Cedar Hill Regional Medical Center
District of Columbia
Cedar Hill proves that PLAs block real CBE participation.
The Cedar Hill Regional Medical Center was promoted as a model for equity, with District law requiring that 35% of the dollar volume of the contract be subcontracted to Certified Business Enterprises (CBEs). In reality, the project fell far short.
The contract totaled $409 million, meaning CBEs should have received more than $143 million in work. Instead, approved CBE spending reached just $75.5 million, or 18.5% of the project.
To mask this failure, the Department of Small and Local Business Development (DSLBD) artificially reduced the contract’s dollar volume to $285 million, cutting the CBE requirement by more than $43 million and creating the illusion of compliance. District law provides no authority for this maneuver. Applied correctly, the project missed its CBE goal by more than $67 million.
How it failed
The Cedar Hill project was subject to a PLA that restricted meaningful participation by CBEs.
The total contract value was $409 million, requiring $143 million in CBE subcontracting under District law.
Actual approved CBE spending reached only $75.5 million, or 18.5% of the project.
DSLBD improperly reduced the contract’s “dollar volume” to $285 million, cutting the CBE requirement by more than $43 million.
District law provides no authority to reduce the dollar volume of the contract in this manner.
Without the improper adjustment, the project missed its CBE requirement by more than $67 million.
The PLA’s exemption for contracts under $6 million effectively confined CBEs to the smallest roles on the project.
