Trust, But Verify

In February 2017, President Donald Trump met with presidents of Historically Black Colleges and Universities and announced that he was shifting federal authority of HBCUs to the White House.

On February 21, 2017, the President signed an executive order announcing the President’s Board of Advisors on HBCUs. In the executive order, President Trump ordered government agencies that regularly interact with HBCUs to develop annual plans to “strengthen the capacity” of those schools. So I wanted to take a moment to find out how the federal agencies are doing.

NASA, as I have stated in previous blogs, has affirmed its commitment to the goal for one percent of their government contract dollars to be awarded to HBCUs. So, I have verified that effective August 2017 NASA’s HBCU/MI goal was added to the NASA Federal Acquisition Regulation (FAR) supplement to implement the agency-wide one percent HBCU/MI goal. However, the question is, a year later as I write this blog August 2018, I still cannot verify how they are doing in actually meeting this goal.

This is a slide from the presentation NASA shares during the agency's HBCU Road Tour. It is the most recent information available on NASA's HBCU contracting goal.

In order to measure how well the agencies are doing, we must first know how well the prime contractors are doing. The prime contractor is where the goal must be implemented and properly executed. However, I cannot verify how they are doing.

There are several reasons why. One reason is because there is not a central location for the public to know how to access this information. Sure there are web sites to visit, like usaspending.gov; but you have to have some knowledge of what to look for. Which brings me to the second reason why it is difficult to independently verify the progress towards NASA's HBCU goal. Each prime contractor can have a specific goal in any given solicitation/requirement, and we will not know what this goal is, unless we are the prime contractor. The third reason is, even if we knew the goal percentage of one prime contractor and one solicitation that does not necessarily mean this goal will be the same goal for another prime contractor. So how do we verify?

The current way the agencies verifies how well the prime contractor is doing on their subcontracting goals is through a mechanism called the Electronic Subcontract Reporting System. This system is used by the prime contractor to document their subcontract awards on all socioeconomic classes. I like this mechanism because although the agency may trust the prime contractor to do the right thing this systems allows them to verify.

So, I believe that in order for HBCUs/MIs to trust this system and properly execute to the plan in the executive order there must be a solid mechanism by which the award documentation to HBCUs/MIs must be verified.