Q&A
DSS efforts to prevent unethical subcontracting practices in shelter system
2:16:45
·
3 min
Commissioner Molly Wasow Park details DSS efforts to prevent unethical subcontracting practices in the shelter system, responding to Council Member Lincoln Restler's concerns.
- Park affirms that the described subcontracting practices are unethical and have been a focus of intense scrutiny.
- She outlines the '65 a review' process, which includes checking for multiple bids, independence of bids, and conflicts of interest.
- Park explains that payments are withheld for subcontracts that don't meet the required standards.
- The discussion touches on the possibility of prohibiting direct financial stakes for leadership and family members in subcontracting entities.
- Park notes that DSS has become more aggressive in reviewing and severing problematic subcontracting relationships in recent years.
Molly Wasow Park
2:16:45
Absolutely.
2:16:46
And I would start by saying, I think the situation that you described goes beyond borderline unethical.
2:16:50
It's just straight up unethical.
Lincoln Restler
2:16:51
Thank you.
Molly Wasow Park
2:16:52
And and we are have been focused very, intensively on that over the last few years.
2:16:58
So we do, have been doing tighter and tighter review of subcontracts.
2:17:03
It's a process that is known as the 65 a review after because we're good bureaucrats and there's a form for everything.
2:17:10
But, where we are really looking at not only starting with how was a subcontract procured.
2:17:17
Right?
2:17:17
Do do the does the provider have 3 bids to go with that subcontract?
2:17:23
And then if they do if they don't have the 3 bids, that's a hard line.
2:17:27
We're not moving forward there.
2:17:28
If they do have the 3 bids, are those bids in fact independent?
2:17:32
Have they gone with the lowest responsible bidder?
2:17:35
And in addition, providers are now required to submit fairly detailed conflicts of interest forms, and then we are also doing, reviews of our own independent review, doing Lexus Nexus searches, as council member 1 indicated, online searches.
2:17:52
Right?
2:17:52
So that we are really identifying if there is a related party interaction with with a sub.
2:17:59
If we find an issue with a sub, even when it is not necessarily something nefarious, but they didn't do you know, they have 2 bids, they don't have 3 bids, we won't make a payment on that.
2:18:09
So we will proceed with the invoice payment, for the rest of the that invoice, but we will hold back on that that particular sub.
Lincoln Restler
2:18:17
Why don't we just prohibit organizations, the senior leadership and board members of the organizations from having a direct financial stake or immediate family members having direct financial stake in the entities that are subcontracting with those nonprofits?
Molly Wasow Park
2:18:30
We we won't do that anymore.
2:18:32
So so there was a there was a time, obviously, as as DOI found where where that was happening.
2:18:39
We will no longer proceed with those if we identify a related party with the with the subs.
2:18:45
We're either going to, you know, sever that relationship between the the vendor and the, the not for profit or we will stop doing business with the organization's fault.
Lincoln Restler
2:18:57
With your own, like, agency latitude, with your own discretion, you separate you choose to separate those contracts.
2:19:04
It's not a law that is in place.
2:19:06
It's a decision
Molly Wasow Park
2:19:07
So this is very much driven you know, MOX is very much involved in this.
2:19:11
I would say we have been quite aggressive on this over the last few years.
2:19:16
And as I I said earlier, you've probably heard complaints from some nonprofits about how long our 65 a review process takes, because it does, but this has been built into the current iteration of passport, which I'm optimistic will make us both more accountable and faster.
2:19:32
I will say, you know, there are some quite terrible relation examples of some of these related party subs and the report calls them out.
2:19:43
I think there's also some examples that are a little murkier.
2:19:46
Right?
2:19:46
A not for profit creates a for profit subsidiary that is a job training program, for example, like, for clients.
2:19:53
That can still be problematic, but, you know, I think not everything starts out as something nefarious.
2:20:00
So but we are, very strict on our our subcontract policy
UNKNOWN
2:20:04
at this
Lincoln Restler
2:20:04
point.
2:20:04
I really appreciate the chance to go a little long.
2:20:06
Pedro, it's nice to see you.
2:20:07
I haven't seen you a long time.
2:20:08
Thank you for the answers, commissioner Park.
2:20:09
As always, appreciate your thoughtfulness and diligence.
Gale A. Brewer
2:20:11
Thank you very much, council member Wong, and then council member Banks.
Julie Won
2:20:15
Thank you so much, chair Brewer.
