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A Recipe for Change: Successful Diversity, Equity, and Inclusion Programs
September 11, 2023
Success Story: How the DBE/ACDBE Program Empowers Disadvantaged Entrepreneurs
October 11, 2023

DBE Fraud Cases: A Timely Reminder to Prioritize Commercially Useful Function Reviews

Last month, the U.S. Department of Transportation Office of Inspector General released an investigative report titled "FHWA Suspends Massachusetts-Based DBE Contractor" which details the suspension of a DBE contractor due to fraudulent activities involving both the Prime Contractor and the certified DBE subcontractor.

Essentially, the Prime Contractor was performing work that the DBE subcontractor was contracted to do. This action directly violates the Commercially Useful Function (CUF) regulations of the U.S. DOT Disadvantaged Business Enterprise (DBE) Program which aims to ensure that DBE subcontractors make significant and meaningful contributions to federally funded projects. This requirement is essential for compelling DBEs to engage in authentic tasks aligned with their scope of work and vital to project success.

By adhering to CUF guidelines, federal agencies and Prime Contractors can determine whether DBEs are actively and genuinely involved in project-related responsibilities. In doing so, federal agencies and Primes can effectively avoid and detect fraudulent activities, uphold the program's integrity, and provide gainful utilization of DBE firms as intended by the U.S. DOT DBE Program. CUF reviews serve as a robust mechanism for deterring and identifying fraud within the DBE program, thereby advancing transparency, equity, and accountability in federally funded projects.

A graphic that describes what is a CUF. A CUF is a Commercially Useful Function. CUF evaluations are required to be conducted for all Disadvantaged Business Enterprise (DBE) firms that work on federally-assisted projects. CUF evaluations are important because they discover fraud, ensure program integrity, and promote genuine DBE participation.

About the Authors

GCAP has over 25 years of experience in the contract compliance field and our DBE compliance experts provide technical assistance in conducting CUF reviews, monitoring DBE subcontractors, and ensuring compliance for your agency or company. To discuss opportunities, contact our Business Development team at bizdev@gcapservices.com. 

Check Out More Compliance Buzz!

October 11, 2023
Success Story: How the DBE/ACDBE Program Empowers Disadvantaged Entrepreneurs
Forbes recently released an article about Randy Hazelton, a young entrepreneur and Airport Concession Disadvantaged Business Enterprise (ACDBE) owner who grew his business from a streetside restaurant in Atlanta to a $50 million enterprise with assistance from the USDOT's ACDBE program.
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September 20, 2023
DBE Fraud Cases: A Timely Reminder to Prioritize Commercially Useful Function Reviews
Last month, the U.S. Department of Transportation Office of Inspector General released an investigative report titled "FHWA Suspends Massachusetts-Based DBE Contractor" which details the suspension of a DBE contractor due to fraudulent activities involving both the Prime Contractor and the certified DBE subcontractor.
Do you like it?
Read more
September 11, 2023
A Recipe for Change: Successful Diversity, Equity, and Inclusion Programs
When it comes to diversity, equity, and inclusion, there is not a ‘one size fits all’ strategy and integration plan—each organization should have their own to address their uniquely identified needs. What works for one organization may or may not work for other. Therefore, assessing, monitoring, and adjusting the strategy is critical to the success of DEI programs.
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Brittany Yamagata
Brittany Yamagata
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