Labor IG Issues Memorandum on ETA Needs to Incorporate Data Analytics Capability to Improve Oversight of the Unemployment Insurance Program

WASHINGTON, Nov. 5 -- The Labor Inspector General issued the following alert memorandum (No. 19-23-012-03-315) on Sept. 25, 2023, entitled "ETA Needs to Incorporate Data Analytics Capability to Improve Oversight of the Unemployment Insurance Program."

Here are excerpts:

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MEMORANDUM FOR: BRENT PARTON, Principal Deputy Assistant Secretary for Employment and Training

FROM: CAROLYN R. HANTZ, Assistant Inspector General for Audit

SUBJECT: Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to Improve Oversight of the Unemployment Insurance Program; Report Number: 19-23-012-03-315

The purpose of this memorandum is to alert the Employment and Training Administration (ETA) to a concern the Office of Inspector General (OIG) has determined needs immediate attention. The OIG has identified nearly $1.3 billion in potentially fraudulent unemployment insurance (UI) payments made during the pandemic in two high-risk age categories, to individuals with Social Security numbers: (1) of children under the age of 14 and (2) of elderly persons 100 years of age or older. The OIG previously identified more than $45.6 billion in potentially fraudulent UI pandemic benefits paid in four other high-risk areas./1

This memorandum builds on our previous work, identifying additional risk within state UI claims data for agency action.

We are concerned ETA currently does not have direct access to state UI claims data. Additionally, we are concerned ETA does not have the capability to analyze said data, which would allow it to better identify fraud and other improper payments, as well as other trends or emerging issues, such as timeliness or equity.

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1 Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments in High-Risk Areas Increased to $45.6 Billion, Report No. 19-22-005-03-315, (September 21, 2022), available at: https://www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-315.pdf

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To provide relief to American citizens experiencing pandemic-related employment issues and challenges, the Coronavirus Aid, Relief, and Economic Security Act and subsequent legislation authorized seven new temporary UI programs./2

These temporary pandemic-related UI programs, coupled with the state UI programs, paid $888 billion in benefits during the heightened period of the COVID-19 pandemic - March 2020 through September 2021. This rapid expansion and substantial increase in benefits significantly increased the risk for fraud, waste, and abuse in UI programs.

For more than 20 years, the OIG has reported on the U.S. Department of Labor's (DOL) challenge to reduce improper payments in the UI program, which has experienced some of the highest improper payment rates across the federal government. In addition to the OIG's prior work, the Government Accountability Office (GAO), in its 2021 report on the federal response to the pandemic, expressed concern about overpayments and potential fraud in the UI system./3

GAO subsequently added the UI system to its "High Risk List" and recommended that DOL develop a plan for transforming this system./4

In 2023, GAO estimated the pandemic related fraud rate for the UI programs was about 11 to 15 percent for the period April 2020 to May 2023, and estimated up to $135 billion was lost to fraud./5

GAO also noted that the full extent of UI fraud during the pandemic will likely never be known with certainty.

The improper payment rate estimate for the UI program, as reported to the Office of Management and Budget, has been above 10 percent for 16 of the last 19 years (see Figure 1)./6

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2 These new programs included the Pandemic Unemployment Assistance program, which extended UI benefits to individuals not traditionally eligible; the Federal Pandemic Unemployment Compensation program, which provided supplemental payments to individuals receiving traditional and other eligible UI benefits; and the Pandemic Emergency Unemployment Compensation program, which provided up to an additional 13 weeks of unemployment compensation to individuals who exhausted their regular UI benefits.

3 GAO, COVID-19: Sustained Federal Action is Crucial as Pandemic Enters Its Second Year, Report No. GAO-21-387 (March 31, 2021), available at: https://www.gao.gov/products/gao-21387

4 GAO, Unemployment Insurance: Transformation Needed to Address Program Design, Infrastructure, and Integrity Risks, Report No. GAO-22-105162 (June 7, 2022), available at: https://www.gao.gov/products/gao-22-105162

5 GAO, Unemployment Insurance: Estimated Amount of Fraud during Pandemic Likely Between $100 Billion and $135 Billion, GAO-23-106696 (September 2023), available at: https://www.gao.gov/assets/gao-23-106696.pdf

6 The improper payment reporting year is the 12-month period ending June 30 of the reporting year.

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In 2021 and 2022, ETA estimated an improper payment rate of 18.71 percent and 21.52 percent, respectively. Further, ETA estimated a fraud rate of 8.57 for 2021--a 170 percent increase over the prior year's fraud rate of 3.17 percent./7

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Figure 1: UI Improper Payment Rates, 2004 - 2022/8

Source: OIG analysis of improper payment data published by ETA

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During our previous audit/9 of DOL's response to the UI program's expansion under the Coronavirus Aid, Relief, and Economic Security Act, we performed comprehensive data analyses on state UI claims data for March 2020 through October 2020. Our analyses identified more than $5.4 billion of potentially fraudulent UI pandemic benefits paid in four specific high-risk areas. The four originally identified high-risk areas were benefits paid to individuals with Social Security numbers: (1) filed in multiple states, (2) of deceased persons, (3) of federal prisoners, and (4) used to file UI claims with suspicious email accounts./10

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7 ETA estimated the fraud rate as part of its Benefit Accuracy Measurement program for the period July 1, 2020, through June 30, 2021. The Benefit Accuracy Measurement program is designed to determine the accuracy of paid and denied claims in three major UI programs: state UI, Unemployment Compensation for Federal Employees, and Unemployment Compensation for Ex-Servicemembers.

8 The 2020 improper payment rate of 9.7 percent was calculated based on 9 months of data, from July 2019 through March 2020, and was reflective of only 8 percent of total program year expenses due to the exclusion of Coronavirus Aid, Relief, and Economic Security Act UI expenditures and the fourth quarter of the program year. The collection of improper payment data from April 2020 to June 2020 was suspended due to the pandemic.

9 COVID-19: States Struggled to Implement CARES Act Unemployment Insurance Programs, Report No. 19-21-004-03-315 (May 28, 2021), available at: https://www.oig.dol.gov/public/reports/oa/2021/19-21-004-03-315.pdf

10 Alert Memorandum: The Employment and Training Administration (ETA) Needs to Ensure State Workforce Agencies (SWA) Implement Effective Unemployment Insurance Program Fraud Controls for High Risk Areas, Report No. 19-21-002-03-315 (February 22, 2021), available at: https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-315.pdf

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Our subsequent analyses of those high-risk areas, using UI claims data through April 2022, brought the cumulative total of potential fraud to more than $45.6 billion./11

We provided ETA with our underlying methodology as well as specific claimant information, and ETA shared the information with states for appropriate action. We are currently performing four separate audits to examine the extent to which ETA and states have taken action on a sample of potentially fraudulent claims in each of the four high-risk areas.

Since our earlier analyses, we have identified almost $1.3 billion in potentially fraudulent UI pandemic benefits paid from March 2020 through April 2022 in two additional high-risk areas. The two additional high-risk areas involve benefits paid to individuals with Social Security numbers: (1) of children under the age of 14 and (2) of elderly persons 100 years of age or older (see Table 1)./12

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Table 1: UI Pandemic Benefits Paid to High-Risk Age Groups, March 2020 through April 2022

Source: OIG data analysis of state UI claims data

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Although these could be legitimate claims, they merit additional oversight and scrutiny as workers typically do not fall into these age categories. For example, the Fair Labor Standards Act of 1938 sets a minimum age of 14 for employment in non-agricultural occupations covered by the act, which effectively limits employment for children under 14 to work that is exempt from the act, such as delivering newspapers and acting.

In addition to the potential fraud risk inherent with children under 14 receiving UI benefits, there is a risk and concern that these children could be victims of child labor exploitation. Since 2018, DOL has seen a 69 percent increase in children being employed illegally by companies. In Fiscal Year (FY) 2022, DOL found 835 companies it investigated had employed more than 3,800 children in violation of labor laws. The OIG is planning to do audit work in this area - which falls under the purview of DOL's Wage and Hour Division - in the future.

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11 Alert Memorandum: Potentially Fraudulent Unemployment Insurance Payments in High-Risk Areas Increased to $45.6 Billion, Report No. 19-22-005-03-315 (September 21, 2022), available at: https://www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-315.pdf

12 To prevent double counting, these results do not include any claims identified in our analyses of the four high-risk areas covered by our previous alert memoranda.

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Further, while there are no legal restrictions placed on elderly workers, it is rare for individuals over the age of 100 to be in the workforce. The U.S. Bureau of Labor Statistics reported the labor force participation rate for people age 75 and older was 8.9 percent in 2020./13

Our analysis identified four states that paid UI claims to 18 percent or more of individuals aged 100 years or older from March 2020 to April 2022./14

If these claims were legitimate, this would indicate a remarkably large percentage of centenarians were still working and eligible for UI benefits in these four states - a trend that was not observed in other states. For example, the State of Michigan paid claims to over 58 percent of its centenarian population during this period, while other states with significantly larger centenarian populations paid claims to less than 1 percent. Excluding the four outlier states with percentages exceeding 18 percent, an average of only 1.2 percent of centenarians in the remaining 46 states received UI pandemic benefits during this period (see Figure 2).

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Figure 2: Percentage of Persons 100 Years of Age or Older with UI Pandemic Benefits Paid from March 2020 through April 2022

Source: OIG data analysis of state UI claims data and 2020 U.S. Census data

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13 Bureau of Labor Statistics, U.S. Department of Labor, The Economics Daily, "Number of people 75 and older in the labor force is expected to grow 96.5 percent by 2030" (November 4, 2021), last accessed August 15, 2023, available at: https://www.bls.gov/opub/ted/2021/number-ofpeople-75-and-older-in-the-labor-force-is-expected-to-grow-96-5-percent-by-2030.htm

14 For this comparison, we used state population data sourced from the 2020 U.S. Census. U.S. Census Bureau, "Exploring Age Groups in the 2020 Census" (May 25, 2023), available at: https://www.census.gov/library/visualizations/interactive/exploring-age-groups-in-the-2020census.html

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Due to the results of our analysis in these two high-risk areas, we remain concerned about the amount of benefits paid in the aforementioned age groups. Further, our latest analysis brings the cumulative total amount of potentially fraudulent payments to more than $46.9 billion15 in the six high-risk areas (see Figure 3),/16 showing how effective and beneficial data analytics can be for providing effective program oversight and combatting fraud.

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Figure 3: Six High-Risk Areas for Potential UI Fraud Identified by the OIG

Source: OIG data analysis of state UI claims data

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In "A Framework for Managing Fraud Risks for Federal Programs," GAO recommends using data analytic tools and techniques to prevent and detect fraud. It states:

'Data analytics activities can include a variety of techniques to prevent and detect fraud. For example, data mining and data-matching techniques can enable programs to identify potential fraud or improper payments that have already been awarded, thus assisting programs in recovering these dollars, while predictive analytics can identify potential fraud before making payments.'/17

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15 Total amounts for these analyses do not include duplicates that were identified in one or more areas.

16 Of the more than $46.9 billion total identified, the OIG had previously reported in prior OIG reports that $45.6 billion in potential fraudulent payments had been identified within four high-risk areas. This report identifies almost $1.3 billion in additional funds put to better use within two additional high-risk areas that were not claimed in our prior reports. See Attachment II for detailed information, including our calculation.

17 Appendix III in the GAO's "A Framework for Managing Fraud Risks in Federal Programs," Report No. GAO-15-593SP (July 2015), available at: https://www.gao.gov/assets/gao-15593sp.pdf

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In addition, the Office of Management and Budget recommends that federal agencies work closely with their data analysts to establish robust analytics capabilities that allow an agency to identify potential improper payments, including fraud, before they occur. Data analytics can include analysis for trends, patterns, anomalies, and exceptions within data sets. The Office of Management and Budget also provides an overview of common data analytic techniques that federal agencies should consider to reduce the risks of improper payments./18

According to ETA, it has developed a preliminary draft of a UI Fraud Risk Profile to align DOL's ongoing fraud risk management activities with GAO's Fraud Risk Framework. ETA also issued guidance in April 2023 to communicate the antifraud strategy for the UI program to the states. This guidance provides states with information on both required and strongly recommended strategies, tools, and services for UI fraud risk mitigation and improper payment reduction./19

ETA's FY 2023 Agency Management Plan states that improving overall program integrity in the UI program is one of the agency's top priorities. Strategy 3.2, "Strengthen Program Integrity by Preventing and Detecting Fraud, and Reducing Improper Payments," indicates that ETA will continue to "promote UI program integrity actively and aggressively by identifying and reducing fraud, waste, and abuse in the program." One of the activities for this strategy is to "invest in technology and data analytics," and specifically:

'Invest in tools and strategies to help states verify [the] identity of UI claimants, promote states' use of these tools/strategies, and perform data analytics to prevent and detect fraud, and reduce investigations backlog. These tools and strategies will be balanced to ensure equitable access and delivery of UI services.'

Another activity identified in ETA's FY 2023 Agency Management Plan is to work with the UI Integrity Center "to promote the consistent use of the Integrity Data Hub (IDH) by states to cross-match with all available datasets and promote the UI Integrity Center's Integrity Knowledge Exchange as a resource for program integrity information, tools (including a data analytics tool), and promising practices to states."

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18 Payment Integrity Alert: The Use of Automation and Data Analytics From the Office of Management and Budget (OMB) Office of Federal Financial Management and the Pandemic Response Accountability Committee (PRAC); posted by the CFO Council on July 21, 2021, available at: https://www.pandemicoversight.gov/media/file/joint-payment-integrity-alert-useautomation-and-data-analytics-omb-and-prac

19 Unemployment Insurance Program Letter No. 22-21, Change 2, available at: https://www.dol.gov/agencies/eta/advisories/uipl-22-21-change-2

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The UI Integrity Center is a joint federal-state initiative funded by DOL and operated by the National Association of State Workforce Agencies./20 It serves as a resource to assist states in their efforts to improve integrity in the UI program, focusing particularly on the prevention, detection, and recovery of improper payments including fraud. One of the services provided by the UI Integrity Center, the IDH, is a multistate data system used for advanced data cross-matching and analysis on submitted claims to help detect and prevent UI fraud and improper payments.

While tools and resources like the IDH can improve program integrity and increase detection and prevention of improper payments, including fraudulent payments, there are significant limitations. First, while ETA encourages states to use the tools available from the UI Integrity Center, ETA maintains that it lacks the authority to require states to participate. To this end, the OIG previously recommended in our first high-risk alert memo,/21 issued in February 2021, that ETA work with Congress to establish legislation requiring state workforce agencies to cross-match high-risk areas, including the four originally identified areas. Consistent with our recommendation, in the FY 2024 President's Budget, ETA included a legislative proposal that would give DOL authority to require states to perform cross-matches using the IDH. Additionally, states that participate in the IDH have been inconsistent in their use of the tool and in the level of claims data shared. For example, as of June 2023, although all 53 state workforce agencies had IDH participation agreements in place, ETA reported only 50 of the 53 state workforce agencies were participating in the IDH multistate cross-matches.

We also found the IDH is limited in its effectiveness in identifying potential improper payments and fraud. We recently reported that the IDH was not able to identify the same amount of potentially improper multistate claims when compared to the OIG's analysis./22 The IDH used a threshold that was higher than what the OIG would use to flag improper multistate claims. However, even when we used the IDH's threshold, we found the IDH only identified 39.7 percent of potential improper multistate claims using data from September 2020, when compared to our analysis. This occurred because the states who participated did not share complete data with the IDH on a consistent basis.

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20 The National Association of State Workforce Agencies is the national organization representing all of the state workforce agencies and whose mission is to enhance the state workforce agencies' abilities to accomplish their goals, statutory roles, and responsibilities.

21 Alert Memorandum: The Employment and Training Administration (ETA) Needs to Ensure State Workforce Agencies (SWA) Implement Effective Unemployment Insurance Program Fraud Controls for High Risk Areas, Report No. 19-21-002-03-315 (February 22, 2021), available at: https://www.oig.dol.gov/public/reports/oa/2021/19-21-002-03-315.pdf

22 COVID-19 - ETA Can Improve its Oversight to Ensure Integrity over CARES Act UI Programs, Report No. 19-23-011-03-315 (September 22, 2023), available at: https://www.oig.dol.gov/public/reports/oa/2023/19-23-011-03-315.pdf

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Finally, even without these limitations, the tools and resources do not relieve ETA from its program oversight responsibilities. ETA has recognized the critical importance of data analytics in detecting and preventing improper payments, including fraud, and improving program integrity. To this end, ETA has invested in providing states with tools through the UI Integrity Center and encouraged states to use data analytics to strengthen program integrity. However, ETA does not have direct access to UI claims data, nor has it developed its own data analytics capability at the federal level as part of its oversight of the UI program.

In its FY 2023 and FY 2024 Congressional Budget Requests for State Unemployment Insurance and Employment Service Operations, ETA included a legislative proposal to allow it to collect and store states' UI claimant data. This proposal would provide DOL "direct access to all claim and wage data used by state agencies in administrating the state's unemployment compensation program solely for the purposes of Federal unemployment compensation administration and to conduct research, evaluation, and performance assessments of unemployment compensation programs and federally funded employment-related programs."/23 Therefore, ETA is aware of its need for access to state UI claims data to provide proper oversight of the UI program.

ETA officials indicated the noted language in its Congressional Budget Requests was included as a component of future UI reform, but it would require statutory authority allowing access to the data, a new records management system, and individual data sharing agreements with states. Because this would take a significant increase in funding and years to plan and achieve, ETA indicated it is focusing its energies and resources on improving integrity controls in the federal-state partnership that reflect the current UI program, such as investing in enhancements to, promoting increased states participation in, and conducting evaluations of the IDH.

Although ETA has stated it needs additional authority to obtain access to state UI claims data, current federal regulations provide such authority for purposes described in this memorandum. Specifically, 20 C.F.R. Sec. 603.6 (a) states that "the Department of Labor interprets Section 303(a)(1), [Social Security Act of 1935], as requiring disclosure of all information necessary for the proper administration of the [UI] program." Additionally, 29 C.F.R. Sec. 96.41 authorizes DOL to obtain UI data from the states to evaluate and improve program integrity. This regulation states that DOL "shall have access to any books, documents... and records (manual and automated) of the entity receiving funds from DOL...for the purpose of making surveys, audits, examinations, excerpts, and transcripts."

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23 FY 2023 Congressional Budget Justification for State Unemployment Insurance and Employment Service Operations, available at: https://www.dol.gov/sites/dolgov/files/general/budget/2023/CBJ-2023-V1-07.pdf; FY 2024 Congressional Budget Justification for State Unemployment Insurance and Employment Service Operations, available at: https://www.dol.gov/sites/dolgov/files/general/budget/2024/CBJ-2024V1-07.pdf

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Conclusion

Ready access to UI claims data from all states and territories would enable ETA to ensure proper administration and provide sufficient oversight of the UI program.

Further, in addition to the tools and resources it provides to the states for fraud detection, such as the IDH, establishing a data analytics capability with a dedicated team of data scientists at the federal level would allow ETA to monitor and analyze UI claims data on an on-going basis. ETA would then be able to identify high-risk areas across multiple states and quickly flag potentially fraudulent claims that can be referred to the OIG and states for further action, which could help prevent future losses to fraudsters. Likewise, incorporating a data analytics capability into its program oversight function would improve ETA's ability to detect trends and emerging issues that could negatively impact the timeliness or equity of UI payments--before the issues grow into critical problems.

Ultimately, a data access and analytics capability would allow ETA management to make better informed decisions about the UI program and help mitigate the risk of improper payments including fraud, while also preparing ETA for future emergency UI programs where hundreds of billions in federal dollars could be at risk.

Recommendations

We recommend the Principal Deputy Assistant Secretary for Employment and Training:

1. Obtain direct access to unemployment insurance claims data from all state workforce agencies.

2. Create an integrity program that incorporates a data analytics capability and regularly monitors state unemployment insurance claims data to detect and prevent improper payments, including fraudulent payments, and to identify trends and emerging issues that could negatively impact the unemployment insurance program.

3. Establish effective controls, in collaboration with state workforce agencies, to mitigate fraud and other improper payments to ineligible claimants in high-risk age categories.

Summary of ETA's Response

On September 6, 2023, ETA provided us its formal response to the draft alert memorandum and recommendations (see Attachment III). ETA agreed with Recommendation 3 and stated it had already implemented controls to mitigate fraud and improper payments to ineligible claimants in high-risk age categories. However, ETA disagreed with Recommendations 1 and 2, stating that they are not achievable at this time without significant new and ongoing appropriations.

For Recommendation 1, ETA stated that it lacks resources to develop a data warehouse that would be required to implement this recommendation. For Recommendation 2, ETA stated that developing a data analytics capability at the federal level would duplicate DOL's ongoing investment in the UI Integrity Center, including the IDH. To address these two recommendations, ETA suggested an alternative approach of working with the UI Integrity Center to improve IDH data analytics capabilities to better identify fraud trends. This would include meeting regularly with the UI Integrity Center to receive information about identified fraud trends and to discuss efforts to mitigate fraud and reduce improper payments.

ETA raised two additional concerns with our alert memorandum, related to our analyses of payments to elderly individuals 100 years of age or older and ETA's legal authority to access state UI claims data.

First, ETA indicated that one of the four outlier states we identified in our analysis had manipulated the date of birth field in the process of creating "pseudo records" for previously identified fraudulent claims. This was done in accordance with ETA guidance to ensure victims of fraud were not unfairly prevented from accessing benefits. According to ETA, 90 percent of the claims we identified for this state were "pseudo records" and not actual payments to individuals 100 years of age or older. ETA also stated that "it advised the OIG of this information and...is disappointed that the OIG did not include this context in the draft alert memorandum...."

Second, ETA raised a concern that the alert memorandum exaggerates DOL's legal authority to obtain data from states. Specifically, ETA stated it can only require the states to disclose claims information that is necessary for the proper administration of the program, and it cannot require states to provide DOL access to all claims data.

OIG Response to ETA Management Comments

For Recommendation 1, the OIG recognizes the resource concerns expressed by ETA and acknowledges there may be other ways that ETA can initially obtain direct access to state UI claims data. For example, with a more complete and consistent data set, the data maintained by the UI Integrity Center could be a potential source for this data until such a time that ETA can allocate funding to establish its own data warehouse.

For Recommendation 2, the OIG disagrees that developing a data analytics capability at the federal level would be a duplicative effort. As we noted in our memorandum, data analytics is an essential tool for program oversight - which is ETA's responsibility - that would allow ETA to improve its detection and prevention of improper payments, including fraud, perpetrated across multiple states, while also preparing ETA for future emergency UI programs where federal money could be at risk.

In relation to ETA's suggested alternative approach, while the suggested actions would likely benefit the UI program, this approach appears to continue shifting program oversight responsibilities to the states and the UI Integrity Center. We noted in our memorandum that states are not required to participate in the IDH, and those that do participate do so to varying degrees--which has limited the IDH's effectiveness. However, even if these limitations were resolved, it would not relieve ETA from its program oversight responsibilities. As such, ETA's suggested alternative approach would not alone meet the intent of the OIG's recommendations.

In relation to the additional concern on our analysis of claims paid to claimants 100 years of age or older, the OIG acknowledged in our memorandum that these claims could be legitimate but they required additional oversight and scrutiny. ETA did not notify us that the claims data contained "pseudo records" with altered dates of birth until it provided that information in its response to our draft memorandum.

Additionally, ETA did not provide us with evidence to support its statement that 90 percent of the claims the OIG identified for this state were "pseudo records." If accurate, this state paid UI claims to 5.9 percent of its centenarians, which was almost 5 times higher than the average of the 46 non-outlier states. The OIG stands by our assertion that all claims paid in high-risk age categories require additional oversight and scrutiny.

We further note that the UI program has experienced historic levels of improper payments. The OIG has issued multiple alert memoranda identifying tens of billions of dollars in potentially fraudulent UI payments identified through our use of data analytics. In addition, GAO recently reported that up to $135 billion could have been lost to UI fraud during the pandemic.

In relation to DOL's legal authority to obtain data from states, the OIG did not recommend ETA acquire unnecessary data but rather, we recommended ETA obtain direct access to UI claims data from all states to improve the accuracy and reliability of results when performing data analytics and oversight of the UI program. ETA should access data that is necessary for, and relevant to, program administration and oversight.

We consider Recommendations 1 and 2 as open and unresolved. For Recommendation 1, ETA should obtain access to the data, ideally developing its own data warehouse; however, until ETA receives sufficient funding, it may be able to obtain access via the UI Integrity Center. For Recommendation 2, ETA should not rely totally on the UI Integrity Center for data analytics capability.

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The memorandum is posted at: https://www.oig.dol.gov/public/reports/oa/2023/19-23-012-03-315.pdf