14-05,
    Change 3 | U.S. Department of Labor;

•   UIPL No. 14-05, Change 2, Performance Criteria for Appeals Case Aging Measures and
    the Starting Date for Measuring Nonmonetary Determinations Time Lapse, issued
    December 13, 2006, UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 14-
    05, Change 2 | U.S. Department of Labor;
•   UIPL No. 14-05, Change 1, Performance Criterion for the Overpayment Detection
    Measure; Clarification of Appeals Timeliness Measures; and Implementation of Tax
    Quality Measure Corrective Action Plans (CAPs), issued October 12, 2005,
    UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 14-05, Change 1 | U.S.
    Department of Labor;
•   UIPL No. 14-05, Changes to UI Performs, issued February 18, 2005,
    UNEMPLOYMENT INSURANCE PROGRAM LETTER No. 14-05 | U.S. Department
    of Labor;
•   Training and Employment Guidance Letter (TEGL) No. 14-24, Fiscal Year (FY) 2025
    Fiscal Year (FY) 2025 Funding Allotments and Operating Guidance for Unemployment
    Insurance (UI) Reemployment Services and Eligibility Assessments (RESEA) Grants,
    issued June 10; 2025, TRAINING AND EMPLOYMENT GUIDANCE LETTER No.
    14-24 | U.S. Department of Labor;
•   TEN No. 28-23, Announcement of a New Data Sharing Partnership Between the U.S.
    Department of Treasury’s (Treasury) Bureau of the Fiscal Service (Fiscal Service) and
    the National Association of State Workforce Agencies’ (NASWA) Unemployment
    Insurance (UI) Integrity Center to provide State UI Agencies Access to Do Not Pay
    Working System (DNP) Data Sources and Services through the UI Integrity Data Hub
    (IDH), issued May 2, 2024, TRAINING AND EMPLOYMENT NOTICE No. 28-23 |
    U.S. Department of Labor;
•   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, TRAINING AND EMPLOYMENT NOTICE
    No. 05-22 | U.S. Department of Labor;
•   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, TRAINING AND EMPLOYMENT NOTICE No. 24-21 | U.S. Department of
    Labor;
•   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, TRAINING AND EMPLOYMENT NOTICE No. 15-21 |
    U.S. Department of Labor;
•   TEN No. 13-21, State Quality Service Plan Assurances Required for Disaster
    Unemployment Assistance, issued October 19, 2021, TRAINING AND EMPLOYMENT
    NOTICE No. 13-21 | U.S. Department of Labor;
•   TEN No. 17-19, Model Unemployment Insurance State Work Search Legislation, issued
    February 10, 2020, TRAINING AND EMPLOYMENT NOTICE No. 17-19 | U.S.
    Department of Labor;
•   TEN No. 12-16, Unemployment Insurance (UI) State Information Data Exchange System
    (SIDES), issued September 27, 2016, TRAINING AND EMPLOYMENT NOTICE No.
    12-16 | U.S. Department of Labor;

   •   TEN No. 03-15, Reengineering Unemployment Insurance (UI) Benefits Program
       Accountability Processes: Update on Implementation Progress and State Impacts, issued
       July 27, 2015, TRAINING AND EMPLOYMENT NOTICE No. 03-15 | U.S.
       Department of Labor
   •   TEN No. 08-14, Reengineering Unemployment Insurance (UI) Benefits Program
       Accountability Processes, issued September 2, 2014, TRAINING AND EMPLOYMENT
       NOTICE No. 08-14 | U.S. Department of Labor;
   •   ET Handbook No. 336, Unemployment Insurance (UI) State Quality Service Plan (SQSP)
       Planning and Reporting Guidelines, 18th Edition, Change 4 (March 2019), Employment
       and Training (ET) Handbook No. 336, 18th Edition, Change 4;
   •   ET Handbook No. 361, Unemployment Insurance Data Validation Handbook, Tax
       (October 2022), ET Handbook No. 361, Unemployment Insurance Data Validation
       Handbook, Tax.
   •   ET Handbook No. 395, Benefit Accuracy Measurement State Operations Handbook, 5th
       Edition (November 2009), Employment and Training (ET) Handbook No. 395, 5th
       Edition;
   •   ET Handbook No. 396, Unemployment Insurance Benefit Accuracy Measurement
       Monitoring Handbook, 4th Edition (November 2009), Employment and Training (ET)
       Handbook No. 396, 4th Edition; and
   •   ET Handbook No. 401, 5th Edition, UI Report Handbook No. 401 (July 2017),
       Employment and Training (ET) Handbook No. 401, 5th Edition.

7. Attachments.
   • Attachment I: Improve Program Performance and Operate the UI Program Effectively
   • Attachment II: Proactively Identify and Prevent Improper Payments and Fraud
   • Attachment III: Strengthening Reemployment Services
   • Attachment IV: Ensure Accurate and Complete Submission of ETA UI Required Reports
   • Attachment V: Measures/Programs to be Addressed in the Fiscal Year (FY) 2026 State
      Quality Service Plan (SQSP)

                                                                                       Attachment I


                                          National Priority #1

             Improve Program Performance and Operate the UI Program Effectively


The SQSP process is intended for states to develop and execute a strategic road map to improve program
administration and ensure quality service delivery. Significant progress has been made nationwide in
improving the timeliness of benefit payments in recent years. However, many states continue to face
challenges in meeting the acceptable level of performance for first payments, adjudication, and appeals.
ETA has observed contributing factors which include the need to make program improvements to aging
technology systems and/or to implement new technology solutions; training state staff; the reduction in
staffing levels as workloads and funding decline; the loss of key subject matter expertise; and the
addition of front-end checks, such as ID verification to strengthen integrity of the UI system.

An effective customer experience (CX) occurs when individuals can effectively and efficiently interact
with state UI systems across all access points such as phone, website, online portal, mobile application,
or in-person. If CX considerations and improvements are interwoven with a SWA’s existing processes,
then individuals are more likely to complete tasks accurately, timely, and more independently (i.e.,
requiring fewer SWA staff interactions). For additional information and resources, see TEN No. 18-24.

As part of the FY 2026 SQSP preparation, states should assess their current strategies and processes to
further improve timeliness and operational effectiveness. States must, in the State Plan Narrative,
describe their plans to address any pending adjudication and appeals backlogs and to improve timely
delivery of benefits.

For FY 2026, ETA will continue to provide intensive technical assistance to support performance
improvements for states with sustained poor performance; and to use the UI performance management
system, UI Performs, which includes core measures and Secretary’s Standards to monitor state
performance.

In developing their SQSPs, states are strongly encouraged to incorporate administrative capacity-
building strategies such as:

•   Conducting business process analysis in key areas to identify opportunities for improving program
    operations, and implementing recommendations from the analysis to improve performance;
•   Reviewing staff training strategies to support succession planning and ongoing staff development
    (https://www.naswa.org/services/learning); and
•   Using technical assistance opportunities offered by the Department, the UI Information Technology
    Support Center (ITSC), and the UI Integrity Center, as well as the peer-to-peer communication
    platforms and other information sharing tools available through the UI Community of Practice
    (CoP).

                                                                                    Attachment II


                                       National Priority #2

              Proactively Identify and Prevent Improper Payments and Fraud


The SQSP process is intended for states to develop and execute a strategic road map to improve
program administration and ensure quality service delivery – this includes strengthening program
integrity and preventing improper payments and fraud.

There are several activities involved in strengthening UI program integrity, such as improper
payment reduction; fraud prevention and detection; identity (ID) verification; fraud risk
mitigation; the recovery of overpayments; the prevention of underpayments; the timely and
accurate payment of benefits; the timely and accurate establishment of employer accounts; the
timely and accurate collection of employer contributions; and ensuring proper unemployment
compensation (UC) administration.

Combatting UI fraud is a continually evolving issue and effective prevention requires the ability
to quickly adapt risk mitigation responses to changing threats. This takes dedicated focus, strong
processes, and system-wide commitment from each state. Rather than simply reacting to detected
fraud, a strong fraud prevention approach focuses on deterring and stopping fraud from occurring
in the first place. Prevention activities are actions performed before benefits are issued to ensure
that the payment is going to the right person, in the right amount, at the right time.

Effective anti-fraud strategies employ a multi-layered approach by leveraging an array of
controls, tools, and resources to detect and fight fraud and reduce improper payments early and,
wherever possible, before a payment is made. ETA continues to strongly encourage states to
responsibly deploy multiple defense strategies such as multifactor authentication (MFA), fraud
risk scoring, data analytics, trend analysis, cross-matching, bank account verification (BAV) or
account verification services (AVS), machine learning, and artificial intelligence (AI) to
proactively detect potential fraud.

ETA’s efforts to improve integrity in the UI programs include providing guidance, technical
assistance, resources, and funding to support states in combatting fraud and improper payments.
The information below highlights additional resources made available for ID verification, UI
Integrity Center resources, the use of the State Information Data Exchange System (SIDES) to
exchange information electronically with employers and their representatives, and support for
states to develop a Fraud Risk Profile in line with framework from the U.S. General
Accountability Office (GAO).

•   ID Verification. Section 303(a)(1) of the Social Security Act (SSA), requires that a state has
    methods of administration to reasonably ensure the full payment of unemployment
    compensation (UC) when due. As well as promptness, the Department has always
    interpreted "when due" to also require accuracy in ensuring that payments are not made when
    they are not due (see 20 CFR 602.11(a), 602.21(c), and UIPL No. 04-01). These federal
    provisions mean, among other things, states must have a system in place to ensure the
    individual applying to receive UI benefits is the true owner of the name and Social Security
    Number (SSN) being used to establish eligibility (see UIPL No. 35-95).

                                                                                     Attachment II


    The strongest method by which states can ensure the name and SSN belong to the individual
    applying for benefits is by conducting evidence-based ID verification. Additionally, cross-
    matching and data analytics are most effective when conducted in real-time during the
    application process and when the state identifies a change in key user data (e.g., bank account
    or mailing address information).

    As workloads fluctuate and fraud schemes evolve, ETA expects states to continuously
    monitor their fraud management operations and collective ID verification efforts for
    effectiveness and adaptation. At a minimum, states are required to employ a risk-based
    approach that involves using both cross-matching and data analytics to identify suspicious
    activity that may be indicative of fraud and/or questionable ID. A risk-based approach could
    also result in the assignment of a risk score, which is a tool or method that involves assigning
    a numerical value (score) based on the level of risk and/or likelihood of fraud associated with
    a user’s actions and/or information supplied at any point in the UI process.

•   Work Authorization and use of the Systematic Alien Verification for Entitlements
    (SAVE) program. In addition to meeting all other eligibility criteria, the wage credits used
    to establish a claim and monetary entitlement to benefits must be earned while an alien is
    legally authorized to work in the United States, and an alien must be legally authorized to
    work in the United States to meet the eligibility requirement of being “available for work”
    while receiving such benefits. Therefore, an alien without valid authorization to work from
    the U.S. Citizenship and Immigration Services (USCIS) is not legally available for work and
    not eligible for benefits. As a condition of eligibility, each applicant for UC must declare
    under penalty of perjury, whether he or she is a citizen or national of the United States and, if
    not, whether he or she is in satisfactory immigration status. States can now access the
    Department of Homeland Security’s SAVE system at no cost to conduct this verification.

•   State Use of UI Integrity Center Resources. The UI Integrity Center, established and
    funded by ETA and operated by NASWA, assists states in their efforts to prevent, detect, and
    recover improper and fraudulent payments, and improve UI program integrity by developing
    and promoting innovative program strategies. The UI Integrity Center is a unique and
    valuable resource available at no cost to states. ETA strongly encourages states to access its
    services and resources on a regular and ongoing basis to inform and support state integrity
    strategies; strengthen fraud prevention and detection; enhance fraud management operations;
    and improve overpayment recovery efforts. Below are important UI Integrity Center services
    and resources that states should connect to and build into the IAP as part of the SQSP.

           o Integrity Data Hub (IDH) – is a secure, robust, centralized, multi-state data
             system that allows participating states to crossmatch, compare, and analyze states
             UC claims data against a variety of datasets for enhanced prevention and
             detection of improper payments and fraud in UI programs. The IDH is a key
             payment integrity tool available to states at no cost. ETA and NASWA work
             together to seek new opportunities and partnerships to continuously improve and
             enhance the IDH and make additional data sources and functionality available to
             states for cross-matching.

                                                                                    Attachment II

               While all 53 state UI agencies have agreements to participate in the IDH, states
               vary significantly in their use of this resource. ETA strongly encourages states to
               take full advantage of all available IDH functionality and submit all UI initial
               claims for cross-matching.

           o 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.

           o 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.

           o Behavioral Insights (BI) – brings together practices from the field of behavioral
             science to promote UI integrity and reduce UI improper payments by applying
             observations about human behavior to strategies that can improve decision-
             making and program outcomes. NASWA’s BI Toolkit provides states with a
             collection of resources, articles, templates, and how-to information to help state
             UI agencies apply the learnings of BI to address program compliance challenges
             and improve UI program integrity (see TEN No. 15-21).

           o 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.

•   State Information Data Exchange System (SIDES). State implementation and employers’
    use of SIDES should be an integral part of each state’s anti-fraud and improper payment
    reduction strategy (see TEN No. 12-16 and information available at
    https://www.naswa.org/uisides).

    SIDES is composed of Web Services for third-party administrators (TPAs) and large
    employers, and E-Response for smaller employers who are less frequent users of the UI
    system. States are encouraged to connect to all SIDES exchanges, which include the
    following:

           o   Separation Information Exchange – supports timely and accurate information
               from employers and TPAs, which aids in reducing separation errors.

           o Monetary & Potential Charges Exchange – advises the employer/TPA of the
             wages used to calculate potential UC payable to the claimant and advises the
             employer of the potential charges applied to the employer’s state unemployment
             taxes if UC is paid and the employer is found liable.

                                                                                             Attachment II


            o Additional Fact-Finding Exchange – permits electronic transmission of unique
              questions and responses between the state and the employer/TPA.

            o Determinations & Decisions Exchange – permits the state to electronically
              transmit a non-monetary determination or an appeals decision to an
              employer/TPA, and permits the employer/TPA to electronically respond, if
              necessary, with an appeal of a non-monetary determination or appeal of a lower-
              level appeal decision using the standard national format.

            o Earnings Verification Exchange – electronically sends wage verification requests
              to employers through a state-specific employer portal and is recommended if a
              state does not have an automated web-based system for requesting employers to
              verify earnings.

            o Benefit Charges Exchange – advises the employer/TPA of the amount of benefits
              charged to the employer for determining the employer’s state unemployment
              taxes based on the claimant’s eligibility and account liability.

            o Power of Attorney Exchange – intended for employers/TPAs/professional
              employer organizations to electronically request authorization to represent an
              employer for tax and/or benefit purposes (TEN No. 14-24).

•   Fraud Risks Profile. The Department’s UI fraud risk management activities are fully
    aligned with the U.S. General Accountability Office’s (GAO’s) Fraud Risk Framework2 and
    the “leading practices” are thoroughly embedded in ETA’s daily UI program integrity work.
    The Department uses its UI Fraud Risk Profile to assess existing UI fraud risk mitigation
    efforts, identify additional risks, and prioritize implementation of anti-fraud strategies. The
    creation, evaluation, monitoring, and evolution of risk mitigation strategies is an ongoing
    process. As such, ETA regularly assesses and updates its UI Integrity Strategic Plan3 and
    continuously evolves its anti-fraud and improper payment reduction strategies to best address
    inherent fraud risks and emerging fraud threats.

    The UI program is a Federal-state partnership, authorized by Federal law (Title III of the
    SSA) and administered by states through conforming state laws. Both ETA and state UI
    agencies have a vested interest in ensuring UI program integrity and are jointly responsible
    for managing the process of assessing and mitigating fraud risks to the UI programs.
    However, only states can directly prevent, detect, and recover improper payments.

    ETA requires states to evaluate UI fraud risks, and implement and maintain sufficient
    controls to effectively prevent fraud and reduce improper payments, which includes
    developing a state-specific anti-fraud strategy.4 To provide resources to state UI agencies to

  See A Framework for Managing Fraud Risks in Federal Programs at https://www.gao.gov/assets/gao-15-593sp.pdf.
3
  The UI Integrity Strategic Plan is found at:
https://ui.workforcegps.org/resources/2024/05/30/18/57/UI_Integrity_Strategic_Plan-Antifraud_Strategy (UI CoP
log-in required).
4
  GAO’s Framework for Managing Fraud Risks in Federal Programs highlights the key elements of an antifraud
strategy (see https://www.gao.gov/assets/gao-15-593sp.pdf, Table 4, page 19).

                                                                                       Attachment II

       aid in the development of state-specific anti-fraud strategies, and share information on ETA’s
       activities regarding UI fraud risk management and the identified national UI fraud risks, ETA
       developed and published UI Fraud Risk Management webpages on the Workforce GPS, UI
       Community of Practice (see TEN No. 32-23).

Integrity and Disaster Unemployment Assistance (DUA)

Although DUA awards are under individual grants separate from the UI state administrative
funding grants, ETA is using this SQSP guidance as an opportunity to stress the importance of
integrity activities related to the DUA program. The incidents of declared disasters qualifying
for DUA5 have increased in recent years. The UI system at large has experienced perpetrators of
fraud attempting to leverage disruptions in the labor market, including disaster events, to file
fraudulent claims. This has been particularly evident regarding DUA and UI claims related to
recent major disasters. As a result, ETA is amplifying the need for states to enhance the integrity
of the DUA program as a national priority.

•      Importance of ID Verification. ETA strongly encourages states to use the same ID
       verification processes for all DUA claims that are used in the administration of their regular
       UI program. To bolster these efforts, ETA intends to make the use of front-end identity
       verification services on disaster-related claims a condition of any extensions or waivers
       requested and approved pursuant to Section 301 of the Stafford Act.

•    Importance of Documentation Substantiating Employment and Self-Employment. As
     described in UIPL No. 09-19, when filing an initial DUA application, if an individual does not
     have the required documentation to substantiate employment or wages, DUA benefits are
     payable based on the individual’s affidavit. The individual has 21 days to present the required
     documentation to continue receiving payments. When an individual does not provide
     documentation demonstrating proof of employment within 21 days, the state must discontinue
     payments, issue a denial of benefits for any payments received by the individual, and establish
     an overpayment, as provided at 20 CFR 625.6(e)(2). As provided at 20 CFR 625.14(a), the
     individual is liable to repay the established overpayment and the state must take all reasonable
     measures under the law to recover the total sum of the DUA payments made to the individual.

ETA reminds states that they are to provide assurances regarding the DUA program as part of the
FY 2026 SQSP submissions (see TEN No. 13-21). The assurances regarding DUA are:

       •   Each state must provide an assurance that it will conduct annual training for DUA staff
           charged with accepting DUA claim applications, adjudicating DUA claims, hearing DUA
           appeals and developing and maintaining a Standard Operating Procedures manual for
           DUA. States are encouraged to use the DUA training modules available on the NASWA
           learning platform at https://www.naswa.org/learning.

       •   Each state must:
              o Indicate that it has conducted training and provide the date(s) of the training; and

    See Section 410 of the Stafford Act (42 U.S.C. § 5177).

                                                                               Attachment II

          o Indicate that it has developed and/or maintained DUA Standard Operating
            Procedures for use during a major disaster declaration. (States may contact the
            RO for a copy of a DUA Standard Operating Procedure Template. ROs will also
            obtain an initial copy from each state for the Department’s record.)

ETA also encourages state UI agencies to review The Disaster Lifecycle from Preparedness
through Resiliency: A Guide for State Workforce Agencies, which ETA recently published and
announced in TEN No. 19-24. This guide is designed to help state workforce agencies and their
partners develop a comprehensive, adaptable, and strategic disaster preparedness and response
planning process that can be quickly implemented by staff and partners.

                                                                                  Attachment III


                                      National Priority #3

                            Strengthening Reemployment Services


The UI program supports reemployment through a variety of targeted strategies, including
through administration of the RESEA, providing for robust work search activities, and the Short-
Time Compensation (STC) program.

RESEA as an Individualized Reemployment Program.

The RESEA program is a dedicated funding stream for states to provide evidence-based
individualized reemployment services and referrals to other workforce partners. RESEA, a
voluntary program for states, is codified in Section 306 of the SSA. Recognizing RESEA as a
permanent workforce partner, states with RESEA programs have been directed to prioritize
strategies that support the expansion and sustainability of the program, such as permanent
staffing, expanded eligibility, and increased service-delivery. ETA publishes operating guidance
each year for the administration of their RESEA program. UIPL No. 12-25, and Training and
Employment Guidance Letter (TEGL) No. 14-24 provide the FY 2025 RESEA operating
guidance.

The RESEA program requires states to submit an annual RESEA state plan as a precondition to
receiving their formula allocated grant. States are permitted to reference their RESEA and
WIOA state plans in the SQSP rather than replicate these strategies and approaches. States
should also discuss in their SQSPs how their RESEA strategies support reducing improper
payments, including the review of claimant eligibility and providing services that help
participants comply with work search requirements.

Robust Work Search Requirements that Actively Support Reemployment.

Another targeted strategy to support reemployment is through the work search requirements set
forth in Section 303(a)(12) of the SSA. Each state defines acceptable work search activities
through its laws and policies, which vary across the states. In TEN No. 17-19, ETA provides
states with model work search legislation. ETA reiterates this TEN and its focus on proactively
referring claimants to suitable work, establishing a comprehensive definition of acceptable work
search activities that focuses on rapid reemployment, and providing fair notice and
documentation of requirements. It is a promising practice for states to have a fully integrated
workforce system that focuses its collective efforts on assisting claimants to return to suitable
work as quickly as possible. The following items reflect work search strategies that states should
consider:

o Requiring work search activities that embrace a wide array of activities that support
  reemployment in today’s labor market and include receiving services through American Job
  Centers;

o Supporting claimant compliance with required work search activities through a
  reemployment service delivery design that includes developing clear, plain language work

                                                                               Attachment III

    search requirements and behavioral insights that: 1) ensure claimants understand work
    search requirements (both acceptable activities and documentation requirements); 2) ensure
    claimants understand the consequences of failing to comply with these requirements; and 3)
    provide assistance in developing a reemployment plan that meets the requirements,
    including through customer-friendly technology applications that facilitate claimants
    carrying out tasks that meet the work search requirements;

o Leveraging the design of the state’s RESEA program:

    o to support the development of an individual reemployment plan that can help each
      claimant effectively plan work search activities, and make such services available
      virtually to support a broader reach; and

    o to encourage RESEA (and other career and reemployment service providers) to take
      advantage of the My Reemployment Plan to support development of individualized
      reemployment plans and connect claimants to effective reemployment resources (see
      Pathways to Reemployment);

o Encouraging states to proactively identify and refer claimants to suitable job openings from
  public and private job banks, and ensure that claimants accept employment in suitable work
  when offered;

o Developing and facilitating continuous review of completed work search activities to verify
  claimant compliance;

o Documenting these activities through the state’s case management system or other
  information technology (IT) systems that support documentation requirements; and

o Providing case management services through American Job Center career counselors, which
  include following up with claimants and employers on the results of job referrals to inform
  future job referrals and/or the need for additional reemployment services for the claimant.


Short-Time Compensation (STC) as a Lay-Off Aversion Program.

The STC program (known also as “work-sharing” or “shared work”) is a lay-off aversion
program in which an employer, under a state-approved plan, reduces the work hours for a group
of workers, and these workers in turn receive reduced UC payments for the weeks in which they
worked reduced hours. ETA also encourages the use of STC to support workers and employers.

                                                                                  Attachment IV


                                      National Priority #4

        Ensuring Accurate and Complete Submission of ETA UI Required Reports


Some states continue to experience technical challenges in submitting timely and accurate ETA-
required reports, including reports for the now-expired temporary pandemic UC programs.

Accurately reported data are essential for properly assessing state performance, distributing
administrative funds appropriately among the states, and providing a basis for many statistical
research analyses. Because performance measures are intended to guide and assist states in
improving their performance and service to their ultimate customers (workers and employers),
states also have an interest in ensuring that the data from reports, upon which these measures are
based, are correct.

The state’s SQSP Narrative is required to include actions planned to address this issue and
ensure appropriate reporting in FY 2026. States are also required to correct any inaccuracies in
previously transmitted reports to ensure accurate data is reported.

                                                                                             Attachment V

                       Measures/Programs to be Addressed in the Fiscal Year (FY) 2026
                                     State Quality Service Plan (SQSP)


                                                                                                  FY 2026
       Core Measures                  Measurement Period                   Criteria
                                                                                                Requirement

First Payment Promptness           Apr 1, 2024 – Mar 31, 2025                87%                    CAP
Nonmonetary Determination          Apr 1, 2024 – Mar 31, 2025              80%
                                                                                                    CAP
Time Lapse                                                            (combined score)
Nonmonetary Determination          Apr 1, 2024 – Mar 31, 2025
                                                                             75%                    CAP
Quality – Non-separations
Nonmonetary Determination          Apr 1, 2024 – Mar 31, 2025
                                                                             75%                    CAP
Quality – Separations
                                   BPC
                                                                             50%                    CAP
                                   Apr 1, 2021 – Mar 31, 2024

                                   BAM                                       95%                  Narrative
Detection of Overpayments
                                   Oct. 1, 2021 – Sep. 30, 2024
                                   If rate over 95% is a result of
                                   improper administration of                95%                    CAP
                                   BAM and/or BPC
Average Age of Pending Lower       Apr 1, 2024 – Mar 31, 2025
                                                                           30 days                  CAP
Authority Appeals
Average Age of Pending Higher Apr 1, 2024 – Mar 31, 2025
                                                                           40 days                  CAP
Authority Appeals
Lower Authority Appeals       Apr 1, 2024 – Mar 31, 2025
                                                                             80%                    CAP
Quality
New Employer Status
                              Jan 1, 2024 – Dec 31, 2024                     70%                    CAP
Determinations Time Lapse
                              Jan 1, 2024 – Dec 31, 2024              No more than 3 tax
                                                                     functions failing Tax
Tax Quality – Part A                                                                                CAP
                                                                     Performance System
                                                                        (TPS) in a year
                                   Jan 1, 2024 – Dec 31, 2024            The same tax
                                                                      function cannot fail
Tax Quality – Part B                                                                                CAP
                                                                       for 3 consecutive
                                                                              years
                                   Jan 1, 2024 – Dec 31, 2024          Score >7 and pass
Effective Audit Measure                                                                             CAP
                                                                          all 4 factors
                                   BAM batches 202326
Improper Payments Measure                                                   < 10%                   CAP
                                   through 202427
UI Overpayment Recovery
                                   Jul 1, 2023 – Jun 30, 2024                68%                    CAP
Measure

                                                                                  Attachment V

   Secretary’s Standards in                                                         FY 2026
                                      Measurement Period            Criteria      Requirement
          Regulation
First Payment Promptness           Apr 1, 2024 – Mar 31, 2025
                                                                     87%             CAP
(Intrastate 14/21 Days)
First Payment Promptness           Apr 1, 2024 – Mar 31, 2025
                                                                     93%             CAP
(Intrastate 35 Days)
First Payment Promptness           Apr 1, 2024 – Mar 31, 2025
                                                                     70%             CAP
(Interstate 14/21 Days)
First Payment Promptness           Apr 1, 2024 – Mar 31, 2025
                                                                     78%             CAP
(Interstate 35 Days)
Lower Authority Appeals (30        Apr 1, 2024 – Mar 31, 2025
                                                                     60%             CAP
Days)
Lower Authority Appeals (45        Apr 1, 2024 – Mar 31, 2025
                                                                     80%             CAP
Days)


                                                                                    FY 2026
      UI Programs, etc.               Measurement Period            Criteria      Requirement

                                                                    Results not
                                                                   submitted by      CAP
                                                                  June 10, 2025
Data Validation –Populations &
                               Apr 1, 2024 – Mar 31, 2025             Failing/
Modules (Benefits and Tax)
                                                                    incomplete
                                                                                     CAP
                                                                 submissions by
                                                                  June 10, 2025
Compliance with NDNH
matching requirements for          Status as of March 31, 2025                       CAP
BAM
BAM operations not compliant
with investigative and/or
                                   Based on the annual
method and procedure
                                   determination letter issued                       CAP
requirements including
                                   on or before May 1, 2025
construction of valid samples
and sample populations
Incorrect recording of the Issue
Detection Date and/or              Apr 1, 2024 – Mar 31, 2025                      Narrative
Determination Date

TPS Sample Reviews                 Jan 1, 2024 – Dec 31, 2024                        CAP

Reporting Deficiencies             Ongoing                                         Narrative

UI Program Integrity               Ongoing                                            IAP

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