MN Public Tools, independent public-records research by Dan Swenson.
Who had oversight responsibility, and when?
For each moment an agency or court had to act, this page shows what the rule required, what actually happened, and what followed. Every entry cites its source. The turning point is March to April 2021, when the Minnesota Department of Education (MDE) stopped paying Feeding Our Future and then, about a month later, started paying again without a court order.
Officials are named only where a cited source assigns a decision or statement to them. Appearing here describes responsibility for program administration. It does not imply personal or criminal culpability. Where a characterization is disputed, the written court record controls.
Who was responsible
Federal child-nutrition money flowed through the Minnesota Department of Education (MDE), and Medicaid money flows through the Department of Human Services (DHS). The entries below show what happened at each link.
Federal child nutrition
USDA money flowed through the Department of Education to Feeding Our Future and its meal sites.
Level 1U.S. Department of Agriculture (USDA) Food and Nutrition Service
Funds the federal child-nutrition programs and sets program rules, and relies on state agencies to administer them.
Level 2Minnesota Department of Education (MDE)
Administered the child-nutrition programs in Minnesota by approving sponsors, disbursing reimbursements, and conducting monitoring reviews.Mary Cathryn Ricker, Commissioner of Education, 2019 to March 2021Heather Mueller, Commissioner of Education, April 1, 2021 to January 2023Willie Jett, Commissioner of Education, Appointed January 2023 and in office as of October 11, 2026What the record says: The Office of the Legislative Auditor (OLA)’s June 2024 special review found that MDE’s inadequate oversight of Feeding Our Future created opportunities for fraud, including complaints and warning signs the department did not act on. Official retrospective report source:Legislative Auditor
Level 3Feeding Our Future (sponsor nonprofit)
Sponsored meal sites, submitted their reimbursement claims to MDE, and collected administrative fees.What the record says: Prosecutors charged that the sponsor and dozens of its sites submitted fake attendance rosters and invoices for meals never served. Its founder was sentenced to more than 41 years in May 2026, with convictions across the investigation continuing. Secondary source:Minnesota Reformer
Level 4Meal sites and vendors
Claimed to serve meals to children at hundreds of locations.What the record says: No wrongdoing was shown at many sites. The Star Tribune’s review tied a subset of the total reimbursements directly to charged businesses. Characterization source:Star Tribune
Medicaid (Medical Assistance)
Federal and state Medicaid money flows through the Department of Human Services (DHS) to enrolled providers across the flagged programs.
Level 1Centers for Medicare & Medicaid Services (CMS)
Funds the federal share of Minnesota Medicaid and approves state plan amendments, including the 2025 termination of Housing Stabilization Services. In 2026 CMS deferred three quarters of federal match ($259.5 million, about $91 million, and $199 million) pending documentation of claims in the 14 high-risk services. It threatened a $515 million per-quarter withhold and accepted the state’s corrective action plan. The state’s suit over the first deferral is on hold until January 2027. A deferral is a request for documentation, not a fraud finding.
Level 2Minnesota Department of Human Services (DHS)
Administers all Minnesota Medicaid programs. Its Office of Inspector General screens providers, investigates complaints, and can withhold payments.Jodi Harpstead, Commissioner of Human Services, August 2019 to February 3, 2025Shireen Gandhi, Commissioner of Human Services (temporary from February 3, 2025, and appointed February 23, 2026), February 2025 to May 4, 2026, and deputy commissioner over Medicaid since thenJohn Connolly, Temporary Commissioner of Human Services (previously Medicaid director), May 4, 2026 onward, as of October 11, 2026James Clark, DHS Inspector General, March 2025 onward, as of October 11, 2026What the record says: The Office of the Legislative Auditor (OLA)’s March 2026 special review found DHS asserted that, before 2025, it lacked authority to investigate kickback-only complaints in the autism-therapy (EIDBI) program. But DHS has long had legal authority to address kickback allegations, the review found. It also found that a decades-old error in DHS administrative rules may limit its ability to suspend payments during kickback investigations. Official retrospective report source:Legislative Auditor
Level 3Attorney General’s Medicaid Fraud Control Unit (MFCU)
Investigates and prosecutes Medicaid provider fraud at the state level, alongside federal prosecutors.What the record says: The MFCU brought the $9.5 million MN Professional personal care assistance (PCA) case in 2023, then the largest in its history, and has taken part in the joint state-federal Medicaid investigations since. Primary source:Minnesota Attorney General
Level 4Medicaid providers (autism therapy, housing stabilization, personal care, and others)
Enroll with DHS and bill Medicaid for services.What the record says: Charging documents across programs describe billing for services not provided, kickbacks to recruit enrollees, and low barriers to provider enrollment. Many 2025-2026 Medicaid defendants have pleaded guilty. Those not convicted are presumed innocent. Primary source:Justice Department
What the Department of Education did, and when
Entries are in date order. The key entry is the March 2021 payment stop. The state stopped paying, started again about a month later without being ordered to, and kept paying through the period in which charging documents allege much of the scheme occurred.
When the sponsor was approved, and under whom
The sponsor was approved under one administration and grew under another.
November 2016 to June 2017. Feeding Our Future was established in November 2016. The Minnesota Department of Education (MDE) approved it as a sponsor in the Child and Adult Care Food Program (CACFP) in June 2017, during the Dayton administration, under Commissioner Brenda Cassellius (who served eight years under Gov. Mark Dayton, through January 2019). It remained inactive until mid-2018 and received its first CACFP reimbursements in August 2018.Official retrospective report source:Legislative AuditorSecondary source:MPR News
May 2017. The Minnesota Court of Appeals’ Partners in Nutrition decision (904 N.W.2d 223) put the department on notice, per the Legislative Auditor, that it needed to codify certain procedures in state administrative rules. It did not seek statutory changes or rulemaking authority. Partners in Nutrition (by then Partners in Quality Care) was later named in the 2022 search warrants, which did not directly accuse it of fraud, and it sued MDE in 2022. The full procedural history is on the lawsuit page.Official retrospective report source:Legislative AuditorPrimary source:Minnesota Court of AppealsSecondary source:Sahan Journal
February 2019. MDE completed its only administrative review of Feeding Our Future in February 2019, at the transition between Commissioner Cassellius and Commissioner Mary Cathryn Ricker.Official retrospective report source:Legislative Auditor
June 2020. MDE approved Feeding Our Future for the Summer Food Service Program in June 2020, under the Walz administration, the decision that preceded the sponsor’s largest growth.Official retrospective report source:Legislative Auditor
MDE receives at least 30 complaints and does not investigate some of them
Date
Mid-2018 through 2021
Agency or person
Minnesota Department of Education
Rule
Federal program rules require the state agency to promptly investigate complaints and program irregularities.
Record
The Legislative Auditor found MDE received at least 30 complaints about Feeding Our Future from mid-2018 through 2021, did not investigate some at all, and at one point inappropriately asked Feeding Our Future to investigate complaints about itself.
What followed
Warning signs known to the department before the pandemic never became effective investigations. The Legislative Auditor concluded MDE "failed to act on warning signs" and "did not effectively exercise its authority."
MDE pauses its reviews and does little offsite monitoring
Date
2020 through 2021
Agency or person
Minnesota Department of Education
Rule
Site monitoring was the check that claimed meals were actually served. Pandemic waivers allowed remote alternatives such as desk audits.
Record
Pandemic waivers let MDE monitor sponsors offsite, but the Legislative Auditor found they “did not prohibit MDE from conducting administrative reviews or onsite monitoring visits of Feeding Our Future.” MDE did not conduct site visits it had scheduled for late 2020. At trial, Emily Honer testified that visiting sites was the sponsor’s job and that she did not do a desk audit of the sites she was worried about.
What followed
The auditor found MDE should have reviewed Feeding Our Future’s operations in other ways, such as desk reviews of its meal claims, and “It did not do so.”
Not established
Testimony also described a department working under pandemic rules and an aggressive lawsuit. The record does not establish that any individual chose not to audit for improper reasons.
MDE agrees to a consent order on site applications
Date
December 22, 2020
Agency or person
The courts
Rule
Feeding Our Future sued MDE in November 2020 over unprocessed site applications. The parties settled before the court ruled.
Record
MDE negotiated and agreed to a consent order committing it to handle federally regulated site applications "reasonably promptly."
What followed
The order became the yardstick for the contempt finding six months later, when MDE had taken more than 30 days on all 143 of the site applications it then denied.
The payment stop, and the voluntary resumption(the turning point)
Date
March 30 to April 2021
Agency or person
Minnesota Department of Education
Rule
MDE could suspend payments after finding "serious deficiencies," subject to the sponsor’s right to remedy them and to court review.
Record
MDE issued a serious-deficiencies letter on March 30, 2021 and suspended payments. Feeding Our Future moved for an order compelling payment. At an April 21, 2021 hearing the judge remarked to state attorneys that "you’ve got a real problem not reimbursing at this stage of the game" (a remark, not an order). MDE lifted the stop-pay in late April, on its own, and asked the court to deny the payment motion as no longer needed, which it did in June 2021. Assistant Commissioner Daron Korte later told congressional investigators that MDE expected the judge to side with Feeding Our Future, which also had a contempt motion pending, and feared sanctions, so “we just decided to voluntarily lift the stop-pay.” He added that MDE knew an FBI investigation “was either underway or would shortly be underway,” and hoped resumed payments would last “only for a short period of time.”
What followed
Payments continued through the period in which charging documents allege much of the scheme occurred. The court’s written correction states no order ever required MDE to resume payments.
Not established
Korte also told investigators he expected MDE to be found in contempt “once again”. The court’s only contempt finding in the case came later, on June 24, 2021, over site applications. The record shows a voluntary decision made under litigation pressure. It does not establish what would have happened had MDE litigated the suspension to a ruling.
Minnesota Department of EducationEmily Honer, Nutrition Program Services division, MDE (a supervisor, then assistant director, in 2020 to 2021, and director since August 2023). Named because her own trial testimony and 2026 interview describe her part in these reports.
Rule
MDE had to investigate program complaints and compliance problems, but it was not a criminal law-enforcement agency. Suspected criminal fraud goes to the U.S. Department of Agriculture (USDA) Office of Inspector General or to law enforcement.
Record
Emily Honer, who worked in MDE’s Nutrition Program Services division (she became its director in August 2023), testified at trial that she reported concerns to the USDA in summer 2020, obtained USDA sign-off on serious-deficiency notices in March 2021, and turned to the FBI after hearing nothing back from USDA’s inspector general. In a 2026 congressional interview she said her conversations with the FBI began around March 2021, that she did not make the first call to the FBI and does not know who did, and that she took part in most of the calls and meetings that followed.
What followed
The FBI had already received a separate tip about Feeding Our Future in February 2021 and interviewed people, but its case agent testified that this did not formally open an investigation. The FBI formally opened it two months later, after Honer approached the agency. That investigation led to the January 2022 raids and the prosecutions that followed.
Contempt over site applications, a separate episode from the payment stop
Date
June 24, 2021
Agency or person
The courts
Rule
The December 2020 consent order required MDE to act on site applications "reasonably promptly."
Record
Between November 30, 2020 and April 13, 2021, Feeding Our Future applied for 144 site IDs (the state’s approval for a meal location). MDE approved one and denied the other 143 in a letter dated April 29, 2021. It took more than 30 days on every one, more than 45 on 129, and more than 80 on 72. The court found MDE in civil contempt of the order it had agreed to.
What followed
MDE was ordered to pay a $35,750 sanction plus $11,750 in stipulated attorney fees, $47,500 in total. This order concerned application processing. It did not order payments resumed.
The "court order" explanation, and the court’s written correction
Date
September 22 to 23, 2022
Agency or person
The courtsTim Walz, Governor of Minnesota. Named because the court’s statement responds to his public remarks by name.John H. Guthmann, Judge, Ramsey County District Court. Authorized the written correction.
Rule
Public officials’ characterizations of court orders can be checked against the orders themselves.
Record
After the first indictments, Governor Tim Walz said MDE’s hands had been tied by a court order to resume payments. The Minnesota Judicial Branch, in a statement authorized by Judge Guthmann, called the characterizations inaccurate. It said no order ever required MDE to resume payments, and the payments were voluntary.
What followed
The court’s written statement is the authoritative record of what it did and did not order. This page relies on it, not on remarks at the hearing or later characterizations.
The Legislative Auditor’s verdict on the oversight
Date
June 13, 2024
Agency or person
Legislature / Legislative Auditor
Rule
The Office of the Legislative Auditor (OLA) special review examined MDE’s oversight of Feeding Our Future against the department’s legal obligations.
Record
The review concluded MDE failed to act on warning signs known before the pandemic, did not effectively exercise its authority to hold Feeding Our Future accountable, and was ill-prepared to respond.
What followed
The findings became the factual backbone for the oversight reforms the Legislature took up in 2025 and 2026.
Complaints, a payment stop, and the FBI case at the Department of Education
The Legislative Auditor found the agency did not act on years of complaints, and a member of the same agency's nutrition division staff brought the concerns that preceded the FBI's formal investigation. Both are in the record. Each step has its own source.
5Emily Honer, then in MDE’s nutrition division (its director since August 2023), kept pressing. She took her concerns to the U.S. Department of Agriculture in 2020 and heard nothing back from its inspector general. Secondary source:Minnesota Reformer
The state checkbook records sponsor payments by fiscal year. Yearly totals cannot show what any one decision cost, so read the chart as context.
What the state paid Feeding Our Future, from the checkbook
This chart shows total state payments to the payee “Feeding Our Future” (dark) in Minnesota's own accounting system, by state budget year. Partners in Nutrition (light), the other large nonprofit sponsor, is shown for scale. Feeding Our Future went from $1.4M in FY2019 to $140.4M in FY2021. Payments stop entirely after the January 2022 FBI raids. Across all years the checkbook shows $245.1M paid to the organization. Checkbook payments and charged fraud amounts measure different things. Payments include money that reached legitimate sites. The amounts prosecutors charged are on their own page.
These are payments to the sponsor, not fraud amounts, and some funds reached legitimate meal sites. Partners in Nutrition is shown only for scale. It has never been criminally charged. In September 2026 it settled a civil False Claims Act suit by the Minnesota Attorney General for about $18.5 million and agreed to dissolve, denying the allegations. FBI search warrants in 2022 alleged fraud by vendors that worked with it.Primary source:MN Open CheckbookDerived source:All-years total (our sum)
The March 2021 payment stop lasted weeks within fiscal year 2021, and the January 2022 raids fall inside fiscal year 2022. I found no monthly figures in the record, so none are estimated here.
What officials said
The public explanation of the 2021 dispute later became contested. The Statements page lists what officials said and what the court and auditor records show.
Political connections and campaign donations from people later charged are on the politics page.
The Medicaid programs
These programs are listed separately because they belong to a different agency, the Department of Human Services (DHS), and many of these cases have not reached sentencing.
Housing Stabilization Services far outgrows its projection
Date
July 2020 to October 2025
Agency or person
Minnesota Department of Human Services
Rule
Housing Stabilization Services (HSS) launched as a standard Medicaid benefit projected to cost about $2.6 million per year.
Record
The program paid out $104 million in claims in 2024 alone, about 40 times the projected annual cost, and more than $302 million from 2021 through June 2025 (this site’s sum of the yearly figures in the U.S. Attorney’s release). Federal prosecutors later charged providers with billing for services never delivered.
What followed
Minnesota terminated the program effective October 31, 2025.
Not established
Growth beyond a projection is not itself fraud. The amounts charged within the program are a subset of its spending.
Kickback complaints DHS said it could not investigate
Date
March 17, 2026
Agency or person
Minnesota Department of Human Services
Rule
DHS’s Office of Inspector General screens Medicaid providers and investigates complaints.
Record
The Office of the Legislative Auditor (OLA) found DHS asserted that, before 2025, it lacked authority to investigate kickback-only complaints in the autism-therapy (EIDBI) program. But DHS "has long had legal authority" to address kickback allegations, the review found. A decades-old error in DHS administrative rules may limit its ability to suspend payments during kickback investigations.
What followed
The three kickback complaints the review examined were closed without investigation, a flag for future investigation, or a referral. The Legislature added explicit kickback authority in 2025.
Many 2025 to 2026 Medicaid cases have not reached sentencing. The Legislative Auditor's findings quoted here are about agency authority and process, not about any defendant. Official retrospective report source:Legislative Auditor
What has changed since
Each reform is listed by date. A law is marked enacted when signed and in effect only after its start date.
A statewide Office of the Inspector General
The law has passed, but the office is not yet operating. SF 856 (2026, Chapter 92) creates an independent executive-branch inspector general to oversee the inspectors general inside individual agencies and to investigate credible fraud allegations in state programs, with its own law-enforcement bureau to follow.
May 14, 2026Signed into law (Chapter 92) (enacted)
January 1, 2027Principal provisions take effect (pending)
February 1, 2027Governor must appoint an inspector general (pending)
September 1, 2027Office must be fully operational (pending)
January 1, 2028Anti-Fraud and Waste Bureau law-enforcement authority begins (pending)
Writing the criteria into law, which the 2017 Partners in Nutrition decision said was needed, happened in stages, starting six years later. Financial-viability criteria for sponsors in the Child and Adult Care Food Program (CACFP) and the Summer Food Service Program (SFSP) were written into Minn. Stat. 124D.111, subd. 2a in 2023, and the subdivision was amended in 2024 and 2025. MDE gained an inspector general with subpoena and data-access authority. As of its June 2024 review, the Legislative Auditor found the administrative-capability and program-accountability standards were not written into law.
May 24, 2023Financial-viability criteria enacted (Laws 2023, ch. 55) (enacted)
May 24, 2023MDE inspector general created (Minn. Stat. 127A.21) (enacted)
May 18, 2024MDE OIG gains subpoena and data-access authority (Laws 2024, ch. 115) (enacted)
June 13, 2024Legislative Auditor finds two of the three performance standards still not written into law (measured)
State-commissioned review of Medicaid payment integrity
Minnesota commissioned Optum to review fee-for-service claims across 14 flagged Medicaid services. The review, as reported, estimated about $1 billion in potential savings from clearer policies and identified more than $52.3 million in payments that clearly violated stated policy. Neither figure is a fraud finding.
February 6, 2026Findings reported (measured)
September 24, 2026OLA publishes a summary of the Optum vulnerability assessment from an unredacted copy, without verifying Optum’s work (measured)
People charged but not convicted are presumed innocent, and amounts labeled alleged come from charging documents, not proven losses. Method and corrections