Project 2025 Tracker / What’s done, what’s next

18. Department of Labor and Related Agencies · Notable

Offer states waivers from Social Security Act UI requirements

Not started

605 18. Department of Labor and Related Agencies

“Offer waivers for suitable alternatives. DOL should offer waivers from the standard requirements imposed on unemployment compensation by § 303(a) and § 303(d) of the Social Security Act to states that propose suitable alternatives.”

What has happened

  1. Not started

    The Department has offered states no waivers from the section 303(a) or 303(d) requirements of the Social Security Act. Its unemployment insurance rulemaking in the window pushes the other way — toward more federal specification, not less: a proposed rule on Federal-State UC data availability (2025-08-29), a proposed rule on the recoupment of benefit overpayments (2026-07-06), and an announced rulemaking on state work-search requirements (RIN 1205-AC31, NPRM scheduled November 2026). The Unemployment Insurance Program Letter channel, where such an act would be announced, was enumerated on 2026-09-06 through ETA's own advisories index: filtering to the UIPL category and to issue dates from 2025-01-20 returns exactly 25 advisories, and every one is routine. Fourteen are quarterly Disaster Unemployment Assistance minimum benefit amounts, annual COLA and General Schedule pay adjustments, sequestration implementation, resource planning targets, State Quality Service Plan guidance, RESEA funding allotments, Payment Integrity Information Act reporting procedures and identity-verification funding; the four in-window changes to earlier letters cover the transition of UI reporting and Benefit Accuracy Measurement applications off the UI Data Base, FY2024 funding amendments, and the rescission of UIPL 01-24 on equitable access; UIPL 02-26 removes summary and background language from active guidance to align it with EO 14148. None approves an administrator and none offers a waiver.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Negative search: chapter log, Cluster negative search — the unemployment insurance asks (#1645, #1646, #1647, #1663, #1664, #1665).
  • Section 303 waiver authority is narrow to begin with — the section conditions the payment of administrative grants on state conformity — so a waiver program of the kind the Quote imagines would itself be novel. Nothing in the window attempts one.
  • Corrected 2026-09-06 (read-queue ticket 07). UIPLs are readable; the route and the control test are written up in #1663’s notes. All 25 in-window UIPLs were enumerated by slug and by subject line, and a full-text search of the advisories (which reads the attached PDFs) for waiver over the window returns two documents, both about WIOA Governor’s Reserve waivers under 20 CFR 679.620 rather than Social Security Act § 303 waivers.
Action
issue
Object
Waivers from Social Security Act §303 UI requirements
ID
1664