Compliance Monitoring and Enforcement
Contract Compliance
On contracts effective October 3, 2025 (see Official Frequently Asked Questions (FAQs) on the U.S. Department of Transportation’s Disadvantaged Business Enterprise Program and Disadvantaged Business Enterprise in Airport Concessions Program Implementation Modifications, October 3, 2025, Interim Final Rule):
- OBO cannot set DBE and/or ACDBE goals until the re-evaluation process has been completed by the Missouri Regional Certification Committee (MRCC)
- Perform Commercially Useful Function (CUF) reviews on existing projects until we receive additional information
- Count DBE and/or ACDBE participation on contracts until the re-evaluation process has been completed by the Missouri Regional Certification Committee (MRCC)
OBO will continue to:
- Track Prompt Payment and Return of Retention
- Review certified payroll records
- Collect information on the Bidders Data Collection Form for all bidders/offerors, including unsuccessful bidders, on projects
- Apply the New DBE Program regulations-see: