The operator overlap is real, and the correction that FoF is a non-profit rather than a federal program is fair. I'll take both points.

But look at what's happened across this exchange:

Essay: Industrial-scale CCAP fraud is "beyond intellectually serious dispute." The evidence: the OLA report shows investigators believed 50%+ of reimbursements were fraudulent.

When challenged that the OLA explicitly could not substantiate $100M and proven fraud was $5-6M: you retreat to "my citation that investigators believed this is absolutely true and is in the report as claimed."

When challenged that "investigators believed X" ≠ "X is beyond intellectually serious dispute" — especially when the same report documents the IG saying "I do not trust the allegation," DHS leadership calling $100M "not credible," investigators having "varying levels of certainty" with some having "not enough experience to have an opinion," and the OLA itself saying "we cannot offer a reliable estimate": you pivot to FoF operator overlap.

You still haven't addressed the actual critique. The overlap proves that some fraudsters work across programs. Not disputed, not surprising, and consistent with your essay's point about fraud lifecycles. What it doesn't do is retroactively substantiate Swanson's 50% CCAP figure. His methodology, spelled out in the very email the OLA appended, counted all payments to any center where children were poorly supervised as 100% fraudulent, a standard he himself distinguished from "the kind of proof needed in a criminal or administrative proceeding." FoF fraud was fabricating meal claims for meals never served. CCAP fraud is billing for children not present. Different programs, different billing mechanisms, different oversight bodies (MDE vs. DHS), different proven scales by orders of magnitude. That some of the same people ran both doesn't collapse the distinction.

"CCAP is also funded by federal block funding" seems designed to blur a line that matters. Many programs are federally funded. That doesn't make convictions in one program evidence of the fraud rate in another.

Here's what's frustrating: I think the essay's core argument is genuinely strong, and it doesn't need the overclaim. The OLA report is already damning on its own honest terms: proven fraud of $5-6M in a program with paper sign-in sheets prosecutors called "almost comical," no electronic attendance verification, 60-day billing windows, a certification statement removed from billing forms in 2013, and the investigators themselves saying centers "open faster than they can close the existing ones down." The report makes it clear fraud was likely substantially higher than proven convictions. That's already a devastating indictment of program oversight. Your argument about base rates, weak controls, and Shirley fishing in a troubled pond all follows from that, from the report as it actually reads.

But "likely substantially higher than $5-6M, in a program with terrible controls" is a very different claim than "50%+ fraud, beyond intellectually serious dispute." Your essay presents the latter. The report supports the former. And the gap matters, because the essay is being read right now, today. in a context where the president is calling Somalis "garbage," prosecutors are throwing out $9 billion estimates in press conferences, and five states just had billions in child care funding frozen. Overstating what the evidence supports isn't a minor rhetorical choice in that environment. It's exactly the kind of epistemic failure the essay warns about when it talks about "irresponsible demagogues" filling the vacuum.