When a disqualification is not entered timely, enter the correct start date on the Sanction/Disqualification (FMAM) screen to impose the disqualification for the remaining months of the disqualification period. The disqualification penalty is considered imposed the month following the month of the discovery. Establish an agency error claim for any months in which the EU was overpaid because the disqualification was not imposed timely.
EXAMPLE: It is discovered in December that an individual should have been disqualified in June for a period of 12 months. The individual is disqualified for the remaining five (5) months. A claim against the EU must be established to cover June through December, the months the individual participated when s/he should have been disqualified.