Montana PBRF-LE Analysis
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
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.