Benefits fraud detection system studies

To Whom It May Concern:

Pursuant to the North Carolina Public Records Law, I hereby request records related to ID verification and unemployment fraud detection tools used by the department.

In an Unemployment Insurance Program Letter published in November 2023 (UIPL No. 1-24), the U.S. Department of Labor provided the following instructions to state agencies responsible for unemployment benefits:

"When a state notices that individuals are unable to verify their ID through web-based or selfservice means, or the state flags individuals as suspicious with automated cross-matching or data analytics activities, states must generate and retain documentation of these instances. States are also required to investigate the flags and make appropriate determinations so that eligible claimants are able to access UI benefits without undue barriers or delay. The state UI agency should then analyze the data to determine if the state’s ID proofing system, fraud detection and prevention solutions, cross-matching and data analytic parameters, or service provider(s) correctly identified fraud or incorrectly flagged claimants. In line with their nondiscrimination obligations under 29 CFR §38.51, states should conduct statistical or other quantifiable data analyses to determine whether their fraud detection systems are disproportionately flagging certain groups."

I request:

1) All contracts the department has entered into since Jan. 1, 2020 for the provision of unemployment fraud detection tools. This includes identity verification tools and data analytics services such as risk-scoring and fraud-scoring algorithms.

2) All analyses of the accuracy of the department's fraud detection tools, as requested by the Department of Labor in UIPL No. 1-24. This should include analyses conducted by the department or provided to the department by the vendor or a third pary since Jan. 1, 2020.

3) All analyses of whether the department's fraud detection tools disproportionately flag certain groups, as requested by the Department of Labor in UIPL No. 1-24. This should include analyses conducted by the department or provided to the department by the vendor or a third pary since Jan. 1, 2020.

I ask that all fees be waived as I am a journalist and intend to used the requested records to publish articles in the public interest and not for any commercial purpose.

If you choose to impose fees, I request a detailed breakdown of the fees, including the hourly wage of each employee involved and an explanation of the employee hours required to fulfill the request.

If you choose to reject this request or redact portions of responsive documents, I ask that you provide a detailed breakdown of the statutory exemptions and associated case law underlying your decision to withhold each/any portions from public review.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days.

Sincerely,

Todd Feathers