Small Business First Program

California Public Contract Code Section 10508.5 allows the UC to award a Purchase Agreement to a certified small business up to $250,000 without being competitively bid, so long as the UC obtains price quotations from two or more certified small businesses.

UC policy BUS-43 requires that all non-construction and non-federally funded purchases valued between $10,000 and $250,000 annually (excluding tax, but including shipping) be awarded to a certified Small Business (SB) or Disabled Veteran Business Enterprise (DVBE). For all requisitions within this threshold, departments must select the appropriate SB First dropdown on their Requisition, and provide additional documentation as detailed below. 

Requisition Guidance

When submitting a requisition in Gateway, the Small Business First (SB First) dropdown selection determines whether the requisition will route for SB First compliance review. Requisitions between $10,000 and $250,000 will automatically route to an SB First workflow step when a waiver category or an SB/DVBE option ($10,000–$100,000 or $100,000–$250,000) is selected. At this step, the requisition is reviewed to ensure compliance with applicable Small Business First requirements before continuing through the approval process.

The following information is provided to help guide requisitioners in understanding how to comply with Small Business First Policy requirements. This guidance includes the criteria used to determine when a requisition will bypass SB First review, descriptions of exemption categories and their definitions, and the dollar thresholds for obtaining one or two quotes from a certified SB/DVBE.

Purchases between $10,000 and $250,000 comply with the policy automatically and will bypass SB First review if they meet any of the following criteria:

• Supplier is UCSB Campus Store
• Award Type is Federally-funded
• Initiated by any of the following Gateway forms:
  • Confirming PO
  • Contract Amendment
  • FlexCard Authorization
  • UCSB Cloud Services
  • Vendor Blanket (VB) Revision

Decision Workflow:

A purchase is not required to comply with the SB First Policy, if it can be:

• made from a Strategically-Sourced Supplier (See definition below.), or
• it meets any of the following policy exemptions:

Note: Requisitioners are responsible for ensuring compliance with SB First Policy requirements when making “Exempt” selections in the SB First dropdown menu. The SB First Team conducts quarterly compliance reviews using randomly selected requisitions to monitor adherence to policy requirements.

If the purchase does not meet any of the policy exemption categories, it must comply with the Small Business First Policy. The purchase must be awarded to a certified Small Business (SB) or Disabled Veteran Business Enterprise (DVBE), or a completed waiver must be submitted with the requisition in Gateway and approved by Procurement.

For purchases of goods and/or services valued between:

• $10,000 - $100,000 annually: one (1) quote must be obtained from either a certified Small Business or Disabled Veteran Business Enterprise.
• $100,000 - $250,000 annually: at least two (2) quotes must be obtained from certified Small Businesses or Disabled Veteran Business Enterprises.

Steps for Submitting a Requisition in Gateway

For Requisitions between $10,000 - $250,000, select the appropriate dropdown from both of the SB First custom fields under the Additional Order Details section in Gateway.

• Click the pencil icon to Edit Additional Order Details Section and select the appropriate dropdown selection under SB First. Gateway will require a selection from the SB First dropdown before allowing the requisition to be submitted.
• For requisitions through a certified Small or Disabled Veteran Business:
  • Select: 1) SB/DVBE $10K to $100K or 2) SB/DVBE $100K to $250K from the SB First dropdown, and
  • Select: “No” from SB First Waiver Justification Attached dropdown since no waiver is required, and
  • Attach: at least one (1) quote from a certified SB or DVBE for requisitions up to $100K, or at least two (2) quotes from certified SB or DVBE for requisitions above $100K, and
  • Attach: a screenshot of active certification(s) for all supplier(s).
• For requisitions that are exempt from the policy:
  • Select: the appropriate Exempt category from the SB First dropdown, and
  • Select: “No” from the SB First Waiver Justification Attached dropdown.
  • Note: Requisitioners are responsible for ensuring compliance with SB First policy requirements when making “Exempt” selections in the SB First dropdown menu. The SB First Team conducts quarterly compliance reviews using randomly selected requisitions to monitor adherence to policy requirements.
• For requisitions that require a waiver:
  • Upload: a completed UCSB Campus Waiver form to the Internal Attachments Section, and
  • Select: the appropriate Waiver category from the SB First dropdown, and
  • Select: “Yes” from the SB First Waiver Justification Attached dropdown

Searching for Certified Small or Disabled Veteran Business Enterprises

Check UCSB’s internal list of interested certified vendors, a searchable workbook of SB/DVBEs who have reached out about working with UCSB. (Access is limited to UCSB-affiliated members only.)

When searching for certified small or diverse businesses, the following databases can serve as helpful resources. Cal eProcure is the authoritative source for California SB/DVBE certification; Supplier.IO is a useful aggregator, but listings from SAM.gov and DSBS require additional verification and should not be relied on alone.

• California suppliers: Must be listed in both Cal eProcure and Supplier.IO. This ensures certification is valid and allows UC to track utilization.
• Out-of-state suppliers: Listings in Supplier.IO, SAM.gov, or DSBS may indicate SB/DVBE status, but departments must confirm with the supplier to ensure they are a certified Small Business (SB) and/or Disabled Veteran Business Enterprise (DVBE) for SB First compliance.

1. Explorer Professional (supplier.io)

Supplier.IO is a platform UC uses to access supplier diversity data nationwide and run SB/DVBE utilization reports. It includes information about businesses that identify as small or diverse, including those listed in SAM.gov. Note: Supplier.IO may reflect self-reported certifications (particularly from SAM.gov or with the designation “Supplier.IO Identified”), which UC does not automatically recognize as validated. For non-California suppliers, departments must confirm with the supplier to verify SB/DVBE certification.

2. Cal eProcure (caleprocure.ca.gov)

Cal eProcure is California’s online marketplace portal designed to allow businesses to sell products and/or services to the State. It provides search functionality to identify SB/DVBEs certified by the State of California. For UC SB First compliance, California-based suppliers must be registered in both Cal eProcure and Supplier.IO. UC considers certifications verified through Cal eProcure as valid. Training resources are available on the UCOP webpage.

3. SAM (SAM.gov)

SAM.gov is a U.S. government website for businesses to register to do business with the federal government, search for contract opportunities, and view contract awards. Businesses listed on SAM.gov have self-identified as small or diverse, but UC does not accept these self-certifications as sufficient for SB First compliance. Verification with the supplier or a recognized certifying agency is required. A user account is needed to search entity registrations. Training resources are available on the UCOP webpage.

4. Small Business Search (search.certifications.sba.gov)

The DSBS is a searchable database maintained by the U.S. Small Business Administration (SBA) that displays information about small business program participants, including 8(a), HUBZone, and WOSB certifications. While it can provide helpful information, DSBS is not a certifying agency for general small business status. Verification with the supplier or a recognized certifying authority is required for SB First compliance.

Considering a vendor who isn’t certified currently but likely qualifies? Departments are encouraged to share the Information for Small Business Owners page with businesses that may meet the eligibility requirements.

When You Might Need a Waiver

Sometimes circumstances may justify not complying with SB First, though it would otherwise apply. Examples include:

• Where at least two SB/DVBE suppliers are not available.
• Business needs cannot be met by a SB/DVBE supplier.
• Unique specifications only certain suppliers can meet.
• The business is small or owned by a disabled veteran, but they are not certified.

Completing a Waiver

UCSB SB First Waiver (PDF) (04/2026) 

Waiver Requirements: the entire waiver form must be completed by the responsible requesting party prior to submission for approval. UCSB requires applicable awards not made to SB/DVBEs be documented for audit purposes. Requisitions/POs are the system of record for campus procurement and the supporting documentation must be attached for compliance and audit preparedness.

The following outlines basic instructions for completing the form (All sections must be completed.):

• General Information: Provide relevant information on the specific contract or purchase opportunity that is being submitted for one-time exception from the SB First program.
  • Requisition #: from Gateway
  • Dollar Amount: the estimated value of the purchase or contract for award (excluding tax but including shipping)
  • Campus Department: the department requesting the good and/or service
  • Supplier: name of supplier to whom the work is being awarded
• Reason for Waiver Request: Document the main reason for needing a waiver. Select the primary reason this waiver is being requested (you may only choose one):
  • Insufficient # of SB/DVBE suppliers identified or unable to obtain enough valid quotes
  • Unable to meet specifications
  • Supplier declined to become a certified SB or DVBE
  • Other, as specified in justification
• Justification Narrative: Include a detailed narrative describing why an award cannot be made to an SB or DVBE that aligns with the Reason for Waiver Request (Section B above). Outline the steps taken to find a SB or DVBE and any other pertinent information to support why this Waiver is needed.
• Attach Relevant Documentation. Include evidence of SB/DVBE recruitment efforts, small business search results, failed solicitations, correspondence with potential suppliers, Small Business Officer assistance, past procurement data search or previous contract information, etc.

Federal Small Business Subcontracting

If you are a department and have a federally funded contract in excess of $900k, you may be required to submit and operate under a Small Business Subcontracting Plan. Refer to the Small Business Subcontracting Plan page for more details.