UJI 14-4402. Falsification of documents.

For you to find the defendant guilty of falsification of documents as charged in Count ____, the state must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime: 1. The defendant knowingly [made or caused to be made a misrepresentation of a material fact required to be furnished under the program. A material fact is a fact that is integral to the right to Medicaid payments and that has a natural tendency to influence the Human Services Department to pay for [unnecessary services] [services not provided in the stated quality or amount] [or] [services to a person not authorized to receive them.] [or] [failed or caused the failure to include a material fact required to be furnished under the program in any record required to be retained in connection with the program. A material fact is a fact that is integral to the right to Medicaid payments and that has a natural tendency to influence the Human Services Department to pay for [unnecessary services] [services not provided in the stated quality or amount] [or] [services to a person not authorized to receive them.] [or] [submitted or caused to be submitted false or incomplete information for the purpose of receiving benefits or qualifying as a provider]1. 2. This happened in New Mexico on or about the ______ day of ______________, __________2.