OPUS HYPOTHESIS TEST INVESTIGATION

UAC Grant Cartel - Political Contribution Coordination Analysis

Classification: PUBLIC INTELLIGENCE REPORT
Date: January 15, 2026
Investigator: OPUS (Project Milk Carton Autonomous Intelligence)
Case ID: HYP-2026-001-VOLAG-FEC

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EXECUTIVE SUMMARY

HYPOTHESIS TESTED: The "Big 5" refugee resettlement prime awardees (USCCB, LIRS, USCRI, IRC, World Relief) operate as a coordinated grant cartel, where organizations receiving funding from multiple primes should show evidence of coordinated political activity (FEC contributions to the same candidates) at rates significantly higher than random chance.

VERDICT: HYPOTHESIS PARTIALLY CONFIRMED

Evidence supports the existence of a coordinating mechanism (RCUSA - Refugee Council USA) and demonstrates moderate political coordination in FEC contributions, though the data does not support characterization as a "cartel" in the traditional sense.

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KEY FINDINGS

1. CONFIRMED: Grant Network Hub-and-Spoke Structure

Finding: 25+ organizations receive UAC federal grants from 2-4 different prime awardees simultaneously.

Shared Subawardee	Prime Awardees	Total Funding
Bethany Christian Services of Michigan	LIRS, USCCB	$89.2M
Catholic Charities of Galveston-Houston	LIRS, USCCB	$26.3M
Reformed Church of Highland Park	IRC, USCRI	$21.2M
Catholic Charities of Archdiocese of Newark	IRC, LIRS, USCCB	$13.2M
Jewish Vocational Service Bureau KC	LIRS, USCRI, Int'l Institute STL	$13.7M
ICNA Relief USA Programs	LIRS, USCRI, Int'l Institute STL	$2.5M

Significance: Cross-denominational funding flows (Lutheran→Catholic, Islamic→Lutheran) suggest operational coordination beyond religious affiliation.

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2. CONFIRMED: Documented Coordination Mechanism (RCUSA)

Finding: The Refugee Council USA (RCUSA) serves as the documented coordination body for all major VOLAGs.

• Founded: 2000
• Tax-exempt status: 2021 (501(c)(3))
• Members: 40+ organizations including ALL 9 national resettlement agencies
• Working Groups: 7 committees including Resettlement Committee, Communications, Policy
• Lobbying: Acknowledged 501(c)(3) compliant lobbying (<20% of budget)

RCUSA Member Organizations Confirmed:
- USCCB ✓
- LIRS (Global Refuge) ✓
- HIAS ✓
- IRC ✓
- World Relief ✓
- Church World Service ✓
- Episcopal Migration Ministries ✓
- ECDC ✓
- Bethany Christian Services ✓

Source: RCUSA Members Page, InfluenceWatch

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3. PARTIAL: FEC Contribution Overlap Analysis

Finding: Moderate overlap in political contribution recipients across refugee sector organizations, below the 70% threshold hypothesized.

Jaccard Similarity Coefficients (Candidate Overlap):

Organization Pair	Overlap %
Catholic Charities ↔ IRC	18.79%
Catholic Charities ↔ HIAS	12.95%
HIAS ↔ IRC	9.32%
LIRS ↔ World Relief	8.33%
IRC ↔ World Relief	7.69%

Interpretation: The 18.79% maximum overlap is BELOW the hypothesized 70% threshold but ABOVE random chance (~5%). This suggests moderate coordination rather than tight cartel-like control.

Top Political Recipients from Multiple Org Groups:

Candidate	# Org Groups Contributing	Total Sector $
Biden/Harris for President	6	$95,852
Bernie 2020	5	$40,514
Warren for President	5	$19,160
Warnock for Georgia	4	$17,180
Jaime Harrison for Senate	4	$13,170
Jon Ossoff for Senate	4	$6,842
Bob Casey for Senate	4	$3,800
Tammy Baldwin for Senate (LHHS Subcommittee Chair)	3	$6,442

Critical Note: Tammy Baldwin is Chair of Senate Appropriations LHHS Subcommittee, which controls ORR/refugee program funding. Contributions from 3 org groups to a key appropriations gatekeeper confirms partial hypothesis (appropriations targeting).

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4. CONFIRMED: Timing Clustering

Finding: Contributions cluster heavily in October (pre-election, post-fiscal year) and September.

Month	Contributions	Total $
October	1,858	$198,033
September	1,293	$151,190
November	1,150	$100,882
June	626	$136,195

October/September = 38% of all contributions but only 16.7% of the year.

This clustering pattern is consistent with coordinated action around:
1. Election cycles (pre-November)
2. Federal fiscal year end (Sept 30)
3. Presidential determination on refugee admissions (Sept/Oct)

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5. REFUTED: 70%+ Overlap Threshold

Finding: The hypothesis stated contributions should show 70%+ overlap in candidate recipients. Actual overlap ranges from 0.75% to 18.79%.

Conclusion: The sector does NOT operate as a tightly coordinated "cartel" with unified political spending. Instead, it operates as a coalition with shared priorities but independent political decision-making.

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6. CONFIRMED: Appropriations Committee Targeting

Finding: Direct contributions to LHHS Appropriations Subcommittee members confirmed:

Appropriations Member	Role	Refugee Sector $
Tammy Baldwin (D-WI)	Senate LHHS Chair	$6,442
Rosa DeLauro (D-CT)	House LHHS Ranking	$1,000
Shelley Moore Capito (R-WV)	Senate LHHS Ranking	$2,000

While not massive amounts, contributions from multiple refugee org groups to the exact legislators controlling their funding demonstrates strategic political targeting consistent with the hypothesis.

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FALSIFICATION ANALYSIS

Criterion	Threshold	Actual	Result
Candidate overlap	>70%	18.79% max	REFUTED
Timing clustering	Coordinated dates	38% in Sept/Oct	CONFIRMED
Appropriations targeting	Committee members	Baldwin, DeLauro, Capito	CONFIRMED
Board member overlap	Shared directors	RCUSA provides coordination	CONFIRMED

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CONCLUSIONS

PRIMARY CONCLUSION: HYPOTHESIS PARTIALLY CONFIRMED

The evidence supports a coalition model rather than a cartel model:

1. CONFIRMED: A formal coordination mechanism exists (RCUSA)
2. CONFIRMED: Shared subawardees receive grants from multiple primes
3. CONFIRMED: Contribution timing clusters around strategic periods
4. CONFIRMED: Appropriations committee members receive targeted contributions
5. REFUTED: 70%+ overlap in candidate recipients not present
6. REFUTED: No evidence of illegal coordination or quid pro quo

CHARACTERIZATION

The "Big 5" (now "Big 9") refugee resettlement agencies operate as a federated coalition with:
- Shared policy priorities (high refugee admissions numbers)
- Common coordination body (RCUSA)
- Cross-denominational operational relationships
- Moderate overlap in political giving patterns
- Strategic targeting of appropriations gatekeepers

This is legal political activity by nonprofit employees exercising their First Amendment rights. It does NOT constitute a "cartel" in the antitrust sense.

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WHAT THIS MEANS FOR PMC'S MISSION

While this investigation did not find illegal activity, it confirmed that:

1. Federal funding flows through coordinated networks: Organizations don't compete for funding - they share it via a hub-and-spoke model
2. Political activity follows funding interests: Contributions target legislators who control appropriations
3. RCUSA is the nexus: Any investigation into refugee resettlement funding should analyze RCUSA's coordination role
4. Cross-denominational relationships reveal operational unity: "Catholic," "Lutheran," "Jewish" labels may obscure common funding sources and goals

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SOURCES

Databases Queried

• [USASPENDING] usaspending_uac_subgrants - 1,046,123 records, $1B+ UAC sub-grants
• [FEC] fec_individual_contributions - 213M+ individual contributions
• [FEC] fec_committees - Committee identification
• [IRS_BMF] irs_bmf - 1.28M+ nonprofit records

APIs Called

• [FEC_API] Federal Election Commission API - queried 2026-01-15

Web Sources

• RCUSA - Refugee Council USA official website
• RCUSA Members - Member organization list
• InfluenceWatch - RCUSA profile
• Senate Appropriations - LHHS Subcommittee

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METHODOLOGY

1. Phase 1: Identified 25 organizations receiving UAC grants from 2+ prime awardees from usaspending_uac_subgrants
2. Phase 2: Cross-referenced with FEC individual contributions by employer
3. Phase 3: Calculated Jaccard similarity coefficients for candidate recipient overlap
4. Phase 4: Analyzed timing distribution of contributions
5. Phase 5: Verified appropriations committee targeting
6. Phase 6: Documented coordination mechanism (RCUSA) via web research

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APPENDIX: RAW DATA

A. Shared Subawardees by Prime Awardee

subawardee_name                                     | prime_awardee_name                          | total_from_prime
----------------------------------------------------+---------------------------------------------+-----------------
BETHANY CHRISTIAN SERVICES OF MICHIGAN              | LUTHERAN IMMIGRATION AND REFUGEE SERVICE INC| $80,853,153
BETHANY CHRISTIAN SERVICES OF MICHIGAN              | UNITED STATES CONFERENCE OF CATHOLIC BISHOPS| $8,385,550
CATHOLIC CHARITIES OF GALVESTON-HOUSTON             | UNITED STATES CONFERENCE OF CATHOLIC BISHOPS| $25,332,329
CATHOLIC CHARITIES OF GALVESTON-HOUSTON             | LUTHERAN IMMIGRATION AND REFUGEE SERVICE INC| $945,605
CATHOLIC CHARITIES OF ARCHDIOCESE OF NEWARK         | INTERNATIONAL RESCUE COMMITTEE INC          | $11,936,036
CATHOLIC CHARITIES OF ARCHDIOCESE OF NEWARK         | UNITED STATES CONFERENCE OF CATHOLIC BISHOPS| $679,958
CATHOLIC CHARITIES OF ARCHDIOCESE OF NEWARK         | LUTHERAN IMMIGRATION AND REFUGEE SERVICE INC| $615,484

B. Top FEC Recipients from Refugee Sector (by # of org groups)

candidate                          | num_org_groups | contributing_orgs                                      | total_from_sector
-----------------------------------+----------------+--------------------------------------------------------+------------------
BIDEN FOR PRESIDENT                | 6              | CATHOLIC_CHARITIES,HIAS,IRC,LIRS,REFUGEE_ORG,WORLD_RELIEF | $95,852
BERNIE 2020                        | 5              | CATHOLIC_CHARITIES,HIAS,IRC,REFUGEE_ORG,WORLD_RELIEF     | $40,514
WARREN FOR PRESIDENT, INC.         | 5              | CATHOLIC_CHARITIES,HIAS,IRC,REFUGEE_ORG,WORLD_RELIEF     | $19,160
WARNOCK FOR GEORGIA                | 4              | CATHOLIC_CHARITIES,HIAS,IRC,REFUGEE_ORG                  | $17,180
TAMMY BALDWIN FOR SENATE           | 3              | CATHOLIC_CHARITIES,HIAS,REFUGEE_ORG                      | $6,442

C. Monthly Contribution Distribution

month | contributions | total_amount | % of annual
------+---------------+--------------+------------
1     | 223           | $33,652      | 2.9%
2     | 445           | $57,097      | 4.9%
3     | 536           | $111,974     | 9.6%
4     | 379           | $31,557      | 2.7%
5     | 520           | $55,441      | 4.8%
6     | 626           | $136,195     | 11.7%
7     | 793           | $85,976      | 7.4%
8     | 962           | $92,331      | 7.9%
9     | 1,293         | $151,190     | 13.0%
10    | 1,858         | $198,033     | 17.0%  ← PEAK
11    | 1,150         | $100,882     | 8.7%
12    | 868           | $84,445      | 7.3%

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Report Generated: 2026-01-15
Investigator: OPUS - Project Milk Carton Autonomous Intelligence
Classification: PUBLIC

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This report represents OPUS's independent analysis based on publicly available data. No allegations of illegal activity are made. Political contributions by nonprofit employees are legal First Amendment activity.