Fraud Detection and Conviction - Back to the Basics
by: Patrica Tweedy
Law Office of Patrica Tweedy
While
insurance fraud is a rampant white-collar crime, it is often
undetected or, if detected, ignored or not prosecuted. Thorough
investigation and documentation can increase fraud detection
and convictions.
I. Heed your internal warning signals.
Does something tell you the claim
is not entirely legitimate? If there are fraud indicators
with regard to the claim, further investigation is required.
If the claimant is overly pushy for a quick settlement,
presents a claim that significantly differs from the police
officer’s investigative report, provides receipts that are
suspicious, fails to have receipts or documentation of items
claimant state are new or other fraud indicators exist,
take another look. Follow up by contacting stores, neighbors,
the investigating officer or other relevant wittiness.
Frequently the adjuster who is
responsible for paying a claim is located in a city remote
from the claimant and claimant’s activities. For example,
we recently assisted in the investigation of a claim that
was being handled from a southern California claims office.
The carrier had retained an outside adjuster company provided
prompt written reports to the insurer and those reports
contained several indicators of a possible fraudulent claim.
Our firm was contacted to assist in the investigation and
we, in turn, contacted Greg Nunes Investigations providing
that company with specific additional tasks.
II. Investigate thoroughly and gather admissible evidence.
When, in your investigation, fraud
is revealed, gather and protect evidence of same. In our
real life example, acting on his own hunch, Investigator
Nunes recontacted the police department and located an original
report filed by the claimant (the named insured). The report
indicated that the claimant (the insured) knew that the
property had been removed from the dwelling by a co-insured.
The “loss” was not covered, the insured knew that it was
covered, and a second police report, claiming that unknowns
had entered her home and stolen her property, provided good
evidence of her intent to defraud. The co-insured was contacted,
her examination under oath was taken and she provided additional
information which demonstrated that the claimant was making
a knowingly false claim.
The insured claimant had provided
numerous check stubs and receipts allegedly documenting
stolen items but Investigator Nunes contacted store owners,
sales personnel, and the like discovering that numerous
documents provided by the claimant were also false. Recorded
statements were taken where feasible and the name, address
and telephone number of each potential witness was documented
for the file.
The co-insured informed us, in
the examination under oath, that the insured claimant had
a criminal history. Again, that lead was followed and it
was discovered that the claimant had been convicted of two
felony white-collar crimes in the past. We obtained the
complete criminal files regarding those matters. Admissible
evidence was gathered each step along the way.
III. Get an outside legal opinion.
Where the claims professional is
convinced that insurance fraud has been committed, counsel
should independently provide an opinion regarding whether
to accept or reject coverage. In our recent case, we recommended
that coverage be denied and further recommended that the
matter be turned over to the authorities for prosecution.
We also drafted the denial letter for the adjuster’s signature.
IV. If the claim is obviously fraudulent, provide the
information to the Department of Insurance.
If you are convinced that the crime
of insurance fraud has been committed, the Insurance Code
requires informing the Department of Insurance. If the Department
of Insurance is unable to prosecute, then consider sending
the evidence to your local District Attorney. Some carriers
have opted to send the evidence to both agencies. In order
to gain the agency’s interest in your case, the material
you send must contain admissible evidence of all elements
of the crime along with a cover letter demonstrating that
a crime has been committed and referencing the evidence
by exhibit. In our recent case, which we will continue to
use as an example, we not only provided the evidence in
the described manner but also provided that information
we had obtained regarding the previous convictions. The
claimant, in our case, was recidivist, thus likely to strike
again. We believe that the Department’s acceptance of the
case was, in part, based on the fact that this was not a
one-time “mistake” in judgment.
Even though our reported case was
a first party claim, third party insurance fraud occurs
with frightening frequently. Often it involves more perpetrators
than first party fraud. Investigative basics are essentially
the same. What you do with the evidence depends on the circumstances.
When you discover chiropractic fraud, the information should
be turned over to the Department of Consumer Affairs for
potential licensing discipline or revocation. When you find
fraud by a medical doctor, the information should be provided
to the Department of Consumer Affairs for possible licensing
discipline or revocation and to the Medicare fraud unit.
We have found Medicare to be quite proactive in recovering
money fraudulently obtained by physicians. Remember, however,
that no agency can be expected to act unless the fraud is
clearly spelled out and properly documented with admissible
evidence. We hope these comments have been helpful. We wish
you a prosperous, healthy and happy year 2000.
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