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ARPA funds for state UI fraud prevention and overpayment recovery
Summary ETA offered states up to $200 million in additional ARPA funding for identity verification, fraud prevention and recovery of unemployment benefit overpayments. It also described required and recommended integrity measures. ETA cancelled this Change 2 through UIPL No. 10-23 after Congress rescinded unobligated ARPA funds.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 22-21, Change 2
Date issued
April 27, 2023
Status
Rescinded
UIPL No. 10-23, issued July 13, 2023, expressly cancelled this Change 2 after Congress rescinded unobligated ARPA funds.
Status last verified October 24, 2026
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CLASSIFICATION
EMPLOYMENT AND TRAINING ADMINISTRATION Unemployment Insurance
ADVISORY SYSTEM CORRESPONDENCE SYMBOL
U.S. DEPARTMENT OF LABOR OUI/DPM
Washington, D.C. 20210 DATE
April 27, 2023
ADVISORY: UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 22-21,
Change 2
TO: STATE WORKFORCE AGENCIES
FROM: BRENT PARTON
Acting Assistant Secretary
SUBJECT: Additional American Rescue Plan Act (ARPA) Funding and Support for States
to Strengthen Unemployment Insurance (UI) Program Integrity, including
Identity (ID) Verification, Fraud Prevention and Detection, and Overpayment
Recovery Efforts in All Unemployment Compensation (UC) Programs and
Required and Strongly Recommended Strategies, Tools, and Services for UI
Fraud Risk Mitigation and Improper Payment Reduction
1. Purpose. To provide states with information on both required and strongly recommended
strategies, tools, and services for UI fraud risk mitigation, improper payment reduction, and
overpayment recovery; and to announce the availability of up to $200 million in additional
ARPA funding and support for states to strengthen UI program integrity, including ID
verification, fraud prevention and detection, and overpayment recovery efforts in all UC
programs.
2. Action Requested. Submissions for the funding opportunities under this Unemployment
Insurance Program Letter (UIPL) are due by the close of business on July 26, 2023. The
U.S. Department of Labor’s (DOL or the Department) Employment and Training
Administration (ETA) requests that State Workforce Agency Administrators:
• Review the funding opportunity described in this UIPL to ensure appropriate staff is
aware of the required and strongly recommended strategies, tools, and services for UI
fraud risk mitigation and improper payment reduction; and to determine if the state will
apply for these funds.
• Coordinate with appropriate state staff to develop a grant application that outlines how
the state intends to use the awarded funds to strengthen UI program integrity, including
ID verification, fraud prevention and detection, and overpayment recovery efforts in all
UC programs as describe in Section 4.g.ii. of this UIPL.
• Submit the budget narrative, grant application, SF-424 (OMB Approval No. 4040-0004),
and SF-424A (OMB Approval No. 4040-0006) forms via www.grants.gov.
RESCISSIONS EXPIRATION DATE
None Continuing
3. Summary and Background.
a. Summary – Over the last several years, the Department has made available funding
opportunities to states to take significant action to combat UI fraud and reduce improper
payments in the administration of UC programs by implementing, strengthening, and
enhancing ID verification, fraud prevention and detection, digital authentication, and
internal security. With this UIPL, the Department is making available an additional $200
million in ARPA funding to states to further support their UI fraud prevention, improper
payment reduction, and overpayment recovery efforts in all UC programs by improving
tools, services, and investigations, as well as evaluating and upgrading integrity strategies
to address emerging trends and new fraud schemes.
Evidence-based ID verification is the strongest method for states to ensure that the Social
Security Number (SSN) used for a UI application belongs to the person applying.
Evidence-based ID verification includes activities such as an individual presenting
documentation (virtually or in person) to establish their identity. However, recognizing
resource constraints and the impact they can have on the timely processing of benefits,
the Department requires that, at a minimum, states use a risk-based approach to
determine which claims are subject to evidence-based ID verification. A risk-based
approach means that states are using cross-matches and data analytics at different points
throughout the life of the claim (described further in Section 4.a. of this UIPL).
States are required to conduct certain integrity controls aimed at fraud prevention and
detection activities and certain overpayment recovery activities. However, simply
deploying a fraud prevention and detection tool, implementing an ID proofing solution,
or adding a new cross-match should not be the only action a state takes. States are
expected to consider where in the UI process a tool, solution, or resource is best used and
how investigations will be prioritized to reduce improper payments. These tools,
strategies, and activities should undergo continuous review and data analysis for
effectiveness and to ensure equitable access for legitimate claimants. Additionally, these
reviews should provide an opportunity for continuous evaluation to ensure timely and
accurate payments to eligible individuals. Section 4.b. and 4.c. of this UIPL provides
states with information on required and recommended strategies, tools, and services for
UI fraud risk mitigation, improper payment reduction, and overpayment recovery.
Section 4.d. of this UIPL provides details on evaluating data to ensure effectiveness and
equity in ID verification and fraud prevention and detection.
While addressing fraud and mitigating improper payment risks, it is also critical that
states protect victims of UI ID fraud. States should ensure the state’s UI fraud reporting
instructions are understandable. States should also have established processes and clear
communication protocols in place when tips involving UI ID fraud are received. Section
4.e. of this UIPL provides information on protecting individuals impacted by UI ID fraud.
Section 4.f. of this UIPL reminds states of the many resources available to support states
with UI integrity efforts.
To enable states to continue strengthening UI program integrity, this UIPL announces the
availability of up to $200 million in additional ARPA funding for the implementation of
tools, services, and activities discussed throughout the UIPL. ETA will review and
approve proposed projects/activities prior to awarding the funds available under this grant
opportunity. Section 4.g. of this UIPL describes the methodology for determining
individual state allocations and outlines the allowable use of funds made available under
this opportunity.
As a condition of receiving funding under this UIPL, states must agree to continued
information disclosure with the Department’s Office of Inspector General (DOL-OIG) as
described in Section 4.h. of this UIPL. States will be required to report on the quarterly
progress and implementation of each project/activity to their ETA Regional Office.
Section 4.i. of this UIPL provides application instructions and Section 4.j. of this UIPL
details reporting requirements.
This UIPL focuses specifically on articulating a vision of effective methods of ID
verification, fraud prevention and detection, and overpayment recovery efforts, as well as
providing funds to support states in implementing new methods and enhancing their
existing processes. ETA will continue to provide states with technical assistance and
future guidance that promotes continuous improvement and enhancement for integrity
and equitable access in the UI system.
b. Background – On March 11, 2021, the President signed ARPA into law (Public Law
(Pub. L.) 117-2). Section 9032, ARPA, creates a new Section 2118 of the Coronavirus
Aid, Relief, and Economic Security (CARES) Act (Pub. L. 116-136) and provides for a
$2,000,000,000 appropriation to the Secretary of Labor (Secretary) to detect and prevent
fraud, to promote equitable access, and to ensure timely payment of benefits to eligible
workers with respect to UC programs. ARPA sets out the allowable uses of these funds,
including to make grants for such purposes to states or territories administering UC
programs.
State UI agencies entered the COVID-19 pandemic after experiencing the lowest claims
workload, and thus lowest administrative funding, in 50 years, which significantly
impacted resources and staffing levels. As pandemic shutdowns began impacting the
nation’s labor market, states had to rapidly increase staffing levels with minimal time for
the proper training needed to respond to the unprecedented increase in claims volume.
During this time, states also had to quickly transition to fully remote operations to
mitigate the spread of COVID-19 in their agencies. Simultaneously, states were asked to
implement complicated new temporary pandemic UC programs, with new eligibility
requirements, for individuals not typically eligible for UI benefits, such as self-employed
and certain gig economy workers. Many states were challenged by antiquated UI
information technology (IT) systems and/or were in the process of modernizing their IT
systems, while also implementing and administering the temporary pandemic UC
programs. To add further complication to state UC program operations, the frequency
and complexity of fraud attacks against state UC programs increased significantly during
the pandemic. States were forced to respond to and address relentless and sophisticated
fraud attacks that continued to evolve to circumvent the prevention and detection tools
and strategies states had in place.
The DOL-OIG issued two alert memorandums,1 identifying potentially fraudulent
unemployment benefits paid in four specific high-risk areas, which included individuals
with SSNs: (1) filed in multiple states, (2) of deceased persons, (3) used to file UI claims
with suspicious email accounts, and (4) of federal prisoners. The Department has taken
action to support states in actively and aggressively addressing UI fraud and reducing
improper payments and many actions have targeted the specific types of fraud identified
by the DOL-OIG. Additionally, in June 2022, the U.S. Government Accountability
Office (GAO) added “the UI system to its list of federal areas at ‘High Risk’ for waste,
fraud, abuse, and mismanagement, or in need of broad-based transformation.”2
Furthermore, GAO issued two reports3 recommending the Department assess fraud risks
to the UI program in alignment with GAO’s Fraud Risk Framework.4 The Department is
actively working to enhance its existing UI fraud risk management processes, using
GAO’s Fraud Risk Framework as a guide, and will continue to identify and address UI
fraud risks. UI program integrity remains a top priority for the Department and the entire
UI system. ETA’s efforts to address fraud risks and improve integrity in the UC
programs includes providing guidance, technical assistance, funding to states to combat
fraud and reduce improper payments, and requiring states to submit an Integrity Action
Plan (IAP) as part of its State Quality Service Plan. ETA is also investing in developing
new and enhancing existing tools, datasets, and resources and making them available to
aid states in more quickly identifying potential improper payments and fraud.
On August 11, 2021, the Department issued UIPL No. 22-21, which provided states with
$140 million in ARPA funding for fraud detection and prevention, including ID
verification and overpayment recovery activities, in all UC programs. The Department
also made available up to $525 million in CARES Act funding to assist states with efforts
Alert Memorandum: The Employment and Training Administration (ETA) Needs to Ensure State Workforce
Agencies (SWA) Implement Effective Unemployment Insurance Program Fraud Controls for High-Risk Areas,
Report No. 19-21-002-03-315 (February 22, 2021) and Alert Memorandum: Potentially Fraudulent Unemployment
Insurance Payments in High-Risk Areas Increased to $45.6 Billion, Report No. 19-22-005-03-315 (September 21,
2022).
See GAO Report issued on June 7, 2022, entitled “Unemployment Insurance: Transformation Needed to Address
Program Design, Infrastructure, and Integrity Risks” at https://www.gao.gov/assets/gao-22-105162.pdf.
See GAO Report issued October 27, 2021, entitled “Additional Actions Needed to Improve Accountability and
Program Effectiveness of Federal Response” at https://www.gao.gov/assets/gao-22-105051.pdf and GAO Report
issued January 23, 2023, entitled “Unemployment Insurance: Data Indicate Substantial Levels of Fraud during the
Pandemic; DOL Should Implement an Antifraud Strategy” at https://www.gao.gov/assets/gao-23-105523.pdf.
See A Framework for Managing Fraud Risks in Federal Programs at https://www.gao.gov/assets/gao-15-593sp.pdf.
to prevent and detect fraud and to recover fraud overpayments in certain CARES Act UC
programs. See UIPL Nos. 28-20; 28-20, Change 1; 28-20, Change 2; and 28-20, Change
4. Additionally, UIPL No. 23-21 provided up to $260 million in funding to assist states
with activities that promote equitable access to all UC programs. Under UIPL No. 11-22,
ETA awarded grant funding to selected states to participate in the ARPA UI Navigator
Program which helps workers learn about, apply for, and, if eligible, receive UI benefits
and related services (i.e., navigate the UI program) and supports state agencies in
delivering timely benefits to workers—especially individuals in groups that are
historically underserved, marginalized, and adversely affected by persistent poverty and
inequality. UIPL No. 02-22, provided up to $200 million in funding to support states
with implementation of recommendations made following a Tiger Team consultative
assessment for fraud prevention and detection, promoting equitable access, and ensuring
the timely payment of benefits, including backlog reduction, for all UC programs.
4. Guidance. UI program integrity includes ID verification, fraud prevention and detection,
improper payment reduction, fraud risk mitigation, the recovery of overpayments, the
prevention of underpayments, the timely and accurate payment of benefits, and ensuring
equitable access in all UC programs. ETA continuously develops and oversees
implementation of integrity strategies that target the root causes of improper payments. The
Department continues to update its antifraud strategies and is committed to ensuring its UI
fraud risk management activities are conducted in alignment with GAO’s Fraud Risk
Framework. GAO’s Fraud Risk Framework calls for a strategic approach for assessing and
managing fraud risks. Since the UI program is a federal-state partnership, which means both
the Department and state UI agencies are responsible for ensuring UI program integrity,
states must also evaluate UI fraud risks and implement and maintain sufficient controls to
effectively prevent fraud and reduce improper payments.
a. ID Verification in UC Programs. Section 1137(a)(1), of the Social Security Act (SSA),
provides for states to require that individuals furnish their SSN as a condition of
eligibility for benefits. As noted in Section 3.A.(1) of UIPL No. 35-95, any system
planned or implemented to provide ease and convenience for filing claims must provide
safeguards, including a way to ensure that the name and SSN used to establish eligibility
for UC belongs to the individual filing the claim. Therefore, this provision of the SSA
requires that states verify an individual’s identity to ensure that the individual filing the
claim is the owner of the name and SSN used when establishing eligibility. The strongest
method by which states can ensure the name and SSN belong to the individual applying
for UC is by conducting evidence-based verification. Evidence-based verification
includes activities such as an individual presenting ID documents (i.e., official
government-issued documentation, control over a device, account or address known to be
associated with an identity, or biometric information) at a physical location, through a
virtual platform, or through other state-developed processes or procedures that validate or
verify an individual’s identity.
Evidence-based verification is most effective at preventing ID fraud:
• during the UC application process,
• immediately following the completion of an initial claim,
• during any break in the claim series (e.g., additional and reopened claims), or
• when a claim is prioritized for investigation based on results of cross-matching or
data analytics and evidence-based verification has not already been completed.
The Department encourages states to employ different fraud prevention and ID
verification strategies at different points throughout the life of the claim. At a minimum,
states must use a risk-based approach to determine which claims should be subject to
evidence-based ID verification. A risk-based approach involves states using cross-
matches and data analytics to identify suspicious activity that may be indicative of fraud.
States must prioritize the investigation of claims having the greatest risks, and where
appropriate, require the completion of evidence-based ID verification.
Cross-matching and data analytics are most effective when conducted in real-time during
the UC application and/or initial claims process. Crossmatching and data analytics
should also be conducted when a state identifies a change to key user data (e.g., bank
account or mailing address information) on an existing claim, which may raise suspicion
of “claim hijacking” or “claim or account takeover”. The state should immediately take
action by flagging the claim for investigation and conducting account verification
services (AVS)/bank account verification (BAV) and/or other data analysis to ensure the
change was made by the legitimate owner of the claim.
As workloads fluctuate and fraud schemes evolve, the Department expects states to
continuously monitor their fraud management operations and collective ID verification
efforts for effectiveness and adaptation.
i. ID Proofing. As defined by the National Institute of Standards and Technology
(NIST) 5, ID proofing is the process by which a credentialed service provider
(CSP)6 collects, validates, and verifies information about a person to establish that
an individual is who they claim to be. ID proofing is one of many options states
may use to conduct evidence-based ID verification. States implementing ID
proofing in their UC programs must implement solutions/services that balance
equitable access with alignment to NIST digital identity guidelines. For example,
NIST Special Publication (SP) 800-63 provides technical requirements for implementing digital identity services.
The publication includes: an overview of identity frameworks; using authenticators, credentials, and assertions in a
digital system; and a risk-based process to select assurance levels at https://pages.nist.gov/800-63-3/sp800-63-
3.html.
NIST SP 800-63 defines a CSP, as a trusted entity that issues or registers subscriber authenticators and issues
electronic credentials to subscribers. A CSP may be an independent third-party or issue credentials for its own use.
states that utilize ID proofing are required to provide a non-digital alternative
option such as in-person ID verification at locations like American Job Centers.
States are encouraged to continue to refine and expand non-digital ID verification
option(s) with funds from this opportunity, leveraging resources in their states
where individuals can go or have gone to have their identity proofed.
The Department has piloted the use of Login.gov, the federal government's secure
sign-in service operated by the General Services Administration, to provide ID
verification for UI services conducted online. The Department plans to expand
the availability of this service to other states and encourages states to contact their
ETA Regional Office to learn more about Login.gov and how to participate. In
addition, the Department is launching a new service to provide in-person,
evidence-based ID verification at U.S. Postal Service locations in states across the
country.
b. Fraud Prevention and Detection Activities. An antifraud strategy describes existing
fraud control activities as well as any new control activities a program may adopt to
address residual fraud risks. ETA issued UIPL No. 23-20, on May 11, 2020, reminding
states of required and recommended program integrity functions for the UC programs. In
this UIPL, ETA is consolidating and clarifying these activities and expanding the
recommended program integrity functions as outlined below. ETA reiterates the
importance of conducting the required program integrity functions and encourages states
to incorporate all recommended functions into a state’s fraud management operations.
States must continue to use, operate, and maintain the required integrity controls and the
required overpayment recovery activities discussed below at all times, including during
times of mass unemployment events, absent specific statutory authorization allowing
suspension of such controls or activities. ETA also strongly encourages states to use,
operate, and maintain the recommended integrity controls and recommended
overpayment recovery activities discussed below during such periods.7
In accordance with UIPL Nos. 02-16 and 02-16, Change 1, states must ensure that the
fraud prevention and detection technologies/strategies they use do not create barriers that
prevent or limit access for some individuals in violation of applicable federal equal
opportunity or nondiscrimination laws. This may include identifying potential barriers
that may impact historically underserved and marginalized populations when making
design decisions and training team members on equity-related issues and processes.
The DOL-OIG issued reports raising concerns that some states suspended and ceased operating some of the
required and recommended integrity controls during portions of the pandemic. See DOL-OIG Report No. 19-22-
006-03-315, COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds from Improper Payments
Including Fraud or from Payment Delays; and DOL-OIG Report No. 19-21-002-03-315, Alert Memorandum: The
Employment and Training Administration (ETA) Needs to Ensure State Workforce Agencies (SWA) Implement
Effective Unemployment Insurance Program Fraud Controls for High Risk Areas.
States should continuously evaluate their fraud prevention and detection activities from
the perspective of equitable access.
i. Required Fraud Prevention and Detection Activities. States must use, operate,
and maintain the following integrity controls to prevent and detect fraud.
• ID Verification (Section 1137(a)(1) of the Social Security Act and UIPL
No. 35-95) including proper notification and adjudication when an
eligibility issue arises (UIPL No. 16-21);
• National Directory of New Hires cross-match (UIPL Nos. 13-19 and 19-
11, TEN No. 05-20);
• Quarterly Wage Records cross-match (20 C.F.R. 603.23);
• Systematic Alien Verification for Entitlement (SAVE) (Section 1137(d) of
the Social Security Act (42 U.S.C. §1320b-7); and
• Referral of allegations reasonably believed to constitute UC fraud, waste,
abuse, mismanagement, or misconduct to DOL-OIG (UIPL No. 04-17,
Change 1).
ii. Recommended Fraud Prevention and Detection Activities. ETA strongly
recommends states implement, use, operate, and maintain the following integrity
controls.
• UI Integrity Center’s Integrity Data Hub (IDH) (see Section 4.f.iii.D. of
this UIPL for details on IDH functionalities/resources);
• Digital Authentication, such as Multifactor Authentication (MFA);
• Device Fingerprint/Reputation Management, which establishes a
combination of inputs (i.e., digital identity) to assist in the authentication
of a user’s identity during ongoing use of online state UI systems;
• Fraud Risk Scoring (i.e., Case Management Prioritization), which includes
using sophisticated risk analytics to assign a risk-based score to claims to
detect suspicious activity early in the claims process, as well as minimize
the number of false positives to protect legitimate claimants from being
flagged for suspected fraud and avoid disproportionately assigning high
risk scores to particular groups of claimants;
• Comparisons and cross-matches that detect shared characteristics (e.g.,
phone numbers, mailing addresses, email addresses, and banking
information) on multiple claims;
• Social Security Administration cross-matches (i.e., Unemployment
Insurance Query (UIQ), Prisoner Update Processing System (PUPS),
Death Master File) (see Section 4.f.vii. of this UIPL for details regarding
PUPS);
• Federal, state, and local incarceration cross-matches;8
• Deceased Records cross-matches;
• Vital Statistics cross-matches;
• State Directory of New Hires cross-match;
• Department of Motor Vehicle cross-match;
• Interstate Benefits (IB) cross-match;
• State Identification Inquiry (SID) and IB8606 enhancements made to the
Interstate Connection (ICON) network cross-match to prevent concurrent
claim filing in multiple states;
• State Information Data Exchange System (SIDES) (Training and
Employment Notice (TEN) No. 12-16) (see Section 4.f.vi. of this UIPL for
details regarding SIDES);
• Use of a unique identifier to identify claimants instead of using the full
SSN;
• Fictitious employer cross-matches;
• Periodic IT security assessments and audits consistent with NIST-
compliant IT security guidelines (UIPL No. 04-21);
• Adequate internal controls to protect the integrity and security of state
assets (UIPL No. 14-17); and
• Implement a cross-functional integrity task force to develop and
implement state-specific action plans to reduce UI improper payments
(UIPL No. 19-11);
iii. Effectively Conducting Fraud Prevention and Detection Activities. As noted
above, simply deploying a fraud prevention and detection tool, implementing an
ID proofing solution, or adding a new cross-match is not the most effective
strategy for fraud prevention and ID verification. To effectively prevent and
detect fraud, the state should consider where in the UI process every tool,
solution, and resource is best used and how investigations are prioritized to
prevent fraud and reduce improper payments.
States should think strategically about how cross-match results are triaged and
prioritize claims for investigation that have a higher probability of fraud or the
potential to result in large improper payments. States should be judicious in
deciding which cross-matches trigger an immediate hold on benefits, and which
require further investigation before a payment series is stopped. ID verification
investigations are time sensitive, especially in situations where payment has
Data sets from jails and prisons may not be updated in real time and therefore may lag in the reported incarceration
entrance and/or release dates. Additionally, data sets may contain unreliable identity information. ETA reminds
states to factor these things in when reviewing incarceration data cross-match results. After receiving incarceration
cross-match information, states must conduct appropriate investigations to determine eligibility. See UIPL No. 01-
22.
already been made on a claim and the individual fails to respond by the deadline.
After the response deadline passes and no response is received, states should act
quickly to stop future payments from occurring by issuing an immediate failure to
respond denial (Section 4 of UIPL No. 16-21).
Further, states should consider the frequency of cross-matches within the life of
the claim – some are more effective when run often and continuously throughout
the claim lifecycle. For example, a multi-state cross-match may be most effective
if conducted during the initial claim application or immediately following the
initial claim and prior to issuing payment. Vital statistics, deceased records, and
incarceration cross-matches are critical activities that are effective if conducted
during the initial claim process, and prior to issuing first payment, and may also
be highly effective at continuing to confirm UI eligibility throughout the life of
the claim. Other activities, such as a suspicious email domain cross-match or
AVS/BAV may be appropriate to run once or on an ad hoc basis when an email
address or bank account is suspect, updated, or changed on a claim.
States should take the following three actions to strengthen fraud prevention and
detection using the IDH:
1. Take advantage of, and use, all IDH functionality;
2. Implement IDH web service/real-time connectivity, if possible; and
3. Submit all UC initial and continued claims to the IDH in real-time, or daily,
at minimum.
c. Overpayment Recovery Activities. UIPL No. 23-20 also reminded states of required
and recommended overpayment recovery activities.9 Overpayment recovery is critical to
protect both state UI trust funds and federal funds and must be given the same priority as
fraud prevention and detection activities.
i. Required Overpayment Recovery Activities. States must implement, use, and
maintain the following activities to recover overpayments.
• Benefit Offsets (Title II, Subtitle A of the Middle-Class Tax Relief and
Job Creation Act of 2012, UIPL No. 05-13, and Section 5 of UIPL No. 13-
20, Change 2);
• Treasury Offset Program (TOP) for applicable covered debt (Bipartisan
Budget Act of 2013, UIPL Nos. 02-19, 12-14, and 04-20);10
States may, under limited circumstances, elect to waive recovery of certain established non-fraud overpayments.
For overpayments in the regular UI program, these circumstances are defined in state law. For overpayments under
the temporary pandemic-related UC programs, refer to UIPL Nos. 20-21 and 20-21, Change 1.
Covered debt includes past-due debts that are the result of claimant fraud or unreported earnings, uncollected
employer contributions, and any penalties and interest assessed on such debt (26 U.S.C. § 6402(f)(4)).
• Cross Program Offset Recovery Agreement (CPORA) (UIPL No. 05-13);
and
• Interstate Reciprocal Offset Recovery Arrangement (IRORA) (UIPL No.
05-13).
ii. Recommended Overpayment Recovery Activities. ETA strongly recommends
that states implement, use, and maintain the following activities to recover
overpayments.
• Negotiating repayment plans;
• Accepting repayments through various methods (e.g., online, via
debit/credit card);
• State Income Tax Offset Program;
• Wage garnishments;
• Property liens and assessments;
• Offsets of lottery winnings, homestead exemptions, and other benefits;
• Active participation in probate and/or bankruptcy proceedings regarding an
individual with an outstanding overpayment;
• Skip tracing;
• Work proactively and collaboratively with banks and financial institutions
to detect suspicious activity, ensure that accounts are not unduly
suspended, and recover overpayments (UIPL No. 19-21);
• Civil actions;
• Credit bureau referrals;
• State/federal prosecution;
• Penalties and interest on overpayments in compliance with state and
federal law;
• Collection agency referrals when state staff is limited, or debt is
uncollectable by other means;11 and
• Other recovery methods as determined by state law or policy.
iii. Effectively Conducting Overpayment Recovery Activities. ETA recommends
that states consider an escalated approach to claimant communications for
overpayment recovery activities. For example, an individual with a non-fraud
overpayment may successfully resolve their overpayment after receiving clear
communication with instructions on how to establish a repayment plan and a clear
explanation regarding any overpayment waiver processes. Only if the non-fraud
overpayment is not waived and an individual fails to establish or comply with a
repayment plan after a period of time that the state deems appropriate, should the
The immediate deposit and withdrawal standards prohibit states from paying third-party collection agencies out of
a recovered overpayment. See 3304(a)(3), FUTA; 303(a)(4), SSA; 3304(a)(4), FUTA, 303(a)(5), SSA.
state send an escalating notice for further recovery activities. States may contact
their ETA Regional Office to be connected to the Department’s Office of
Unemployment Insurance Modernization (OUIM) for support with plain language
conversions to simplify terminology complexity when communicating with
claimants as described in Section 4.f.iv. of this UIPL.
d. Evaluating Data to Ensure Effectiveness and Equity in ID Verification and Fraud
Prevention and Detection. A critical part of fraud risk management includes evaluating
outcomes using a risk-based approach and adapting activities to improve fraud risk
management. States should monitor and evaluate the effectiveness of fraud prevention
and improper payment reduction activities, to adapt to changing risks and continuously
improve the effectiveness of their fraud management operations. This includes collecting
and analyzing data for fraud trends and identifying potential control deficiencies.
Effective monitoring and evaluation focuses on measuring outcomes and progress toward
the achievement of objectives, rather than simply reviewing outputs and progress in
implementing control activities. Results of the monitoring and evaluations should be
used to improve the design and implementation of fraud risk management activities.
As states are implementing and refining processes for digital authentication, ID proofing,
cross-matching, data analytics, and other fraud prevention and detection activities, states
must consider and address any equitable access impacts. One of the most common
barriers to equitable access is an ID proofing process that is difficult to complete.
Examples of difficulty in completing ID proofing processes may involve individuals with
limited English proficiency; individuals with limited access to, or understanding of,
technology; or instructions that are unclear or cumbersome. Another common barrier is
states erroneously flagging legitimate claim activity as suspicious. This can result in
delays for eligible individuals to receive UI benefits – a matter which is further
exacerbated when states are experiencing high workload volumes, making it difficult for
individuals to contact the state unemployment agency. States must ensure there is at least
one timely, effective, and accessible non-digital alternative to online ID verification.
This non-digital option should not be overly burdensome on applicants, limit access to
public benefits programs or the timely receipt of benefits, or stigmatize members of the
public in any way.
ETA strongly recommends that states implement data collection and analysis to review
their fraud prevention and detection activities – monitoring for barriers to equitable
access and taking swift action to mitigate such barriers.12 The data for this analysis may
come from system datapoints, customer surveys, periodic user interviews, and case
samples. States should work with their service providers or with their in-house fraud
As described in UIPL No. 11-14, the Department’s regulations also require state compliance with the U.S. Office
of Management and Budget (OMB) guidelines on the collection of data based on race or ethnicity. See 29 CFR
§ 38.41(d). States must provide information about the reasons for a data request, and the ways in which the data
may be used before asking about a claimant’s race/ethnicity, sex, age, or disability status.
management operations to identify and resolve any barriers or equitable access impacts
resulting from ID proofing practices and data analytics and cross-matching services.
When using a CSP for ID proofing or a third-party solution, ETA recommends that states
establish, within their contracts, a process to receive Personally Identifiable Information
(PII) and data on an individual’s ID proofing status (i.e., verified, not verified, pending,
inconclusive) within a service provider’s system or solution. To be able to properly
respond to customer inquiries, states should have access to such information in real-time
(if possible), but no later than 24 hours after an individual started the ID proofing process
and whenever there is a change in the ID proofing status. By knowing the individual’s
ID proofing status, the state can also ensure that appropriate instructions and next steps
are provided to the individual. The Department outlined stringent technical, service
level, business performance, and equity requirements in its solicitation for ID proofing
services described in TEN No. 06-21. ETA recommends that states incorporate similar
provisions in their ID proofing solicitations and contracts with service providers.
Attachment VI to this UIPL describes recommended contract provisions for ID proofing
services and solutions.
DOL-OIG recently issued an Alert Memorandum13 highlighting concerns about states’
use of ID verification service providers, specifically those employing the use of facial
recognition technology, and the impact these ID proofing services may have on equitable
and secure access to UI benefits. ETA strongly encourages states to carefully review ID
proofing solutions that use biometrics such as facial recognition. While these solutions
may help to reduce ID fraud, they may have negative implications for14or lead to
violations of states’ nondiscrimination obligations under Section 188 of Workforce
Innovation and Opportunity Act (WIOA). States are reminded that a non-digital
alternative option for ID verification must be available and not require substantially more
time, hardship, or delay to complete. Furthermore, states using ID proofing solutions that
employ the use of facial recognition technology, must test the system for biases15 and
work with the service provider to identify and resolve any biases or barriers to equitable
access resulting from the ID proofing process.
Alert Memorandum: ETA and States Need to Ensure the Use of Identity Verification Service Contractors Results
in Equitable Access to UI Benefits and Secure Biometric Data, Report No. 19-23-005-03-315 (March 31, 2023).
For instance, recent research indicates that, depending on how it is implemented, certain biometric technology
may have a disproportionate adverse impact on protected groups. See, e.g., National Institute of Standards and
Technology (NIST), NIST Study Evaluates Effects of Race, Age, Sex on Face Recognition Software (Dec. 19,
2019), https://www.nist.gov/news-events/news/2019/12/nist-study-evaluates-effects-race-age-sex-face-recognition-
software (finding demographic differentials in the majority of the 189 face recognition algorithms studied, and
noting that “a false positive in a one-to-many search puts an incorrect match on a list of candidates that warrant
further scrutiny”).
States should be aware that 29 CFR § 38.51 requires UI program administrators to conduct statistical or other
quantifiable data analyses of demographic records and data to determine whether their UI programs and activities
are being conducted in a nondiscriminatory way.
Below are a few examples of data points and information that can be used to conduct
meaningful analysis, monitor equity outcomes, and make necessary changes to ensure
equitable access.
• PII and data on an individual’s ID proofing status (i.e., verified, not verified,
pending, inconclusive) within a service provider’s system or solution to identify
any disparate results amongst demographic groups or specific friction points
within the ID proofing process, such as:
o Data from individuals who successfully verify through alternative
method(s) after failing initial screenings, including appeals data;
o Number of ID proofing attempts each user is making;
o Time spent in the system at each identification step;
o Wait time for customer service requests related to ID proofing;
o Location, device type, and connection type;
o The strength of the identification match; and
o System, monitoring, and incident reports.
• How many claimants used a non-digital option to verify their ID including:
o what caused them to be unable to access the technology (if applicable);
o what caused them to be denied by the technology (if applicable); and
o which alternative access option was used.
• Which claims were flagged as suspicious and warranting further investigation,
including:
o the length of time to resolve these investigations; and
o the outcome of these investigations, such as whether they resulted in a
fraudulent overpayment, non-fraudulent overpayment,
suspected/confirmed ID fraud, claim abandoned during the ID verification
process, or a non-issue (i.e., “false positive”), by demographic group.
Additionally, ETA strongly recommends conducting root cause analysis to identify the
source of specific instances where legitimate claimants have been adversely affected by
UI program integrity measures (i.e., fraud risk scoring, fraud prevention and detection
activities, ID proofing systems or solutions). State root cause analysis should seek to
identify issues that may exist at larger scale and may merit more systemic modifications
to the state’s overall fraud risk mitigation and improper payment reductions strategies,
including ID verification and fraud prevention and detection activities.
e. Protecting Victims of UI ID Fraud. States must provide individuals who suspect that
they are victims of UI ID fraud with options to report such activity and, once fraud has
been confirmed, states must take actions to protect the UI ID fraud victim. To meet these
requirements, ETA strongly recommends that states provide a reporting mechanism for
UI ID fraud on their websites, communicate status updates for such investigations, and
take action to protect the victim when the state determines that UI ID fraud has occurred.
i. Providing a reporting mechanism for UI ID fraud on state websites. As
described in Section 5 of UIPL No. 16-21, states must provide individuals who
suspect that their ID has been stolen with easily accessible options to report such
theft or fraudulent activity. This may include dedicated phone options, email
addresses, or an online portal by which individuals can notify the state agency.
States may also provide links to resources from other agencies that specialize in
protecting consumers and their PII, such as the Federal Trade Commission’s
Consumer website at IdentityTheft.gov.
In December 2022, the Department published updated website content on the UI
ID fraud reporting website at www.dol.gov/fraud. ETA issued TEN No. 14-22,
on January 4, 2023, strongly encouraging states to align their website content and
communications for individuals who experience UI ID fraud with the new
content, resources, and reporting requirements outlined at
https://www.dol.gov/fraud.
ii. Communicating status updates. ETA strongly recommends that states clearly
communicate their UI fraud reporting requirements on their state website(s) and
have in place established processes and procedures for assisting individuals who
have experienced UI ID fraud. To reduce confusion and anxiety for a victim of
UI ID fraud, states should provide updates throughout the process once a report of
UI ID fraud has been received. This may include, but is not limited to:
• Providing confirmation to the submitter that the fraud report was received;
• Clearly defining expectations and outlining next steps;
• Providing ongoing updates to the submitter and/or SSN owner (if known)
throughout the investigation; and
• Notifying the submitter and/or SSN owner (if known) once the
investigation is complete.
iii. Protecting victims. When a state determines that UI ID fraud has occurred the
state must take actions to protect the rights of the UI ID fraud victim. As
discussed in UIPL No. 20-21, Change 1, once the state issues a fraud
determination, one option states can use to mitigate negative impacts on the UI ID
fraud victim is to establish a pseudo claim record and transfer all claim
information regarding the fraudulent activity to the pseudo claim. This removes
the fraudulent activity from the victim's SSN and/or UI account, which should
remove barriers the victim may encounter if they need to file for UI in the future.
This solution also applies to “claim hijacking” (also known as “claim or account
takeover”). On hijacked claims, any weeks that were fraudulently redirected must
be removed from the legitimate UI claim and the weeks must be immediately
repaid to the rightful owner of the claim if eligibility for those weeks is
determined. In the case of hijacked claims, the state should employ ID
verification as part of its investigation to verify the legitimate claimant’s ID prior
to repaying the weeks.
States are also strongly encouraged to use the UI Integrity Center’s IDH BAV
service to authenticate new bank account information provided on all claims prior
to issuing payments, including verifying bank account information on claims that
have been determined to be hijacked, prior to reissuing any payments. The IDH’s
BAV service validates the status of the bank account (e.g., account is open or
closed) and provides a level of assurance that the individual identified as the UI
claimant is the bank account owner and/or authorized user.
States that may not have the current administrative capability to move such
activity to a pseudo claim may choose to temporarily mark the overpayment as
“uncollectible.” This ensures that UI ID fraud victims are not negatively
impacted while the state develops a process to disassociate the fraudulent activity
from the victim’s SSN. Below are other actions the state may take to mitigate the
negative consequences for the UI ID fraud victim:
• Ensure that if a future claim is filed under the victim’s SSN, the claimant
undergoes a secondary ID verification process (e.g., include an in-person
reporting requirement or other expanded ID verification alternatives).
However, states should try to minimize the burden on the victim as much
as possible when verifying identity.
• Ensure that the owner of the SSN is not held responsible for any
overpayment and, whenever possible, is not issued a Form 1099G at the
end of the year.
• Exclude the overpayment from TOP and suspend any Benefit Payment
Control collection activity for the actual owner of the SSN.
• Do not initiate any legal actions against the actual owner of the SSN.
f. Additional Important Resources, Strategies, Tools, and Services for States. As noted
above, fraud prevention and detection activities, as well as overpayment recovery
activities, are strongest when states employ a variety of tools, strategies, and resources.
ETA reminds states of the many other resources available to support states with ID
verification, fraud prevention and detection, and overpayments recovery.
i. ETA’s Regional Offices. ETA’s Regional Offices are available to provide states
with ongoing technical assistance regarding integrity strategies, tools, and
services and to connect states with such resources supported and funded by the
Department. States are encouraged to work closely with ETA’s Regional Offices
to address root causes of fraud and improper payments and in developing IAPs
and any needed corrective action plans.
ii. Tiger Teams. The Department’s multidisciplinary technical assistance teams
(known as Tiger Teams) work with states to conduct consultative assessments to
address state-specific, unique challenges and/or collect best practices to prevent
and detect fraud, promote equitable access, reduce backlogs, and ensure timely
payment of benefits. Tiger Teams work with states to identify immediate needs
and issues focused on near-term improvements in customer experiences and
improved operational processes, while also proposing grant funded
recommendations to address fraud and support more equitable access for
legitimate claimants. The Department engaged with 24 states for the Tiger Team
initiative in Year 1 (July 2021 - June 2022) of the project and continues to finalize
and deliver recommendations to states based on Tiger Team consultative
assessments. Trends from Tiger Team recommendations are available at:
https://oui.doleta.gov/unemploy/pdf/TigerTeamCohortTrendsJune_2022.pdf.
ETA strongly encourages all states to engage in a Tiger Team consultative
assessment. See UIPL Nos. 02-22 and UIPL 02-22 Change 2.
iii. UI Integrity Center. Established and funded by the Department and operated by
the National Association of State Workforce Agencies (NASWA) Center for
Employment Security Education and Research (CESER), the UI Integrity Center
is designed to assist states in their efforts to prevent, detect, and recover improper
and fraudulent payments and improve program integrity by developing and
promoting innovative program strategies. The UI Integrity Center supports the
needs of states in adopting and implementing strategies to ensure program
integrity, to reduce the UI improper payment rate, and to address fraud in UC
programs. The following resources and tools are available through the UI
Integrity Center at no costs to states.
A. 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.
B. 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.
The Library also contains the Behavioral Insights (BI) Toolkit – a
collection of resources, articles, templates, and how-to information
developed to help state UI agencies apply the learnings of BI to address
program compliance challenges and improve UI program integrity. See
TEN No. 15-21.
C. 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.
D. Integrity Data Hub (IDH) – a secure, robust, centralized, multi-state data
system that allows participating states to cross-match, compare, and
analyze state UC claims data against a variety of datasets. See TEN No.
24-21. Current IDH datasets and functionality includes:
• Suspicious Actor Repository (SAR) – allows states to match UI
claims against other states’ known suspicious claims data. This
tool allows each state to benefit from the investigative work of all
states as claims data associated with known or probable UI fraud is
submitted and stored in the SAR for cross-matching purposes.
• Suspicious E-Mail Domains and Patterns – allows states to cross-
match their claims against a database of suspicious e-mail domains
and detects suspicious email patterns, that have been associated
with fraudulent activity, and flags claims with these domains
and/or patterns for further investigation by the submitting state.
• Foreign Internet Protocol (IP) address detection – allows states to
receive flags on UI claims filed from IP addresses outside of the
U.S.
• Multi-State Cross-Match (MSCM) – states can submit current UI
claims for cross-matching and receive notifications when
potentially fraudulent claims are filed in multiple states.
• Identity Verification (IDV) Solution – provides states with a
centralized, front-end identity verification tool by returning
identity scoring information, including flagging of false and
synthetic identities, to help states prioritize investigations
involving questionable identities. The IDV solution includes a
cross-match to the SSA’s Death Master File to identify claims filed
using identities of deceased individuals.
• Bank Account Verification (BAV) Service – allows states to
proactively identify and authenticate bank account information on
the UI claim by validating the status of the bank account (e.g.,
account is open or closed) and providing a level of assurance that
the individual identified as the claimant is the bank account owner
and/or authorized user prior to initiating the UI benefit payment.
• Fraud Alert System – allows states to share and receive fraud alerts
with each other and DOL-OIG, ensuring as emerging fraud
schemes are identified they are shared broadly within the UI
community and with federal law enforcement.
Additionally, new IDH enhancements, such as IDH Results Prioritization
and Results Sorting, Filtering, and Outcomes, allow states to prioritize,
analyze, and manage IDH results quickly and easily, and help states
identify why a claim warrants further investigations.
iv. Office of Unemployment Insurance Modernization (OUIM). OUIM, located
within the Department’s Office of the Secretary, is developing services to assist
states with equitable practices that reduce claimant errors which contribute to
improper payments. These services include plain language conversions,
evaluation of customer experiences, and assistance with design of digital
experiences that minimize friction for users. States are encouraged to contact
their ETA Regional Office to inquire about technical assistance and participation
in OUIM modernization pilots and activities. States may also visit OUIM’s
reference site where promising practices and materials related to IT modernization
and updates from Department-sponsored engagements are housed. The reference
site is located at https://www.dol.gov/agencies/eta/ui-modernization.
v. UI Information Technology Support Center (UI ITSC). ETA created UI ITSC
in 1994 through a cooperative agreement with the State of Maryland to develop
products and services and to support state UI agencies in the use of IT for
efficient administration of the UI program. Since 2009, NASWA CESER has
operated the UI ITSC. UI ITSC’s activities involve providing information
technical assistance, products, and services to states in support of the
modernization of IT systems used to administer the UI program. For more
information on UI ITSC visit http://www.itsc.org.
vi. SIDES. State implementation and employers’ use of SIDES should be an integral
part of a state’s IAP. See TEN No. 12-16 and information available at
https://www.naswa.org/uisides. States should view SIDES as a critical part of
their UI integrity efforts and are encouraged to connect to all available SIDES
Exchanges. See UIPL No. 17-22 for details on the SIDES Exchanges.
vii. PUPS. To be eligible for UI benefits, an individual must be able, available, and
actively seeking work. Incarcerated individuals do not typically meet the
eligibility requirements to receive UI benefit payments. ETA worked in
partnership with SSA to establish a secure data exchange between ICON and
SSA’s PUPS to provide states with the ability to cross-match UI claims data with
incarceration records to assist states in making accurate UI eligibility
determinations. See UIPL No. 01-22. States are strongly encouraged to cross-
match all UC claims against incarceration datasets, including PUPS and/or other
federal, state, and local incarceration records.
viii. DOL-OIG. ETA recommends states build a strong partnership with their DOL-
OIG offices. ETA encourages all states to collaborate with their ETA Regional
Offices and DOL-OIG to share fraud trends and analysis, discuss
recommendations and effective strategies for responding to emerging fraud
schemes, receive updates on prosecution efforts, and facilitate sharing of UI fraud
and integrity-related challenges and best practices among states.
ix. Other Department-Funded Resources and Services for Project Execution. The
Department has made available to states, operational and technical resources and
services to further support execution of states’ APRA-related grant projects,
including future ARPA formula funded grant programs (see UIPL No. 03-23).
These resources include such services as Project Management, Change
Management, State-specific IT programming/development support, System
application enhancements, Department-led initiatives, and UI operations subject
matter expertise.
g. Funding for States to Strengthen UI Program Integrity, Including ID Verification,
Fraud Prevention and Detection, and Overpayment Recovery Efforts in All UC
Programs. This section discusses the grants available to states under this UIPL,
including the amount available to each state, allowable uses of grant funds, application
instructions, and reporting requirements. These grants are subject to the requirements of
2 C.F.R. Parts 200 and 2900, Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards.
i. Amount Available to States.16 The Department is providing up to $200 million
in additional funding to states to strengthen UI program integrity, including ID
verification, fraud prevention and detection, and overpayment recovery efforts in
all UC programs. The methodology for state funding levels is based on size of UI
covered employment in the state. For purposes of this methodology, states are
assigned to four groups (Small, Medium, Large, and Extra-Large) based on the
12-month average of UI covered employment for the four quarters in calendar
year 2021 reported on the ES 202 (Employment, Wages and Contributions)
report. States are assigned to the size groups as follows:
Since Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, the Federated States of
Micronesia, the Republic of the Marshall Islands, and the Republic of Palau do not operate regular UC programs, this
grant opportunity is not being made available to these jurisdictions.
• Small: covered employment under 1 million employees
• Medium: covered employment between 1 million and 2 million employees
• Large: covered employment between 2 million and 7 million employees
• Extra Large: covered employment greater than 7 million employees
Attachment I provides the funding available for each state.
ii. Allowable Use of Funds. States must use the funds made available under this
UIPL to strengthen ID verification and other fraud prevention and detection and
overpayment recovery efforts in all UC programs. Types of costs may include the
procurement and implementation of tools, payment of subscription costs, and
hiring of investigative staff.17
Examples of permissible uses of these funds include, but are not limited to, the
activities listed below. The term “effectiveness” refers to a state's ability to
properly detect suspicious activity, investigate in a timely manner, and mitigate
barriers to equitable access.
• Establishing and refining the state’s risk-based approach to determine
which claims are subject to evidence-based verification as described in
Section 4.a. of this UIPL;
• Implementing new or maintaining enhancing existing ID verification
solutions and/or procedures to verify the identity of individuals filing for
UC;
• Strengthening the effectiveness of how the state uses required fraud
prevention and detection activities and required overpayment recovery
activities as described in Sections 4.b. and 4.c. of this UIPL;
• Implementing new and strengthening the effectiveness of how states use
recommended fraud prevention and detection activities and recommended
overpayment recovery activities as described in Sections 4.b. and 4.c. of
this UIPL;
• Establishing and refining the state’s use of data, including through the use
of activities such as filing metrics and customer surveys, to monitor and
adapt the effectiveness of tools used to combat UI ID fraud and other
improper payments as described in Section 4.d. of this UIPL;
• Establishing and refining external communication protocols when states
receive reports of UI ID fraud as described in Section 4.e. of this UIPL;
• Establishing and refining protections for victims of UI ID fraud as
described in Section 4.e. of this UIPL; and
States are reminded of the ability to exercise flexibility in staffing models for the performance of certain UC
administrative activities, as described in UIPL No. 12-01, Change 2.
• States may also use the funds made available under Section 4.g.i. of this
UIPL for the same activities described in Section 5.b. of UIPL No. 22-21.
iii. Allowable Uses for Remaining Balances under Allotment in UIPL No. 22-21.
States with remaining balances from grants awarded under UIPL No. 22-21 may
use such funding for the additional activities described in Section 4.g.ii. of this
UIPL. We note that the period of performance for grants under UIPL No. 22-21
currently ends on September 30, 2023. For this reason, states are strongly
encouraged to obligate funding from that grant before funding from this grant.
iv. Period of Performance for the Grant. These grant funds must be obligated by
states by December 31, 2025. All funds must be liquidated within 90 days
thereafter. Funding for state staff may not be obligated for use at a future date
and the obligation may only occur at the time the staff performs services on the
project/activity.
v. Relationship to Other Grant Opportunities. ETA recognizes that states have
received grant funding for other purposes18 and encourages states to consider all
grant funded activities when determining which activities to fund under this grant
funding opportunity. Activities funded under this UIPL should not be duplicative
of the activities funded under other grant opportunities, but should instead be
complementary, either expanding on or enhancing existing efforts, implementing
new tools, strategies, or solutions, or improving processes and/or procedures.
h. Required Disclosure to DOL-OIG. As discussed in UIPL No. 04-17, Change 1, states
must refer allegations which they reasonably believe constitute UC fraud, waste, abuse,
mismanagement, or misconduct to the DOL-OIG. As a condition to receiving grants
awarded under UIPL No. 22-21, the state agreed to provide all confidential UC
information to DOL-OIG for purposes of both investigating fraud and performing audits
through weeks of unemployment ending before December 31, 2023.
As a condition of receiving funding through the solicitation announced in this UIPL
(UIPL No. 22-21, Change 2), the state must agree to continue to provide all confidential
UC information to DOL-OIG for purposes of both investigating fraud and performing
audits through weeks of unemployment ending before December 31, 2025.
States may use funds awarded under this UIPL, the UI administrative grant under Section
302(a), SSA, or another source of funding to pay any expenses incurred for this
disclosure. See 20 C.F.R. 603.8(b).
Additional grant opportunities include CARES Act integrity funding under UIPL Nos. 28-20; 28-20, Change 1;
28-20, Change 2; and 28-20, Change 4, ARPA integrity funding under UIPL No. 22-21, ARPA equity funding under
UIPL No. 23-21, ARPA UI navigator funding under UIPL No. 11-22, and ARPA Tiger Team funding under UIPL
No. 02-22.
i. Application Instructions. States are required to submit an application that includes: (1)
the grant application as provided in Attachment II to this UIPL; (2) the SF-424 and SF-
424A as provided in Attachment III to this UIPL; and (3) a Budget Narrative as provided
in Attachment IV of this UIPL. The grant application must include details on the activity
or activities for which the funds will be used, in accordance with the permissible uses
outlined in Section 4.g.ii. of this UIPL.
ETA encourages states to submit these forms as soon as possible, but no later than July
26, 2023, via www.grants.gov.
In order to attest compliance with the requirement to receiving this funding under Section
4.h. of this UIPL, states should check the “I AGREE” box under Item 21 and include the
appropriate language in Item 15 as indicated in the instructions for completing the SF-
424. Additionally, please note that states should maintain any supporting documentation
that serves as evidence for meeting the required DOL-OIG disclosure in this UIPL.
j. Reporting Requirements. States must provide a narrative Quarterly Progress Report
(ETA 9178-ARPA) and Quarterly Financial Report (ETA 9130) containing updates on
the progress and implementation of each grant project/activity. The form ETA 9178-
ARPA is provided as Attachment V. ETA will use the ETA 9178-ARPA report to track
each state’s progress in addressing UI program integrity with ARPA funds, ensuring that
a state’s use of funds is consistent with the permissible solutions/activities outlined in
section 4.g.ii. of this UIPL and ensuring fraud prevention solutions/activities do not have
a negative impact on access to benefits for legitimate claimants. Although a state may
use the funding under this UIPL to expand upon existing UI program integrity activities
and/or conduct activities similar to activities being funded under UIPL No. 22-21, states
are required complete and submit separate 9178-ARPA reports for each of the two ARPA
integrity funding opportunities. See discussion in Section 4.g.v above.
States must provide their ETA Regional Office with an ETA 9178-ARPA narrative
update quarterly that identifies the specific issue a state’s proposed solutions/activities
will impact, and report specific outcome metrics as they relate to the solutions/activities,
including service delivery expectations that mitigate access barriers to individuals. Refer
to Attachment V for instructions for completion and the timeline of submission for the
ETA 9178-ARPA.
5. Inquiries. States should direct inquiries to the appropriate ETA Regional Office.
Submissions for the funding opportunities under this UIPL are due by the close of business
on July 26, 2023.
6. References.
• American Rescue Plan Act of 2021 (ARPA), including Title IX, Subtitle A, Crisis
Support for Unemployed Workers (Pub. L. 117-2);
• Consolidated Appropriations Act, 2021, including Division N, Title II, Subtitle A, the
Continued Assistance for Unemployed Workers Act of 2020 (Pub. L. 116-260);
• Coronavirus Aid, Relief, and Economic Security (CARES) Act, Title II, Subtitle A –
Relief for Workers Affected by Coronavirus Act (Pub. L. 116-136);
• Section 188 of the Workforce Innovation and Opportunity Act (WIOA), 29 U.S.C.
§3248;
• Section 303 of the Social Security Act (SSA), 42 U.S.C. §503;
• Section 1137 SSA, 42 U.S.C. §1320b-7;
• Section 3304 of the Federal Unemployment Tax Act (FUTA), 26 U.S.C. §3304;
• Section 6402(f) of the Internal Revenue Code (IRC), 26 U.S.C. §6402(f);
• 2 C.F.R. Parts 200 and 2900, Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards;
• 20 C.F.R. Part 603;
• 29 C.F.R. Part 38;
• Executive Order 13985 of January 20, 2021; 86 FR 7009, page 7009-7013,
https://www.federalregister.gov/documents/2021/01/25/2021-01753/advancing-racial-
equity-and-support-for-underserved-communities-through-the-federal-government;
• UIPL No. 03-23, Availability of U.S. Department of Labor (Department) Funded
Resources and Services to State American Rescue Plan Act (ARPA) Grantees, issued
March 6, 2023, https://www.dol.gov/agencies/eta/advisories/uipl-03-23;
• UIPL No. 17-22, Additional Planning Guidance for the Fiscal Year (FY) 2023
Unemployment Insurance (UI) State Quality Service Plan (SQSP), issued July 22, 2022,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
17-22;
• UIPL No. 11-22, Grant Opportunity for States to Participate in the American Rescue
Plan Act (ARPA) Unemployment Insurance (UI) Navigator Program, issued January 31,
2022, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-
letter-no-11-22;
• UIPL No. 02-22, Change 2, Extension of Time for States to Express Interest in the Grant
Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No. 02-22,
to Support States Following a Consultative Assessment for Fraud Detection and
Prevention, Promoting Equitable Access, and Ensuring the Timely Payment of Benefits,
including Backlog Reduction, for all Unemployment Compensation (UC) Programs,
issued September 19, 2022, https://www.dol.gov/agencies/eta/advisories/uipl-02-22-
change-2;
• UIPL No. 02-22, Change 1, Extension of Time for States to Express Interest in the Grant
Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No. 2-22 to
Support States Following a Consultative Assessment for Fraud Detection and Prevention,
Promoting Equitable Access, and Ensuring the Timely Payment of Benefits, including
Backlog Reduction, for all Unemployment Compensation (UC) Programs, issued
February 16, 2022, https://www.dol.gov/agencies/eta/advisories/unemployment-
insurance-program-letter-no-02-22-change-1;
• UIPL No. 02-22, Grant Opportunity to Support States Following a Consultative
Assessment for Fraud Detection and Prevention, Promoting Equitable Access, and
Ensuring the Timely Payment of Benefits, including Backlog Reduction, for all
Unemployment Compensation (UC) Programs, issued November 2, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-22;
• UIPL No. 01-22, Announcing the Availability of an Incarceration Data Exchange and
Instructions to Access the Data Exchange between the Unemployment Insurance (UI)
Interstate Connection Network (ICON) and the Social Security Administration (SSA)
Prisoner Update Processing System (PUPS), issued October 29, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
01-22;
• UIPL No. 23-21, Grant Opportunity for Promoting Equitable Access to Unemployment
Compensation (UC) Programs, issued August 17, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
23-21;
• UIPL No. 22-21, Change 1, Extension of Time to Submit Request for Funding under
Grant Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No.
22-21, issued September 17, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
22-21-change-1;
• UIPL No. 22-21, Grant Opportunity to Support States with Fraud Detection and
Prevention, Including Identity Verification and Overpayment Recovery Activities, in All
Unemployment Compensation (UC) Programs, issued August 11, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
22-21;
• UIPL No. 20-21, Change 1, Additional State Instructions for Processing Waivers of
Recovery of Overpayments under the Coronavirus Aid, Relief, and Economic Security
(CARES) Act, as Amended, issued February 07, 2022,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
20-21-change-1;
• UIPL No. 20-21, State Instructions for Assessing Fraud Penalties and Processing
Overpayment Waivers under the Coronavirus Aid, Relief, and Economic Security
(CARES) Act, as Amended, issued May 5, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
20-21;
• UIPL No. 19-21, Benefits Held by Banks and Financial Institutions as a Result of
Suspicious and/or Potentially Fraudulent Activity and the Proportional Distribution
Methodology Required for Recovering/Returning Federally Funded Unemployment
Compensation (UC) Program Funds, issued May 04, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
19-21;
• UIPL No. 16-21, Identity Verification for Unemployment Insurance (UI) Claims, issued
April 13, 2021, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-
program-letter-no-16-21;
• UIPL No. 04-21, Unemployment Insurance (UI) Information Technology (IT) Security –
Additional Information, issued November 2, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-21;
• UIPL No. 28-20, Change 5, Extension of Time to Submit Request for Funding under
Grant Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No.
28-20, Change 4, issued October 17, 2022,
https://www.dol.gov/agencies/eta/advisories/uipl-28-20-change-5;
• UIPL No. 28-20, Change 4, Support for States to Resolve Outstanding Items from the
Expired Coronavirus Aid, Relief, and Economic Security (CARES) Act Unemployment
Compensation (UC) Programs, Including Additional Funding to Assist States with
Reporting and Detection and Recovery of Overpayments, issued July 22, 2022,
https://www.dol.gov/agencies/eta/advisories/uipl-no-28-20-change-4;
• UIPL No. 28-20, Change 3, Extension of Time to Submit Request for Funding under
Grant Opportunity Announced in Unemployment Insurance Program Letter (UIPL) No.
28-20, Change 2, issued September 17, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20-change-3;
• UIPL No. 28-20, Change 2, Additional Funding to Assist with Strengthening Fraud
Detection and Prevention Efforts and the Recovery of Overpayments in the Pandemic
Unemployment Assistance (PUA) and Pandemic Emergency Unemployment
Compensation (PEUC) Programs, as well as Guidance on Processes for Combatting
Identity Fraud, issued August 11, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20-change-2;
• UIPL No. 28-20, Change 1, Additional Funding for Identity Verification or Verification
of Pandemic Unemployment Assistance (PUA) Claimants and Funding to Assist with
Efforts to Prevent and Detect Fraud and Identity Theft as well as Recover Fraud
Overpayments in the PUA and Pandemic Emergency Unemployment Compensation
(PEUC) Programs, issued January 15, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20-change-1;
• UIPL No. 28-20, Addressing Fraud in the Unemployment Insurance (UI) System and
Providing States with Funding to Assist with Efforts to Prevent and Detect Fraud and
Identity Theft and Recover Fraud Overpayments in the Pandemic Unemployment
Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC)
Programs, issued August 31, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
28-20;
• UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program and
the UI Programs Authorized by the Coronavirus Aid, Relief, and Economic Security
(CARES) Act of 2020 - Federal Pandemic Unemployment Compensation (FPUC),
Pandemic Unemployment Assistance (PUA), and Pandemic Emergency Unemployment
Compensation (PEUC) Programs, issued May 11, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
23-20;
• UIPL No. 13-20, Change 2, Families First Coronavirus Response Act, Division D
Emergency Unemployment Insurance Stabilization and Access Act of 2020 (EUISAA) -
Review of State Compliance for Receipt of Emergency Administrative Grants and
Clarification on Benefit Offset Requirements, issued June 3, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
13-20-change-2;
• UIPL No. 04-20, Treasury Offset Program (TOP) Revised and Clarified Requirements
for Referring Unemployment Compensation (UC) Debts for Recovery through Federal
Tax Refund Offset, issued December 16, 2019,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-20;
• UIPL No. 13-19, National Directory of New Hires (NDNH) and State Directory of New
Hires (SDNH) Guidance and Best Practices, issued June 7, 2019,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
13-19;
• UIPL No. 02-19, Recovery of Certain Unemployment Compensation Debts under the
Treasury Offset Program, issued December 12, 2018,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-19;
• UIPL No. 14-17, States' Responsibilities for Internal Security in the Unemployment
Insurance Program, issued March 23, 2017,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
14-17;
• UIPL No. 04-17, Change 1, Requirement for States to Refer Allegations of
Unemployment Compensation (UC) Fraud, Waste, Abuse, Mismanagement, or
Misconduct to the Department of Labor's (Department) Office of Inspector General's
(DOL-OIG) and to Disclose Information Related to the Coronavirus Aid, Relief, and
Economic Security (CARES) Act to DOL-OIG for Purposes of UC Fraud Investigation
and Audits, issued August 3, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-17-change-1;
• UIPL No. 02-16, Change 1, State Responsibilities for Ensuring Access to Unemployment
Insurance Benefits, Services, and Information, issued May 11, 2020,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
02-16-change-1;
• UIPL No. 02-16, State Responsibilities for Ensuring Access to Unemployment Insurance
Benefits, issued October 1, 2015,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
2-16;
• UIPL No. 01-16, Change 1, Federal Requirements to Protect Claimant Rights in State
Unemployment Compensation Overpayment Prevention and Recovery Procedures -
Questions and Answers, issued January 13, 2017,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
1-16-change-1;
• UIPL No. 01-16, Federal Requirements to Protect Individual Rights in State
Unemployment Compensation Overpayment Prevention and Recovery Procedures, issued
October 1, 2015, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-
program-letter-no-01-16;
• UIPL No. 12-14, Required Use of the Treasury Offset Program to Collect Covered
Unemployment Compensation Debt, issued May 20, 2014,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-
no12-14;
• UIPL No. 11-14, Collection and Analysis of Claimant Demographic Data, issued May
15, 2014, https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-
program-letter-no11-14;
• UIPL No. 05-13, Work Search and Overpayment Offset Provisions Added to Permanent
Federal Unemployment Compensation Law by Title II, Subtitle A of the Middle Class Tax
Relief and Job Creation Act of 2012, issued January 10, 2013,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
05-13;
• UIPL No. 19-11, National Effort to Reduce Improper Payments in the Unemployment
Insurance (UI) Program, issued June 10, 2011,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
19-11;
• UIPL No. 12-01, Change 2, States’ Ability to Exercise Flexibility in Staffing Models for
the Performance of Certain Unemployment Compensation (UC) Administrative
Activities, issued January 8, 2021,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
12-01-change-2;
• UIPL No. 04-01, Payment of Compensation and Timeliness of Determinations during a
Continued Claims Series, issued October 27, 2000,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
04-01;
• UIPL No. 35-95, The Department of Labor’s Position on Issues and Concerns Associated
with the Utilization of Telephone and Other Electronic Methods in the Unemployment
Insurance (UI) Program, issued June 28, 1995,
https://www.dol.gov/agencies/eta/advisories/unemployment-insurance-program-letter-no-
35-95;19
• TEN No. 14-22, Updated Unemployment Insurance (UI) Identity (ID) Fraud Reporting
Website Content, issued January 4, 2023,
https://www.dol.gov/agencies/eta/advisories/ten-14-22;
• TEN No. 05-22, Authority of the U.S. Department of Labor’s (Department) Office of
Inspector General (DOL-OIG) to Receive Confidential Unemployment Compensation
(UC) Data, issued September 15, 2022,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-05-22;
• TEN No. 24-21, Encouragement for States to Use the Integrity Data Hub (IDH)
available through the Unemployment Insurance (UI) Integrity Center, issued May 5,
2022, https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-
24-21;
• TEN No. 16-21, Announcing Grant Awards Made to States Selected to Participate in the
Unemployment Insurance (UI) Information Technology (IT) Modernization Project -
Claimant Experience Pilot, issued December 2, 2021,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-16-21;
• TEN No. 15-21, Announcing the National Association of State Workforce Agencies
(NASWA) Unemployment Insurance (UI) Integrity Center's Behavioral Insights Toolkit,
issued November 17, 2021, https://www.dol.gov/agencies/eta/advisories/training-and-
employment-notice-no-15-21;
• TEN No. 06-21, Accessing Unemployment Insurance (UI) Identity Verification and
Fraud Protection (Identity Proofing) Services using the U.S. Department of Labor’s
(Department) Blanket Purchase Agreements (BPA), issued September 15, 2021,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-06-21;
• TEN No. 05-20, National Directory of New Hires (NDNH), State Directory of New Hires
(SDNH), and Other Improper Payment Prevention and Detection Resources, Tools, and
Services Available to States, issued September 24, 2020,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-05-20;
• TEN No. 04-20, Encouragement for States to Use the Integrity Data Hub (IDH)
available through the Unemployment Insurance (UI) Integrity Center, issued August 31,
2020, https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-
04-20;
• TEN No. 03-20, Unemployment Insurance (UI) Integrity Center’s Integrity Data Hub
(IDH) Fraud Alert System, issued August 31, 2020,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-03-20;
• TEN No. 12-16, Unemployment Insurance (UI) State Information Data Exchange
Systems (SIDES), issued September 27, 2016,
https://www.dol.gov/agencies/eta/advisories/training-and-employment-notice-no-12-16;
and
Although this UIPL shows an expiration date of June 30, 1996, TEN No. 26-21 (published May 24, 2022)
confirms that it is still active.
• Employment Security Manual, Section 7511, The Secretary’s Interpretation of Federal
Law Requirements, available at 20 C.F.R. Part 614, Appendix C, Standard for Fraud and
Overpayment Detection.
7. Attachment(s).
• Attachment I: State Size Classifications and Funding Allocation to Support States in
Strengthening Identity (ID) Verification and Improving Fraud Prevention, Detection,
and Overpayment Recovery Efforts in All Unemployment Compensation (UC)
Programs.
• Attachment II: Grant Application for Strengthening Identity (ID) Verification and
Improving Fraud Prevention, Detection, and Overpayment Recovery Efforts in All
Unemployment Compensation (UC) Programs.
• Attachment III: Instructions for Completing the SF-424 and SF-424A.
• Attachment IV: General Instructions for the Completion of a Budget Information
Narrative.
• Attachment V: Form ETA 9178-ARPA Quarterly Narrative Progress Report.
• Attachment VI: Identity (ID) Proofing Services and Solutions Recommended Contract
Provisions.
Attachment I to UIPL No. 22-21, Change 2
State Size Classifications and Funding Allocation to Support States in Strengthening
Identity (ID) Verification and Improving Fraud Prevention, Detection, and Overpayment
Recovery Efforts in All Unemployment Compensation (UC) Programs
State Size Classification UC Fraud Funding Allotment
Alabama Medium $3,480,000
Alaska Small $1,740,000
Arizona Large $5,220,000
Arkansas Medium $3,480,000
California Extra Large $6,935,000
Colorado Large $5,220,000
Connecticut Medium $3,480,000
Delaware Small $1,740,000
District of Columbia Small $1,740,000
Florida Extra Large $6,935,000
Georgia Large $5,220,000
Hawaii Small $1,740,000
Idaho Small $1,740,000
Illinois Large $5,220,000
Indiana Large $5,220,000
Iowa Medium $3,480,000
Kansas Medium $3,480,000
Kentucky Medium $3,480,000
Louisiana Medium $3,480,000
Maine Small $1,740,000
Maryland Large $5,220,000
Massachusetts Large $5,220,000
Michigan Large $5,220,000
Minnesota Large $5,220,000
Mississippi Medium $3,480,000
Missouri Large $5,220,000
Montana Small $1,740,000
Nebraska Small $1,740,000
Nevada Medium $3,480,000
New Hampshire Small $1,740,000
New Jersey Large $5,220,000
New Mexico Small $1,740,000
New York Extra Large $6,935,000
North Carolina Large $5,220,000
North Dakota Small $1,740,000
Ohio Large $5,220,000
Oklahoma Medium $3,480,000
Oregon Medium $3,480,000
Pennsylvania Large $5,220,000
Puerto Rico Small $1,740,000
Rhode Island Small $1,740,000
South Carolina Large $5,220,000
South Dakota Small $1,740,000
Tennessee Large $5,220,000
Texas Extra Large $6,935,000
Utah Medium $3,480,000
Vermont Small $1,740,000
Virgin Islands Small $1,740,000
Virginia Large $5,220,000
Washington Large $5,220,000
West Virginia Small $1,740,000
Wisconsin Large $5,220,000
Wyoming Small $1,740,000
U.S. TOTAL $200,000,000
Attachment II to UIPL No. 22-21, Change 2
Grant Application for Strengthening Identity (ID) Verification and Improving Fraud
Prevention, Detection, and Overpayment Recovery Efforts in All Unemployment
Compensation (UC) Programs
Instructions: States must complete the application using the suggested format and
instructions below for the projects/activities for which the state is seeking funding. This
application is to be combined with a completed SF-424, a SF-424A, and Budget Narrative
covering all projects/activities (see Attachment III and IV to this UIPL).
Grant funding for Strengthening Identity (ID) Verification and Improving Fraud
Prevention, Detection, and Overpayment Recovery Efforts in All Unemployment
Compensation (UC) Programs
State Name:
Total Funds Requested:
Name, Title, and Address of Grant Notification Contact (Typically the State Workforce
Agency Administrator)
Name:
Title:
Address:
Name, E-Mail Address, and Phone Number of Grant Project or Fiscal Manager Name:
E-Mail Address:
Telephone Number:
Provide the following information for each project (add additional rows as needed:)
Individual Workload Total Cost of Workload Proposed Completion Date
Project/Activity Name Project/Activity
Name of Funding Activity or Activities
Amount of Funding Request for the Activity or Each Activity
State Contact
Name:
E-Mail Address:
Telephone Number:
Description of Activity or Activities
Project Timeline for Each Activity
Description of Costs:
State Agency Staff Costs:
Type of Position Total Hours Cost Per Hour Total
Contract Staff Costs:
Type of Position Total Hours Cost Per Hour Total
Hardware, Software and Telecommunications Equipment:
Item Description Cost Per Item Quantity Total
Other Costs:
Item Cost Explanation
Strategic Design
Application Instructions
Name of Funding Activity or Activities: Provide the name of the proposed integrity
project/activity to be carried out. If the state is submitting requests to fund more than one
project/activity, each project/activity should be identified by a different name that describes each
project/activity. The state must provide a separate Grant Project Application for each
project/activity they are seeking to have funded by the grant (the applications should match the
projects in the Request Abstract).
Amount of Funding Requested for the Activity or Each Activity: Provide the total amount of
funds requested in this individual project/activity.
State Contact: Provide name, telephone number, and e-mail address of the individual who can
answer any questions relating to the proposal.
Description of Activity or Activities: Provide a brief description of the integrity
project/activity for which the state is seeking funding and explain how the project/activity will
support strengthening the integrity of UC programs for the participating state.
Project Timeline for Each Activity: Provide a list of the dates and the milestones for each
project/activity. The timeline should include the completion of the work, the designation of
specific tasks to appropriate parties, the issuance of a request for proposal, if appropriate, the
projected start date, the proposed dates to begin and complete testing (if necessary), and the
proposed date for full implementation of the project/activity. These milestones and dates will be
used to monitor the implementation of the project/activity. Any additional work needed to
identify and provide progress on the identified outcome metric should be included in this
project/activity timeline.
Description of Costs: Provide an explanation of all costs included in the project/activity.
1. State Agency Staff Costs: Use the table format provided in this attachment to request
state staff to support project/activity implementation.
2. Contract Staff Costs: Use the table format provided in this attachment to request
contract staff to support project/activity implementation.
3. Hardware, Software, and Telecommunications Equipment: Provide an itemized list
of hardware, software, and telecommunications equipment including the cost per item
and the number of each item requested. A description of each item must provide any
information needed to identify the specific item and a description of the size and capacity
of each item if applicable.
4. Other Costs: Identify each item of cost not covered elsewhere and provide the expected
cost per item. The need for each item must be explained.
Strategic Design: The strategic design of the integrity project should provide evidence of a
thorough analysis of current operations and include information supporting how the use of these
funds will provide a return on investment with regards to strengthening UI program integrity in
the UC programs. All activity funded under this UIPL must be complementary rather than
duplicative of activities funded under other grant opportunities.
Attachment III to UIPL No. 22-21, Change 2
Instructions for Completing the SF-424 and SF-424A
Application for Federal Assistance (SF-424)
Use the current version of the form for submission. Expired forms will not be accepted. SF-
424, Expiration Date 11/30/2025, Office of Management and Budget (OMB) Control No.
4040-0004 (Grants.gov).
Section # 8, APPLICANT INFORMATION:
• Legal Name: The legal name must match the name submitted with the System for Award
Management (SAM). Please refer to instructions at https://www.sam.gov/SAM/.
• Employer/Tax Identification Number (EIN/TIN): Input your correct 9-digit EIN and
ensure that it is recorded within SAM.
• Unique Entity Identifier (UEI): Starting on April 4, 2022, the DUNS Number was
replaced by a new, non-proprietary identifier requested in and assigned by the System for
Award Management (SAM) at SAM.gov. This new identifier is being called the Unique
Entity Identifier (UEI), or the Entity ID. To learn more about SAM’s rollout of the UEI,
please visit the U.S. General Service Administration (GSA), Unique Entity Identifier
Update webpage. Before submitting, states must also ensure its registration with
SAM.gov is current. (SAM replaced the Central Contractor Registry.) States can find
instructions for registering with SAM at https://sam.gov/content/entity-registration. An
awardee must maintain an active SAM registration with current information at all times
during which it has an active Federal award or an application under consideration. To
remain registered in the SAM database after the initial registration, states must review
and update the registration at least every 12 months from the date of initial registration.
Failure to register with SAM and maintain an active account will result in a rejection of
your submission.
• Address: Input your complete address including Zipcode+4; Example: 20110-0831. For
lookup, use link at https://tools.usps.com/go/ZipLookupAction_input.
• Organizational Unit: Input appropriate Department Name and Division Name, if
applicable.
• Name and contact information of person to be contacted on matters involving this
application: Provide complete and accurate contact information including telephone
number and email address for the point of contact.
Section # 9, Type of Applicant 1: Select Applicant Type: Input “State Government”.
Section # 10, Name of the Federal Agency: Input “Employment and Training
Administration”.
Section # 11, Catalog of Federal Domestic Assistance Number: Input “17.225”; CFDA
Title: Input “Unemployment Insurance”.
Section # 12, Funding Opportunity Number and Title: Input “UIPL No. 22-21, Change
2, ARPA Fraud Prevention Grant 2023”.
Section # 13, Competition Identification Number: Leave Blank.
Section # 14, Areas Affected by Project: Input the place of performance for the project
implementation; Example “NY” for New York.
Section # 15, Descriptive Title of Applicant’s Project:
• Input “UIPL No. 22-21, Change 2, ARPA Fraud Prevention Grant 2023”.
• Additionally, input: “State attests to meeting the requirement to receive funding as
described in UIPL No. 22-21, Change 2.”
Section # 16, Congressional Districts of
a. Applicant: Input the Congressional District of your home office. For lookup, use
link at www.house.gov with Zip code + 4.
b. Program/Project: Input the Congressional District where the project work is
performed. If it is the same place as your home office, input the congressional district
for your home office. For lookup, use link at www.house.gov with Zipcode+4.
Section # 17, Proposed Project Dates.
a. Start Date: Input a valid start date for the project (earliest start date will be April 1,
2023).
b. End Date: Input a valid end date for the project (December 31, 2025).
Section # 18, Estimated Funding ($):
Input the applicable funding allotment as listed for your state in Attachment I.
Section #s 19 – 20: Complete as per instructions for Form SF-424.
Section # 21, Authorized Representative: Please select the “I AGREE” check box and
provide complete information for your authorized signatory including contact information
such as telephone number and email address. If your Authorized Representative has changed
from your previous application submission for this program, please include a letter from
higher-level leadership authorizing the new signatory for the application submission.
Remember to have the SF-424 signed and dated by the Authorized Representative.
Budget Information - Non-Construction Programs (SF-424A)
• Use the current version of the form for the submission. Expired forms will not be
accepted. SF 424A, Expiration Date 02/28/2025, OMB Control No. 4040-0006
https://apply07.grants.gov/apply/forms/sample/SF424A-V1.0.pdf
• Section B – Budget Categories: Ensure that TOTALS in Section 6, Object Class
Categories matches the Estimated Funding requested in the SF-424.
• If indirect charges are specified in Section 6, Object Class Categories, then include either:
(a) The approved indirect cost rate with a copy of the Negotiated Indirect Cost Rate
Agreement (NICRA), a description of the base used to calculate indirect costs along with
the amount of the base, and the total indirect costs requested; OR
• (b) For those applicant states that meet the requirements to use the 10 percent de minimis
rate as described in 2 C.F.R. 200.414(f), a description of the modified total direct cost
base (see 2 C.F.R. 200.1 for definition) used in the calculation along with the amount of
the base, and the total indirect costs requested based on the 10 percent de minimis rate.
Attachment IV to UIPL No. 22-21, Change 2
General Instructions for the Completion of a
Budget Information Narrative
The Budget Information Narrative must include the following information:
• Each line item on the SF‐424A must be explained, and the cost provided for each. Each
line item on the SF‐424A pertains to projected costs at the recipient level, with the
exception of the Contractual line item. Contractual should include costs at the project
operator level.
• The total for each line item on the Budget Information Narrative must match the total for
each line item on the SF‐424A.
• If a grant modification requests to realign the budget, the narrative must address the
reason for the change in each affected line item.
1. Personnel – List all staff positions by title. State the annual salary of each person, the
percentage of each person’s time devoted to the project, the amount of each person’s
salary funded by the grant, and the total personnel cost for the period of performance.
2. Fringe Benefits – Provide the overall fringe benefit percentage which reflects the
recipient’s organizational fringe, and list the components included, such as health
insurance, FICA, retirement, etc. Provide the fringe benefit calculation for each staff
position listed under the Personnel line item.
3. Travel – Specify the type and purpose of the travel, the number of travelers, approximate
mileage, per diem rates, estimated number of trips, and other associated travel costs.
4. Equipment – Identify each item of equipment to be purchased. Equipment has an
estimated acquisition cost per unit of $5,000 or more, and a useful life of one year or
more. List the quantity and unit cost per item. Items with a unit cost of less than $5,000
are classified as supplies.
5. Supplies – Supplies include all tangible personal property other than “equipment.”
Identify supply categories (e.g., office supplies, cell phones, personal tools for disaster
clean‐up, etc.). List the cost associated with each category.
6. Contractual –
• Identify each project operator and the funding allocation made to the organization.
• Provide total projected costs (NOT for each project operator but as a lump sum)
for each of the following categories: Administrative Costs, Career Services,
Supportive Services, Training (itemize work-based training and classroom
training), and Other Costs (itemized).
7. Construction – Construction costs are not allowed and this line must be left as zero.
Minor alterations to adjust an existing space for grant activities (such as a classroom
alteration) may be allowable. DOL does not consider this as construction and the costs
must be shown on other appropriate lines such as Contractual.
8. Other – List each item in sufficient detail for DOL to determine whether the costs are
reasonable or allowable. Costs included under Other should not fit into any other line
item category.
9. Indirect Charges – If charging indirect costs to the grant, this line item must be
populated. Include the current approved Negotiated Indirect Cost Rate Agreement,
signed by the Federal cognizant agency, as an attachment to the grant application.
Attachment V to UIPL No. 22-21, Change 2
Form ETA 9178-ARPA
U.S. Department of Labor (DOL) OMB No. N/A20
Employment and Training Administration Expiration Date: N/A
Form ETA 9178-ARPA
Quarterly Narrative Progress Report
American Rescue Plan Act (ARPA) Grants
General Information
Report Quarter Date of
State Name: Grant Number:
Ending: Submission:
Project Name: UIPL Number:
Project Contact Information
Name: Agency:
Title Address:
Phone: Ext: City:
E-Mail: State: Zip Code:
Project Report
A. Summary of Project
Please limit your response to 1000 characters or less.
States must use this section to provide a detailed executive summary of the project/activity/solution
(project). Each funded project will have its own separate quarterly progress report (ETA 9178-ARPA)
through the quarter the project ends. States must use this section to provide a short summary of the
project’s purpose. This summary should only change during the life of the grant if the state has received
an approved modification. Modifications only apply to grants that require a full application.
B. Timeline for Grant Activities and Milestones or Deliverables
Please limit your response to 1000 characters or less.
States must use this section to provide the timelines for and the progress in completing grant activities,
key milestones, and deliverables for this quarter. A timeline must still be developed for all project
activities. The timeline must provide a project flow that includes start and end dates, schedule of
activities, and projected outcomes. In order to reap the most benefit from the timeline, the timeline must
be updated each quarter noting the actual date of completion as each activity is accomplished. Items to
incorporate in the timeline include: project goals, milestones, special events, important deadlines and
deliverables.
Refer to section 2116(a) of P.L. 116-136, the Coronavirus Aid, Relief, and Economic Security Act, March 27,
2020.
C. Project Implementation and Funding Status
Please limit your response to 1000 characters or less.
States must use this section to provide a description of the implementation of key activities and/or
project status for the current quarter. Place an ‘X’ in one of the four check-boxes provided below to
provide an assessment of implementation progress. The assessment must be supported by the status
narrative noting if the project is on schedule, behind schedule, ahead of schedule, or complete this
quarter. Once the project is marked as complete this quarter, the state is no longer required to submit an
ETA 9178-ARPA report for the project.
In addition, please provide the funding status for this project for the end of the quarter, including the
total project funding, total obligated, funding balance, and time remaining to expend funds/expenditure
target.
Behind Complete this
State Self- On Schedule Ahead of Schedule
Schedule Quarter
Assessment:
Total Project Funding Total Obligated Funding Balance Expenditure Target
D. Project Challenges, Risk Mitigation Efforts/Modification Requests, and Technical Assistance
Needs
Please limit your response to 1500 characters or less.
States must use this section to summarize any significant challenges to project implementation
encountered during the quarter and describe any risk mitigation efforts or actions taken to address the
identified challenges. In addition, a status update must be provided on the resolution of challenges
identified in previous quarters. This section should also include any questions you have for DOL and
note any identified needs for technical assistance from DOL or others. The narrative must also indicate
whether the grantee is requesting a modification to any project strategies and how the modification
request changes the original project proposal. If a modification has been requested, the narrative must
also indicate the status of the modification request. Modifications only apply to grants that require a full
application. If states have nothing to report, that should be specified.
E. Best Practices, Promising New Strategies and Success Stories
Please limit your response to 1000 characters or less.
States must use this section to describe promising approaches, innovative processes, or grant success
stories. States must also describe any lessons learned and how those lessons learned will be
implemented. Throughout the implementation of the project, states may discover new strategies that
emerge as a result of data-driven continuous improvement. As progress is made with a new and
promising strategy, or as data is gathered to support it, states must document the progress and data each
quarter. If states have nothing to report, that must be specified.
F. Additional Outcome Information
Please limit your response to 1000 characters or less.
This section requires states to report grant-specific outcomes not captured in other sections of the
quarterly narrative progress report, including, but not limited to, outcomes measuring equitable service
delivery, outcomes measuring fraud detection and prevention, outcomes measuring backlog reduction,
specific outcomes included in the grant application.
Certification
Name of Grantee Certifying Official:
Phone:
E-Mail Address:
Instructions to Complete ETA 9178-ARPA
Project Contact Information:
This section is to provide the contact information (i.e., Name, Title, Address, etc.) for the state
official who is responsible for the day-to-day operation and implementation of the project. This
may be a different person that the certifying official.
Certification:
• Name of Grantee Certifying Official
Use this section to provide the name of the state official who is certifying submission of
the report to the U.S. Department of Labor (Department).
• Phone
Provide the area code and telephone number ((###) ###-####) of the authorized state
official.
• E-Mail Address
Provide the email address of the authorized state official.
General Instructions
States receiving ARPA Grant Funds are required to submit quarterly progress reports to the
Department’s Employment and Training Administration (ETA) in order to comply with the
reporting and record keeping requirements of these funds. Each state recipient of funds must
submit a narrative Quarterly Progress Report (QPR) containing updates on the progress and
implementation of the project(s) undertaken as a result of the funding.
Report Form and Instructions
The QPR provides narrative updates on the implementation of project(s) undertaken as a result of
the funding and the status of each project per quarter.
Due Dates
All quarterly reports are due to ETA no later than 45 days after the end of each reporting quarter.
The table below shows the expected due dates for each reporting quarter.
Reporting Quarters Due Dates
October 1st – December 31st February 14th
January 1st – March 31st May 15th
April 1st – June 30th August 14th
July 1ST – September 30th November 14th
Should the due date of the report fall on a Saturday, Sunday, or holiday, the report is due the
previous business day.
Submission Procedures
Information contained in the quarterly report (ETA 9178-ARPA) must be submitted by email
directly to the ETA regional office. An ETA Federal Project Officer will review and accept the
report within 30 days of receipt.
Office of Management and Budget (OMB) Approval. Section 2116(a) of the CARES Act, 5
U.S.C. 9032(a), states that “Chapter 35 of Title 44, United States Code, (commonly referred
to as the ‘Paperwork Reduction Act of 1995’) shall not apply to the provisions of, and the
amendments made by, this subtitle.” As the OMB approval process is waived for these
reporting instructions, these instructions should be considered final.
Attachment VI to UIPL No. 22-21, Change 2
UI Identity (ID) Proofing Services and Solutions Recommended Contract Provisions
In evaluating potential service providers to deliver a solution for ID proofing, states
should consider including the following recommended contract provisions.
Recommended Technical Provisions
1. Digital ID Proofing
2. Data Privacy & Sharing
3. Data Access & Ownership
4. Audit Trail
5. Performance, Scalability & Availability
6. Support & Training
7. Service Level Provisions
8. General Provisions – Section 508 Compliance
Recommended Business Provisions
1. Business Performance Provisions (Timeliness and Transparency)
2. Equity Provisions
More detail on each recommended provision, including the specific recommendation, its
purpose, and the sample contract language is included in the table below.
Digital ID Proofing
Recommended Provision Purpose Sample Contract Language
Implement ID proofing that balances equitable Improves speed of delivery of benefit • Solution incorporates best practices
access with alignment to National Institute of payments by establishing high from NIST 800-63-3 guidelines while
Standards and Technology’s (NIST)’s digital confidence in the claimant’s identity. ensuring equitable access.
identity guidelines. (See Reduces workload on state staff by • Solution provides configurable and
https://csrc.nist.gov/publications/detail/sp/800- assisting on identity verification. accessible User Interfaces/User
63a/final). Section 4.4 pages 8-11. Reduces online fraud, including Experience (UX) flow that is mobile-
identity theft and identity fraud. responsive and compatible with
CAUTION: Carefully review solutions that use multiple browsers and device types as
biometrics such as facial recognition. While per industry standards.
these solutions may help to reduce identity • Solution provides verified, not
fraud, they may have negative implications for verified, and pending outcomes along
equity or lead to violations of states’ with configurable data associated
nondiscrimination obligations under Section back to calling systems for
188 of Workforce Innovation and Opportunity continuation of adjudication and
Act (WIOA). processing of claims or other related
activities.
Implement authentication to online systems Reduces fraud and online “claims • Solution incorporates best practices
incorporating best practices from NIST’s hijacking” also known as “claims or from the NIST 800-63-3 AAL2
Authenticator Assurance Level (AAL) 2 account takeover” by establishing standard.
standard definition. (See stronger authentication/verification of • Solution provides configurable and
https://csrc.nist.gov/publications/detail/sp/800- the claimant’s online identities when accessible User Interfaces/UX flow
63b/final). Section 4.2 pages 6-8. accessing systems to change contact that is mobile-responsive and
information, address information, and compatible with multiple browsers
CAUTION: NIST 800-63-3 AAL2 bank account information. and device types as per industry
recommends very strict session timeouts that standards.
may be burdensome to some applicants,
particularly to those less familiar with multi-
factor authentication. States are encouraged to
balance these factors and exercise judgment
when instituting secure authentication.
Data Privacy and Sharing
Recommended Provision Purpose Sample Contract Language
Require Data Privacy & Data Sharing Protects user data from unauthorized • Disclose all uses of user data including data
Provisions. disclosure, particularly Personally sharing with third parties and how they
Identifiable Information (PII) and mitigate potential third-party service bad
sensitive information. actors or negligent actors to ensure the
protection of user data, especially PII and
sensitive information.
• Support supply chain audits as requested by
state and must comply with the provisions of
the Privacy Act of 1974. All personnel
assigned to this contract are required to take
proper precautions to protect the information
from disclosure. The contractor must not
release, publish, or disclose sensitive
information to unauthorized personnel, and
must protect such information following
provisions of the following laws and any
other pertinent laws and regulations
governing the confidentiality of sensitive
information: 18 U.S.C. 641 (Criminal Code:
Public Money, Property or Records).
Prohibit Claimant Data Resale or To prevent the resale or commercial use • Prohibition on Claimant Data Resale or
Commercial Use. of claimant or state data. Commercial Use: The contractor is
prohibited from reselling or using for any
commercial purpose, whether individually
or in aggregate, any claimant or state data
collected in the execution of the contract or
subsequent orders. Sharing of data other
than for the express purpose of identity
verification for Unemployment
Compensation (UC) claims is strictly
prohibited.
Data Access & Ownership
Recommended Provision Purpose Sample Contract Language
Preserve State Access to and To preserve a state’s ability to create, At a minimum, the solution must support the
Ownership of Government Data. maintain, and modify the Government following Data ownership requirements
Data included within the solution. inclusive and not limited to:
• Machine-Readable Exports: Solution must
support creating a digital, reusable copy of
the Government Data, in whole and parts, as
a platform-independent and machine-
readable file.
• Use of Government Data: Solution’s
copyright, patent, or intellectual property
considerations must not restrict state use of
the solution to create, maintain, and modify
the Government Data. The solution must
not make use of the Government Data for
any commercial purpose or any purpose not
specified in this agreement, whether to the
benefit of the solution’s vendor or a third-
party.
Audit Trail
Recommended Provision Purpose Sample Contract Language
Provide a comprehensive audit trail The selected vendor must provide a • Audit reports must have comprehensive
(See: NIST SP 800-53 Rev 5.0). thorough and comprehensive audit trail. audit trail capability to collectively provide
It is important to have a full accounting documentary evidence of the processing
of who applied for benefits, what the used to aid in tracing from original
decision was, etc. This will assist with transactions forward to related records and
required compliance reporting, as well as reports, and/or backwards from records and
provide documentation on state decisions reports to their component source
should the state face legal challenges. transactions. The Audit trail must comply
with NIST SP 800-53 Rev 5.0 controls
contained in the Audit and Accountability
family. The solution must provide reporting
for compliance with the Federal Information
Security Modernization Act of 2014
(FISMA) and National Institute of Standards
and Technology (NIST) Special Publication
(SP) 800-53 (as amended).
Performance, Scalability & Availability
Recommended Provision Purpose Sample Contract Language
Ensure system’s capability to scale It is crucial that the supplied solution be • System’s capability to handle an increasing
up quickly and effectively to handle able to scale up quickly and efficiently, number of users or an increase in requests
increased caseloads. should there be a surge in UI claims, so (e.g., more than 500,000 ID proofing
that response time and throughput are not requests per week) without adversely
negatively impacted. affecting response time and throughput. The
uptime guarantee for production instances
must be 99.95% to prevent the impact on the
UI programs.
Support & Training
Recommended Provision Purpose Sample Contract Language
Provide robust training and support The selected contractor must provide a • The contractor must provide customer
network for both program staff and robust training and support network to support for state client bases, including, but
UI applicants. support both program staff and UI not limited to, system owners and managers,
applicants. as required.
• Support state technical staff to create stable
This training should include, at a integration architecture.
minimum, an online repository of help • Call center support for all login, ID
guides and videos. Support should proofing, Multi-Factor Authentication
include, at a minimum, a call center to (MFA) help desk tickets.
assist with login, ID proofing, and multi- • Support for individuals whose ID proofing
factor authentication help desk tickets. is pending or is in failed status while
attempting to obtain verification.
• Provide prioritized
integration/implementation, architecture,
and solutions support.
• Training support such as conducting
webinars, online videos, and other
documentations as needed.
• Online technical and user documentation
(architecture, help guides, videos, runbooks,
etc.).
Service Level
Recommended Provision Purpose Sample Contract Language
Provide rapid response times for ID The selected contractor should prioritize In additional general service/support
verification. rapid response times for ID verification. activities, the contractor must comply with the
The target should be to provide a decision following:
for supervised remote ID verification in no • Supervised remote ID verification must
more than 48 hours and for unsupervised not exceed 48 Hrs. to provide a decision
ID verification in no more than 5 minutes. outcome.
Likewise, average page load times should • Unsupervised ID verification must not
not exceed 5 seconds. This will ensure exceed 5 minutes to provide a decision
customer satisfaction and an efficient and outcome.
effective ID verification process. • Average response times for page loads
must not exceed 5 seconds.
• Priority 1 helpdesk and product/technical
support tickets must be processed in 2
Hrs. Priority 2 product/technical support
tickets must be processed in 24 Hrs. All
other product/technical support tickets
must be processed within a 72 Hrs.
• Authentication and ID verification error
rates (false positives or false negatives)
must not exceed 1%
General
Recommended Provision Purpose Sample Contract Language
Meet state-specific security and To ensure that the content is accessible to • The selected contractor must ensure
Section 508 Compliance standards. people with disabilities. compliance with state-specific security
standards as well as Section 508 of the
Rehabilitation Act, to ensure that the
content is accessible to people with
disabilities.
• The Section 508 standards incorporate by
reference the Web Content Accessibility
Guidelines developed by the Web
Accessibility Initiative to make web
pages as accessible as possible to the
widest range of users, including users
with disabilities.
Business Performance
Recommended Provision Purpose Sample Contract Language
Timely communication of ID Timeliness and transparency are important Timeliness:
verification decisions to the state UI pieces of the contractor’s ID verification • The contractor’s ID verification system
agency. system. It is important to ensure that the must be able to provide notification to the
contractor’s ID verification system state UI agency whether an individual’s
communicates the decision made on an identity has been verified, not verified, or
individual’s identity (e.g., verified, not is pending, if possible, in real-time, but
verified, pending) to the state UI agency. no later than 24 hours after the individual
These decisions should be communicated started the ID verification/proofing
in real-time, if possible, but no later than process to the ID.
24 hours after the individual begins the ID • As requested by the state UI agency,
verification process. The contractor contractor must notify the individual of
should also notify the individual of the whether their identity has been verified,
decision within the same timeline not verified, or is pending, if possible, in
discussed above. real-time, but no later than 24 hours after
the individual started the ID
verification/proofing process.
Equity Provisions
Recommended Provision Purpose Sample Contract Language
Ensure equitable access. The contractor selected to provide ID Unemployment Insurance Program Letter (UIPL) No. 02-
verification services should have a plan to 16 (published October 1, 2015) and UIPL No. 02-16,
ensure equitable access to ID verification Change 1 (published May 11, 2020), provide State
services, including for individuals with Responsibilities for Ensuring Access to Unemployment
disabilities, individuals with Limited Insurance Benefits, Services, and Information.
English Proficiency (LEP), older Consistent with these requirements, the Department
individuals, and those unable to access or requires the contractor to provide the following.
use a web-based system. To ensure equity, • The contractor must provide an efficient alternative
the contractor should provide alternative access method for individuals who are unable to
access methods that are readily available, complete ID verification through electronic or self-
timely, and of no-cost to the individual. service means. This includes individuals with
barriers to access, such as individuals with
disabilities, LEP individuals, older individuals,
individuals who experience challenges with
technology, and individuals who experience
challenges with literacy. This also includes
individuals who need support troubleshooting.
• The alternative access methods must: (1) ensure
meaningful access to limited English proficient
(LEP) individuals so that they are effectively
informed about and/or able to participate in ID
verification. Language assistance services must be
accurate, provided in a timely manner, and free of
charge to the individual; and (2) be advertised on the
contractor’s application and include information
about how an individual who has difficulty using the
site or service can get assistance to access the site or
service.
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