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Louisiana LIHEAP Service Delivery Guide 78 | P a g e

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 Witness Narrative Report form (Appendix R) 3. Management must investigate within reason and document the applicant’s file to determine if fraudulent activity actually occurred versus applicant error. 4. If the investigation determines that fraudulent activity did indeed occur, then the following steps may follow depending upon the time of discovery: a. If it is determined that it appears that false information was provided during the application process, the applicant file must be denied and the client notified in writing. b. If it is determined that the client received benefits based on false information provided by the client, it is considered an overpayment. The Subgrantee should attempt to recapture the funds and the client must be given an opportunity to repay the funds in question by either reimbursement to the Subgrantee/LHC or recoupment from the Utility Vendor. If the client makes contact with the Subgrantee, payment arrangements may be discussed and formalized per the Subgrantee’s policy. The Subgrantee should track all payments and notify the client when the obligation has been met. 9.4 Investigation and Prosecution Fraud is considered theft and a crime; therefore, the Subgrantee should report the criminal activity to the LHC, State Inspector General, US DHHS Inspector General, and the local law enforcement agency. 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. The Subgrantee should continue to work with the prosecuting officials, and the Subgrantee can, if requested, receive and track repayments from the client. All repayments must be returned to LHC. The Subgrantee must contact LHC and keep staff informed as to the progress of the investigation, the disposition, and if any funds will be returned.