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Implementation of DOI recommendations from 2021 report
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Council Member Diana I. Ayala inquires about the implementation of recommendations from a 2021 DOI report on oversight for nonprofit human service contracts. Charles Diamond from MOCS responds, detailing the actions taken in response to the report.
- 2021 DOI report covered human services sector across the board, not just DHS
- Implementation of standard invoice review process (SIRP) in 2021
- Creation of vendor integrity unit at MOCS and vendor compliance cabinet
- Development of new policies on anti-nepotism, conflicts of interest, and related party transactions
Diana I. Ayala
0:44:27
Okay.
0:44:28
In 2021, DOI issued a separate report on oversight for nonprofit human service contracts and included 23 policy recommendations that continue to be relevant for the 2024 report that led to, this hearing.
0:44:40
Can DHS provide updates on its implementation of the relevant recommendations?
Molly Wasow Park
0:44:46
Sure.
0:44:47
So just by way of context, the the 2021 report was really human services sector, across the board.
0:44:54
DHS was, actually a relatively small piece of that one.
0:44:58
So the the recommendations pertained to citywide practices.
0:45:02
So I'm gonna, pass the mic to to Monks.
Charles Diamond
0:45:09
I'm sorry, councilor.
0:45:12
What was the question?
Diana I. Ayala
0:45:13
So the question was, the DOI issued a separate, report on oversight of nonprofit human service contracts and in in 2021, and included 23 policy recommendations that continue to be relevant for the 24 report that led to this hearing.
0:45:27
Can DHS provide updates on its implementation of the relevant recommendations?
Charles Diamond
0:45:32
Yeah.
0:45:32
Absolutely.
0:45:32
So, chair, in terms of building off of the 2021 and moving towards where we are, I think as the commissioner put it well, most of what DOI is talking about in this 2024 report references work that we have already doing.
0:45:46
So I think starting in 2021, you had the implementation of the, what was it?
0:45:51
I think it was the standard invoice review process, SIRP.
0:45:55
And that, I think exactly as, the commissioner, and the chief accountability officer were talking about, that's that enhanced review and giving our agencies those tools to say here's one path, here's another.
0:46:06
So we have standardized insurance review policies or I'm sorry, invoice review policies starting in 2021.
0:46:09
As we move forward into this administration, we had the creation of the vendor integrity unit at Mox.
0:46:14
As you see, that was directly referenced as one of the recommendations is to create something we have already created, and indeed gone beyond that with the vendor compliance cabinet.
0:46:23
And I in terms of timing, I know we've, in our time in government, seen a lot of groups and task forces and things like that can that can come and go.
0:46:30
With the vendor compliance cabinet, we've put a real effort on making sure that it's going to be institutionally strong.
0:46:35
It has its own charter.
0:46:36
It has very distinct members that are required to do discrete actions.
0:46:40
And it is also both an input and an output scenario.
0:46:43
They're gonna be producing policies, all of these things that I discussed before that are in the pipeline to be discussed at the meeting later today, but then also an an input for agencies.
0:46:52
So for DHS, we we've the the issues that come with our agencies having different portfolios, different programmatic needs, there needs to be that clearinghouse effect.
UNKNOWN
0:47:00
Mhmm.
0:47:01
So I
Charles Diamond
0:47:01
think a lot of our effort has been to establish that VIU in mocks, which is able to be a little more in the weeds, the vendor compliance cabinet, which includes procuring agencies, oversights, and in that and to be a kind of, input output clearing house.
0:47:14
And then now we're at the very exciting stage of having these concrete policies.
0:47:17
So I've policies.
0:47:17
So I've referenced them previously at one point, but we have the anti nepotism policy, which is already effective, conflicts of interest and related party transactions which are in the pipeline.
0:47:25
And indeed, something we haven't spoken about but is similar, the standard, audited financial review, SAFER, which, again, we talk about standardizing the very burdensome audit processes in our nonprofit providers.
0:47:37
This is also with the vendor compliance cabinet and due to be released in 2025.
0:47:41
Vendors have already seen it.
0:47:42
I'm sorry.
Diana I. Ayala
0:47:42
So those recommendations came from the 2021 report?
Charles Diamond
0:47:45
Well, I would say one of some of those do feed that way, but at the same time, I think, as I think the 2024 report shows very clearly, our our, our desire to implement these, issues comes from the issues that we see on the ground.
0:48:00
As the commissioner said, a lot of these were flagged for DOI.
0:48:03
So a lot of them have grown out of the 2021 and 20, the 2021 report.
0:48:08
But I I think it's fair to say that, for all of us here, these are important issues that have been going on for 20, 30, 40 years that long preexist the 20
Diana I. Ayala
0:48:16
Yeah.
0:48:16
I ask because I'm just because you you referenced that, you know, the that a lot of the recommendations had already been implemented.
0:48:21
And I so I I I question why would the UI recommend that you implement a policy that is already in existence unless it wasn't something that was already in you know, have been activated in some sense.
Charles Diamond
0:48:35
Well, Chair, I will certainly defer to DOI on that.
0:48:37
I think we we certainly raised with DOI the fact that this is very, the majority, not all, but I I believe the majority of the conduct that we're talking about in this report, is very old.
0:48:47
And so it relates to a period in which those policies were not in place.
0:48:51
And indeed it relates to some instances that were reported to DOI and then as DHS or other entities, MOX or MORMEC, acted upon that.
0:48:59
So throughout this process, you know, I I would say that I agree with you.
0:49:05
But I think that the what the report does reflect, I think I think recommendation 2 is fair in saying Box has already created this VIU, and they should continue to do that.
0:49:15
So we're very thankful for our partners at DOI and their work, and and their role, But certainly, on on our side, we've been proactively taking these steps long before the issuance of this report.
0:49:26
And certainly DHS, even before MOX, is the one even more on the ground.
0:49:29
Okay.