The Commission requires contractors to submit a HUB subcontracting plan for all procurements with an expected value greater than $100,000. For the 13 contracts tested,
the Commission consistently documented its justification when choosing a non-HUB vendor instead of a HUB vendor. The Commission complied with most HUB contractor and
subcontractor reporting requirements. The Commission did not ensure that contractors submitted monthly Progress Assessment Reports, as required. However, the Commission required a completed Progress Assessment Report to be submitted with all requests for payment, and it did not process payments until after it has reviewed the Progress Assessment Report.
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