Overview
The United States Department of Transportation issued an Interim Final Rule (IFR) that amends the Federal Regulations that govern the Disadvantaged Business Enterprise and Airport Concession Disadvantaged Business Enterprise (DBE and ACDBE) Programs. The IFR was published October 3, 2025.
In compliance with the IFR, the certification process for new DBE’s and the certifications of all existing DBE firms have been suspended pending the implementation of the new DBE certification guidelines consistent with the IFR. Until the DBE program reevaluation process is complete, South Carolina Department of Transportation (SCDOT) will count DBE participation towards the goal for projects as outlined below:
DBE Quarterly Reports for Construction, LPA and Professional Services Contracts
Participation of the DBE is determined by evaluating the prime contractor's actual payments to the firm DBE. The prime contractor is obligated under rules set forth by the SCDOT when reporting and receiving credit towards the DBE contract goal. The prime contractor must give an account of actual payments made to DBEs on the SCDOT - DBE Quarterly Report Forms.
Contracts Awarded Prior to October 3, 2025:
DBE Quarterly Reports
Previously certified DBEs shall continue working as outlined in the contract awards and/or committals provisions subject to the DBE Supplemental Specification for replacement, augmentation or supplement (Replacement) of committed DBEs.
Prime Contractors are to submit signed DBE Quarterly Reports for work performed by the committed and non-committed DBE firms on all projects through September 30, 2025, for the third quarter, Q32025. Data should include projects with and without DBE goals.
Districts and Consultants should use the following fillable forms to submit Quarterly Report packets to MSBA-DBE Reporting and Data Management Unit via email at DBEQuarterlyReports@scdot.org:
- LPA & Construction DBE Quarterly Report
- LPA & Construction DBE Status Spreadsheet
- Professional Services DBE Quarterly Report
- Professional Services DBE Status Spreadsheet
NOTE: After submission of all outstanding DBE Quarterly Reports through September 30, 2025, no further DBE Quarterly Reporting is required until implementation of the reevaluated South Carolina Unified Certified Program (SCUCP).
Contracts Awarded on or After October 3, 2025:
- Do not submit DBE Quarterly Reports on contracts awarded during this time until further guidance.
- A notification will be distributed accordingly and placed on SCDOT’s website once the agency has completed the DBE Certification reevaluation of firms.
- Prime contractors are encouraged to utilize DBE firms on these projects as regular subcontractors for qualified work items.
REVISED DBE Closeout Form
Once DBE participation on the project is completed, a request is made to close and reconcile DBE participation to determine if goals and commitments were met. Quarterly Reports submitted over the duration of the project are reviewed to verify DBE payments and reconciled with request for DBE closeout.
When projects are ready to be closed, complete the revised Special DBE Closeout Request form and submit relevant documents as instructed on the closeout form. Only include completed DBE participation up through September 30, 2025, Q32025 in the closeout totals.
Use this same revised DBE Closeout Form for Construction/LPA projects and Professional Services contracts awarded before October 3, 2025. Select the appropriate program type on the top right of the form.