Request to Amend Unemployment Insurance Program Letter

The undersigned charitable nonprofit organizations write to share concerns regarding Unemployment Insurance Program Letter (UIPL) No. 18-20, which provides instructions to states as they provide unemployment insurance (UI) relief to certain nonprofit organizations. Because this guidance disrupts the charitable nonprofit sector’s ability to provide critical services to those in greatest need during the COVID19 pandemic, we urge the Department to withdraw this guidance, and to issue clarifying guidance that encourages state unemployment systems to exercise flexibility in relation to payments from self-insured organizations, particularly by providing self-insured nonprofits a credit for the 50 percent federal unemployment relief as opposed to a reimbursement.