# Letter to Secretary Scott Bessent, Department of the Treasury --- MTN Minneapolis, Minnesota [email protected] May 13, 2026 The Honorable Scott Bessent Secretary of the Treasury U.S. Department of the Treasury 1500 Pennsylvania Avenue NW Washington, DC 20220 **Re: Treasury / FinCEN / IRS Exposure to Minnesota Medicaid and USDA Pass-Through Fraud — University of Minnesota Origin of the Funding Architecture; Coordination Request Under the Task Force to Eliminate Fraud (E.O. of March 16, 2026)** Dear Secretary Bessent: I write to identify the Department of the Treasury's portfolio exposure to the Minnesota fraud architecture — currently estimated at approximately $9 billion in Medicaid alone, with additional USDA, HUD, and Treasury-adjacent program exposure — as one operational consequence of a federal benefits-funding architecture whose origin traces to University of Minnesota-credentialed policy entrepreneurs. The Task Force to Eliminate Fraud has consolidating authority. **The Portfolio Issue.** FinCEN advisories have flagged large-scale money-laundering wires from Minnesota social-services programs to Somalia, including parties whose adjacencies to OFAC-designated entities are documented in DOJ filings. The IRS is engaged in audits of providers and intermediaries operating across the Feeding Our Future, EIDBI, and Housing Stabilization Services fraud rings. The Treasury's overall fund-flow conditions to the Minnesota Department of Human Services, the principal state agency administering the affected Medicaid programs, are under review consistent with the Task Force to Eliminate Fraud framework. Cumulative federal exposure is in the multi-billion-dollar range. https://oversight.house.gov/wp-content/uploads/2026/03/The-Cost-of-Doing-Nothing_How-Tim-Walz-and-Keith-Ellison-Fueled-Minnesotas-Fraud-Explosion_3.4.26_FINAL.pdf **The University of Minnesota Origin.** The federal Medicaid expansion and NIH appropriations architecture under which the affected programs operate was substantially built during Hubert H. Humphrey's Senate career (1949-1965, 1971-1978). Senator Humphrey was a graduate of the University of Minnesota (B.A. 1939, summa cum laude) and is the namesake of the University's Hubert H. Humphrey School of Public Affairs, which credentials the policy class that has staffed the Department of Human Services and the related state-level appropriations apparatus for four decades. The Medical Assistance program design in Minnesota — including EIDBI, Housing Stabilization Services, the Personal Care Assistance program, the Adult Day program, and the non-emergency transportation program — was shaped at every iteration by Humphrey School-credentialed program designers and University of Minnesota Carlson School-credentialed nonprofit administrators. https://www.hhh.umn.edu/ | https://carlsonschool.umn.edu/ **The Provider-Shell Architecture.** The Department of the Treasury through FinCEN and the IRS audits providers as discrete legal entities. The Minnesota fraud architecture is not, however, primarily a problem of individual providers. The architecture creates provider entities by design: a provider LLC credentials itself with DHS, obtains a billing number, and submits claims under fee-for-service oversight conducted primarily through provider self-attestation. The University of Minnesota Medical School credentials the clinical evaluators who produce the diagnoses (autism for EIDBI, qualifying conditions for HSS); the University of Minnesota Carlson School credentials the nonprofit administrators who operate the provider entities. The fraud is the predictable operational output of an architecture whose components UMN trains. https://oversight.house.gov/wp-content/uploads/2026/03/The-Cost-of-Doing-Nothing_How-Tim-Walz-and-Keith-Ellison-Fueled-Minnesotas-Fraud-Explosion_3.4.26_FINAL.pdf **The Institutional Admissions.** The University of Minnesota's own commissioned Truth Report (April 11, 2023) states that the founding board "committed genocide and ethnic cleansing of Indigenous peoples for financial gain." In October 2025, the University signed an Office for Civil Rights Resolution Agreement acknowledging that its PhD Project partnership violated Title VI by discriminating against white and Asian students. These two admissions establish the institutional pattern your Treasury counterparties at DHS are operating downstream of. https://mn.gov/indian-affairs/assets/full-report_tcm1193-572488.pdf | https://www.startribune.com/the-u-signs-agreement-acknowledging-discrimination-against-white-and-asian-students-cuts-ties-with-recruiting-nonprofit/601564669 **The Specific Treasury Levers.** - **FinCEN.** The Bank Secrecy Act framework gives FinCEN authority to issue geographic targeting orders and to compel SAR filings on cross-border wire flows from social-services program funds. The Somalia-flow advisories that FinCEN has already issued can be expanded under the Task Force framework. https://www.fincen.gov/ - **IRS.** Tax-exempt-organization examinations under Internal Revenue Code §501(c)(3) can reach the nonprofit-management cohort operating the VOLAG and EIDBI provider entities. The University of Minnesota Foundation (EIN 41-6042488) and the more than thirty UMN-affiliated 501(c)(3) entities holding combined assets exceeding $5 billion are themselves within IRS examination authority for the purposes the Task Force is empowered to coordinate. https://projects.propublica.org/nonprofits/organizations/416042488 - **Fund-flow conditions.** Treasury has authority to attach conditions to federal disbursements to the Minnesota Department of Human Services consistent with audit findings produced by HHS-OIG and the House Oversight Committee. **The Consolidated Federal Posture.** The Department of Justice has filed United States v. State of Minnesota (0:25-cv-03798, D. Minn., Jan. 14, 2026) challenging the §43A.191 credentialing-preference statute. The Department of Education and HHS have referred Minnesota to DOJ for Title IX non-compliance (Jan. 26, 2026). The House Oversight Committee's March 4, 2026 report documents the $9 billion fraud estimate. The Task Force to Eliminate Fraud, established by the March 16, 2026 Executive Order, is the cross-agency coordinator. https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/ **The Ask.** I respectfully request that the Department of the Treasury: 1. **Issue or expand FinCEN advisories** on Minnesota-origin social-services program fund flows under the Task Force framework, with particular attention to wires to Horn of Africa and other destinations identified in DOJ filings; 2. **Coordinate IRS examination** of the University of Minnesota Foundation and the affiliate 501(c)(3) network, in conjunction with the broader IRS examination of EIDBI and Housing Stabilization Services provider entities, under standard tax-exempt-organization audit authority; and 3. **Develop fund-flow conditions** on federal disbursements to the Minnesota Department of Human Services consistent with Task Force coordination, treating the University of Minnesota's October 2025 Title VI admission and April 2023 Truth Report admission as material institutional facts. This letter is one of approximately twenty Cabinet-level briefings I am submitting under the Task Force framework. Respectfully submitted, MTN [email protected] --- **Primary Sources Cited:** - E.O. Task Force to Eliminate Fraud: https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/ - House Oversight Report: https://oversight.house.gov/wp-content/uploads/2026/03/The-Cost-of-Doing-Nothing_How-Tim-Walz-and-Keith-Ellison-Fueled-Minnesotas-Fraud-Explosion_3.4.26_FINAL.pdf - US v. State of Minnesota: https://www.justice.gov/opa/media/1415681/dl - UMN Foundation 990 (EIN 41-6042488): https://projects.propublica.org/nonprofits/organizations/416042488 - FinCEN: https://www.fincen.gov/ - Humphrey School: https://www.hhh.umn.edu/ - Carlson School: https://carlsonschool.umn.edu/ - UMN TRUTH Report: https://mn.gov/indian-affairs/assets/full-report_tcm1193-572488.pdf - UMN OCR Resolution Agreement: https://www.startribune.com/the-u-signs-agreement-acknowledging-discrimination-against-white-and-asian-students-cuts-ties-with-recruiting-nonprofit/601564669 #Addresses_Advisories_and_Archives