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DEO LIHEAP Policies and Procedures Manual Page 37

2. People who claim household members or list household members that do not actually reside in household (example-children) 3. Couples pretending to be tenant and landlord and making up a fictitious tenancy D. Preventative measures should be taken to keep fraud from occurring in the first place. Due diligence during the application process can prevent the disbursement of funds to ineligible applicants. Early detection allows the subrecipient to refer suspicious cases to the management where an examination of an applicant's case is made before benefits are received. Examination of these cases can determine whether the client is reporting accurate information or is attempting to receive benefits he or she may not be eligible to receive. E. Detection of fraud occurs after funds have been disbursed on behalf of the client. Fraud can be detected with both open and closed cases and can involve benefits received under a single program as well as multiple programs. F. If, after following the subrecipient’s process for reporting potential fraud, it is determined that it appears that false information was provided during the application process, the file is denied and the client is notified in writing. If the fraud occurred from a previous application and disbursement of funds, the file enters a repay phase. G. If it is determined that the client received benefits based on false information provided by the client, then it is considered an overpayment. The subrecipient should attempt to recapture the funds and the client is given an opportunity to repay the funds in question. 1. If the client contacts the subrecipient, payment arrangements may be discussed and formalized per the subrecipient’s policy. The subrecipient should track all payments and notify the client when the obligation has been met. H. Investigation and Prosecution 1. Fraud is considered theft and a crime. Therefore, the subrecipient should report the criminal activity to their local law enforcement subrecipient. 2. Once every attempt has been made to contact and work with the client for recovery of overpayments, and the client has been unresponsive or uncooperative, the information should be turned over to local law enforcement. 3. The subrecipient should continue to work with the prosecuting officials and the subrecipient can, if requested, receive and track repayments from the client. 4. All repayments must be returned to DEO.