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Fraud prevention funding and controls for pandemic UI programs

Summary ETA reminded state UI agencies of fraud prevention and recovery duties and described tools for detecting identity theft and improper payments. It also offered funding to help states address fraud in the temporary Pandemic Unemployment Assistance and Pandemic Emergency Unemployment Compensation programs. The advisory and its attachments set out state application and reporting instructions.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 28-20
Date issued
August 31, 2020
Status
Active
ETA’s listing marks this letter Active, and its PDF prints “Rescissions: None” and “Expiration Date: Continuing.”
Status last verified October 24, 2026

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About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 UI
               ADVISORY SYSTEM
                                                          CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR
                                                          OUI/DPM
             Washington, D.C. 20210
                                                          DATE
                                                          August 31, 2020

ADVISORY:       UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 28-20

TO:             STATE WORKFORCE AGENCIES

FROM:           JOHN PALLASCH
                Assistant Secretary

SUBJECT:        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

1. Purpose. To remind states of their roles and responsibilities in addressing fraud in the UI
   system and the techniques and strategies available to assist states with their fraud
   management operations; and to provide states with funding to assist with efforts to prevent
   and detect fraud and identity theft and recover fraud overpayments in the PUA and PEUC
   programs using many of the tools and resources already available to states as discussed
   below.

2. Action Requested. The U.S. Department of Labor’s (Department) Employment and
   Training Administration (ETA) requests that State Workforce Agency Administrators
   provide information contained in this Unemployment Insurance Program Letter (UIPL) to
   appropriate program and other staff in the state’s workforce system.

3. Summary and Background.

   a. Summary – This UIPL provides guidance to states on addressing fraud in the UI system
      and reiterates fraud management requirements and tools, strategies, and services available
      to states that the Department has previously encouraged states to adopt. To further assist
      in these efforts, the UIPL also provides states with funding to assist with efforts to
      prevent and detect fraud and imposter claims resulting from identity theft and recover
      fraud overpayments in the PUA and PEUC programs.

   b. Background – In calendar year 2019, states established 296,749 cases of UI fraud
      amounting to $366.8 million. Since the enactment of the Coronavirus Aid, Relief, and
      Economic Security (CARES) Act of 2020, which created several new temporary
      unemployment compensation (UC) programs (including PUA and PEUC), UI fraud has

 RESCISSIONS                                             EXPIRATION DATE
 None                                                    Continuing

        increased significantly, further testing the integrity of individual state systems and the UI
        program as a whole.

        Prior to COVID-19 and the enactment of the CARES Act, the Department had been
        working with states to address fraud in the UI program. As the Department became
        aware of fraud ticking up in the regular UI program and understood the vulnerabilities of
        remote claims taking and the potential for imposter claims, it began the development of
        tools and resources through the Integrity Data Hub, including the Suspicious Actor
        Repository and a suite of on-line training modules for fraud investigators. We also began
        the process of securing an identity verification solution to be make available to all states.
        These tools are discussed in more detail below.

        Section 303(a)(1) of the Social Security Act (SSA) requires that, as a condition of a state
        receiving administrative grants for its UI program, state law must provide for “methods
        of administration . . . as are found by the Secretary of Labor to be reasonably calculated
        to insure full payment of unemployment compensation when due.”

        The Department has consistently interpreted section 303(a)(1) to require “that state law
        include provision for such methods of administration as are, within reason, calculated (1)
        to detect benefits paid through error by the agency through willful misrepresentation or
        error by the claimant or others, and (2) to deter claimants from obtaining benefits through
        willful misrepresentation.” Employment Security Manual, Section 7511, The Secretary’s
        Interpretation of Federal Law Requirements.1 UIPL No. 04-01 interprets the “when due”
        requirement in section 303(a)(1) to also require states to ensure that payment of benefits
        is not made when payment is not due. Investigations of UI program fraud by claimants,
        employers, and state staff are necessary for the proper administration of the UI program.

        The Department included program integrity language in all of the major pieces of
        guidance associated with state implementation of the CARES Act programs and other
        provisions. In addition, on May 11, 2020, ETA issued UIPL No. 23-20, which discusses
        program integrity requirements for the regular UC program and the UC programs
        authorized by the CARES Act. UIPL 23-20 makes clear that the temporary CARES Act
        programs operate in tandem with the fundamental eligibility requirements of the federal-
        state UI program. In addition, the CARES Act programs have new eligibility
        requirements that states must apply to ensure that only eligible individuals receive
        benefits.

        As previously communicated to States on May 11, 2020, States must make efforts to
        rapidly and proactively prevent, detect, and investigate fraudulent activity; establish and
        recover fraud overpayments; and pursue criminal and civil prosecution to deter fraud.
        State Benefit Payment Control (BPC) staff or other designated state staff have the
        primary responsibility for these activities. However, all state staff members are

1
 Employment Security Manual, Part V, Sections 7510-7515, can be obtained at 20 C.F.R. Part 614, Appendix C,
Standard for Fraud and Overpayment Detection.

                                                      2

       responsible for maintaining the integrity of the UI program. States can also mitigate UI
       fraud through the use of available prevention and detection methods and tools.

4. Managing Fraud in the UI System. This UIPL describes successful and cost-effective
   methods to target fraud and suspicious claims activity, including improvements, additions,
   and modifications to UI systems and operations, that the Department has long encouraged
   States to adopt. Please refer to UIPL No. 23-20 for an inventory of the required program
   integrity functions.

   a. Fraud Prevention and Detection. Intercepting fraud as early as possible minimizes its
      impact on the UI system. As UI claims are filed, states are strongly encouraged to
      employ multiple techniques to validate UI claims and uncover suspicious or fraudulent
      characteristics, including:

              Identity Verification – to verify personal information supplied by individuals filing
               claims, using a variety of methods and resources, such as:
                      o Social Security Administration Cross-match – to validate a Social Security
                         Number supplied by a claimant.
                      o Systematic Alien Verification for Entitlement (SAVE) – to verify the
                         immigration status of non-U.S. citizens and to confirm the validity of the
                         information supplied by individuals filing claims.
                      o Incarceration cross-matches – to compare UI applicants’ information to
                         local, state, and federal prison databases.
                      o Interstate Connection Network (ICON) – to compare UI applicants’
                         information to detect duplicate claims filed in other states and under other
                         UI programs using Interstate Benefits (IB) Cross-match and the State
                         Identification Inquiry (SID) State Claims and Overpayment File, and the
                         IB8606 applications.
                      o Internet Protocol (IP) Address – to identify IP addresses linked to multiple
                         claims or claims filed outside of the U.S.
                      o Data Analytics – to cross-reference UI claims and identify shared
                         characteristics among claims that can be indicators of suspicious or
                         fraudulent claims activity.

               Data mining and data analytics – to detect fraud when a claim is filed and on an
                ongoing basis throughout the lifecycle of a claim. Continuous efforts to prevent
                and detect fraud are critical since fraud can occur at any point during the continued
                claims series.

       As the Department has emphasized in the past, some of the most effective tools are
       contained in the Integrity Data Hub (IDH), many of which have been available to states
       for well over a year. The IDH is a secure, robust, centralized, multi-state data system that
       allows participating state UI agencies to submit claims for cross-matching, provides a
       national fraud alert system to states, and supports data analytics on multi-state claims.
       The following IDH functionalities are currently available to participating states:

                                                    3

   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 – allows participating states to cross-match their claims
    against a database of suspicious e-mail domains that have been associated with
    fraudulent activity (e.g., YOPmail). The IDH flags claims with these domains for
    further investigation by the submitting state.
   Foreign IP Addresses – allows participating states to receive flags on UI claims filed
    from IP addresses outside of the U.S.
   Data Analysis – provides the unique ability to analyze national claims data and
    conduct cross-state analysis within a secure system.
   Multi State Cross-Match (MSCM) – allows the IDH to collect and store claims data
    submitted by states creating a multi-state database of UI claims data. Using this
    database, the IDH is able to identify where UI claims data are being used across
    multiple states (i.e., flagging a Social Security Number that is being used across four
    different states). The MSCM also provides a lookback capability to identify after-
    the-fact matches based on new claims or fraud activity data submitted to the IDH.
   Identity Verification (IDV) – provides states with a centralized identity
    verification/identity proofing solution. The IDV solution provides fraud scoring
    information, including flagging of synthetic identities. The IDV solution is now
    operational and available for state use. Early adopter states have reported that it is a
    highly successful integrity resource to prevent and detect identity theft.
   Fraud Alert System – allows states to share information through the secure IDH
    environment on emergent fraud schemes/activities identified in their states. The
    capability allows all states to review and/or submit information on fraud schemes and
    to receive updates to improve awareness across the UI community. The IDH Fraud
    Alert System is available to all states independent of the state executing an agreement
    with the UI Integrity Center or participating in other IDH functionality.

Other valuable assets provided by the UI Integrity Center include the following:

   UI Integrity Center Fraud Calls – states, ETA, and Office of Inspector General (OIG)
    staff have been engaging in periodic conference calls since fraud was first being
    detected in the early stages of the CARES Act program to discuss and share
    information on UI fraud schemes. These calls are conducted by the UI Integrity
    Center to share information on UI Integrity Center services, tools, and resources, and
    to provide a secure forum for states to discuss emergent fraud schemes and share best
    practices to prevent and detect fraud activity affecting the UI system.
   State Services – the UI Integrity Center employs a diverse group of UI professionals
    with a broad range of experience. The State Services team provides both virtual and
    onsite consultation services to states to provide state-specific recommendations and
    operational best practices in the prevention and detection of identity theft and fraud,
    and the recovery of improper payments. These services have been available to states
    for over 2 years.

                                         4

      National Integrity Academy (NIA) – one of the first offerings of the Integrity Center,
       the Academy currently provides 126 eLearning lessons and modules, including
       course bundles targeted to new Claims Takers, Adjudicators, and staff administering
       the Pandemic Unemployment Assistance (PUA) program, and includes four NIA
       certificate programs: UI Operations Integrity Certificate, UI Tax Integrity Certificate,
       UI Fraud Investigations, and UI Program Leadership. Additional information about
       course offerings, along with the online course catalog, can be found at:
       https://www.naswa.org/learning.
      Integrity Knowledge Exchange – an increasingly valuable tool that captures
       information on state practices and provides recommendations to states on ways to
       combat UI fraud and improve integrity. Through the Integrity Knowledge Exchange,
       the UI Integrity Center documents specific practices, creates model operational
       blueprints, and shares information with all states. Nearly 1,900 resource documents
       are currently available on the knowledge exchange, including 96 documented
       successful integrity practices that support the Model BPC Blueprint.

   As the Department has previously communicated, States are on notice that they should
   engage with the UI Integrity Center and utilize its important integrity tools and resources;
   implement and fully utilize all IDH functionalities; submit and review emergent fraud
   schemes through the IDH Fraud Alert System; and participate in UI Integrity Center
   fraud calls. State’s failure to take advantage of these resources may result in a state’s
   inability to comply with Federal law to prevent, detect, and recover improper and
   fraudulent payments. Technical assistance, tools, and resources are available through the
   UI Integrity Center at https://integrity.naswa.org/ and the UI Community of Practice on
   the Department’s knowledge sharing site, WorkforceGPS at
   https://www.workforcegps.org/login?returnUrl=https://ui.workforcegps.org/&siteFor=ui.
   Additionally, states may contact the UI Integrity Center State Liaison for their region for
   additional assistance at https://integrity.naswa.org/contact-us.

   States are also encouraged to explore other tools, methods, and strategies to deter and
   prevent fraud, such as the Social Security Administration’s Death Cross-match, Vital
   Statistics Cross-matches, Department of Motor Vehicles Cross-matches, Fictitious
   Employer Cross-matches, and other comparisons that detect shared characteristics (i.e.,
   phone numbers, mailing addresses, email address, and banking information) on multiple
   claims.

b. Fraud Civil and Criminal Prosecutions. The prosecution of cases is usually aided by
   law enforcement agencies, such as the OIG, Department of Justice, and other federal,
   state, and local enforcement agencies. States should work collaboratively with law
   enforcement agencies to administer their prosecutorial actions, and continue to make
   referrals to the OIG in accordance with established agreements and following the
   requirements outlined in UIPL Nos. 04-17 and 29-05, reporting known or alleged
   fraudulent activities and providing related claims data to the OIG’s Office of
   Investigations.

                                             5

5. Funding for States to Address Fraud in the PUA and PEUC Programs. Many states
   have experienced a significant number of fraudulent claims in the CARES Act programs,
   including PUA and PEUC, and are working with federal, state, and local law enforcement to
   investigate, prosecute, and, in collaboration with banking institutions, recover identified
   fraudulent payments. As a result of the significant increase in fraud and the need for states to
   have additional funding to support fraud prevention, detection, and investigation activities,
   the Department is providing a total of $100 million in administrative funding targeted
   specifically at addressing fraud and identity theft in the PUA and PEUC programs as part of
   its responsibility to provide “such sums as… necessary” for administration of the CARES
   Act programs.

    Attachment I, State Size Classifications and Funding Allocation for Fraud Investigation
    Activities in the Pandemic Unemployment Assistance (PUA) and Pandemic Emergency
    Unemployment Compensation (PEUC) Programs, lists the amounts of PUA and PEUC
    funding provided for fraud investigation activities for each state.

    The methodology for state funding levels is based on state size.2 For purposes of this
    methodology, States are assigned to three groups (Small, Medium and Large) based on the
    12-month average of UI covered employment for the four quarters in calendar year 2019
    reported on the ES 202 (Employment, Wages and Contributions) report published by the
    Bureau of Labor Statistics. States are assigned to the size groups as follows:
        Small: covered employment under 1 million employees
        Medium: covered employment between 1 million and 2 million employees
        Large: covered employment greater than 2 million employees

    a. Use of Funds. States are permitted to use this targeted funding for staff or contract
          services to conduct fraud investigations and other fraud detection-related activities, or
          to implement tools to increase prevention, detection, and recovery of fraudulent
          improper payments in the PUA and PEUC programs. States may also work
          collaboratively to invest these funds to benefit multiple states. It is ETA’s
          expectation that states will use at least 50 percent of the funds for staff to conduct
          fraud prevention, detection, and investigatory activities. Examples of activities that
          these funds may be used for include, but are not limited to:
               Accessing and utilizing the private or public data sets available through the UI
                  Integrity Center’s IDH (see Section 4(a) above for details). ETA expects that
                  all states will be positioned to use this data as soon as administratively
                  feasible, and no later than March 31, 2021.
               Implementing data mining tools, including the use of staff or contractor
                  services for conducting data mining activities.
               Implementing software/tools to conduct data analytics, including the use of
                  staff or contractor services for conducting data analytics activities.

2
  The Pacific territories are included in PUA pursuant to CARES Act Section 2101(a)(5), but not in PEUC. Since
the Pacific territories have relatively small populations and do not operate regular UI programs (and therefore lack
information on covered employment), their PUA funding is based on estimated claims workloads.

                                                          6

    b. Application Instructions. States are required to submit an SF-424 for each funding
       allotment (i.e., one SF-424 for the PUA funding and a second SF-424 for the PEUC
       funding). ETA encourages states to submit these forms as soon as possible, but no later
       than September 15, 2020, by electronic submission to the National Office at covid-
       [email protected], with a copy to the appropriate ETA Regional Office. For additional
       information on completing the SF-424, please refer to Attachment II, Instructions for
       Completing the SF-424. Attachment I, State Size Classifications and Funding Allocation
       for Fraud Investigation Activities in the Pandemic Unemployment Assistance (PUA) and
       Pandemic Emergency Unemployment Compensation (PEUC) Programs, lists the funding
       allotment(s) for both the PUA and PEUC programs for each state.

    c. Reporting Requirements.

        States will report quarterly progress on the form ETA 9178-F, provided at Attachment
        III.3 The ETA 9178-F is intended to be a monitoring instrument used by ETA to track
        each state’s progress in addressing fraud in the PUA and PEUC programs with these
        funds. The form ETA 9178-F will be used by the states to provide ETA with narrative
        updates on fraud investigation activities to help ensure that the goals described in section
        (5)(a) of this UIPL are met. Please refer to Attachment III for instructions for completion
        and the timeline of submission for the ETA 9178-F.

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

7. References.
       Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. 116-136),
         Title II, Subtitle A – Relief for Workers Affected by Coronavirus Act;
       Section 303 of the Social Security Act (42 U.S.C. 503);
       20 C.F.R. Section 603.23;
       UIPL No. 15-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of
         2020 – Federal Pandemic Unemployment Compensation (FPUC) Program
         Operating, Financial, and Reporting Instructions, issued April 4, 2020,
         https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9297;
       UIPL No. 15-20, Change 1, Coronavirus Aid, Relief, and Economic Security
         (CARES) Act of 2020 - Federal Pandemic Unemployment Compensation (FPUC)
         Program Reporting Instructions and Questions and Answers, issued May 9, 2020,
         https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3946;
       UIPL No. 15-20, Change 2, Coronavirus Aid, Relief, and Economic Security
         (CARES) Act of 2020-New Data Collection Instrument and Revised Reporting
         Instructions for Federal Pandemic Unemployment Compensation (FPUC), issued
         June 15, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7785;

3
 CARES Act, Section 2116 provides that Chapter 35 of Title 44 of the U.S. Code (commonly referred to as the
“Paperwork Reduction Act of 1995”) shall not apply to provisions of, and amendments made by, Subtitle A
(Unemployment Insurance Provisions) of Title II of the CARES Act.

                                                       7

   UIPL No. 16-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of
    2020 – Pandemic Unemployment Assistance (PUA) Program Operating, Financial,
    and Reporting Instructions, issued April 5, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4628;
   UIPL No. 16-20, Change 1, Coronavirus Aid, Relief, and Economic Security
    (CARES) Act of 2020 – Pandemic Unemployment Assistance (PUA) Program
    Reporting Instructions and Questions and Answers, issued April 27, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5899;
   UIPL No. 16-20, Change 2, Coronavirus Aid, Relief, and Economic Security
    (CARES) Act of 2020 - Pandemic Unemployment Assistance (PUA) Additional
    Questions and Answers, issued July 21, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5479;
   UIPL No. 17-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of
    2020 – Pandemic Emergency Unemployment Compensation (PEUC) Program
    Operating, Financial, and Reporting Instructions, issued April 10, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8452;
   UIPL No. 17-20, Change 1, Coronavirus Aid, Relief, and Economic Security
    (CARES) Act of 2020-Pandemic Emergency Unemployment Compensation (PEUC)
    Program: Questions and Answers, and Revised Reporting Instructions for the PEUC
    ETA 227, issued May 13, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8689;
   UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program
    and the UI Programs Authorized by the Coronavirus Aid, Relief, and Economic
    Security (CARES) Act of 2020 - Federal Pandemic Unemployment Compensation
    (FPUC), Pandemic Unemployment Assistance (PUA), and Pandemic Emergency
    Unemployment Compensation (PEUC) Programs, issued May 11, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4621;
   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://wdr.doleta.gov/directives/corr_doc.cfm?docn=5373;
   TEN No. 12-16, Unemployment Insurance (UI) State Information Data Exchange
    System (SIDES), issued September 27, 2016,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8026;
   UIPL No. 01-16, Federal Requirements to Protect Individual Rights in State
    Unemployment Compensation Overpayment Prevention and Recovery Procedures,
    issued October 1, 2015, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5763;
   UIPL No. 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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7706;
   UIPL No. 5-13, 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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3698;

                                      8

      •   UIPL No. 12-14, Required Use of the Treasury Offset Program to Collect Covered
          Unemployment Compensation Debt, issued May 20, 2014,
          https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9344;
      •   UIPL No. 28-11, Unemployment Insurance (UI) State Integrity Task Forces and
          Strategic Plans, issued September 1, 2011,
          https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3078;
      •   UIPL No. 19-11, National Effort to Reduce Improper Payments in the Unemployment
          Insurance (UI) Program, issued June 10, 2011,
          https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3036;
      •   UIPL No. 29-05, Memorandum of Understanding Regarding Unemployment
          Insurance Criminal Investigations Between the U.S. Department of Labor’s Office of
          Inspector General and the Employment and Training Administration, issued August
          2, 2005, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2104;
      •   UIPL No. 04-01, Payment of Compensation and Timeliness of Determinations during
          a Continued Claims Series, issued October 27, 2000,
          https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=1746;
      •   TEN No. 3-20, Unemployment Insurance (UI) Integrity Center’s Integrity Data Hub
          (IDH) Fraud Alert System, issued August 31, 2020,
          https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5585;
      •   ET Handbook No. 336, 18th Edition, Unemployment Insurance State Quality Service
          Plan Planning and Reporting Guidelines, May 6, 2019,
          https://wdr.doleta.gov/directives/attach/ETAHandbook/ET_Handbook_No.336_18th_
          Edition_Change_4_acc.pdf;
      •   ET Handbook No. 401, 5th Edition, issued August 16, 2017,
          https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7774;
      •   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.

8. Attachment(s).
       Attachment I: State Size Classifications and Funding Allocation for Fraud
         Investigation Activities in the Pandemic Unemployment Assistance (PUA) and
         Pandemic Emergency Unemployment Compensation (PEUC) Programs
       Attachment II: Instructions for Completing the SF-424
       Attachment III: ETA 9178-F Quarterly Narrative Progress Report

                                             9

                                                                         Attachment I to UIPL No. 28-20

                   State Size Classifications and Funding Allocation
for Fraud Investigation Activities in the Pandemic Unemployment Assistance (PUA) and
        Pandemic Emergency Unemployment Compensation (PEUC) Programs

        State                  Size Classification         Pandemic            Pandemic
                                                           Unemployment        Emergency
                                                           Assistance (PUA)    Unemployment
                                                           Funding Allotment   Compensation
                                                                               (PEUC) Funding
                                                                               Allotment
        Alabama                Medium                             $1,499,400             $285,600
        Alaska                 Small                              $1,020,600             $194,400
        Arizona                Large                              $2,041,200             $388,800
        Arkansas               Medium                             $1,499,400             $285,600
        California             Large                              $2,041,200             $388,800
        Colorado               Large                              $2,041,200             $388,800
        Connecticut            Medium                             $1,499,400             $285,600
        Delaware               Small                              $1,020,600             $194,400
        District of Columbia   Small                              $1,020,600             $194,400
        Florida                Large                              $2,041,200             $388,800
        Georgia                Large                              $2,041,200             $388,800
        Hawaii                 Small                              $1,020,600             $194,400
        Idaho                  Small                              $1,020,600             $194,400
        Illinois               Large                              $2,041,200             $388,800
        Indiana                Large                              $2,041,200             $388,800
        Iowa                   Medium                             $1,499,400             $285,600
        Kansas                 Medium                             $1,499,400             $285,600
        Kentucky               Medium                             $1,499,400             $285,600
        Louisiana              Medium                             $1,499,400             $285,600
        Maine                  Small                              $1,020,600             $194,400
        Maryland               Large                              $2,041,200             $388,800
        Massachusetts          Large                              $2,041,200             $388,800
        Michigan               Large                              $2,041,200             $388,800
        Minnesota              Large                              $2,041,200             $388,800
        Mississippi            Medium                             $1,499,400             $285,600
        Missouri               Large                              $2,041,200             $388,800
        Montana                Small                              $1,020,600             $194,400
        Nebraska               Small                              $1,020,600             $194,400
        Nevada                 Medium                             $1,499,400             $285,600
        New Hampshire          Small                              $1,020,600             $194,400
        New Jersey             Large                              $2,041,200             $388,800
        New Mexico             Small                              $1,020,600             $194,400
        New York               Large                              $2,041,200             $388,800
        North Carolina         Large                              $2,041,200             $388,800
        North Dakota           Small                              $1,020,600             $194,400
        Ohio                   Large                              $2,041,200             $388,800
        Oklahoma               Medium                             $1,499,400             $285,600
        Oregon                 Medium                             $1,499,400             $285,600
        Pennsylvania           Large                              $2,041,200             $388,800
        Puerto Rico            Small                              $1,020,600             $194,400
        Rhode Island           Small                              $1,020,600             $194,400
        South Carolina         Large                              $2,041,200             $388,800
        South Dakota           Small                              $1,020,600             $194,400
        Tennessee              Large                              $2,041,200             $388,800
        Texas                  Large                              $2,041,200             $388,800
        Utah                   Medium                             $1,499,400             $285,600

                                                     I-1

State                    Size Classification         Pandemic            Pandemic
                                                     Unemployment        Emergency
                                                     Assistance (PUA)    Unemployment
                                                     Funding Allotment   Compensation
                                                                         (PEUC) Funding
                                                                         Allotment
Vermont                  Small                              $1,020,600             $194,400
Virgin Islands           Small                              $1,020,600             $194,400
Virginia                 Large                              $2,041,200             $388,800
Washington               Large                              $2,041,200             $388,800
West Virginia            Small                              $1,020,600             $194,400
Wisconsin                Large                              $2,041,200             $388,800
Wyoming                  Small                              $1,020,600             $194,400
TOTAL                                                      $83,311,200          $15,868,800

Pacific Territories                                  Pandemic
                                                     Unemployment
                                                     Assistance (PUA)
                                                     Funding Allotment
American Samoa                                       $100,000
Commonwealth of the Northern Mariana Islands         $210,000
Federated States of Micronesia                       $100,000
Guam                                                 $210,000
Palau                                                $100,000
Republic of Marshall Islands                         $100,000
TOTAL                                                $820,000

                                               I-2

                                                         Attachment II to UIPL No. 28-20

                           Instructions for Completing the SF-424

Please note that States are required to submit an SF-424 for each funding allotment (i.e.
one SF-424 for the Pandemic Unemployment Assistance funding; and a second SF-424 for
the Pandemic Emergency Unemployment Compensation funding).

I. 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 12/31/2022, Office of Management and
       Budget (OMB) Control No. 4040-0004 (Grants.gov).
       http://www.grants.gov/web/grants/forms/sf-424- family.html

       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
        Employer/Tax Identification Number (EIN/TIN): Input your correct 9-digit EIN and
          ensure that it is recorded within SAM
        Organizational DUNS: All applicants for Federal grant and funding opportunities are
          required to have a 9-digit Data Universal Numbering System (D-U-N-S®) number,
          and must supply their D-U-N-S® number on the SF-424. Please ensure that your
          state is registered with the SAM. Instructions for registering with SAM can be found
          at https://www.sam.gov. Additionally, the state 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, there is a requirement to review and update the
          registration at least every 12 months from the date of initial registration or
          subsequently update the information in the SAM database to ensure it is current,
          accurate, and complete. 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: 20110-831.
          For lookup, use link at https://tools.usps.com/go/ZipLookupAction!input.action
        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”

                                               II-1

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:
 For Pandemic Unemployment Assistance Funding Allotment:
   Input “UIPL No. 28-20, Pandemic Unemployment Assistance Fraud Investigation
   Activities Grants”

   For Pandemic Emergency Unemployment Compensation Funding Allotment:
    Input “UIPL No. 28-20, Pandemic Emergency Unemployment Compensation Fraud
    Investigation Activities Grants”

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:
 For Pandemic Unemployment Assistance Funding Allotment:
   Input “UIPL No. 28-20, Pandemic Unemployment Assistance Fraud Investigation
   Activities Grants”

   For Pandemic Emergency Unemployment Compensation Funding Allotment:
    Input “UIPL No. 28-20, Pandemic Emergency Unemployment Compensation Fraud
    Investigation Activities Grants”

Section # 16, Congressional Districts of:
   a. Applicant: Input the Congressional District of your home office. For lookup, use
       link at www.house.gov with Zipcode + 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
   a. Start Date: Input a valid start date for the project (earliest start date will be July 1,
       2020)
   b. End Date: Input a valid end date for the project (June 30, 2021)

                                          II-2

Section # 18, Estimated Funding ($):
Input the applicable funding allotment for each of the programs 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

                                        II-3

                                                                       Attachment III to UIPL No. 28-20

                                                Form ETA 9178-F
U.S. Department of Labor                                                 OMB No. N/A4
Employment and Training Administration                             Expiration Date: N/A
Form ETA-9178-F
                          Quarterly Narrative Progress Report
 PUA and PEUC Fraud Prevention, Detection, and Investigation Activities (UIPL No. 28-20)
                                              General Information
State Name:                                   Report Quarter Ending:                Date of Submission:

                                              Contact Information
Name:                                                        Agency:
Title                                                        Address:
Phone:                                          Ext:         City:
                                                                                              Zip
E-Mail:                                                             State:
                                                                                              Code:
                                          Quarterly Activities Report
A. Summary
Please limit your response to 1000 characters or less.
This section is an executive summary of the activities carried out using Fraud Investigation
funds. Use this section to provide a short summary of the state’s activities and expected impact
to fraud prevention and detection activities.
B. Implementation and Funding Status
Please limit your response to 1000 characters or less.
Use this section to provide a description of the implementation of key activities outlined in this
UIPL for the current quarter. In addition, please report the number of Pandemic Unemployment
Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC) fraud cases
referred during the quarter to the Department of Labor’s Office of the Inspector General (OIG).
Finally, 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.

        Total Project
                                    Total Obligated               Funding Balance          Expenditure Target
          Funding

                                                   Certification
Name Certifying Official:
Phone:
E-Mail Address:

4
    Refer to section 2116(a) of P.L. 116-136, the Coronavirus Aid, Relief, and Economic Security Act, March 27, 2020 .

                                                          III-1

                             Instructions to Complete ETA 9178-F

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.

A. Certification
    Name of Certifying Official
        Use this section to provide the name of the state official who is certifying submission of
        the report to the Department.
    Telephone Number
        Provide the area code (###) and telephone number ((###) ###-####) of the authorized
        state official.
    Email Address
        Provide the email address of the authorized state official.

General Instructions
States receiving funding for PUA and PEUC Fraud Prevention, Detection, and Investigation
activities are required to submit quarterly progress reports to the United States Department of
Labor’s Employment and Training Administration (USDOL/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

                                                 III-2

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-F) must be submitted by email directly to
the ETA regional office. An ETA Federal Project Officer will review and accept the report within
30 days of receipt.

OMB Approval. Section 2116(a), Division B, Title II of the CARES Act 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 amendments made under this subtitle. As the OMB approval process is
waived for these reporting instructions, these instructions should be considered final.”

                                                 III-3

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