He cites the 50% number from Jay Swanson, a CCAP Investigations Unit manager, and then dismisses criticism of the number by saying the criticism requires an unreasonable standard (only criminal convictions).

But if you read the cited source of how Swanson came up with that number he said it wasn't just for over-billing (claiming more kids than the places actually had).

Instead, by his estimation, the employees working are not actually working because 'children are unsupervised, running from room to room while adult “employees” spend hours in hallways chatting with other adults' and so all of the funds to those providers are fraudulent. [1]

I think it's pretty easy to criticize the logic for that 50% fraud rate number without requiring criminal convictions.

[1] https://www.auditor.leg.state.mn.us/sreview/ccap.pdf#page=16