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DOT UCP Changes

Not a month goes by that we don’t wonder what to write about.  Sometimes it is easier, like when massive change forces your hand! To refresh, the US Department of Transportation (DOT) is the parent agency that fosters Unified Certification Programs (UCP) for SDMWVBEs (Small, Disadvantaged, Minority, Women, or Veteran Business Enterprises) by state DOTs. Back in August we wrote about how changes in this process impacted interstate certifications, while this time we’re focused on how changes the UCP application will affect the first time applicant.

The form itself is actually a little more friendly. The process used to ask about family relationships well before it asked for details about any owner, which seemed a little counter-intuitive to us. So the flow of the application has definitely improved. On the other hand, the owner information pages make the assumption that there is a 51% owner — or rather, you are instructed to complete a form for the 51% owner, which begs the question, what if there isn’t one? It is possible for a business to qualify for SDMWVBE certification with multiple owners, and the percentage of ownership could be 50/50 and still be eligible. For example, if the company is 100% women-owned with a 50% ownership position for each and there are clearly stated agreements regarding decision making (control and governance) how does one complete the form? This argument can be present in myriad combinations and only by requesting a clarification from DOT will we get a meaningful answer.

Another new feature, beyond asking about key business functions an individual performs, we’re now asked to to rate how often an activity occurs. For example, if one “Obligates business by contract/credit” does it happen Always, Frequently, Seldom or Never? There is still no option for Not Applicable and what if the company doesn’t have “field operations”?

Unfortunately, while the form is a bit easier to understand, the whole process remains fairly opaque and each of us will have to seek individual answers for any areas of confusion from the certifying agency (the state DOT office, presumably). Don’t forget, as one Midwest DOT certification manager remarked, there is one certification program with 53 implementations! Better to ask those questions before you file your paperwork.