“The Department also seeks comment on whether the spouse of an applicant owner should have to file a PNW statement, even if the spouse is not involved in the business in question.” Yes they absolutely should. Spousal tax filings, if they are filed separately, will also give a clearer picture of the true economic situation of the candidate.
The US government could’ve saved some money by simply asking people familiar with the Awards/Commitments and Payments Report to submit a narrative on its ineptitude before they funded a GAO report. There is no way any quality data has ever been compiled from these things. First, there’s the “form over function” effect, which puts emphasis on “awards/commitments” rather than the amounts actually spent on DBEs. This has allowed many recipients to get by with shell DBE programs which simply go through the motions of contracting but achieve minimal/no results for DBEs. Their “awards/commitments” are reported to executive management and all is well and good because management doesn’t realize there is a difference between a commitment and actual – and more importantly, because USDOT doesn’t seem to care about the actual.
Second, there are too many variations between recipients reports, compounded when there are recipient internal personnel changes; the most significant being the lack of a standard definition (or USDOT understanding) of the concept of “completion of a project”. Many “completed” projects remain open for years, so developing an internal “completed” date is not as easy as it sounds. This results in distorted, irrelevant data.
Nthanda Chenot
This is comment on Proposed Rule
Disadvantaged Business Enterprise: Program Implementation Modifications
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