A trashcan with the Department of Small and Local Business Development's logo on it
The Department of Small and Local Business Development is facing a variety of questions about its management of the Main Streets program. Credit: Alex Koma

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This story was supported by a grant from Spotlight DC—Capital City Fund for Investigative Journalism.

Elizabeth Anderson can be a big help if you run a small business in D.C.

Her company, Cadogan & Associates, specializes in helping new firms get off the ground, particularly if they’re looking to do business with the District government. She can help your company find D.C. grants and contracts to bid on, provide technical support should you win that work, and even shepherd through your application to become a “Certified Business Enterprise,” a designation that gives your business a leg up at winning more government contracts in the future. In fact, D.C.’s Department of Small and Local Business Development once proclaimed Anderson’s firm its “CBE of the Year” in recognition of that work.

So why is Anderson so good at what she does? For one thing, she also happens to be a D.C. government employee.

Since July 2020, Anderson has simultaneously run her consulting business while working for a pair of government agencies. She first joined DSLBD and then moved over to the Office of the Deputy Mayor for Planning and Economic Development, all while working with companies and nonprofits that do business with DSLBD and other government agencies, a DMPED spokeswoman confirmed following City Paper’s investigation of the matter.

Her business has won at least $1.5 million in contracts and grants from the city over the past six years, and City Paper uncovered at least two instances where Cadogan & Associates earned D.C. funding while Anderson herself simultaneously drew a government salary. Several people who interacted with Anderson before she joined DSLBD describe a culture where D.C. officials appeared to routinely favor her company in awarding government work, though it’s unclear whether that practice has continued since she became a government employee. Anderson declined to comment for this article and deferred questions to DMPED.

Incredibly, none of this is illegal. D.C. employees are allowed to operate side businesses, per the D.C. code, so long as they disclose those interests and work to keep their public and private roles fully separate. DMPED spokesperson Natalia Vanegas says Anderson has met those requirements. The main grant Anderson’s company has managed since she joined the government comes from another agency, the Department of Energy and Environment, so Vanegas says Cadogan & Associates has been allowed to continue drawing those funds since Anderson pledged to “play no role” in directing how they’re used.

But it is difficult to believe that Anderson could completely exclude herself from that part of her business considering the small size of her company, which appears to be headquartered at her home in Northeast. Ethics experts believe she is essentially complying with the letter of the law, but not its spirit. 

“She is just barely skirting around the conflict of interest laws,” says Craig Holman, a lobbyist with the watchdog group Public Citizen, who has helped draft many of the D.C. Council’s recent ethics reform bills. 

The most charitable possible explanation here is that Anderson honed an expertise working with small businesses in her private career, making her a natural fit to come back into government, so long as she’s following all the applicable rules. But some in D.C.’s small business community see Anderson’s story as indicative of problems within Mayor Muriel Bowser’s administration, specifically at DSLBD and its Main Streets program, which is designed to build up commercial corridors and help local companies. Some businesses and nonprofits have accused the agency of playing favorites by directing lucrative deals to the same handful of favored bidders and ignoring their mistakes (or instances of potential fraud, in two cases). They see Anderson and her side gig as part of this pattern. First, she got close with DSLBD officials, and her company repeatedly benefited from that association. Then she won the benefit of the doubt from those same officials about her potential ethical conflicts once she entered government.

“This all doesn’t tie only to Liz, it’s more an overarching critique of DSLBD as a whole,” says Brianne Dornbush, the head of District Bridges, a nonprofit that has won six Main Street grants and worked repeatedly with Anderson in both her public and private roles.

A DSLBD spokesperson did not return requests for comment for this article. The agency remains under investigation by D.C.’s Office of the Inspector General for its handling of the Main Street programs, which Anderson was closely involved with, following allegations from Dornbush and the former head of the Upper Georgia Avenue Main Street, Jackson Carnes. The OIG has already determined that the Main Streets are “highly susceptible to fraud, waste, and abuse,” but it won’t issue a full report on its findings until later this year.

A full service firm

Anderson got her start in District government back in 2014, according to city records, working for the Office of Contracting and Procurement. (Back then, she used the name “Elizabeth Cadogan” or “Elizabeth Anderson-Cadogan,” appearing to take her husband’s last name before later reverting to “Elizabeth Anderson.”)

She rose up the ranks from a public affairs specialist to a business engagement manager at the agency, which manages city contracting across the entire District government. She took what she learned at that job and struck out on her own in 2016, according to her company’s website. 

Cadogan & Associates, which also does business as “C&A Global Consulting” after a recent rebranding effort, makes it clear on its website that it can help companies do business with the government. Click on the “government solutions” tab, and you’ll find the site touting the company’s experience working with “multiple state and local government agencies on various projects across different sectors.” It adds that the firm “can assist you in getting certified as a small/minority/women/veteran-owned business on a local state and/or federal level,” and “can help you properly register your new business in your home state.” The firm also touts its experience with grant and contract management, noting the company can “handle everything from compliance and invoicing to drafting progress reports, subcontractor administration, and more.”

Though many references to the company’s specific D.C. experience appear to have been removed, including which Main Street organizations the company counted as clients, an archived version of the site from earlier this year shows it boasting of the firm’s experience working with “government agencies and nonprofit organizations in supporting Washington D.C.’s most underserved communities.”

Anderson herself was more specific about her company’s capabilities when she testified about several bills affecting city contractors in a November 2017 hearing convened by the Council’s Committee of the Whole. She told lawmakers that her firm “specializes in helping small, underserved, and underrepresented business owners navigate state and local grants and government contracts” and has a “long standing relationship with government and private grantors,” as she tried to outline why the Council should take her views on the legislation seriously.

Elizabeth Anderson testifies at a 2017 D.C. Council hearing on procurement. Credit: D.C. Government

“One of the most utilized services that my business provides for clients is a daily search of all the [city’s] contracting and procurement sites,” Anderson told the committee. “It often takes my team hours to comb through the vast list of solicitations and, for small businesses, with one or two members, it is impossible to find all the opportunities without [them] being in one location …We search the sites every single day.”

Plainly, Anderson had intimate knowledge of how to win business with the city, and used that knowledge to emerge as a successful consultant. According to documents released to City Paper in response to a public records request, she became especially adept at helping nonprofits who wished to compete for and then manage “Main Street” grants handed out by DSLBD. 

The purpose of the $5 million Main Streets program is to establish hyperlocal neighborhood advocacy organizations that will build up small businesses and enliven retail corridors across D.C. DSLBD awards grant funding to a nonprofit organization to set up each Main Street, then those groups hire staffers to manage day-to-day operations. Essentially, Main Streets are meant to act as a civic backbone of sorts, putting on local events or helping to publicize and support small businesses in each neighborhood.

Each Main Street is generally a pretty lean organization, with an executive director and perhaps a few support staff, but not much else. That’s where Anderson and her company come in.

Emails and documents show that Anderson inked some contracts directly with nonprofits running Main Streets. For instance, Cadogan & Associates agreed to a $19,610 consulting deal with the Ward 7 Business Partnership in June 2017 to help it manage events funded by a Main Street grant. On other occasions, DSLBD would hire her firm directly to offer training sessions or consulting services to the Main Streets.

In October 2017, Cristina Amoruso, DSLBD’s Main Streets coordinator, wrote to Anderson alerting her that she’d “gotten the green light to request proposals for training” for Main Street staffers, according to emails released via the records request. She outlined a variety of courses Anderson might be interested in applying for based on her firm’s work, and followed up again in November 2017 with other areas where Anderson might be well-suited for the RFP the agency planned to release. 

Anderson would eventually apply for and win the chance to lead these programs, the emails show. Anderson and Amoruso also discussed the possibility that Anderson’s firm could help new Main Street programs with fundraising in a series of workshops. Amoruso assured Anderson in a March 2018 email that “I don’t need anything complicated” in an application to receive this grant money. She merely needed someone to “meet with the four [Main Street programs] ASAP to help them develop their funding plans.” Cadogan & Associates picked up that bit of business shortly after that exchange, winning a roughly $16,000 deal.

‘I can’t think of one thing Liz doesn’t do well!’

Nonprofits in the Main Streets orbit say it shouldn’t come as a surprise if this discussion of business opportunities between a government official and a potential contractor does not feel like a traditional, neutral procurement process. Dornbush, who operates several Main Street grants, says Anderson’s company was one of several that DSLBD relied on over and over to assist Main Street programs in this time period, making her wonder whether it was truly a “competitive process” to win this work. 

She says Amoruso repeatedly directed District Bridges staff to receive trainings from Anderson, with DSLBD setting aside money for these services out of each Main Street program’s grant. Other repeat contractors included the Center for Nonprofit Advancement, which is the same organization that Carnes accused of benefiting from DSLBD’s favor by avoiding consequences for financial irregularities. DSLBD’s records show that the CNA also managed trainings for Main Street programs around this time.

“There was just no transparency for us in terms of how these contracts were awarded or competed,” Dornbush says.

Dornbush adds that some frequent DSLBD contractors were quite helpful, citing the market studies prepared by Jon Stover & Associates (which, the emails show, the agency relied on frequently to support the Main Streets program). Anderson’s company, by contrast, offered “very basic advice” and seemed to be “just working off a template” of standard nonprofit fundraising practices, without details specific to the Main Streets, Dornbush says.

“She suggested a gala for us, even though we were in no position to run one,” Dornbush says. “She was also pushing a direct mail campaign to raise money, but I’ve never seen one that’s not a waste of money. And these are taxpayer dollars here … It just felt like DSLBD was making decisions based on who they know and have worked with versus somebody who is an expert in this area.”

Dornbush mainly felt as if DSLBD was forcing her nonprofit to work with Anderson, even though she would’ve rather seen the grant money spent elsewhere. 

Emails from this time period make it clear that DSLBD was not shy about ensuring that Main Streets worked with Cadogan & Associates. Amoruso assured Anderson in a January 2018 note that “all executive directors from the new and newer Main Street programs will be required to attend” the fundraising workshops that Cadogan and CNA were about to host. A month later, Amoruso recommended that another Main Street director meet with Anderson, commending her as “amazing” multiple times. 

“Honestly, I can’t think of one thing Liz doesn’t do well!” Amoruso wrote in the Feb. 9, 2018, email.

This work with the Main Street programs appears to have been just one part of Anderson’s business. The emails released in response to City Paper’s Freedom of Information Act request also show Anderson acting as a CBE sherpa, helping small businesses interface with DSLBD and other city agencies that review these applications. The CBE program has faced criticism for many years now (with large, politically connected companies frequently gaming the system with few repercussions), but at its best, it can ensure that small, D.C.-based companies benefit from government contracts. 

The problem is that winning CBE certification can be a complex and “lengthy process,” as Cherie Lester, a consultant to a pair of Main Street programs, lamented in a July 2018 email to Amoruso and other officials. Luckily, Anderson was on the case. “She feels confident this [application] will work out,” Lester wrote. (That confidence aside, the emails also show that Amoruso checked in with her DSLBD colleagues about Lester’s application and noted that some Main Street programs had already counted her as a CBE to meet city requirements for small business contracting, even though her application wasn’t finished. The city’s CBE database currently shows Lester’s firm fully registered through 2024, so Anderson’s efforts must’ve been successful.)

Anderson even counts among her clients one of the city’s more prominent local entrepreneurs: Ian Callender, the sneakerhead behind the slew of Sandlot pop-up bars cropping up in D.C.’s vacant lots as well as the Suite Nation events design firm. In a June 2021 email to Amoruso and DSLBD Director Kristi Whitfield about a collaboration with his firm, Callender recalled that Anderson was “phenomenal in helping me secure my CBE back in the day.” He didn’t respond to a request for comment for more detail.

Generally, Anderson seems to have benefited greatly in her private career from the strong ties she built with DSLBD officials. There’s nothing inherently wrong with that sort of relationship—perhaps the agency saw her services as being so valuable that it was worth repeatedly relying on her company. But DSLBD’s critics believe it is also a clear sign of the agency’s insular thinking: driving work to the same small circle of contractors regardless of complaints about their methods. In such an environment, they say it makes sense why the agency did not rush to force Anderson to abandon her private business once she rejoined the government, given its value to DSLBD. 

Going public

On July 21, 2020, Amoruso sent an email to Main Street directors and DSLBD staff with “the big announcement you all have been waiting for.” 

Anderson was joining the agency as its Main Streets grants manager, and “we are tickled pink” about that fact, Amoruso wrote, per the announcement forwarded to City Paper. (“Tickled pink” was both italicized and highlighted in a bright shade of that color, to drive that point home).

Both Dornbush and Carnes, the ex-Upper Georgia Avenue director turned whistleblower, say they remember encountering Anderson frequently after she joined the agency. She often worked with the programs as they managed their city grants, just as she once did as a consultant. Emails released via a separate FOIA request show Anderson working with Main Streets and their nonprofit backers to track down and log their expenses, or help run some of their programs (correspondence from last year suggests she was the department’s “point person” for the city’s popular “Art All Night” event, for instance). 

Carnes says Anderson was also among the DSLBD officials who he notified about alleged financial irregularities at the Center for Nonprofit Advancement, which backed his Main Street program. He believes the organization’s CEO, Glen O’Gilvie, would charge unwarranted expenses to the grant or pull away Main Street money without his permission among other improper financial practices (allegations O’Gilvie has uniformly denied), and the emails show Anderson working with Amoruso to try and verify Carnes’ claims. DSLBD ultimately wrote a letter late last year identifying “deficiencies, weaknesses and shortcomings” in the center’s management structure, but said it found no evidence of executives committing any fraud.

As Anderson was doing this work, it appears her own company (which shares clients and functions with CNA) was operating like normal. Anderson posted on her company’s Facebook page that it would be rebranding as “C&A Global” on Aug. 18, 2020, just weeks after she joined DSLBD. A video attached to the post explains (via a slightly unsettling computer-generated narrator) that the new name “more accurately reflects what the company stands for,” as it had recently added “international clients” to its portfolio.

But Anderson wrote that she looked forward to “keeping her followers updated on opportunties [sic] and resources,” and the account posted a link to a small business conference a few weeks after that announcement before going dormant. 

Vanegas, the DMPED spokesperson, says Anderson detailed her business activities once she joined DSLBD. Specifically, Anderson told agency officials that her company received a $1,000 “microgrant” from DMPED on July 6, 2020, as part of the agency’s pandemic relief efforts, as well as a $45,600 grant from the Department of Energy and Environment on June 17, 2020. (Those awards came just a few weeks before she was hired at DSLBD.)

“The DOEE grant was competitively awarded to provide educational programming to promote pollution prevention practices among students,” Vanegas wrote in an email. DOEE did not respond to requests for comment, but the grant appears to be for something called the “GreenWrench Education Project,” based on documents the agency provided to the D.C. Council ahead of oversight hearings.

“The goal of the project is educate automotive technical students (high school age and up) studying to be automotive mechanics in the District of Columbia, on federal regulations, EPA compliance objectives and the importance of working with federal and local regulatory bodies in regards to best practices for waste reduction while doing automotive repairs,” DOEE wrote in the documents.

Other agency documents show Anderson’s firm was awarded another $29,600 when the grant was renewed in October 2021, and Vanegas says it was amended once again in September 2022 to add another $20,000 worth of work and extend the grant period through December. Additional amendments brought the total grant amount to $100,875, she says.

She says Anderson sought ethics guidance from both DSLBD’s lawyers and the Board of Ethics and Government Accountability on how to handle this situation, and they informed her “that her company was not prohibited from contracting with the District so long as she played no role in the contract—including meeting with District government employees regarding the work, negotiating the terms of the contract, and attending related meetings.” 

“To our knowledge, the employee has abided by this guidance,” Vanegas wrote, adding that “to our knowledge, the employee’s company has not pursued a new District government grant or contract since she has been an employee at DMPED or DSLBD.” Anderson applied for a transfer over to DMPED and received one in December 2021, Vanegas said. She now works as “retail small business director” for the Great Streets program, which hands out grants directly to small businesses to improve commercial corridors. 

‘Porous’ ethics

But there are some major questions left unanswered by the government’s assurances.

For starters, it’s worth noting that Cadogan & Associates is a very small company, so it’s unclear how it could manage this grant without Anderson’s involvement. Emails from the past few years make reference to just one other employee at the firm, a “director of business development,” who appears to still work there, per her LinkedIn profile. When Cadogan & Associates applied in June 2020 for a Paycheck Protection Program loan (a pandemic-inspired program to save jobs), it reported having just a single employee. (The company eventually received a $12,000 loan that was subsequently forgiven.)

Vanegas said that Anderson “has designated another point of contact responsible for handling this work” to DOEE, but did not provide additional details. 

The extent of the company’s business with the government during Anderson’s time as an employee is also unclear. D.C. records show that her firm held a $500,000 contract with the Office of Contracting and Procurement when she joined DSLBD in 2020, though there are scant details about what work that entailed. Vanegas says this was a “indefinite delivery indefinite quantity” contract, which are designed to give small firms like Anderson’s the opportunity to compete for District contracts without guaranteeing it will receive money. And “no purchase orders have ever been issued related to this” contract, Vanegas says, so Anderson’s firm was not actively doing work for the government when she was hired. 

The Cadogan & Associates website also listed work it performed for DSLBD, the Department of Housing and Community Development, and the Department of General Services among examples of its past performance on government contracts, but it does not specify whether that business took place before or after Anderson’s hiring. Spokespeople for those agencies didn’t answer questions about their interactions with the firm.

Add it all up, and while this might seem a bit messy, it appears to all be above board. Sure, one could argue that it’s a conflict that Anderson worked with officials reviewing CBE applications as she ran a business helping expedite those same applications. But that set-up was technically legal, as her role at DSLBD involved grantmaking, not CBE certifications.

Similarly, Anderson holding a role within the government might seem to give her one heck of a leg up when it comes to winning public money. But so long as she didn’t have a direct role in handing out those grants to her own company, she’s in the clear. (Ethics experts note that the city has, however, strictly enforced its rules in this area of the law, fining a Department of Health employee in 2021 after she awarded a grant to a university where she also worked as an adjunct professor). 

Holman, the Public Citizen lobbyist, notes that “disclosure” of these potential conflicts is pretty much the only tool the city has to guard against abuse. And Vanegas says Anderson filed the required financial disclosure statements when she joined DSLBD and then DMPED.

Many of those forms are available on a city website for all to see. But Vanegas says Anderson qualified as a “confidential” filer when she joined DSLBD—BEGA only requires employees to make these forms available to the public if they make more than roughly $119,000 annually. Anderson made $90,500 when she joined DSLBD, then got a raise to $115,000 when she moved over to DMPED, per agency rosters submitted to the Council. City Paper has filed a FOIA request for her forms, but the city is still processing it, missing an Oct. 24 deadline to fulfill it.

Anderson’s case is a good example of how “current conflict of interest requirements when it comes to government contracts are fairly porous,” Holman says. Critics of DSLBD, in particular, believe it’s also indicative of cultural problems within the agency that it would hire Anderson even as she ran a favored government contractor. Carnes remembers being shocked when he discovered her dual roles (and was similarly surprised when she got a five-figure raise for what seemed to him to be a “lateral move” over to DMPED).

Dornbush has long been critical of the agency, and believes it’s strayed from its mission of helping the sort of small businesses and nonprofits that she works with on a daily basis. To her, Anderson’s favored status within the agency is just more evidence about the need for major changes there.

“The goal is to get the most money into the hands of small businesses and help the vitality of commercial corridors,” Dornbush says. “But is that really happening?”