The Benefit Accuracy Measurement (BAM) program is a federal program designed to assess the accuracy of paid and denied unemployment insurance (UI) claims, according to the Employment and Training Administration’s (ETA’s) “Benefit Accuracy Measurement Program Fact Sheet.” BAM program audits are required by Section 602 of Title 20 of the Code of Federal Regulations. The Department of Unemployment Assistance (DUA), as part of the BAM program, evaluates its accuracy in administering the Commonwealth’s UI program. This administration includes DUA’s review of a claimant’s availability for work and their efforts to find suitable employment. As part of this process, DUA randomly selects weekly BAM samples of UI claim payments and denials from three groups: general claimants, federal employee claimants,20 and ex-service member claimants.21 It also looks at DUA’s determinations for approving and denying eligibility.
States with a higher number of claims must use a sample size of 480 cases per year for BAM investigation, according to the “Benefit Accuracy Measurement Program Fact Sheet.” DUA must also select a sample of 150 cases per year for each type of denial: monetary, separation, and nonseparation. Using this system, in order to complete the BAM investigation, DUA usually selects at random 10 paid claims and 9 unpaid claims each week, but the sample size may vary depending on weekly claim volumes. The goal is to ensure sufficient coverage throughout the year to meet the required sample size.
During the audit period, DUA did not complete the required number of claim reviews to meet BAM program requirements. Specifically, we found the following issues:
- In fiscal year 2023, DUA reviewed 439 paid claims, 137 monetary claims, 134 separation claims, and 133 nonseparation unpaid claims.
- In fiscal year 2024, DUA reviewed 434 paid claims and 135 claims in each denial category.
By not completing the required number of claim reviews (480 per year), DUA may limit its ability to accurately assess both paid and denied claims, which could increase the risk of DUA not identifying improper payments.
DUA stated that the shortfall was because of staffing constraints during the implementation of the Employment Modernization and Transformation system, which temporarily reduced DUA’s BAM Unit from 10 investigators to 4. BAM investigators were reassigned to support the system launch because of their professional expertise in DUA’s claims process. DUA stated that, despite this reassignment, it was able to complete 91% of the required claim investigations for fiscal year 2023 and 90% for fiscal year 2024.
DUA should ensure that its BAM Unit completes the required number of reviews for paid claims and for each denial category to comply with federal BAM program requirements.
Auditee’s Response
As DUA was preparing to transition from its legacy system to a new, modernized [Employment Modernization and Transformation (EMT)] system, BAM staff were temporarily reassigned to support the project, and DUA was unable to meet the minimum required number of audits during the audit period. Those staff have now returned to the BAM unit, restoring the unit’s capacity to timely complete BAM casework.
DUA has also taken additional corrective actions to strengthen BAM operations. . . . The agency is actively working to hire two BAM investigators, which will increase investigative capacity and help ensure that required audit completion levels are met. . . .
The new EMT system has incorporated BAM functionality, including a case management tool designed to reduce the amount of clerical time required to develop and manage BAM cases. This system enhancement is expected to improve workflow efficiency, allow investigators to focus more time on substantive case review, and support more timely completion of BAM audits.
DUA is committed to meeting BAM requirements consistent with federal guidelines. DUA will continue to monitor staffing levels, workload, and case completion rates to ensure that the BAM unit completes the required number of audits going forward and that public guidance accurately reflects its current practices.
Auditor’s Reply
Based on its response, DUA is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | September 21, 2026 |
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