Commercially Useful Function Training

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CUF Monitoring Report

Why complete a CUF monitoring report?

• It's required. Title 49 Part 26.37(b) of the Code of Federal Regulations states in part: "Your DBE firm's program must also include a monitoring and enforcement mechanism to ensure that work committed to DBE firms at contract award or subsequently (e.g., as the result of modification to the contract) is actually performed by the DBE firms to which the work was committed. This mechanism must include a written certification that you have reviewed contracting records and monitored work sites in your state for this purpose."


• Ensuring that work committed to DBE firms at or after contract award is actually performed by the DBE firms to which the work was committed mitigates fraud and maintains the integrity of the DBE program
  • This provides opportunities for legitimate DBE firms to participate on Federally-assisted contracts
  • Legitimate DBE firms are not "shut out" of opportunities by firms that are on the contract in name only, or that perform only a portion of the work committed to them
  
  
• Contract staff review contract records and observe work operations every day. This is how CUF is assessed. Contract staff are already making these assessments; the assessments need to be documented uniformly. This form is the method that Department and Subrecipients use to comply with the Federal regulation.

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