Share on Social Media

For Margarita Abramov, New York City contract and compliance administrator for IBTS, the process of improving compliance policies and procedures is never quite finished. “There’s always room for improvement,” she says.

Abramov was responsible for program compliance oversight for recovery programs in New York City after Hurricane Sandy, a situation she notes was extreme due to the magnitude of damage and number of individuals impacted.

“No one was ready for it, but IBTS’s processes and procedures were set-up well considering what we were dealing with after Sandy,” she explains.

Abramov recommends the following tips for localities managing disaster recovery program compliance. These are applicable to localities and disaster recovery programs of all sizes and scopes.

Contract understanding: Meet face-to-face.

Ensure all parties understand the contract. Abramov recommends meeting with contractors face-to-face to present the entire package. During this meeting:

• Clarify the language in the contract. Coach contractors through their questions and common mistakes, and ensure they know exactly what they are signing.

• Ensure the contractor understands expected deliverables.

• Review the invoice and billing process and provide checklists and templates for invoice requirements.

• Review all federal, state and program-specific requirements. For example, ensure contractors have a clear understanding of HUD’s Community Development Block Grant Disaster Recovery (CDBG-DR) Section 3 Requirements, which require contractors to use women, minority, veteran and locally owned businesses.
  • Direct contractors to your state’s Office for Minority and Women Business Enterprises (MWBEs), where they can search through your state’s database of certified MWBEs that can help meet this requirement.

• Have contractors sign-off on all forms at the meeting. This ensures all forms are completed at the outset of the program so they may be submitted to the appropriate governmental agencies.

• Establish a single point of contact who will act as the point of communication for all accounting and compliance.

Implement streamlined processes.

Abramov stresses the importance of practices that streamline the compliance process and promote complete transparency.

• Distribute compliance checklists internally and to the contractor to insure all team members are aware of and can address common compliance mistakes.

• Maintain continuous compliance monitoring processes and periodically review invoices for compliance or needed amendments. “We send subcontractors reminders about insurance expiration dates and provide them with updates if any changes take place in compliance regulations,” Abramov says.

Establish a verification processes for invoices and payments.

• During the invoice verification process, check invoices for visual errors and noncompliance, and validate the invoiced work that has been performed.

• To help prevent and detect billing errors, like duplicate billing, use a spreadsheet that contains all billing points, and enter each line item into them.

• If problems like duplicate billing become a repetitive issue, charge fees for the time it takes your agency to identify and fix invoice errors.

Abramov provides review and oversight of contracts for the IBTS New York City office to ensure contract compliance.