20.3 WELFARE FRAUD FAILURE TO DISCLOSE A MATERIAL FACT 414.39(1)(a) To prove the crime of [crime charged], the State must prove the following three elements: 1. [Name of defendant] knowingly failed to disclose a material fact by false statement, misrepresentation, impersonation, or other fraudulent means. 2. The fact was used to determine qualifications to receive aid or benefits. 3. The aid or benefits came fromstate or federally funded assistance a program. DEFINITIONS: 1. Fraudulent means the intent or purpose of suppressing the truth or perpetrating a deception. 2. Aid or abet means help, assist or facilitate. 3. An attempt to commit a crime is the formation of an intent to commit that crime and the doing of some act toward the commission of the crime other than mere preparation to commit the crime. 4. Knowingly means with actual knowledge and understanding of the facts or the truth. OPTIONAL DEFINITION: Knowingly means an act done voluntarily and intentionally and not because of mistake or accident or other innocent reason. It is not a defense that [name of defendant] repaid the assistance or services obtained. A paid warrant made to the order of [name of defendant] is sufficient to establish that [name of defendant] received assistance, though this fact may be disproved by competent evidence.