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EAP Policy Manual FFY23 Chapter 10 Incidents and Appeals Page 3 • Understand or follow instructions. • Enter or process household information and data correctly. • Follow policies and procedures. Any of these occurrences can result in incorrectly determining eligibility, benefits or services and incorrect payment to energy vendors, households and contractors. Commerce must be notified when the Service Provider believes the error(s) rises to the level of an incident that Commerce should be made aware. Waste Waste occurs as the result of resources being consumed by inefficient or non-essential activities. Systematic errors or misapplication of policy can cause waste of valuable resources and puts the integrity of EAP funds at risk. Service Provider or energy vendor waste can cause harm to households. Service Providers can assist in the prevention of waste by ensuring energy vendors and Service Provider employees have been trained and understand EAP policies and procedures. Internal controls also help identify errors before they become systematic waste. Waste of program funds by the Service Provider or energy vendor must be reported to Commerce. Abuse Abuse is the purposeful departure from policies and procedures where resources are improperly used. Abuse of resources does not necessarily indicate fraud, unless it meets the definition listed below. Abuse of program funds by the Service Provider or energy vendor must be reported to Commerce. Suspected Fraud Fraud is an event of suspected intentional deception, omission, or concealment made for business or personal gain, to assist or harm others and/or to misuse program funds. Service Providers must have internal controls and take reasonable steps to prevent fraud by households, employees, contractors and energy vendors. When EAP funds are misspent because of fraud, the Service Provider must report the incident to the Commerce and take steps to recover those funds. Preventing and Detecting Errors or Fraud Service Providers must utilize procedures by establishing internal controls and self-monitoring activities to reduce, find and correct errors that may occur during intake, verification, certification and bookkeeping activities. Where feasible, divide responsibility for application