The Programs
What the City built after 2021, and how an assessment would test it
The City's forthcoming RFP (draft under review) is not only a disparity study. Its Task 3 makes the engagement equally a supplier diversity programs assessment, with its own task and its own 20 percent payment milestone. Frederick earned that scope: within months of the 2021 study, the City adopted MWBE aspirational goals, a Small Business Reserve, annual review requirements, and a dedicated compliance role. Those programs are now four-plus years old. This page maps each one, states what the public record shows about performance, and lays out the assessment framework HSG would bring on day one.
Built from the City's program pages, the 2026 MWBE/SBR forms, the 2021 study, and press coverage of the 2022 annual review. Where sources differ, the difference is stated, not resolved.
The architecture
Six program elements, adopted within months of the study
Purchasing Policies amended by resolution of the Mayor and Board of Aldermen in the November to December 2021 window, within months of the study's March 2021 presentation. The amendments created the MWBE program and the Small Business Reserve and required yearly effectiveness reviews of both.
Adopted aspirational goals vs measured availability
The five MWBE goals sit at the 2021 study's availability estimates, rounded
Source: The City's 2021 study (Griffin & Strong, P.C.), availability by category; City MWBE program pages, adopted goals. The study never states the adopted goals; the match is an inference from the two documents read together.
Why this chart is nearly two identical bars
The City set its aspirational goals at the availability levels the 2021 study measured, rounded to whole numbers. The study report itself never states the adopted goals; the match is an inference from reading the report and the City's MWBE program pages together. Goals calibrated to measured availability are the defensible design. The assessment question is whether utilization has walked toward them since.
MWBE aspirational goals
Annual aspirational goals in five procurement categories, set at the availability the 2021 study measured. Eligibility is 51 percent or greater ownership and control by socially and economically disadvantaged individuals, with certification through MDOT or an approved certifying agency.
Goals set at measured availability are well calibrated on paper. The assessment tests whether utilization has moved toward them, category by category, using the City's own award and payment records since 2022.
Contract-specific construction goals
For construction contracts over $250,000, the City sets contract-specific MWBE goals based on scope and subcontractor availability. The police headquarters project carried a 40 percent MWBE design goal, achieved, and a 41 percent construction goal, still pending at the 2022 review.
Contract-specific goals only bind if attainment and good-faith efforts are verified through closeout. The public record shows goals being set; it does not show a goal-attainment ledger. The assessment asks where that ledger lives and what it contains.
Small Business Reserve
Per the City's 2026 MWBE/SBR form, professional and other services purchases from $10,000 to $49,999.99 are reserved for certified Small Business Enterprises, and above $49,999.99 the Contract Compliance Administrator assesses SBE availability and may include the purchase in the reserve. The City's web pages and 2023 press coverage describe the program in different terms: a reserve applying to procurement over $10,000, a construction reserve for projects under $250,000, and a requirement that the SBE self-perform at least 50 percent of the work.
The 2026 form and the City's public pages describe the reserve's band and terms differently. That is a documentation-consistency question, stated here neutrally: the assessment would reconcile both against the adopted policy text. Catching this kind of drift is exactly what the yearly effectiveness review was built to do.
Certification recognition
SBE eligibility runs on SBA size standards, with SBA certification, MDOT, USDOT, or City self-certification accepted. For MWBE status the City recognizes MDOT certification or an approved certifying agency, and it hosts free MDOT certification workshops for local firms.
Multi-pathway recognition lowers the cost of entry, which is the right instinct. The assessment tests reciprocity in practice: how long each pathway takes, where applications stall, and how the City keeps MWBE records separate from federal DBE records after the 2025 federal rule changes.
DEI Advisory Board annual review
Resolutions 20-15 and 20-17 of 2020 charge the Diversity, Equity and Inclusion Advisory Board with reviewing the City's procurement policy annually for MWBE participation, impact, dollar value of contracts awarded, and compliance. The board is chaired by Lucien Metellus and meets four to six times a year.
The governance structure for annual accountability exists on paper. The assessment asks what the board has actually received each year since 2022, in what form, and whether its reviews reach the public.
Compliance staffing
A dedicated Contract Compliance Administrator, a credentialed supplier-diversity professional, reviews MWBE documentation and certifications, working alongside a triple-certified Purchasing Manager and a Manager of Equity and Inclusion. This answers the 2021 study's first recommendation directly: staff the compliance function.
The seats are filled, and they sit in three different offices: Purchasing under Budget and Administration, Equity and Inclusion under the Mayor's office, Contract Compliance under Economic Development. The assessment maps who owns which decision, where the data hands off, and where handoffs can drop it.
The performance record
One strong annual review, then public silence
The first annual effectiveness review, covering 2022 and presented at a Mayor and Board workshop, is the only public performance record of the programs located to date. Its figures are specific and creditable, which makes the silence after it the finding.
The 60 exemptions of 2022, by stated reason
Source: First annual effectiveness review, 2022 data, as reported in press coverage of the Mayor and Board workshop.
No public annual reviews after 2022
The policy requires yearly effectiveness reviews, and the 2022 review happened and was covered in the press. No published FY23, FY24, or FY25 review was located on the City site or in news coverage. Later reviews may well exist as internal workshop materials; the public record does not show them.
No utilization dashboard, despite the platform to build one
The City invested roughly $275,000 in OpenGov procurement and budgeting software and already collects vendor classification at registration. No public MWBE utilization dashboard exists. The gap between the data the City holds and the data the public sees is an implementation deliverable waiting to be claimed.
The MWBE function spans three offices
Purchasing sits under Budget and Administration, Equity and Inclusion under the Mayor's office, and Contract Compliance under Economic Development. Capable people hold all three seats. The structural question is where accountability for program data and reporting consolidates, especially with the executive-sponsor lane in transition since June 2026.
The study period will straddle a platform migration
The City moved from IonWave to OpenGov Procurement effective January 1, 2026. The update's five most recent fiscal years therefore span two systems of record. Joining awards, payments, and vendor classifications across that seam is a data-collection task the work plan must name and resource on day one.
The Task 3 framework
Ten elements, tested against evidence, ending in deliverables
The draft RFP's Task 3 lists the program elements the assessment must cover. For each element, this grid states what HSG would test, what evidence is public today, and what the update should leave behind. No other bidder arrives with this map already drawn.
Policies
- What we test
- Reconcile the adopted policy text against the published program pages and the 2026 MWBE/SBR forms, including the reserve band, self-performance terms, and thresholds.
- Public evidence today
- The 2021 amending resolution (in meeting records), the City's program pages, and the 2026 form, which describe the SBR in different terms.
- What the update should deliver
- A single reconciled policy text and a change-control rule so forms and web pages track the policy as it evolves.
Outreach
- What we test
- Whether outreach converts: which certified and self-identified firms actually bid, and whether workshops and registration drives translate into bids and awards.
- Public evidence today
- Free MDOT certification workshops, a vendor-registration process that has classified 400+ firms, and 223 self-identified S/M/WBE vendors.
- What the update should deliver
- An outreach-to-bid conversion measure and a target-firm list built from current availability data, so outreach is aimed, not broadcast.
Program administration
- What we test
- The three-office structure: where MWBE decisions, data, and reporting hand off among Purchasing, Equity and Inclusion, and Contract Compliance.
- Public evidence today
- Directory listings place the function across three offices; the Chief of Staff who oversaw Equity and Inclusion departed in June 2026.
- What the update should deliver
- A responsibility map with a single accountable owner for program data and reporting, whatever the org chart.
Compliance monitoring
- What we test
- How goal attainment, good-faith efforts, and the self-performance requirement are verified during performance and at closeout, not just at award.
- Public evidence today
- A credentialed Contract Compliance Administrator reviews documentation; 60 exemptions were logged with reasons in 2022.
- What the update should deliver
- A monitoring protocol that tracks attainment to closeout and publishes the exemption log annually.
Goal-setting and waivers
- What we test
- Whether the five aspirational goals still match availability measured on current data, and how contract-specific goals, waivers, and exemptions are set and documented.
- Public evidence today
- The goals match the 2021 study's measured availability, rounded; 60 exemptions were tallied by reason in 2022; no later public series exists.
- What the update should deliver
- A documented goal-setting methodology refreshed on new availability, and a standing waiver log with stated reasons.
Certification reciprocity
- What we test
- Processing time and drop-off across the SBA, MDOT, USDOT, and self-certification pathways, and whether recognition works the same in practice as on paper.
- Public evidence today
- Four recognized pathways; 154 SBEs certified since January 2022.
- What the update should deliver
- A reciprocity matrix with tracked timelines, and a clean separation of MWBE records from federal DBE records after the 2025 federal rule changes.
Data collection and performance measurement
- What we test
- Whether awards, payments, and subcontracts can be joined firm by firm across the full study period, spanning both IonWave and OpenGov.
- Public evidence today
- One public annual review (2022). No FY23 to FY25 reviews located. No utilization dashboard despite the roughly $275K OpenGov investment. The 2021 study found zero tracked subcontractors in FY2018.
- What the update should deliver
- A standing utilization dashboard on the OpenGov platform and an annual-review template City staff can run without a consultant.
Packaging and unbundling
- What we test
- The contract-size distribution against SBE capacity: which large solicitations could be divided without cost, and whether forecasting gives small firms lead time.
- Public evidence today
- A monthly procurement forecast page is live, listing 19 FY2026 projects, several carrying MWBE or DBE goals.
- What the update should deliver
- An unbundling review protocol tied to the forecast calendar, applied before solicitations post.
Prompt payment
- What we test
- Payment timelines to primes and pass-through timelines to subcontractors, a barrier the 2021 study's anecdotal record and the national evidence both flag for small firms.
- Public evidence today
- No public payment-timeline data located for the City.
- What the update should deliver
- Measured payment cycles from the City's own ledger and a prompt-payment standard with subcontractor pass-through terms.
Technology
- What we test
- Whether OpenGov is configured to capture classification, goals, attainment, and subcontracts, and whether IonWave history migrated intact.
- Public evidence today
- OpenGov Procurement went live January 1, 2026; the legacy IonWave portal no longer lists public sourcing events; the update's study period straddles the migration.
- What the update should deliver
- A data dictionary, a migration validation memo, and platform configuration that makes next year's annual review a query, not a project.
The cautionary tale next door
What Frederick County's 2026 study teaches the City's 2026 assessment
Frederick County, a separate government from the City, released its first disparity study in March 2026. Its experience is the strongest argument for treating program assessment and data architecture as one task.
The county study found substantial disparity. It nonetheless could not support race- or gender-conscious remedies, because only 27 percent of prime contractors kept subcontractor records and the evidentiary record the case law requires could not be built from what existed. That is a records problem, not a consultant problem: no methodology can analyze data that was never collected. The county's consultant recommended race-neutral steps, and the county has retained implementation support. The City's own 2021 study flagged the same exposure in the City's data: FY2018 closed with zero tracked subcontractors.
Source: Frederick County disparity study, MGT Impact Solutions, released March 2026; the City's 2021 study, data-reform recommendation. Frederick County is a separate government; its study is a benchmark for the City, never a substitute for the City's own record.
A program assessment that stops at policy language would repeat the pattern. The assessment must audit the data architecture that any future study, and any future defense of the programs, will stand on.
The data architecture the assessment must audit
- Formal award identifiers on every contract action, so awards, payments, and vendors join cleanly
- Real NIGP commodity codes in place of vague catch-all codes, so utilization maps to markets
- Prime-to-subcontractor tracking with payment verification, the exact record the county could not produce
- A standing utilization dashboard built on the OpenGov investment the City has already made
Each item traces to the 2021 study's own data-reform recommendation. The county experience shows what it costs to defer them.