Client Overview & Challenge Presented:
An Ohio company accepted responsibility for alleged misconduct on various federally-funded transportation projects in Ohio, Kentucky, Indiana, and Michigan, including violating the False Claims Act by improperly representing compliance with the Disadvantaged Business Enterprise (DBE) program.
The company agreed to implement certain remedial measures and enter into a three-year Administrative Monitoring and Compliance Agreement to ensure compliance with federal DBE requirements.
Our Approach / Solution:
- Thoroughly researched the contractual requirements of the company’s Administrative Agreement with USDOT.
- Engaged in an extensive investigation and assessment of the company’s compliance with contractual and federal requirements.
- Provided hands-on education and training to company leadership.
- Developed and executed a strategic plan in which adequate oversight and monitoring was implemented that included regular visits, auditing, and tracking to ensure the company’s compliance with the regulations and requirements.
- Developed effective reporting methods and provided recommendations to the company for continuous Improvement measures.
- Successfully completed Independent Monitoring for three years so no longer operating under Administrative Agreement.
- As the Independent Monitor, we constructed and submitted 12 accurate and thorough reports identifying the compliance issues and the corrective action items implemented by the company being monitored, and submitted the reports to the USDOT.
- Ultimately, we met USDOT’s Independent Monitoring criteria for successful monitoring of the identified company, and we helped the company successfully meet federal regulations and requirements for the DBE program.