Minnesota’s results in this federal review should prompt a very important question: if the data shows our Medicaid payments were largely supported, why did the media's narrative lean so heavily toward fraud? Why was the $9B figure thrown around when Governor Walz highlighted on his 12/19/25 conference that the actual confirmed number of Fraud was in the millions, not billions (see the linked first entry in our Series titled 'Medicaid Fraud Accountability and Investigation Status as of 12/19/25'). The State's programs were described as "riddled with fraud", "drowning with fraud" and "staggering".

The CMS findings make it clear that most errors were technical due to missing documentation, incomplete enrollment steps, or verification gaps and not intentional wrongdoing. Yet for the past two years, the conversation has often centered on fraud rather than the underlying control weaknesses that actually drive improper payments. When documentation is incomplete or enrollment steps aren’t followed, even legitimate services fall into the “improper payment” category. Still, that doesn’t mean widespread fraud occurred, even at 2.1%.

I can't stop emphasizing that controls are the real issue. The following is an excerpt from the DOJs findings while investigating Housing Stabilization Services: “In July 2020, Minnesota became the first state in the country to offer Medicaid coverage for Housing Stabilization Services. The Housing Stabilization Services Program is a Medical Assistance (that is, Medicaid) benefit designed to help people with disabilities, including seniors and people with mental illnesses and substance use disorders, find and maintain housing. By design, the HSS Program had low barriers to entry and minimal records requirements for reimbursement that combined to make the Program susceptible to fraud.”

It seems clear that we need to start addressing the programs that were built with low barriers to entry and without strong control requirements. Those design choices led to all of this, and a system of trust should no longer be an answer. Unfortunately, significant damage to an entire community has already been done. Even though the $9B figure has yet to be proven with actual numbers or prosecutions.

As an emerging Somali business leader here in Minnesota, I’ve been extremely frustrated with the narratives around fraud in Medicaid programs blaming Governor Walz and the Somali community. People may think our state was sleep at the wheel, but I've always felt that the media here 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 a lot of 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.

I relocated here partly because the Minnesota Somali business community was thriving and inspirational. Minnesota Somalis were entering and leading in many key areas such as entrepreneurship, education, healthcare, and politics. Minneapolis was the hub where Somali conferences and business expos were held, and innovative ideas gained support and funding. Somalis across the world came here to do business and so did I. I saw opportunity here, a place where everyone can thrive along with all the other reasons why Minnesota is the one of the best places to raise a family. That opportunity I saw now feels diminished until a permanent solution is put in place. Taxpayers and the Somali community deserve a solution that is preventative and puts these problems to bed.

I believe by creating another layer by effectively bringing CPA firms to this mix, CPAs can be one of the answers if we leveraged the many attestation services these firms can offer. CPA firms are regulated by the Minnesota State Board of Accountancy, which require firms to maintain quality control, continuing professional education, risk management, confidentiality and independence safeguards, and a duty to protect the public interest. CPA firms may also be required to obtain peer review from an approved body such as AICPA or the MN Society of CPAs. Peer review requirements depend on the services provided.

Last year, I was one of the CPAs at the Capitol who successfully advocated for the CPA Additional Pathways bill, which Governor Walz signed into law this past May. That legislation removed a major barrier that has long limited diversity in the accounting profession. For decades, becoming a CPA required 150-credits (a five‑year college commitment), tens of thousands in student loans, and passage of one of the most difficult licensing exams in the world all while state boards enforced ongoing CPE requirements to maintain competency. The financial barrier of needing 150 college credits, essentially a master’s degree, disproportionately impacted poor students and minority communities. When communities lack access to culturally competent CPAs, the risks of fraud, waste, and abuse naturally increase. ESG professionals would immediately recognize these systemic inequities as key drivers that contributed to the very crisis we are now facing.

Discussing Fraud 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 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? Who were the accountants serving the supposed fraudsters? 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? Single Audits require strong controls over financial and cash management. They wouldn’t eliminate fraud entirely, but they would dramatically reduce it, and they would finally bring Medicaid programs up to the same accountability standards expected as grants. That's common sense though, and common sense isn't common. The reality is that in a world full of cybercrime, fake jobs, and widespread scams, this was inevitable.