The 2021 Baseline
The study Frederick already has, and what it obligates the update to do
In 2020 the City retained Griffin & Strong, P.C. to measure whether minority- and woman-owned businesses won City work in proportion to their availability in the regional market. The answer was no: statistically significant MWBE underutilization in all five industry categories, including two categories with zero prime MWBE dollars across five years. The City acted on those findings within months. The update is not a blank page; it is a before-and-after study of the program era the 2021 study started, and it should be held to the baseline's own standard.
2021 City of Frederick Disparity Study, Griffin & Strong, P.C., presented March 2021. Read the full report (237 pages).
What the 2021 study found
Significant underutilization in all five categories. Two of them at zero.
The study measured MWBE availability as the share of ready, willing, and able firms in the market area and utilization as the share of prime dollars in formal awards of $50,000 and over. The disparity index divides one by the other; below 0.80 is the conventional threshold for a substantial disparity. Every category's shortfall tested as statistically significant, and the finding survived a regression analysis controlling for capacity and other race- and gender-neutral factors.
MWBE availability vs prime utilization by category
Share of prime award dollars, FY2014-FY2018
Source: 2021 City of Frederick Disparity Study, chapter availability and utilization narratives and Appendix F.
Official disparity indices, all MWBE
0-1 scale; below 0.80 = substantial. All flagged cells tested significant.
| Category | Prime | Prime + sub |
|---|---|---|
| Construction | 0.70 | 0.74 |
| A&E | 0.39 | 0.70 |
| Professional Services | 0.00 | 0.09 |
| Other Services | 0.24 | 0.24 |
| Goods & Supplies | 0.00 | n/a |
Source: Appendix F, Study Period rows. Goods & Supplies has no prime-plus-sub analysis: the category had no tracked subcontractors.
Group by category
Where the 2021 disparities concentrated
Appendix F's Study Period rows, on the 0-1 index scale the study itself uses. The grid is mostly empty: 21 of the 25 group-by-category prime cells recorded zero MWBE dollars over five fiscal years. The two green cells are the study's two overutilization findings, and one of them is the single dominant firm.
2021 prime disparity indices by group and category
0-1 scale; below 0.80 flags a substantial disparity; significance tested at 95 percent confidence
| Group \ Industry cluster | Construction | A&E | Professional Services | Other Services | Goods & Supplies |
|---|---|---|---|---|---|
| African American-owned | 0.00 | 0.00 | 0.00 | 0.31 | 0.00 |
| Asian American-owned | 8.31 | 0.00 | 0.00 | 0.00 | 0.00 |
| Hispanic American-owned | 0.00 | 0.00 | 0.00 | 0.78 | 0.00 |
| Native American-owned | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 |
| Women-owned | 0.00 | 1.76 | 0.00 | 0.00 | 0.00 |
| Total MBE | 0.86 | 0.00 | 0.00 | 0.31 | 0.00 |
| Total MWBE | 0.70 | 0.39 | 0.00 | 0.24 | 0.00 |
Source: 2021 City of Frederick Disparity Study, Appendix F, Tables F-1 to F-5, Study Period rows. Hispanic American-owned firms in Other Services (0.78) had too few award occurrences to test for significance.
What the City did next
The program era the update must evaluate
The 2021 study did not sit on a shelf. Within nine months the City amended its Purchasing Policies, created a Small Business Reserve and an MWBE goals program, and wrote a yearly effectiveness review into policy. That makes the update an evaluation, not just a remeasurement: which interventions moved participation, for whom, and through which channel.
- Feb 2020
The Board of Aldermen commissions the study: Griffin & Strong, P.C., not-to-exceed $238,000, selected from five responses.
- Mar 2021
Findings presented: statistically significant MWBE underutilization in all five industry categories, surviving regression controls. The study concludes the City has a basis for race- and gender-conscious remedies, limited to the groups with identified underutilization.
- Nov-Dec 2021
Purchasing Policies amended by resolution: a race-neutral Small Business Reserve plus an MWBE program with annual aspirational goals set at the study's measured availability levels, and a required yearly effectiveness review.
- 2022
First annual review: roughly 20 percent of $44M in procurement spend, about $8.8M, reached small, women-, and minority-owned firms; 154 small businesses certified since January 2022.
- FY23-FY25
No public annual effectiveness reviews located, despite the yearly-review requirement the 2021 policies wrote in. Reconstructing these years is the update's first records task.
- Jan 2026
Procurement moves from IonWave to OpenGov. The update's five-year study window will straddle the migration: a data-collection complication to plan for, not discover.
- 2026
The City drafts the RFP for a Supplier Diversity Programs Assessment, Disparity Study, and Strategic Implementation Plan: the update this portal supports (draft under review, no RFP number yet).
The study's availability estimates became the City's goals
The City's annual aspirational MWBE goals match the study's five availability estimates, rounded to whole numbers.
| Category | Measured availability | Adopted goal |
|---|---|---|
| Construction | 41.37% | 41% |
| A&E | 39.89% | 40% |
| Professional Services | 31.59% | 32% |
| Other Services | 29.13% | 29% |
| Goods & Supplies | 15.93% | 16% |
Source: Availability from the 2021 study; goals from the City's current MWBE program materials. The report itself never states the adopted goal numbers; the match, exact for all five categories once rounded, is an inference from reading the two documents side by side.
A close read
What a careful update must reconcile
This review is built from the study's own text and is offered with respect: the 2021 study measured five categories at both prime and subcontract level, ran regression controls, fielded a substantial anecdotal record, and saw its recommendations adopted into City policy within months. The notes below are not criticisms of that work. They are the reconciliation items any update inherits, stated plainly so the work plan can price them.
Two availability series need one reconciliation
The chapter narrative and Appendix F print slightly different availability figures for the same categories: Construction 41.37 versus 41.48 percent, Other Services 29.13 versus 29.14. The deltas are small and change no finding, but the update should publish a single reconciled availability build with its construction documented step by step, so every downstream number traces to one series.
The headline tables are images
The executive summary and chapter tables are embedded as graphics, so their cell values cannot be text-extracted or machine-checked; the group-level record has to be reassembled from Appendix F. The update should deliver every table machine-readable, so the next analyst, or the next courtroom, can recompute rather than transcribe.
The subcontractor layer is the thinnest
FY2018 had zero tracked subcontractors, and Goods & Supplies has no prime-plus-sub analysis at all. The study's own Recommendation 6 called for a relational subcontractor database. Frederick County's March 2026 study shows the stakes: it could not meet the legal threshold for race- and gender-conscious remedies because only 27 percent of primes kept subcontractor records.
Construction's index is a one-firm number
With 96.58 percent of MWBE prime dollars at a single vendor, the strongest category index in the study (0.70) is carried by one firm, and the largest non-MWBE construction vendor took 49.86 percent of construction dollars. The update should publish concentration diagnostics alongside every ratio, so no single vendor can silently carry, or sink, a category.
Thin cells could not be tested
Some group-by-category cells had too few award occurrences to test, such as Hispanic American-owned firms in Other Services. A city of Frederick's size will always produce thin cells; the update should pre-commit its small-sample rules in the methodology, before the data arrive, rather than decide them case by case afterward.
The data are a pre-program snapshot
FY2014-FY2018 closed eighteen months before COVID and three years before the Small Business Reserve and MWBE programs existed. That is not a flaw of the work; it is the definition of a baseline. The update's five-year window is the first measurement of the program era, which is exactly why its data architecture matters more than its ratios.
The obligation
Five questions the baseline leaves open
A rigorous update treats each one as a testable hypothesis, with the method named in advance.
Did participation move toward the goals, and for whom?
The goals were set at the study's measured availability: 41, 40, 32, 29, and 16 percent. The only public figure since is roughly 20 percent of 2022 spend. And because the baseline's totals were carried by one firm, group-level movement is the real question: an MWBE total can rise while African American-, Hispanic-, and women-owned participation stays at zero.
Did the Small Business Reserve create primes?
The SBR reserves the $10,000 to $49,999.99 band for certified small businesses, and 154 firms certified since January 2022. The theory behind the 2021 recommendation was that reserved work grows small firms into primes. That is testable in the City's own award data: did SBR awardees later win formal awards of $50,000 and over?
Is the subcontractor record now buildable?
The baseline tracked zero FY2018 subcontractors. Next door, Frederick County's 2026 study could not support race- or gender-conscious remedies because only 27 percent of primes kept subcontractor records. Whether the City's post-2021 compliance function actually captured subcontracts decides how much of the update's analysis is even possible.
Which barriers persist after the programs?
The 2021 anecdotal record described an entrenched informal network, repeat use of the same firms, unmonitored good-faith efforts, and vendors who did not know Frederick was buying. The update should re-field those same questions and measure movement against the 2021 answers, not just retell them.
What does the record lawfully support now?
The 2021 study concluded the City had a basis for race- and gender-conscious remedies under the case law of its time. The 2023-2026 era, from SFFA to the July 2026 permanent injunction against Houston's MBE program, has tightened what the evidence must show. The update must state what today's record supports, race-neutral measures first, and build the evidence before any remedy leans on it.
The methods behind each question live in the approach ladder and the published data-and-questions inventory.