Office of Contract Compliance Subcontractor Utilization - October 2024
|
Office of Contract Compliance Subcontractor Utilization - October 2024
Released October 2024 Download the Full Report here Download the Highlights Page here We undertook this audit in response to resolution 22-R-3198, which requested an audit of the extent to which minority-owned and female-owned enterprises were used as subcontractors on city contracts Our recommendations to the director of the Office of Contract Compliance is to work with the chief procurement officer to formalize a communication protocol between Contract Compliance and user agencies on contract execution, ensure key documents are uploaded into SDMS, require primes and subcontractors to upload documentation showing proof of payment within three business days of payment receipt, document approval of changes to the subcontractor plan consistent with city code requirements, update policies to set a minimum number of site visits required, the specific intervals they should be performed, and required documentation of site visits to be uploaded to SDMS, assign staff to manage projects at the master contract level, rather than by task order, work with the SDMS vendor to implement system features to tie task orders to master contracts, require compliance specialists to retroactively link all task orders for active projects to master contracts, work with B2G representatives to identify the appropriate diversity participation reports from SDMS that reflect the office's operations, update policies and procedures to reflect current practices and use of SDMS and develop a schedule to ensure annual reviews occur, require staff to conduct through review of contracts, ensure goals are met with qualified subcontractors, and investigate anomalies, ensure that procedures are developed to indicate steps to be followed when a firm that is contracted and performing work is denied re-certification or certification is revoked, put a structured quality control system in place to ensure that staff are following procedures, and contract management is consistent among compliance specialists. |
|
We found:
- Contract Compliance is responsible for tracking and monitoring EBO goal attainment on eligible contracts; however, the office has not proactively ensured that it has complete information to carry out its responsibilities
- Although SDMS was designed to manage contracts, contract specialists were not using the system as intended, employing workarounds that led to data inaccuracies and make it difficult to track diversity participation goals.
- We also found that Contract Compliance’s FY23 annual report to City Council on diversity participation was inconsistent with the data in SDMS, overreporting minority and female business participation for EBO contracts by a significant amount.