TDOT begins re-evaluation of DBE firms after Oct. 3 interim rule; plans June 15 submission to USDOT

David, a TDOT staff member leading the agency’s DBE program, told participants that an Oct. 3 interim final rule from the U.S. Department of Transportation removed the prior presumption that race or sex could be considered in DBE certification and now requires every firm previously certified to complete a one-time re-evaluation.

The re-evaluation requires a personal narrative and a personal net worth statement to show how an owner was socially and economically disadvantaged compared with a similarly situated non‑disadvantaged person. "This is a one‑time deal," David said, adding that annual updates remain separate from the re‑evaluation process.

TDOT said it began re-evaluations in mid‑December and that, before the IFR, its DBE roster was about 1,600 firms (roughly 800 in‑state and 800 out‑of‑state). After the rule change, TDOT focused on the roughly 800 in‑state firms; staff reported 32 firms had been re‑certified so far. To collect and manage applications TDOT is using B2G (sometimes called B2G now), an online DBE management system the agency began rolling out late last year.

State certifying partners have raised procedural concerns about the subjective nature of personal narratives, TDOT staff said. Some partners opted to stop certifying, and TDOT is temporarily absorbing those firms’ files and working to transfer them back once partner systems are able to process them. Staff cautioned that partner software can use tiered pricing tied to the number of certified firms, which has raised cost questions for some partners.

TDOT encouraged firms to upload materials through its portal (tdot.dbe.programtn.gov) and said it will assist firms that need help preparing narratives. The agency plans to submit its re‑evaluation documentation and a three‑year DBE goal plan to USDOT (FHWA) on or around June 15; TDOT staff said setting reasonable goals will depend on how many firms are restored to the database.

Participants asked whether airport or local certifiers (for example, Memphis Shelby County Airport or other partners) should still conduct re‑certifications. TDOT staff said the agency is processing Memphis airport files, will approve where appropriate and will transfer files back to local partners for maintenance once systems are aligned. Staff also said DBE re‑evaluation services should be free and advised firms not to pay third parties for basic DBE processing.

TDOT acknowledged short‑term impacts to small businesses and to goal‑setting for contracting, but staff said the agency’s priority is quickly restoring as many firms as possible and providing targeted help to complete narratives. The agency closed the session by repeating contact instructions and urging firms to submit documents promptly.

The immediate next steps are for firms to upload their personal narratives and net worth statements into B2G; TDOT will continue coaching applicants and expects to finalize its submission to USDOT around mid‑June.