Preliminary analysis prepared independently by House Strategies Group LLC from public data, for the City of Frederick's supplier diversity assessment and disparity study, RFP-27-08, released August 6, 2026. Not affiliated with or endorsed by the City of Frederick. Every figure carries its source and its limits. Not a procurement-disparity finding.

Module · At no charge, as part of establishing context

The report the City owes itself, drafted, plus the machine that produces the next one

The 1996 plan required annual reporting and produced none in twenty-two years. The 2021 policy requires an Annual Effectiveness Review and has produced one in five. We are drafting the next one at no charge as part of establishing context for this study, publishing the exact data it needs, and providing a working engine so the City can produce it every year without a consultant.

The City owes itself this report and has produced one in five years.

The Disadvantaged Business Enterprise plan adopted in 1996 required annual reporting to the Mayor and Aldermen and produced none across twenty-two years, a gap that surfaced only when the president of the Frederick County NAACP filed Public Information Act requests and was told the records did not exist. The policy adopted in December 2021 requires an annual review of programme effectiveness. One has been published, covering calendar year 2022.

We are drafting the next one at no charge, as part of establishing context for the study. It is not priced, it is not an option line, and it does not change the not-to-exceed. We would rather begin the engagement already knowing what the City's own numbers say.

The engine

Render the draft now

Load our reconstructed award record, or upload your own file matching the schema below. Everything runs in your browser; nothing is uploaded anywhere. Where a file cannot support a section, the engine says so rather than estimating.

What a complete review contains

Eight sections, and which of them public records can already answer

Three of the eight are draftable today from what we rebuilt before award. The rest need records only the City holds, which is precisely why the review has never been complete.

1

Total procurement, and what share reached small, minority and women-owned firms

Draftable now

Draftable now from the reconstructed award record for FY2022 to FY2026, at the Council-approved level only.

Needs: Award or payment file for the period · Vendor identity resolved to a legal entity · Certification status with its basis

2

The same figures at subcontract level

Needs City records

Cannot be drafted from public records, but the City confirmed on 13 August that it tracks subcontractor usage, amounts, payments and certification status. The data exists. It has not been analysed, which is why the review has never been complete.

Needs: Bid-time participation forms · Subcontractor certificates of insurance · Pay applications and lien waivers · Section 1.18 change approvals

3

Small Business Reserve operation: designations, exemptions, and why

Draftable now

The City's own exemption report of September 2023 to June 2025 already carries this: 78 solicitations, 58 exemptions, 7 meeting programme criteria.

Needs: Solicitation register · SBR designation decisions · Exemption requests with stated reason and disposition

4

Goal attainment against the aspirational goals

Needs City records

Requires the City's current goal table, which is not published.

Needs: Current goals by category · Utilization by category from section 1

5

Concentration: how much of the total sits with how few firms

Draftable now

Draftable now. The 2021 study found 96.58 percent of MWBE prime dollars going to a single firm, so this section matters more here than in most jurisdictions.

Needs: Award file with vendor identity

6

Availability, and the gap between availability and utilization

Needs City records

The study produces the availability base. Until then this section can only cite the 2021 figures.

Needs: Availability base from the disparity study · Utilization from section 1

7

Complaints and barriers raised, and their disposition

Needs City records

No intake, triage or disposition record is described anywhere public. Building one is a study recommendation.

Needs: Business diversity inbox log · Protest file · Written comments to Council

8

Year-over-year movement and what moved it

Draftable now

Draftable across FY2022 to FY2026 from the reconstruction, with the caveat that the definitions are ours until City records replace them.

Needs: Prior years on the same definitions

The data

Exactly what the City needs to capture

Seventeen fields. Most already exist somewhere in the City's systems; the subcontract fields are the ones that do not, and are the reason the report has never been whole. Capture these at the moment of award and the review becomes a query rather than a project.

FieldTypeWho holds itWhy it is needed
fiscal_yearintegerFinanceGroups the report and drives the year-over-year section.
solicitation_idtextProcurementJoins the award to the solicitation register, the SBR designation and any exemption.
award_datedateProcurementPlaces the award in the right period and allows certification status to be read as of award.
vendor_legal_nametextFinance / vendor masterEntity resolution. Trade names and d/b/a variants are the single largest source of miscounting.
vendor_uidtextVendor masterA stable identifier so a firm is not counted twice under two spellings.
amount_awardedcurrencyProcurementThe numerator and denominator of nearly every figure in the report.
amount_paid_to_datecurrencyFinanceAward value is not spend. Reporting both is what stops the report overstating.
categoryenumProcurementConstruction, A&E, professional services, other services, goods. Findings are category-specific or they are not defensible.
naics_or_commoditytextProcurementTies utilization to an availability base built on the same classification.
sbr_designatedbooleanEquity & InclusionMeasures how often the reserve was actually applied.
exemption_reasonenumEquity & InclusionThe City already records this. It is the most informative single column in the file.
cert_statusenumEquity & InclusionSBE, MBE, WBE, SDVOSB, none. Never inferred from a name.
cert_basistextEquity & InclusionWhich certifier, which number, which date. A status without a basis is an assumption.
sub_entity_nametextPrime, at bid and at closeoutThe subcontract layer. One row per subcontractor per contract.
sub_amount_committedcurrencyBid participation formWhat was promised.
sub_amount_paidcurrencyCloseoutWhat was delivered. Committed against delivered is the sharpest test the report can run.
sub_cert_statusenumEquity & InclusionOwnership status of the subcontractor, on the same basis rule as the prime.

The benchmark

What everybody else publishes, and where this goes further

Before claiming this is better we went and read what other jurisdictions actually publish. The most demanding benchmark we found is New York City's quarterly M/WBE compliance report, which covers the largest municipal programme in the country. It reports utilization by industry and by contract size band, splits MBE from WBE, and discloses waivers. It is genuinely good on coverage. Across the whole document, however, the word disparity appears zero times, concentration zero times, and availability once.

The omission has a cost, and NYC's own tables show it
The NYC size bands make the omission visible. In construction that quarter, certified firms took 80 percent of micro-purchases by value and 13 percent of the band above $25 million. The aggregate reads 29 percent. They publish the data that would expose the pattern and never compute the measure.
ElementFrederick 2022 reviewNYC quarterly reportThis engine
Aggregate share of spendOne numberYesYes
Broken out by categoryNoYesYes
Broken out by contract size bandNoYesYes
MBE and WBE separatedNoYesYes
Waivers and exemptions, with reasonsNoPartlyYes
Prime and subcontract separatelyNoPartlyYes
Availability reported beside utilizationNoNoYes
Disparity indexNoNoYes
Concentration and dispersionNoNoYes
Committed at bid against delivered at closeoutNoNoYes
New firms entering the vendor poolNoNoYes
Complaints received and their dispositionNoNoYes
Published schema, reproducible from the fileNoNoYes
Stated coverage limits and what it cannot sayNoNoYes

Six of those match the best practice we could find. Eight go beyond anything we found published by any jurisdiction. The two that matter most for Frederick specifically are concentration, because the 2021 study found a single firm holding 96.58 percent of MWBE prime dollars, and new-entrant rate, because that is the direct test of whether an entrenched referral network is loosening. Neither appears in any municipal report we read.

Who does it

Three ways to produce it every year, and what each really costs

Assign it to existing staff

  • Contract Compliance Administrator, Office of Equity & Inclusion — owns the file, runs the queries, writes the narrative
  • Procurement analyst — supplies the solicitation register, designations and exemption dispositions
  • Finance or budget analyst — supplies the payment file and reconciles award value to spend
  • IT or data staff — maintains the OpenGov export that feeds it

Roughly 60 to 80 staff hours in the first year and 25 to 40 thereafter, once the export is standing and the definitions are fixed.

The realistic option, and the cheapest. The reason it has not happened is not headcount, it is that nobody owns the query set. We deliver that.

Procure it annually

  • An external analyst engaged for a short annual assignment

A defined scope of the same 60 to 80 hours, at consulting rates.

Defensible but expensive for what it is, and it recreates the dependency the City is trying to leave behind.

Automate it

  • Whoever maintains the data export

The engine below, pointed at a conforming file.

Right answer once the schema is enforced at the point of award. The report stops being a project and becomes a page.

Why automating it matters more than the report itself
The twenty-two year gap did not surface because someone audited the City. It surfaced because a member of the public asked and there was nothing to hand him. An engine that renders the report from a conforming file means the next person who asks gets an answer the same day, in the same format, computed the same way. That is worth more to the City's legal position than any single finding, because a programme that reports on itself annually and publishes the result is the programme hardest to characterise as unmonitored or open-ended.

Source: The reporting obligations are the City's own, in the 1996 Disadvantaged Business Enterprise plan and the December 2021 purchasing policy. Exemption figures are the City's Small Business Reserve exemption report of September 2023 to June 2025. The demonstration data is HSG's reconstruction of Council-approved awards, which is ours and not the City's, and is used here to show the engine working rather than to state a finding. Prepared 18 August 2026.