Fraud Waste and Abuse Company Training

DEFINITIONS Fraud means an intentional deception or misrepresentation knowingly made in order to obtain unauthorized benefit. Waste means thoughtless or careless expenditure, consumption, mismanagement, or squandering of resources owned and operated by an entity. Abuse means actions that are inconsistent with sound fiscal business and that could or do result in an unnecessary cost associated with and/or charged to contractors for unauthorized or unnecessary services. Claim means any request or demand for money that is submitted to the government or its contractors. Knowingly means that a person or organization: has actual knowledge that the information is false, acts in deliberate ignorance as to the truth or falsity of the information, or acts in reckless disregard of the truth or falsity of the information. Fraud means an intentional deception or misrepresentation knowingly made in order to obtain unauthorized benefit. This includes any act that constitutes fraud under applicable Federal or State laws.

Purpose and Background The False Claims Act (FCA) makes it a crime for any person or organization to knowingly make a false record or file a false claim with the government for payment. Skils’kin as contractor, if involved in an FCA claim, may be excluded from participating in federal contract programs, and facing criminal prosecution. Federal and state laws protect those individuals who report fraud to the government. Skils’kin is committed to complying with all applicable Federal and State standards regarding fraud, waste, and abuse. A violation of the FCA may result in penalties of up to three times the value of each false claim, plus $11,000 per claim filed. Federal law also imposes civil penalties of up to $5000 per claim and twice the value of the claim when a person supports the claim with a false statement or omission of a material statement. Washington State has similar legislation found in the Health Care False Claim Act (Revised Code of Washington (RCW) 48.80), and the Medicaid Fraud False Claims Act (Revised Code of Washington (RCW) 74.66). Like the federal laws, the RCW penalizes false claims as well as false records or statements material to the false claim with civil fines between $5-11,000 plus triple the damages incurred. Skils’kin as contractor, if involved in an FCA claim, may be required to enter into a Corporate Integrity Agreement with the government. FCA claims may result in being excluded from participating in federal contract programs, and facing criminal prosecution Under both federal and state law, an individual may initiate a lawsuit under the FCA on behalf of the government. If the government recovers money based on that lawsuit, the whistleblower may receive a portion of the recovered dollars. Federal and state laws protect those individuals who report fraud to the government. In the case of employees, employers may not retaliate against an employee who raises concerns or reports fraud to the government. If a court finds that an employer has retaliated, the court can order the employer to make the employee whole or even rehire the employee, and to pay the employee two times the amount of back pay plus interest and legal fees. Skils’kin is committed to complying with all applicable Federal and State standards regarding fraud, waste, and abuse. This includes whistleblower provisions. This policy provides information regarding the laws prohibiting false claims for reimbursement from federal and local government organizations. Additionally, this policy sets forth expectations of employees in regards to ethical business practices and prudent use of company resources to reduce waste. The Board of Directors and all employees of Skils’kin will make every effort to ensure that no fraud, waste, or abuse occurs. All Skils’kin employees who interact with our customers and partner organizations must be alert to the fact that many organizations and agencies that Skils’kin conducts business with have internal policies that regulate fraud, waste, and abuse including accepting of gifts. It is incumbent that Skils’kin employees are sensitive to this fact in order to ensure full compliance with other organizations or agencies internal policies.

Purpose and Background Fraud, waste, and abuse run counter to Skils’kin’s values. Fulfilling Skils’kin’s mission and vision requires trust. Therefore, it’s important that the organization, discourage, guard against, report, and take corrective action as necessary concerning fraud, waste and abuse. Employees are expected to report to Skils’kin any concerns about all suspected forms of fraud, waste, and abuse, or any other issue they feel is illegal, unethical, or otherwise inappropriate. Fraud means an intentional deception or misrepresentation knowingly made in order to obtain unauthorized benefit. This includes any act that constitutes fraud under applicable Federal or State laws.

Examples A business under-reporting its worker hours. Billing for services not performed. An injured worker collecting time-loss compensation benefits while working at another site. Forgery or alteration of documents (checks, contracts, purchase orders, etc…) Misrepresentation of information on documents (employment history, time sheets, leave records, etc…) Theft, unauthorized removal, or willful destruction of records. Misappropriation of funds, equipment, supplies, or any other asset. Improprieties in the handling and reporting of financial transactions. Are there other examples you can think of? People who commit fraud don’t fit a single profile. Opportunity + Motivation = Fraud

How to Report You may go to your manager directly. You may contact our Corporate Compliance Officer, Gayle Lawrence: glawrence@skils-kin.org | (509) 326-6760 x 2300 You may contact our President / CEO, Brian Behler: bbehler@skils-kin.org | 509-326-6760. You may contact our Board President by email at SkilskinBoardofDirectors@gmail.com Any of the above can be contacted by US Mail at: 4004 East Boone Ave, Spokane, WA 99202-4509 You may contact the Department of Defense, Office of Inspector General Hotline to report suspected fraud, waste, and abuse regarding a Service Contract Agreement at 1-800- 424-9098 (Toll-Free). Are there other examples you can think of? People who commit fraud don’t fit a single profile. Opportunity + Motivation = Fraud

How to Report For reports involving SourceAmerica employees may contact them directly: You may report anonymously When reporting, please include: Reason you believe a violation has occurred When and how the conduct occurred or is occurring Information regarding the specific nature of the incident and/or conduct Name of individual and/or group you suspect of committing the violation Date the situation occurred Other information you may have to help with the investigation or understanding of the situation Are there other examples you can think of? People who commit fraud don’t fit a single profile. Opportunity + Motivation = Fraud Skils’kin encourages persons making anonymous reports to maintain contact with the CCO, so that the CCO may obtain any additional information needed to properly investigate the report.

Final Thoughts Skils’kin will take reasonable steps to maintain confidentiality of the identity of any person providing information to Skils’kin to the fullest extent possible. Due to Skils’kin obligations to investigate, report certain issues to state and/or federal authorities, and take appropriate action to correct violations or misconduct, Skils’kin cannot guarantee complete confidentiality of the identity of persons who make reports. Additionally, Skils’kin cannot make promises regarding a person’s liability or what steps Skils’kin may take in response to the report. Are there other examples you can think of? People who commit fraud don’t fit a single profile. Opportunity + Motivation = Fraud Skils’kin encourages persons making anonymous reports to maintain contact with the CCO, so that the CCO may obtain any additional information needed to properly investigate the report.

Questions? Are there other examples you can think of? People who commit fraud don’t fit a single profile. Opportunity + Motivation = Fraud Skils’kin encourages persons making anonymous reports to maintain contact with the CCO, so that the CCO may obtain any additional information needed to properly investigate the report.