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Penalties for Frauduent Claims to a "Value Bank"


Miner88

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A multiemployer employer welfare plan maintains a "Value Bank" that members can use to pay for dental claims, prescription co-pays, etc. There have been several fraudulent claims sent in by members trying to get "their money." The reimbursements are, of course, funded by the agreed upon employer contributions to the plan, but the members do not actually have any "money" in an "account." If they don't have valid claims, they don't get any money.

The trustees would like to amend the plan to impose a penalty upon anyone they find sending in fraudulent claims. A possible penalty would be loss of all funds credited to their Value Bank "account."

Does anyone see any problems with this? Does this need to be collectively bargained?

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