Identity verification in unemployment claims

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 Unemployment Insurance
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OUI/DUIO
             Washington, D.C. 20210                       DATE
                                                          April 13, 2021


ADVISORY:        UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 16-21

TO:              STATE WORKFORCE AGENCIES

FROM:            SUZAN G. LEVINE
                 Principal Deputy Assistant Secretary

SUBJECT:         Identity Verification for Unemployment Insurance (UI) Claims

1. Purpose. To highlight the importance of identity verification in ensuring the proper payment
   of unemployment benefits and to provide guidance to states on required administrative
   procedures when processing claims and determining UI eligibility in cases where an
   individual’s identity (ID) is questionable.

2. Action Requested. The U.S. Department of Labor’s (Department) Employment and
   Training Administration (ETA) requests that State Administrators provide this information to
   appropriate staff.

3. Summary and Background.

   a. Summary – UI integrity is a top priority of the Department and State Workforce
      Agencies. The Department supports states’ efforts to verify ID as part of the UI claims
      process in order to stop fraudulent claims using stolen personally identifiable information
      (PII), including Social Security Numbers (SSN). In resolving issues related to ID
      verification, states must follow the adjudication standards outlined in sections 303(a)(1)
      and 303(a)(3) of the Social Security Act (SSA) (42 U.S.C. 503(a)(1) and (3)) and the
      Standard for Claim Determination (CD) (20 C.F.R. Part 614, Appendix B). When ID
      issues arise through a crossmatch with a federal database, the Computer Matching and
      Privacy Protection Act of 1988 (CMPPA), 5 U.S.C. 552a(o)-(r), also applies.

        As states consider new and evolving ID verification tools and strategies, the Department
        has become aware of some uncertainty among states about the administrative processes
        that are required when resolving issues of questionable ID.

        This UIPL provides guidance to states about the adjudication standards as they apply
        specifically when processing claims and determining UI eligibility in cases where an
        individual’s ID is questionable.



 RESCISSIONS                                              EXPIRATION DATE
 None                                                     Continuing

   In addition to the content described in this UIPL, for resources, recommendations, and
   best practices regarding identity verification and combatting identity theft and fraud,
   including data analytics, prevention, detection, and recovery activities, please visit the UI
   Integrity Center’s Knowledge Exchange Library. ETA strongly encourages state
   workforce agencies to align their state website content and communications for victims of
   unemployment identity theft with the content, resources, and reporting requirements
   outlined at www.dol.gov/fraud.

b. Background – Section 303(a)(1) of the SSA, requires that a state have methods of
   administration to reasonably ensure the full payment of unemployment compensation
   when due. In addition, Section 1137(a)(1), SSA, requires states to require the individual
   to furnish their Social Security Number as a condition of eligibility for benefits. These
   Federal provisions mean, among other things, that a state must have a system to
   reasonably ensure that the name and Social Security Number used to establish eligibility
   for unemployment compensation belong to the individual filing the claim. UIPL No. 35-
   95 also outlines that the provision of an individual’s SSN is a requirement for
   claimstaking.

   Since the unprecedented increase in claims resulting from the economic impact of the
   Coronavirus Disease 2019 (COVID-19) pandemic, UI programs have become a target for
   fraud with significant numbers of imposter claims being filed with stolen or synthetic
   identities. Synthetic identity fraud occurs when real and fake information are combined
   to create false identities. Additionally, fraudulent employers report fabricated wages for
   real individuals or use synthetic identities to have the fabricated wages appear to have
   been earned in the base period and then those associated employees file fraudulent UI
   claims based on these fabricated wages. Because synthetic identities combine multiple
   data points, it is more difficult to prevent and detect this type of fraud, requiring the use
   of crossmatches with additional data sources to support detection.

   The Unemployment Insurance Fraud Protection Guide issued by the U.S. Department of
   Justice on September 21, 2020, page 1, states: “Fraudsters, some of which are
   transnational criminal organizations, are using stolen identities of U.S. citizens to open
   accounts and file fraudulent claims for UI Benefits, exploiting the unprecedented
   expansion of these benefits provided in response to economic disruption caused by the
   COVID-19 pandemic.” (See https://www.justice.gov/file/1324726/download)

   ID theft is not only a major concern for the UI programs but also a growing nationwide
   and worldwide problem. Recognizing this dilemma, Congress passed Public Law 105-
   318, which modified 18 U.S.C. § 1028 ("Fraud and related activity in connection with
   identification documents, authentication features, and information") to make it a federal
   crime for whoever “knowingly transfers, possesses, or uses, without lawful authority, a
   means of identification of another person with the intent to commit, or to aid or abet, any
   unlawful activity that constitutes a violation of Federal law, or that constitutes a felony
   under any applicable state or local law.” 18 U.S.C. 1028(a)(7). In 2019, the Federal
   Trade Commission received over 650,000 reports of ID theft and in recent years, state UI
   systems have identified multiple fraud schemes involving stolen Personally Identifiable

      Information (PII). According to the Identity Theft Resource Center, government ID theft
      occurs when a victim’s sensitive PII is used to obtain funds and/or services from federal
      or state governments (https://helpcenter.idtheftcenter.org/s/).

      States are employing a wide array of strategies to verify the identities of UI claimants
      through crossmatches, state developed tools, and private vendor services. In addition, the
      UI Integrity Center’s Integrity Data Hub (IDH) is making new data sources available for
      states’ use, such as its Identity Verification (IDV) solution.

      The IDH provides states a secure and centralized system, containing various datasets, to
      assist states in detecting and preventing fraud, identity theft, and improper payments in
      the unemployment insurance program. In essence, states send their unemployment
      insurance claims data to the IDH, which the IDH crossmatches against a variety of
      datasets to determine if a claim has suspicious attributes that may indicate fraud or
      identity theft.

4. Claims Determination Processes Related to ID Verification.

   When a state obtains information through automated systems or other sources that question
   whether the name and/or SSN used to file a claim belong to the individual who is filing the
   claim, the state must act quickly to: i) provide the individual with proper notice and an
   opportunity to provide information to resolve the issue; ii) decide whether or not sufficient
   information has been provided to verify the individual’s ID; and iii) issue a written
   determination. The notice must also include information that failure to respond could result
   in a determination denying benefits and establishing an overpayment of any benefits
   previously paid. These processes must be consistent with the adjudication standards of
   sections 303(a)(1) and 303(a)(3) of the SSA (42 U.S.C. 503(a)(1) and (3)), and the CD (20
   C.F.R. Part 614, Appendix B).

   If the information that creates the ID issue is obtained from a federal database, the state must
   follow the requirements of the CMPPA. Section 4.g. of UIPL No. 01-16 discusses these
   requirements in detail. The CMPPA does not apply when states are using their own internal
   data or non-federal databases, such as the UI Integrity Center’s IDH, though states must still
   conform to the adjudication standards described in this UIPL when resolving the question of
   an individual’s ID raised by a non-federal database. ETA funds the UI Integrity Center
   through a cooperative agreement with the Center for Employment Security Education and
   Research (CESER) (a subsidiary of the National Association of State Workforce Agencies
   (NASWA), which is an organization representing state workforce agencies). The UI
   Integrity Center operates the IDH. ETA does not store or have access to any IDH data.

   States must act promptly to verify an individual’s ID in order to meet the requirement of
   section 301(a)(1), SSA, that the state have methods of administration reasonably calculated
   to ensure full payment of UI when due. For new claims, payment “when due” means that
   qualified and eligible individuals receive their first benefit payments as soon as
   administratively feasible. Refer to subsection b, Adjudication of ID Verification Issues,
   below regarding the “when due” requirement applicable to continued claims.

UIPL No. 04-01 interprets the “when due” requirement to also require states to ensure that
payment of benefits is not made when payment is not due. Investigations of fraudulent
imposter claims involving claimants, employers, and/or state staff are necessary for the
proper administration of the UI program. States must have processes in place to ensure
benefits are only paid to the individual whose identity has been verified. However, once a
claim has been established and payments have been issued, there is a presumption of
eligibility (refer to UIPL 04-01). Therefore, there must be evidence on the record that
substantiates a reasonable basis for stopping payments once a determination of eligibility has
been made and payments have been issued.

a. ID Verification Processes

   Acceptable documents to verify ID are documents made or issued by or under the
   authority of the United States Government, any of the states (including the District of
   Columbia, the Commonwealth of Puerto Rico and the U.S. Virgin Islands), political
   subdivisions of a state, a foreign government, a political subdivision of a foreign
   government, an international governmental or an international quasi-governmental
   organization which, when completed with information concerning a particular individual,
   is of a type intended or commonly accepted for the purpose of identification of
   individuals. Some examples of acceptable identification documents include, but are not
   limited to, Social Security cards, birth certificates, driver’s licenses, government
   passports, alien registration cards, and other government issued identification cards.
   Limiting the acceptable documents that may be used for ID verification in this manner is
   consistent with 18 U.S.C. 1028(d)(3), which addresses fraud and related activity in
   connection with identification documents. Because these types of documents are the
   most reliable for verifying identity and preventing fraud, this requirement is a reasonable
   interpretation of the SSA section 303(a)(1) obligation to provide “[s]uch methods of
   administration … as are found by the Secretary of Labor to be reasonably calculated to
   insure full payment of unemployment compensation when due.”

   A state’s list of acceptable documents to verify ID must include a sufficient variety to
   provide for equal access to UI benefits for all claimants. For example, if the state
   requires a state driver’s license as proof for ID verification, it must offer a reasonable
   alternative for those who may not have that type of identification or provide sufficient
   time for other means of identification to be obtained.

   Suspicious claims may be flagged at three different times during the claims filing
   process. We provide scenarios describing the timing of each, the issue to be resolved,
   and instructions for how the state reports such activities. When a suspicious claim is
   flagged for ID verification in all three of these scenarios, the state’s request for additional
   information and resolution of the issue must align with the notice requirements discussed
   in subsection c, Requirements for Processes to Verify Identity, below.

Timing of ID verification issues.

As mentioned above, there are three times in the life cycle of a claim when ID
verification may occur:

    1. After an application is received by the state, but before the application is entered
      into the state’s benefit system (e.g., the state presents ID verification questions
      and only allows the claim to be processed when the applicant is able to correctly
      answer the ID verification questions);
    2. After a claim is filed, but before payment is issued (e.g., the state identifies
      potential ID verification issues during the claim filing process, but accepts the
      claim and requests the claimant provide proof of ID before payments are made);
      and
    3. After a claim is filed and payments have been issued.
          a. The state became aware of the ID issue through its normal processes of
              issue identification (e.g., the state receives information that the individual
              who filed the claim is not the owner of the wages or the identity used on
              the claim or the claim is “hijacked” by an imposter after the owner of the
              wages/identity files a legitimate claim).
          b. A financial institution identifies suspicious activity and contacts the state
              to return funds (refer to subsection b below).

Possible outcomes of an attempt to verify ID.

If the claimant provides the requested information and the state is able to verify the
claimant is the owner of the wages used to file the claim, the issue is resolved and the
claimant is eligible for benefits, as long as the claimant otherwise meets all other
eligibility requirements.

If the claimant does not respond to the request for information and the state is unable to
verify the claimant’s ID, the state must issue an immediate prospective denial based on a
failure to respond (see subsection c, Requirements for Processes to Verify Identity, below
for additional instructions). The issuance of a prospective denial for failure to respond
does not preclude the state from continuing to investigate potential fraud for any weeks
that have already been paid. If the claimant does not respond to the request to provide
proof of identity and the state is unable to verify the claimant’s identity, and no payments
have been made on the claim, the state may disqualify the claimant for failure to respond
to a request for information from the beginning of the claim. Such denial may continue
indefinitely until the individual reports or provides information as directed.

If the state conducts an investigation and determines that the individual who filed the
claim (or in the case of a claim that was “hijacked,” the individual who was paid the
benefits) is not the owner of the wages/identity, the state must issue a determination
based on the identity not being verified, issue a fraud determination, and establish a fraud
overpayment (see subsection c, Requirements for Processes to Verify Identity, below for
additional instructions).

b. Adjudication of ID Verification Issues

   States must determine a claimant’s eligibility whenever an ID verification issue arises.
   The adjudication process must conform to the adjudication standards detailed in this
   UIPL, including: i) providing the individual with proper notice and an opportunity to
   provide information to resolve the issue; ii) deciding whether or not sufficient
   information has been provided to verify ID; and iii) issuing a written determination.

   ETA strongly recommends that states redact the employer information (i.e., name of
   employer and Employer ID information) on the monetary determinations when ID theft is
   suspected during the initial claim process.

   For ID verification issues that arise after the initial claim is filed and benefit payments
   have been issued, the state must determine if it is appropriate to pause payment while the
   identity verification is being conducted. To do so, the state must have evidence on the
   record that substantiates a reasonable basis for establishing the issue and pausing
   payment (e.g., the state has identified potential fraud based on its own data analytics).

   If the state determines that it is appropriate to pause payment while the identity
   verification is being conducted, the state is not required to issue payment for the week in
   question until it issues a determination of eligibility or ineligibility, as long as the
   determination is timely. For continued claims, timely payment (i.e., payment “when
   due”) means that a determination is made no later than the end of the week following the
   week in which the issue is detected. If the decision is not issued timely, the state must
   continue to pay the continued claim and issue a determination as soon as administratively
   feasible after payment is made. (See UIPL No. 01-16 and UIPL No. 04-01.)

   A financial institution’s decision to return UI benefit payments to the state is not
   sufficient, on its own, to determine benefits have been overpaid or that fraudulent activity
   occurred. If the state has not already done so, the state must verify the individual’s
   identity.

   If the financial institution does not provide any details on why the payments were
   returned and the state has no other information to indicate suspicious activity occurred,
   the state may not stop payments to the individual while conducting the ID verification
   process. The state must have a process to reissue any benefits as soon as administratively
   feasible and through an alternative method (e.g., new direct deposit account, debit card,
   paper check). This process must include contacting the claimant to update the payment
   method. (See UIPL No. 02-16, Section 4A)

   Timely determinations prevent fraudulent benefit payments while ensuring that qualified
   and eligible claimants receive benefits as soon as administratively feasible.

c. Requirements for Processes to Verify Identity

   The CD standards set forth at 20 C.F.R. Part 614, Appendix B, apply to all eligibility
   issues identified throughout the continued claim cycle, including ID verification issues.
   These requirements, as they apply specifically to ID verification, are discussed in detail
   below.

        Proper Notice. The state’s first step after a question of ID arises is to notify the
         individual of the issue and that ID verification is required. The notice must provide
         clear instructions for the individual to meet the requirement by providing: 1) an
         explanation of the issue; 2) the types of documentation accepted by the agency as
         proof to verify ID; 3) instructions on where/how/to whom the information must be
         provided; and 4) the consequences of not responding timely, including that the
         consequences for failure to respond could result in a determination denying benefits
         and establishing an overpayment of any benefits previously paid. The notice must
         also include a reasonable deadline by which the individual is to provide the
         requested information.

         The state must use the contact information provided by the individual filing the
         claim. (See sections 6012 A, 6013 A.1, and 6015 of the CD.) In addition, and
         separate from the notification, if the state posts such notice(s) on a claimant portal,
         the message must remain in the claimant’s login portal until the issue has been
         resolved.

         States may use a variety of mechanisms to verify an individual’s ID (e.g., submit
         documents on-line, report in-person, or complete a questionnaire). States must
         provide alternative mechanisms for individuals with access barriers, such as a
         disability or limited English proficiency. (See Sections 5-9 of UIPL No. 02-16)

        Written Determination. If the individual does not respond timely or responds but
         does not provide adequate information, the state must provide a written
         determination in accordance with section 6013 C.1.c. of the CD (“[t]he agency
         must give each claimant a written notice of … [a]ny…determination which
         adversely affects a claimant’s right to benefits”). The determination must explain
         the reason for the decision, including the facts: what the individual was asked to
         provide; what was received; and, if information was received, why that information
         was insufficient to verify the individual’s ID.

         In accordance with section 6012 C of the CD, the state must keep a record of the
         facts used in its determination.

         Notice of appeal rights. The written determination must give the claimant the
         option to appeal the determination or to ask for reconsideration, as required by
         sections 6012 A, 6013 C.2., and 6013 C.2.i. of the CD.

                While an individual’s failure to respond is sufficient to prevent additional benefits
                from being paid until the individual responds, failure to respond in and of itself is
                not sufficient to establish an overpayment. The state must consider the evidence
                supporting suspicious activity, in addition to the individual’s failure to respond to
                the state’s attempt to verify identity, and determine if, under state law, the evidence
                in the record is sufficient to establish an overpayment. Application of state law
                informs whether the overpayment is considered fraudulent or non-fraudulent based
                on the facts and evidence in the claim file.

                The agency must keep a written record of the facts considered in reaching its
                determination. Examples of evidence supporting suspicious activity may include,
                but are not limited to:

                        IDH matches indicating suspicious claims data;
                        IDV score below the state’s established threshold;
                        Crossmatches with Federal, state and/or local databases indicating
                         suspicious activity;
                        Crossmatches with private-sector databases indicating suspicious activity;
                        Data analytics from state developed tools or private vendor services detect
                         suspicious activity such as:
                             o Multiple claims using the same Internet Protocol (IP) address,
                                mailing address, email address, phone number, bank account,
                                security answers, or other data elements;1
                             o Multiple claims with trends in days or times that claims are filed;
                             o SSN used on claims in multiple states;
                             o Physical or mailing address belongs to a vacant property or fictitious
                                address;
                             o Out-of-country IP address;
                             o Phone number with an invalid area code;
                             o Email address using a domain frequently identified as fraudulent;
                             o Mismatched city and county information;
                             o Time spent filing the claim is significantly quicker than the median
                                filing time.
                        Employer or Employer Representative indicates no record of employment
                         or reports the individual never worked for them;
                        Claim tied to fictitious employer investigation or determination;
                        Benefit payment rejected by a bank or financial institution;
                        Claimant requests to change the bank account for direct deposit;
                        A statement from the alleged victim of ID theft.2

1
  It is important to recognize that there are legitimate instances of multiple claimants using the same IP addresses
when accessing the state UI system, such as individuals using computers at local libraries, legal aid office, or at
America Job Centers. Similarly, there are legitimate instances of multiple claimants using the same mailing address,
such as residents of Domestic Violence Safe Houses, homeless shelters, or other communal living locations. State
UI agencies are encouraged to identify these types of legitimate multiple user indicators and ensure they do not get
included as indicators of suspected fraudulent activities.

                 Fraud determinations may not be made by an automated system. The written
                 determination must be sent to the individual who filed the claim (i.e., the imposter),
                 using the address provided when the claim was filed (see UIPL 01-16).

                 Denial for failure to respond. If a claimant is required to verify their ID and fails to
                 respond to the request, provided state law allows, the state may deny benefits as of
                 the date the individual failed to report or respond to the request for information.
                 Such denial may continue indefinitely until the individual reports or provides
                 information as directed. However, if the facilities or systems to which the
                 individual was directed to report are unavailable (e.g., unable to report in-person
                 because the office is closed), no denial can be issued for that week.

                 States must send a written determination to individuals who are denied for failure
                 to respond. When the individual is denied for failure to respond as requested to
                 verify their ID, to mitigate unnecessary appeal hearings, we strongly recommend
                 that states include instructions in the written determination explaining how they can
                 comply with the reporting requirements.

    d. Reporting

         Determinations related to ID verification may affect the claimant's monetary
         determination. The state must report this only in two places: 1) the original monetary
         determination on the ETA 218 – Benefit Rights and Experience report; and 2) the
         nonmonetary redetermination in column 17 – “Other (Aliens, Athlete, School)” of the
         ETA 207. A monetary redetermination issued as a result of the nonmonetary
         determination is not reportable.

         Currently, there is no mechanism for states to report ID verification issues when the ID
         verification determination results in the denial of the claim before the claim is actually
         processed in the state’s benefit system. ETA will provide additional reporting
         instructions for this workload item in subsequent guidance.

         The state will report the initial monetary determination on the ETA 218, Benefit Rights
         and Experience report. Once the claimant’s ID is confirmed, the state must re-issue the
         monetary determination, with the full employer details. The re-issuance of the monetary
         determination is not reported on ETA 218, Benefit Rights and Experience report.

         Similarly, a monetary denial due to the removal of wages is in essence a monetary
         redetermination. Redeterminations must not be included in the Benefit Accuracy
         Measurement (BAM) sample universe and should be deleted from the sample selection.

2
  Note that the alleged victim does not need to verify their own identity for the state to begin an investigation on a
suspicious claim. The individual filing the claim is responsible for validating their own identity. If the alleged
victim is trying to file a claim, then the state must, as a matter of course in filing a claim, require the alleged victim
to validate their own identity.

      If these redeterminations are selected in the BAM sampling universe, they must be
      deleted from the sample. If these monetary redeterminations are consistently included in
      the BAM sample, ETA strongly recommends that the state agency review and address
      any inconsistencies within its reports in order to correct this issue.

      States would report non-monetary determinations based on the individual’s failure to
      respond to the identity verification request in the ETA 207 Nonmonetary Determination
      Activities report, on lines 301 and 302, in column 15 “Reporting Requirement Call-ins
      and Other”. The state will report any non-monetary determinations based on the
      individual’s failure to verify identity on the ETA 207 Nonmonetary Determination
      Activities report on lines 301 and 302, in column 17 “Other (Aliens, Athlete, School)”.

      Additionally, ETA is creating a new category for ID verification issues and additional
      reporting instructions for affected UC required reports. Until this new category is
      created, states must report the number of determinations and denials reported in column
      15 and column 17 for failure to report/respond issues and failure to verify identity
      determinations.

5. Protecting ID Theft Victims.

   When a state determines that ID theft has occurred, that is, the person filing the claim is not
   the actual owner of the name and/or SSN under which the claim was filed, it must take
   precautions to protect the rights of the ID theft victim and mitigate the negative consequences
   related to the fraudulent activity, including:

         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 or,
          whenever possible, is not issued a Form 1099G at the end of the year;
         Exclude the overpayment from the Treasury Offset Program (TOP) and suspend any
          Benefit Payment Control collection activity; and
         Not initiating any legal actions against the actual owner of the SSN.

   One option states can use to mitigate negative impacts on ID theft victims is to establish a
   pseudo claim record and transfer all claim information regarding the imposter’s claim to the
   pseudo claim once the state makes a fraud determination. This removes the fraudulent
   activity from the victim's SSN, should the victim need to file for unemployment benefits in
   the future. Additionally, this preserves data from the fraudulent activity to be used for future
   analytics.

   States must provide individuals who suspect theft of their identity for purposes of filing UI
   claims easily accessible options to report such theft or fraudulent activity, such as dedicated
   phone lines, email addresses or an online portal by which individuals can notify the state
   agency. States may also provide links to other agencies that specialize in protecting

   consumers and their personal identifiable information, such as the Federal Trade
   Commission’s Consumer website at https://www.consumer.ftc.gov/topics/identity-theft.
   ETA strongly encourages state workforce agencies to align their state website content and
   communications for victims of unemployment identity theft with the content, resources, and
   reporting requirements outlined at www.dol.gov/fraud.

6. Cases Selected for Program Integrity/Quality Reviews.

   Claims involving ID verification issues that are selected for review through the ongoing
   BAM program or the Benefit Timeliness and Quality Review (BTQ) program should include
   the following information in the BAM/BTQ case file in order to complete its analysis or
   investigation:

             All documentation related to the ID verification processes utilized on the claim;
             Case information for the SSN as well as any information transferred to a pseudo SSN;
              and
             Fact-finding documentation and logic for the claim determination(s).
   State agencies are required to complete BAM coding for ID theft consistent with the
   methodology outlined in the ETA Handbook No. 395 and the error coding for elements (ei1)
   through (ei4) must reflect the action taken by the BAM investigator as summarized below:

             (ei1) = the amount paid for the key week;
             (ei2) Key Week Action = 10;
             (ei3) Error Cause = 480 through 489; and
             (ei4) Error Responsibility may include 4 to reflect the person or entity who
              committed the identity theft.

   The prior actions recorded in elements (ei5) BAM Detection Point, (ei6) Prior Agency
   Action, (ei7) Prior Employer Action, and (ei9) Prior Claimant Action should also be
   included.

7. Tools Available through the UI Integrity Center Integrity Data Hub (IDH).

   As most recently discussed in UIPL Nos. 23-20, 28-20, and 28-20, Change 1, the IDH is a
   secure, robust, centralized, multi-state data system that allows participating state UI agencies
   to submit claims for crossmatching and analysis to support the prevention and detection of
   improper payments, fraud, and ID theft. The IDH contains an expanded set of data sources
   and new functionality continues to be explored and added. Currently the IDH offers the
   following capabilities:

                Identity Verification (IDV)
                Suspicious Actor Repository (SAR);
                Suspicious E-Mail Domains;
                Foreign IP Address Detection;
                Multi State Cross-Match (MSCM);

                Data Analytics;
                Fraud Alert System; and

    In July 2020, the IDH added an IDV component, which provides centralized ID verification
    solution. The IDV component offers states advanced ID verification scoring to maximize
    front-end ID verification, enabling states to assess whether an individual is using a false,
    stolen, or synthetic ID.

    The IDH is available to participating states at no cost and is an effective tool in preventing
    and detecting improper payments and combatting imposter fraud and ID theft. All states are
    strongly encouraged to participate.3

8. Inquiries. Please direct inquiries to the appropriate ETA Regional Office.

9. References.

       Computer Matching and Privacy Protection Act of 1988 (CMPPA) (5 U.S.C. § 552a(o)-
        (r));
       Identity Theft and Assumption Deterrence Act of 1998 (18 U.S.C. § 1028 note)
       Section 303 of the Social Security Act (SSA) (42 U.S.C. § 503);
       Claim Determination (CD) Standards set forth at 20 C.F.R. Part 614 Appendix B;
       Standard for Benefit Payment Promptness - Unemployment Compensation, 20 C.F.R.
        Part 640;
       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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9897;
       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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8044;
       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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4621;

3
  The Pacific territories (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 have access
to the IDH.

       UIPL No. 02-16, Change 1, State Responsibilities for Ensuring Access to Unemployment
        Insurance Benefits, issued May 11, 2020,
        https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5491;
       UIPL No. 02-16, State Responsibilities for Ensuring Access to Unemployment Insurance
        Benefits, issued October 1, 2015,
        https://wdr.doleta.gov/directives/corr_doc.cfm?docn=4233;
       UIPL No. 01-16, Change 1, Federal Requirements to Protect Individual Rights in State
        Unemployment Compensation Overpayment Prevention and Recovery Procedures –
        Questions and Answers, issued January 13, 2017,
        https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7706;
       UIPL No. 01-16, Federal Requirements to Protect Individual Rights in State
        Unemployment Compensation Overpayment Prevention and Recovery Procedures, issued
        October 1, 2015, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5763;
       UIPL No. 04-01, Payment of Compensation and Timeliness of Determinations during a
        Continued Claims Series, issued October 27, 2000,
        https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=1746;
       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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=1901;4
       ET Handbook No. 401, 5th edition, Unemployment Insurance Reports Handbook, August
        2017;
       ET Handbook No. 301, 5th edition, UI Performs: Nonmonetary Determinations Quality
        Review, July 29, 2005;
       Report Unemployment Identity Theft, U.S. Department of Labor Employment and
        Training Administration website, www.dol.gov/fraud;
       UI Integrity Center website, https://www.naswa.org/integrity-center; and
       Unemployment Insurance Fraud Consumer Protection Guide, U.S. Department of Justice,
        issued September 21, 2020, https://www.justice.gov/file/1324726/download.




4
 We note that the link to this document shows an expiration date of June 30, 1996. However, per Training and
Employment Notice No. 15-20, issued January 14, 2021, this remains an active UIPL.