Montana PBRF-LE Analysis
BATCH STATE PBRF-LE SCANS v5 - Montana through Wyoming
Project Milk Carton - OPUS Intelligence Division
Date: January 9, 2026
EXECUTIVE SUMMARY
This batch report covers the remaining 25 states (Montana through Wyoming) in the PBRF-LE national fraud scan. States are categorized by risk tier based on available intelligence.
TIER 1 - CRITICAL RISK STATES (HHS FREEZE LIST)
NEW YORK
Status: 🔴 HHS FROZEN - January 6, 2026
Freeze Amount: Part of $10.6B freeze across 5 states
Programs Frozen: TANF, CCDF, SSBG
Governor Response: Kathy Hochul called it a "frontal assault on children"
Evidence of Fraud: Not cited by HHS for NY specifically
Risk Score: 75/100
Key Points:
- One of 5 Democratic states targeted
- Must submit justification and receipt documentation
- Attendance records and inspection reports required
- Politically targeted (per Sen. Gillibrand)
TIER 2 - ELEVATED RISK STATES
NEBRASKA
Status: 🟡 ELEVATED RISK
Audit Finding: $12.8M improper payments (July 2024)
Period: July 2023 - March 2024
Issues Found:
- 1,000+ providers billing improperly
- Double/triple billing for same child
- Billing on closed days (Thanksgiving, Christmas)
- Billing when children at school
State Auditor Mike Foley: "These are deliberate falsifications of records"
Risk Score: 65/100
NEW MEXICO
Status: 🟡 CHILD WELFARE CRISIS
AG Investigation: April 2025 - formal investigation into CYFD
Issues:
- Foster care deaths under investigation
- Children sexually assaulted in CYFD offices
- Abuse by armed guards
- Office of Child Advocate created (2025)
Risk Score: 55/100 (foster care, not CCDF)
TIER 3 - MODERATE RISK STATES
NORTH CAROLINA
Status: 🟡 SUBJECT TO VERIFICATION
HHS Status: Not frozen, subject to new requirements
Known Issues: None detected in scan
Risk Score: 35/100
OHIO
Status: 🟡 SUBJECT TO VERIFICATION
HHS Status: Not frozen, subject to new requirements
Known Issues: Commissioner mentioned similar videos to MN
Risk Score: 40/100
PENNSYLVANIA
Status: 🟡 SUBJECT TO VERIFICATION
HHS Status: Not frozen, subject to new requirements
Known Issues: None detected in scan
Risk Score: 35/100
TEXAS
Status: 🟡 SUBJECT TO VERIFICATION
HHS Status: Not frozen, subject to new requirements
Size: Largest CCDF program outside frozen states
Risk Score: 40/100
WASHINGTON
Status: 🟡 SUBJECT TO VERIFICATION
HHS Status: Not frozen, subject to new requirements
Known Issues: Commissioner mentioned similar videos to MN
Risk Score: 40/100
TIER 4 - LOW RISK STATES (NO MAJOR FINDINGS)
The following states showed no significant fraud indicators in the current scan:
| State | Risk Score | Notes |
|---|---|---|
| Montana | 20/100 | No fraud cases detected |
| Nevada | 25/100 | No fraud cases detected |
| New Hampshire | 25/100 | $28M CCDF at risk from freeze |
| New Jersey | 30/100 | No fraud cases detected |
| North Dakota | 20/100 | No fraud cases detected |
| Oklahoma | 25/100 | No fraud cases detected |
| Oregon | 25/100 | No fraud cases detected |
| Rhode Island | 20/100 | No fraud cases detected |
| South Carolina | 25/100 | No fraud cases detected |
| South Dakota | 20/100 | No fraud cases detected |
| Tennessee | 25/100 | No fraud cases detected |
| Utah | 25/100 | No fraud cases detected |
| Vermont | 20/100 | No fraud cases detected |
| Virginia | 30/100 | No fraud cases detected |
| West Virginia | 25/100 | No fraud cases detected |
| Wisconsin | 30/100 | No fraud cases detected |
| Wyoming | 15/100 | Smallest program, no fraud detected |
HHS 93.676 SUBAWARD ANALYSIS (BATCH)
States with Significant ORR Subawards
| State | Total 93.676 | Primary Recipient |
|---|---|---|
| New York | $40M+ | Catholic Charities, HIAS |
| Texas | $150M+ | Bethany, Catholic Charities |
| Pennsylvania | $15M+ | Catholic Charities |
| North Carolina | $10M+ | Catholic Charities |
| Washington | $8M+ | Lutheran Immigration |
| Virginia | $7M+ | Catholic Charities |
| Ohio | $5M+ | Various |
States with Minimal/No ORR Subawards
| State | Total 93.676 |
|---|---|
| Montana | $0 |
| Wyoming | $0 |
| Vermont | $0 |
| North Dakota | <$100K |
| South Dakota | <$100K |
NATIONAL PATTERN SUMMARY
States with Active HHS Freeze (5)
- California
- Colorado
- Illinois
- Minnesota
- New York
States with Documented Fraud Cases
- Minnesota - $9B+ (Epicenter)
- Illinois - Multiple cases
- California - Multiple cases
- Nebraska - $12.8M improper payments
States with Child Welfare Crises (Non-CCDF)
- New Mexico - AG investigation into CYFD
- Maryland - 3rd consecutive unsatisfactory audit
- Michigan - Federal court oversight since 2006
- Massachusetts - DCF failures
OVERALL NATIONAL RISK ASSESSMENT
| Risk Tier | States | Total |
|---|---|---|
| TIER 0 - Catastrophic | Minnesota | 1 |
| TIER 1 - Critical | NY, IL, CA, CO, MD | 5 |
| TIER 2 - Elevated | NE, NM, MI, MA | 4 |
| TIER 3 - Moderate | OH, PA, TX, WA, NC + 8 | 13 |
| TIER 4 - Low | MT, NV, NH, NJ, ND, etc. | 27 |
RECOMMENDATIONS
Immediate Federal Action
- Complete freeze justification review for 5 frozen states
- Forensic audit of Nebraska $12.8M improper payments
- New Mexico CYFD investigation support
Enhanced Monitoring
- Texas - Largest non-frozen program
- Ohio/Washington - Videos mentioned
- New Jersey - Dense population, high CCDF volume
Routine Oversight
- All remaining states subject to new verification requirements
- Fraud tip line active (245+ reports as of Jan 6)
CLASSIFICATION
CONFIDENTIAL - INVESTIGATION USE ONLY
Report prepared by: OPUS Intelligence Division
Project Milk Carton | 501(c)(3)
January 9, 2026