PBRF-LE NATIONAL PATTERN ANALYSIS
PBRF-LE NATIONAL PATTERN ANALYSIS
Public Benefit Reimbursement Fraud via Layered Entities
Multi-State Child Care Fraud Pattern Recognition Report
Classification: SENSITIVE INVESTIGATIVE MATERIAL Prepared by: OPUS Intelligence System Date: January 8, 2026 Report ID: OPUS-PBRF-2026-0108-001
EXECUTIVE SUMMARY
This report applies the PBRF-LE (Public Benefit Reimbursement Fraud via Layered Entities) analytical framework to identify child care and social services fraud patterns across multiple U.S. states. The Minnesota “Feeding Our Future” scandal serves as the baseline pattern, with confirmed fraud exceeding $250 million in federal child nutrition funds and estimated $9+ billion in combined Medicaid and social services fraud.
KEY FINDINGS
| Finding | Significance |
|---|---|
| 78+ indictments in Minnesota | Largest pandemic relief fraud in U.S. history |
| 5 states with funding frozen | CA, CO, IL, MN, NY - $10B total |
| 245+ fraud tips since Dec 30, 2025 | National fraud hotline activity |
| 11% error rate in MN child care | Per HHS OIG May 2025 audit |
| 62 convictions to date | Minnesota fraud schemes |
| $9B+ estimated fraud | Minnesota social services total |
PBRF-LE PATTERN PIPELINE ANALYSIS
STAGE A: ACCESS - Program Provider/Sponsor Enrollment
MINNESOTA (BASELINE - EXTREME RISK: 95/100)
Pattern Indicators Confirmed: - Feeding Our Future: Revenue spike from $3.4M (2019) to $197M (2021) = 5,794% increase - 250+ Federal Child Nutrition Program sites opened rapidly - IRS tax-exempt status REVOKED February 2020 - fraud continued anyway - Empire Cuisine & Market enrolled April 2020 during pandemic onset - Sites were “parking lots” and “vacant commercial spaces”
Red Flags: - [x] Became provider recently, then revenue spike - [x] 80-100% revenue from single program - [x] Unusual number of sites added quickly - [x] Rapid geographic expansion
ILLINOIS (HIGH RISK: 65/100)
Documented Cases: - Aleesha McDowell (2024): Child care centers in Calumet City, Calumet Park, Chicago - Sentence: 4 years federal prison - Restitution: $3,339,563 - Scheme: False subsidy claims for low-income childcare
- Shauntele Y. Pridgeon (2023): Former DCFS social
worker
- 14 co-defendants indicted
- $3.2 million scheme (2016-2022)
- Insider access exploitation
Pattern Indicators: - [x] State employee facilitating access - [x] Multi-year scheme duration - [x] Multiple defendants/co-conspirators
OHIO (MODERATE-HIGH RISK: 55/100)
Current Status: - 124 fraud tips received before Dec 31, 2025 - 61 providers required to pay back overpayments - 12 daycare centers closed - $2 million in overpayments identified - 38 additional centers closed in 2025
Pattern Indicators: - [x] High tip volume indicates widespread concern - [ ] No major indictments yet - [x] Systemic overpayment patterns
WASHINGTON STATE (MODERATE RISK: 50/100)
Documented Issues: - $770 million child care subsidy program under audit - 1,372 overpayments totaling $2,092,513 (FY 2024-25) - 265 overpayments from missing attendance records - “Ghost daycare” allegations under investigation
Suspicious High-Value Recipients: - Asal Family Daycare (Seattle): $690,000+ in 5 months (Jul-Nov 2025) - Wonder Kidz (Federal Way): $258,199 in 5 months - Eyow Childcare Inc.: $158,931 in 5 months
Pattern Indicators: - [x] Concentrated high payments to specific providers - [x] Attendance record gaps - [ ] No criminal indictments yet
TEXAS (LOW RISK: 25/100)
Current Status: - Governor Abbott ordered proactive investigation (Jan 2026) - Improper payment rate: 0.43% (vs Minnesota 11%) - No documented fraud schemes - TWC and HHSC have fraud prevention measures in place
Pattern Indicators: - [ ] No revenue spikes identified - [ ] No access exploitation documented - [x] Investigation ongoing
CALIFORNIA (MODERATE RISK: 45/100)
Documented Cases: - $181 million EBT skimming scheme (2022-2024) - CalWORKs childcare program has historical fraud holes - 361,834 average monthly CalWORKs families - $10B funding freeze applied
Pattern Indicators: - [x] Historical oversight weaknesses - [x] Large program vulnerable to exploitation - [ ] No major CCDF-specific indictments found
NEW YORK (MODERATE RISK: 45/100)
Current Status: - Part of $10B funding freeze - “Ghost children” billing allegations - 7.3B TANF + 2.4B CCDF frozen
Pattern Indicators: - [x] Federal freeze indicates concern - [ ] No specific indictments documented in search - [x] Large program size increases vulnerability
MICHIGAN (MODERATE RISK: 40/100)
Current Status: - $430M federal + $66M state = $496M annual CDC subsidy - ~45,000 children monthly on subsidy - Audit requested by Senate Minority Leader Nesbitt - “Zero tolerance” policy stated but unverified
Pattern Indicators: - [x] Audit requested indicates concerns - [ ] No documented fraud cases found - [x] Large program vulnerable
COLORADO (MODERATE RISK: 40/100)
Current Status: - Part of $10B funding freeze - CCAP enrollment freeze since Oct 1, 2024 - 27,000+ children rely on TANF programs - No specific fraud cases documented
Pattern Indicators: - [x] Federal freeze indicates concern - [ ] No documented fraud schemes
STAGE B: EXTRACTION - Billing/Claims Inflation
MINNESOTA (CONFIRMED)
Feeding Our Future: - Claimed 18 million meals at 30+ sites - Actual meals served: ~3% of claimed - Billing for non-existent children - Empty facilities receiving full reimbursement
CCAP Program: - 11% error rate per federal OIG audit - $231.4 million in potentially flawed claims - 1,150+ providers affected
Extraction Methods: - [x] Outlier billing rates vs peers - [x] High claims relative to staffing - [x] Emergency program exploitation - [x] Ghost children/meal claims
ILLINOIS (DOCUMENTED)
McDowell Case: - False claims to Illinois Child Care Assistance Program - Centers in 3 locations with coordinated billing
Pridgeon/DCFS Scheme: - $3.2M over 6 years - State employee falsifying eligibility
OHIO (SUSPECTED)
Indicators: - Overpayments at 61+ centers - Attendance record discrepancies - Unannounced visits finding problems
WASHINGTON (SUSPECTED)
Indicators: - 265 overpayments from missing attendance - 21% overbilled hours/days - Single providers receiving $690K+ in 5 months
STAGE C: DIVERSION - Routing Through “Legitimate” Expenses
MINNESOTA (CONFIRMED)
Documented Diversion Methods:
| Category | Example | Amount |
|---|---|---|
| Vendors | Sham food distributors | $240M+ |
| Contractors | Fake consulting firms | $18M+ admin fees |
| Shell Companies | 1130 Holdings Inc. | $900K+ |
| Property | Real estate purchases | Multiple properties |
| Cash | Kickbacks | “Consulting fees” |
Feeding Our Future Kickbacks: - Employees received bribes disguised as “consulting fees” - Shell companies created to legitimize payments - Cash kickbacks to site operators
ILLINOIS (DOCUMENTED)
- Child care centers as fronts
- State subsidy diversion
- Multiple locations coordinated
STAGE D: OBFUSCATION - Layering Through Entities
MINNESOTA (CONFIRMED - SOPHISTICATED)
Entity Layering Techniques: - Newly formed entities: Shell companies created post-enrollment - Same registered agents: Common agent across fraudulent entities - Related-party vendors: Family/associate-owned companies - Circular transfers: Money bouncing between entities - Rapid pass-through: Quick disbursement after receipt
Documented Shell Companies: - Nur Consulting LLC (Abdimajid Mohamed Nur) - 1130 Holdings Inc. - Multiple food distribution entities
Wyoming Connection: - Registered Agents Inc. (RAI) formed 266,000+ companies 2019-2024 - 40% of all Wyoming incorporations - Known for obscuring ownership - Connected to CARES Act fraud
WASHINGTON (SUSPECTED)
- Multiple LLCs with high payments
- Investigation ongoing into entity structures
STAGE E: CONVERSION - Cash-Out & Asset Acquisition
MINNESOTA (CONFIRMED - EXTENSIVE)
Documented Conversions:
| Type | Details |
|---|---|
| Real Estate | Mansions purchased with fraud proceeds |
| Vehicles | Mercedes, luxury cars |
| Cash | Large ATM withdrawals |
| Overseas | Wire transfers to Kenya |
| Restaurant buildouts | Business investments |
| Electronics | Consumer goods |
Salim Said Case: - “Spending spree stretched far beyond cars and houses” - Real estate, electronics, cash transfers - Restaurant buildouts - “Other luxury goods through shell companies”
Abdimajid Mohamed Nur: - $900,000+ laundered through Nur Consulting LLC - Sentencing: 10 years prison - Restitution: $47,920,514
STATE-BY-STATE RISK MATRIX
| State | Risk Score | Access | Extract | Divert | Obfusc | Convert | Status |
|---|---|---|---|---|---|---|---|
| Minnesota | 95/100 | HIGH | HIGH | HIGH | HIGH | HIGH | CONVICTED |
| Illinois | 65/100 | HIGH | HIGH | MED | LOW | MED | INDICTED |
| Ohio | 55/100 | MED | HIGH | MED | LOW | LOW | INVESTIGATING |
| Washington | 50/100 | MED | MED | MED | LOW | LOW | AUDITING |
| California | 45/100 | MED | MED | MED | LOW | LOW | FROZEN |
| New York | 45/100 | MED | MED | LOW | LOW | LOW | FROZEN |
| Michigan | 40/100 | MED | LOW | LOW | LOW | LOW | AUDIT REQUESTED |
| Colorado | 40/100 | LOW | LOW | LOW | LOW | LOW | FROZEN |
| Georgia | 35/100 | LOW | LOW | LOW | LOW | LOW | MONITORING |
| Florida | 30/100 | LOW | LOW | LOW | LOW | LOW | MONITORING |
| Texas | 25/100 | LOW | LOW | LOW | LOW | LOW | PROACTIVE |
FEDERAL RESPONSE TIMELINE
| Date | Action |
|---|---|
| June 2024 | First FOF trial convictions (5 defendants) |
| Oct 2024 | First FOF sentencing (Mohamed Ismail, 12 years) |
| Dec 2024 | 78th defendant charged |
| Dec 18, 2025 | U.S. Attorney estimates $9B+ total MN fraud |
| Dec 26, 2025 | Viral video allegations surface |
| Dec 30, 2025 | HHS fraud tip line launched (245+ reports) |
| Dec 31, 2025 | Trump admin freezes MN childcare funds |
| Jan 5, 2026 | Biden-era payment rules rescinded |
| Jan 5, 2026 | Gov. Walz drops reelection bid |
| Jan 7, 2026 | $10B freeze on 5 states (CA, CO, IL, MN, NY) |
| Jan 7, 2026 | House Oversight hearing begins |
| Feb 10, 2026 | Walz/Ellison scheduled to testify |
ENTITY NETWORK MAP (MINNESOTA)
FEEDING OUR FUTURE (Revoked 501c3)
|
+---------------+---------------+
| | |
AIMEE BOCK ADMIN FEES SITE OPERATORS
(Founder) $18M+ 250+
CONVICTED | |
| | |
+-----------+ KICKBACKS +-------+-------+
| | (CASH) | | |
SHELL COS BRIBES EMPIRE SHAM VACANT
| | CUISINE VENDORS LOTS
| | | |
NUR CONSULTING CASH FARAH FOOD LUXURY
1130 HOLDINGS PAYMENTS CONVICTED DISTROS GOODS
| | | | |
v v v v v
REAL ESTATE FAMILY WIRE TRANSFERS CARS MANSIONS
OVERSEAS MEMBERS (KENYA)RELATED FRAUD SCHEMES (MINNESOTA)
The child care fraud connects to broader “industrial-scale” fraud:
| Program | Estimated Fraud | Status |
|---|---|---|
| Feeding Our Future | $250M | 78+ indicted, 62 convicted |
| CCAP Child Care | $100M+ (2017 estimate) | Under investigation |
| Medicaid Services | $9B+ (14 programs) | 50%+ fraud rate alleged |
| Autism Services | Charged Sept 2025 | Investigation ongoing |
| Housing Stabilization | $3.5M (Philly men) | “Fraud tourism” |
| PPP Loans | $430M suspicious | 13,600 loans flagged |
| SBA Funding | $5.5M halted | Under review |
RECOMMENDED INVESTIGATIVE ACTIONS
IMMEDIATE (0-30 Days)
- IRS 990 Analysis
- Pull 990s for all major child care nonprofits in frozen states
- Flag: Revenue spikes >100% year-over-year
- Flag: Administrative fees >10% of program revenue
- Flag: Consulting fees to related parties
- Business Registry Cross-Reference
- Cross-reference provider registrations with LLC filings
- Identify shared registered agents across multiple entities
- Map address overlaps between providers and vendors
- Bank Record Subpoenas
- Target high-payment providers in WA, OH
- Trace fund flows from government to end recipients
- Identify cash withdrawals post-reimbursement
SHORT-TERM (30-90 Days)
- Site Verification
- Unannounced visits to top-billing providers
- Photo documentation of capacity vs claimed enrollment
- Attendance record audits
- Vendor Network Analysis
- Map all vendors receiving >$100K from child care providers
- Check formation dates vs contract dates
- Web presence verification
- Family/Officer Relationship Mapping
- Cross-reference officer names across entities
- Identify family relationships between provider operators and vendors
- Social media analysis for undisclosed relationships
LONG-TERM (90+ Days)
- State-by-State Deep Dives
- Priority: Ohio, Washington, California
- Apply full PBRF-LE framework
- Coordinate with state OIGs
- Federal Coordination
- Share findings with HHS OIG
- Support DOJ task force
- Brief congressional investigators
AGENCIES TO CONTACT
| Agency | Jurisdiction | Contact |
|---|---|---|
| HHS OIG | Federal CCDF oversight | oig.hhs.gov |
| DOJ Fraud Section | Federal prosecution | justice.gov |
| FBI Minneapolis | Multi-state coordination | fbi.gov |
| State AGs | State-level prosecution | Varies |
| State OIGs | State program integrity | Varies |
| IRS Criminal Investigation | Tax fraud, 990 violations | irs.gov |
DATA SOURCES
Primary Sources
- U.S. Department of Justice Press Releases
- HHS Office of Inspector General Reports
- Minnesota Office of Legislative Auditor
- Federal Court Filings (District of Minnesota)
- State Business Registrations
- IRS Form 990 Filings (ProPublica Nonprofit Explorer)
Secondary Sources
- Sahan Journal (Minneapolis investigative journalism)
- CBS News National Investigations
- Fox News Political Coverage
- NPR National Desk
- Local TV News (KARE11, FOX9, KSTP)
- Washington Post Pandora Papers
APPENDIX A: KEY DEFENDANTS (MINNESOTA)
| Name | Role | Charges | Status |
|---|---|---|---|
| Aimee Bock | FOF Founder | Wire fraud, money laundering | CONVICTED (Mar 2025) |
| Abdiaziz Shafii Farah | Ringleader | 20+ counts | CONVICTED (Jun 2024) |
| Salim Said | Co-conspirator | All counts | CONVICTED (Mar 2025) |
| Abdimajid Mohamed Nur | Shell company operator | Fraud, money laundering | SENTENCED 10 years |
| Mohamed Ismail | Site operator | Multiple counts | SENTENCED 12 years |
| Dorothy Jean Moore | Shell company | Wire fraud | CHARGED |
APPENDIX B: PBRF-LE SCORING METHODOLOGY
Risk Score Calculation:
| Indicator | Points |
|---|---|
| Revenue spike tied to reimbursement | +20 |
| Outlier billing vs peers | +15 |
| High payments to new/no-presence vendors | +15 |
| Vendor overlap (address/agent/officer) | +10 |
| Circular transfers between entities | +10 |
| Cash withdrawals / personal transfers | +10 |
| Asset purchases after reimbursements | +10 |
| Prior civil actions / audits | +10 |
Risk Interpretation: - 0-24: Low / Normal - 25-49: Moderate Risk - 50-74: High Risk - 75-100: Extreme Risk - Formal Escalation Warranted
CONCLUSION
The Minnesota fraud pattern represents a replicable blueprint that bad actors may deploy in other states. Key vulnerabilities include:
- Pandemic-era rule changes that prioritized speed over verification
- Enrollment-based rather than attendance-based payment systems
- Weak oversight capacity in state agencies
- Easy LLC formation with minimal transparency
- Large program sizes creating audit challenges
States with similar demographics, program structures, and oversight gaps should be considered HIGH PRIORITY for proactive investigation.
Report Classification: SENSITIVE INVESTIGATIVE MATERIAL Distribution: Project Milk Carton Authorized Personnel Only Next Update: As developments warrant
Generated by OPUS Intelligence System Project Milk Carton - Child Welfare Transparency Initiative
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.