Q&A
Conflicts of interest disclosure system reforms and executive compensation guidance
0:49:29
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146 sec
Commissioner Molly Wasow Park discusses reforms to the conflicts of interest disclosure system for providers and addresses questions about executive compensation guidance. She explains the current processes and ongoing efforts to improve transparency and oversight.
- Changes made and ongoing improvements to conflicts of interest disclosure system
- Use of LexisNexis checks to verify provider disclosures
- Storage of conflict of interest forms in the Passport document vault
- Explanation of how executive compensation is handled through indirect rates in contracts
- Clarification that executive director salaries are not direct line items in DHS contracts
UNKNOWN
0:49:29
Has DHS, reformed this conflicts
Diana I. Ayala
0:49:29
of interest disclosure system, disclosure system, for providers and or developed any guidance around executive compensation?
Molly Wasow Park
0:49:41
So with respect to conflicts of interest, yes.
0:49:44
Absolutely.
0:49:45
There's changes we've made and changes that we are continuing to make.
0:49:48
So, as we are approving specific contracts, we are looking at both provider disclosures.
0:49:57
Right?
0:49:57
So they are required to tell us if there is any of interest related party organizations, but we are also not necessarily taking their word for them.
0:50:05
We're doing LexisNexis, checks so that we can, if somebody is is trying to hide something from us, that we have an opportunity to do that.
0:50:15
The conflict of interest forms are getting stored in the passport, document vault, and then we are working with mocks to roll out policies and procedures around that so it is more trans what we are doing becomes more
UNKNOWN
0:50:27
transparent, both to the vendor community and to our staff.
Molly Wasow Park
0:50:27
So that is is a work in compensation directly.
0:50:38
There is no DHS shelter contract where an executive There is no DHS shelter contract where an executive director salary is a line in the contract.
0:50:48
Instead, the way executive director salaries are paid is through the indirect rate that is included in the contract, right, which is used for, overhead costs including executive salaries.
0:51:00
Indirect rates are set in one of 2 ways.
0:51:03
It's either a de minimis 10% or it is a federally approved level.
0:51:08
Right?
0:51:08
So whatever the relevant federal agency for that organization reviews the documentation, looks at audited financial statements, other other documents, and says this is an appropriate overhead rate.
0:51:21
If an organization has a federally approved overhead rate, we will generally accept that.
0:51:26
Mocks does do do a review as well.
0:51:29
So because we are not directly paying those salaries, right, they are not showing up as a line item in the budget, and furthermore, because most of our providers are doing business not just with DHSDSS, but with many other city agencies, often state agencies, federal agencies, we're not in a position to make unilateral, decisions based on executive compensation.
