Unemployment Insurance Technology Pain Points Across Three States

Aiming to prevent economic collapse during the height of the COVID-19 pandemic, Congress approved unprecedented levels of financial aid for unemployed workers–some $787 billion and created several pandemic unemployment insurance (UI) programs. States saw the claims volume skyrocket overnight, causing UI systems to crash and effectively blocking claimants from filing. Simultaneously and while state systems were most vulnerable, they were sustaining attacks from organized criminal groups, amounting to billions lost to fraud.

In March 2021, Congress responded to the cascading set of UI technology failures by providing $2 billion in the American Rescue Plan Act (ARPA) to the U.S. Department of Labor (DOL) to improve UI technology in three areas: improving timeliness of benefit payments, increasing equitable access to UI for disenfranchised workers, and detecting and preventing organized criminal fraud. Two years later, Congress rescinded $1 billion from the DOL ARPA funding as part of the Financial Responsibility Act. Ultimately, DOL has awarded $783 million in grants to states for UI modernization.

Throughout the pandemic and beyond, legal aid advocates have been essential in helping workers secure benefits, and increasingly informing state technology systems. To learn more about pain points these workers face in digital state UI systems, we spoke with legal aid advocates from Massachusetts, Michigan and Washington. The advocates are members of the Unemployment Insurance Technology Coordinating Coalition, a community of practice of the Digital Benefits Network (DBN) that engages cross-sector practitioners, including states, legal advocates, labor unions, technologists, think tanks, and other nonprofits through bi-weekly calls, annual convenings, closed-door sessions, research, and technical assistance in order to improve the technology delivery of the UI system.

The advocates interviewed recognized the challenges state UI administrators face in balancing the needs of ensuring payment timeliness, improving equitable access, and detecting and preventing fraud, and shared that their labor agencies are doing more outreach to advocates for conversations to improve delivery. They have noticed the improved engagement and a change in the tone of communication from agency leaders that acknowledges that better technology can help improve service delivery.


Common Pain Points 

The interviews revealed observations of a common set of UI claimant pain points in core themes including identity verification, mobile device accessibility, and digital communications. 

Account creation and identity verification as first steps can cause delays. 

In Michigan, Jacob Fallman works as an advocate with the Sugar Law Center, working on behalf of claimants in accessing the state’s UI system. The center handles more than 200 UI cases a year, and the majority of those cases involve appeals once workers have initially been denied benefits. Michigan requires claimants to first create a state Single Sign-On (SSO) account and enter a Social Security Number before they start applying for UI benefits. Once an account is created, an individual can start applying for UI and is prompted to submit additional forms of identity verification, like a driver’s license, to complete the application. This creates several challenging steps for claimants ahead of claim filing. 

The DBN offers data about how UI agencies are using authentication and identity proofing as part of their processes, and also recently wrote about promising practices in digital identity in public benefits. 

There are no alternatives when online processes fail. 

Anne Paxton, an attorney and policy director with the Unemployment Law Project in Washington, co-authored a new report that interviewed 100 workers on their experiences applying for UI. Paxton highlighted when workers cannot get their identity verified online, they cannot go any further in the process. Paxton cited a number of examples where claimants submitted a driver’s license multiple times, but the system failed to validate it, which led to delays—sometimes months-long—before benefits would be paid. 

As a staff attorney for Greater Boston Legal Services, Jason Salgado helps Massachusetts clients access UI, from filing the initial application to resolving appeals, including representation in court. In order to address an onslaught of likely fraudulent claims during the pandemic, the Massachusetts Department of Unemployment Assistance (DUA) added additional identity verification to the UI claim process. Most recently, via partnership and funding from US DOL, DUA transitioned their identity verification to Login.gov offered as a service by the federal government, which provides a technology offramp for in-person verification through a USPS location. 

There are short windows from online to offline communications.

When using Login.gov in Massachusetts, claimants only have five days after getting a notice from DUA to verify their identity. Salgado expressed that this is not enough time for the claimants he works with, who are often unaware of the five-day limit. Salgado has observed an additional challenge for people who request information on their claim in a language other than English, which means information associated with their claim will be sent through the mail, including requests for additional identity verification. This could lead to the identity verification notice arriving after or right before the expiration of the five-day period. He recently observed an example of the mail notice arriving on the fourth day. If the code expires, claimants have to navigate an appeals process and hearing, potentially delaying their benefits. 

Online does not equal mobile friendly.

In Massachusetts and Michigan, Salgado and Fallman both agreed another frustration for UI claimants is that current online systems are designed for desktop computers and not for mobile devices like phones and tablets. The clients they serve rely on smartphones to access UI and often do not have access to a desktop computer. Salgado explained claimant notices arrive as PDF documents in their UI portal account. When they open the notice a new browser window launches, which mobile users have difficulty accessing. 

In Washington, Paxton highlighted that the Employment Security Department designed for mobile phone access, yet claimants are still experiencing issues with certain features. Important boxes that the claimant needed to click to proceed—visible on a computer screen—are often cut off on the smartphone screen and out of reach of their scrolling. Several claimants were also perplexed when trying to download a PDF; their only option seemed to be cumbersome page-by-page screenshot saves. Other users said they regularly checked a box so that the system would remember their phone to avoid future two-factor authentication requirements, however users noted that their phone was not remembered at a future sign in.

Online status tracking for offline interactions creates confusion.

As Massachusetts, Michigan, and Washington drive UI claims processing online, agency communications to claimants via web portals can cause pain points. Salgado offered examples in Massachusetts where in some disputed wage cases, the agency asks claimants to send wage documentation to a PO Box in Boston, but the claimant cannot track online if the agency has received that information. In Michigan, claimants who cannot read English are excluded entirely from the unemployment agency web portal. Workers who primarily use other languages, such as Spanish or Arabic, must file for benefits over the phone or visit an unemployment agency office in person to access benefits.

Different communications are sent to online and offline inboxes. 

Fallman highlighted the challenges for access and protecting due process that emerge from government systems that are not well integrated. For unemployment claimants in Michigan, the first two steps in the benefit appeals process occur within the Unemployment Insurance Agency (UIA). If a claimant is dissatisfied by UIA’s initial decision, they can protest it by mail, phone, or the online portal. The same is true if a claimant appeals the subsequent redetermination issued by the UIA. However, if a claimant pursues additional appeals, this is where the technology and the communication about an individual’s claim can break down and cause challenges for claimants. 

Those additional appeals, which are usually related to worker benefit entitlement or employer liability issues, are handled by separate agencies. The Michigan Office of Administrative Hearings and Rules (MOAHR) handles appeals related to the first level redeterminations. Appeals beyond that are managed through the Unemployment Insurance Appeals Commission (UIAC-housed inside UIA), and those decisions can be appealed to a circuit court. The decisions related to those appeals beyond the initial redetermination are sent through the mail and not tied to the claimants UI portal account, or accessible online at all. For Fallman, because the UIA promotes online claims filing, he argues that it sets an expectation that all claim related information, including appeals, will be available online by a claimant. However, this is not the case and claimants have missed appeal deadlines because of this false expectation. Fallman is optimistic that over time agencies will coordinate their technology to address these concerns. Already, MOAHR is developing an electronic claims filing system for unemployment appeals, and have been actively soliciting feedback from advocates. 

UI plays a vital role in financially stabilizing workers after job loss. As Paxton noted, it is very stressful to be unemployed and workers have many time pressures when they are unemployed, especially for finding new work. If claimants do not have a clear understanding of the processes and steps—including not having clear communication guidance on websites—and if the technology is not functioning for the users, it adds to the stress of being unemployed. Today, the majority of claimants are interfacing with state UI systems online. But they may face issues related to access because of limited mobile-friendly interfaces, lack of clear communications, notifications, and customer experience challenges related to identity verification. Federal and state governments and advocates and community organizations working together to identify and address pain points will help ensure that federal investments in UI modernization will work for claimants and employers alike. 

Ensuring that workers can easily file and receive benefits through the web and on any device should be a primary mission for labor agencies in the 21st century. We see promising efforts and investments across the country to ensure that UI digital services work for claimants and employers.