Minnesota’s Competitive Grant Procedures Are Not Well. Let me explain using Feeding Our Future as an Exemplar
Minnesota’s competitive grant procedures are supposed to follow clear, statute-driven policies designed to protect public funds before, during, and after they’re awarded. Under Minnesota law and the Office of Grants Management (OGM) policies, all executive branch agencies, including the Department of Education, are required to conduct fair, evidence-based, competitive reviews; assess applicant capacity to perform; document reviewer decisions; avoid conflicts of interest; and monitor performance once funds are disbursed.
By Don Allen, Journal Of A Black Teacher (2025) - Editorial Opinion
St. Paul, MN…Here’s the plain truth: what happened in Minnesota wasn’t a “Somali problem.” It was a systems problem; a leadership problem, created and sustained inside Minnesota’s own state agencies. When billions of public dollars slide out the door with barely a question asked, the issue isn’t the people who noticed the open vault. The issue is the people who left it unlocked.
Patrick Lencioni, in The Advantage, argues that organizational health is the greatest advantage any institution can possess. Healthy organizations communicate clearly, confront uncomfortable truths, and refuse to hide behind bureaucracy. What we witnessed in Minnesota was the opposite: fragmented leadership, siloed communication, automatic approvals, and a culture more interested in process theater than real accountability. That’s how fraud scales. That’s how bad actors, of any background, find gaps, walk through them, and tell their friends.
Here’s a reality-based explanation of what went wrong with Minnesota’s competitive grant process, and why the failure was systemic, not cultural:
Minnesota’s competitive grant procedures are supposed to follow clear, statute-driven policies designed to protect public funds before, during, and after they’re awarded. Under Minnesota law and the Office of Grants Management (OGM) policies, all executive branch agencies, including the Department of Education, are required to conduct fair, evidence-based, competitive reviews; assess applicant capacity to perform; document reviewer decisions; avoid conflicts of interest; and monitor performance once funds are disbursed. These standards apply across the grant lifecycle: pre-award, active grant management, and closeout.
On paper, competitive grants should involve:
- A transparent request for proposals that sets evaluation criteria aligned with statutory purpose.
- Independent reviewers scoring applications based on need, capacity, and project feasibility.
- Conflict-of-interest disclosures and multiple tiers of internal checks to ensure objectivity.
- Verification of grantees’ legal status, financial stability, and ability to deliver services.
- Ongoing monitoring and accountability throughout the grant period.
That’s how the process should work.
What happened instead in Minnesota’s day-care, feeding, and other social services grants was dramatically different.
State grants administered through agencies like the Minnesota Department of Education have relied heavily on self-reported data, minimal verification, and rapid funding flows prioritizing speed over scrutiny. In childcare and early education streams, providers submit enrollment and attendance reports with little upfront validation, and agencies pass reimbursements based almost entirely on that self-reporting. Critics have long warned that emphasizing access without matching verification invites abuse, and the loopholes were exploited at scale.
The Feeding Our Future case, now recognized as one of the largest pandemic-era fraud schemes in the country, is illustrative. Federal prosecutors found that the nonprofit submitted fraudulent meal claims while providing few actual services. State auditors later documented that the Minnesota Department of Education continued issuing funds even after early red flags, including implausible paperwork and revoked nonprofit status. In fact, the agency approved major funding without re-verifying critical compliance requirements simply because legal pressure was applied.
This wasn’t a rogue application slipping through a strong system. It was a system that had no real bumper rails, no robust pre-award vetting, no durable verification of claims, and few consequences when warning signs appeared.
The Office of the Legislative Auditor’s evaluations of state grant oversight beforehand already showed substantial issues: agencies were not consistently following best practices, payments were made in violation of internal policies, and staff lacked the consistent training and tools required to manage grants effectively.
In the absence of rigorous compliance enforcement or even consistent application of the policies that do exist, the competitive grant process became susceptible to manipulation. Instead of making agencies earn the public’s trust through transparent, documented decision-making and ongoing oversight, the system operated with broad discretion and weak accountability.
That’s the root of what went wrong.
Here’s the sober conclusion: Minnesota’s competitive grant framework was supposed to guard against fraud by forcing agencies to act as rigorous gatekeepers. Instead, years of underinvestment in compliance infrastructure, spotty enforcement of existing rules, and a culture that prioritized rapid distribution over verification turned that framework into a sieve.
Fixing this isn’t about stigmatizing any community. It’s about recognizing that when the state abdicates its responsibilities and fails to implement its grant-making policies diligently, fraud isn’t an aberration. It’s the predictable outcome of a process without real disciplines of oversight.
Let’s stop pretending this was about ethnicity or community. The state built a system so loose that nearly anyone could have exploited it. Applications were rubber-stamped. Oversight was performative. Internal controls were weak. People inside agencies either didn’t know what was happening, didn’t want to know, or chose to believe that paperwork equals proof. It didn’t. There were no bumper rails. No meaningful verification. No “show me.” In some cases, there wasn’t so much as a photograph of children eating meals that supposedly justified massive reimbursements. That’s not cultural failure, that’s administrative negligence.
Minnesota’s agencies are supposed to be the adults in the room. They are trusted with taxpayer dollars, responsible for public confidence, and obligated to design systems that anticipate misconduct. Instead, leadership relied on goodwill, assumed honesty, and built oversight structures that collapsed the moment real pressure hit. When you create programs that disperse large sums quickly but without rigor, fraud isn’t a surprise; it’s the logical outcome.
And here’s the uncomfortable part: deflecting attention toward the Somali community is convenient. It avoids asking why senior officials didn’t demand tighter controls. It dodges questions about whether warnings were ignored. It allows leaders to point outward rather than into the mirror. The narrative becomes “look what they did,” instead of “how did we let this happen?”
We need a different conversation, one grounded in responsibility.
Why weren’t stronger checks built in from the beginning?
Why did agencies fail to audit, verify, and question obvious red flags?
Why was speed prioritized over accuracy, and appearance prioritized over truth?
Fraud doesn’t grow in well-run systems. It grows in confusion, silence, and bureaucratic complacency.
Minnesota has to rebuild trust, not by scapegoating, but by rebuilding leadership cultures that speak honestly, argue openly, and enforce expectations consistently. That means rigorous oversight. Relentless transparency. Real communication across departments. Leaders who are willing to say “no,” slow things down, and verify claims before signing checks.
People saw an opportunity and took it. That’s human. The scandal is that the state left the opportunity there, wide open, and then acted shocked when someone stepped through.
If we’re serious about preventing this from happening again, stop blaming communities. Fix the systems. Fix the leadership. Fix the communication failures that made fraud easy.
Anything less is denial, and denial is exactly what got us here.
Official Reports and Audits
Office of the Legislative Auditor. (2024, June 13). Minnesota Department of Education: Oversight of Feeding Our Future(Special Review). State of Minnesota. https://www.auditor.leg.state.mn.us/sreview/2024/mdefof.htm (Legislative Auditor)
General Coverage of Oversight Failures
Derosier, A. (2024, June 14). Minnesota’s inadequate oversight led to $250M meal program fraud. Governing. https://www.governing.com/management-and-administration/minnesotas-inadequate-oversight-led-to-250m-meal-program-fraud (Governing)
Background on the Feeding Our Future Case
Feeding Our Future. (n.d.). In Wikipedia. Retrieved December 29, 2025, from https://en.wikipedia.org/wiki/Feeding_Our_Future (Wikipedia)
News Coverage of the Auditor’s Findings
Associated Press. (2024, June 13). Audit finds Minnesota agency’s lax oversight fostered theft of $250M from federal food aid program. AP News. https://apnews.com/article/7106883911765bb0c3794fe6196fcf9d (AP News)
Leadership/Organizational Context
Lencioni, P. (2012). The Advantage: Why organizational health trumps everything else in business. Jossey-Bass.
Feeding Our Future. (n.d.). In Wikipedia. Retrieved December 29, 2025, from https://en.wikipedia.org/wiki/Feeding_Our_Future (Wikipedia)
Lencioni, P. (2012). The Advantage: Why organizational health trumps everything else in business. Jossey-Bass.
Office of the Legislative Auditor. (2024, June 13). Minnesota Department of Education: Oversight of Feeding Our Future(Special Review). State of Minnesota. https://www.auditor.leg.state.mn.us/sreview/2024/mdefof.htm (Legislative Auditor)
Associated Press. (2024, June 13). Audit finds Minnesota agency’s lax oversight fostered theft of $250M from federal food aid program. AP News. https://apnews.com/article/7106883911765bb0c3794fe6196fcf9d (AP News)
What happened instead in Minnesota’s day-care, feeding, and other social services grants was dramatically different.
State grants administered through agencies like the Minnesota Department of Education have relied heavily on self-reported data, minimal verification, and rapid funding flows prioritizing speed over scrutiny. In childcare and early education streams, providers submit enrollment and attendance reports with little upfront validation, and agencies pass reimbursements based almost entirely on that self-reporting. Critics have long warned that emphasizing access without matching verification invites abuse, and the loopholes were exploited at scale.
The Feeding Our Future case, now recognized as one of the largest pandemic-era fraud schemes in the country, is illustrative. Federal prosecutors found that the nonprofit submitted fraudulent meal claims while providing few actual services. State auditors later documented that the Minnesota Department of Education continued issuing funds even after early red flags, including implausible paperwork and revoked nonprofit status. In fact, the agency approved major funding without re-verifying critical compliance requirements simply because legal pressure was applied.
This wasn’t a rogue application slipping through a strong system. It was a system that had no real bumper rails, no robust pre-award vetting, no durable verification of claims, and few consequences when warning signs appeared.
The Office of the Legislative Auditor’s evaluations of state grant oversight beforehand already showed substantial issues: agencies were not consistently following best practices, payments were made in violation of internal policies, and staff lacked the consistent training and tools required to manage grants effectively.
In the absence of rigorous compliance enforcement or even consistent application of the policies that do exist, the competitive grant process became susceptible to manipulation. Instead of making agencies earn the public’s trust through transparent, documented decision-making and ongoing oversight, the system operated with broad discretion and weak accountability.
That’s the root of what went wrong.
Here’s the sober conclusion: Minnesota’s competitive grant framework was supposed to guard against fraud by forcing agencies to act as rigorous gatekeepers. Instead, years of underinvestment in compliance infrastructure, spotty enforcement of existing rules, and a culture that prioritized rapid distribution over verification turned that framework into a sieve.
Fixing this isn’t about stigmatizing any community. It’s about recognizing that when the state abdicates its responsibilities and fails to implement its grant-making policies diligently, fraud isn’t an aberration. It’s the predictable outcome of a process without real disciplines of oversight.
Let’s stop pretending this was about ethnicity or community. The state built a system so loose that nearly anyone could have exploited it. Applications were rubber-stamped. Oversight was performative. Internal controls were weak. People inside agencies either didn’t know what was happening, didn’t want to know, or chose to believe that paperwork equals proof. It didn’t. There were no bumper rails. No meaningful verification. No “show me.” In some cases, there wasn’t so much as a photograph of children eating meals that supposedly justified massive reimbursements. That’s not cultural failure, that’s administrative negligence.
Minnesota’s agencies are supposed to be the adults in the room. They are trusted with taxpayer dollars, responsible for public confidence, and obligated to design systems that anticipate misconduct. Instead, leadership relied on goodwill, assumed honesty, and built oversight structures that collapsed the moment real pressure hit. When you create programs that disperse large sums quickly but without rigor, fraud isn’t a surprise; it’s the logical outcome.
And here’s the uncomfortable part: deflecting attention toward the Somali community is convenient. It avoids asking why senior officials didn’t demand tighter controls. It dodges questions about whether warnings were ignored. It allows leaders to point outward rather than into the mirror. The narrative becomes “look what they did,” instead of “how did we let this happen?”
We need a different conversation, one grounded in responsibility.
Why weren’t stronger checks built in from the beginning?
Why did agencies fail to audit, verify, and question obvious red flags?
Why was speed prioritized over accuracy, and appearance prioritized over truth?
Fraud doesn’t grow in well-run systems. It grows in confusion, silence, and bureaucratic complacency.
Minnesota has to rebuild trust, not by scapegoating, but by rebuilding leadership cultures that speak honestly, argue openly, and enforce expectations consistently. That means rigorous oversight. Relentless transparency. Real communication across departments. Leaders who are willing to say “no,” slow things down, and verify claims before signing checks.
People saw an opportunity and took it. That’s human. The scandal is that the state left the opportunity there, wide open, and then acted shocked when someone stepped through.
If we’re serious about preventing this from happening again, stop blaming communities. Fix the systems. Fix the leadership. Fix the communication failures that made fraud easy.
Anything less is denial, and denial is exactly what got us here.
Research Used for this editorial
Official Reports and Audits
Office of the Legislative Auditor. (2024, June 13). Minnesota Department of Education: Oversight of Feeding Our Future(Special Review). State of Minnesota. https://www.auditor.leg.state.mn.us/sreview/2024/mdefof.htm (Legislative Auditor)
General Coverage of Oversight Failures
Derosier, A. (2024, June 14). Minnesota’s inadequate oversight led to $250M meal program fraud. Governing. https://www.governing.com/management-and-administration/minnesotas-inadequate-oversight-led-to-250m-meal-program-fraud (Governing)
Background on the Feeding Our Future Case
Feeding Our Future. (n.d.). In Wikipedia. Retrieved December 29, 2025, from https://en.wikipedia.org/wiki/Feeding_Our_Future (Wikipedia)
News Coverage of the Auditor’s Findings
Associated Press. (2024, June 13). Audit finds Minnesota agency’s lax oversight fostered theft of $250M from federal food aid program. AP News. https://apnews.com/article/7106883911765bb0c3794fe6196fcf9d (AP News)
Leadership/Organizational Context
Lencioni, P. (2012). The Advantage: Why organizational health trumps everything else in business. Jossey-Bass.
References
Derosier, A. (2024, June 14). Minnesota’s inadequate oversight led to $250M meal program fraud. Governing. https://www.governing.com/management-and-administration/minnesotas-inadequate-oversight-led-to-250m-meal-program-fraud (Governing)Feeding Our Future. (n.d.). In Wikipedia. Retrieved December 29, 2025, from https://en.wikipedia.org/wiki/Feeding_Our_Future (Wikipedia)
Lencioni, P. (2012). The Advantage: Why organizational health trumps everything else in business. Jossey-Bass.
Office of the Legislative Auditor. (2024, June 13). Minnesota Department of Education: Oversight of Feeding Our Future(Special Review). State of Minnesota. https://www.auditor.leg.state.mn.us/sreview/2024/mdefof.htm (Legislative Auditor)
Associated Press. (2024, June 13). Audit finds Minnesota agency’s lax oversight fostered theft of $250M from federal food aid program. AP News. https://apnews.com/article/7106883911765bb0c3794fe6196fcf9d (AP News)
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