PAN Lab example
Michigan MiDAS
Automation without review: a benefits-fraud system
Michigan's MiDAS system wrote unemployment fraud determinations into claimant records, often with no human review. It wrongly accused tens of thousands of people.
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MiDAS, Michigan's Integrated Data Automated System, is the system Michigan's Unemployment Insurance Agency used to decide whether claimants had committed unemployment insurance fraud. From October 2013 to September 2015 it made many of those fraud determinations by algorithm alone, with no human involvement. It issued accusations, penalties, and collections on them.
What happened
The sources count more than 60,000 fraud determinations from 2013 to 2015. IEEE Spectrum reports that from October 2013 to September 2015, MiDAS decided 40,195 fraud cases by algorithm alone. Of those determinations, 85 percent were wrong.
Another 22,589 cases had some human involvement, and 44 percent of those were wrong. The Benefits Tech Advocacy Hub reports that a 2016 review of 22,000 MiDAS fraud determinations found 93 percent did not involve fraud. The sources do not say how these counts relate to each other.
The Benefits Tech Advocacy Hub says the system falsely accused 40,000 people of fraud in its first two years. IEEE Spectrum counts more than 34,000 wrongly accused from October 2013 to September 2015. Quadruple penalties, wage garnishment, and tax refund seizures followed. The sources also record bankruptcies.
Reporting, the Michigan Attorney General's office, and incident records all describe the extremely high error rate.
How the mistakes repeated
MiDAS applied one rule set to every case. So a single flaw repeated at caseload scale instead of averaging out, and produced tens of thousands of wrongful determinations.
MiDAS wrote its determinations straight into claimant records, with no person in between. Collections and penalty systems then copied them automatically. The sources describe no independent check of those copies against the source records before anyone acted on them.
What human involvement changed
Among the cases with some human involvement, 44 percent of the determinations were wrong. Among the cases MiDAS decided by algorithm alone, 85 percent were wrong. Both counts cover October 2013 to September 2015.
The harm followed from the records and the copies in collections, not from staff decisions. Many determinations were issued without any staff review at all.
How it was stopped
The agency stopped using MiDAS for purely automated fraud decisions in September 2015. That followed pressure from the federal government and a federal lawsuit filed the same month.
The settlement of the Zynda lawsuit, in 2017, forced the reinstatement of human review. It also made the agency reverse and refund certain fraud determinations. The Bauserman civil rights class action, alleging false accusations of unemployment fraud, settled for $20 million in 2022.
The case file reads the case as the strongest documented argument that who can correct, and how fast, matters more than the system's overall accuracy.
The same deployment after the settlements
The Lab draws this deployment a second time, after the settlements, in the case titled After the settlements: review returns to a benefits-fraud system. There, the court-ordered review and the correction of the records are in place.
Where the facts come from
The facts here come from four sources. Three are the AI Incident Database's Incident 373, the Benefits Tech Advocacy Hub's case study, and reporting in IEEE Spectrum. The fourth is the Michigan Attorney General's 2022 announcement of the Bauserman settlement.
What the available tools can and cannot address
A failure pathway is a link between two parts of the network, where a mistake made by one part can be passed on to the other. A closed pathway is one that mistakes stop passing along. The work along it may go on.
This case has a budget of 11 units. Explore (No Targets) sets no targets. Contained means the network's mistakes are corrected rather than building on each other.
Under Explore and Service Targets Only, two tools costing 5 of the 11 units are enough to keep the mistakes contained. Under Service Targets Only the same two also meet the service target. That target asks for the automated system to be helping the work.
One such pair is Peer sharing rules with Vet connections. Peer sharing rules stops the one rule set repeating mistakes across cases.
With every tool at its standard setting, each combination that meets the targets under Service Targets Only includes Vet connections. It stops mistakes passing along the automatic copy of determinations into collections.
Under Service and Safety Targets the targets can be met. That level adds closing every failure pathway. The cheapest combination costs 8 of the 11 units: Understand the system, Vet connections, and Store less data.
Understand the system costs 4 units at this level. While it is on, Vet connections and Store less data cost 2 units each instead of 3. Every combination that meets these targets includes all three tools.
Under All Governance Targets the targets are not fully addressable with the available tools. That level asks for the automated system to be clearly helping the work. No combination within the budget that contains the mistakes and closes every failure pathway does that. The best leaves the system helping, but not clearly.
More money does not change that. With the budget set aside and every tool at its stronger setting, every failure pathway closes, and the automated system ends up hurting the work.
Tools that work on the agency staff alone, such as Pause AI on alarms, do not contain the mistakes on their own. Here the records and the copies pass the mistakes on. Staff decisions do not.
Open this example in PAN Lab v0.1 to apply pressures and levers and watch what the system does.
What this models
This example runs on the MiDAS-class automated determination system network: 4 components and 8 pathways between them. Every context in the Lab is a stylized model, never a reconstruction of any actual deployment, and each assumption behind it carries a provenance label.
Evidence base: 3 assumed · 2 published baseline. In the Lab, the shaded evidence band behind each headline readout draws its width from the least-established class below.
Show all 5 assumptions
- assumed
This example follows the pattern of automated fraud determination documented for Michigan's MiDAS. It does not rebuild the real system.
- baseline
One rule set scores every case. So one flaw repeats across the caseload instead of averaging out, as the sources on MiDAS document.
- baseline
In this example, human review starts close to none. The sources count most determinations from October 2013 to September 2015 as made by algorithm alone.
- assumed
The collections and penalty systems copy determinations from the claimant records with no independent check. The sources document this for MiDAS.
- assumed
The sources describe no check comparing copies with claimant records. The tool Check copied records adds one.
Sources and evidence
What this example rests on, claim by claim. Every entry resolves to the same ledger the Evidence Registry publishes.
A single automated rule set applied uniformly and without human review produced tens of thousands of correlated wrongful fraud determinations in the documented Michigan MiDAS case — one flaw repeating at caseload scale rather than averaging out.
empirical- Government Michigan AG, settlement of civil-rights class action (Bauserman, 2022) https://www.michigan.gov/ag/news/press-releases/2022/10/20/som-settlement-of-civil-rights-class-action-alleging-false-accusations-of-unemployment-fraud
- Investigative IEEE Spectrum, Michigan's MiDAS unemployment system: Algorithm alchemy that created lead, not gold https://spectrum.ieee.org/michigans-midas-unemployment-system-algorithm-alchemy-that-created-lead-not-gold
In the documented MiDAS case, a 2016 review of 22,000 fraud determinations found 93% did not involve fraud, and from October 2013 to September 2015 determinations erred at about 85% when decided by algorithm alone versus 44% with some human involvement.
empirical- Government Michigan AG, settlement of civil-rights class action (Bauserman, 2022) https://www.michigan.gov/ag/news/press-releases/2022/10/20/som-settlement-of-civil-rights-class-action-alleging-false-accusations-of-unemployment-fraud
- Investigative IEEE Spectrum, Michigan's MiDAS unemployment system: Algorithm alchemy that created lead, not gold https://spectrum.ieee.org/michigans-midas-unemployment-system-algorithm-alchemy-that-created-lead-not-gold
- Investigative AI Incident Database, Incident 373 (MiDAS false fraud claims) https://incidentdatabase.ai/cite/373/
- Advocacy Benefits Tech Advocacy Hub, Michigan UI False Fraud Determinations https://www.btah.org/case-study/michigan-unemployment-insurance-false-fraud-determinations.html
Documented benefit-automation failures replicated determinations into downstream systems with no independent reconciliation against the source records — Michigan MiDAS actioned replicated flags and Robodebt reversed the onus onto recipients.
empirical- Government Michigan AG, settlement of civil-rights class action (Bauserman, 2022) https://www.michigan.gov/ag/news/press-releases/2022/10/20/som-settlement-of-civil-rights-class-action-alleging-false-accusations-of-unemployment-fraud
- Investigative IEEE Spectrum, Michigan's MiDAS unemployment system: Algorithm alchemy that created lead, not gold https://spectrum.ieee.org/michigans-midas-unemployment-system-algorithm-alchemy-that-created-lead-not-gold
- Government Royal Commission into the Robodebt Scheme, Report (2023) https://robodebt.royalcommission.gov.au/publications/report
- Investigative Law Society Journal, Crude, cruel and unlawful: Robodebt findings https://lsj.com.au/articles/crude-cruel-and-unlawful-robodebt-royal-commission-findings/
Where this connects
Institutional pressures in this domain
- Austerity & recovery incentives — Cost-cutting and overpayment-recovery targets tilt the system toward denial and enforcement errors.
- Vendor opacity — The deploying institution cannot inspect the model, data, or update pipeline it is accountable for.
- Compliance over substance — Paper controls (sign-offs, checklists) satisfy audits while the behavior they describe erodes.
- Reviewer bottleneck — One fixed-capacity checking stage sits between AI output and consequence; everything queues behind it.
All of them in context on the Public benefits & eligibility domain page.
Levers available here and the patterns behind them
- Pause AI on alarms — Deployment circuit-breaker
- Gate record entries — Human-in-the-loop write gating
- Require sign-off — Conformity assessment gate
- Gate vendor updates — Vendor quality gate
- Understand the system — Understand the system
- Review on schedule — Oversight cadence & retrospectives
- Vet connections — Connection authorization
- Upgrade model — Improve the model
- Store less data — Data minimization
- Peer sharing rules — Peer-edge governance
- Check with a second model — Cross-model verification
- Check copied records — Reconcile copied records
Documented case histories
- Michigan MiDAS
- Robodebt (Australia)
- Indiana / IBM eligibility modernization
- Rotterdam welfare-fraud risk model
- Arkansas ARChoices / ARIA
- Netherlands childcare-benefits scandal (Toeslagenaffaire)
- SyRI (Netherlands)
- CNAF benefit-fraud risk score (France)
- Forsakringskassan VAB fraud-selection profile (Sweden)
- Udbetaling Danmark data-driven control (Denmark)
- BOSCO (Spain)
- Serbia Social Card (Socijalna karta)
- UK DWP Universal Credit Advances fraud model
- ID.me identity verification as an unemployment eligibility gate
- Medicaid unwinding: automated ex parte renewal at population scale
- INSS auto-analysis: when the productivity metric makes denial the fastest way out
- Samagra Vedika
- Workforce Australia Targeted Compliance Framework: automated payment sanctioning after Robodebt
- NYC MyCity business chatbot
- Nevada DETR generative-AI unemployment appeals
- Tennessee TennCare TEDS