Overview
DCAMM did not ensure that contractors completed projected staffing tables each quarter that identified female and minority workers. Staffing tables are meant to provide DCAMM with an update on each contractor working toward achieving workforce participation goals for women and minorities. As a result of this issue, DCAMM did not identify contractors that did not comply with the workforce participation goals for women and minorities and needed to submit these staffing tables. In our analysis, we determined that, during our audit period, an average of 56 of the 60 contracts per quarter did not meet the women’s workforce participation goal of 6.9% and an average of 40 of the 60 contracts per quarter did not meet the minority workforce participation goal of 15.3%.
Without receiving and reviewing the quarterly projected staffing tables, DCAMM cannot determine what specific actions contractors are taking toward meeting their workforce participation goals for women and minorities and therefore cannot evaluate whether any enforcement provisions are warranted.
Below is a chart detailing the number of contracts for each quarter during our audit period and the number that met workforce participation goals for women and minorities.
Female and Minority Workforce Participation Goal Results by Calendar Year and Quarter
|
Calendar Year and Quarter (Q) |
Number of Contracts |
Contracts That Met the Workforce Participation Goal (Women) |
Contracts That Did Not Meet the Workforce Participation Goal (Women) |
Contracts That Met the Workforce Participation Goal (Minorities) |
Contracts That Did Not Meet the Workforce Participation Goal (Minorities) |
|
2019 Q1 |
58 |
3 |
55 |
10 |
48 |
|
2019 Q2 |
62 |
3 |
59 |
18 |
44 |
|
2019 Q3 |
61 |
4 |
57 |
23 |
38 |
|
2019 Q4 |
69 |
4 |
65 |
26 |
43 |
|
2020 Q1 |
59 |
6 |
53 |
21 |
38 |
|
2020 Q2 |
59 |
1 |
58 |
23 |
36 |
|
2020 Q3 |
58 |
3 |
55 |
22 |
36 |
|
2020 Q4 |
50 |
5 |
45 |
14 |
36 |
Authoritative Guidance
Section 44(G) of Chapter 149 of the General Laws states,
Every contract by a state agency or state assisted contract for design, construction, reconstruction, installation, demolition, maintenance or repair shall set forth the participation goals of minority and women workers to be employed on each such contract and the processes and procedures to ensure compliance with those workforce participation goals, including reporting and enforcement provisions.
Section 3(B) of Appendix A of the general conditions of the Commonwealth’s standard construction contract states,
The Contractor shall prepare projected staffing tables on a quarterly basis. These shall be broken down into projections, by week, of workers required in each trade.
Although DCAMM did include the staffing tables as a reporting provision of the contracts, it did not ensure that contractors submitted them.
Reasons for Noncompliance
DCAMM did not have any policies and procedures or a monitoring component to ensure that contractors completed projected staffing tables quarterly to update its tracking of the contractors’ steps toward achieving its workforce participation goals for female and minority workers.
Recommendation
DCAMM should develop policies and procedures, including a monitoring component, to ensure that all contractors work toward meeting its workforce participation goals for female and minority workers every quarter.
Auditee’s Response
As described in the Auditee Response to Finding No. 1 above, DCAMM is implementing the recommendation of the [Office of the State Auditor] by supplementing the existing procedures of its compliance unit to include additional supervisor review on a quarterly basis and automatic implementation of its contract option to require quarterly projected workforce tables.
Auditor’s Reply
Based on its response, DCAMM is taking measures to address our concerns on this matter.
| Date published: | February 23, 2022 |
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