The State of Minority- and Women- Owned ... - Cleveland.com

Executive Summary
While M/WBEs’ experiences often differed markedly from non-M/WBEs, one area of agreement
was the need to thoroughly eradicate the use of “front” firms or “passthrough” firms to create the
appearance of participation.
• Waivers of Goals
In response to these issues, several participants stated that they had been able to obtain waivers
of goals based upon having made good faith efforts to meet them.
• Contract Performance Monitoring and Enforcement
Finally, concerns were raised about how the City monitors and enforces compliance with M/FBE
requirements. M/WBEs and even some non-M/WBEs were concerned about the strength of the
post-award monitoring process. Several certified firms reported that while they had been listed
on the bid documents, they were substituted later or did not receive full payment.
• Mentor-Protégé Initiatives
There was significant support among general contractors for mentor-protégé initiatives.
• CSB Set-asides
Many participants, both M/FBEs and non-certified firm owners, supported the concept of setting
aside some smaller contracts for bidding solely by CSBs.
J. Conclusion
As summarized above, and based on the detailed findings below, we conclude that there is strong
evidence of large, adverse, and frequently statistically significant disparities between minority
and female participation in business enterprise activity in the City of Cleveland’s relevant market
area and the actual current availability of those businesses. We further conclude that these
disparities cannot be explained solely, or even mostly, by differences between M/WBE and non-
M/WBE business populations in factors untainted by discrimination, and that these differences
therefore give rise to a strong inference of the presence of discrimination.
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