Internal
Compliance Unit · Oregon Employment Department

Paid Leave Oregon
Compliance Program V3

A new standard for compliance review — built for accuracy,
grounded in Oregon law, and designed for what's next.

Ed Rose
Compliance Manager · Oregon Employment Department
July 2026
Overview

Today's Agenda

1
The Role of Compliance ReviewOur compliance unit, what we do, and the previous framework
2
What Changed in V3Redesigned scorecards — Basic Claims & Eligibility
3
The Rule & Statute LayerAn entirely new dimension of compliance review
4
Platform & TechnologySmartsheets, the Compliance Hub, and case assignment
5
Rollout TimelineCS3 testing now · CS2 training begins August 3
Family
Foundation

The Role of Compliance Review

📋
Tracks Decision Accuracy
Measures whether staff decisions on paid leave claims align with policy, procedure, and Oregon law — producing a consistent, defensible record of program performance.
📊
Surfaces Trends
Aggregates findings into monthly reports that identify systemic error patterns and training opportunities, giving leadership an accurate picture of where the program stands.
🔁
Drives Improvement
Provides program leadership with data-driven insights to support targeted coaching, policy refinement, and process improvement across the compliance unit.
⚖️
Protects Claimants
Ensures Oregonians receive the benefits they've earned — correctly determined, properly documented, and grounded in the rules and statutes that govern the program.
Who conducts reviews

Compliance Specialist 2 (CS2) and Compliance Specialist 3 (CS3) staff complete structured scorecard reviews on assigned claims — using approved procedures and data from the Frances system.

Background

The Previous Framework

Established December 2025 · Two scorecards · CS2 & CS3 responsibilities
Scorecard 1
Basic Claims
  • Employer Information (EI)
  • Leave Type — Allowed (LIA)
  • Leave Type — Denied (LID)
  • Employer Notification of Leave (NOL)
Scorecard 2
Benefit Eligibility
  • Not Currently Employed (NE)
  • Not Covered Employment (NC)
  • Late Application (LA)
  • Week Claimed Late (WCL)
  • Other Coverage — UI & Workers' Comp
  • Equivalent Plans (Sim. Coverage & Active BY)
  • Penalty Waiver (PW)
Review Approach
How It Worked
  • Manual Excel Assigner sheet for case routing
  • Compliance note created manually in Frances
  • Yes/No branching with error sub-categories
  • Benefit Payment Impact (BPI) captured per error
  • Monthly report provided to program leadership
📌
CAM Review — Discontinued December 2025

A quality assurance process that monitored customer care phone interactions was retired when the current compliance reviews launched. This work was absorbed into customer care's own internal review processes.

Rationale

Why V3? Four Identified Gaps

1
Limited Error Specificity

The old system flagged that an error occurred — but not which type. V3 identifies exactly what went wrong, enabling targeted coaching, policy feedback, and meaningful trend analysis.

2
No Statutory Grounding

Previous reviews checked process adherence but did not verify decisions against Oregon Administrative Rules or Oregon Revised Statutes. V3 adds that verification layer directly into every review.

3
Coverage Blind Spots

Self-employed claimants, Designated Representative interactions, the Appeals process, and Assistance Grant applications were not reviewed under the prior framework. V3 covers all of them.

4
Operational Systems at Their Limit

The claims assignment process relied on Microsoft Excel pushed beyond its functional capacity. Because reviews were tied to Issue IDs rather than Claims, the Assigner could not be properly configured in the program's management platform — creating workflow instability.

V3 Changes

The Scorecard Evolution

V3 is not an update — it's a rebuild. We moved from checking "was the decision correct?" to verifying decisions against the specific Oregon laws and rules that govern every step of the process.

Before — December 2025
Scorecard 1
Basic Claims
"Was the decision correct?"
Reviewed: Employer information, leave type determinations (allowed & denied), employer notification of leave
Scorecard 2
Benefit Eligibility
"Was the decision correct?"
Reviewed: 9 eligibility issue types — late applications, employment coverage, equivalent plans, and others
Not captured
✗  No link to specific OAR or ORS
✗  Pre-determination accuracy not assessed
✗  Decision letter accuracy not scored
✗  Reason for errors not documented
✗  4 claim areas entirely unreviewed
Version 3 — 2026
↺ Rebuilt
Basic Claims
Guided decision-tree — every question routes automatically to the correct next step
Standardized error categories — consistent capture across all reviewers
New additions
+ Were leave dates & schedule accurate before the determination?
+ Were the correct decision letters sent to both the claimant and employer? Are form numbers documented?
Each step tied to specific OAR & ORS citations
↺ Rebuilt
Eligibility Issues
All 9 issue types now follow identical, consistent branching logic
No reviewer discretion on what to ask — the flow is the same every time
New additions
+ Why did the period range fail? (Start date, end date, or both — documented every time)
+ Was the correct decision letter sent and properly documented on every error found?
Each step tied to specific OAR & ORS citations
★ Brand New
Rule & Statute Compliance
Does every decision comply with the specific Oregon rule or statute that governs it?
· 80+ questions — each cites a specific OAR or ORS provision
· Frances navigation embedded at every step
· 8 program areas, including 4 reviewed for the first time:
Self-Employed · Designated Rep · Appeals · Assistance Grants
Why this structure matters — law, accountability & federal readiness

Every V3 question is anchored to a specific Oregon statute or administrative rule — the same citation-based methodology used in federal unemployment insurance audit programs. If this program ever underwent federal oversight or alignment review, our compliance records would already be structured to meet that standard.

New in V3

Rule & Statute Compliance Scorecard

80+ questions anchored directly to Oregon Administrative Rules (OAR) and Oregon Revised Statutes (ORS)

6
Benefit Eligibility
17
Claim Decision
5
Designated Rep ✦ New
7
Appeals ✦ New
9
Assistance Grants ✦ New
19
Equivalent Plans
14
Self-Employed ✦ New
80+
Total Questions
OAR / ORS Anchored
Every question is tied to a specific rule or statute. Reviewers see the citation directly in the scorecard.
Frances Navigation Embedded
Step-by-step Frances system navigation is built into each question — eliminating guesswork for reviewers.
4 New Coverage Areas
Self-employed claimants, Designated Representatives, Appeals, and Assistance Grants — all reviewed for the first time.
Platform

Technology & Tools

All V3 infrastructure is built and ready — scorecards, dashboards, and case assignment in one platform.
📋
Digital Scorecards
All three scorecards built in Smartsheets and the Compliance Hub. Decision-tree logic is enforced digitally — reviewers are guided through the correct path automatically, with no ambiguity.
📊
Real-Time Dashboards
Live compliance data visibility for the team and leadership. Replaces the manual, Excel-dependent reporting cycle with automated, always-current metrics and trend visibility.
📁
Improved Assigner — Full Claims, Not Just Issues
Previously, reviewers were assigned to specific issues within a claim — meaning a claim could be partially reviewed or touched by multiple reviewers independently. V3 shifts to full-claim review: each assigned case is a complete claim reviewed end-to-end. Claims enter a rolling queue within 14 to 45 days of their decision and are assigned at random for consistent, comprehensive coverage across the caseload.
Platform note

Built in Smartsheets and the AI-powered Compliance Hub. All tools have been tested by CS3 staff during the familiarization phase and are confirmed ready for CS2 training.

Rollout

Training & Implementation Timeline

May – July 2026
Build & Development Complete
All three scorecards, dashboards, and the Assigner built and finalized. SOPs documented. Tools validated by the compliance team.
Now · July 2026
CS3 Testing & Familiarization
CS3 staff are actively using all V3 tools — testing scorecards, validating the Assigner workflow, and building hands-on familiarity ahead of full deployment.
August 3, 2026
CS2 Training Begins
Structured one-month training for all CS2 staff on V3 tools, updated procedures, and the new Rule & Statute scorecard. CS3 staff serve as peer resources throughout.
~September 3, 2026
Full Team Deployment
Training complete. Full compliance unit operational on V3. First V3 monthly report to program leadership to follow shortly after.
Paid Leave Oregon · Compliance Unit

A More Rigorous,
Data-Rich Compliance Program

Built on what we know, grounded in Oregon law, and designed for what's next.

Better Error Intelligence
We now know not just that an error occurred, but exactly why — enabling targeted coaching and systemic fixes.
Statutory Compliance Verified
Every decision reviewed against the actual Oregon rules and statutes that govern the Paid Leave program.
Full Program Coverage
Self-employed, Designated Rep, Appeals, and Assistance Grants now reviewed for the first time.
🖥️
Let's See It in Action
A live walkthrough of the new scorecards and review process — what reviewers see from start to finish.
Basic Claims Decision Tree Eligibility Scorecard Flow Rule & Statute Tool Case Assignment & Queue
Ed Rose
Compliance Manager
Oregon Employment Department