There are two dangers associated with the tier system of MWBE reporting. First, creating a tiered system gives companies ample opportunity to pass off, to the Tier 1 suppliers, the responsibility for building a strong MWBE supply base. Second, information about MWBEs can too easily “disappear” beyond Tier 1.

Abbott, the global healthcare and research corporation, apparently recognizes both of these dangers because its supplier diversity program website says this about second-tier reporting: “Abbott asks our top 100 suppliers to submit second tier reports quarterly.” In this way the company assumes responsibility for tracking supplier diversity beyond Tier 1 and ensures the information does not “disappear.”