[Harvey] looked it over and told me that based on the information we had provided -- whatever the contract may provide or not provide for -- there was clear evidence of probable offenses of a criminal nature.

I've never been given a satisfactory explanation for why what was seen at the start as criminal activity was not prosecuted.

I think you could say at least in some cases this is just good business judgment. At some point the district may conclude the effort required is not worth the potential of the return.

It would be a lot easier and more sensible if you were dealing with a single program and single funding source and all that. You're not. And so it may be a loophole.

In all cases, I leave it up to them.

It's more important that we're taking actions that will produce either a decision that somebody shouldn't be a provider -- which has happened in a lot of cases -- or a decision that allows that provider to improve their management.