U.S. RAILROAD RETIREMENT BOARD

OFFICE OF INSPECTOR GENERAL 

Management Information 

Report

Interim Review of Railroad 

Retirement Board CARES 

Act Benefit Payments During

the Pandemic

Report No. 21-04 March 26, 2021
OFFICE OF INSPECTOR GENERAL

U.S. RAILROAD RETIREMENT BOARD

Management Information Report

Interim Review of Railroad Retirement Board 

CARES Act Benefit Payments During the Pandemic

Report Summary March 26, 2021 Report No. 21-04

What We Found

The Coronavirus Aid, Relief, and Economic Security Act (CARES 

Act), signed into law on March 27, 2020, boosts unemployment 

and sickness benefits for railroad workers impacted by the 

pandemic. CARES Act benefit payments were made in three 

phases. Over $13 million in payments have been made through 

December 2020 for phase I. Over $135 million in payments have 

been made through December 2020 for phase II. Over 

$7 million in payments have been made through December 

2020 for phase III. Railroad Retirement Board (RRB) 

management has not addressed their responsibilities to 

increase efforts to identify potential fraud for CARES Act benefit 

payments and the need to send fraud referrals to the Office of 

Inspector General (OIG) in a timely manner. In addition, RRB is 

not set up to collect recoveries involving CARES Act benefit

payments.

What We Recommend

To address the issue about identifying potential fraud for CARES 

Act benefit payments, we recommended that the Office of 

Programs allocate resources to work on fraud referrals. For 

collecting recoveries, we recommended that the Executive 

Committee commit additional resources to implement an 

automated debt recovery process for CARES Act benefit 

payments.

RRB management concurred with the first recommendation 

about allocating resources to make fraud referrals. RRB 

management did not concur with the second recommendation 

about committing additional resources to implement an 

automated debt recovery process for CARES Act benefit 

payments. We continue to see the need for the second 

recommendation.

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 lack of fraud 

referrals and the lack of an 

automated debt recovery system 

for CARES Act benefit payments.

The objective of our continued 

interim review is to provide RRB 

management with information that 

will assist them in ensuring 

compliance, transparency, and 

fiscal accountability under the 

CARES Act.

The scope of this review is the 

RRB’s actions and implementation

of controls over CARES Act benefit 

payments from April 2020 through 

December 2020.
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

Contents

INTRODUCTION 1

OBJECTIVE, SCOPE, AND METHODOLOGY 1

BACKGROUND 2

THE CARES ACT 2

RRB’S ACTIONS UNDER THE CARES ACT 3

RRB ACTIONS IN RESPONSE TO THE CORONAVIRUS PANDEMIC AND THE CARES ACT 5

OIG OVERSIGHT OF CARES ACT FUNDS AT RRB 5

CONTINUED ASSISTANCE TO RAIL WORKERS 6

RESULTS OF REVIEW 7

RESOURCES NOT COMMITTED TO FRAUD IDENTIFICATION 7

RECOMMENDATION 8

MANAGEMENT’S COMMENTS 8

LACK OF AUTOMATED DEBT RECOVERY PROCESS 8

RECOMMENDATION 10

MANAGEMENT’S COMMENTS AND OUR RESPONSE 10

UPDATES ON RECOMMENDATIONS IN THE RRB OIG’S SEPTEMBER 28, 2020 INTERIM REPORT 11

DEPLOYMENT OF MOBILE PHONES TO RRB EMPLOYEES 11

TIMELY COMPARISON OF CARES ACT PAYMENTS TO STATE DATA 11

APPENDIX I: MANAGEMENT COMMENTS 12

APPENDIX II: MANAGEMENT COMMENTS 14

LIST OF FIGURES

FIGURE 1. UNEMPLOYMENT AND SICKNESS CLAIMS AND APPLICATIONS 2

FIGURE 2. PHASE I BENEFITS PAID THROUGH DECEMBER 31, 2020 4

FIGURE 3. PHASE II BENEFITS PAID THROUGH DECEMBER 31, 2020 4

FIGURE 4. PHASE III BENEFITS PAID THROUGH DECEMBER 31, 2020 4
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Interim Review RRB CARES Act – Report No. 21-04 1

INTRODUCTION

This interim report presents additional concerns identified by the Office of Inspector General 

(OIG) as part of our ongoing oversight of the Coronavirus Aid, Relief, and Economic Security Act 

(CARES Act) implementation at the Railroad Retirement Board (RRB).

1 This report addresses 

concerns about controls being applied to RRB issued CARES Act benefit payments. On 

March 11, 2020, the World Health Organization announced that the coronavirus outbreak could 

be characterized as a pandemic. The CARES Act, signed into law on March 27, 2020, boosts 

unemployment and sickness benefits for railroad workers impacted by the pandemic.

Objective, Scope, and Methodology

The objective of our continued interim review is to provide RRB management with information 

that will assist them in ensuring compliance, transparency, and fiscal accountability under the 

CARES Act. 

The scope of this review is the RRB’s actions and implementation of controls over CARES Act 

benefit payments from April 2020 through December 2020.

To accomplish the review objective, we:

 identified criteria for benefit payments from the CARES Act; 

 identified and reviewed RRB internal communication and documentation; 

 interviewed RRB officials; and

 requested and reviewed source documentation from RRB. 

We conducted our oversight work at RRB headquarters in Chicago, Illinois from August 2020 

through February 2021. 

 1 Pub. L. No. 116-136 (2020).
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Interim Review RRB CARES Act – Report No. 21-04

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 

and their families under the Railroad Unemployment Insurance Act (RUIA).

2 These RRB 

programs provide income protection in the event of temporary unemployment or sickness. 

During fiscal year 2020, the RRB paid net unemployment-sickness benefits of $188 million to 

approximately 41,000 claimants. The maximum biweekly rate for unemployment and sickness 

benefits was $800 prior to sequestration. The RRB experienced dramatic increases in both 

unemployment and sickness applications and claims from March to August 2020 and they 

remain greater than pre-pandemic levels. See figure 1 for a graphic illustration of these 

dramatic increases.

Figure 1. Unemployment and Sickness Claims and Applications

Source: OIG generated based on information provided by RRB’s Office of Programs.

The CARES Act 

The CARES Act contains several provisions that affect railroad workers. Under the CARES Act, 

the one-week waiting period required before railroad workers can receive unemployment or 

sickness benefits is temporarily eliminated. This change applies to an employee’s first two-week 

registration period for continuing sickness or unemployment beginning after the effective date 

of the law and ending on or before December 31, 2020. In addition, the amount of 

unemployment benefits is increased by $1,200 per two-week period. This increase is in addition 

 2 45 U.S.C. Sections 351-369, Railroad Unemployment Insurance.

2,281 940

1,466

5,979 7,303

3,505 2,417

1,557 1,012 1,673 2,384 1,708

14,006

11,336 12,324

14,961

29,273

40,417

32,544

25,376

14,498

19,914 19,583 20,196

1,155

974

1,052

2,006 1,624 1,416 2,207

2,735 1,417 2,139 2,749 3,213

11,918

9,510

17,314

16,026

10,007 10,406

9,826

12,026

7,987

12,014 13,062

14,584

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

UI Applications UI Claims SI Applications SI Claims
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Interim Review RRB CARES Act – Report No. 21-04

to the current biweekly maximum. This increased amount applies to any two-week registration 

period beginning on or after April 1, 2020, through July 31, 2020. 

Funding provided for the RRB consisted of 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. If these funds are exhausted, the new provisions will no longer 

apply. The RRB was also awarded an additional amount of $5 million, this amount will remain 

available until September 30, 2021, to prevent, prepare for, and respond to coronavirus, 

including the purchase of information technology equipment to improve the mobility of the 

workforce and provide for additional hiring or overtime hours as needed to administer the 

RUIA. 

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

who received unemployment benefits from July 1, 2019, to June 30, 2020. Under the 

legislation, railroad workers with less than 10 years of service may be eligible for up to 65 days 

of extended benefits within 7 consecutive two-week registration periods. Workers with 10 or 

more years of railroad service, who were previously eligible for up to 65 days in extended 

benefits, may now receive benefits for up to 130 days within 13 consecutive two-week 

registration periods. The payment of these extended unemployment benefits uses remaining 

funds previously appropriated under the American Recovery and Reinvestment Act of 2009 and 

the Worker, Homeownership, and Business Assistance Act of 2009. 

RRB’s Actions under the CARES Act

The RRB chose to distribute the payments under the CARES Act in three phases. The phases 

corresponded to the different provisions provided under the CARES Act as follows:

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

 Phase II was implemented to pay an extra $1,200 CARES Act recovery payment for 

unemployment benefits.

 Phase III was implemented to pay the days of the waiting period for both 

unemployment insurance (UI) and sickness insurance (SI). 

Phase I is being funded with money from prior appropriations under the American Recovery 

and Reinvestment Act of 2009 and the Worker, Homeownership, and Business Assistance Act of 

2009 as allowed under the CARES Act. The remaining amount from these appropriations is 

approximately $133 million. The RRB issued the first extended unemployment benefit 

payments under Phase I in May 2020. The RRB has issued extended unemployment benefits of 

over $13 million or about 10 percent of the total amount remaining, under this provision 

through December 2020 as illustrated in figure 2.
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Interim Review RRB CARES Act – Report No. 21-04

Figure 2. Phase I Benefits Paid through December 31, 2020

Source: OIG generated based on information provided by RRB’s Bureau of Fiscal Operations.

The RRB issued the first CARES Act recovery payment of enhanced unemployment benefit 

payments under Phase II on May 28, 2020. The RRB received an appropriation of $425 million 

to fund these payments under the CARES Act. The RRB has issued CARES Act benefit payments 

of over $135 million or about 32 percent under this appropriation through December 2020 as 

illustrated in figure 3. 

Figure 3. Phase II Benefits Paid through December 31, 2020

Source: OIG generated based on information provided by RRB’s Bureau of Fiscal Operations.

The RRB issued Phase III CARES Act benefit payments for the waiver of the first waiting periods 

for unemployment and sickness 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 completely implemented on August 13, 2020. These benefit payments were 

funded with a $50 million appropriation under the CARES Act. The RRB has issued CARES Act 

benefit payments for Phase III exceeding $7 million or about 16 percent through 

December 2020 under this appropriation as illustrated in figure 4. 

Figure 4. Phase III Benefits Paid through December 31, 2020

Source: OIG generated based on information provided by RRB’s Bureau of Fiscal Operations.

90%

10% Funds Remaining

$119,515,096

Funds Expended

$13,783,485

68%

32%

Funds Remaining

$289,457,409

Funds Expended

$135,542,591

84%

16% Funds Remaining

$42,232,628

Funds Expended

$7,767,372
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RRB Actions in Response to the Coronavirus Pandemic and the CARES 

Act

In response to safety concerns, the RRB closed field offices in March 2020 and provided the 

railroad public with services through alternate means. In addition to the field offices, RRB has 

served railroad workers and railroad employers online and through its national toll-free 

number. In fiscal year 2019, approximately 46,000 of the railroad public visited field offices for 

service. In response to the pandemic, and to ensure the safety of the railroad public and RRB 

employees, all RRB field offices have been closed to the public since March 2020 and telework 

maximized. RRB had to ensure the vast majority of its approximately 812 RRB employees, of 

which approximately 227 work in the field offices, had the resources needed to telework so it 

could help manage the increased customer traffic to its online services and toll-free number. 

In August 2020, the RRB released the RRB’s Return to Facilities at the RRB Plan (Plan), which

describes a framework that will guide RRB through the pandemic. This Plan sets forth a phased 

approach, based upon specific health metrics (i.e. Coronavirus Disease 2019 (COVID-19) 

positivity rate and trend of new COVID-19 cases) to guide the RRB’s movement forward or 

backward through the various phases. The Plan also describes the condition of the RRB’s 

telework posture and public facing operations of each phase. This Plan allows the RRB to 

transition back to in-person agency operations, while balancing the health and safety needs of 

RRB’s employees, as well as the public they serve. The Plan describes a phased approach that 

would shift staffing from a status of maximum telework, which was implemented in response to 

the pandemic, to resuming unrestricted staffing of worksites, with some continued precautions, 

as local conditions allow. Additionally, the RRB developed training to further inform agency 

staff about the pertinent elements of the Plan and discuss how employees can continue to 

reduce the spread of COVID-19. On July 31, 2020, the Board approved this plan and shared the 

Plan with RRB employees on August 21, 2020.

RRB continues to monitor the communities in which the field offices are located. As of 

January 2021, RRB field offices remain on a maximum telework schedule after a brief reopening 

for two weeks in October 2020. 

OIG Oversight of CARES Act Funds at RRB

On May 15, 2020, the RRB OIG issued a CARES Act Oversight Plan.3 This plan detailed the RRB 

OIG’s plan of action for monitoring agency implementation of the CARES Act and the issuance 

of the economic considerations. The objective is to provide RRB management with information 

that will assist them in ensuring compliance, transparency, and fiscal accountability with the 

CARES Act. 

This plan detailed the OIG’s planned actions that included reviewing procedures for 

implementing the provisions of the CARES Act; monitoring the RRB’s approved expenditure 

 3 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).
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plans to ensure that they meet the purposes as defined in the CARES Act; and communicating 

OIG concerns to management’s attention timely during the ongoing oversight process.

This interim report is being issued under the oversight plan to provide transparency to the 

public and to ensure that RRB can review and respond to areas of concern in a timely manner. 

This report addresses concerns with the controls over the CARES Act benefit payments. 

Continued Assistance to Rail Workers 

On December 27, 2020, the President signed into law H.R. 133, the Consolidated Appropriations 

Act of 2021.4 The bill includes a $900 billion comprehensive package to provide COVID-19 relief 

to businesses and individuals, including an extension of unemployment insurance. H.R. 133 is 

the largest assistance package to be considered since passage of the CARES Act in March 2020.

This law includes Subchapter III – Continued Assistance to Rail Workers Act (CARWA). CARWA 

extends the unemployment and sickness benefits that were paid under the CARES Act. The 

provisions that detail the benefit payments for periods beginning December 26, 2020 through 

March 14, 2021 are detailed in sections 231 through 235. 

Since these benefits will be issued after the end of fieldwork for this report, they will not be 

included in the scope of this report. The oversight of the CARWA benefits will be included in a 

subsequent OIG CARES Act report.

 4 H.R.133 - Consolidated Appropriations Act of 2021 (116th Congress 2019-2020), Pub. L. No. 116-260.
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RESULTS OF REVIEW

This interim report details the review of the benefit payment controls and the monitoring of the 

unemployment and sickness payments in response to the CARES Act. The full text of 

management’s response to the recommendations is included in Appendix I and II.

Resources Not Committed to Fraud Identification 

The RRB’s Office of Programs (OP) coordinates and directs services to the beneficiaries and all 

claims processing operations. The Unemployment and Programs Support Division (UPSD) 

performs several functions for the OP, including issuing unemployment and sickness benefit 

payments. The Sickness and Unemployment Benefit Section (SUBS) within the UPSD, makes 

adjudicative decisions on information and issues unemployment and sickness benefit 

payments. Internal procedures place responsibility on SUBS for making fraud determinations 

involving unemployment and sickness applications and claims. SUBS makes the referrals to the 

OIG if SUBS determines fraud may be involved. 

Agency management has not addressed their responsibilities to increase efforts to identify 

potential fraud for CARES Act 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 SUBS to OIG. 

During this time, RRB paid approximately $151 million in CARES Act benefit payments through 

September 16, 2020. 

Since mid-September 2020, one fraud referral has been sent to OIG concerning payments 

involving the CARES Act and it was only provided after the OIG expressed concerns regarding 

the lack of fraud referrals. The individual in SUBS assigned to prepare UI and SI fraud 

determinations for OIG referral left RRB in March 2020.

For fiscal years 2017, 2018, and 2019, the RRB provided a total of 99 referrals to the OIG, Office 

of Investigations (OI), for an average of 33 referrals per year. Prior to CARES Act legislation, 

from October 2019 through April 2020, the RRB provided 18 fraud referrals to OIG OI.

RRB procedures provided in the Adjudication Instruction Manual, part 16, require 

personnel in SUBS to make fraud determinations and to refer suspected cases to OIG 

for fraud investigations. RRB employees that suspect fraud in UI or SI claims refer the 

suspected claims to SUBS. 

In June 2020 the OIG OI informed RRB that for UI and SI fraud notifications, OIG needs to 

receive these referrals as soon as RRB becomes aware of them and that every CARES Act 

payment case should be sent, and to disregard monetary thresholds. 
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OP management explained that SUBS resources are directed to adjudicate and to issue both 

unemployment and sickness benefit payments, staff has not been assigned to work on fraud 

referrals. The one CARES Act referral that was sent to OIG was worked directly by OP 

management. 

Without fraud referrals from SUBS, the RRB cannot identify fraudulent situations timely. Delays 

in the identification of these situations reduces the effectiveness of the investigation. The 

investigation and prosecution of coronavirus fraudulent schemes, including CARES Act benefit 

payments, was made a priority by the Department of Justice in March 2020. The sooner these 

cases are provided to OIG OI for investigation, the opportunity for successfully pursuing 

prosecution increases.

On February 18, 2021 the Inspector General sent a memorandum to the RRB Chairman 

addressing the lack of UI and SI fraud referrals. The Inspector General encouraged the RRB to 

increase oversight and seek immediate solutions to the lack of fraud referrals. 

Recommendation

We recommend that the Office of Programs

1. 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 Office of Inspector 

General, Office of Investigations.

Management’s Comments

The Office of Programs concurred with our recommendation.

Lack of Automated Debt Recovery Process

The RRB’s Debt Recovery Section (DRS) has the responsibility to record, manage, collect and 

account for all debts under the RUIA. This includes mechanically calculating and establishing 

RUIA debts based on information provided by the OP, promptly releasing notices of delinquent 

debts, responding to inquiries regarding delinquent debts, promptly and correctly employing all 

appropriate collection tools and techniques, accurately and efficiently accounting for all 

collections, adjudicating waiver requests, and reporting on the status of debts and collections. 

In September 2020 the OIG asked the OP about debt collection activities involving CARES Act 

benefit payments. OIG learned that RRB is not set up to collect recoveries involving CARES Act 

benefit payments. OIG was told that CARES Act benefits are funded through four different 

funds. While RRB can pay benefits using these sources, they are not yet set up to establish 

recoveries for these various funds. OIG confirmed in February 2021 that RRB has not yet 

finalized a process to establish recoveries for CARES Act benefit payments. The RRB has been 

actively developing a debt recovery process for CARES Act benefit payments since June 2020 

and it is scheduled to be final in mid-March 2021.
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Throughout the CARES Act Oversight project, OIG has received routine updates from OP about 

the work that is underway at RRB for CARES Act updates. A recent update from the OP 

indicated that they continue to work with Bureau of Fiscal Operations (BFO) and Bureau of 

Information Services (BIS) on establishing overpayments for CARES Act benefits.

The RRB has established an Executive Committee (EC) that is directed by and overseen by the 

Senior Executive Officer. The EC is responsible for oversight and problem-solving regarding 

cross-organizational internal control issues. It is composed of the Senior Executive Officer who 

is currently also the Director of Administration. Other members are the General Counsel, the 

Chief Financial Officer, the Director of Programs, the Chief Information Officer, the Director of 

Field Service, and the Chief Actuary.

The RRB has concentrated most of their efforts on issuing CARES Act benefit payments. As a 

result, the development of the debt recovery process has not been completed despite the 

ongoing efforts of OP, BFO, and BIS. These CARES Act benefit payments have been issued since 

May 2020 with no debt recovery procedures yet developed for establishing recoveries and 

recording debt concerning CARES Act benefit payments made in error. BFO has confirmed that 

they are manually keeping a record of all CARES Act benefits that were offset to recover 

traditional UI and SI benefits that were paid in error. RRB confirmed that a final process is 

underway and they recognized that the existing internal controls are deficient and must be 

modified to establish recoveries and record debt for CARES Act benefit payments.

On May 27, 2020, the RRB’s Office of General Counsel advised the OP that recovery of CARES 

Act benefits under section 2(a)(5)(A) of the RUIA are subject to overpayment recovery in the 

same way as other RUIA benefits. According to the Government Accountability Office’s 

Standards for Internal Control in the Federal Government, management should identify, 

analyze, and respond to significant changes that could impact the internal control system.5

These standards also specify that automated control activities tend to be more reliable because 

they are less susceptible to human error and are typically more efficient. 

An automated debt recovery process for CARES Act benefits does not exist because the RRB has 

not dedicated enough resources necessary to develop and implement a debt recovery process 

for CARES Act benefits. The RRB continues to work on developing a debt recovery process for 

the CARES Act benefits.

The recording and tracking of the debts as well as the recovery of debts is more susceptible to 

errors, including omission, when there is no process used for recording and tracking debts. 

Without management designing and implementing control activities to respond to risks, 

including risks of CARES Act benefit payments paid incorrectly, the control deficiencies are not 

remediated.

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

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

We recommend that the Executive Committee

2. commit additional resources necessary to ensure the implementation of an automated 

debt recovery process for CARES Act payments.

Management’s Comments and Our Response

The Executive Committee non-concurred with the recommendation. The full text of the 

comments is found in Appendix II. The Executive Committee stated that the three bureaus 

impacted by updating the existing debt recovery system had made progress from June 2020 

through March 2021 and were able to work with the financial system vendor to successfully put 

in production a modified system that included CARES Act debt establishment and subsequent 

collection. They said that the modifications were in production as of March 15, 2021.

The OIG ‘s recommendation that the Executive Committee commit additional resources 

necessary to ensure the implementation of an automated debt recovery process for CARES Act 

benefit payments remains unchanged. We recognized that recording and tracking of debts and 

recovery of debts is susceptible to errors and omissions when there was no process for CARES 

Act benefit payments that were paid incorrectly. While progress by the RRB has been noted, we 

remain concerned about CARES Act debt establishment and subsequent collection. 

As stated in this report, we acknowledge that the RRB continues to work on developing a debt 

recovery process for CARES Act benefits. OIG did receive an email from RRB on 

February 19, 2021 with an attachment as described in the management comments. We have 

not verified implementation, so the recommendation remains valid and open to ensure the 

implementation of an automated debt recovery process for CARES Act benefit payments. 

Because this audit recommendation will remain open, an audit closure request should be 

submitted to the OIG from the Executive Committee following the routine process that includes 

evidence of implementation. We will review the evidence to determine whether the 

recommendation can be closed as implemented. 
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UPDATES ON RECOMMENDATIONS IN THE RRB OIG’S 

SEPTEMBER 28, 2020 INTERIM REPORT

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

Act Expenditures and Controls, we recommended that the RRB’s EC reconsider the need for all 

RRB employees to have the mobile phone and the related recurring costs and make the mobile 

phone numbers available internally for the RRB employees since these are considered

secondary contact methods.6

The RRB’s EC did not concur with the recommendation to reconsider the need for all RRB 

employees to have mobile phones, but did concur to make the phone numbers available 

internally. The RRB completed the deployment of all the mobile phones by November 2020. 

Timely Comparison of CARES Act Payments to State Data 

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

provisions of the CARES Act since May 2020. These benefit payments continue to be issued 

without any concurrent checks against state wages and unemployment benefits 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 EC obtain state wage and 

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

payments; thereby identifying potential fraudulent CARES Act benefit payments quicker and 

increasing program integrity.7 The RRB’s EC did not concur with the recommendation. 

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

benefit payments with state data should result in the RRB performing some additional 

procedures outside of the normal state wage matching process. The RRB has still not attempted 

to identify other sources of wage information that could help in the identification and review of 

fraudulent payments. The RRB needs to use other tools that could be used for CARES Act

benefit payments such as The Work Number. The Work Number is used in certain 

circumstances to get timely wage and employment information in cases of continuing disability 

reviews. In fact, RRB examiners are required to obtain and verify employment and income using 

The Work Number for all Railroad Retirement Act disability claims and all Social Security Act 

disability claims when developing for continuing disability reviews.

 6 RRB OIG, Interim Report Regarding CARES Act Expenditures and Controls, Report No. 20-08 (Chicago, IL: 

September 28, 2020).

7 RRB OIG, Report No. 20-08.
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APPENDIX I: MANAGEMENT COMMENTS
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APPENDIX II: MANAGEMENT COMMENTS
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