St. Louis County Office of Diversity, Equity and Inclusion | 41 S. Central Ave., Clayton, Missouri 63105 | 314-615-0993

Frequently Asked Questions

Q: Do I need to get my business certified as an MBE and/or WBE by St. Louis County?

A: St. Louis County is not a certifying agency.

Q: Which certifications are recognized by St. Louis County?
 

A: St. Louis County recognizes the certifications provided by the City of St. Louis’ Airport Authority and the Missouri Department of Transportation (MoDOT). In all instances the certified firms must have a local business presence, i.e. the St. Louis Metropolitan Area.

Q: How do I find the lists of certified M/WBEs?

A: City of St. Louis’s Business Diversity Development Office MWBE Directory 
 

MoDOT External Civil Rights

Q: My firm is certified as an MBE. If I am bidding as a prime contractor, do I have to meet the WBE goal?
 

A: All Bidders, including M/WBE Bidders, must make a good faith effort to meet the contract MBE and WBE goals.

Q: My firm is certified as an MBE. If I am awarded a contract, is that considered 100% MBE?
 

A: No. Only the value of your self-performed work, plus any work subcontracted to other MBEs, will count towards the MBE contract goal. It should be noted that the self-performed work must be in areas of work the firm is certified to perform. In all instances M/WBE participation credit is only provided for firms performing a commercially useful function.

Q: My firm is certified as an MBE and WBE. Can my work count towards either goal?

A: Firms certified as MBE and WBE may be counted towards either goal on a contract, but not for MBE and WBE on the same contract.

Q: How does St. Louis County monitor and enforce the M/WBE participation goals?

A: St. Louis County’s monitoring and enforcement efforts occur both pre-and post-contract award. In the pre-award phase St. Louis County reviews M/WBE Utilization Plans submitted by prospective vendors who respond to a County solicitation. The M/WBE Utilization Plan details the M/WBE subcontractors that will assist in completing the request scope of work/services. That information is verified by phone calls and/or emails with each of the M/WBEs scheduled to participate on the contract. If the contract goal(s) are not being met, a good faith efforts evaluation is conducted.

During the post contract award phase, the County will also review the payments being made to subcontractors to determine that the Prime Contractor is making progress and at minimum, engaging in good faith efforts to meet M/WBE goals. Site visits will also be made to determine that M/WBEs are both working on the project and are performing a commercially useful function.

Q: I am a legitimate MBE contractor and I have been certified for over 20 years. I resent having to submit to a contract monitoring review. My participation on a contract is minimal and it seems to me that the County’s time and efforts would be better spent developing programs to assist minority-owned businesses. If the front companies were not certified in the first place, perhaps we wouldn’t have all these problems.
 

A: St. Louis County will monitor every project having M/WBE participation. It is our goal to perform a “commercially useful function” review on each M/WBE firm participating on a County project. Firms who do not perform a commercially useful function and/or fail to cooperate with our requests for project-related information, which will enable us to monitor the project, will be reported to their certifying agency.

Q: What can M/WBEs do to increase their participation in the bidding process?
 

A: These simple steps can increase your opportunities with St. Louis County Government.

  • Become M/WBE certified. Contact the M/WBE staff for assistance 

  • Attend pre-bid conferences and bid opening meetings

  • Attend seminars, workshops, and outreach sessions sponsored by St. Louis County

  • Establish and maintain contacts and relationships with general contractors for potential business

  • Respond promptly to solicitation requests

  • Maintain open communication with St. Louis County and notify appropriate departments regarding any changes in your address, telephone number, or scope of work or service offered by your firm.​

Q: My firm was listed on a Utilization Plan and not solicited or utilized. What can I do about that?

A: If your firm is listed on a County approved M/WBE Utilization Plan and you were not solicited or utilized on the project, please contact Jack Thomas or Francoise Lyles-Wiggins of the County’s Diversity Office immediately.

Q: Does St. Louis County allow lower-tier subcontracting?
 

A: Yes, sometimes. It is incumbent upon the Bidder to check the contract specifications for each project. The Transportation Department does not allow lower tier subcontracting on their projects.

Q: What constitutes a “good faith effort”?

A: Good faith efforts means efforts to achieve a DBE goal or other requirement of this part which, by their scope, intensity, and appropriateness to the objective, can reasonably be expected to fulfill the program requirement.
 

Q: I frequently bid on County work as a prime contractor. Should I concentrate on meeting the M/WBE goals or being the apparent low bidder?
 

A: A bidder using good business judgment would consider a number of factors in negotiating with subcontractors, including M/WBE subcontractors, and would take a firm's price and capabilities as well as contract goals into consideration. However, the fact that there may be some additional costs involved in finding and using M/WBEs is not in itself sufficient reason for a bidder's failure to meet the contract M/WBE goals, as long as such costs are reasonable. Also, the ability or desire of a prime contractor to perform the work of a contract with its own organization does not relieve the bidder of the responsibility to make good faith efforts. Prime contractors are not, however, required to accept higher quotes from DBEs if the price difference is excessive or unreasonable.

Q: How does the 5% bid discount work?

A: Bid submittals for construction projects of $300,000 or less from certified MBE/WBEs will receive a 5% bid discount applied to their bid. This discounted bid amount will be used in the evaluation process of awarding to the low responsive, responsible bidder. The original bid amount will be the basis for contract award. For example, a $100,000 bid with a 5% bid discount would be evaluated at $95,000. However, $100,000 would be the award amount and amount paid to the bidder.

To qualify for the bid discount, the M/WBE bidder must include a copy of the current M/WBE certification approval letter issued by a certifying agency. The certifying agencies are St. Louis-Lambert International Airport and the Missouri Department of Transportation. Firms not certified at time of bid opening are ineligible for a bid discount.

Q: How does the 15% incentive credit work?

A: The County will provide a 15% incentive credit to each M/WBE Respondent. The incentive credit will be provided during the proposal evaluation process. To qualify for the incentive credit, the M/WBE Respondent must include a copy of the current M/WBE certification approval letter issued by the certifying agency. The certifying agencies are St. Louis-Lambert International Airport and the Missouri Department of Transportation.

Q: What is a “commercially useful function”?

A: An M/WBE performs a commercially useful function when it is responsible for execution of the work of the contract and is carrying out its responsibilities by actually performing, managing, and supervising the work involved. To perform a commercially useful function, the M/WBE must also be responsible, with respect to materials and supplies used on the contract, for negotiating price, determining quality and quantity, ordering the material, and installing (where applicable) and paying for the material itself. To determine whether a M/WBE is performing a commercially useful function, you must evaluate the amount of work subcontracted, industry practices, whether the amount the firm is to be paid under the contract is commensurate with the work it is actually performing and the M/WBE credit claimed for its performance of the work, and other relevant factors.


An M/WBE does not perform a commercially useful function if its role is limited to that of an extra participant in a transaction, contract, or project through which funds are passed in order to obtain the appearance of M/WBE participation. In determining whether an M/WBE is such an extra participant, you must examine similar transactions, particularly those in which M/WBEs do not participate.


If a M/WBE does not perform or exercise responsibility for at least 30 percent of the total cost of its contract with its own work force, or the M/WBE subcontracts a greater portion of the work of a contract than would be expected on the basis of normal industry practice for the type of work involved, you must presume that it is not performing a commercially useful function.

Q: How do I become a registered vendor with St. Louis County?
 

A: Go to www.stlouisco.com and select “Vendor Self-Service” to register. You will be required to create a User ID and password. The registration process will allow you to select the category description (NIGP Commodity Codes) of the products and services that you provide. Doing so will enable you to receive notification of any St. Louis County opportunity that fits your commodity code profile.