Procurement Compliance Bulletin
January 20, 2026
Happy New Year! We hope that it is off to a great start. The beginning of a new year is often a time to renew, re-evaluate and rejuvenate, both personally and professionally. You may have already made some New Year's resolutions that will allow you to carry out one or more of these actions. Personally, you may have decided to spend more time with loved ones or prioritize self-care. Professionally, you may have chosen new ways to reach your goals or found a more effective approach to tackle certain tasks.
As we begin this new year, we are reminded that we are midway through FY2026 and the 2nd Quarter Reports are due soon. Take a moment to reflect on where your unit currently stands with the goals/set-aside for the Socioeconomic Programs. Will your unit reach or exceed the goals/set-aside? Is your unit including MBE/CSB/VSBE vendors in all procurement categories? Does your unit need to increase MBE/CSB/VSBE procurement opportunities? Let’s continue to bring cheer throughout the year by extending and increasing the procurement opportunities/contracts to our MBE, CSB and VSBE vendors.
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The next OSBA Compliance Call is scheduled for:
January 22, 2026, from 10:00 AM - 12:00 PM
The Department of Social and Economic Mobility (DoSEM) Office of Small, Minority & Women Business Affairs (OSBA) hosts a compliance call each quarter to address issues impacting compliance of the SBR, MBE, and VSBE procurement programs 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. This will be a Google Meet. Meeting invites were sent to our SBR, MBE and VSBE Liaisons, and other agency procurement and compliance professionals that have asked to be added to our distribution list. Check your calendar. If you have not received a calendar invite, please contact Lisa Mitchell Sennaar at lisa.sennaar@maryland.gov and ask to be added to the distribution list. If you received an invite and do not wish to attend, simply decline the invite.
Topics had to be submitted no later than January 8, 2026, to be included in this Compliance Call.
January 22 Quarterly Compliance Call topics will include:
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Discussion of common report preparation mistakes/questions:
- FY2025 MBE, VSBE and SBR Annual Report submissions
- FY2026 MBE, VSBE and SBR Quarterly Report submissions
- Procurement Reform Act (PRA) of 2025 impact on the SBR Program
- New threshold- all eligible procurements $1,000,000,000 and below to be designated as SBR
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Reminder of EXECUTIVE ORDER 01.01.2024.38 - Delivering a More Efficient, Equitable, and Competitive Procurement System for Maryland
- Rule of two for SBR designation
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Reminder- Policies, training and guidelines for getting MBE and VSBE subs to be compliant and turn in monthly payment reports.
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New SBR Annual data requirement - to report by December 1, 2026 - The total number and dollar value of awards made to small businesses owned by economically disadvantaged individuals under designated small business reserve contracts.
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Unit-level Goal Setting - overview of what's coming
FY2025 Annual Reporting
Annual reports were due to OSBA on September 30 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:
- After review, the MBE Compliance Manager will reach out to the report preparer if any corrections are required. Timely responses to report corrections are critical to the overall success and compliance of this reporting cycle.
- 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.
- From the date the Summary Statement is received by the participating unit, the unit will have five (5) days to return the Summary Statement signed by the Report Preparer, Chief Financial Officer, and Agency Head or Designee, confirming 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.
The FY2026 Quarter 2 Reporting will be due January 30, 2026. The QTR 2 report should include data from July 1, 2025, through December 31, 2025.
Friendly Reminder Regarding MBE Quarterly Reports:
- FY2026 Quarterly reporting and submission is MANDATORY, and timely submission is critical and must include the following:
- Participating units that fail to submit the required data by the deadline will be noted in the quarterly report.
- Quarterly reports do not require signatures.
- OSBA has 15 days following the submission deadline to prepare the statewide quarterly report for the Governor, Lieutenant Governor, Board of Public Works, and the Governor’s Cabinet.
If you have any questions or need one-on-one assistance, please reach out to your assigned MBE Compliance Managers, Karen Reyes and Tiara Randolph.
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
FY2026 2nd Quarterly Reporting is due on January 30, 2026
SBR quarterly data is cumulative. Quarterly Reports are due no later than 30 days
following the quarter being reported. FY2026 SBR 2nd Quarter Report should contain data from
the start of the fiscal year, July 1, 2025, through December 31, 2025.
For the Quarterly Reports, friendly 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.
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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 since FY2025. 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, CSB 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 is referred to as a Certified Small Business (CSB), not SBR. SBR is a Program, not a certification. There are SBR designated procurements that are awarded to CSBs.
- Recertifications & new certifications for CSB vendors 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 the Department of General Services (DGS) Office of State Procurement's (OSP) website to reflect these changes.
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.
FY2026 VSBE Quarterly Reporting
The FY2026 Quarter 2 Reporting will be due January 30, 2026. The QTR 2 report should include data from July 1, 2025, through December 31, 2025.
Friendly Reminder Regarding VSBE Quarterly Reports:
- 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.
- The VSBE Quarterly Template 2026
- The VSBE 2026 Procurement Activity Report
- Each unit should also be tracking its outreach towards the veteran small business community
VSBE Compliance
As we embark on the upcoming legislative session, OSBA will be making changes to the VSBE Compliance COMAR chapter. If you have inputs of specific items you deem necessary to be included, please provide those suggestions to the VSBE Compliance Manager via email ASAP.
Let's be more intentional for Q3 & Q4!
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.
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