U.S. RAILROAD RETIREMENT BOARD

OFFICE OF INSPECTOR GENERAL 

Management Information 

Report

Railroad Retirement Board’s

Actions in Response to 

Pandemic Funding

Report No. 22-06 March 16, 2022
OFFICE OF INSPECTOR GENERAL

U.S. RAILROAD RETIREMENT BOARD

Management Information Report

Railroad Retirement Board’s Actions 

in Response to Pandemic Funding

Report Summary March 16, 2022 Report No. 22-06

What We Found

This report presents recommendations and updates on prior 

issues raised by the Office of Inspector General (OIG) during our 

oversight of the actions of the Railroad Retirement Board (RRB) 

while implementing the Coronavirus Aid, Relief, and Economic 

Security Act (CARES Act) and the subsequent related laws. The 

series of laws in 2020 and 2021 provided economic relief to the 

rail community and the RRB during the pandemic. These laws 

were the CARES Act, the Continued Assistance to Rail Workers 

Act (CARWA), and the American Rescue Plan Act (ARPA). Each 

act provided for the payment of enhanced and extended 

benefits under the Railroad Unemployment Insurance Act. This 

report addresses the transparency in the RRB’s reporting of 

CARES Act obligations and their hiring practices using ARPA 

funding. This report also addresses RRB communication of 

COVID-19 purchase card requirements.

What We Recommend

To address the weaknesses identified in this review, we made 

three recommendations. We recommended that RRB reconcile 

obligations reported to determine the correct total for 

obligations charged to a $5 million technology appropriation. 

We recommended that RRB establish a group tasked with hiring 

decisions and that the group use documented and reliable 

procedures for hiring using ARPA appropriations. We also 

recommended that RRB reconsider and revise its plans for 

hiring based on ARPA appropriations.

RRB management did not concur with the three 

recommendations.

We continue to see the need for these recommendations. 

What We Did

The OIG works to provide oversight 

to all aspects of agency 

responsibility, which includes 

monitoring the implementation of 

significant provisions of laws and 

regulations and major projects to 

identify at-risk situations.

Consistent with this approach, we 

examined the transparency in the 

RRB’s reporting of CARES Act 

obligations and the RRB hiring 

using ARPA funding.

Our objective was to provide RRB 

management with information that 

would assist them in ensuring 

pandemic funding compliance, 

transparency, and fiscal 

accountability. 

The scope of this review was the 

RRB’s actions and monitoring of 

the appropriated pandemic 

funding and the hiring practices

under the ARPA appropriation.
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

Contents

INTRODUCTION 1

OBJECTIVE(S), SCOPE, AND METHODOLOGY 1

BACKGROUND 1

THE PANDEMIC FUNDING 3

RRB’S ACTIONS WHILE ISSUING BENEFITS WITH PANDEMIC FUNDING 4

RRB OIG OVERSIGHT OF THE RRB’S PANDEMIC FUNDING 4

RESULTS OF REVIEW 6

REPORTING OF OUTLAYS AND OBLIGATIONS UNDER THE INFORMATION TECHNOLOGY 

APPROPRIATION 6

RECOMMENDATION 7

MANAGEMENT’S COMMENTS AND OUR RESPONSE 7

RRB’S HIRING DECISIONS UNDER AMERICAN RESCUE PLAN ACT 8

RECOMMENDATIONS 10

MANAGEMENT’S COMMENTS AND OUR RESPONSE 10

REPORTING OF PURCHASE CARD TRANSACTIONS 11

UPDATES TO RECOMMENDATIONS IN THE RRB OIG’S SEPTEMBER 28, 2020 AND MARCH 26, 2021

INTERIM REPORTS 12

DEPLOYMENT OF MOBILE PHONES TO RRB EMPLOYEES 12

TIMELY COMPARISON OF CARES ACT PAYMENTS TO STATE DATA 12

RESOURCES NOT COMMITTED TO FRAUD IDENTIFICATION 13

LACK OF AUTOMATED DEBT RECOVERY PROCESS 13

APPENDIX I: MANAGEMENT COMMENTS 14

LIST OF FIGURES

FIGURE 1. 2020-2021 UNEMPLOYMENT APPLICATIONS AND CLAIMS 2

FIGURE 2. 2020-2021 SICKNESS APPLICATIONS AND CLAIMS 2
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 1

INTRODUCTION

This report presents additional recommendations and updates on prior issues raised by the 

Office of Inspector General (OIG) during our oversight of the actions of the Railroad Retirement 

Board (RRB) while implementing the Coronavirus Aid, Relief, and Economic Security Act (CARES 

Act) and the subsequent related laws.1 A series of laws in 2020 and 2021 provided economic 

relief to the rail community and the RRB. These laws were the CARES Act, the Continued 

Assistance to Rail Workers Act (CARWA), and the American Rescue Plan Act (ARPA).2 Each act 

provided for the payment of enchanced and extended benefits under the Railroad 

Unemployment Insurance Act (RUIA). This report addresses the transparency in the RRB’s 

reporting of CARES Act obligations and their hiring practices using ARPA funding. This report 

also addresses RRB communication of COVID-19 purchase card requirements. In this report, the 

funding received under all programs will be referred to as “pandemic funding.”

Objective(s), Scope, and Methodology

The objective of our review was to provide RRB management with information that would

assist them in ensuring pandemic funding compliance, transparency, and fiscal accountability. 

The scope of this review was the RRB’s actions and monitoring of the appropriated pandemic 

funding and the hiring practices under the ARPA appropriation.

To accomplish the review objective, we:

 held bi-weekly discussions to coordinate efforts that included Office of Audit, Office of 

Investigations, and the OIG’s General Counsel;

 identified criteria for RRB appropriations from the pandemic funding;

 reviewed regular status updates provided by the RRB’s Bureau of Information Services 

and Office of Programs (OP);

 interviewed RRB officials; and

 requested and reviewed source documentation from RRB.

We conducted our oversight work at RRB headquarters in Chicago, Illinois from March 2021 

through September 2021.

Background

The RRB is an independent agency in the executive branch of the Federal Government. The RRB 

administers the unemployment and sickness insurance benefit programs for railroad workers 

 1 Pub. L. No. 116-136 (2020). 2 H.R. 133-776 (2021) and Pub. L. No. 117-2 (2021).
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 2

and their families under the RUIA.3 These RRB programs provide income protection in the event 

of temporary unemployment or sickness. The RRB experienced significant increases in both 

unemployment and sickness applications and claims beginning in March 2020 and continuing 

into 2021. See Figures 1 and 2 for graphic illustrations of these increases.

Figure 1. 2020-2021 Unemployment Applications and Claims 

Source: RRB OIG Analysis of RRB’s Office of Programs data.

Figure 2. 2020-2021 Sickness Applications and Claims 

Source: RRB OIG Analysis of RRB’s Office of Programs data.

 3 45 U.S.C. 11, Railroad Unemployment Insurance Act.

0

10,000

20,000

30,000

40,000

50,000

2020-2021 Unemployment Applications and Claims

UI Applications UI Claims
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 3

The Pandemic Funding

The CARES Act, signed into law on March 27, 2020, boosted unemployment and sickness 

benefits for railroad workers impacted by the pandemic. The RRB received funding with an 

appropriation of $425 million to pay for the increase in unemployment benefits and an 

additional $50 million to cover the cost of eliminating the waiting period. The RRB was also 

awarded an additional $5 million to remain available until September 30, 2021 to prevent, 

prepare for, and respond to coronavirus, including the purchase of information technology (IT) 

equipment to improve the mobility of the workforce and provide for additional hiring or 

overtime hours as needed to administer the RUIA.

Under the CARES Act, the one-week waiting period required before railroad workers received

unemployment or sickness benefits was temporarily eliminated through December 31, 2020. In 

addition, the amount of unemployment benefits was increased by $1,200 per two-week period

for any two-week registration period beginning on or after April 1, 2020, through July 31, 2020.

The CARES Act also authorized payment of extended unemployment benefits to rail workers 

who received unemployment benefits from July 1, 2019 to June 30, 2020. The payment of these 

extended unemployment benefits used remaining funds previously appropriated under the 

American Recovery and Reinvestment Act of 2009 and the Worker, Homeownership, and

Business Assistance Act of 2009.4

The unemployment and sickness benefits established under the CARES Act were extended on 

December 27, 2020 with H.R. 133, the Consolidated Appropriations Act of 2021.5 The benefit 

provisions for the CARES Act benefit payments were extended for periods beginning 

December 26, 2020 through March 14, 2021. The increase to weekly unemployment was 

reduced to $600 per two-week period. These benefits were paid from remaining CARES Act 

funds.

ARPA provided the most recent pandemic funding and extended those same benefit provisions 

allowed under the CARES Act. 6 ARPA was signed into law March 11, 2021 and extended the 

benefits created with the CARES Act. The increase in weekly unemployment remained at $600 

per two-week period. These benefits were extended through registration periods beginning on 

or before September 6, 2021. ARPA appropriated an additional $2 million to fund the additional 

extended unemployment insurance benefits.

ARPA also appropriated an additional $27.975 million to remain available until expended, to 

prevent, prepare for, and respond to the pandemic. Of this total, $6.8 million was for additional 

hiring and overtime bonuses as needed to administer the RUIA, and the remaining 

$21.175 million for supplementing the Board’s IT Investment Initiatives. 

 4 Pub. L. No. 111-5 (2009) and Pub. L. No. 111-92 (2009). 5 H.R.133 - Consolidated Appropriations Act of 2021 (116th Congress 2019-2020). 6 Pub. L. No. 117-2 (2021).
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 4

RRB’s Actions While Issuing Benefits with Pandemic Funding

The RRB issued unemployment and sickness benefit payments using the pandemic funding in 

three phases corresponding to the benefits provided. The phases started with the CARES Act 

payments, but continued under the same method for the CARWA and ARPA payments. The 

phases corresponded to the type of benefit provided under the legislative acts as follows:

 Phase I was implemented for the extended unemployment insurance benefits. The RRB 

issued the first extended unemployment benefit payments under Phase I on 

May 10, 2020. The RRB issued benefits of over $45 million under this provision through 

August 2021.

 Phase II was implemented to pay the extra CARES Act Recovery Payments (CARP) for 

enhanced unemployment benefits. The RRB issued the first CARP enhanced 

unemployment benefit payments under Phase II on May 28, 2020. Under the CARES Act, 

these enhanced benefits were $1,200 per two-week period. The payments were 

reduced to $600 per two-week period in the subsequent acts. The RRB issued benefit 

payments exceeding $194 million under this provision through August 2021. 

 Phase III was implemented to pay the waiver of the waiting period for unemployment

and sickness insurance. The RRB issued these payments in two releases. The first release 

began to issue payments for new unemployment and sickness waiting periods and was 

implemented on July 13, 2020. The second release was for the retroactive payment of 

the first unemployment and sickness waiting periods and was implemented on 

August 13, 2020. The RRB issued benefits exceeding $12 million through August 2021 

under this appropriation. 

RRB OIG Oversight of the RRB’s Pandemic Funding 

The RRB OIG continued to perform oversight of the RRB since we issued our CARES Act 

Oversight Plan on May 15, 2020.7 In accordance with this plan, we monitored agency 

implementation of the pandemic funding and provided RRB management with information to 

assist them in ensuring compliance, transparency, and fiscal accountability with the CARES Act, 

CARWA, and ARPA. 

We previously issued two management information reports on the RRB’s actions under the 

CARES Act. The first report was issued on September 28, 2020.8 This report addressed concerns 

about the RRB’s purchase and deployment of mobile phones for all employees, as well as 

concerns about CARES Act benefit payments being issued without any concurrent checks 

against state wage and unemployment benefit data for the same periods. Our second report 

was issued on March 26, 2021.9 This report addressed concerns about identifying potential 

 7 Railroad Retirement Board (RRB) Office of Inspector General (OIG), Railroad Retirement Board’s Office of 

Inspector General Coronavirus Aid, Relief, and Economic Security Act Oversight Plan (Chicago, IL: May 15, 2020). 8 RRB OIG, Interim Report Regarding CARES Act Expenditures and Controls, Report No. 20-08

(Chicago, IL: September 28, 2020). 9 RRB, OIG, Interim Review of Railroad Retirement Board CARES Act Benefit Payments During the Pandemic, Report 

No. 21-04 (Chicago, IL: March 26, 2021).
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fraud for CARES Act benefit payments and the resources committed to implement an 

automated debt recovery process for CARES Act benefit payments. 

As part of the ongoing oversight, the RRB OIG contracted with outside auditors to perform 

reviews of the RRB’s mobile phone deployment and the modernization appropriation awarded 

under ARPA. Audit reports will be issued at the conclusion of these contracted audits. Also as 

part of our ongoing oversight, we are currently auditing the extended benefit payments issued 

to railroad employees as a result of the pandemic legislation. We will also address internal 

controls for these benefit payments. That audit report will be issued later in this fiscal year.
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 6

RESULTS OF REVIEW

Our review identified inconsistencies in the reporting of outlays and obligations reported to 

Office of Management and Budget (OMB) for the $5 million CARES Act appropriation and 

questioned the hiring process and documentation supporting those hiring decisions with the 

funding provided under ARPA.

In addition, our review of RRB purchase card COVID-19 requirements found that the RRB 

properly communicated the requirements even though no COVID-19 related transactions were 

identified or reported to the RRB Program Coordinator. 

See Appendix I for the full text of management’s response to our findings and

recommendations.

Reporting of Outlays and Obligations under the Information Technology

Appropriation

The amounts that have been reported to OMB in the outlay reports do not reflect the same 

obligations as reported to USAspending.gov. The outlay report to OMB reflects total obligations 

for the $5 million appropriation of $4,018,904 as of June 30, 2021. This amount was

significantly less than the amounts reported through USAspending.gov for RRB COVID-19 

outlays and obligations. USAspending.gov reflects outlays by the RRB that total $6,302,005 and 

COVID-19 obligations of $14,466,034 as of June 28, 2021.

Memorandum OMB M-20-21 (OMB M-20-21) provides guidance for agencies to implement the 

requirements of Sections 15010 and 15011 of the CARES Act.10 These sections require Federal 

agencies to report on the use of covered funds and in coordination with OMB to provide user 

friendly means for recipients to meet these requirements. In accordance with this directive, 

RRB’s Bureau of Fiscal Operations (BFO) began reporting obligations for the $5 million 

appropriation to OMB on a weekly basis with the RRB’s Report of COVID-19 Outlays report

(outlay report) since May 2020. The outlay report was developed with guidance from OMB and 

originally included both outlays and obligations. After consultation with OMB in 

September 2020, the RRB changed to reporting only obligations.

The RRB also reports total obligations for the $5 million appropriation to OMB through 

USAspending.gov. USAspending.gov provides outlay data for COVID-19 showing what agencies 

have paid out, in addition to the existing obligation data showing what agencies have promised 

to pay.

During our review, OIG attempted to determine the obligations that should be charged against 

this appropriation using information from various sources. These sources had conflicting 

information on the obligation amounts. The lack of consistent data on the amounts obligated 

 10 Office of Management and Budget (OMB), Implementation Guidance for Supplemental Funding Provided in 

Response to the Coronavirus Disease 2019, Memorandum M-20-21 (Washington, D.C.: April 10, 2020).
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 7

prevented a reconciliation.

OMB M-20-21 requires agencies to incorporate reporting of performance on COVID-19 relief 

funding into their established mission performance plans and reports to the maximum extent 

possible. OMB indicated that spending transparency and regular reporting provides important 

accountability mechanisms to help safeguard taxpayer dollars and agencies must report 

information on awards to provide the public with information in a clear, accurate, and timely 

manner.

OMB M-20-21 also requires agencies to submit financial and award data to USAspending.gov. 

These submissions include summary financial data, obligation and outlay data by program 

activity and budget object class, and summary award-level obligation data.

The RRB’s BFO provided instructions for creating the outlay report. These instructions do not 

address a reconciliation of the COVID-19 obligations reported to OMB through 

USAspending.gov and the obligations reported to OMB through the weekly outlay report. 

The RRB was not providing OMB with consistent COVID-19 spending and obligation data and

did not satisfy the spending transparency requirement under OMB M-20-21. The inconsistent 

amounts reported to OMB as total obligations under the $5 million technology appropriation 

could also affect the accuracy of tracking these appropriated funds. 

Recommendation

We recommend that the Bureau of Fiscal Operations:

1. reconcile the obligations as reported to USAspending.gov and the weekly outlay report 

to determine the correct total for Coronavirus Disease 2019 obligations charged to the 

$5 million technology appropriation.

Management’s Comments and Our Response

RRB management did not concur with recommendation 1. The RRB Executive Committee 

answered this recommendation noting that because the Chief Financial Officer is also a 

member of the RRB’s Executive Committee, the response to the financial issues have been 

incorporated and are included in the consolidated response from the Executive Committee 

rather than being provided separately. 

The RRB Executive Committee stated that BFO reconciled the monthly OMB Outlay Report to 

the DATA Act and Government-wide Treasury Account Symbol Adjusted Trial-Balance System 

submissions for the period ending December 2021. They noted that the OIG stated via email 

that “[s]ince the information indicates changes made subsequent to the reporting period, we 

will not be making a change to the report.” See Appendix I for the full response.

The OIG‘s recommendation 1 remains unchanged. During fieldwork, several attempts were 

made to identify the obligations that should be charged against this appropriation and to 

reconcile to the OMB Outlays report. Due to conflicting source information, a reconciliation 
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Railroad Retirement Board’s Actions in Response to Pandemic Funding - Report No. 22-06 8

could not be performed despite numerous communications with staff in BFO. The reconciliation 

that RRB references in their response was based on changes subsequent to the period referred 

to in this report; therefore, no change is made to the recommendation.

RRB’s Hiring Decisions under American Rescue Plan Act

Congress, through Section 2904 of ARPA, provided the RRB a $6.8 million appropriation for 

additional hiring and overtime bonuses as needed to administer RUIA. In response to an OIG 

inquiry, the RRB Senior Executive Officer indicated that the $6.8 million will be used to hire 40 

to 45 additional claims representatives for the RRB’s Bureau of Field Service (BFS) and 15 claims 

examiners for OP.

The RRB’s Justification of Budget Estimates for fiscal year 2022 included a discussion of 

impending retirements and the need to hire staff to fill those vacancies. According to this 

justification, the ARPA appropriation will temporarily support RRB efforts of hiring to “manage 

the increased workloads resulting from the pandemic.” Further, the Justification for Budget 

Estimates in the section “High Priority Staffing Need” documents that BFS was operating at a 

27 percent staffing deficit in fiscal year 2020.

We have reliability concerns with the decision to hire additional claims representatives because 

we were not provided with supporting documentation. We inquired of the RRB’s Executive 

Committee to identify the group responsible for making staffing decisions, but no answer was 

received. RRB did not provide a reliable method for calculating staffing levels and did not 

provide a risk assessment for determining staffing needed to meet critical mission essential 

needs.

For example, RRB stated that the ARPA appropriation would be used in part for hiring 

additional claims representatives. To analyze the need for the additional claims representatives, 

we gathered statistics from RRB for call volumes, visits, and number of full-time equivalents in 

BFS for fiscal years 2016 through 2020. Using those statistics in a data analytics model, we

performed a regression analysis. Our analysis found a strong correlation between the number 

of calls and visits and the number of full-time equivalents required. Then, we used a regression 

prediction with actual fiscal year 2020 claims representative headcount and found that the 

actual headcount was higher than what was needed to handle the actual calls and visits. 

In the Fiscal Year 2022 Justification of Budget Estimates, RRB refers to the attrition that was 

cited and stated an inability to fill BFS positions. We analyzed the yearly attrition from 2016 

through 2020 and found the average attrition to be two percent, or four claims representatives, 

which was far below the additional 40 to 45 claims representatives to be hired. We also 

evaluated the average number of calls answered by claims representatives for fiscal years 2016 

and 2020 and found an average decrease of 20 percent. 

We did not attempt to determine the number of claims representatives or claims examiners 

that the RRB should hire. However, our analysis of attrition suggests that only four new claims 

representatives would need to be hired and the regression prediction model we developed 

using 5-year data estimates suggests that only one new claims representative should be hired. 
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Based on our analytics and evaluation, it appears BFS plans to hire a greater number of claims 

representatives than was necessary. RRB did not provide any substantive evidence or models to

support the number of claims representatives for BFS or claims examiners for OP that RRB 

planned to hire. 

During our review, we learned that 15 individuals were hired as OP claims examiners with the 

ARPA appropriation. These 15 individuals started training in August 2021 with an expected 

completion date in April 2022. We were not provided documentation to support the decision to 

hire these 15 claims examiners. 

OP represented that during a typical day for a BFS claims representative, they would spend 

80 percent of their time on telephone calls. Our analysis of the call statistics that we obtained 

for the fiscal years 2019 and 2020 yielded a conclusion that about 19 percent of a claims

representatives’ time would be spent on calls. OIG’s concern was the apparent disparity 

between BFS analysis of 80 percent and OIG analysis based on call statistics of 19 percent and 

that without a reliable method to base hiring decisions, these decisions appear to be inefficient 

and ineffective. OIG analysis did not find severe understaffing in BFS, as described by BFS 

officials. 

Staffing levels have decreased in BFS for fiscal years 2016 through 2020. Our analysis indicates 

that while the staffing levels have decreased in fiscal years 2019 and 2020, existing staff levels 

continue to provide approximately the same level of support for calls/visits. Therefore, the 

reduction in the staffing levels has not impacted the amount of calls/visits they service. 

A concern exists about the ability of RRB to fund the costs of these additional hires after the 

$6.8 million appropriated in the ARPA is exhausted. OIG concerns extend to the possibility that 

if the majority of claims representatives’ time in BFS are spent on telephone calls, then space in 

RRB headquarters in Chicago could be used and the space for field offices across the United 

States could be reduced or eliminated. 

Government Accountability Office’s Standards for Internal Control in the Federal Government 

specifies that agencies should use quality information that is current, accurate, and provided on 

a timely basis to achieve its objectives and inform its decisions.11 Internal controls would enable 

RRB to provide reasonable assurance that the objectives of the RRB will be achieved. RRB lacks 

reliable methods for calculating staffing needs and did not prepare adequate documentation to 

support hiring decisions.

Inefficient hiring practices lead to increased budgets without program efficiencies and results. 

By developing a reliable method for calculating staffing levels, RRB would have a more accurate 

picture of the extent of any shortfalls and could take corrective action to address identified 

gaps.

 11 Government Accountability Office, Standards for Internal Control in the Federal Government, GAO 14-704G 

(Washington, D.C.: September 2014).
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Recommendations

We recommend that the Railroad Retirement Board’s Executive Committee:

2. establish a group tasked with hiring decisions for appropriated funds from the American 

Rescue Plan Act. This group should use documented and reliable procedures that are 

based on accurate and reliable data sources to determine hiring and staffing levels using 

appropriated funds from the American Rescue Plan Act; and 

3. reconsider and revise its plans concerning hiring based on the American Rescue Plan Act

appropriation because adequate supporting documentation had not been prepared.

Management’s Comments and Our Response

The Executive Committee (EC) did not concur with recommendation 2. The EC is the group, at 

the RRB, tasked with determining hiring priorities and the appropriate use of funds, whether 

from RRB’s annual appropriation, the American Rescue Plan Act (ARPA), or any other source of 

annual or emergency funding. The EC stated information about how they make their hiring 

decisions and what information they use for these decisions. See Appendix I for the full 

response.

The OIG‘s recommendation 2 remains unchanged. The documents to which the EC referred to 

in their non-concur response were documents previously provided to the OIG. The EC referred 

to Basic Board Order 2 that directs the EC to develop the RRB’s Human Capital Plan (HCP). The 

Board Order suggests that each EC member develop a human capital plan for their organization 

and then work together on an overall plan. The OIG accepts the Board Order for its direction to 

the EC. The issue for the OIG is that RRB lacks reliable methods for calculating staffing needs 

and did not prepare adequate documentation to support its hiring decisions. These elements 

are not specified in the Basic Board Order. A HCP for RRB labeled for fiscal year 2021, but 

not dated as to when it was prepared, was provided to the OIG. Some information is 

given in this plan; however, the OIG’s concern is with the plan’s lack of supporting data, and 

lack of a reliable method for calculating staffing needs and for hiring based on those needs. This 

issue is not addressed in the HCP.

The EC did not concur with recommendation 3. RRB points out that OIG questions the reasons 

and support behind the hiring of claims examiners in OP and claims representatives in BFS. See 

Appendix I for the full response.

The OIG’s recommendation 3 remains unchanged. In their response, the EC referenced a 

document they provided to the OIG that was prepared for the Committee on Oversight and 

Reform. That document contains bullet points that list the impacts of the pandemic and 

resulting office closures and restrictions. It also enumerates various items of workloads for 

claims examiners, but it does not provide data or a methodology for what is being counted. 

The documentation does not provide an explanation of how the additional hiring of 

another 15 individuals will impact the workloads. Much of the increased workloads are the 

result of pandemic-related occurrences that will decrease over time.
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The EC referenced the HCP and states that it is further support that the RRB planned to hire 10 

additional claims examiners into the SUBS section of OP. The OIG’s issue is not the HCP, it is the 

lack of supporting data and the need for a reliable methodology, including a risk assessment.

The EC stated that they already had plans to hire 5 new staff and replace 51 additional staff for 

field service over the period of fiscal years 2022 through 2024 in anticipation of promotions. 

The EC also stated that pandemic funding allowed them to accelerate the hiring of 40 to 45 of 

these positions in the current year to address increased workloads pursuant to the pandemic. 

The EC also provided details on the average wait time for customer calls in reference to the 

additional hiring for BFS. However, the OIG’s issue is that while staffing geographically 

dispersed field offices may increase the number of calls they can answer and decrease call wait 

times, this approach may not be the most efficient and cost-effective means to address these 

concerns. The OIG’s concerns extend to the possibility that if the majority of claims 

representatives’ time in BFS is spent on telephone calls, then space in RRB Headquarters in 

Chicago could be used for this purpose and the space for field offices across the United States 

could be reduced or eliminated. The OIG offered this proposal as a possible improvement for 

business efficiency in a prior report.12

Reporting of Purchase Card Transactions

RRB has a program for purchase card use and purchase card requirements. The procedures are 

documented in Administrative Circular, OA-21.13 This program was managed by the Program 

Coordinator as identified in the administrative circular. On April 16, 2020, the Program 

Coordinator notified all RRB purchase card holders of the COVID-19 requirements found in 

OMB M-20-21 that apply to purchase card transactions. OMB M-20-21 contained a reference to 

purchase card use for COVID-19. Further guidance was issued with OMB M-20-27 in 

July 14, 2020.

14

The CARES Act oversight team inquired of the RRB Program Coordinator in November 2020 and 

in July 2021. The RRB continues to administer the purchase card program and the card holders 

have been notified of the COVID-19 requirements. No COVID-19 related transactions were 

identified or reported to the RRB Program Coordinator.

 12 RRB OIG, Office of the Inspector General’s Proposal to Improve Business Efficiency at the Railroad Retirement 

Board (Chicago, IL: September 21, 2011). 13 RRB Administrative Circular OA-21, Government Purchase Card Procedures, September 25, 2020. 14 OMB, Additional Guidance on Federal Contracting Resiliency in the Fight Against the Coronavirus Disease

(COVID-19), Memorandum M-20-27 (Washington, D.C.: July 14, 2020).
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UPDATES TO RECOMMENDATIONS IN THE RRB OIG’S 

SEPTEMBER 28, 2020 AND MARCH 26, 2021 INTERIM REPORTS

Deployment of Mobile Phones to RRB Employees

RRB approved an operating plan for the $5 million appropriation under the CARES Act. As part 

of this plan, the RRB purchased 685 mobile phones that were received in the RRB’s inventory as 

of April 17, 2020. The RRB expected to complete deployment of all the mobile phones by 

August 31, 2020, but the deployment was not completed until November 6, 2020. 

In our September 28, 2020 OIG Report 20-08 Interim Report Regarding CARES Act Expenditures 

and Controls, we recommended that the RRB’s Executive Committee reconsider the need for all 

RRB employees to have the mobile phone and the related recurring costs. We also 

recommended that the RRB make the mobile phone numbers available internally since these 

are considered secondary contact methods.15 The RRB’s Executive Committee did not concur 

with the recommendation to reconsider the need for all RRB employees, but did concur to 

make the phone numbers available internally. 

The OIG will continue to review the RRB‘s implementation and usage of the mobile phones with 

a contracted audit. The contracted audit for the continued review of the mobile phones began 

in September 2021.

Timely Comparison of CARES Act Payments to State Data 

The RRB had continued to issue additional unemployment and sickness benefits under the 

provisions of the CARES Act. These benefit payments were issued without any concurrent 

checks against state wage and unemployment benefits data for the same periods. In our 

September 28, 2020 OIG Report 20-08 Interim Report Regarding CARES Act Expenditures and 

Controls, we recommended that the RRB’s Executive Committee obtain state wage and 

unemployment data in a timelier manner in order to match with CARES Act RRB payments; 

thereby identifying potential fraudulent CARES Act payments quicker and increasing program 

integrity.16 The RRB’s Executive Committee did not concur with the recommendation. 

In our response in the interim report, the OIG indicated that the lack of timely matching of 

CARES Act payments with state data should require the RRB to perform some additional 

procedures outside of the normal state wage matching process (SWM). 

A September 2021 update from OP indicated that the RRB had not identified any new tools that 

capture real time employer information outside of the SWM process. However, once cases are 

identified through the SWM process, The Work Number allows the agency to obtain up-to-date 

wage information on a case-by-case basis. The agency was unable to perform timelier batch 

processing with The Work Number due to provisions in the Computer Matching and Privacy 

 15 RRB OIG, Report No. 20-08. 16 RRB OIG, Report No. 20-08.
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Protection Act, cost, and higher agency priorities.

Resources Not Committed to Fraud Identification

In our previous review, RRB management had not addressed their responsibilities to increase 

efforts to identify potential fraud for the pandemic funding benefit payments and the need to 

send fraud referrals to the OIG in a timely manner. RRB began issuing CARES Act benefit 

payments in May 2020. From May 2020 through September 15, 2020, no fraud referrals were 

sent from the RRB Unemployment and Programs Support Division – Sickness and 

Unemployment Benefit Section to OIG. During this time, RRB paid approximately $151 million in 

CARES Act benefit payments. 

In our March 26, 2021 OIG Report 21-04 Interim Review of Railroad Retirement Board CARES 

Act Benefit Payments During the Pandemic, we recommended that the OP allocate resources 

for the RRB Unemployment and Programs Support Division – Sickness and Unemployment 

Benefit Section to work on fraud referrals as provided in the Adjudication Instruction Manual, 

Part 16, and as instructed by the OIG, Office of Investigations.17 The RRB concurred with our 

recommendation.

The RRB has started to commit additional resources for fraud identification as evidenced by the 

RRB Unemployment and Programs Support Division – Sickness and Unemployment Benefit 

Section preparing individual cases for the RRB OIG’s Office of Investigations. They have also 

provided hiring plans that support providing additional resources. The OIG will continue to 

monitor the fraud identification efforts of the RRB through an on-going audit.

Lack of Automated Debt Recovery Process

The RRB issued benefit payments under the pandemic funding beginning in May 2020 with no 

debt recovery procedures developed for establishing recoveries and recording debt concerning 

benefit payments made in error. In our March 26, 2021 OIG Report 21-04 Interim Review of 

Railroad Retirement Board CARES Act Benefit Payments During the Pandemic, we 

recommended that the Executive Committee commit additional resources necessary to ensure 

the implementation of an automated debt recovery process for CARES Act payments.18 The RRB 

non-concurred with the recommendation indicating that sufficient resources had been 

committed.

A modified system that included CARES Act debt establishment and subsequent collection was 

implemented as of March 15, 2021. The RRB reports that overpayments for benefit payments 

established through July 2021 totaled $416,821 with recoveries of $157,749.

 17 RRB OIG, Report No. 21-04. 18 RRB OIG, Report No. 21-04.
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APPENDIX I: MANAGEMENT COMMENTS
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