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B26-0257 • 2025

Subcontracting Requirements Exemption for Contracts for Health Benefits to District Employees Amendment Act of 2025

Subcontracting Requirements Exemption for Contracts for Health Benefits to District Employees Amendment Act of 2025

Labor
Active

The official status still shows this bill as active or still awaiting another formal step.

Sponsor
at the request of the Mayor
Last action
2026-03-27
Official status
Under Council Review
Effective date
Not listed

Plain English Breakdown

The official source material does not provide specific details on penalties or consequences for vendors failing to submit subcontracting plans by the new deadline.

Health Benefits Contract Exemption Act

This act allows vendors bidding on contracts for health benefits to District employees and their families more time to provide subcontracting plans.

What This Bill Does

  • Adds a new subsection (d)(4) to the Small and Certified Business Enterprise Development and Assistance Act of 2005, allowing vendors to submit subcontracting plans after enrollment projections are set but before the plan year starts.

Who It Names or Affects

  • Vendors bidding on contracts to provide health benefits to District government employees and their families.
  • District of Columbia government agencies responsible for awarding these contracts.

Terms To Know

Subcontracting plan
A plan that outlines how a company will allocate part of its contract value to smaller businesses or certified business enterprises.
Vendor
A company that provides goods or services to another organization, in this case, the District government.

Limits and Unknowns

  • The bill does not specify how much longer vendors have to submit their subcontracting plans.
  • It is unclear what happens if a vendor fails to provide a subcontracting plan by the new deadline.

Bill History

  1. 2026-03-27 Council of the District of Columbia LIMS

    Public Hearing on B26-0257 View Public Hearing Record

  2. 2026-03-06 Council of the District of Columbia LIMS

    Notice of Public Hearing Published in the District of Columbia Register

  3. 2026-03-03 Council of the District of Columbia LIMS

    Revised Notice of Public Hearing filed in the Office of Secretary by Executive Administration and Labor

  4. 2026-01-26 Council of the District of Columbia LIMS

    Public Hearing Canceled

  5. 2026-01-23 Council of the District of Columbia LIMS

    Cancellation Notice of Public Hearing filed in the Office of Secretary

  6. 2026-01-09 Council of the District of Columbia LIMS

    Notice of Public Hearing Published in the District of Columbia Register

  7. 2026-01-05 Council of the District of Columbia LIMS

    Notice of Public Hearing filed in the Office of Secretary by Executive Administration and Labor

  8. 2025-06-03 Council of the District of Columbia LIMS

    Referred to Committee on Executive Administration and Labor

  9. 2025-05-30 Council of the District of Columbia LIMS

    Notice of Intent to Act on B26-0257 Published in the District of Columbia Register

  10. 2025-05-22 Council of the District of Columbia LIMS

    B26-0257 Introduced by Chairman Mendelson at Office of the Secretary

Official Summary Text

Subcontracting Requirements Exemption for Contracts for Health Benefits to District Employees Amendment Act of 2025

Current Bill Text

Read the full stored bill text
MURIEL BOWSER MAYOR
May 22, 2025
The Honorable Phil Mendelson
Chairman
Council of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, NW, Suite 504
Washington, DC 20004
Dear Chairman Mendelson:
Enclosed for consideration and enactment by the Council of the District of Columbia is the
Subcontracting Requirements Exemption for Contracts for Health Benefits for District Employees
Emergency Amendment Act of 2025, along with the accompanying emergency declaration
resolution, the Subcontracting Requirements Exemption for Contracts for Health Benefits for
District Employees Temporary Amendment Act of 2025, and the Subcontracting Requirements
Exemption for Contracts for Health Benefits for District Employees Amendment Act of 2025.
The legislation adds a new subsection (d)(4) to D.C. Official Code§ 2-218.46 to extend the time
in which compliant subcontracting plans for contracts for health benefits to District employees and
their families shall be provided.
I urge the Council to take prompt and favorable action at your earliest convenience.
Sincerely,
1
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A BILL
~~
~Phil Mendelson
at the request of the Mayor
12 IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
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17 To amend the Small and Certified Business Enterprise Development and Assistance Act of 2005
18 to extend the time in which compliant subcontracting plans for contracts for health
19 benefits for District employees and their families shall be provided.
20
21 BE IT ENACTED BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
22 act may be cited as the "Subcontracting Requirements Exemption for Contracts for Health
23 Benefits to District Employees Amendment Act of 2025".
24 Sec. 2. Section 2346(d) of the Small and Certified Business Enterprise Development and
25 Assistance Act of 2005, effective October 20, 2005 (D.C. Law 16-33; D.C. Official Code§ 2-
26 218.46(d)), is amended by adding a new paragraph (4) to read as follows:
27 "(4) Notwithstanding the foregoing paragraphs (1) and (3) of this subsection, the
28 subcontracting plan for contracts to provide health benefits to District government employees
29 and their families shall be provided prior to commencement of performance of the plan year, and
30 a bid or proposal that does not include a subcontracting plan may be deemed responsive if it is
31 submitted in response to a solicitation to provide health benefits to District government
32 employees and their families."
33 Sec. 3. Fiscal impact statement.
1
2
The Council adopts the fiscal impact statement of the Chief Financial Officer as the 33
impact statement required by section 4a of the General Legislative Procedures Act of 1975, 34
approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.47a). 35
Sec. 4. Effective date. 36
This act shall take effect following approval by the Mayor (or in the event of veto by the 37
Mayor, action by the Council to override the veto), and shall remain in effect for no longer than 38
90 days, as provided for emergency acts of the Council of the District of Columbia in section 39
412(a) of the District of Columbia Home Rule Act, approved December 24, 1973 (87 Stat. 788; 40
D.C. Official Code § 1-204.12(a)). 41
Government of the District of Columbia
Office of the Chief Financial Officer

Glen Lee
Chief Financial Officer

1350 Pennsylvania Avenue, NW, Suite 203, Washington, DC 20004 (202)727 -2476
www.cfo.dc.gov
MEMORANDUM

TO: The Honorable Phil Mendelson
Chairman, Council of the District of Columbia

FROM: Glen Lee
Chief Financial Officer

DATE: April 17, 2025

SUBJECT: Fiscal Impact Statement – Subcontracting Requirements Exemption for
Contracts for Health Benefits for District Employees Emergency
Amendment Act of 2025

REFERENCE: Draft Bill as provided to the Office of Revenue Analysis on April 10,
2025

Conclusion

Funds are sufficient in the fiscal year 2025 through fiscal year 2028 budget and financial plan to
implement the bill.

Background

The District government requires any vendor bidding on a District contract valued at over $250,000
to include a subcontracting plan for how it will allocate 35 percent of the contract’s dollar volume to
small business enterprises or certified business enterprises. 1 The vendor must submit the
subcontracting plan when it submits its bid; otherwise, the bid is deemed nonresponsive.

The bill authorizes a vendor bidding on contracts to provide health benefits to District government
employees to submit their subcontracting plan prior to beginning the plan year, as opposed to at the
time of bid submission.

1 Small, Local, and Disadvantaged Businesses Enhancement Amendment Act of 2006, effective March 2, 2007
(D.C. Law 16-192; D.C. Official Code § 2-218.46).
The Honorable Phil Mendelson
FIS: “Subcontracting Requirements Exemption for Contracts for Health Benefits for District Government
Employees Emergency Amendment Act of 2025,” Draft Bill as provided to the Office of Revenue Analysis on
April 10, 2025

Page 2 of 2

Financial Plan Impact

Funds are sufficient in the fiscal year 2025 through fiscal year 2028 budget and financial plan to
implement the bill. Employee health benefit contract values are not set at the time they are awarded
because the value of the contract is dependent upon enrollment projections for each contractor.
These projections are unknown until the District’s open enrollment period at the end of each calendar
year. The bill allows vendors to submit their subcontracting plans after enrollment project ions are
set and before the plan year starts and still have their initial bids considered. There are no costs
associated with providing this exemption for District government employee health contract vendors.
1350 Pennsylvania Avenue, N.W., Suite 409, Washington, D.C. 20004
Phone (202) 262-6402 Email: adele.el-khouri@dc.gov

GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL

BRIAN L. SCHWALB PRIVILEGED AND CONFIDENTIAL
ATTORNEY GENERAL ATTORNEY-CLIENT COMMUNICATION

LEGAL COUNSEL DIVISION

MEMORANDUM

TO: Tomás Talamante
Director
Office of Policy and Legislative Affairs

FROM: Adele El-Khouri
Deputy Attorney General
Legal Counsel Division

DATE: April 14, 2025

SUBJECT: Legal Sufficiency Review of the “Subcontracting Requirements Exemption for
Contracts for Health Benefits for District Employees Amendment Act of 2025” with
Accompanying Emergency Declaration, Emergency and Temporary Versions
(AE-25-098)
_____________________________________________________________________________________

This is to Certify that the Office of the Attorney General has reviewed the
above-referenced legislation and found it to be legally sufficient. If you have any questions in this
regard, please do not hesitate to call me at (202) 262-6402.

_________________________________
Adele El-Khouri