Connecticut Good Faith Efforts requirements, explained
Updated July 2026 · Not legal advice
Who has to file a GFE plan?
Any contractor awarded a public works contract with $150,000 or more in state funding — whether the awarding authority is a state agency, quasi-public agency, municipality, or grantee of state funding. This threshold took effect October 1, 2025, replacing the old Set-Aside and Affirmative Action plan regime.
Short Form vs Long Form
- Short Form GFE Plan — state funding between $150,000 and $1,000,000. Section-by-section breakdown.
- Long Form GFE Plan — state funding of $1,000,000 or more, or any Construction Manager on a project with more than $150,000 in state funding. What changed in 2026.
On the templates effective 07/01/2026, the two forms share the same seven sections — cover page, project description, the subcontractor/supplier/vendor availability analysis, MBE goals and timetables (Attachment III), documentation checklist, prompt payment, closeout notice, and the signed concluding statement. The Long Form adds exactly one section: the Good Faith Efforts Attachment, a short narrative on how you broke the work into economically feasible units, how S/M/W/DisBE firms got equal access to plans and specifications, whether you held a pre-bid meeting, and whether the plan preparer has attended CHRO's Technical Assistance training. (Earlier versions of the Long Form required workforce/EEO sections such as an organizational chart and employment statistics — the 07/01/2026 Long Form does not.)
Both forms are accompanied by a Bid Tabulation Worksheet documenting every quote received and the reason any S/M/W/DisBE bidder was not selected. Not sure which applies? Use the free form picker.
Spending Allocation Goals
Since July 1, 2026, awarding authorities set project-specific goals for SBE and MBE participation (previously statewide defaults of 25% SBE / 6.25% MBE). The goals appear in the bid notification — your GFE plan documents how you tried to meet them. The MBE-side goal covers all three diverse DAS certification types together: MBE, WBE (women-owned), and DisBE (disabled-owned) — and every diverse certification includes SBE eligibility, so those firms count toward both goals.
What counts as evidence?
CHRO's guidance is evidence-centric: written solicitations preserved, phone outreach documented in written notes, responses and follow-ups logged, and non-selection reasons recorded. Records must be kept for at least two years after the CHRO issues, to your company, a Notice of File Closure letter, and CHRO can audit during or after the project.
The 07/01/2026 forms spell out what a reviewer looks for in the availability analysis:
- Written notice at least 10 days before bids are due to a reasonable number of certified S/M/W/DisBE firms for each trade, material, and service — the form asks this as a direct yes/no question, and asks you to justify any "no".
- Follow-up after the initial solicitation to gauge interest — the second yes/no question. "Called/left message" alone is not follow-up evidence.
- Solicit at least three S/M/W/DisBE firms per trade, material, or service — CHRO's stated best practice. If none were solicited for an item, document why (for example, the project documents specify a sole manufacturer).
- Concrete outcomes, not placeholders. "Bid received", "no response", "said will bid", or "did not bid" are insufficient on their own — record the concrete result ("Bid too high", "Declined to bid", "No response to 3 solicitations") and show the follow-up behind it.
- Search the DAS Supplier Diversity database with simple, varied keywords — "precast" instead of "precast concrete products". Overly specific searches that miss certified firms can themselves count against a good-faith finding.
Closeout
Within 45 days of substantial completion, contractors submit subcontractor payment documentation, lien waivers, and any outstanding subcontract notifications. General contractors must pay subs within 15 days of the due date absent a bona fide dispute.
How to file with CHRO
CHRO's Contract Compliance Forms page directs all award notifications and requests to execute to [email protected]. In practice:
- What to send — the completed official Short Form or Long Form GFE Plan and Bid Tabulation Worksheet (use the current templates from CHRO's site), signed by the head of your company, with your outreach evidence attached.
- When — at award / before contract execution; closeout documentation follows within 45 days of substantial completion, as covered above.
- Your goals — the awarding authority sets the project's Spending Allocation Goals in the bid notification; your plan documents how you pursued them.
Verify the address and current templates against CHRO's site before sending — requirements and forms change.
What happens if you don't comply?
Withheld contract payments, disqualification from future bidding, and civil penalties or legal action by CHRO.
Sources & official references
- CHRO — Contract Compliance Forms and Reports — the hub for current templates and submission instructions.
- CHRO Notice of Changes (Sept. 30, 2025) — the $150k threshold, Spending Allocation Goals, 45-day closeout, 15-day prompt payment, and penalties.
- Official templates: GFE Short Form Plan (eff. 7/1/2026) · GFE Long Form Plan (eff. 7/1/2026) · Bid Tabulation Worksheet
- CHRO Notice Regarding Record Retention
- CHRO Spending Allocation Goal calculator (the awarding-authority portal)
Not legal advice. Requirements and document locations change — verify against the official sources above before filing.
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