WeGo outlines review after USDOT DBE interim rule; agency pauses goals and will re‑certify vendors

Antoine Moye, business diversity manager and DBE liaison at WeGo, told the board that a USDOT interim final rule issued Oct. 3, 2025, removed the prior presumption that minority‑ and women‑owned firms are automatically socially disadvantaged and now requires each firm to submit an individual narrative to demonstrate social and economic disadvantage.

Moye said USDOT has directed recipients to pause contract goals and counting procedures while agencies complete eligibility reviews in partnership with the Tennessee Unified Certification Program and TDOT. He said roughly 35 vendors certified through WeGo and about 90 vendors inherited from airport certification are affected locally; statewide, the pause affects more than 500 vendors.

"That presumption has gone away actually, and now all firms in the program are required to prove that they are socially and economically disadvantaged by the submission of what's called an individual narrative," Moye said. He recommended freezing goal language on pending solicitations, circulating FAQs under legal review, and conducting outreach and proactive vendor education.

Board members asked how the pause affects reporting and whether agencies are coordinating; Moye said semiannual reporting has been paused to allow a coordinated review and that WeGo is working with state and national work groups to align processes and identify best practices. Staff said they will bring a complete eligibility review to the board when available and continue vendor outreach during the transition.