Procurement Compliance Bulletin

November 19, 2025

Honoring Those That Have Served

Each November, we nationally honor the veterans who bravely served our country, and here in Maryland, we also take this time to celebrate our veteran-owned small businesses in meaningful ways. Our office, in collaboration with several other organizations, recognized many Maryland-based veteran business owners during our annual Veteran Small Business Week, which was November 3-7. This year, we received many nominations and was able to select exemplary veteran-owned businesses from each region of Maryland. We will continue to recognize certified VSBEs at the Annual VSBE Appreciation Breakfast on November 20th. I am very happy to announce that we hit a major milestone of over 1,000 certified VSBEs in the eMMA Database, and we aren't done yet. We are encouraging your unit to foster relationships with the veteran small business vendor community, especially this month. Not only will this impact your unit's outreach efforts, but overall contribute to our statewide VSBE participation goal of a minimal 3%. If your unit needs assistance with identifying VSBEs, feel free to reach out to the VSBE Compliance Manager, Danielle Davis.

Next Compliance Call

Save the date : The next OSBA Compliance Call is scheduled for January 22, 2026, from 10:00 AM - 12:00 PM

The Office of Small, Minority & Women Business Affairs (OSBA) hosts a compliance call each quarter to address issues impacting how the SBR, MBE, and VSBE procurement programs are implemented by participating state units/agencies/departments.

Topics for discussion come from you, our liaisons, procurement and compliance officers and the questions you are emailing us. We use the Compliance Call to discuss them in an open and transparent forum so we can all learn from one another.

The next Compliance Call will be a virtual Google Meeting. We will email meeting invites to our SBR, MBE and VSBE Liaisons, and other agency procurement and compliance professionals. You should have already received a calendar invite. If you have not, please contact Lisa Mitchell Sennaar and ask to be added to the distribution list. 

Mandatory Surveys from the House Appropriations Committee

The House Appropriations Committee mandated an additional round of surveys in 2025 to address ongoing concerns about the attainment of MBE goals, MBE/SBR liaison vacancies, and the liaison's role within each participating unit. OSBA is conducting the surveys in collaboration with the Department of General Services Office of State Procurement. A report is due to the Committee in January.

Agency MBE Participation Attainment Survey (MBE Liaisons only)

The Agency MBE Participation Attainment Survey launched on August 20, 2025.  

•  Surveys have been sent to Procurement Directors and MBE Liaisons.
• Liaisons will need to collaborate with procurement directors to provide accurate and scrubbed FY25 MBE annual procurement data for the survey.
• The Agency MBE Participation Attainment Survey will close on November 20, 2025.

Agency Liaison Survey (MBE & SBR Liaisons)

• A new Agency Liaison Survey launched on August 20, 2025.
• The survey will close on November 20, 2025.
• This survey is collecting data about agency liaison vacancies and the duties of MBE and SBR liaisons.

Submission of these surveys is required, and agencies that fail to submit the requested data by the due date will be reported as non-responsive to the Committee. No extension can be granted.

Questions about the surveys may be directed to your MBE Compliance Manager.

Karen Reyes - karen.reyes@maryland.gov

MBE Program

FY2025 Annual Reporting

Annual reports were due to OSBA on September 30th and included data from July 1, 2024, through June 30, 2025. OSBA is in the process of verifying each participating unit's MBE Annual Report data.

Below is how the verification process works:

1. After review, the MBE Compliance Manager will reach out to the report preparer if there are any corrections that are required. Timely response to report corrections is critical to the overall success and compliance of this reporting cycle.
2. Once corrections are complete and the report is verified for compliance in accordance with COMAR 21.11.03.17, the MBE Compliance Manager will send a Summary Statement when the report is deemed finalized. 
3. From the date the summary statement is received by the participating unit, the unit will have 5 days to return the summary statement signed by the Report Preparer, Chief Financial Officer, and Agency Head or Designee, confirming they are in agreement with the final verified MBE numbers. 

If you have questions pertaining to the MBE Annual Report, feel free to submit them via email or contact the MBE Compliance Manager to schedule a meeting. 

FY2025 QTR 4 & FY2026 QTR 1 Report

Designated MBE Compliance Manager One-on-One Scheduling

Each MBE Compliance Manager has been assigned to specific participating agencies to provide more tailored and hands-on assistance. Click the link to view who your designated MBE compliance manager is: OSBA Assigned MBE Liaison Template.pdf

Below, are Karen Reyes and Tiara Randolph's Calendly links to make it easy for you to schedule one-on-one sessions whenever you need guidance or have questions. We look forward to collaborating with you to ensure your success as an MBE liaison. 

Karen Reyes Calendly Link​

Tiara Randolph Calendly Link

Feel free to reach out via email as well:

                                           Karen Reyes - karen.reyes@maryland.gov

Tiara Randolph - tiara.randolph@maryland.gov

SBR Program

FY2026 1st Quarterly Reporting 

The SBR 1st Quarter FY2026 Report​​​​​​ is now past due​. A big thank you to all of those units that submitted their reports! 

 
For the Quarterly Reports, remember that:

• Quarterly reporting is MANDATORY, and submission of the data is critical. The quarterly report will note participating units that fail to submit the required data on time.
• Quarterly Reports do not have to be signed.
• OSBA prepares a statewide quarterly report for the Governor, Lieutenant Governor, the Board of Public Works, and the Governor’s Cabinet.
• The FY2026 SBR QTR Reporting Instructions and Template have been revised. Note that the Instructions/Template have been updated to include Small Business Preference (SBP) awards/payments data. This information is available in the SBR Reporting Toolkit. Please make certain that the new template is being utilized.
• We are available for one-on-one training and assistance to address any questions or concerns about SBR waivers, reporting, certification, outreach, or training assistance.  Please email your SBR Compliance Manager to schedule a meeting. 

Lisa Mitchell Sennaar - lisa.sennaar@maryland.gov
Tanita Johnson - tanita.johnson1@maryland.gov

Program Updates

As of August 29, 2025:

• A certification for a small business will be referred to as a Certified Small Business (CSB)
• Recertifications & new certifications for CSB will be every 3 years, instead of every year.

As of October 1, 2025:

A procurement with a total dollar value OF $1,000,000 OR LESS shall be designated for the Small Business Reserve (SBR) Program. 

PROCUREMENT REVIEW GROUP: Guidance and Worksheets and BEST PRACTICES: Small Business Reserve (SBR) Implementation Guidelines have been updated on Department of General Services (DGS) Office of State Procurement's (OSP) website.

What Does Your Agency Need to Do

• Update your website and any materials that reference SBR vendors to CSB terminology
• Encourage any vendors during outreach to recertify (CSB) when it is their time, so the 3-year timeframe can take effect

VSBE Program

FY2026 1st Quarterly Reporting 

The VSBE 1st Quarter FY2026 Report​​​​​​ is now past due​.
For the Quarterly Reports, remember that:

• Quarterly reporting is MANDATORY, and submission of the data is critical. The quarterly report will note participating units that fail to submit the required data on time.
• Quarterly Reports do not have to be signed.
• The FY2026 VSBE QTR Reporting Instructions and Template have been revised. Please make certain that the new template is being utilized. There are 2 templates required to be submitted, even if your unit had no participation. 

VSBE Database Increase

New certified VSBEs are being added to the database daily. Please continue to complete new market research to identify VSBE opportunities. 

To address any questions or concerns about VSBE certification, outreach, training, or reporting, please contact the VSBE Compliance Manager. 

Danielle Davis - danielle.davis2@maryland.gov.

FY2026 Procurement Forecast

Thank you to the agencies/units that have already submitted their Procurement Forecasts! If your unit has not yet forwarded the forecast, submit it as soon as possible. This is a mandatory report for all participating units. The Procurement Forecast is provided to the public and serves as a valuable tool for the small, minority, women, and veteran business community. - Procurement Forecast Portal.

Each unit submits only one Forecast that includes all of your eligible projected procurements over $100,000.

Please use the FY2026 Instructions and Template.  Do not use previous year templates. Also, do not modify the template. It must be uploaded to our Forecast database, and it cannot be uploaded if the spreadsheet is modified. If you have any questions, you may contact Lisa Mitchell Sennaar lisa.sennaar@maryland.gov

Forward completed reports to compliance.gosba@maryland.gov

New Liaison Onboarding  

We are revising our "New Liaison Onboarding" for a launch in the new year. You may contact SBR, VSBE and MBE Compliance Managers to schedule one-on-one meetings for your new liaisons in the interim.

SBR Compliance Managers:

Lisa Mitchell Sennaar - lisa.sennaar@maryland.gov 

Tanita Johnson - tanita.johnson1@maryland.gov

VSBE Compliance Manager:

Danielle N. Davis -danielle.davis2@maryland.gov

MBE Compliance Managers:

Karen Reyes​ - karen.reyes@maryland.gov

Tiara Randolph - tiara.randolph@maryland.gov

From the Desk of the MBE Ombudsman

By Nichelle Johnson

So You Have Been Contacted by the Ombudsman Unit, Now What? If your State procurement agency has been contacted by an assigned Ombudsman/Compliance Manager regarding an issue an MBE-certified vendor is having on a contract, consider it a valuable opportunity to enhance your agency's engagement with Minority Business Enterprise (MBE) certified vendors. This isn't just about compliance; it's about fostering a thriving, inclusive business ecosystem within our state! As a state procurement agency, you play a crucial role in this process. State Government §9-303.3 underscores the requirement for agencies to cooperate with OSBA in these matters. By fostering clear communication and shared commitment, we can address challenges efficiently and strengthen the integrity of the MBE Program. Proactive Communication is Key State agencies have a clear mandate to work with the Ombudsman Unit to resolve issues raised by MBE firms. Specifically, the law mandates the following, as found in State Government § 9-303.3: Prompt Response: The procurement agency should promptly acknowledge receipt of the communication from the Ombudsman Unit and must work with the Ombudsman/Compliance Manager to promptly resolve any complaints or problems raised by an MBE firm. Information Sharing: The agency must provide the Ombudsman/Compliance Manager with any requested information concerning a contract or a potential contract with an MBE. Documentation: The agency must maintain detailed records of all communications, findings, and actions taken to resolve the complaint or problem. For a full understanding of the statutory requirements, please refer to the text of State Government § 9-303.3. Your Agency's Responsibilities COMAR 21.11.03.13 outlines your agency's responsibilities in ensuring fair and equitable treatment of MBE vendors. Proactive communication ensures transparency and builds trust, fostering stronger relationships with our valued vendors. Procurement agencies must: Investigate Thoroughly: Conduct a thorough investigation into the vendor's concerns. Corrective Action: If an investigation reveals a violation of the MBE Program, the agency must compel parties to take appropriate corrective action. Consider the Ombudsman Unit as a partner in your efforts to promote diversity and inclusion within state contracting. Our insights and recommendations can help you: Identify potential barriers to MBE participation. Improve communication and engagement with MBE vendors. Develop more effective strategies for achieving MBE goals. When working with the assigned Ombudsman/Compliance Manager, it is vital that your agency Maintain Transparency by keeping both the assigned Ombudsman/Compliance Manager and the MBE vendor informed about the progress of your investigation, any challenges encountered, and the anticipated timeline for resolution. Once a solution has been reached, the agency must promptly report the final resolution to the assigned Ombudsman/Compliance Manager. This step is essential for closing the case and allows the Ombudsman Unit to document the successful outcome. Best Practices Preventative Measures: Regularly review your agency's internal procurement policies and procedures to ensure they are in line with state law, regulations, and policy, and are equitable and inclusive. Facilitate training for procurement staff on MBE program requirements and best practices for working with MBE vendors. Establish clear communication channels for vendors to raise concerns and seek  assistance. Ongoing Engagement: Participate in OSBA-sponsored workshops and training sessions. Form a great relationship with your OSBA assigned MBE Compliance Manager and MBE Ombudsman Compliance Manager. Seek feedback from vendors on their experiences with your agency. Continuously strive to improve your agency's performance in meeting MBE goals. By embracing these best practices, we can collectively create a procurement environment where MBE vendors thrive, innovation flourishes, and the state of Maryland benefits from the diverse talents and perspectives of its business community. The Ombudsman Unit views every contact not as a conflict, but as an opportunity for improvement. We look forward to working collaboratively with your agency.   ASSIGNED AGENCIES - MBE OMBUDSMAN UNIT

Save the Date

SBR/MBE/VSBE Compliance Call:

January 22, 2026: 10:00 AM - 12:00 PM