2022-029 Improve Controls over the Identification, Recording, and Reporting of Overpayments Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor did not maintain adequate controls over the identification, recordin...
2022-029 Improve Controls over the Identification, Recording, and Reporting of Overpayments Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: The Georgia Department of Labor disagrees with this finding. USDOL provides guidance and recommended procedures for crossmatches but does not dictate a frequency or cadence for performing them. The crossmatch process is conducted using third party software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. The audit report indicates misinterpretation of the data reflected on the federal reports, specifically the ETA 227. The ETA 227 is for reporting of overpayment detection and recovery activities that the Agency performed in a quarter. It is not for reporting the amount of benefits overpaid for specific weeks during that quarter. A federal reporting team was created to accurately identify and track overpayments. The Department is taking necessary actions to complete the overpayment reconciliation for the ETA 227 and 902 reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it would require multiple GDOL staffing levels to review all cross matches, requiring increased levels of state and federal funding. Summary GDOL has developed an aggressive plan to complete all remaining state and pandemic program cross matches. We have filled all of our budgeted positions for the Overpayment Unit and are utilizing non-overpayment staff to assist with identification and overpayment investigations. Additionally, we are utilizing temp agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. In early 2022, we started to freeze the overpayment data at the end of every month so that we can conduct periodic reconciliation of the overpayment records. GDOL is coordinating with USDOL to ensure the timely and accurate identification, tracking and reporting of overpayments. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: January 1, 2022 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov