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

📋
Measures Legal Consistency
Determines whether decisions on paid leave claims are consistent with Oregon law and program policy — identifying where program operations align or diverge from the rules and statutes that govern them.
📊
Surfaces Program Trends
Aggregates findings into reports that identify systemic patterns across the program — giving leadership a clear, data-driven picture of where legal compliance is strong and where gaps exist.
⚖️
Ensures Program Accountability
Provides program leadership with objective data on how well the program is operating within the bounds of Oregon law and administrative rule — supporting informed oversight and policy decisions.
🛡️
Protects Claimants
Ensures Oregonians receive the benefits they've earned — correctly determined and grounded in the rules and statutes that govern the paid leave program.
Who conducts reviews

Compliance Specialist 2 (CS2) and Compliance Specialist 3 (CS3) staff complete structured scorecard reviews on assigned claims.

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 previous framework flagged that an error occurred — but not which Oregon rule or statute was not followed. Without that specificity, the program had no way to track which legal requirements were consistently being missed, and staff could not be trained on the precise OAR or ORS provisions the program must meet. V3 identifies exactly which law or rule applies to each decision, making legal compliance visible and trainable.

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, Assistance Grant applications, and Employer Equivalent Plans 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

The old scorecards reviewed the same claims, leave types, and eligibility issues we review today. The difference: V3 holds every decision to the standard of Oregon law and administrative rule — not manual procedures. That shift identifies program compliance as a whole.

Before — December 2025
Scorecard 1
Basic Claims
Reviewed via manual SOPs
Employer information, leave type determinations (allowed & denied), employer notification of leave
Scorecard 2
Benefit Eligibility
Reviewed via manual SOPs
9 eligibility issue types — late applications, employment coverage, equivalent plans, and others
The gap
✗  Decisions measured against procedure, not law
✗  No link to specific OAR or ORS citation
✗  Could confirm process was followed — not that the decision was legally correct
✗  5 claim areas entirely unreviewed
Version 3 — 2026
↺ Same Coverage · New Standard
Basic Claims
Same areas reviewed — employer information, leave types, employer notification
Now reviewed directly against specific OAR & ORS provisions — not manual procedures
What law-first review identifies
+ Pre-determination accuracy against the applicable statute
+ Decision letter compliance with legal notice requirements
Every question cites the OAR or ORS it verifies
↺ Same Coverage · New Standard
Eligibility Issues
All 9 issue types still reviewed — late apps, coverage, equivalent plans, and others
Now reviewed directly against specific OAR & ORS provisions — not manual procedures
What law-first review identifies
+ Period range compliance with statute (start date, end date, or both)
+ Decision letter compliance with legal notice requirements
Every question cites the OAR or ORS it verifies
★ 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
· 5 program areas reviewed for the first time:
Self-Employed · Designated Rep · Appeals · Assistance Grants · Equiv. Plans
The shift — from procedure compliance to program accountability

V3 does not ask "did staff follow the procedure?" — it asks "does this decision comply with Oregon law?" By anchoring every review question to a specific OAR or ORS, V3 identifies program compliance as a whole, not just whether internal steps were followed. This is the same citation-based methodology used in federal unemployment insurance audit programs — and it positions the program to demonstrate legal accountability under any future oversight.

New in V3

Rule & Statute Compliance Scorecard

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

2
Benefit Eligibility
21
Claim Decisions
6
Designated Rep ✦ New
7
Appeals ✦ New
9
Assistance Grants ✦ New
18
Equivalent Plans ✦ New
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.
5 New Coverage Areas
Designated Representatives, Appeals, Assistance Grants, Equivalent Plans, and Self-Employed claimants — 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, Assistance Grants, and Employer Equivalent Plans now reviewed for the first time.
🖥️
Let's See It in Action
A tour of the V3 Compliance Scorecard, live Dashboard, and Claims Assigner — the full system in action.
V3 Compliance Scorecard Compliance Dashboard Claims Assigner
Ed Rose
Compliance Manager
Oregon Employment Department