The Lobby That Buys Children

Inside the Shadow Lobbying Network That Shaped Adoption Policy While Operating Beyond Traditional Disclosure Rules

There is a polished version of adoption politics that Congress likes to show the public. In that version, adoption is pure rescue, bipartisan compassion, a family-values success story wrapped in photographs of smiling children, grateful parents, and lawmakers standing beside nonprofit executives who speak the language of hope. It is one of the few issues in Washington that can still pass through partisan walls because almost no elected official wants to be seen as hostile to adoption, skeptical of family formation, or indifferent to children in crisis. The word itself carries moral force. Adoption sounds like the answer after tragedy, the redemption after abandonment, the humane exit from foster care, and the pro-life alternative to abortion. That public image is powerful, and for twenty-five years it has protected a machinery of influence that deserves far more scrutiny than it has received.

Behind the sentiment is an industry. Behind the industry is a lobbying ecosystem. Behind that ecosystem is a political architecture built from trade associations, congressional caucuses, faith-based mobilization networks, nonprofit advocacy groups, high-net-worth family foundations, government contractors, tax credits, federal grants, religious-liberty litigation, and regulatory appointments. This investigation is not an attack on every adoptive parent, every caseworker, every foster family, or every child who found a loving permanent home through adoption. It is an examination of the institutional market that grew around adoption after the Adoption and Safe Families Act of 1997, and of the organizations that learned how to shape federal policy while often appearing not to lobby at all.

The central finding is simple and explosive: the adoption industry did not merely respond to federal child welfare policy. It helped build the political environment that made that policy possible, then embedded itself inside the funding streams, advocacy networks, and regulatory agencies that administer it. Over twenty-five years, the network described in this investigation operated through several interlocking layers: the National Council For Adoption, or NCFA, as the industry trade association; the Congressional Coalition on Adoption ecosystem as the Capitol Hill access point; the Christian Alliance for Orphans and related evangelical organizations as the grassroots mobilization engine; and wealthy donor networks, including DeVos-connected funding streams, as the financial and political accelerant behind major contractors and faith-based policy campaigns.

The result is not traditional lobbying as most Americans imagine it. It is not merely a registered lobbyist walking into a congressional office with a disclosure form and a client list. It is more sophisticated than that. It is shadow lobbying through nonprofit infrastructure. It is congressional access through caucus culture. It is grant-funded advocacy. It is church-status mobilization that can move millions of listeners without ordinary nonprofit disclosure. It is donor-advised funding that obscures the original source of political money. It is trade association leadership moving into federal regulatory positions. It is a child welfare market in which the organizations that benefit from adoption policy help define adoption policy, defend adoption policy, and sometimes administer the federal programs created by adoption policy.

The numbers alone should have triggered national scrutiny. Between 2001 and 2005, NCFA received approximately $20.8 million in federal grants for the Infant Adoption Awareness Training Program, a program the organization had helped advance through federal legislation. During roughly the same period, NCFA reported approximately $1.72 million in lobbying expenditures while receiving the bulk of its revenue from HHS grant money. Bethany Christian Services, one of the largest Christian adoption and child welfare contractors in the country, is tied in the research record to more than $436 million in federal contracts across entities and years, while government contracts made up a dominant share of its operating revenue in key periods. In 2017, a coalition of roughly 150 organizations helped reverse a House tax bill provision that would have eliminated the federal adoption tax credit within five business days, while the campaign’s most powerful mobilization routes operated through nonprofit and faith-based channels that reported little or no traditional lobbying activity. In early 2026, former NCFA President and CEO Ryan Hanlon was appointed Associate Commissioner of the Children’s Bureau, the federal office responsible for major child welfare funding and oversight programs.

Each of those facts can be explained individually by people inside the system as normal public policy work, normal advocacy, normal contracting, normal nonprofit coalition building, or normal personnel movement. The danger is visible only when the pieces are viewed together. The same movement that sells adoption as a moral imperative also lobbies for adoption incentives, defends adoption tax credits, receives federal grants to promote adoption counseling, builds congressional caucus relationships, channels evangelical political energy into legislative fights, protects faith-based adoption providers from nondiscrimination rules, and places industry leadership into the agency environment that regulates child welfare funding. That is not a loose collection of charities. It is an influence machine.

The origin story matters because it reveals the purpose. NCFA was not born as a neutral child welfare research organization or a grassroots coalition of adoptees demanding reform. According to the investigation, it was launched in 1980 with approximately $50,000 in seed money raised from the adoptive parent donor base of the Edna Gladney Home in Fort Worth, Texas, a major adoption agency. Its explicit early mission was to fight the Carter administration’s proposed Model State Adoption Act, which would have opened adoption records and required agencies to act as intermediaries in search efforts. From the beginning, then, NCFA’s project was not simply to promote adoption in the abstract. It was to defend a particular adoption system: agency-centered, records-sealed, politically connected, and resistant to reforms that would shift power toward birth parents, adoptees, or transparency.

William L. Pierce, NCFA’s co-founder and longtime president, became the movement’s legislative strategist. He had Washington experience, understood congressional process, and spent two decades shaping the organization into an adoption policy force. The investigation identifies his role in opposing open records, promoting sealed-record frameworks, fighting state-level transparency efforts, supporting the Uniform Adoption Act’s restrictive provisions, and taking credit for major adoption-related legislative victories. Whether one views Pierce as a defender of adoption stability or as an architect of secrecy depends on where one sits in the adoption triad. But the policy pattern is unmistakable: NCFA’s early influence was organized around maintaining institutional control over adoption records and shaping federal law in ways that protected agency power.

That history should change how readers understand the later fight over ASFA. NCFA did not single-handedly write the Adoption and Safe Families Act, and responsible reporting should not claim that it did. But the organization spent years helping build the ideological and political climate in which ASFA’s adoption-forward incentive structure became possible. ASFA arrived in 1997 as a response to the real problem of children languishing in foster care, but it also created financial incentives for finalized adoptions and pushed states toward faster termination of parental rights under the 15-of-22-month timeline. Adoption became the politically clean answer to foster care drift. What received far less attention was who benefited when adoption became the federal system’s preferred measure of permanency.

The investigation quotes ASFA architect Richard Gelles as saying that the adoption component was a way of “sanitizing the bill” to make it more appealing to a broader group of people. That phrase should haunt the entire debate. Adoption was not merely a child welfare outcome; it was also the moral packaging that made the legislation sellable. Once adoption was placed at the center of the story, critics of family separation, racial disparity, poverty-based removal, or parental due process could be portrayed as defenders of foster care drift. The public was given a choice between children trapped in state custody and children moved quickly to adoptive homes. Missing from that binary were the parents not invited into the policy conversation, the children who would become legal orphans after termination without adoption, and the industry groups positioned to benefit from a system that rewarded adoption volume.

The most brazen episode in this record is the Infant Adoption Awareness Training Program. The program emerged from the Children’s Health Act of 2000 and was designed to train pregnancy counselors at federally funded clinics to present adoption information. On paper, the goal was nondirective counseling. In practice, according to the investigation’s cited Guttmacher Institute analysis, NCFA-associated training reportedly included tactics and techniques aimed at persuading clients to choose adoption, prayer sessions, and an environment that barely tolerated pro-choice perspectives. HHS’s own assessment reportedly found that family planning clinics were already providing nondirective counseling, raising questions about whether the program was necessary at all. Yet Congress kept funding it.

The financial structure is staggering. Between 2001 and 2005, NCFA received approximately $20.8 million in HHS grants tied to the program, including about $6.1 million of an $8.6 million first-round grant, roughly seventy-one percent of the total. During those same years, NCFA reported lobbying expenditures of approximately $400,000 in 2002, $613,703 in 2003, $405,814 in 2004, and $297,611 in 2005. The problem is not simply that an adoption advocacy organization received a federal grant. The problem is that NCFA helped shape the legislative environment for a program, received the majority of the first-round funding to implement it, represented adoption agencies that benefited from adoption promotion, and continued lobbying Congress while heavily funded by the federal government. That is the revolving triangle of influence: write the program, receive the grant, lobby to preserve the policy environment.

This is where the public language of “awareness” becomes suspect. Awareness is a soft word. It suggests neutral information. But adoption counseling exists in a deeply unequal context involving pregnant women, poverty, religious pressure, family crisis, lack of health care, and organizations with financial or ideological stakes in adoption outcomes. If counseling is genuinely nondirective, it must be insulated from adoption industry pressure. If the organization training counselors is an adoption trade association with member agencies that benefit from adoption placement, the conflict is obvious. A system that lets industry advocates train federally connected counselors under the banner of neutrality is not merely flawed. It is designed to blur the line between public service and market development.

The same pattern appears in the Bethany Christian Services and DeVos-linked network. Bethany is not a marginal actor. Founded in Grand Rapids, Michigan, it became one of the largest Christian adoption and child welfare agencies in the United States, operating across dozens of states and internationally. The investigation identifies government contracts as a major share of Bethany’s revenue, including refugee and immigrant services, foster care, and Office of Refugee Resettlement-related work. By 2018, government contracts reportedly constituted approximately sixty-eight percent of Bethany’s operating revenue. In fiscal year 2021, the investigation identifies more than $62 million from refugee and immigrant services and more than $35 million from foster care, with cumulative federal contracts across entities documented at more than $436 million.

That scale matters because government contractors are not merely charities doing good works. They are vendors in a public system. When a child welfare contractor depends heavily on federal funds, its policy preferences matter. Its board relationships matter. Its donor network matters. Its lobbying matters. Its legal positions matter. Its access to officials matters. And when that contractor is embedded in a religious and political network with cabinet-level proximity, the conflict concerns intensify.

The DeVos connection is the kind of story Washington often manages to discuss in fragments without confronting as a system. Brian DeVos, identified in the investigation as a cousin of Dick DeVos, served as Senior Vice President of Child and Family Services at Bethany until May 2018, departing one month before the family separation crisis became national news. Maria DeVos, wife of Doug DeVos, served on Bethany’s board during the crisis. DeVos family foundations are documented in the investigation as having donated at least $853,000 to Bethany across years, while the larger DeVos philanthropic ecosystem also funded organizations such as Focus on the Family and Alliance Defending Freedom. Betsy DeVos, meanwhile, served as U.S. Secretary of Education during the Trump administration.

At the peak of the 2018 family separation crisis, Bethany reportedly held eighty-one children separated from their parents and was paid approximately $200 per child per day under federal arrangements. The investigation emphasizes that no GAO audit, inspector general referral, or dedicated congressional hearing appears to have specifically examined the conflict-of-interest implications of a DeVos-funded organization holding separated children while a DeVos family member sat in the Cabinet and other family-linked figures had recent or board-level Bethany ties. The point is not to claim that every federal payment to Bethany was unlawful or that family connections alone prove misconduct. The point is that the conflict deserved investigation. When a politically connected contractor receives federal child welfare money during a national child-separation crisis, the public should not have to rely on nonprofit disclosures, scattered news reports, and independent investigators to reconstruct the network years later.

The influence operation extends beyond one contractor. The investigation describes a vertically integrated policy supply chain funded or supported by DeVos-aligned networks: Bethany as contractor, Alliance Defending Freedom as legal defender of religious-liberty claims, Focus on the Family as evangelical mobilization engine, and state legislators as the policy delivery mechanism for faith-based exemption laws. Michigan’s 2015 faith-based adoption exemption law, for example, protected agencies that refused placements conflicting with religious beliefs, a policy environment that benefited organizations like Bethany when they sought to exclude LGBTQ prospective parents. Similar provider inclusion bills appeared at the federal and state levels over the following decade.

This is how policy capture works in practice. It does not require one secret meeting where everyone agrees to a conspiracy. It requires aligned organizations operating in complementary lanes. The contractor receives government money. The legal group defends the contractor’s right to discriminate or operate under religious exemptions. The media and ministry network generates moral pressure. The donors fund the ecosystem. The legislators introduce the bills. The caucus gives congressional access. The trade association supplies policy language. The result is a movement that can shape law while each participant insists it is only doing its part.

The 2017 adoption tax credit fight is the cleanest demonstration of the machine’s power. On November 2, 2017, the House version of the Tax Cuts and Jobs Act proposed eliminating the adoption tax credit, which could be worth more than $13,000 per child. Five business days later, on November 9, the House Ways and Means Committee voted 24 to 16 to restore it. In Washington, reversing a tax provision in five days is not normal unless intense pressure has been applied. The coalition that mobilized included roughly 150 organizations, with groups such as NCFA, CAFO, Show Hope, NACAC, adoption attorneys, RESOLVE, Voice for Adoption, and others pushing the issue. Focus on the Family used its radio platform to urge listeners to contact Congress. Evangelical leaders and pro-life organizations framed the credit as essential to adoption and abortion alternatives. Celebrity adoptive parents amplified the message.

The astonishing fact is that the campaign operated with effectively zero traditional lobbying disclosure from some of the most powerful actors involved. Focus on the Family’s church-equivalent status meant no Form 990 and no ordinary nonprofit lobbying disclosure, despite its enormous annual revenue and audience reach. CCAI’s role as a secretariat-like coordinator spread political action across a broad coalition. Many nonprofits can engage in lobbying within limits, but the structure made the campaign difficult to see in ordinary disclosure systems. By the time an enforcement analyst could map the network, the vote had already changed. That is the point. Shadow lobbying works because it moves faster than oversight.

This should matter to taxpayers because the adoption tax credit is not merely a family benefit. It is also a market support. It helps preserve demand for adoption services by offsetting costs for adoptive families. Supporters argue the credit helps children find homes and reduces barriers for families. Critics argue it disproportionately benefits families with enough income and tax liability to use it, while doing little for birth-family preservation, kinship care, poverty prevention, or services that might stop unnecessary child welfare entry in the first place. Either way, the 2017 fight showed that the adoption lobby could rapidly activate religious, pro-life, celebrity, nonprofit, and congressional channels to protect a financial mechanism central to the adoption economy.

The theological layer makes this influence infrastructure even more powerful because it turns policy questions into spiritual obligations. The evangelical adoption movement did not merely encourage families to consider adoption as one good act among many. It developed an “orphan theology” that framed adoption as an earthly mirror of God’s adoption of believers, blending family formation with the Great Commission, pro-life politics, and global orphan crisis narratives. Russell Moore’s 2009 book Adopted for Life helped canonize the framework, while the Southern Baptist Convention’s 2009 resolution urging families to pray about adoption mobilized a massive religious constituency. CAFO’s Orphan Sunday and related programs extended the message through churches across the country.

The problem is not that religious people adopt children. Many do so with extraordinary love and sacrifice. The problem is that theological urgency can be weaponized into political infrastructure that inflates demand, simplifies complex child welfare realities, and treats adoption as the morally superior solution even when family preservation, kinship care, poverty relief, or community-based services may be better for the child. The movement has often cited global orphan figures between 143 million and 210 million, even though UNICEF’s stricter estimate for children who have lost both parents is far lower. Inflated orphan statistics create inflated moral urgency. Inflated urgency creates political pressure. Political pressure sustains markets.

Inside the United States, that urgency dovetails with foster care adoption policy. If adoption is framed as both spiritual rescue and pro-life answer, then policies that slow adoption in order to protect due process, preserve families, or examine racial disparities can be painted as anti-child. That framing protects the industry from scrutiny. A critic who asks whether adoption bonuses distort child welfare decision-making can be accused of opposing adoption. A journalist who asks whether contractors benefit from family separation can be accused of attacking Christian charity. A lawmaker who questions the tax credit can be accused of making adoption harder. The moral shield is almost impenetrable unless readers are willing to separate adoption as a human relationship from adoption as an industry.

The Congressional Coalition on Adoption ecosystem is another crucial layer. The Congressional Coalition on Adoption caucus, founded in 1985, reportedly includes 145 members of Congress, making it one of the largest bipartisan caucuses in Washington. In 2001, the Congressional Coalition on Adoption Institute was created as a nonprofit support arm, institutionalizing access between adoption advocates and congressional offices. Caucuses can serve legitimate educational purposes, but they can also become pipelines through which industry narratives reach lawmakers with minimal adversarial testing. When a caucus is framed around adoption, the invited voices are often adoption agencies, adoptive parents, advocacy nonprofits, and faith-based organizations. Birth parents, adoptees critical of sealed records, families harmed by coercive practices, and communities affected by over-removal are less likely to have comparable access.

This stakeholder imbalance goes back to ASFA itself, where biological parents were not central policy participants, while adoption agencies and foster parent organizations were treated as valuable partners. That is not an accident. It is how policy gets shaped when the people with resources and institutional legitimacy define the problem. If child welfare hearings are populated by adoption providers, foster care contractors, and permanency advocates, then adoption appears as the natural endpoint. If poor parents, family defense lawyers, kinship caregivers, adult adoptees, and youth who aged out after failed permanency are missing, the policy conversation becomes structurally biased.

The lobbying expenditure map shows the limits of traditional disclosure. NCFA’s reported lobbying peaked in the early 2000s during the same period it received major HHS grants. Adoption attorneys reported lobbying on tax credits and adoption law issues. Bethany reported lobbying in certain years tied to ORR contracts and provider inclusion issues. Catholic Charities reported significant lobbying on refugee resettlement and migrant child funding in later years. But the most powerful campaigns may not appear in the disclosed totals because they run through nonprofit coalition letters, church broadcasts, caucus briefings, op-eds, donor networks, and grassroots mobilization. The disclosed money is the visible tip. The influence iceberg is below the waterline.

Focus on the Family is the prime example of the disclosure black hole. With church-equivalent IRS status, enormous revenue, and a massive media audience, it can activate political pressure without the disclosure obligations that would apply to many other nonprofits. Its 2017 adoption tax credit call-to-action was functionally grassroots lobbying: listeners were urged to contact government officials about specific legislation. Yet because of its status, the ordinary IRS lobbying tests and Form 990 transparency mechanisms do not operate in the usual way. This is not a small loophole. It is a political weapon disguised as a religious classification.

The Dave Thomas Foundation for Adoption represents a different form of soft power. Founded by the Wendy’s founder in the early 1990s, the foundation has grown into a major adoption philanthropy with significant revenue and assets. It reports no registered lobbying, yet it funds adoption organizations, supports programs such as Wendy’s Wonderful Kids, appears in congressional testimony, and participates in adoption tax credit coalitions. Its work may place children with families, but it also subsidizes the operational ecosystem of adoption agencies by funding dedicated recruiters. This illustrates another blurred line: philanthropy can be service delivery, market support, policy advocacy, and reputation management all at once.

The child welfare provider inclusion fight reveals the civil rights stakes. Since 2013, federal and state bills have sought to protect faith-based child welfare providers that refuse services or placements based on religious beliefs. Supporters frame these bills as necessary to prevent religious agencies from being forced out of child welfare. Critics argue they allow government-funded discrimination against LGBTQ families, religious minorities, unmarried people, or others disfavored by provider doctrine. The investigation identifies multiple federal attempts and several state laws, with Bethany and allied organizations positioned within the broader debate. The policy question is simple: should an agency receiving taxpayer money to perform public child welfare functions be allowed to deny qualified families based on religious criteria?

The data question is equally important. In 2020, the Trump administration removed sexual orientation data requirements from AFCARS, eliminating federal tracking that could have helped measure outcomes for LGBTQ youth in foster care. LGBTQ youth are estimated by advocates and researchers to be overrepresented in foster care, yet without data, discrimination becomes harder to prove and policy harm becomes easier to deny. If a system refuses to collect the evidence needed to identify unequal treatment, it has not become neutral. It has become blind by design.

The revolving door completes the capture picture. In early 2026, Ryan Hanlon moved from leading NCFA, the adoption industry’s primary trade association, into the role of Associate Commissioner of the Children’s Bureau within ACF. The Children’s Bureau influences and administers federal child welfare policy, grants, and oversight across the states. Hanlon’s appointment may be defended by supporters as bringing subject-matter expertise into government. But expertise and conflict are not opposites. A trade association leader entering the federal office that oversees the policy and grant environment his former sector depends on is a textbook revolving-door concern. It does not require proof of personal misconduct to warrant scrutiny. The problem is structural: the regulated movement gains direct influence inside the regulator.

Hanlon is not an isolated example in the investigation’s account. Former NCFA president Thomas Atwood came from conservative policy institutions and served on a Bethany board while running NCFA. Again, the issue is not whether any individual broke a law. The issue is whether the same professional network circulates among industry advocacy, faith-based contracting, conservative policy organizations, and federal oversight roles until the boundary between public regulator and private beneficiary becomes impossible for outsiders to trust.

This is how regulatory capture often looks in the real world. It is rarely a cartoon villain handing a suitcase of money to a senator. It is a respected nonprofit leader invited to testify. It is a caucus briefing with sympathetic lawmakers. It is a grant award to a group that helped design the program. It is a religious broadcaster mobilizing listeners without lobby disclosure. It is a foundation funding both service delivery and policy advocacy. It is a contractor with family ties to political power. It is a former trade association executive moving into government. Each piece can be defended. Together they create a system where the industry gets repeated access and the affected families get processed.

The most important missing voices are the children and families who do not fit the adoption industry’s preferred narrative. Birth mothers who felt pressured toward adoption. Adoptees who want open records. Parents who lost children through poverty-based child welfare cases. Kinship caregivers who were under-supported while strangers were recruited. LGBTQ youth whose outcomes vanished from federal data. Families separated at the border whose children entered contractor care. Older foster youth who did not want adoption but were counted in permanency metrics. These are the people most affected by adoption policy, yet they are least likely to have permanent caucus access, grant-funded advocacy staff, or church networks capable of reversing federal legislation in five business days.

The industry’s defenders will say adoption saves children. Sometimes it does. They will say many children need permanent homes. That is true. They will say faith-based agencies have served children for decades. Also true. They will say tax credits help families afford adoption. True in some cases. They will say government partnerships are necessary because child welfare systems cannot operate alone. Also true. But none of those truths answer the capture question. A system can include genuine acts of love and still be distorted by money. A contractor can provide needed services and still have conflicts. A faith-based organization can help children and still wield political power without adequate disclosure. Adoption can be good and the adoption lobby can still be dangerous.

The distinction is essential. This investigation is not anti-adoption. It is anti-capture. It asks who writes the rules, who benefits from the rules, who funds the advocacy, who gets invited to Congress, who receives federal grants, who controls the data, who mobilizes voters, who enters the regulatory agency, and who is missing from the room when policy is made. Those are not ideological questions. They are democratic questions.

A serious reform agenda would begin with disclosure. Organizations that coordinate federal legislative campaigns through nonprofit coalitions should be required to report meaningful lobbying activity when they mobilize members or audiences around specific legislation. Church-equivalent entities that engage in repeated legislative calls-to-action should face at least narrow disclosure requirements for political advocacy expenditures. Congressional adoption caucus activity should be transparent, including outside groups involved in briefings, funding, travel, awards, and policy drafting. Federal grants to advocacy organizations should include stricter conflict-of-interest reviews when those organizations also lobby on the same policy area.

Second, federal child welfare contractor conflicts should be audited aggressively. Contractors receiving major federal child welfare, ORR, foster care, or adoption-related funds should disclose board relationships, major donors, family ties to federal officials, related-party transactions, and affiliated legal or advocacy organizations. When a politically connected contractor receives emergency custody of children during a national crisis, an inspector general review should be automatic. The question should not be whether journalists can prove wrongdoing years later. The question should be why the federal government did not proactively test the conflict at the time.

Third, the revolving door between adoption trade associations and federal child welfare regulatory offices should be constrained. At minimum, senior leaders of adoption industry associations should face cooling-off periods before entering positions with authority over grants, accreditation, incentive policy, or regulatory guidance directly affecting their former sector. If government wants their expertise, it can use advisory committees with balanced representation, including birth parents, adoptees, family defense attorneys, youth formerly in care, tribal representatives, disability advocates, LGBTQ youth advocates, and kinship caregivers. Expertise should not mean industry dominance.

Fourth, adoption policy must stop being built around demand-side subsidies while neglecting family preservation. Every dollar spent encouraging adoption should be compared with dollars spent preventing unnecessary removal, supporting kinship care, providing housing stabilization, funding legal defense for parents, and treating mental health or substance use without child removal. If the federal government subsidizes the transfer of children into new families more aggressively than it subsidizes the survival of existing families, then the market will tilt toward transfer. That tilt is not neutral.

Fifth, federal data collection must be restored and expanded, not deleted. LGBTQ youth data should be collected with privacy safeguards. Adoption disruption and dissolution should be tracked. TPR-to-adoption gaps should be reported publicly. Faith-based provider exclusions should be measurable. Birth family outcomes should be studied. Without data, the most vulnerable groups disappear from policy analysis, and disappearance benefits the institutions that prefer not to be measured.

The story of the adoption lobby is not a story of one villainous organization or one corrupt family. It is a story of a political ecosystem that learned how to use moral language, religious infrastructure, nonprofit status, federal grants, and bipartisan sentiment to protect a market. It is a story of how adoption became almost impossible to question because questioning adoption policy was made to sound like questioning children’s need for families. It is a story of how influence can hide behind charity and how charity can become a vehicle for influence.

For twenty-five years, the adoption industry has enjoyed extraordinary access to Congress, federal agencies, and public money. It has shaped the laws that define permanency, defended the subsidies that sustain demand, mobilized religious voters to protect financial benefits, and embedded its leaders in the institutions that regulate child welfare. Meanwhile, the families most likely to be separated, the adoptees most likely to demand transparency, the youth most likely to be harmed by discrimination, and the parents most likely to be judged by poverty have remained politically outgunned.

That is the scandal at the heart of this investigation. Not that adoption exists. Not that some children need new families. Not that religious people care about orphans. The scandal is that an industry built around the transfer of children has been allowed to shape federal policy with too little scrutiny, too little disclosure, too many conflicts, and too much moral immunity.

When an industry can help write programs, receive federal grants, lobby Congress, mobilize churches, protect tax credits, defend discriminatory exemptions, influence data collection, and send its executives into regulatory agencies, the question is not whether the lobby buys children in the crude sense. The question is whether it has bought the political conditions under which children become marketable.

That is the question Congress has avoided for a generation. It is time to ask it in public.

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PRIMARY SOURCES

VERIFIED IRS church-equivalent filing; ProPublica noting no 990 Southern Baptist Convention annual meeting records

NCFA 990 Filings (EIN: 75-1721671): ProPublica: https://projects.propublica.org/nonprofits/organizations/751721671 William Pierce Papers + NCFA Records (PRIMARY LOBBYING DOCS): Univ. of Minnesota Social Welfare History Archives: https://archives.lib.umn.edu/repositories/11/resources/2404

Bethany Christian Services 990s (EIN: 38-1405282): ProPublica: https://projects.propublica.org/nonprofits/organizations/381405282

CAFO 990s (EIN: 26-1492375): ProPublica: https://projects.propublica.org/nonprofits/organizations/261492375

CCAI 990s (EIN: 54-2035617): ProPublica: https://projects.propublica.org/nonprofits/organizations/542035617

Dave Thomas Foundation 990s (EIN: 31-1356151): ProPublica: https://projects.propublica.org/nonprofits/organizations/311356151

HHS TAGGS - Bethany: https://taggs.hhs.gov/Detail/RecipDetail?arg_EntityId=1th9dhd4DXm...

Bethany lobbying profile: OpenSecrets: https://www.opensecrets.org/orgs/bethany-christian-services/summary?id=D000047732

AAAA lobbying: OpenSecrets: https://www.opensecrets.org/federal-lobbying/clients/summary?cycle=1999&id;=D000046851

Guttmacher IAATP Analysis (2004): https://www.guttmacher.org/gpr/2004/08/out-compliance-implementing-infant-adoption-awareness-act

DeVos family donations to Bethany: NPR: https://www.npr.org/2018/08/02/630112697/devos-family-money-is-all-over-the-news-right-now Bethany/DeVos/Zero

Tolerance: Snopes: https://www.snopes.com/news/2018/06/26/bethany-christian-services-family-separation-betsy-devos/

DeVos Foundation profiles: InfluenceWatch: https://www.influencewatch.org/non-profit/richard-and-helen-devos-foundation/ 2017 Adoption Tax Credit fight:

CNBC: https://www.cnbc.com/2017/12/01/how-parents-of-adopted-children-foiled-a-us-republican-tax-proposal.html

CCAI 2017 blog post (primary source): https://ccainstituteblog.org/2017/11/07/update-on-tax-reform-and-the-adoption-tax-credit/

AFCARS LGBT data deletion: Metro Weekly: https://www.metroweekly.com/2020/05/trump-administration-removes-lgbtq-data... Ryan Hanlon appointment: The Imprint: https://imprintnews.org/child-welfare-2/president-trump-has-made-his-pick-for-the-federal-childrens-bureau/270097

Gladney Center full history: Texas State Historical Association; Bastard Nation: https://bastards.org/bb-the-model-state-act-the-ncfa-and-the-uaa/

Evangelical Adoption Crusade investigation: Type Investigations/The Nation: https://www.typeinvestigations.org/investigation/2011/04/26/evangelical-adoption-crusade/

The Child Catchers: Kathryn Joyce, PublicAffairs Books 2013 -- foundational text on evangelical adoption industry

Trouble with the Christian Adoption Movement: New Republic: https://newrepublic.com/article/127311/trouble-christian-adoption-movement

Bethany sexual abuse arrest (2023): WOODTV: https://www.woodtv.com/news/grand-rapids/youth-counselor-charged-with-sexually-assaulting-young-immigrant/

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