Preliminary analysis prepared independently by House Strategies Group LLC from public data, ahead of the City of Frederick's forthcoming supplier diversity assessment and disparity study RFP (draft under review). Not affiliated with or endorsed by the City of Frederick. Every figure carries its source and its limits. Not a procurement-disparity finding.

Module 6 · Benchmarks

A preliminary evaluation of the Maryland disparity-study landscape

Maryland is one of the most studied procurement markets in the country: the state, the county next door, and nearly every large neighboring jurisdiction has commissioned a disparity study this decade. Frederick measured itself in 2021. The studies below show what that crowded landscape has learned, and why the differentiator is no longer measuring the gap. It is explaining it, and building the record that survives.

Who does this work
A handful of firms produce most disparity studies nationally: Griffin & Strong, which conducted the City's 2021 study and Harford County's, alongside MGT, which conducted the state's, Frederick County's, Montgomery County's, Howard County's, Baltimore City's, and WSSC Water's, plus BBC Research, Keen Independent, Colette Holt & Associates, Mason Tillman, and Miller3. House Strategies Group is pursuing the Frederick update directly, as prime, with a modern data and analytics core and an academic bench whose members have led, reviewed, and litigated disparity-study work nationally. The point of the evaluation below is not that these studies are wrong. It is that in a market this thoroughly measured, the next study earns its fee by explaining causes and building the durable record, and the methodological frontier has moved to exactly that ground.

City of Frederick, MD

2021
Griffin & Strong, P.C.FY2014-FY2018 (July 2013 through June 2018); findings presented March 2021

The City's 2021 study found statistically significant MWBE underutilization in all five procurement categories, with MWBE firms at 25.09 percent of prime dollars overall but 96.58 percent of those dollars concentrated in a single firm.

Commissioned in February 2020 at a not-to-exceed price of $238,000, the study analyzed $91.2 million in prime spending across construction, architecture and engineering, professional services, other services, and goods, in a market area drawn to capture at least 75 percent of prime award dollars. Every category showed significant underutilization that survived regression controls; Professional Services and Goods recorded zero prime MWBE dollars across all five years. The anecdotal record described an entrenched informal network and repeat use of the same firms, and the data chapter found FY2018 had no tracked subcontractors at all. The City responded in late 2021 by creating its Small Business Reserve and MWBE programs and setting annual aspirational goals at the study's measured availability levels.

Relevance to Frederick: This is the baseline the City's forthcoming RFP (draft under review) updates. It fixes the FY2014-FY2018 data window, the five-category structure, the availability-based goals, and the data-reform agenda, tracked subcontractors above all, that the update must carry forward.
Preliminary evaluation: A systematic and documented study whose most consequential findings were about the record itself: an unmistakable statistical pattern, an anecdotal chapter matching the network mechanism the leading Fourth Circuit case credits, and a data architecture that could not yet see the subcontract tier. The update's value depends on fixing that architecture, not just recomputing ratios.
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Frederick County, MD (a separate government)

2026
MGTFive years of competitive procurement data; released March 2026

The County's first-ever disparity study found MWBEs at 17.47 percent of available firms but 4.23 percent of competitive spend, a combined index of 24.22, yet the legal threshold for race- or gender-conscious programs was not met because the subcontractor record could not be built.

MGT's $290,626 study, the County's first, found substantial disparity on the conventional index but reported that only 27 percent of prime contractors kept records of their subcontractor dealings, so the evidence a race- or gender-conscious program requires under Croson could not be assembled. The recommendations are race-neutral: a Small Business Enterprise program, improved data collection, simplified processes, and expanded outreach, with the consultant retained for roughly another year on an implementation framework and a task force forming.

Relevance to Frederick: The City and the County are different governments, and this is not the City's study. It is the nearest benchmark and the clearest cautionary tale: a substantial measured disparity produced no conscious-program authority because the data infrastructure was not in place first. The City's own 2021 study flagged the same gap, zero tracked subcontractors in FY2018, which makes data reform the highest-leverage deliverable of the City's update.
Preliminary evaluation: A systematic five-year analysis whose defining lesson is sequencing: evidence must precede remedy, and the record must exist before the study that needs it. The practical takeaway for the City is to treat subcontractor payment capture as a deliverable of the update, not a hope for the study after it.
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Baltimore City, MD

2022
MGT Consulting GroupRetained June 2020; final report August 26, 2022, released October 5, 2022

Baltimore City's study examined minority-, women-, veteran-, disability-, and LGBTQ-owned business categories together and found significant underutilization supporting the City's MWBOO program.

An availability and disparity study across one of the region's largest municipal procurement portfolios, notable for its scope decision: it measured five ownership categories in a single instrument and underpins the Minority and Women's Business Opportunity Office program.

Relevance to Frederick: The scale anchor of the regional set, and a reminder that scope, which certifications and ownership categories a study measures, is a design choice the City should make deliberately in the update rather than inherit.
Preliminary evaluation: A broad-scope study for a jurisdiction with mature program infrastructure. Frederick's portfolio is a fraction of Baltimore's, which is exactly why category and scope design should follow Frederick's own record rather than a big-city template.
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Baltimore County, MD

2021
Mason Tillman Associates, Ltd.July 1, 2012 through June 30, 2017; released March 2021

MWBEs won roughly 9 percent of Baltimore County awards against roughly 38 percent measured availability across the four industries studied.

Mason Tillman's study for Baltimore County measured availability and utilization across four industry groups and reported minority- and women-owned firms winning about 9 percent of awards against about 38 percent availability, one of the widest gaps reported in the Maryland set.

Relevance to Frederick: A second national practice active in the Maryland market, and a gap-size reference point: reported Maryland disparities range widely, which is why each jurisdiction's own record, not a regional average, has to carry its conclusions.
Preliminary evaluation: An award-oriented reading of the gap. The methodological lesson for the update is to report both award counts and dollars, since concentration effects, like the single-firm concentration in Frederick's own 2021 baseline, can make the two tell very different stories.
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Montgomery County, MD

2024
MGT Consulting GroupFinal report September 23, 2024

Montgomery County's 2024 study examined both public procurement and private-sector markets and supports the County's Minority, Female, and Disabled-owned business program.

The final report, dated September 23, 2024, pairs procurement analysis with private-sector marketplace evidence for one of the region's largest county buyers, and it sustains the reauthorization of the County's MFD program.

Relevance to Frederick: The adjacent-county benchmark on the Washington side of Frederick's market. Because the City's 2021 study drew its market area from the Washington-Baltimore-Arlington region, Montgomery's availability geography overlaps the City's, making its marketplace findings a useful external check on the update's availability estimates.
Preliminary evaluation: A full-scope study in the current template. Its function for Frederick is comparative: same regional market, much larger buyer, and a program posture the City can measure its own evidence against rather than import.
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Howard County, MD

2026
MGTLaunched April 2023; released June 2026 (study period July 2018 through June 2023)

Howard County's first-ever study, an investment of more than $400,000, found MWBEs receiving 9.19 percent of contract dollars across five procurement categories.

Structurally the closest recent comparable to a first-cycle Maryland county study: five procurement categories, a five-year window, and a reported investment above $400,000. Released in June 2026, it lands in the same post-SFFA legal environment the City's update will.

Relevance to Frederick: A live price and scope reference for county-scale work in this market, and a timing peer: its implementation phase will run alongside the City's update, giving Frederick contemporary Maryland comparators for goal design and program assessment.
Preliminary evaluation: A current-generation study whose findings are still moving toward implementation. The City's opportunity is to pair measurement with an implementation plan in one engagement, which is precisely what the draft scope's strategic-implementation task does.
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Harford County, MD

2023
Griffin & Strong, P.C.Commissioned 2022; released June 29, 2023 (study period 2017-2021)

Harford County's study led to concrete operational follow-through: eMMA registration pushes, contract unbundling, vendor events, and enhanced outreach.

Conducted by the same firm that produced the City's 2021 baseline, Harford's study is most instructive for what happened after it: the County moved on registration, unbundling, and outreach, the race-neutral operational levers that require no constitutional showing.

Relevance to Frederick: The nearest example of the City's own 2021 consultant working elsewhere in Maryland, and a follow-through benchmark: the value of a study shows up in the procurement operations it changes.
Preliminary evaluation: The post-study action list is the takeaway. The update should treat operational remedies, data capture, unbundling, outreach, and payment discipline, as first-class deliverables with owners and dates, not an appendix.
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State of Maryland

2025
MGT (with ARG and Chrysalis)Statewide MBE program study; reauthorization effective June 1, 2026

The statewide study found minority firms at 26.1 percent availability against 15.2 percent of award value, a gap it called large and statistically significant, and it carried HB 1578's reauthorization of the MBE program through July 1, 2031.

The General Assembly rested the 2026 reauthorization on this study, and the statute codifies race-neutral-first: race-neutral efforts are to be used to the maximum extent feasible. Statewide MBE participation ran 22.0 percent in FY2024 against the 29 percent goal, and the next statutory analysis is due September 30, 2030.

Relevance to Frederick: The legal weather for every Maryland jurisdiction. Croson still requires Frederick's own record, so the state study is context, never the basis. But its race-neutral-first codification and its fixed re-study clock are the environment the City's update will be read in.
Preliminary evaluation: A statewide instrument built for a statute. The discipline it models, race-neutral measures first, explicit significance language, and a scheduled re-study cadence, maps cleanly onto what a defensible city-scale record needs.
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Maryland DOT (federal DBE program)

2018
MDOT disparity study seriesFederal DBE goal-setting regime, before the October 2025 interim final rule

MDOT's 2018 DBE disparity study, the most recent completed federal-side study found, belongs to a regime that changed fundamentally in October 2025, when USDOT removed race- and gender-based presumptions.

The 2018 study (volumes 1 through 3, following a 2013 predecessor) supported MDOT's federal DBE goal-setting. In October 2025 a federal interim final rule removed the DBE program's race- and sex-based presumptions, and certifying agencies are re-evaluating certified firms. Litigation challenging the prior regime was dismissed as moot in March 2026 after the rule change.

Relevance to Frederick: A boundary marker for the update: federal DBE and local MBE evidence are different legal lanes, and the federal lane's presumptions no longer exist. The City's study should keep DBE and MBE certification data strictly separate and never rest a local program conclusion on the federal regime.
Preliminary evaluation: Its usefulness now is cautionary and architectural. A defensible city study treats federal-lane data as context and as a data-hygiene checklist, not as support for any local race-conscious design.
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WSSC Water (bi-county utility)

2022
MGT Consulting Group, Inc.FY2015-FY2019; results presented January 2023

WSSC Water's study covered FY2015 through FY2019, and the utility has since reported FY2024 MBE spend above $173 million, about 34 percent.

The bi-county water utility's study was presented in January 2023 and approved by its commissioners. WSSC's reported FY2024 MBE utilization of roughly 34 percent is among the strongest reported figures in the region.

Relevance to Frederick: A special-purpose buyer in the same regional market showing what sustained program operation looks like on the utilization side. For the City it is a reference, not a target: utilization follows availability and program design, and Frederick's own availability estimates have to set Frederick's goals.
Preliminary evaluation: The pairing of a study with visibly reported annual utilization is the practice worth importing. Frederick's 2021 programs require yearly effectiveness reviews, and only the 2022 review is public; a published annual number is itself a program deliverable.
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City of Asheville, NC (pop. ~94,000)

2024
Miller3 ConsultingKicked off October 2022; report delivered 2024

Asheville, a city of about 94,000, paid $321,748 for its most recent disparity study.

One of the two closest small-city price comparables in the recent record: a population similar to Frederick's, a national consultant, and a contract price about a third above the City's 2020 anchor of $238,000.

Relevance to Frederick: Price calibration. Small-city full studies have recently run from the low $300,000s upward, and Frederick's forthcoming scope adds a supplier-diversity program assessment and a strategic implementation plan on top of the study itself.
Preliminary evaluation: A standard-template small-city engagement. The comparison suggests the market has repriced since 2020, and that scope, not city size alone, should drive the City's budget expectations.
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City of Greenville, NC (pop. ~92,000)

2025
Miller3 ConsultingApproved January 2025; 18-month term

Greenville and its utilities commission jointly approved $460,098 for a disparity study, with the utility contributing $100,000.

The most recent small-city price point in the record: a joint city and utility engagement at $460,098, of which the Greenville Utilities Commission contributed $100,000, putting the city's own share near $360,000.

Relevance to Frederick: The upper edge of the small-city price band. Together with Asheville and the City's own $238,000 anchor, it frames the honest budget conversation for a scope that now includes program assessment and implementation planning.
Preliminary evaluation: Evidence of where small-city pricing has moved, and of joint-funding structures worth noting wherever a jurisdiction shares buyers or infrastructure with a utility or authority.
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Why the method matters in Maryland

The controlling appellate case already drew the line, here

H.B. Rowe Co. v. Tippett, 615 F.3d 233 (4th Cir. 2010) is the leading federal appellate treatment of a disparity-study record, counsel on our bench litigated it, and Maryland sits in the Fourth Circuit, so it is controlling law for Frederick, not merely persuasive. The court upheld race-conscious contracting measures only for the groups the evidence actually supported, and struck them down where the record lacked statistically significant, properly controlled findings. Its central holding credited evidence of an informal, exclusive network, which is the same mechanism the City's own 2021 study described in its anecdotal chapter. A disparity study that holds up in Frederick is the one built, from the first design choice, to clear that bar. Every improvement below is made for exactly that reason.

The methodological frontier

Where our method goes further, and is more legally defensible

Each row pairs a common limitation of the published studies with what House Strategies Group would do instead, why it produces a more defensible result, and a documented example from the case law and the research where that limitation has surfaced. These are not hypothetical concerns.

Common limitation

Availability is often an equal-weight count of firms in a geography, which inflates the denominator with firms that never bid or cannot perform.

Our method

A ready, willing, and able custom availability survey, anchored to actual public-work registration and bid behavior, not a raw headcount.

Why it is more defensible

Defeats the inflated-availability attack, the most contested step under Croson, by measuring the pool a court actually recognizes.

In the record: research by George R. La Noue (University of Maryland, Baltimore County) finds studies routinely count firms that never bid or lack the capacity to perform, inflating the pool the comparison rests on.
Common limitation

A raw availability-to-utilization ratio is treated as a finding, with no control for the legitimate factors that also drive who wins work.

Our method

Controls for firm size, age, experience, and capital, plus a private-sector but-for regression, so a gap is reported as a barrier only when it survives those controls.

Why it is more defensible

Separates a barrier from a capability difference, which is the core of a strong-basis-in-evidence showing and the gap critics most often exploit.

In the record: in H.B. Rowe Co. v. Tippett, 615 F.3d 233 (4th Cir. 2010), the leading federal appellate treatment of a disparity-study record, the court struck the contracting measures for the groups whose findings were not backed by controlled, statistically significant evidence.
Common limitation

A single headline index can mask which specific groups and categories the evidence actually supports.

Our method

Group-by-category findings with significance testing on every cell, remediated only where the evidence holds.

Why it is more defensible

Matches H.B. Rowe, which upheld measures only for the groups the record supported and struck them where it did not.

In the record: H.B. Rowe upheld remedies for African American and Native American firms but struck them for Asian, Hispanic, and women-owned firms, and Croson warned against treating unlike groups as one.
Common limitation

Anecdotal evidence is sometimes anonymous, unverified, and self-selected.

Our method

A verified, attributed, and retained anecdotal record, with structured instruments and a documented protocol.

Why it is more defensible

Meets the corroboration courts require and survives the discovery that has undone studies whose underlying records could not be produced.

In the record: La Noue's congressional testimony warns that anonymous or unverified anecdotes cannot, on their own, sustain a race- or gender-based preference.
Common limitation

The deliverable is frequently a static PDF, and the underlying data and code are not published.

Our method

Published data, documented model specifications, and a live, interactive, Section 508-compliant platform delivered to the City.

Why it is more defensible

Makes the strong-basis-in-evidence showing auditable and reproducible, the failure mode that sank disparity evidence in other jurisdictions.

In the record: La Noue documents disparity-study litigation in which a regression analysis could not be reviewed (Montana) and a consultant could not produce its underlying data (Shelby County, Tennessee).
Common limitation

Recommendations can be boilerplate, leading with race-conscious goals.

Our method

Race-neutral, opportunity-focused remedies first, with race-conscious measures reserved for the narrow, significant, group-specific gaps neutral tools cannot close.

Why it is more defensible

The narrow-tailoring discipline Croson and 49 C.F.R. 26.51 require, and the posture most durable after Students for Fair Admissions.

In the record: Croson and 49 C.F.R. 26.51 require race-neutral measures be considered first, and La Noue documents the institutional pressure on for-profit firms to find disparity rather than test for it.
The common thread, read honestly
Across every study in this landscape, minority- and women-owned firms are a substantial share of the available market and a smaller share of the dollars. Frederick's own 2021 measurements ran from an index of 0.70 in construction down to 0.00 in professional services and goods, and the county next door measured a combined index of 24.22 on the conventional 100 scale in 2026. A gap is a question, not a verdict. The value of the update is in measuring the City's gap correctly, explaining what causes it, and leaving behind the data architecture, tracked subcontractors above all, that lets the answer hold up.

See the approach behind these claims

The methodology page draws the line between what public data can show and what the full study adds. The approach module sets out how we move from a measured gap to its cause.