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Unemployment Insurance: Data Indicate Substantial Levels of Fraud during the Pandemic; DOL Should Implement an Antifraud Strategy

GAO-23-105523 Published: Dec 22, 2022. Publicly Released: Jan 23, 2023.
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Fast Facts

Congress created 4 new unemployment insurance programs to support workers during the COVID-19 pandemic. Following this expansion, the amount of fraud in these programs increased—with evidence indicating that the total fraud was over $60 billion and perhaps much higher.

The Department of Labor has taken steps to address such fraud. For example, it issued guidance, provided funding to states, and recommended improvements to state unemployment insurance programs. However, the department has yet to develop an antifraud strategy based on leading practices from GAO's Fraud Risk Framework as required by law.

We recommended that it do so.

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What GAO Found

Considered together, measures and estimates indicate substantial levels of fraud and potential fraud in unemployment insurance (UI) programs during the pandemic. However, each measure and estimate has strengths and limitations, and none completely and reliably indicates the extent of fraud in UI programs during the pandemic.

Examples and Definitions of Measures and Estimates

Examples and Definitions of Measures and Estimates

DOL has taken steps to address UI fraud risks. For example, DOL issued guidance, provided funding to states, and deployed teams to recommend improvements to state UI programs. While these steps help prevent, detect, and respond to fraud, as of December 2022, DOL has not yet developed an antifraud strategy based on leading practices in GAO's Fraud Risk Framework. Also, it has not yet addressed the six October 2021 recommendations GAO made including to identify, assess the impact of, and prioritize UI fraud risks. These are essential pieces to inform an overall antifraud strategy. Without an antifraud strategy, DOL is not able to ensure that it is addressing the most significant fraud risks facing the UI system in alignment with the Fraud Risk Framework.

Why GAO Did This Study

The UI system has faced long-standing challenges with program integrity, which worsened during the pandemic. Congress created four new UI programs to support workers during the pandemic. According to DOL data, approximately $878 billion in benefits were paid across all UI programs from April 2020 through September 2022. The unprecedented demand for benefits and the need to implement the new programs quickly increased the risk of financial fraud. Due to this risk and other challenges, GAO added the UI system to its High-Risk List in June 2022.

GAO was asked to review matters relating to the scope and severity of fraudulent activity in the UI system during the pandemic. This report examines what measures and estimates indicate about the extent of UI fraud during the pandemic and the extent to which DOL designed and implemented a strategy to manage UI fraud risks. GAO reviewed information that federal and state entities used to measure and estimate the extent of fraud in UI programs, then evaluated DOL's activities against leading practices in GAO's Fraud Risk Framework. This report is part of an ongoing body of work to better understand and manage federal fraud, including future work to improve estimates of fraud.


GAO recommends that DOL develop and implement an antifraud strategy for UI programs that is consistent with leading practices from GAO's Fraud Risk Framework. DOL partially agreed with the recommendation and noted plans to address it.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Labor The Secretary of Labor should design and implement an antifraud strategy for UI based on a fraud risk profile consistent with leading practices as provided in the Fraud Risk Framework. (Recommendation 1)
Open – Partially Addressed
In August 2023, DOL officials provided us with a copy of the UI fraud risk profile. This fraud risk profile provides a link to the UI Integrity Strategic Plan, which according to DOL, continuously evolves and includes strategies to address emerging fraud threats and integrity risks to the UI program. The UI Integrity Strategic Plan for fiscal year 2022--the most recent available as of August 2023--describes strategies through which DOL supports states to combat fraud. The strategies include strengthening UI systems, cybersecurity, ID verification, and data analytics. In August 2023, DOL officials also provided an update on their work in developing and communicating an antifraud strategy to states. Officials cited specific guidance that DOL provided to states that communicated antifraud tools and controls, citing the UI fraud risk profile. In July 2023, DOL provided additional guidance to states that stated the purpose of DOL's antifraud strategy and listed both mandatory and recommended fraud controls that states should utilize. DOL officials said they were continuing to work with state partners to develop, document, communicate, and evaluate a UI antifraud strategy. DOL's most recent UI Integrity Strategic Plan does not reference the UI fraud risk profile and does not explicitly link antifraud controls back to the highest residual risks. It also does not establish specific roles and responsibilities for those involved with fraud risk management. We maintain that, consistent with our Fraud Risk Framework, it is important for DOL to fully develop and document a comprehensive and unified antifraud strategy. Doing so could help state workforce agencies and DOL better manage UI fraud risks.

Full Report

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Antifraud programsFraudImproper paymentsInsurance claimsOverpaymentspandemicsRisk managementUnemployment compensation programsUnemployment insuranceUnemployment insurance rates