Agenda Item 9
October 7, 2014
Public Hearing
MEMORANDUM
October 3,2014
TO:
FROM:
County Council
Robert
H.
Drummer, Senior Legislative Attorney
i\
/"VIA
J
SUBJECT:
Public Hearing:
Expedited Bill 42-14, Contracts and Procurement - Minority-
Owned Businesses - Sunset Date - Amendments
Expedited Bill 42-14, Contracts and Procurement - Minority-Owned Businesses - Sunset
Date - Amendments, sponsored by the Council President at the request of the County Executive,
was introduced on September 16,2014. A Government Operations and Fiscal Policy Committee
worksession was held on September 29. Action is tentatively scheduled for October 14.
Bill 42-14 would establish the deadline for submission to the Council by the Executive of
a report that evaluates the minority owned business purchasing program. The Bill would also
extend the sunset date for the program until December 31, 2019.
Background
The Supreme Court in
City
ofRichmond
v.
J.
A. Croson Company,
488 U.S. 469 (1989),
established a framework for a local government to implement a program that provides a
preference for minority owned businesses. The Court held that there must be substantial
evidence of past or ongoing discrimination in order to show a compelling government interest to
justify the program. The Program must be narrowly tailored to remedy the past or ongoing
discrimination. For this reason, local governments that have this type of program must evaluate
the continuing need for it every few years. The County Executive submitted a Disparity Study to
the Council on July 1,2014 prepared by Griffin and Strong that supports the continuation of the
program.
2014 Disparity Study
In May 20l3, the County retained Griffin
&
Strong, P.e. (GSPC) to conduct a
comprehensive disparity study. GSPC examined and analyzed the procurement policies and
practices of the County and its prime contractors regarding the use of Minority, Female, and
Disabled owned businesses (MFD) on County contracts for goods and services. The goal was to
determine if there was a statistically significant disparity between the number of MFD firms in
the relevant market and the dollars awarded to MFD firms through County contracts. GSPC
divided County contracts into 4 categories - Construction, Professional Services, Services, and
Goods.
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GSPC conducted a quantitative analysis of the County's contracting history between July
1,2007 and June 30, 2012. This analysis started with a detennination of the relevant geographic
market area for each of the 4 categories of procurement contracts. GSPC concluded that the
relevant market was the geographic area where 75-85% of the finns contracting with the County
are located. Within each relevant market, GSPC compared the percentage of finns in each race,
ethnicity, gender, and disability group that are qualified, willing and able to perfonn services
used by the County with the percentage of dollars spent by the County on finns in each MFD
group. GSPC used this analysis to detennine if each MFD group was underutilized or
overutilized in each relevant market. GSPC looked at both prime contractor utilization and
subcontractor utilization.
GSPC further analyzed the results to detennine if the underutilization observed was
statistically significant and if the underutilization could be attributed to the MFD status of the
finns through both a regression analysis that controlled for other possible explanations, such as
business size or experience, and anecdotal evidence. A summary of the statistically significant
underutilization found by GSPC is at ©9-10. The complete report can be found at:
http://www.montgomerycountymd.gov/catlservices/disparitvstudy.html.
GO Committee Worksession
The Committee discussed Expedited Bill 42-14 at a September 29 worksession.
Councilmember Navarro suggested that the Council create 2 task forces, by resolution, to study
the procurement system and the MFDlLocal Small Business Reserve Program and make
recommendations for improvements. Councilmember Navarro also moved to amend the Bill to
reduce the extension of the MFD Program from 5 years to 1 year in order to pennit the Council
to consider possible amendments to the MFD and Procurement laws based upon the Task Force
recommendations. See Councilmember Navarro's memorandum at ©11-12.
The Committee (3-0) approved the Navarro amendment to reduce the extension to 1 year
along with 2 technical amendments subject to the upcoming public hearing.
Issues
1. How does the MFD program work?
Section I1B-60 provides:
(a)
By September 30 of each year, the Chief Administrative Officer must set for the
following calendar year percentage goals of the dollar value of purchases subject
to this Article for each socially or economically disadvantaged group. The goals
must correspond to the availability of that group by source selection method and
purchasing category in the relevant geographic market area as detennined by the
most recent report that the County Executive must submit to the County Council
under Section 11 B-61 (b) to perfonn work under County contracts. The Chief
Administrative Officer must set separate goals for each socially or economically
disadvantaged group in the County's purchases of goods, construction,
professional services, and other services. The Chief Administrative Officer must
2
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not set goals for a socially or economically disadvantaged group unless the Chief
Administrative Officer determines that the value of purchases made during the
previous fiscal year from that group in each category of purchases under a
particular source selection method, compared with the availability of that group to
perform work in that category, shows a significant under-utilization of the group.
A prime contractor awarded a contract subject to the MFD program must subcontract a
defined percentage of the work to an MFD firm. The prime contractor must use one or more
MFD firms belonging to an MFD group for which the CAO has established a percentage goal for
that year. For example, if the CAO determines that Hispanic-American firms were not
underutilized in the past year, the CAO will not set a goal for Hispanic-American firms and a
prime contractor will not get credit for using a Hispanic-American firm toward the
NIFD
goal for
that contract. The DGS Director may waive all or part of the MFD goals for a contract upon a
finding that the prime contractor was unable to find sufficient MFD firms after making a good
faith effort to do so.
2. Does the Disparity Study support the extension of the law?
GSPC found a statistically significant underutilization of some MFD groups in each
procurement category that can be attributed to discrimination in the marketplace. Although
GSPC did not find a statistically significant underutilization for all MFD groups
in
each
category, they did find that African American. owned firms were underutilized
in
each
procurement category each year of the study. GSPC concluded that the "evidence suggests that
absent affirmative measures the County would be a passive participant in a pattern of exclusion
ofMFD firms." See Study, page 235.
The Disparity Study supports the extension of the MFD program because GSPC found a
statistically significant underutilization due to the MFD status of the owner for some MFD
groups in each procurement category. The MFD program requires the CAO to compare the prior
year utilization for each MFD group in each procurement category each year with the availability
found in the Study before setting a goal for an MFD group.
Committee recommendation
(3-0):
subject to testimony at the public hearing, approve the extension of the program for one year.
3. Technical amendments.
(a)
Relevant Geographic Market.
The definition of
relevant geographic market area
in the law refers to the 2005 Disparity
Study. The definition should refer to the most recent Disparity Study, which is now the 2014
Disparity Study described above.
Committee recommendation (3-0):
amend the definition of
relevant geographic market as follows:
lIB-58. Definitions.
*
(b)
*
*
Relevant geographic market area
means the geographic market area identified by
the County Executive in [[a]) the most recent report [[dated July 1, 2005]] that
3
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evaluates the need to continue the program and is issued in accordance with
Section llB-61(b).
(b)
Time Period Between Evaluations.
Section IlB-57(e) states that a 4-year period is reasonable to continue the Program
before evaluating it. This is inconsistent with the provision in the Bill that would require the
next Disparity Study to be completed in 5 years. To
be
consistent, §llB-57(e) should be
amended to require a 5-year period. Committee recommendation (3-0): approve the change in
§11B-57(e) to a 5-year period. See line 5 at ©2.
This packet contains:
Expedited Bill 42-14
Legislative Request Report
Memo from County Executive
Fiscal and Economic Impact statement
GSPC Summary of Findings
Councilmember Navarro Memorandum
F:\LAW\BILLS\I442 Minority Owned Businesses - Amendments\PH Memo.Doc
Circle #
1
3
4
5
9
11
4
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Expedited Bill No.
42-14
Concerning: Contracts and Procurement
- Minoritv-Owned Businesses ­
Sunset Date - Amendments
Revised: October 1, 2014 Draft No.
~
Introduced:
September 16. 2014
Expires:
March 16,2016
Enacted: _ _ _ _ _ _ _ _ __
Executive: _ _ _ _ _ _ _ _ __
Effective:
_-::--_-:---:-:---:::=:::-::-:-==-:::-::-:-=_
Sunset Date: December 31, [[20191120.1.5
Ch. _ _, Laws of Mont. Co. _ __
COUNTY COUNCIL
FOR MONTGOMERY COUNTY, MARYLAND
By: Council President at the Request of the County Executive
AN EXPEDITED ACT
to:
1) establish the deadline for submission to the Council by the Executive of a report that
evaluates the minority owned business purchasing program;
2) extend the sunset date for the County's minority owned business purchasing program;
and
3) generally amend the County's minority owned business purchasing program.
By amending
Montgomery County Code
Chapter 11 B, Contracts and Procurement
Sections lIB-57, 11B-58.1 IB-61 and IIB-64
Boldface
Underlining
[Single boldface brackets]
Double underlining
[[Double boldface brackets]]
* * *
Heading or defined term
Added to existing law by original bill.
Deletedfrom existing law by original bill.
Added by amendment.
Deletedfrom existing law or the bill by amendment.
Existing law unqlfected by bill.
The
County Council for Montgomery County, Maryland approves the following Act:
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BILL
No.
42-14
1
Sec. 1. Sections
lIB-57, lIB-58, llB-6l
and
llB-64
are amended as
follows:
lIB-57.
Legislative findings and policy.
2
3
4
*
(e)
*
*
5
6
A [[four-year]] five-year period is a reasonable time to continue the
minority owned business purchasing program before evaluating it.
7
*
lIB-58.
Definitions.
*
*
*
*
8
9
10
11
*
(b)
Relevant geographic market area
means the geographic market area
identified by the County Executive in [[a]] the most recent report
[[dated July 1, 2005]] that evaluates the need to continue the program
and is issued in accordance with Section 11B-61(b).
12
13
14
*
llB-61.
Reports.
*
*
*
15
16
*
(b)
*
17
18
19
By July 1, [2014] 2019, the County Executive must submit a report to
the County Council evaluating the need to extend the minority owned
business purchasing program.
20
llB-64.
Sunset date.
This Article is not effective after December 31, [2014] [[2019]] 2015.
21
22
23
24
Sec. 2. Expedited Effective Date.
The Council declares that this legislation is necessary for the immediate
protection of the public interest. This Act takes effect on January 1, 2015.
Cj)
'-;{AW\BILLS\I442 Minority
Owned
Businesses - Amendments\BiIl2.Doc
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LEGISLATIVE REQUEST REPORT
Expedited Bi1l42-14
Contracts and Procurement
-
Minority-Owned Businesses
-
Sunset Date
-
Amendments
DESCRIPTION:
Establishes the deadline for submission to the County Council of a
report that evaluates the, minority owned business purchasing
program and extends the sunset date for the program.
The Supreme Court in
City of Richmond
v.
J. A. Croson Company,
488 U.S. 469 (1989), established a framework for a local government
to implement a program that provides a preference for minority
owned businesses. According to the Court, there must
be
substantial
evidence of past or ongoing discrimination in order to justify the
program. For this reason, local governments that have this type of
program must evaluate the continuing need for it every few years.
The County Executive submitted a Disparity Study to the Council on
July 1,2014, that supports the continuation of the program.
Fair opportunities for minority owned businesses to obtain County
contracts and business.
Office ofthe County Attorney, Department of General Services.
To be requested.
To be requested.
To be requested.
Not applicable.
Marc P. Hansen, County Attorney
240-777-6700
Not applicable.
PROBLEM:
GOALS AND
OBJECTIVES:
COORDINATION:
FISCAL IMPACT:
ECONOMIC
IMPACT:
EVALUATION:
EXPERIENCE
ELSEWHERE:
SOURCE OF
INFORMATION:
APPLICATION
WITHIN
MUNICIPALITIES:
PENALTIES:
Not Applicable.
F:\LAw\BILLS\1442 Minority Owned Businesses - Amendments\LRR.Doc
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-
.
OFFICE OF THE COUN1Y EXECUTIVE
ROCKVILLE. MARYLAND 20850
Isiah Leggett
County Executive
MEMORANDUM
August 12,2014
TO:
Craig Rice, President
Montgomery County Council
Isiah Leggett, County Executive
Extension of Minority-Owncd Business Purchasing Program
FROM:
SUBJECT:
In accordance with Section IIB-61(b) of the County Code, I transmitted to the
County Council the Montgomery County Disparity Study, which evaluated the need
to
extend
Montgomery County's Minority-Owned Business Purchasing Program.
The Disparity Study concluded that Montgomery County has "made great efforts
to establish a fine-tuned procurement process that is sct up to provide equal access to all firms."
Nevertheless, the Disparity Study concluded that there is a "significant basis for an inference of
passive participation and discrimination and/or evidence ofpast discrimination against minority,
female, and disabled-owned businesses in Montgomery County." Therefore, work remains to be
done to eradicate the under-utilization of minority-owned businesses in Montgomery County's
procurement program.
Consequently, I am transmitting to the Counci11egislation to extend the County's
Minority-Owned Business Purchasing Program. In addition, I have asked Executive staff to
review other recommendations made by Griffin
&
Strong, the consultants who prepared the
study to increase the effectiveness ofthe County's Minority-Owned Business Purchasing
Program.
I look forward to working with the Council to pass this important legislation
cc:
Timothy Firestine, Chief Administrative Officer
Marc Hansen, County Attorney
David Dise. Director, Deparbnent of General Services
Bonnie Kirkland, Assistant ChiefAdministrative Officer
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Fiscal Impact Statement
Bill
#-#,
Contracts and Procurement - Minority-Owned Business - Amendments
1.
Legislative Summary
The proposed legislation establishes the deadline of July
1,2019,
for submission
to
the
County Council by the County Executive of a report that evaluates the minority-owned
business purchasing program. The legislation would also extend the sunset date from
December
31,2004,
to December
31,2019,
for the County's minority-owned business
purchasing program.
2.
An
estimate of changes in County revenues and expenditures regardless of whether
the revenues or expenditures are assumed
in
the recommended or approved budget.
Includes source of information, assumptions, and methodologies used.
No revenues or expenditures are expected from the proposed legislation.
The Department of General Services does not
require
any additional resources to extend
this program for another 5 years. The current cost ofthis program to the County is
$251,883 per
year.
3. Revenue and expenditure estimates covering at least the next 6 fiscal years.
See item #2.
4.
An
actuarial analysis through the entire amortization period for each bill that would
affect retiree pension or group insurance costs.
The legislation does not affect retiree pension or group insurance costs.
S.
Later actions that
may
affect future revenue and expenditures
if
the bill authorizes
future spending.
The legislation does not authorize future spending.
6.
An
estimate of the staff time needed to implement the bill.
Not applicable.
7.
An explanation of how the addition of new staff responsibilities would affect other
duties.
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Fiscal Impact Statement: CE Bill- Local Business Subcontracting Program
Page 2 of2
Not applicable.
8. An estimate of costs when an additional appropriation is needed.
Not applicable.
9. A description of any variable that could affect revenue and cost estimates.
Not applicable.
10. Ranges of revenue or expenditures that are uncertain or difficult to project.
Not applicable.
11.
If
a bill is 6kely
to
have no fiscal
impaet~
why that
is
the case.
The Department of General Services does not require any additional resources
to
extend
this program for another 5 years. The current cost of
this
program to the County is
$
251,883
per year.
12. Other fiscal impacts or comments.
None
13. The following contributed to and concurred with this analysis:
Grace Denno, Office of Business Relations and Compliance, Department of General Services
Pam Jones, Office of Procurement, Department of General Services
Erika Lopez-Finn, Office of Management and Budget
Naeem Mia, Office of Management and Budget
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Eeonomic Impact Statement
BiD
#-#,
Contracts aDd Procurement -
MiDority...()wn~
Business
~
Am.endments
Background:
This
legislation would establish
the
de8dline of July
1,2019.
for submission
to
the
Co'\,IDty Council by the County Executive ofa
report
that
evaluates
the
minority-owned
business purchasing
program.
The legislation would also
extend
the
sunset
date
from
December
31,2014,
to
December
31, 2019,
for the
County'sminority~wned
business
.purchasing
program.
.'
1. The sources of information, assumptions, aDd methodologies
used.
Source of
information
is
the
Office ofBusiness Relations and Compliance,
Department of General Services. Infonnation and
data
in the preparation ofthe
economic impact statement come from various
annual
reports from the Office of
Business Relations
and
Compliance.
2. A description of
any
variable that eould affect the economic impact estimates.
The
variables
that
could
affect
the economic
impact
estimates
are
the
total
revenues/dollars
subject
to
the
Minority, Female,
and
Disabled Person Owned
Business Program
(MFD)
and the
revenues/dollars spent
to
certified
MFD
contractors.
Based on
data
provided
in
the
MFD
annual
reports from fiscal
year
2011
to
fiscal
year
2013,
the average
total
dollars subject to
MFDrequirements
was slightly above
$746.5 million and
the
average
total
dollars for MFD procurement
was
slightly above
$144.7
million or
19.4
percent
3.
The
BiD's
positive or negative effect,
if
any on employment, spending, saving,
investment, incomes, and property values in the County.
The extension of the
minority~ed
business purchasing program
(MFD)
would
have
a
positive economic effect of
business
income
to
~rity-oWned
businesses.
Based
on
data
for
the
past
three
:fiscal years
through
FY2013,
the
average number of
con.tractors
was
nearly
1,900
(including
both
prime and sub-contractors)
with
an
average contract
award
over
$77,000
per
contractor.
The
bill could
also
have
an
effect on
employment by
minority~wned
contractors.
4.
If
a
BiD
is likely
to
have no economic impact,
why is
that the case?
The
bill would have a positive economic impact on minority-owned businesses -
see
paragraph #3.
Page 1 of2 .
(j)
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Economic Impact Statement
BiU
f#..:II.,
CORtracts and Procurement - Minority-Owned Business - Amendments
S. The foUawinl
contributed
to
or
concurred
with
this
analysis: David Platt
and
Rob
Hagedoom, Finance; Grace Denno
and
Alvin Boss,
Office of
Business Relations
and
Compliance, DGS; Naeem
Mia,
Office of Management and Budget.
@'1~
o
.
Beach,
Director
partment
of
Finance
.
Page 2
of2
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/'C
\..JJ
GR1FF1N&
STRONG
rc:
n.
SUMMARY OF FINDINGS
The
Study
found a statistically significant disparity between the number of available MFDs
in
the
relevant markets
in
each work category throughout the term and the utilization. measured by
dollars awarded by the County, of those same
MFD
groups. GSPC
also
determined that when the
disparity
was
broken down by
each
racefgenderfethnicity group, on average, over the
entire
Study, the following significant underutilizations were found.
Table
1:
Summary of Statistically Significant Underutilization
ill
Primc Contracting
Montgomery County, Maryland
Disparity Study
(Over
Entire
Study
Period - July
I, 2007
through June
30, 2012)
From P.O., DPO, and P-card Purchases
Griffin
&
strong,
P.e.
2014
Construction
African American
Asian American
Professional
Services
Services
Goods
African American
African American
Asian
American (DPO Asian American
and P-card purchases
only)
Hispanic American
(DPO Hispanic
American
Hispanic
American
Hispanic American
(OPO and P-card
(DPO and P--card
and P--card purchases
only)
purchases onlyl
Qurchases onlyl
Native American
Native American
Native American
Native American
(DPO
and
P--card
'Purchases
only)
Female
(PO
and P-card Female
Female
Female'
purchases only)
Disabled (PO and
P~
Disabled
Disabled
Disabled
card
only)
African American
Asian
American
With
regard
to subcontractors, GSPC found that the following
MFD
groups
in
the following
business categories showed significant underutilization:
141Page
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rc
\....P
GRIFFlN&
STRONGI~
Table
2:
Summary ofStatistically Signific.ant Ulldcrutilization in Subcontracting
Montgomery County, Maryland
Disparity Study
(Over Entire Study Period - July
1, 2007
through June
30, 2012)
From Prime Vendor Questionnaire
Construction
African American
Asian American
Hispanic American
Native American
Female
Disabled
Gnffin
&:
Strong, P.C.
2014
Professional Services
African American
Hispanie American
Native American
Disabled
Services
.Goods
Asian American
Hispanic American
Native American
Disabled
African American
Asian American
Hispanic American
NativeAmerican
Disabled
GSPC then tested the disparities for likely cause through a regression analysis and determined
that Montgomery County, Maryland may be an active or passive participant in past or present
discrimination in
its
vendor marketplace. Notwithstanding this general finding, the County
has
made some improvements in the inclusion of MFDs in
its
procurement process since the last,
2005
Disparity
Study
and the enactment of the
Local
Small Business Reserve Program in
all
areas
except Construction
which
decrease by a
minimal.1%.
Table 3: Sunullary ofMFD Prime Utilization Comparison Between
2001-03
and
2007-12
Montgomery County, Maryland
Disparity Study
FromP.O.s
Griffin
&: Strong,
P.e.
2014
2001-2003
2 0
07-
2 012
%
Change
%
%
Construction
Professional Services
Services
Goods
26.11
7.
08
19·61
6.19
26.01
8.94
31-95
7.13
- .10
+1.86
+12.34'
+·94
Detailed
findings
are included in Section VIII of
this
report.
•Substantial
increase
is
primarily due
to
jump in Asian American utilizlltkm from.68
in
2001-3
to
14-69 in
2007-20l2.
.
15IPage
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MONTGOMERY COUNTY COUNCIL
ROCKVILLE, MARYLAND
NANCY NAVARRO
COUNCILMEMBER, DISTRICT 4
CHAIR, GOVERNMENT OPERATIONS
&
FISCAL POLICY COMMITTEE
MEMORANDUM
September 26, 2014
TO:
FROM:
Councilmembers
Nancy Navarro, Chair
i
/ /
Government Operations
&.
Fiscal Policy Committee
Procurement Process
&
Disparity Study
,/'?/1-tl
SUBJECT:
On Monday, the Government Operations
&
Fiscal Policy Committee will discuss three
items related to the County's procurement process. We will receive a briefing from the
Office of Legislative Oversight (OLO) regarding a survey of businesses, hear from
Griffin
&
Strong, P.C. and the County Attorney regarding the 2014 Disparity Study, and
review legislation proposed by the County Executive to extend the sunset date of the
Minority, Female, and Disabled-owned business program (MFD).
The overall theme of the OLO survey and Disparity Study is that the current procurement
process is not working for businesses. In general, businesses feel the procurement process
in Montgomery County is difficult to navigate, confusing, and lacks clear communication
between the County and prospective bidders. In particular, minority, female, and disabled
owned businesses are not bidding on contracts, in part, because they are not familiar with
procurement opportunities with the County.
OLO offers three recommendations based on the survey findings:
I. Ask the County Executive
to
strengthen and expand current outreach efforts­
particularly to Local Small Business Reserve Program (LSBRP) and MFD
businesses--to increase businesses' awareness of County contracting
opportunities.
2. Ask the County Executive to develop a consistent set of follow-up procures for
all bid submissions for County contracts to inform businesses about the status of
their bid.
STELLA B. WERNER COUNCIL OFFICE BUILDING· RoCKVILLE, MARYLAND 20850
(240) 777-7968 • TTY (240) 777-7914
COUNCILMEMBER.NAVARRO@MONTGOMERYCOUNTYMD.GOV • WWW.COUNCILMEMBERNAVARRO.COM
@
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3. Ask the County Executive to closely examine the promotion and administration
of the Minority, Female, and Disabled-Owned Program.
Based on the 2014 Disparity Study, the County Executive is recommending Expedited
Bill 42-14. This legislation would extend the sunset of the current MFD program until
December 31,2019 and require the County Executive to submit a new disparity study to
the Council by July 1,2019.
.
While I agree that the Council should extend the current MFD program temporarily so it
does not expire at the end of the year, I strongly oppose simply maintaining the status
quo. Montgomery County has had an MFD program for more than three decades, yet the
2014 Disparity Study found "statistically significant underutilization of some MFD
groups in each procurement category that can be attributed to discrimination in the
marketplace.")
In light of the OLO survey and 2014 Disparity Study, I propose establishing two Task
Forces by Council Resolution.
First, the Procurement Reform Task Force would be comprised of business owners,
procurement experts, and County officials. The objectives ofthe Task Force would be to:
• Review and evaluate current procurement practices, office structure, and funding;
offer recommendations to increase outreach, streamlining and improved
processes;
• Review national industry standards and best practices for procurement; offer
recommendations to align County practices with best practices.
Second, the MFD Program Task Force would be comprised of minority, women, and
disabled-owned business owners and County officials, such as representatives from the
Department of General Services and the Office of the County Attorney. The objective of
this Task Force would be to:
• Review and evaluate the current MFD program; offer recommendations for
improvement;
Both task forces would work in parallel tracks during a similar time period. After they
complete their work, Council Staffwill integrate the reports into a single set of
recommendations for the GO Committee to consider in a comprehensive way.
On Monday, I propose the GO Committee recommends the appointment of these task
forces to the full Council. In addition, I support approving Expedited Bill 42-14, but
amending
it
to sunset the MFD program after one year-Qn December 31, 2015. This will
provide the task forces with a full year to offer recommendations to the Council that will
enhance the current MFD program and improve the procurement process more generally.
lhttp:'
(www.montgornerycQuntymd.gov.councH/Resources.Files.agenda.cm/20 14
1140929 12014
0929
G03.pdf
STELLA
B.
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