The thing which is beyond intellectually serious dispute is industrial-scaled fraud.
You keep wanting to make me "own" the CCAP's estimate. I will not reciprocally try to make you "own" $5 million, because I am charitable and because history has been unkind to the officials who made it.
I do ask you to own: "Minnesota HAS NOT suffered industrial-scale fraud across several social programs." Otherwise this is judging a high school debate competition, and I've had better.
The way I phrased that point was "The investigators allege repeatedly visiting daycare centers which did not, factually, have children physically present at the facility despite reimbursement paperwork identifying specific children being present at that specific time. The investigators demonstrated these lies on timestamped video, and perhaps in another life would have been YouTube stars."
<LLC voice>
We have reviewed your feedback on our editorial choices, and are comfortable that we have characterized the claims in the report accurately. We stand by "Minnesota has suffered a decade-long campaign of industrial-scale fraud against several social programs. This is beyond intellectually serious dispute." This is editorial analysis, informed—as is stated in the plain text—by the experience of several programs. Feeding our Future, for example, is cited in the piece, with analysis. It has resulted in dozens of convictions and guilty pleas, and federal prosecutors characterize it as having defrauded the public of nine figures.
You are welcome to your own opinion as to what could motivate a publication which routinely writes about fraud and finance to write about fraud and finance. Past issues you may enjoy include a year-long investigation into a single incident of fraud in NYC, a topological look at the fraud supply chain in credit cards, discussions of how the FTX fraud was uniquely enabled by their partner bank failing to properly configure their AML engine, and similar.
</LLC voice>
FoF claimed to supply meals at the same physical locations as CCAP and paid the same owners. As mentioned, one of nine of the operators profiled, who was previously raided in an investigation into alleged overbilling of CCAP, received $1.5M from FoF. FoF is in fact not a federal nutrition program but actually the name of a non-profit which received grants from a federal nutrition program for forwarding to third parties. CCAP is also funded by federal block funding.
The Swanson memo memorializes the consensus of his investigatory group and, put to question by OLA and legislators, they stick with that story:
Page 14 of PDF:
[The OLA] did not find evidence to substantiate Stillman’s allegation that there is $100 million in CCAP fraud annually. We did, on the other hand, find that the state’s CCAP fraud
investigators generally agree with Stillman’s opinions about the level of CCAP fraud, as well as why it is so pervasive.
(Stillman is a line level investigator who gave a media statement which was explosive. Swanson, who authored in the internal memo, was his manager.)
I do mention that other officials only agreed to characterize as fraud fraud which had resulted in convictions. We now, years later, have nine figures just from the convictions (and guilty pleas). These officials pointedly refuse to put any number on fraud other than the number incident to convictions.
Moreover: you should be very clearly correct if you accuse someone of citing a document as making claims it does not say. That is a serious accusation. BAM's citation of this piece is "the state’s own investigators believed that, over the past several years, greater than fifty percent of all reimbursements to daycare centers were fraudulent." This is _absolutely true_ and _is in the report as claimed_.
It will be a large part [0] of the portfolios of "wealth management products" [1], which will take large hits, which will then see redemptions from retail because these products are sold as being functionally riskless, which will then need to liquidate their other assets, which will per force fall in price, which will...
[0] Evergrande is the largest real estate developer and largest user of this type of financing in China, and is reasonably mid tens of percent or higher of some wealth management portfolios.
[1] These are investment products which aren't generally sold as such; they're effectively shadow banking. Most users do not understand that they actually are running material capital risk in return for their e.g. 8% annually.
I spend a lot more yen than you do rupees, have USD denominated reporting and payment obligations, and have asked my professional representatives about this. I was told a variant of "De minimis non curat lex." ("The law does not concern itself with trifles.")
This is similar to income-shaped small transfers of money within families; there would be Congressional hearings if the IRS found a deficiency in mandatory withholding taxes on babysitting money, which is unambiguously earned income of a statutory employee.
164.308(a)(5)(ii)(B): We have policies for guarding against,
detecting, and reporting malicious software. Specifically, we require our workforce to use Macs or Linux machines, and we exclusively host our applications on Linux machines, as industry consensus is that these machines are less vulnerable to infection by viruses than Windows machines. We will revisit this policy annually and revise if we determine that the risk of infection of a Mac or Linux machine is greater than Very Low. Our present assessment is Very Low. See also $POINTER, where we discuss securing the applications we host. Accordingly, our risk analysis recommends against spending engineering resources on this threat. Note that this subsection is Addressable, not Required, so we believe that this is sufficient for this subsection.
Welcome to HIPAA! You can do almost anything as long as you document the heck out of it.
This is a great example of a HIPAA poser, because that system: still a violation if one treats the regulations as actually meaning what they say. The "We have a message for you" disclosed a doctor-patient relationship (protected health information) about an email address (personally identifiable).
It's unlikely they'll receive a complaint/investigation for installing that software.
1) The requirements are theoretically tractable by an SMB but only just.
2) Non-compliance is ridiculously widespread. Ridiculously. This is partly because HIPAA prohibits people from doing things they really want to do (emailing about a patient, perhaps to that patient) and partially because the requirements are so vague.
3) Be prepared to use HIPAA as a pricing segmentation engine and for your providers to use it on you. Getting a BAA with Rackspace, for example, quintupled our costs.
4) Get insured. Because literally everyone is exposed to this and investigations are infrequent, the industry treats them like acts of God. You can insure, minimally, the cost of responding to an investigation (though my policy doesn't cover any fines assessed) and breach notification.
One is welcome to use staff that cost $20k per month (e.g. DevOps engineers who understand those four technologies well enough to use them in production) to shave ~50% off one's AWS bill, but one needs minimally two to three of them, so your friendly neighborhood insurance company should probably pay their $15k or whatever a month without blinking.
revenue from servicing the startup economy will dry up
One of the salient differences between the 90s tech bubble and our current state of affairs is that in the 90s Yahoo sold to startups justifying a higher valuation for Yahoo justifying more startups... and this largely doesn't happen now.
I haven't worked with Github but I have worked with many companies which are "strikingly similar" to Github. Their median customer is a boring business which sells things to people for money. If the entire Bay Area slid into the sea, most software companies wouldn't notice until their pull requests stopped getting accepted.
"We can terminate your account for any reason" is a legal term which should be in every SaaS's (default) terms of service. Your lawyer will be happy to explain why. If you'd like a less formal explanation, consider what happens when you get a phone call at 4 AM in the morning which begins "Hello, is this the owner of $COMPANY? Great. This is Sgt. Stevens with the $CITY police department. I have a lawyer named John Smith in my office here. Mr. Smith alleges that you're assisting in the violation of a temporary restraining order."
Data retention is a separate issue, but I can envision reasons why I'd want to reserve a maximally "We don't owe it to you" clause, as a SaaS operator. (Slack, for example, allows arbitrary file uploads. This is a high risk feature, for a lot of reasons, data security, copyright compliance, and explosive reputational risk being only three of them.)
As a separate matter: if these clauses discomfit you, speak to enterprise sales. For $10,000+ you can negotiate better ones. If you do not wish to pay $10,000+, that's fine, but you don't get custom legal language.
FWIW: I don't work 70 to 80 hours a week. My best estimate would be 35 to 45, with variances depending on what is happening in life.
The more useful numbers for calculating successful implementation of my ideas are 8 and 5. I have 8 years in the game, and get +/- 5% compounding improvements a month. This happens fairly reliably whether I work 20 hour weeks or 90 hour weeks and, after a few years in the salaryman salt mines, I know which I'd rather pick.
You could integrate Java applets into the DOM. Now you have two problems. (Keep in mind that back when this was popular IE 4 was busy kicking the pants off of Netscape Navigator. Fancy programming against IE 4?)
It was the core, defining feature of the most used language in the business world... and everyone with any sense is trying to forget it every happened.
Back on the first version of my site some years ago, I tested blue links versus my design's default (orange, if I recall correctly). Blue won by a mile.
Your mileage may vary. I've also had folks cite usability experts who suggest that changing navigation options is a Very Bad Thing. I do it when folks go to the purchasing page. It is a Very Bad Thing That Pays My Rent And Then Some.
You keep wanting to make me "own" the CCAP's estimate. I will not reciprocally try to make you "own" $5 million, because I am charitable and because history has been unkind to the officials who made it.
I do ask you to own: "Minnesota HAS NOT suffered industrial-scale fraud across several social programs." Otherwise this is judging a high school debate competition, and I've had better.