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Additional pandemic UI fraud funding and identity verification guidance

Summary ETA offered states a third round of funds to prevent and detect fraud and recover overpayments in the Pandemic Unemployment Assistance and Pandemic Emergency Unemployment Compensation programs. It also described identity fraud and encouraged stronger identity proofing and fair access for legitimate claimants. Change 3 later extended the grant application deadline to October 31, 2021; the programs and deadline are historical.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 28-20, Change 2
Date issued
August 11, 2021
Status
Active
ETA’s listing marks this change Active, and its PDF prints “Rescissions: None” and “Expiration Date: Continuing.” Change 3 later extended its 2021 grant application deadline to October 31, 2021.
Status last verified October 24, 2026

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About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 Unemployment Insurance
               ADVISORY SYSTEM
                                                          CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR
                                                          OUI/DPM
             Washington, D.C. 20210
                                                          DATE
                                                          August 11 , 2021


ADVISORY:       UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 28-20,
                Change 2

TO:             STATE WORKFORCE AGENCIES

FROM:           SUZAN G. LEVINE
                Acting Assistant Secretary

SUBJECT:        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

1. Purpose. To inform states regarding the availability of a third round of fraud prevention and
   recovery funding and to provide application instructions. The funding may be used to
   combat fraud in the PUA and PEUC programs, including to support innovative strategies and
   solutions to assist with identity verification and combatting identity fraud; strengthen fraud
   detection and prevention efforts; recover overpayments; and cover administrative expenses
   related to integrity efforts. Additionally, this Unemployment Insurance Program Letter
   (UIPL) provides definitions for different types of fraud and guidance on processes for
   combatting identity fraud.

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 UIPL to appropriate staff.

3. Summary and Background.

   a. Summary – On May 11, 2020, ETA issued UIPL No. 23-20 to remind states of their roles
      and responsibilities in addressing fraud in the Unemployment Insurance (UI) system and
      the techniques and strategies available to assist states with their fraud management
      operations. These activities must also be applied to unemployment programs authorized
      by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, as amended,
      including the PUA and PEUC programs. On August 31, 2020, ETA issued UIPL No. 28-
      20, which provided states with $100 million in funding to assist with efforts to prevent
      and detect fraud and identity theft and recover fraud overpayments in the PUA and PEUC

   RESCISSIONS                                             EXPIRATION DATE
   None                                                    Continuing

         programs. On January 15, 2021, ETA issued UIPL No. 28-20, Change 1, to provide
         states with an additional $100 million in funding to support identity verification or
         validation of PUA claimants and to assist with efforts to prevent and detect fraud and
         recover overpayments in the PUA and PEUC programs.

         This Change 2 to UIPL No. 28-20 informs states of the availability of a third round of
         fraud prevention and recovery funding to combat fraud in the PUA and PEUC programs,
         how to apply for the funding, and how the funding may be used. States are strongly
         encouraged to combat identity fraud (including account takeovers when a fraudster
         hijacks an existing claim) by implementing National Institute of Standards and
         Technology (NIST)-compliant1 Identity Assurance Level 2 (IAL2) and Authenticator
         Assurance Level 2 (AAL2) identity proofing at the time of filing an initial application for
         benefits, in addition to other points during the claim. NIST-complaint identity proofing
         is discussed in greater detail in Section 4.b. of this UIPL.

         To obtain this funding, 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
         13, 2021, by electronic submission to the ETA National Office at [email protected],
         with a copy to the appropriate ETA Regional Office. Attachment I lists the amounts of
         PUA and PEUC funding available for each state. Attachment II provides additional
         information on completing the SF-424.

    b. Background – Since the onset of the Coronavirus Disease 2019 (COVID-19) pandemic,
       the UI program has been an attractive target for international and domestic criminal
       organizations perpetrating identity fraud. States have worked tirelessly to combat
       relentless and sophisticated fraud attacks, while simultaneously responding to the highest
       claims workload in the history of the UI program.

         The CARES Act was enacted on March 27, 2020, (Public Law (Pub. L.) 116-136) and
         created new temporary unemployment benefit programs (including PUA and PEUC).
         These programs provided unemployment benefits to individuals who were not typically
         eligible to obtain benefits (e.g., individuals who were self-employed). See UIPL No. 14-
         20. The Continued Assistance for Unemployed Workers Act of 2020 (Continued
         Assistance Act) was enacted on December 27, 2020, (Pub. L. 116-260), and the
         American Rescue Plan Act of 2021 (ARPA) was enacted on March 11, 2021, (Pub. L.
         117-2), both of which further amended and extended the CARES Act programs. See
         UIPL Nos. 09-21 and 14-21, respectively. With each new enactment, states were
         required to modify their computer systems and service delivery processes, as well as to
         notify individuals of changes to eligibility requirements for the PUA and PEUC
         programs.


1
 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.

All states signed an “Agreement Implementing the Relief for Workers Affected by
Coronavirus Act” (Agreement) with the Secretary in March 2020 to administer the PUA
and PEUC programs. The Agreement incorporates amendments to the CARES Act made
by the Continued Assistance Act and ARPA. Under the Agreement, each state is
required to operate the programs as required by any statutory amendments and the
Department’s guidance. This is discussed further in Section 4.c. of this UIPL.

Addressing both eligibility fraud and identity fraud remain a top priority for the
Department and the entire unemployment compensation (UC) system. As discussed in
UIPL Nos. 23-20; 28-20; and 28-20, Change 1, ETA strongly encourages states to adopt
an array of solutions and techniques to detect and fight fraud, have robust strategies in
place to verify the identity of individuals applying for unemployment benefits, and
strengthen efforts to recover overpayments, including fraudulently paid UC benefits.
This includes implementing NIST-compliant IAL2 and AAL2 identity proofing (see
Section 4.b. of this UIPL for more information). States are also encouraged to make use
of the tools, resources, and services of the UI Integrity Center, funded by the Department
and operated in partnership with the National Association of State Workforce Agencies
(NASWA). See Training and Employment Notice (TEN) No. 04-20 for further
information on the Integrity Data Hub (IDH).

As a reminder, states must refer allegations which they reasonably believe constitute UC
fraud, waste, abuse, mismanagement, or misconduct to the Department’s Office of
Inspector General (DOL-OIG). Additionally, states are required to disclose confidential
UC information related to the CARES Act, as amended, to DOL-OIG for the purpose of
UC fraud investigations and audits for the entire pandemic relief period. See UIPL No.
04-17, Change 1. States should actively and regularly share information about suspected
fraud with other state UI agencies and with local, state, and federal law enforcement.

ETA is committed to supporting states by providing funding and investing in the most
innovative and successful tools and resources to stay ahead of fraud schemes, which
includes providing states with options to access NIST-compliant identity proofing and
authentication solutions. This includes Blanket Purchase Agreements (BPAs) awarded
by the Department that provide the Department with a procurement vehicle to enhance
identity proofing in the state’s UI programs. In the near future, the Department plans to
issue guidance to states on the BPAs and the procedures for the Department to issue
orders under those BPAs, in accordance with federal procurement regulations. As part of
that ordering process, the Department anticipates working with states to identify
particular requirements applicable to a state UI program and to provide for the payment
for services ordered using grants made available under this UIPL or another funding
source identified by the state subject to the requirements of federal appropriations law.

Promoting Program Equity. As states consider additional tools to incorporate into their
fraud management operations, equitable access to unemployment benefits must be at the
forefront of the decision-making process, in line with Executive Order (EO) 13985 of
January 2021 and UIPL Nos. 02-16 and 02-16, Change 1. At the most fundamental level,
equity within the UC program means the provision of UC payments to eligible workers,

       regardless of one’s background, in a timely and fair manner, with an application process
       that is readily accessible to all workers. In the context of fraud management, equitable
       access means that there are alternatives to digital mechanisms of identity proofing; that
       the mechanisms used to prove identity or flag for fraud do not contain racial, gender, or
       other bias; and that data is available to understand the impact of fraud mitigation on
       eliminating barriers that prevent full and equal access to benefits for all eligible
       individuals.

       The Department expects to issue additional funding opportunities for detecting and
       preventing fraud for the regular UC program in the near future. The Department expects
       to also offer states additional funding opportunities to increase equity in the regular UC
       program. States may want to consider these additional funds when putting together their
       fraud strategies to incorporate equitable access into their strategies to combat fraud.

4. Guidance. This section provides definitions for different types of fraud, namely eligibility
   fraud and identity fraud. States are encouraged to implement NIST-compliant processes for
   identity proofing and authentication to combat identity fraud. States are also reminded of the
   required program activities after termination or expiration of the PUA and PEUC programs,
   as well as the requirement to share information with the DOL-OIG.

   a. Types of Fraud. There are primarily two different types of fraud occurring within the
      UC program.

          Eligibility fraud generally occurs when benefits or services are acquired as a result of
           false information with the intent to receive benefits for which an individual or
           individuals would not otherwise be qualified. State law determines how this is
           evaluated within the UC program. Not all improper payments are considered
           fraudulent.

          Identity fraud is when one person acquires and uses the identifying information of
           another person in order to illegally receive benefits. The fraud can happen either at
           the time of UI application submission, or by changing key user data like bank account
           information after a claim has been established. As discussed in UIPL No. 16-21,
           synthetic identity fraud occurs when real and fake information are combined to create
           false identities.

   b. National Institute of Standards and Technology (NIST)-compliant IAL2/AAL2
      Identity Proofing and Authentication. The Department strongly encourages all states
      to implement NIST-compliant identity proofing, specifically IAL2 and AAL2, before
      claimants start filling out the UI claims application and for re-accessing their account.
      IAL2 and AAL2 are recommended for UC programs due to the personally identifiable
      information (PII) collected from individuals and employers. NIST Standard Publication
      (SP) 800-63 outlines components of identity assurance that states should take into
      consideration when reviewing available tools/solutions:

    i.   Identity Assurance Level (IAL) indicates how robust the identity proofing process is
         and how the identity in question is bound between an authenticator and a specific
         person. IAL2 requires evidence that supports the real-world existence of the
         claimed identity and verifies that the applicant is appropriately associated with this
         real-world identity. IAL2 introduces the need for either remote or physically-
         present identity proofing and includes filling out personal information (name,
         address, DOB, etc.) and submitting photos of approved government-issued
         identification or supporting documents for remote identity proofing.

   ii.   Authenticator Assurance Level (AAL) refers to the authentication process and
         indicates the confidence that the person trying to log in is the same person as the
         person attached to the account. AAL2 indicates the level of security behind the
         point of access, which requires the proof of possession and control of two distinct
         authentication methods.

   As states are implementing NIST-compliant IAL2/AAL2 identity proofing and
   authentication services or other identity verification methods, the Department strongly
   encourages states to include service delivery expectations that mitigate access barriers to
   individuals. The state must provide at least two options to individuals upfront to verify
   their identity (i.e., online, by phone, and/or in-person). An example of service delivery
   expectations that further mitigate access barriers include that incorrect identity proofing
   by denying the validation of an individual’s identity who has accurately represented
   themselves and submitted to identity proofing requirements (which is an example of a
   “false positive”) shall not exceed 0.5 percent of the total IAL2 identities processed.
   Timely determinations prevent fraudulent benefit payments while ensuring that qualified
   and eligible claimants receive benefits as soon as administratively feasible. See UIPL
   Nos. 04-01, 01-16, and 16-21.

c. Reminders to States.

    i.   Applicability of program requirements after termination or expiration of PUA and
         PEUC. Under current federal law, the PUA and PEUC programs will expire on
         September 6, 2021, and some states have elected to terminate participation before
         September 6, 2021. As described in Section 4.a. of UIPL No. 14-21, Change 1, the
         state must process and pay benefits to eligible individuals under the PUA and
         PEUC programs for all weeks of unemployment ending on or before the date of
         termination or expiration (whichever comes first). The state must also comply with
         all responsibilities with respect to claims filed under these programs for those
         weeks, including, without limitation, the requirements under the Agreement and in
         guidance. Accordingly, the Agreement remains in effect with respect to the PUA
         and PEUC programs for weeks of unemployment ending on or before the date of
         termination or expiration (whichever comes first) until all issues relating to those
         weeks are resolved. The Department expects that states will continue to detect and
         recover fraudulent overpayments with respect to these covered weeks after the date
         of termination or expiration.

         ii.    Required Information 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.
                Additionally, states are required to disclose confidential UC information related to
                the CARES Act, as amended, to the DOL-OIG for the purpose of UC fraud
                investigations and audits for the entire pandemic relief period, which for most states
                will be weeks of unemployment beginning after January 27, 2020, through weeks of
                unemployment ending before September 6, 2021.

5. Funding for States to Combat Fraud in the PUA and PEUC Programs. This section
   discusses the amount available to states, allowable uses of funds, application instructions,
   and reporting requirements.

      a. Amount Available to States. The Department is providing an additional $100 million to
         states to combat fraud in the PUA and PEUC programs. The methodology for state
         funding levels is based on size of UI covered employment in the state.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
         2020 reported on the ES 202 (Employment, Wages and Contributions). 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

         Attachment I lists the amounts of PUA and PEUC funding available for each state.

      b. Allowable Uses of Funds. States may use the funds made available under this UIPL to
         support innovative strategies and solutions to assist with identity verification and
         combatting identity fraud; strengthen fraud detection and prevention efforts; recover
         overpayments; and cover administrative expenses related to integrity efforts. Examples
         of permissible uses of these funds include but are not limited to the following activities.

          i.    Procuring, implementing, and paying reoccurring subscription costs and/or ongoing
                maintenance costs of identity verification and fraud detection solutions, such as
                NIST-compliant IAL2 and AAL2 tool(s)/strategy(ies) that provide identity
                verification and user authorization of all individuals applying for PUA and PEUC.
                This includes using such funds to pay for services provided under an order issued
                by the Department against one of the Department’s identity proofing BPAs;

         ii.    Implementing or enhancing data analytics capabilities to understand the nature and
                prevalence of fraud and the impact of fraud mitigation efforts, such as tracking:


  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
  data on employment), their PUA funding is based on estimated claims workloads.

                    o Current and historical numbers of cases flagged as potential or resolved
                      fraud;
                    o Type of fraud (eligibility fraud vs. identity fraud);
                    o Type of perpetrators; and
                    o Investigation outcomes.

        iii.    Implementing cross-matching to detect suspicious activity, including synthetic or
                false identities, and identification of other patterns of fraudulent behavior (e.g., with
                a state’s own internal data or the IDH3 Identity Verification (IDV) solution;

        iv.     Implementing or enhancing cybersecurity perimeter defense for the websites and
                web applications responsible for initial application steps and regular certification
                (e.g., to protect against online bot attacks);

         v.     Costs incurred from working with banks and financial institutions to detect
                suspicious activity, ensure that accounts are not unduly suspended and eligible
                claimants with suspended claims are paid benefits, and facilitate the expeditious
                return of improperly paid UC funds;

        vi.     Costs incurred to capture and analyze additional data elements to measure the
                service delivery expectations. This includes capturing any data elements to
                measure effectiveness and equity outcomes of identity verification and fraud
                detection and prevention solutions, tools, and actions associated with the use of
                these funds to ensure that service delivery does not adversely affect people of color,
                individuals in poverty, and others who may have been historically underserved or
                marginalized.

                Examples include tracking which claims were flagged as potential fraud at any
                time, the length of time to resolve these investigations, and the outcome of these
                investigations (e.g., fraud, overpayment but not fraudulent, non-issue (i.e., “false
                positive”)) by demographic group.

                Other examples include reporting data on claimant experience with fraud fighting
                technology (e.g., speed of identity proofing broken out by subgroups such as race,
                ethnicity, gender, disability status, geographic location, age).

       vii.     Assessing and mitigating disproportionate impact of fraud measures on vulnerable
                communities such as communities of color, communities with disabilities, limited
                English proficient and immigrant communities, and certain geographic communities
                (e.g., rural versus urban).



3
  The Pacific territories (Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, the
Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau) do not have access
to the IDH. ETA will provide targeted technical assistance to the Pacific territories to explore options to assist with
identity verification and support enhanced fraud detection and prevention.

      viii.     Assessing and mitigating security vulnerabilities (e.g., migrating from using PINs to
                strong passwords, locking accounts after multiple failed login attempts,
                immediately notifying users when key account information like when a mailing
                address or bank account is modified);

        ix.     Hiring staff or obtaining contract services to conduct fraud investigations, other
                eligibility fraud and identity fraud detection-related activities, and support
                overpayment recovery efforts;4

         x.     Costs incurred as a result of a state’s participation in forfeiture and seizure efforts of
                law enforcement agencies (e.g., Department of Justice, United States Secret
                Service); and

        xi.     Administrative expenses incurred by the state to gather business requirements,
                program computer systems, or otherwise implement tools, strategies, or solutions to
                strengthen fraud detection, prevention, and recovery efforts.

    c. Application Instructions.

         States are required to submit an SF-424 (OMB No. 4040-0004)
         https://apply07.grants.gov/apply/forms/sample/SF424_4_0-V4.0.pdf for each funding
         allotment (i.e., one SF-424 for the PUA funding and a second SF-424 for the PEUC
         funding). Attachment II provides additional information on completing the SF-424.

         ETA encourages states to submit this form as soon as possible, but no later than
         September 13, 2021, by electronic submission to the ETA National Office at covid-
         [email protected], with a copy to the appropriate ETA Regional Office.

    d. Reporting Requirements.

         States must provide a narrative Quarterly Progress Report (ETA 9178-F) and Quarterly
         Financial Report (ETA 9130) containing updates on the progress and implementation of
         each project. ETA will use the ETA 9178-F to track each state’s progress on
         activities/solutions and ensure that a state’s use of funds is consistent with the permissible
         activities outlined in section 5.b. of this UIPL, and ensuring fraud prevention
         solutions/activities do not have a negative impact on access to benefits.

         Refer to Attachment III in UIPL No. 28-20 for instructions for completion and the
         timeline of submission for the ETA 9178-F. In the Summary under Section A, states
         must provide, to the extent available, an assessment of the issue they are addressing, an
         explanation of how the proposed use of funds would address the issue, and a plan to
         measure the outcomes and effectiveness of the strategies, tools, and/or actions associated
         with the use of these funds. States may need to consider updates and changes to their

4
  Refer to UIPL No. 12-01, Change 2, for states’ ability to exercise flexibility in staffing models after the emergency
flexibilities under Section 9015, ARPA, expire on September 6, 2021.

       existing computer systems to capture new data elements needed to demonstrate the
       effectiveness of these action(s). The Department expects to award these funds prior to
       September 6, 2021, and so the first ETA 9178-F report under this UIPL will be due
       November 14, 2021.

       A note for states participating in the Department’s identity proofing BPAs. States that
       participate in the Department’s identity proofing BPAs may be subject to additional terms
       and conditions. The terms and conditions of any grant issued in accordance with this
       UIPL shall be read in harmony with, and as complementary to, the terms and conditions
       set forth in the identity proofing order and corresponding BPA.

6. Inquiries. States should direct inquiries to [email protected] and copy to the appropriate
   ETA Regional Office.

7. 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 (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);
          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. 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://wdr.doleta.gov/directives/corr_doc.cfm?docn=9571;
          UIPL No. 16-21, Identity Verification for Unemployment Insurance (UI) Claims,
           issued April 13, 2021, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9141;
          UIPL No. 14-21, Change 1, State Responsibilities After the Temporary
           Unemployment Benefit Programs under the Coronavirus Aid, Relief, and Economic
           Security (CARES) Act, as amended, End Due to State Termination of Administration
           or When the Programs Expire, issued July 12, 2021,
           https://wdr.doleta.gov/directives/corr_doc.cfm?docn=9502;
          UIPL No. 14-21, American Rescue Plan Act of 2021(ARPA) - Key Unemployment
           Insurance (UI) Provisions, issued March 15, 2021,
           https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5669;
          UIPL No. 09-21, Continued Assistance for Unemployed Workers Act of 2020
           (Continued Assistance Act) - Summary of Key Unemployment Insurance (UI)
           Provisions, issued December 30, 2020,
           https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3831;

   UIPL No. 28-20, Change 1, Additional Funding for Identity Verification or
    Verification of Pandemic Unemployment Assistance (PUA) Claimants and Funding to
    Assist with Efforts to Prevent and Detect Fraud and Identity Theft as well as Recover
    Fraud Overpayments in the PUA and Pandemic Emergency Unemployment
    Compensation (PEUC) Programs, issued January 15, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9897;
   UIPL No. 28-20, Addressing Fraud in the Unemployment Insurance (UI) System and
    Providing States with Funding to Assist with Efforts to Prevent and Detect Fraud and
    Identity Theft and Recover Fraud Overpayments in the Pandemic Unemployment
    Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC)
    Programs, issued August 31, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8044;
   UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program
    and the UI Programs Authorized by the Coronavirus Aid, Relief, and Economic
    Security (CARES) Act of 2020 - Federal Pandemic Unemployment Compensation
    (FPUC), Pandemic Unemployment Assistance (PUA), and Pandemic Emergency
    Unemployment Compensation (PEUC) Programs, issued May 11, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4621;
   UIPL No. 16-20, Change 5, Expanded Eligibility Provisions for the Pandemic
    Unemployment Assistance (PUA) Program, issued February 25, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3202;
   UIPL No. 16-20, Change 4, Continued Assistance to Unemployed Workers Act of
    2020 —Pandemic Unemployment Assistance (PUA) Program: New Operating
    Instructions and Reporting Changes, issued January 8, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6973;
   UIPL No. 16-20, Change 3, Coronavirus Aid, Relief, and Economic Security
    (CARES) Act of 2020 - Eligibility of Individuals who are Caregivers for Pandemic
    Unemployment Assistance (PUA) in the Context of School Systems Reopening, issued
    August 27, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3849;
   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. 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, 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. 14-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of
    2020 – Summary of Key Unemployment Insurance (UI) Provisions and Guidance
    Regarding Temporary Emergency State Staffing Flexibility, issued April 2, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3390;

   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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5817;
   UIPL No. 02-16, Change 1, State Responsibilities for Ensuring Access to
    Unemployment Insurance Benefits, Services, and Information, issued May 11, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5491;
   UIPL No. 02-16, State Responsibilities for Ensuring Access to Unemployment
    Insurance Benefits, issued October 01, 2015,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4233;
   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. 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. 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. 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://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8998;
   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. 4-20, Encouragement for States to Use the Integrity Data Hub (IDH)
    available through the Unemployment Insurance (UI) Integrity Center, issued August
    31, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3588;
   TEN No. 03-20, 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; and
   Employment Security Manual, Section 7511, The Secretary’s Interpretation of
    Federal Law Requirements, available at 20 C.F.R. Part 614, Appendix C, Standard
    for Fraud and Overpayment Detection.

8. Attachment(s).

         Attachment I: State Size Classifications and Funding Allocation to Strengthen
          Fraud Detection and Prevention Efforts and Recover Overpayments in the
          Pandemic Unemployment Assistance (PUA) and Pandemic Emergency
          Unemployment Compensation (PEUC) Programs; and
         Attachment II: Instructions for Completing the SF-424.

                                                        Attachment I to UIPL No. 28-20, Change 2

   State Size Classifications and Funding Allocation to Strengthen Fraud Detection and
Prevention Efforts and Recover Overpayments in the Pandemic Unemployment Assistance
    (PUA) and Pandemic Emergency Unemployment Compensation (PEUC) Programs


          State                  Size                   Pandemic          Pandemic
                                 Classification         Unemployment      Emergency
                                                        Assistance        Unemployment
                                                        (PUA) Funding     Compensation
                                                        Allotment         (PEUC)
                                                                          Funding
                                                                          Allotment
          Alabama                Medium                      $1,384,200         $264,600
          Alaska                 Small                       $1,020,600         $194,400
          Arizona                Large                       $2,133,900         $405,900
          Arkansas               Medium                      $1,384,200         $264,600
          California             Large                       $2,133,900         $405,900
          Colorado               Large                       $2,133,900         $405,900
          Connecticut            Medium                      $1,384,200         $264,600
          Delaware               Small                       $1,020,600         $194,400
          District of Columbia   Small                       $1,020,600         $194,400
          Florida                Large                       $2,133,900         $405,900
          Georgia                Large                       $2,133,900         $405,900
          Hawaii                 Small                       $1,020,600         $194,400
          Idaho                  Small                       $1,020,600         $194,400
          Illinois               Large                       $2,133,900         $405,900
          Indiana                Large                       $2,133,900         $405,900
          Iowa                   Medium                      $1,384,200         $264,600
          Kansas                 Medium                      $1,384,200         $264,600
          Kentucky               Medium                      $1,384,200         $264,600
          Louisiana              Medium                      $1,384,200         $264,600
          Maine                  Small                       $1,020,600         $194,400
          Maryland               Large                       $2,133,900         $405,900
          Massachusetts          Large                       $2,133,900         $405,900
          Michigan               Large                       $2,133,900         $405,900
          Minnesota              Large                       $2,133,900         $405,900
          Mississippi            Medium                      $1,384,200         $264,600
          Missouri               Large                       $2,133,900         $405,900
          Montana                Small                       $1,020,600         $194,400
          Nebraska               Small                       $1,020,600         $194,400
          Nevada                 Medium                      $1,384,200         $264,600
          New Hampshire          Small                       $1,020,600         $194,400
          New Jersey             Large                       $2,133,900         $405,900
          New Mexico             Small                       $1,020,600         $194,400
          New York               Large                       $2,133,900         $405,900
          North Carolina         Large                       $2,133,900         $405,900
          North Dakota           Small                       $1,020,600         $194,400

State                 Size                   Pandemic          Pandemic
                      Classification         Unemployment      Emergency
                                             Assistance        Unemployment
                                             (PUA) Funding     Compensation
                                             Allotment         (PEUC)
                                                               Funding
                                                               Allotment
Ohio                  Large                       $2,133,900         $405,900
Oklahoma              Medium                      $1,384,200         $264,600
Oregon                Medium                      $1,384,200         $264,600
Pennsylvania          Large                       $2,133,900         $405,900
Puerto Rico           Small                       $1,020,600         $194,400
Rhode Island          Small                       $1,020,600         $194,400
South Carolina        Medium                      $1,384,200         $264,600
South Dakota          Small                       $1,020,600         $194,400
Tennessee             Large                       $2,133,900         $405,900
Texas                 Large                       $2,133,900         $405,900
Utah                  Medium                      $1,384,200         $264,600
Vermont               Small                       $1,020,600         $194,400
Virgin Islands        Small                       $1,020,600         $194,400
Virginia              Large                       $2,133,900         $405,900
Washington            Large                       $2,133,900         $405,900
West Virginia         Small                       $1,020,600         $194,400
Wisconsin             Large                       $2,133,900         $405,900
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

                                                 Attachment II to UIPL No. 28-20, Change 2

                           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).
       https://apply07.grants.gov/apply/forms/sample/SF424_4_0-V4.0.pdf.

       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.
        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/SAM/. 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.
        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:
 For Pandemic Unemployment Assistance Funding Allotment: Input “UIPL No. 28-
   20, Change 2, Pandemic Unemployment Assistance – Identity Verification, Fraud
   Prevention, and Overpayment Recovery Grants”.

   For Pandemic Emergency Unemployment Compensation Funding Allotment: Input
    “UIPL No. 28-20, Change 2, Pandemic Emergency Unemployment Compensation –
    Identity Verification, Fraud Prevention, and Overpayment Recovery 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, Change 2, Pandemic Unemployment Assistance – Identity Verification,
       Fraud Prevention, and Overpayment Recovery Grants”.

       For Pandemic Emergency Unemployment Compensation Funding Allotment:
        Input “UIPL No. 28-20, Change 2, Pandemic Emergency Unemployment
        Compensation - Identity Verification, Fraud Prevention, and Overpayment
        Recovery 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 Dates.
   a. Start Date: Input a valid start date for the project (earliest start date will be
       January 1, 2021).
   b. End Date: Input a valid end date for the project (June 30, 2022).

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.

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