An equally divided Supreme Court of Pennsylvania has held that uncorroborated hearsay evidence alone can support a factual finding in an administrative hearing if the proponent establishes some foundation for the hearsay's reliability or reliability is apparent on its face.
Unemployment Compensation Board of Review v. Ceja, 493 Pa. 584, 427 A.2d 631 (1981).
George P. Faines,
Administrative Law - Evidence - Hearsay - Residuum Rule,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol20/iss2/10