DOJ page 22

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57. Contrary to the HMIS written procedures, however, between August 17, 2020, and the present, HMIS and its employees, supervisors, and managers regularly engaged in a systemic fraudulent timecard scheme designed to fleece the DOE for their own benefit, 58. Between August 17, 2020, and the present, due to HMIS’s failure to appropriately plan and schedule fire protection work for its hourly employees to do, it was customary, accepted, and daily practice for HMIS hourly employees in the Fire Systems Maintenarce unit to experience significant idle time, during which they had no work to perform, and to nonetheless falsely record their full shifts to active change codes on tier timecards, falsely and fraudulently indicating that these hourly employees had performed work that they had not performed, in order to seek ‘and obtain reimbursement from DOE for the idle hours. These timecards, containing false statements and representations, were approved by supervisory HMIS employees who were or should have been aware that the timecards did not accurately reflect the work performed because of the extensive and unreasonable amount of idle time experienced by hourly workers on a daily or near daily basis 59. During this timeftame, HMIS eraft personnel, including the pipefitters and electricians responsible for fire systems maintenance at facilities across the entire Hanford Site, frecuently experienced significant ide time, where they had no work to perform. Severe! factors within the control of IMIS contributed to this idle [UNITED STATES’ COMPLAINT IN INTERVENTION - 22

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