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(c) Consider in the contracting process whether firms competing for large contracts could <br /> subcontract with DBEs.For Indian Tribal,State and local Government recipients,this <br /> will include dividing total requirements when economically feasible into smaller tasks <br /> or quantities to permit maximum participation by DBEs in the competitive process. Commented[11:@Keith sanders will this work to resole not <br /> receiving reports at the end of the project...so they report regardless <br /> (d) Encourage contracting with a consortium of DBEs when a contract is too large for one of the activity... J <br /> Of these firms YO handle individually. Commented[2R3]:@Debra Dickson No,it will make no <br /> difference. The instructions on this document are to the recipient,as <br /> you know. The quarterly report that is submitted to us contains both, <br /> (e) Use the services and assistance of the SBA and the Minority Business Development a report from the entity and a report from the prime contractor. <br /> Receiving timely reports are not just a problem at the end of a <br /> Agency of the Department of Commerce. project,it is a problem sometime throughout the course of the <br /> construction. It has always been a low priority to consultants to <br /> stick to this requirement and always will be until you refuse to pay <br /> (f) If the prime contractor awards subcontracts, require the prime contractor to take the them without the report.IT is tedious for the consultants,they have <br /> steps in paragraphs(a)through(e)of this section to get with the contractor and the entity for the information and in <br /> most cases the mayor's are required to sign it which can take some <br /> time.With the addition of all the new SRF projects it isn't going to <br /> MBE/WBE REPORTING,40 CFR,Part 33,Sections 33.502 and 33.503 be any quicker except that our project engineers are collecting them <br /> and they have a closer working relationship with the consultant <br /> The Borrower agrees to complete and submit EPA Form 5700-52A, "MBE/WBE Utilization ;! usually <br /> Under Federal Grants,Cooperative Agreements and Interagency Agreements,"or other designated Commented[as sent <br /> @Debra Dickson and @Keith sanders what <br /> '' if a mass email was sent each quarter as a reminder? <br /> reporting form,beginning with the Federal fiscal year reporting period the recipient receives the }` Commented[4R1]:WE can include this in the section as well <br /> award and continuing each quarter until the project is completed.�Itegardless of the activity,if the about failure to submit reports could delay or suspend your award? <br /> projeis not complete,reports must be submitted to meet the reporting requirement each uarter.! litnis-W`"" =__frgp� "�utitie-vccio�-zoo.zo_e. <br /> ct p p gq !j j Commented[5R1]:@Leah Johannes(AAD)@Debra Dickson <br /> Failure to submit reports timely, could result in non-compliance. According to eCFR title 2, S;. p mail out alread <br /> y y goes out to the projects that are under <br /> subtitle A, chapter II, Part 200, Part D 200.339 remedies for noncompliance" list six (6) constmction on a quarterly basis but that was a good idea. Maybe <br /> circumstances the State can take for noncompliance, the list can be found at check with Matthew to see how he wants to handle it;he is <br /> responsible for it now. <br /> https://www.ecfr.gov/current/titl a-2/subtitle-A/chapter-II/part-200/subpart-D?toc—I.Only <br /> procurements with certified MBE/WBEs are counted toward a reci ient's MBE/WBE 'Y commented[6R17:Yes,but keep in mind at thisjunction,they <br /> P have already been awarded and have begun construction. <br /> accomplishments. Quarterly reports are due by the l 5th of the month following the end of each .,j,' Historically,mgmt.hasn't been concerned about withholding <br /> payments for the delayed response to these DBE reports. It is a low <br /> quarter' priority.In my opinion,the only way to expedite these reports is to <br /> threaten to or actually withhold pay request until it is received. This <br /> Period Due Date is Matthew's responsibility,shouldn't he be in on this conversation or <br /> yall could take it up in your mgmt.meetings maybe? <br /> Jan—Mar Apr 15 Commented[7R1]:@Leah Johannes(AAD)Agree with you <br /> Apr—Jun Jul 15 totally about waming them up front before they are awarded,and <br /> Jul—Sept Oct 15 before construction begins and all throughout the process they <br /> should be warned we will withhold payment if this isn't done. <br /> Oct—Dec Jan 15 Hopefully you can convince mgmt.it is an important enough thing <br /> to withhold payment if not received. Good thinking! <br /> SAM and I,lE1 Requirements Commented[8R1]:@Keith Sanders @Leah Johannes(AAD) <br /> did you want to change any additional language in this section? <br /> System for Award Management and Universal Identifier Requirements. Commented 19R1]:@Debra Dickson unless you want to pat in <br /> the CFR number,about failure to submit timely report could <br /> interrupt the payments.If not than I an fine with the way,it is <br /> A. Requirement for System for Award Management (SAM) unless exempted from this w itte1 <br /> requirement under 2 CFR 25.110,the Borrower must maintain current information in Commented[10R1]:@Debra Dickson @Leah Johannes(AAD) <br /> I agree with Leah. The entities/consultants(mainly)just need <br /> the SAM. This includes information on the Borrower's immediate and highest-level reminded early and oxen of their obligations regarding this reporting <br /> owner and subsidiaries, as well as on all the Borrower's predecessors that have been requirement.It takes repetitive training of the consultants and we <br /> awarded a federal contract or federal financial assistance within the last three years,If have lot new and younge uof <br /> p rconsultants not in the habit <br /> i submitting <br /> these.these. Our engineers are going to have to step up and <br /> applicable,until the submittal of the final financial report required under this award or start demanding these quarterly reporting forms, <br /> receipt of the final payment,whichever is later.This requires that the Borrower reviews Commented[11R1]:@Debra Dickson and @Dewania <br /> Coleman-Jones I have added the information about failure stay in <br /> compliance.I just need Debby to proof it and make any changes <br /> needed. <br /> D-3 <br />