Page 70

2) Investigation: Contractor agencies must investigate all credible reports and/or findings of suspected client fraud.

a) Investigations may involve the following activities: re-verification of household income, cross checks for duplication, follow-up interviews with client and/or related individuals, etc. b) When contractor agency investigations appear to confirm suspicions of client fraud, the agency must contact the client to discuss with the client the validity of the evidence. If the client does not concur with the evidence presented, the contractor agency must hold an agency conference at which the client may present his/her own rebutting evidence. If the agency conference fails to remove the suspicion of fraud, the contractor agency must take the following actions:  Notify the client that his/her DEAP benefits will be terminated and that he/she has the right to a Fair Hearing.  Refer the case through the DSSC/OCS to the State Department of Justice and provide the supporting documentation.  If benefit has already been paid, notify client in writing that they must return funds. Contractor agency must make 3 attempts in writing to collect fraudulently paid DEAP benefit.  If client still does not return benefit, client is prohibited from receiving DEAP benefit or services for 3 years.

B. Vendor Fraud 1) Internal Controls: Contractor agency will select vendors and, if applicable, corresponding DEAP client accounts that will be monitored annually. The size of the sample selected to be monitored will depend on the number of subcontracts with vendors in each specific county. Contractor agencies may obtain individual client records from vendors or visit the vendors’ offices to review the vendors’ books and records on site.

a) Vendor monitoring will consist primarily of verifying posted fuel costs with the fuel costs on the date of delivery; and determining that DEAP clients and non-DEAP clients were charged the same price per unit for fuel delivered.