UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Criminal No. 25-3GC PSD UNITED STATES OF AMERICA, AMENDED INFORMATION Plaintiff, 18 U.S.C. § 1843 v. ASHA FARHAN HASSAN, Defendant. ‘THE UNITED STATES ATTORNEY CHARGES THAT: At times relevant to the Information: A. The Minnesota Early Intensive Development and Behavior Intervention (“EIDBI”) Benefit (Autism Services) 1. Autism spectrum disorder (‘ASD” or “autism") is a neurological and developmental disorder that affects how,people interact with others, communicate, Jean, and behave. 2, Applied Behavior Analysis, sometimes called “ABA therapy,” is a type of one-on-one behavioral therapy designed to help children on the autism spectrum develop social and emotional skills. ABA therapy seeks to improve social skills by rewarding and reinforcing positive behavior while discouraging negative behavior. 3. The Early Intensive Developmental and Behavioral Intervention (EIDBP’) benefit is a publicly funded Minnesota Health Care Program that offers medically necessary services to people under the age of 21 with autism spectrum disorder. The EIDBI benefit is available to Minnesota residents under the age of 21 who are on Medical Assistance, MinnesotaCare, or other qualifying health care rien 9/24/25 TATE W, FOGARTY JUDGMENT ENTD DEPUTY CLERK.‘United States v. Asha Farhan programs and who have been diagnosed with ASD. According to the Minnesota Department of Human Services (“DHS”) website, the purpose of the EIDBI program is “to provide medically necessazy, early and intensive intervention for people with ASD and related conditions.” 4. The EIDBI benefit covers various treatment options for persons diagnosed with ASD and related conditions, including ABA therapy. 5. In order to qualify for the EIDBI benefit, a person must be under 21 years old; be diagnosed with ASD or a related condition; have had a comprehensive multi-disciplinary evaluation (CMDE) that establishes their medical need for EIDBL services; and be enrolled in a qualifying healthcare program, such as Medicaid. 6. ‘The CMDE is used to develop the person's individual treatment plan (ITP). An ITP is a personalized, written plan of care that outlines the goals for the person and sets forth the specific interventions the person will receive based on their individually assessed needs. 7. EIDBI treatment services must be delivered under the supervision of a Qualified Supervising Professional (or “QSP") that is employed by the EIDBI provider. The QSPs supervise and manage all aspects of EIDBI services, treatment, and documentation, including supervising the medical providers that actually provide services. The QSP assumes full professional responsibility for the services provided by each supervisee, including the supervisee’s actions and decisions. B. The Federal Child Nutrition Program and Feeding Our Future 8. The Food and Nutrition Service is an agency of the United States Department of Agriculture (USDA) that administers various federal child nutritionUnited States v. Asha Farhan Hassan programs, including the Summer Food Service Program and Child and Adult Care Food Program (together, the “Federal Child Nutrition Program”). 9. The Minnesota Department of Education (MDE) administers the Federal Child Nutrition Program in Minnesota 10. Meals funded by the Federal Child Nutrition Program are served by “sites.” Bach site participating in the Federal Child Nutrition Program must be sponsored by a sponsoring organization that is authorized to participate in the Federal Child Nutrition Program. Sponsors are required to submit an application to MDE for each site. Sponsors are responsible for monitoring each of their sites and preparing reimbursement claims for their sites. 11. Sponsors submit reimbursement claims to MDE on behalf of sites under their sponsorship. The USDA then provides federal reimbursement funds on a per- meal basis. MDE provides the federal funds to the sponsoring agency, which in turn pays the reimbursements to the sites under its sponsorship. The sponsoring agency retains 10 to 15 percent of the funds as an administrative fee in exchange for sponsoring the sites, submitting reimbursement claims, and dispersing the federal funds 12, Historically, the Federal Child Nutrition Program has generally functioned by providing meals to children involved in educational-based programs or activities, During the Covid-19 pandemic, however, the USDA waived some of the standard requirements for participation in the Federal Child Nutrition Program, Among other things, the USDA allowed for-profit restaurants to participate in the program. The USDA also allowed for off-site food distribution to children outside ofUnited States v. Asha Farhan Hassan educational programs. At the same time, the state government's stay-at-home order and telework policies made it difficult to oversee the program. These changes left the program vulnerable to fraud and abuse. 13, Feeding Our Future was a non-profit organization purportedly in the business of helping community partners participate in the Federal Child Nutrition Program. Aimee Bock was the founder and executive director of Feoding Our Future. 14. Prior to the onset of the Covid-19 pandemic, Feeding Our Future was a small non-profit that sponsored the participation of daycares and after-school programs in the Federal Child Nutrition Program. 15. Beginning in approximately April 2020, Feeding Our Future dramatically increased the number of sites under its sponsorship as well as the amount of Federal Child Nutrition Program funds received by those sites. Feeding Our Future went from receiving and disbursing approximately $3.4 million in federal funds to sites under i sponsorship in 2019 to nearly $200 million in 2021. 16. Bock oversaw a massive scheme to defraud the Federal Child Nutrition Program carried out by sites under the sponsorship of Feeding Our Future. Bock and Feeding Our Future sponsored entities that submitted fraudulent reimbursement claims and fake documentation while purporting to serve hundreds and, in many instances, thousands of children per day. Bock and her company sponsored the opening of nearly 200 Federal Child Nutrition Program sites despite knowing that the sites intended to and did submit fraudulent claims.United States v. Asha Farhan Hassan C. Smart Therapy LLC 17. Defendant ASHA FARHAN HASSAN was the President and CEO of Smart Therapy LLA 18. Smart 'Therapy was registered with the Minnesota Secretary of State in November 2019. 19. Shortly after forming the company, HASSAN enrolled Smart Therapy as a provider agency in the EIDBI program. 20. HASSAN also enrolled Smart Therapy in the Federal Child Nutrition Program under the sponsorship of Feeding Our Future Count 1 (Wire Fraud) 21. From in or about December 2020 through in or about 2025, the defendant, ASHA FARHAN HASSAN, and others known and unknown to the grand jury, did knowingly devise and participate in a scheme and artifice to defraud and to obtain money by means of materially false and fraudulent protenses, representations, and promises, and by concealment of material facts. 22. More specifically, HASSAN used Smart Therapy to defraud two government benefit programs—the Federal Child Nutrition Program and the EIDBI program, 23. From in or about November 2019 through in or about December 2024, HASSAN used Smart Therapy to carry out a scheme to defraud the EIDBI program.United States v. Asha Farhan Hassan 24. Shortly after forming Smart Therapy, HASSAN enrolled the company as a provider agency in the HIDBI program. HASSAN listed herself as the sole owner of Smart Therapy. In reality, other individuals also had ownership stakes in Smart Therapy but were not listed on DHS documents, including because one of the owners previously owned an adult daycare and was excluded by DHS for three years due to her conduct running the adult daycare center. 25. Smart ‘Therapy purported to be providing necessary one-on-one ABA therapy to children with autism. In fact, Smart Therapy employed unqualified individuals as “behavioral technicians.” These behavioral technicians were often 18- or 19-year-old relatives with no formal education beyond high school and no training or certifications related to the treatment of autism. 26. Torun their fraud scheme, HASSAN and her partners needed children who had an autism diagnosis and an individual treatment plan. HASSSAN and her partners approached parents in the Somali community to recruit their children into Smart Therapy. Where a child did not have an autism diagnosis and an individual treatment plan, HASSAN and her partners worked with a QSP to get the recruited children qualified for autism services. There was no child that Smart Therapy was not able to get qualified for autism servis 27. As a vecruitment tactic to drive up enrollment, HASSAN and her partners paid monthly cash kickback payments to the parents of children who enrolled their children to receive EIDBI services through Smart Therapy. These kickback payments ranged from approximately $300 to $1,500 per month, per child.