Fraud Prevention & Internal Control Series
We understand intricate issues such as financial literacy, resource constraints, and weak internal controls in highly regulated industries such as healthcare and non-profit. We also understand the importance of integrity of public funds. We're stepping up by interpreting current events, simplifying the messaging, and delivering actionable resources.
Recent Updates
Published 1/28/26 by Ahmed Hassan
Quick summary of CMS's latest audit of Minnesota Medicaid
Published 1/26/26 by Ameera Hassan
One-pager summarizing updates for care providers subject to EVV requirements
Published 12/28/25 by Ahmed Hassan
Quick update regarding Medicaid fraud investigations in Minnesota
About Us
Established January 2025 in Bloomington, Minnesota, Hassan CPA PLLC (dba Hassan.CPA) is a Minnesota licensed Certified Public Accounting firm providing accounting, advisory, and consulting services.
Our Mission
We empower businesses and mission‑focused organizations with guidance, modern infrastructure, and data‑driven insights that support sustainable growth. We lead with our values to elevate ethical professional standards, and we recruit, train, and develop client service professionals into community leaders.
Our Vision
To proudly serve businesses and mission focused organizations and empower them to shape their own successes through ESG principles, modern finance and data.
Our Values & Commitments
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Integrity
We uphold the highest ethical standards, ensuring transparency and trust in our relationships.
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Excellence
We strive for continuous improvement, seeking innovative solutions that make the best sense.
3
Balance
We leverage modern technology to create space for work and a healthy life outside of it.
4
Confidence²
Our CPA firm permit and adherence to State Board and professional standards reinforce confidence for clients and the public.
5
Elevate the Profession
We invest in the future of accounting through advocacy, CPA exam support, and resources for the next generation of CPAs.
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ESG Mindset
We respond to community needs by incorporating sustainability and strong governance into the way we advise.
Our Story Told
Breaking Barriers
On May 23, 2025, Governor Walz signed legislation we helped advance with the Minnesota Society of CPAs, removing the 150‑credit requirement and opening new pathways to CPA licensure. This milestone reinforces our ESG commitment to equity, access, and opportunity in the profession.
Transforming Data & Operations
We recognized the power of data management to turn complex financial and non‑financial information into clear insights. Our data team was built to deliver visualizations that drive smarter decisions. At the same time, we streamlined processes to help execute all our services efficiently.
Automation & Systems Integration
We highlighted the power of technology automation, the risks around data privacy, and the impact of effectively using AI. We narrowed our tech stack after meticulous research, feasibility, and risk assessments. We finally settled on some of the most secure technology solutions on the market.
Our Story Told (Cont.)
Alignment with the CAS 2.0 Framework
Our full team enrolled in structured training provided by CPA.com’s CAS Professional Services. Their program provided a deep dive into the CAS 2.0 framework and helped us identify any existing gaps in our practice.
Top Notch Solutions
Developed key alliances with leading modern accounting, tax, finance companies to deliver a seamless service experience for our clients.
Fraud Prevention & Internal Control Series
We invested heavily in developing free educational resources, including guides, templates, workshops, and training materials. Our goal is to simplify complex topics, educate on internal controls, and help organizations operate with confidence and clarity.
Our CAS Leader's Journey
Early Excellence
Gregory Terrell & Company
Detroit, MI (2016-2019)
Ahmed launched his career at Gregory Terrell & Company, where he built a strong foundation serving community care providers, non-profits, schools, and city government.
During this time, he was mentored by seasoned CPAs, expanded his network through prominent community events, and supported the firm by taking on a wide range of responsibilities.
Strategic Moves
Ernst & Young, LLP
Seattle, WA (2019-2021)
Ahmed joined EY in Seattle as an Assurance Associate. There, he had the opportunity to work on financial audits and reviews for a wide range of clients including private companies, pre-IPO ventures, and publicly traded corporations with revenues as high as $28 billion.
Ahmed gained valuable insight to challenges organizations face at different stages of growth. EY provided opportunities for Ahmed to sharpen his technical skills and establishing a community presence through NABA.
Leadership & Impact
Deloitte & Touche, LLP
Seattle/MPLS (2021-2024)
At Deloitte, Ahmed led private and publicly traded company audit engagements including serving as a lead Senior on a Big Tech audit engagement and the Manager on a BIG-10 university.
Ahmed advanced his leadership aspirations by studying ESG, facilitating SOX internal control and fraud trainings, and serving as a people leader for the Central Region.
Careers | Join Our Leadership
We’re not offering jobs. We’re offering ownership.
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OPEN | 15% Equity Owner*
CAS Accounting Leader (CPA required)
Healthcare & Non-Profit
Minneapolis, MN
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OPEN | 15% Equity Owner*
Director of Accounting & Tax (CPA or EA required)
Small Businesses
Minneapolis, MN
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OPEN | 7.5% Equity Owner*
Director of Administration & Business Development
Minneapolis, MN
*Equity Requirements
Equity ownership is governed by MN Statute 326A.05, which requires that CPAs hold at least 51% of firm ownership.
- Experience: Appropriate years of experience for desired role that includes progression and industry expertise.
- Leadership: Proven track record in client service, business growth, and/or team development.
- Values Alignment: Commitment to our values and collaborative leadership.
- Operational Fit: Ability to deliver services that align with our mission, tech, and operational flow.
- Communication: Strong skills in translating technical concepts into simplified guidance.
Why Client Fit Matters for CAS
The Right Clients. The Right Tools. The Right Team.
We’re built for clients who want operational efficiency, regulatory compliance, and sustainable growth. Our work only succeeds when systems, controls, and tools are aligned. We've partnered with independent professionals and solution providers who strengthen our work and seamlessly support our clients.
Meet Our Extended Team:
Michelle Chen | Ramp, Sr. Channel Partner Manager
- Michelle supports a smooth client onboarding process.
- Ramp delivers airtight expense controls, automated documentation, and real‑time visibility.
- Streamline AP & Treasury (Earn 2.5% interest)
- Learn more about Ramp here!
Anjali Etwaru | ADP, District Manager
- Anjali leads payroll and HR solutions for our clients.
- ADP provides payroll processing, automated tax filings, and integrated HR tools.
- Retirement, Workers Compensation, Timekeeping solutions also available.
- Learn more about ADP here!
Jordan Rocca, CPA | Owner of Rocca CPA
- Independent, vetted CPA aligned with our firm approach
- Jordan provides tax planning, advisory, and preparation services.
- Learn more about Rocca CPA here!
Book a Discovery Call:
Contact Us:
Mailing Address: 8500 Normandale Lake Blvd Suite 350, Bloomington, MN 55437
Phone: 612-280-0697
Email: info@hassan.cpa
Working Hours: Monday-Friday, 9-5pm
Our Founder
Ahmed Hassan, CPA
CAS Accounting & Practice Leader
In May 2024, Ahmed set out to build a purpose driven modern firm and has invested over 2,500 hours researching and strategizing how to efficiently serve key industries. Ahmed has over 10 years of experience providing audit, accounting, and advisory services to public and private companies, small businesses, governments, and non-profit organizations. As the practice leader, he is responsible for the oversight of quality, compliance, strategy, and personnel development. He spends his free time caring for his newborn daughter, volunteering on an FQHC board, and catching up on Detroit sports.
Experience:
- Board Member at Riverland Community Health
- Audit & Assurance Manager at Deloitte
- Assurance Associate at EY
- Senior/Staff Accountant at Gregory Terrell & Company, CPAs
Education & Certifications:
- Sustainable Capitalism & ESG, Berkeley Law Executive Education Certificate
- Principles of ESG for Business, Arizona State University Learning Enterprise Certificate
- Grand Valley State University, Bachelors in Accounting & Finance
- Louisiana State University, Online Distance Learning, Non-Profit & Governmental Accounting
- Certified Public Accountant: Licensed in Minnesota & Washington State
Our Co-Founder
Ameera Hassan, MSDA, CHFP
CAS Data & Business Insights
Ameera combines the analytical depth of a chemist with the storytelling prowess of a data analyst. She approaches data problems with relentless curiosity and determination. She skillfully blends Python, SQL, and Tableau to transform complex data into clear, actionable strategies. Her career highlights include analyzing chromatography data for regulatory approvals, designing standardized workflows to ensure compliance, and presenting FTQ metrics that catalyzed operational improvements. She is responsible for delivering data analytics, business insights and visualizations for our clients. Ameera spends her free time caring for her niece and learning new spoken languages.
Experience:
- Co-Founder of Hassan.CPA
- R&D Mechanical Technician II at General Motors
- Analytical Chemist at Avomeen
- Pharmacy Intern at Henry Ford Pharmacy
Education & Certifications:
- Western Governors University, Master's in Data Analytics
- Eastern Michigan University, Bachelor's in Chemistry
- Certified Healthcare Financial Professional, Healthcare Financial Management Association
- Introduction to CAS 2.0 Training, CAS Professional Services, CPA.com
Minnesota Medicaid Payments Score Well in New Federal Audit
Published 1/28/2026 | By: Ahmed Hassan
New federal data from the Centers for Medicare & Medicaid Services (CMS) shows that Minnesota’s Medicaid improper payment rate is far below the national average. CMS found Minnesota at just over 2.1%, compared to 6.1% nationally.
This review looked at whether claims were billed correctly by comparing billing statements with medical records. Importantly, the data reflects the period before Minnesota began rolling out its newest fraud‑prevention steps to prevent mistakes and fraud.
CMS reviewed Minnesota’s Medicaid payments for the period July 1, 2023 – June 30, 2024, as part of the federal PERM program, which checks whether states and providers followed the rules when billing Medicaid. Please note this was not a fraud investigation.
So, what counts as an “Improper Payment”?
CMS considers a payment “improper” when:
- Required documentation is missing
- Provider enrollment steps weren’t completed
- Eligibility information wasn’t fully verified
- A claim was processed incorrectly
Once a payment is labeled improper, CMS takes a second step: they determine whether the service was real and the client was eligible. If both are true but the paperwork was incomplete, the claim becomes a technically improper payment.
Hassan's Insight
This is why strengthening processes and controls matters. With technically improper payments, providers won’t owe money back, but the state will flag you as they must report these under their corrective action plan to the feds. Strong documentation, clean enrollment, and thoroughly reviewed billings protect you from being part of the problem. Want to see how a claim flows into this category?
Source: OMB Circular A-123, Appendix C
What Else CMS Found
- CMS reviewers confirmed that most claims were billed correctly.
- Errors were generally tied to documentation or process, not intentional fraud.
State leaders emphasized that even low error rates require ongoing improvement. Minnesota continues to strengthen internal controls and tighten oversight.
Recent DHS Actions to Strengthen Program Integrity
Since fall 2024, Minnesota has implemented major changes to reduce fraud and prevent improper payments:
- Identified 14 high‑risk services and launched a public program‑integrity webpage
- Conducted audits and on‑site visits for autism service providers
- Discontinued Housing Stabilization Services
- Placed a moratorium on new providers in the 14 high‑risk services
- Implemented licensure requirements for autism centers
- Disenrolled inactive providers
- Began enhanced pre‑payment review for fee‑for‑service claims in high‑risk areas
- Developed plans for provider review and revalidation in those same services
These steps are designed to prevent improper payments before they occur and strengthen Minnesota’s overall Medicaid oversight.
How Providers Should Interpret This
Providers should expect:
- More documentation checks
- Stricter enrollment and revalidation
- Increased pre‑payment review in high‑risk services
- Continued audits and monitoring
Hassan's Insight
An improper payment is a payment with missing or incorrect paperwork. For example, if a service was provided but the progress note was missing, CMS counts that as an improper payment. The CMS review confirms that Minnesota is performing well, but Minnesota’s Medicaid program documentation and process issues still create risk. Providers who operate strong controls, keep their paperwork complete, maintain proper enrollment, and follow billing rules will be well‑positioned for future audits and reviews.
Sources:
Minnesota DHS Releases EVV Requirement Update
Published 1/26/2026 | By: Ameera Hassan
Beginning January 1, 2026, Minnesota Department of Human Services moved to full electronic visit verification (EVV) enforcement to ensure every agency meets federal and state requirements in documentation of services billed to the state. DHS will review provider EVV data against billing compliance standards on a set schedule and issue corrective actions when performance does not meet required levels. Enforcement applies to all providers, including FMS and MCOs. Please note that Hospice Services are exempt and PCA Supervision will no longer require EVV. Live‑in caregivers must enter EVV data once per day, not in real time. The timeline below outlines what DHS will review, what providers must do to remain compliant, and when enforcement actions will occur.
The Minnesota EVV system will verify:
- Type of service performed
- Who received the service
- Date of service
- Location of service delivery
- Who provided the service
- When the service begins and ends
Hassan's Insight
Focusing on the fundamentals is paramount in compliance. EVV is no different and providers that master documentation, enrollment, and clean data can be on cruise control when the 80% enforcement begins in October 2026.
Additional Provider Responsibilities
Monitor compliance for all tax IDs and NPI/UMPI numbers, review reports regularly, correct issues, and check MN-ITS for DHS notices. Providers must ensure third‑party systems connect to HHAX and meet state requirements. DHS does not oversee third-party devices.
Compliance Reports
Monthly reports are issued on the 25th. DHS reviews each report and sends corrective actions when needed. Providers may be required to submit improvement plans or meet with DHS. Enforcement may escalate if issues are not resolved.
Verification Methods
The state-selected EVV system, HHAeXchange (HHAX), offers two verification methods: the mobile application and Interactive Voice Response. Provider agencies using a third-party system may explore other methods to verify EVV that capture the required data. HHAX billing is currently optional, and providers are not required to set up billing through HHAX now. Providers may continue billing through their existing processes if they choose not to use HHAX's billing system.
Hassan's Resource
Keep up with these deadlines and feel free to download the one-pager. Remember to review Minnesota's Department of Human & Health Services (MN DHS) official update page which is linked under sources. Please note this is just a simplified one-pager for quick reference. Always review the authoritative source when evaluating compliance and regulatory requirements. In the case of this EVV update, it'd be MN DHS.
Download One-Pager:
Sources:
Minnesota Department of Human Services
Electronic visit verification
The federal government will soon require some providers to use electronic visit verification systems to document that people are receiving the services that are billed to the state. Providers of personal care, including personal care assistance (PCA) and some waiver services (beginning in 2020) and home health care providers (beginning in 2023) will use electronic visit verification to be eligible for full federal Medicaid matching dollars.
For More Information:
Fraud Accountability and Investigation Status
Published 12/28/2025 | By: Ahmed Hassan
Governor Tim Walz Taking Accountability
- The Governor said he is taking responsibility for fraud that happened in the Medicaid system.
- He promised to fix the problems and prevent fraud going forward.
- The U.S. Attorney is handling criminal cases, but the state was the one that stopped payments first when they saw issues.
- The state got permission to stop payments in June.
- Payments for Housing Stability Grants were stopped in July.
- Cases were then sent to law enforcement.
- More arrests are expected as investigations continue.
How Much Fraud Has Actually Been Found
- Some people claimed there was $9 billion in fraud, but there is no evidence for that number.
- So far, the confirmed fraud is in the tens of millions, not billions.
- Minnesota’s Inspector General asked the federal government to show proof if they believe the number is higher.
- The Medicaid program is $18 billion over 7 years, and most of it already has strong safeguards:
- $6 billion goes through managed care plans
- $10 billion requires Electronic Visit Verification (EVV)
- $11 billion is approved by county case managers
What Happens When Payments Are Suspended
- Providers get a two‑week transition period to protect clients.
- This helps make sure clients still get care, even if payments are paused.
- If DHS finds clear evidence of fraud, payments are stopped immediately.
- The goal is to protect legitimate providers and clients, not punish everyone.
Hassan's Viewpoint
People may think our state was sleep at the wheel, but I've always felt that the media was a bit too obsessed with highlighting Fraud. I've also took notice of many regulatory changes that have occurred since 2023. You see, Fraud is a topic that has been a dark cloud over my head since I moved to Minnesota in July 2023, a time when Feeding Our Future was hot on the news cycle. As a Somali CPA, it was something I couldn't avoid, and it brought shame. This same fraud topic keeps me happy driving a 2016 Volkswagen. The same fraud prompting pressured conversations once folks find out I am a Somali accountant. The awkward vibes while sitting through ethics CPE trainings focused on, you guessed it, fraud. Truth is, 2025 didn't uncover Fraud in Minnesota. The State has been all over it long before I moved here and, in the end, I believe the results will prove that.
Discussing it isn't taboo or complicated for me. I've addressed it throughout my 10-year career serving the education, non-profit, big tech, and governmental industries. During my time at Big 4 as an audit manager, I facilitated a successful SOX Controls and Fraud Training for a corporation with over $2B in revenues. We had 172 attendees, and our team received significant praise from majority of them. Those attendees were not all accountants or financial analysts. They were also regular employees from other functions. Their participation was normal because that is how fraud prevention works. Fraud and its prevention are a shared responsibility.
At the corporate level, fraud is far more intricate than billing for services never delivered. These were complex schemes involving management override and collusion between employees. Auditors in nonprofit, government, and corporate settings are required to understand the entity and its environment, investigate management’s background and qualifications, conduct mandatory fraud audit team discussions, and hold one on one inquiries with senior leadership. We also tested entity level controls such as ethics hotlines, the company's policies, risk assessments, and more. The only way to stop the toughest fraud is a strong control environment and ethical culture from the top down. Fraud prevention was a shared responsibility in corporate.
As independent auditors, these were standard procedures over historical financial reporting and controls that were solely management’s responsibility. And guess who audited our fraud responses? The PCAOB. The many layers we see here where Fraud prevention is the goal indicates everyone shares the responsibility to stop it. So why is shared responsibility everywhere but Medicaid programs?
And when corporate fraud is caught, the person is usually pushed out quietly. No law enforcement. No media shaming. No sensationalism. Why? Because the fact they pulled it off exposes a material weakness in the company’s control environment and organizational culture. Fraud prevention becomes a bigger issue than the fraud itself because understanding how it happened matters most.
Early on I had many questions regarding Minnesota’s Medicaid fraud cases. Aren't there case managers and families involved? Where were the auditors? Who reviewed their work? Why are strong controls not the expectation for taxpayer funded programs? Why does federal law require a Single Audit for grants over $750,000 (now $1 million), yet Medicaid, another form of government funding, operates without the same expectations for significant billings into the millions?
The reality is that in a world full of cybercrime, fake jobs, and widespread scams, this was inevitable. Time to move forward. The Governor and anyone else willing to take accountability now have the chance to restructure Medicaid programs and prevention efforts for not just Minnesota, but all states.
For us at Hassan.CPA, we also take accountability and share this responsibility with Governor Walz. Our goals will be simple; simplify current events and educate on the important matters. Staying focused on fraud prevention lets us stay objective. We can teach. We can build systems. We can help all sides by focusing on prevention. By prioritizing what public companies do.
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