Attorney General Keith Ellison's office just sued a tree. One dead nonprofit, one founder, one stack of contracts the office says were backdated. The forest is a Minnesota rule that made the nonprofit necessary in the first place, and the complaint mentions it twice, as background, and never asks why it's there.
The nonprofit is Refocus Recovery. It billed Medicaid for peer recovery support, the one-on-one help a trained person in recovery gives someone trying to stay sober. The office filed State of Minnesota v. Refocus Recovery and Daniel Larson on October 1 in Hennepin County, No. 27-CV-26-16966. It's a civil suit. The complaint asks the court to dissolve Refocus and to order restitution, disgorgement and civil penalties. Everything it says is an allegation, and nothing has been proven. The founder has denied intentional wrongdoing before. KARE 11 reports that in a court filing last year he called the investigations into Kyros "politically motivated" and said, to his knowledge, they had found "no evidence of intentional wrongdoing."
One plain disclosure before the facts. I ran against Ellison in the August primary and lost. Weigh what follows with that in mind. Everything below comes from documents you can open yourself, and they're listed at the bottom.
The tree
Here's the setup the complaint describes. A nonprofit holds the right to bill Medicaid. A for-profit company owned by the nonprofit's founder does nearly all the work. The nonprofit sends the money across.
The numbers come from Refocus's own tax return. In 2022, the complaint says, Refocus paid $2,137,982 to Kyros Services, LLC and $2,397,155 to Kyros Staffing, LLC, and those payments "constituted over 85% of Refocus' $5,305,437 in total expenses, and over 96% of its reported revenue for 2022."
Why a nonprofit at all? The complaint answers in its paragraph 13: "In Minnesota, an RCO must be an 'independent, nonprofit organization led and governed by representatives of local communities of recovery.' As a for-profit, Kyros could not bill Medicaid directly for its services." RCO stands for recovery community organization. The founder, by the complaint's account, said it out loud to his investors. Refocus was a "legal entity that we need covered for regulatory purposes . . . [and] are using strictly for licensing purposes." The complaint says he told them that cutting out a twenty percent fee paid to bill under a licensed facility, plus twenty-one days of payment processing, would work "wonders for [Kyros'] cash flow and scalability."
So the rule said nonprofit, and he built one. The office sued the nonprofit.
The forest, in Kaiser's own words
Now look at the biggest version of that structure in the country.
Kaiser Permanente describes itself as "one of the nation's largest not-for-profit health plans, serving 12.9 million members." It says the care comes from somewhere else: "The Permanente Medical Groups, which provide care for Kaiser Permanente members". The medical groups say the same thing from their side. They're "practicing exclusively within Kaiser Permanente", and "self-governed, physician-led". Their own page breaks the system into three lines. "Permanente Medical Groups provide the health care". "Kaiser Foundation Health Plan provides the coverage". "Kaiser Foundation Hospitals provide the medical facilities".
A nonprofit holds the plan and the members. Separate medical groups, run by the doctors who deliver the care, do the work. The nonprofit sends the money across. That's the structure.
And Kaiser's own tax return shows the scale. On its 2024 Form 990, Kaiser Foundation Health Plan, Inc. reported $82,490,440,881 in total revenue. It listed The Permanente Medical Group as an independent contractor for medical services and reported paying it $16,218,406,066. It reported paying the Southern California Permanente Medical Group another $13,073,106,607. Those two groups alone took about 35.5 percent of the plan's revenue.
Put that next to Refocus. Kaiser's 2024 payment to one medical group was about 3,576 times Refocus's 2022 payments to Kyros. Kaiser's 2024 revenue was about 17,508 times Refocus's 2022 revenue of $4,711,454. Different years, different programs, same shape. And nobody's suing Kaiser, because there's nothing wrong with the shape.
If the structure were the scandal, Kaiser would be the biggest one in America. It isn't.
What actually separates them
Here's Ellison's own framing, from KARE 11's October 1 report. "It was a sham designed to funnel money to an individual," he said. "It was simply Daniel Larson's alter-ego," he added. Sham and alter-ego are claims about this nonprofit. Neither one is a claim about the structure.
So what made Refocus different? Read the complaint and three things jump out, all in the office's own words.
Nobody sat across the table. The complaint says the founder "owned 100% of Kyros PBC when Refocus Recovery was incorporated", and that "Refocus Recovery did not maintain any bank accounts separate from Kyros." Kyros was supposed to be paid its "actual costs of providing the Administrative Services + five and one-quarter percent (5.25%) administrative fee", out of an account swept to one Kyros controlled. Kaiser's 2024 return, by contrast, lists exactly one interested-person business transaction on Schedule L, an officer's family member's pay of $128,848. The Permanente groups aren't on it.
The nonprofit had no purpose of its own. That's the "strictly for licensing purposes" line. The complaint also says no board was formally appointed until 18 months after Refocus was founded, that "No board meetings were held", and that its first board meeting came on November 17, 2022.
The paper came afterward. The complaint says the Kyros contracts "were executed on March 23, 2023, and backdated to May 25, 2021", and that the two Kyros LLCs "were both incorporated in February 2023." It quotes a Kyros representative steering the valuation firm: "[W]e should have the engagement letter solely in the name of Refocus Recovery . . . . That way, it can be an 'independent' valuation Refocus can rely upon in making its determination that the fees are FMV."
Minnesota law already covers that bad version. Minn. Stat. § 317A.255, subd. 1, lets a nonprofit sign a contract with a company its director has a financial stake in, but only on conditions. One is that the deal "was, and the person asserting the validity of the contract or transaction has the burden of establishing that the contract or transaction was, fair and reasonable as to the corporation when it was authorized, approved, or ratified". Another is that "the material facts as to the contract or transaction and as to the director's interest are fully disclosed or known to the board", and the board approves it "in good faith", with the rule that "the interested director or directors may not vote and are not considered present for purposes of a quorum."
Fair price, or full disclosure and a clean vote. That's the whole test.
Has anybody read the 990?
Here's what bugs me. The complaint knows about Refocus's 2022 Form 990. It cites it twice, for the $4.7 million in revenue and for the Kyros payments. It takes the numbers. It leaves the rest.
The rest is Schedule L, the part of the return where a nonprofit reports business with insiders. Refocus filed it. Here's what it told the IRS, signed November 15, 2023, in the capital letters the IRS file uses:
"DANIEL LARSON LEFT THE MEETING AND RECUSED HIMSELF FROM VOTING WHEN THE REFOCUS RECOVERY BOARD CONSIDERED AND MOVED TO APPROVE THE MSA AND SSA WITH KYROS CARE PBC."
It reported the relationship, "BOARD MEMBER DANIEL LARSON, OWNS GREATER THAN 35% OF KYROS CARE PBC", and the amount, $4,535,137. And it said of each fee, "THE MANAGEMENT FEE WAS DETERMINED TO BE FAIR MARKET VALUE WHICH WAS VALIDATED BY AN INDEPENDENT THIRD PARTY VALUATION SPECIALIST HIRED BY RR."
Now the complaint, Count I: Refocus "did not require that Larson's interest in the transaction be disclosed, it did not obtain a vote from only the non-interested members of the board, and it was not established that the transaction was fair and reasonable as to the corporation."
Those two documents can't both be the whole story. The complaint does fight the valuation, hard, in paragraphs 31 and 32. It says the payments before 2023 had no approval at all. It never mentions Schedule L, never mentions the recusal statement, and never says the return reported the Kyros payments as a transaction with an insider.
I'm not deciding which document is right. The 990's statement could be false. The board vote it describes could have been a rubber stamp on a deal the founder had already rigged, which is roughly what the complaint alleges. And the silence could be strategy. But § 317A.255 asks about disclosure and who voted, and the statute says "ratified," not just "approved". A 22-page complaint about self-dealing that never engages the filer's own signed disclosure of the self-dealing reads as if the return doesn't exist.
To be fair about where that return was, the office probably didn't have it in its own files. Minnesota makes a registered charity attach "a copy of all tax or information returns, including all schedules and amendments," to its annual report to the Attorney General, under Minn. Stat. § 309.53. The complaint says Refocus tried to register in November 2023 and that the registration was deficient and never fixed. The office's public charity search returns nothing for Refocus by name or by its EIN. So this isn't a document that sat in the office's drawer.
It sat on the IRS's own servers, public, for anyone to download. KARE 11 read it. Its June 5, 2024 story reported that "The tax filing also disclosed that Larson owned 'greater than 35%' of Kyros at the time." On the return, the sentence about owning more than 35 percent sits in the same Schedule L entry as the recusal statement. The recusal is the very next sentence. And the office had the power to demand more. Minn. Stat. § 8.31, subd. 2, says the Attorney General "may obtain discovery from any person regarding any matter, fact or circumstance, not privileged, which is relevant to the subject matter involved in the pending investigation," and that it "may be obtained without commencement of a civil action and without leave of court". The complaint doesn't say when the investigation began. It says only that the founder's access to Refocus's money "was terminated after the AGO initiated its investigation." Sources told KARE 11 the office was investigating by February 2024.
Did anybody ask about the recusal? The complaint doesn't say.
Two years late
Line up the dates. Every one is from the complaint unless I say otherwise.
- May 25, 2021: Refocus is incorporated.
- June 12, 2023: MinnPost runs a feature on Refocus and Kyros that describes the setup in plain view. Kyros, it says, is "a for-profit technology company that works in tandem with Refocus", and the founder explains that Kyros "takes a percentage of what nonprofits bill insurance companies".
- November 15, 2023: Refocus signs the 990 that reports the Kyros deal on Schedule L.
- December 2023: the founder leaves the Refocus board, and the complaint says his access to Refocus's accounts ended when he resigned.
- February 14, 2024: DHS's inspector general tells legislators, "DHS can confirm an ongoing investigation regarding Kyros and Refocus Recovery." KARE 11 reports the same day: "Sources tell KARE 11 the Minnesota Attorney General's office is also investigating."
- May 1, 2024: KARE 11 reports, "The Minnesota Attorney General's Office also has active criminal and civil investigations underway, sources tell KARE 11."
- September 6, 2024: "citing 'a credible allegation of fraud' related to the Kyros' services, DHS stopped payments to Refocus Recovery."
- September 2024: Kyros "abruptly shut down and terminated hundreds of employees without notice", and Refocus "ceased operations."
- October 1, 2026: the office sues, 755 days after DHS stopped the money.
- November 3, 2026: the general election, 33 days after the suit. (Minn. Stat. § 204D.03, subd. 2, sets it on "the first Tuesday after the first Monday in November".)
The complaint itself calls Refocus a nonprofit "which is no longer operating." The conclusion I'll draw is about the target. By the time this suit landed, the tree had been on the ground for two years.
You can't fix a program by suing its corpse.
The rule that built the shell
Here's the part nobody's talking about. The rule the complaint quotes wasn't even in the statute when Refocus was born.
Minnesota's definition of a recovery community organization lives in Minn. Stat. § 254B.01, subd. 8. In the 2020, 2021 and 2022 editions of the statutes, it said "'Recovery community organization' means an independent organization led and governed by representatives of local communities of recovery." No "nonprofit." The vendor rule, then in § 254B.05, subd. 1(d), said "A recovery community organization that meets certification requirements identified by the commissioner is an eligible vendor of peer support services."
So the nonprofit wall in 2021 came from the Department of Human Services, not the Legislature. A DHS presentation to a Senate committee in February 2022 put it in one line: "DHS required RCOs show membership to the Association of Recovery Community Organizations (ARCO) in order to enroll as an eligible vendor for MA." ARCO is a national membership program run by Faces & Voices of Recovery. The first of its "10 Best Practices for Recovery Community Organizations", as Minnesota's established RCOs submitted them to that same committee, reads: "The organization is a non-profit with a current 501c3 status."
Then the Legislature wrote it in and kept tightening it.
- 2023: Laws 2023, chapter 50, article 3, section 5, signed May 24, 2023, inserted ", nonprofit" into the definition. Section 6 added that eligible vendors must "be nonprofit organizations".
- 2024: Laws 2024, chapters 125 and 127, signed May 24, 2024, made it "be nonprofit organizations under section 501(c)(3) of the Internal Revenue Code, be free from conflicting self-interests, and be autonomous in decision-making". That "free from conflicting self-interests" language tracks ARCO's own best-practice text almost word for word. Chapter 254B never defines it.
- 2026: Laws 2026, chapter 95, article 5, section 18, signed May 14, 2026, kept every word of the nonprofit requirement and moved the deadline for every RCO to get certified from June 30, 2027 to June 30, 2026.
Listen to how the 2024 changes were sold. Rep. Luke Frederick, DFL-Mankato, sponsored the bill that made recovery peers employees instead of contractors, now clauses (11) and (12) of the same vendor list. "This legislation came in response to one specific bad actor," he told KARE 11. That's the Legislature writing a tree into statute.
Here's the kicker. The rule doesn't keep profit out of peer recovery. Minn. Stat. § 254B.0501, subd. 1, says "Programs licensed by the commissioner are eligible vendors", and peer recovery support services are one of the treatment services a licensed program provides under § 245G.07. Nothing in that subdivision requires a licensed program to be a nonprofit. That's the licensed facility whose twenty percent fee, by the complaint's account, the founder wanted to cut out. So a for-profit can bill peer recovery through a licensed treatment program. What it can't do is bill as a stand-alone peer-recovery shop. For that one door, Minnesota requires a 501(c)(3).
The rule didn't keep for-profits out. It pushed them behind a wall that nobody was watching. And the wall had an early warning on it. The complaint says ARCO revoked Refocus's membership in 2022 over "concerns around the business practices of Refocus Recovery; undue influence on Refocus Recovery by Kyros, a for-profit entity; and autonomy of Refocus Recovery from Kyros." The complaint says DHS "ultimately determined that Refocus Recovery could continue operating as an RCO despite the lack of ARCO certification".
The certifier flagged it in 2022. Payments stopped in 2024.
Compare how Minnesota handles the same problem where it actually thought about it. In nursing homes, Minn. Stat. § 256R.12, subd. 6, lets a facility count what it pays a related company only "at the cost incurred by the related organization", and says "the related organization's costs must not include an amount for markup or profit." Medicare does the same thing under 42 C.F.R. § 413.17, which explains that when a provider buys from a company its owners control, "in effect the items are obtained from itself." For charter schools, Minn. Stat. § 124E.07, subd. 3(e), says "A contractor providing facilities, goods, or services to a charter school must not serve on the board of directors", and § 124E.14 says a conflicted contract is void: "A violation of this prohibition renders the contract void."
Chapter 254B has none of that. I searched the current text of chapter 254B, the autism-services statute § 256B.0949, the waiver rate-setting statute § 256B.4914, and 2026 Laws chapter 95 for "related party" and "related organization". Zero hits in all four. The same search in § 256R.12 finds "related organization" 12 times.
We built a nonprofit-only door with no lock on it.
What KARE 11 found, and what it took for granted
Credit where it's due. KARE 11 did the digging, and A.J. Lagoe's team stayed on it for more than a year. Its "Recovery Inc." series was a 2025 finalist for the Goldsmith Prize for Investigative Reporting. Its September 19, 2024 story, the one the Attorney General's complaint cites, reported that former clients "believed the Kyros-Refocus partnership billed taxpayers for services they did not receive", documented "taxpayer-funded movie nights and contests to see who could bill Medicaid the most", and heard from former client Nic Costa. "Some of it's just flat-out lies," he said. It laid out what DHS's letter said Refocus had done: "Billed for services not provided", "Submitted claims not entitled to reimbursement", "Failed to provide supervision as required". KARE's June 5, 2024 story found state records showing Refocus was reimbursed "more than $14 million – more than all other peer support nonprofits in Minnesota combined" between January 2022 and October 2023.
That's the real fraud question. Billing for services nobody got is theft from a public program. It's DHS's lane and the fraud investigators' lane, and that includes the Attorney General's own Medicaid Fraud Control Unit. KARE dragged it into the light.
KARE named the rule, too. More than once. June 5, 2024: "Under the law, the for-profit Kyros cannot bill Medicaid directly for peer services. But the nonprofit Refocus Recovery can." September 19, 2024: "Under state law, non-profits are the only ones allowed to bill Medicaid for certain addiction recovery services. So, Refocus Recovery submitted the bills but paid Kyros to provide services." October 1, 2026: "Under Minnesota law, organizations billing Medicaid for those services must be independent nonprofits led and governed by representatives of the recovery community."
Every time, it's a fact of life. Never the problem.
The structure got the scary words instead. The September story said the nonprofit "had been used to funnel millions of tax dollars into his for-profit company." The June story ran a section headed "Red flags" and quoted Doug Kelley, the former head of the U.S. Attorney's white-collar crime section in Minnesota. "If it turns out that the nonprofit is a mere shell corporation to get the money into a for-profit, that's a huge red flag," Kelley said. His "if" is the right word. A nonprofit paying the company that does the work isn't a red flag. Kaiser does it to the tune of $16 billion a year with one medical group. A nonprofit with no working board, no bank account of its own and one man on both sides of the payment is the red flag, and that's what the complaint alleges.
Then look at what the Legislature did with KARE's reporting. KARE's June 2024 story says Rep. Heather Edelson, DFL-Edina, helped draft the law that "banned nonprofits with conflicting self-interests", and quotes her. "It was very clear to us in Minnesota that that was happening," she said. KARE also reports Kyros hired lobbyists to try to kill the reforms. They lost. Good. But the fix was a phrase, "free from conflicting self-interests," that chapter 254B never defines, bolted onto a rule that still makes a for-profit build a nonprofit to get in the door.
The Legislature fixed the tree and kept the forest.
The other side's best case
The office has a real case, and you should hear it straight.
Suing is its job. Minn. Stat. § 8.31, subd. 1, says "The attorney general shall investigate violations of the law of this state respecting unfair, discriminatory, and other unlawful practices in business, commerce, or trade, and specifically, but not exclusively, the Nonprofit Corporation Act". The complaint alleges backdated contracts, a valuation written to order, a board kept in the dark, and one man holding the only key to the bank account. If that's true, it's a textbook breach.
A dead nonprofit still has loose ends. The complaint says the suit is needed to "ensure its remaining assets are appropriately distributed for actual charitable purposes". Somebody has to close the books.
People got hurt. Hundreds of workers lost their jobs when Kyros shut down. The Attorney General put it this way in the office's release: "People in recovery should be supported, not abruptly left without support, which is exactly what happened when Kyros shut down amid allegations of fraud." He's right about that.
And the Charities Division can only do what it can do. The office's release says, "The Charities Division does not enforce criminal laws." The office as a whole isn't civil-only, though. On September 29 it announced that its Medicaid Fraud Control Unit "has criminally charged nine separate individuals" in other Medicaid cases. Sources told KARE 11 in May 2024 that the office had criminal and civil investigations underway into Kyros and Refocus. The only public result I could find is this civil complaint, and it names no criminal charge. Neither does the office's own list of press releases. The Charities Division doesn't write Medicaid vendor rules either. That's the Legislature and DHS. I'll give the Charities Division this much: it sued with the tools it has.
But the job description is bigger than the lawsuit. An Attorney General who sees the same pattern twice is the person best placed to tell the Legislature why it keeps happening. A suit that ends with a dissolved nonprofit and a judgment against one founder leaves the rule exactly where it was. The next founder reads the same statute.
Fine. Sue. Then tell the Legislature why.
A pattern I keep running into
This isn't the first time I've watched the state chase the case and leave the rule. Yesterday I wrote that the statement of economic interest Minnesota's constitutional officers file never asks about travel by name (Who paid for the trip). Back in June I wrote that of Feeding Our Future's $250 million, prosecutors had recovered a bit more than $50 million as of late 2024, and that prevention returns multiples while recovery returns cents (What fraud costs Minnesota).
Same lesson each time. Fix the rule, or pay again.
What we can do
Open the door, and put a lock on it. Let any qualified organization, nonprofit or not, enroll as a vendor of peer recovery support services on the same standards an RCO meets today: people in recovery delivering the service, training, supervision and certification. A for-profit can already bill peer recovery through a licensed program under § 254B.0501, subd. 1. Make the stand-alone door honest instead of requiring a nonprofit costume. If Kyros could have billed in its own name, Kyros itself would have been the enrolled provider. Federal rules already make the state collect, when a provider applies, "The name and address of any person (individual or corporation) with an ownership or control interest" in it (42 C.F.R. § 455.104(b)(1)(i)). The owner would have been on file as the owner from day one, not as one director of a nonprofit that hired his company.
Make related-party payments a filing, not a favor. Today, federal rules make a Medicaid provider disclose the owners of its big subcontractors only "within 35 days of the date on a request" (42 C.F.R. § 455.105(b)). Minnesota can require it every year for every peer-recovery vendor, and cap related-party payments at cost using the sentence it already wrote for nursing homes in § 256R.12, subd. 6: no "markup or profit."
If the Legislature keeps the nonprofit rule, give it teeth. Copy the charter-school rules into chapter 254B. A contractor doesn't sit on the board (§ 124E.07, subd. 3(e)). A conflicted contract is void (§ 124E.14). And when a certifier pulls an RCO's membership, payments pause until DHS reviews it. Refocus lost its ARCO membership in 2022, and DHS didn't stop its payments until September 2024. That gap is a sentence long to close.
When the office sues a captive nonprofit, name the rule that built it. The Charities Division doesn't need new power for this. Every complaint like this one should come with a short note to the Legislature: here's the eligibility rule that made the shell necessary, and here's the fix. The Refocus complaint already quotes the rule in paragraph 13. One more page would get it to the people who can change it.
The founder's alleged conduct is a tree. The rule is the forest. The tree's already down. Fix the forest.
First the facts. Then the fix.
Sources
The complaint is State of Minnesota v. Refocus Recovery and Daniel Larson, Hennepin County District Court No. 27-CV-26-16966, filed October 1, 2026 at 1:11 p.m. (a 22-page complaint behind a two-page summons), downloaded from the Attorney General's site at ag.state.mn.us/Office/Communications/2026/docs/16966_Refocus-Recovery_Complaint.pdf and read in full. Every quotation and fact attributed to the complaint, including the 2022 payment figures, the founder's statements to investors, the valuation email, the backdating, the bank-account and board allegations, ARCO's 2022 revocation, DHS's September 6, 2024 payment stop, Kyros's shutdown and Refocus's closure, comes from that document and is an allegation, not a finding. The complaint names no criminal charge against Refocus, Kyros or Daniel Larson. The office's press release of October 1, 2026, at ag.state.mn.us/Office/Communications/2026/10/01_Refocus-Recovery.asp, calls it a "civil lawsuit," says it was "filed in Ramsey County," and is the source of the Attorney General's quoted statement and the sentence about the Charities Division. The caption and the court's e-filing stamp say Hennepin County, so this piece says Hennepin.
Refocus Recovery's 2022 Form 990 (EIN 87-0955028, tax year 2022, signed November 15, 2023) was read as the IRS's own electronic-filing record, object 202333199349323003, downloaded from the IRS's public e-file archive at apps.irs.gov/pub/epostcard/990/xml/. The Schedule L text, the $4,535,137 amount, the $4,711,454 total revenue and the Kyros contractor listings are quoted from that file. Kaiser Foundation Health Plan, Inc.'s 2024 Form 990 (EIN 94-1340523, tax year 2024, e-file record timestamped November 17, 2025) was read the same way, object 202503219349309715. The revenue figure, the two Permanente Medical Group payments and the single Schedule L row are from Part I, Part VII-B and Schedule L of that file. The ratios (about 3,576 and about 17,508) and the 35.5 percent share are my arithmetic on those filed numbers. Kaiser Foundation Health Plan files one return among several Kaiser entities, and its five-highest-contractor list does not cover the Permanente groups paid by other Kaiser plans, so the 35.5 percent describes two groups on one return, not the whole system.
Kaiser Permanente's description of itself is from its Fast Facts page, about.kaiserpermanente.org/who-we-are/fast-facts, fetched October 9, 2026. The medical groups' descriptions are from permanente.org/our-medical-groups/ and permanente.org/about/, fetched October 9, 2026. I looked for a statement in the groups' own words about who owns them and found "self-governed, physician-led", so that's the phrase this piece uses.
The statutory history was read at revisor.mn.gov on October 9, 2026: the current text of chapter 254B and its 2020, 2021, 2022, 2023 and 2024 editions; Laws 2023, chapter 50 (sections 5 and 6 of article 3); Laws 2024, chapters 125 and 127; and Laws 2026, chapter 95 (article 5, section 18, which the Revisor's page lists as amending § 254B.0501, subd. 6). The posted 2025 statutes predate chapter 95, so the 2026 change was read in the session law itself. The DHS slide quoted above is from "Recovery Community Organization: History and Overview", a DHS presentation archived with a Minnesota Senate committee's February 24, 2022 meeting materials, and the ARCO best-practices text is from the addendum to a February 9, 2022 letter to legislators from fourteen Minnesota recovery community organizations, archived with the same committee's February 10, 2022 materials. Both are at the Legislative Reference Library, lrl.mn.gov. Other Minnesota statutes were read in the 2025 edition at revisor.mn.gov on October 9, 2026: §§ 8.31, 124E.07, 124E.14, 204D.03, 245G.07, 254B.0501, 256B.0949, 256B.4914, 256R.12, 309.53 and 317A.255. The federal regulations, 42 C.F.R. §§ 413.17, 455.101, 455.104 and 455.105, were read in the current eCFR at ecfr.gov on October 9, 2026. The "related party" and "related organization" searches were run on those downloaded texts; § 256R.12 uses "related organization" or "related organizations" 12 times (counting its subdivision 6 heading and not counting "nonrelated"), spread across seven paragraphs, counting the subdivision 6 heading, which shows the search finds the phrase when it's there.
The Attorney General's charity search, at ag.state.mn.us/Charity/Search/, was run October 9, 2026 for "Refocus" and for EIN 870955028 and returned no organization either time. The same search for "Minnesota Recovery Connection" returned that charity, so the search was working.
The MinnPost article is "'Disruptive' approach to peer support training sparks curiosity, concern among Minnesota addiction recovery leaders", published June 12, 2023, fetched and read in full October 9, 2026. The Goldsmith Prize description is the 2025 finalist page for "KARE 11 Investigates: Recovery Inc." at goldsmithawards.org, fetched October 9, 2026. KARE 11's reporting was read in full in a browser on October 9, 2026: "KARE 11 Investigates: Comprehensive reforms passed in wake of recovery program scandal", by A.J. Lagoe and Steve Eckert, published June 5, 2024; "KARE 11 Investigates: Addiction recovery company Kyros shuts down amid fraud allegations", by A.J. Lagoe, Steve Eckert and Gary Knox, published September 19, 2024 and updated September 20, 2024, the story the complaint cites in its footnote 2; and "INVESTIGATES: Minnesota AG sues Refocus Recovery, alleges 'sham' nonprofit funneled Medicaid money to for-profit Kyros", by A.J. Lagoe, published October 1, 2026 and updated October 6, 2026. Two more KARE 11 stories were read the same way: "KARE 11 Investigates: State investigating addiction recovery company Kyros", by A.J. Lagoe and Steve Eckert, published February 14, 2024, and "FBI investigating Twin Cities company and nonprofit", by A.J. Lagoe, published May 1, 2024. The Medicaid Fraud Control Unit quotation is from the office's September 29, 2026 release at ag.state.mn.us/Office/Communications/2026/09/29_Medicaid-Fraud.asp, fetched October 9, 2026. Every quotation above attributed to KARE 11, to Ellison's remarks to KARE, to Reps. Frederick and Edelson, to Doug Kelley, to Nic Costa, to DHS's letter, and to the founder's earlier court filing comes from those five stories. KARE 11's story list is from its "Recovery Inc." collection page at kare11.com/recoveryinc.
The race facts are from MPR News's August 11, 2026 report on the primary, as cited in my October 8 piece. The two earlier pieces linked above are on this site and carry their own sources.
What I searched, what I found, and what I could not establish. I could not find a criminal charge against Refocus Recovery, Kyros or Daniel Larson. A web search limited to justice.gov for Kyros and Refocus Recovery returned no Justice Department page, while the same search for Feeding Our Future returned Justice Department releases. The Hennepin County Attorney's site search returned "No results" for Kyros and also for the control searches "Feeding Our Future" and "charged", and a web search limited to that domain returned nothing for target or control, so that search wasn't working and tells you nothing either way. The complaint is the document this piece relies on, and it names no charge. The Attorney General's press-release list for 2023 through 2026 (the yearly script files its news page loads, read October 9, 2026) names Refocus, Kyros or Larson only in the October 1, 2026 civil-suit release. The same list carries the September 29, 2026 Medicaid Fraud Control Unit release, so the search reads it. That list holds titles and summaries, not each release's full text. The office's investigations are reported only through KARE 11's unnamed sources, in its February 14 and May 1, 2024 stories, and this piece attributes them that way. For other coverage of the rule, a web search limited to MPR News and to the Minnesota Reformer returned no story on Kyros or Refocus at all, while the same searches for Feeding Our Future returned stories from each outlet. The same searches limited to the Star Tribune and Sahan Journal returned nothing for the control either, so I can't say what those two outlets have written. Corrections: campaign@madgettformn.com.