Lacking full and open competition for one or more methods of Small business element no submitted and/or implemented procurement Improper use of geographic preferences DBE goal not submitted to FTA Lacking compliant A&E procurement practices DBE goal submission deficiencies No FTA clauses DBE goal public participation process deficiencies Buy America provision not in solicitation and/or contract Uniform DBE reports not submitted semi-annually Contract files lacking Buy America certifications Uniform DBE reports dot not include required information No verification that excluded parties are not participating ARRA-specific DBE reports not submitted correctly Excluded parties participating in covered transactions Goal achievement analysis not completed or not submitted Change order procedures deficiencies Inadequate implementation of DBE contract compliance Procurement quantities in excess of need Grantee does not monitor DBE compliance Improper piggyback purchase Grantee not complying with DBE termination process DBE goal achievement analysis not completed or not Contract(s) exceed five year limitation submitted Pre-award and/or post-delivery audits not performed Inadequate implementation of DBE contract compliance Pre-award and/or post-delivery certifications lacking Grantee not complying with DBE termination process No TVM certification Not participating in a UCP Insufficient oversight of procurement DBE certifications not adequate No approved DBE program Interstate certification deficiencies Inadequate designation of DBE officer DBE directory does not include NAICS codes DBE program not updated Other (Applicable Triennial Review deficiency) Questions FTA State Reponses Reviewer Comments Comments
Lacking full and open competition for one or more methods of procurement Small business element no submitted and/or implemented Improper use of geographic preferences DBE goal not submitted to FTA Lacking compliant A&E procurement practices DBE goal submission deficiencies No FTA clauses DBE goal public participation process deficiencies Buy America provision not in solicitation and/or contract Uniform DBE reports not submitted semi-annually Contract files lacking Buy America certifications Uniform DBE reports dot not include required information No verification that excluded parties are not participating ARRA-specific DBE reports not submitted correctly Excluded parties participating in covered transactions Goal achievement analysis not completed or not submitted Change order procedures deficiencies Inadequate implementation of DBE contract compliance Procurement quantities in excess of need Grantee does not monitor DBE compliance Improper piggyback purchase Grantee not complying with DBE termination process Contract(s) exceed five year limitation DBE goal achievement analysis not completed or not submitted Pre-award and/or post-delivery audits not performed Inadequate implementation of DBE contract compliance Pre-award and/or post-delivery certifications lacking Grantee not complying with DBE termination process No TVM certification Not participating in a UCP Insufficient oversight of procurement DBE certifications not adequate No approved DBE program Interstate certification deficiencies Inadequate designation of DBE officer DBE directory does not include NAICS codes DBE program not updated Other (Applicable Triennial Review deficiency) Questions FTA Comments State Reponses Reviewer Comments
FY12ODOT%20SMR%20Review%20Questions%20ODOT%20Response-Final-wODOTresponse.docx