oversight

SERVICE-DISABLED VETERAN-OWNED SMALL BUSINESS PROGRAM: Governmentwide Fraud Prevention Control Weaknesses Leave Program Vulnerable to Fraud and Abuse, but VA Has Made Progress in Improving Its Verification Process

Published by the Government Accountability Office on 2012-02-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                             United States Government Accountability Office

GAO                          Testimony
                             Before the Subcommittee on Technology,
                             Information Policy, Intergovernmental Relations
                             and Procurement Reform, Committee on
                             Oversight and Government Reform, House of
                             Representatives
                             SERVICE-DISABLED
For Release on Delivery
Expected at 10:00 a.m. EST
Tuesday, February 7, 2012

                             VETERAN-OWNED SMALL
                             BUSINESS PROGRAM
                             Governmentwide Fraud
                             Prevention Control
                             Weaknesses Leave Program
                             Vulnerable to Fraud and
                             Abuse, but VA Has Made
                             Progress in Improving Its
                             Verification Process
                             Statement of Richard J. Hillman, Managing Director
                             Forensic Audits and Investigative Service




GAO-12-443T
                                               February 7, 2012

                                               SERVICE-DISABLED VETERAN-OWNED SMALL
                                               BUSINESS PROGRAM
                                               Governmentwide Fraud Prevention Control
Highlights of GAO-12-443T, a testimony
                                               Weaknesses Leave Program Vulnerable to Fraud and
before the Subcommittee on Technology,         Abuse, but VA Has Made Progress in Improving Its
Information Policy, Intergovernmental
Relations and Procurement Reform,
                                               Verification Process
Committee on Oversight and Government
Reform, House of Representatives

Why GAO Did This Study                         What GAO Found
In fiscal year 2010, federal agencies          Governmentwide fraud prevention control weaknesses over the SDVOSB
awarded $10.8 billion to Service-              program leave it vulnerable to fraud and abuse. In October 2009, GAO reported
Disabled Veteran-Owned Small                   on 10 selected firms that misrepresented their status as SDVOSBs, which
Businesses (SDVOSB), according to              allowed them to win approximately $100 million in SDVOSB set-aside and sole-
the Small Business Administration              source contracts. Cases like this happen because the SDVOSB program relies
(SBA). The Department of Veterans              on firms to self-certify annually in the federal government’s contractor registry
Affairs (VA) awarded $3.2 billion, or          that they are owned and controlled by service-disabled veterans, but most
approximately 30 percent of                    agencies do not validate this information. In fact, GAO found that the program
governmentwide SDVOSB awards.
                                               lacks key fraud prevention framework elements, which include preventing firms
The SDVOSB program, established by
                                               from fraudulently entering the program, detecting and monitoring for continuing
the Veterans Benefit Act of 2003, is
designed to honor disabled veterans’
                                               compliance, and investigating firms that abuse the program.
service by providing them with                 Figure 1: GAO’s Fraud Prevention Framework
exclusive contracting opportunities.
Since 2009, GAO has issued seven
reports or testimonies on the SDVOSB
program, focusing on its vulnerability to
fraud and abuse and agencies’ actions
to prevent contracts from going to firms
that misrepresent themselves as
SDVOSBs.
For this testimony, GAO was asked to
(1) summarize the status of
governmentwide fraud prevention
controls over the SDVOSB program               For example, the only governmentwide fraud prevention control in place is SBA’s
and (2) discuss GAO’s recent                   bid-protest process, in which interested parties can contest contract awards. In
assessment of fraud prevention control         prior work, GAO found that the process lacked effective controls because firms
improvements instituted by VA over its
                                               could complete contracts even after SBA found them ineligible, rendering the
verification program.
                                               process ineffective. In July 2011 GAO testified that the 10 firms cited in the 2009
This testimony is based on prior GAO           report had received another $100 million dollars in new federal contract
products on the SDVOSB program.                obligations despite their fraudulent history. SBA and VA had taken some actions
GAO also reviewed applicable laws,             against firms by July 2011, including suspending 2 of the firms, and requesting
regulations, and guidance including the        that all firms change their status in federal contracting databases to show they
Comptroller General’s Standards for            were not eligible for SDVOSB contracts. However, as of July 2011, several of
Internal Controls in the Federal               the firms continued to self-certify themselves as SDVOSBs.
Government and related findings from
VA’s and SBA’s Inspector General.              VA has made progress implementing a verification program for firms seeking
                                               SDVOSB contracts from VA. GAO testified in November 2011 that VA’s program
                                               includes an initial verification process involving document reviews, site visits to
                                               contractor offices, and a risk assessment for each applicant firm. In addition, VA
                                               has instituted a status protest process and a debarment committee designed to
                                               ensure only eligible firms receive contracts and that ineligible firms face
                                               consequences for misrepresenting their status. Those improvements may help
                                               VA reduce the risk that ineligible firms will gain access to VA SDVOSB contract
                                               dollars. Nonetheless, GAO also made 13 recommendations to VA for improving
                                               its verification program and further reducing the risk of fraud and abuse. VA
View GAO-12-443T. For more information,
contact Richard J. Hillman at (202) 512-6722   concurred with the recommendations and outlined plans to improve the program.
or hillmanr@gao.gov.                           To improve governmentwide fraud prevention controls, GAO suggested that
                                               Congress consider expanding the VA verification program to all agencies.
                                                                                            United States Government Accountability Office
Chairman Lankford, Ranking Member Connolly, and Members of the
Subcommittee:

Thank you for the opportunity to discuss fraud prevention controls within
the Service-Disabled Veteran-Owned Small Business (SDVOSB)
program. The SDVOSB program is intended to honor the service
rendered by veterans with disabilities incurred or aggravated in the line of
duty. To be eligible for a set-aside or sole-source SDVOSB contract, a
firm must be majority-owned by one or more service-disabled veterans
who manage and control its daily business operations. 1 Firms self-certify
annually that they meet these criteria in the Central Contractor
Registration (CCR) before bidding on these contracts. 2 The Small
Business Administration (SBA) stated in a recent report that in fiscal year
2010, $10.8 billion in federal contracts were awarded to self-certified
SDVOSBs. 3 The Department of Veterans Affairs (VA) SDVOSB contracts
accounted for $3.2 billion or approximately 30 percent of governmentwide
SDVOSB contracts during fiscal year 2010.

The SDVOSB procurement program was initiated with the Veterans
Benefits Act of 2003. 4 Executive Order 13360 also requires heads of
federal agencies to provide opportunities for these firms to increase their
share of federal contracts and subcontracts. The statutorily mandated
prime and subcontracting goal for SDVOSB participation governmentwide
is not less than 3 percent of all federal contract dollars each fiscal year. 5
In addition, VA established an agency-specific goal for SDVOSB
participation of 7 percent.




1
 If the business is publicly owned, at least 51 percent of the stock must be held by one or
more service-disabled veterans. In the case of a veteran with a permanent and severe
disability, the spouse or permanent caregiver of such veteran may control the business.
2
 CCR is the primary registrant database for the U.S. federal government. CCR collects,
validates, stores, and disseminates data in support of agency acquisition missions,
including federal agency contract and assistance awards.
3
 SBA calculates its SDVOSB total by including all small-business dollars awarded to
SDVOSBs, not just those received through set-aside or sole-source contracts.
4
Pub. L. No. 108-183, § 308, 117 Stat. 2651, 2662 (2003).
5
 Veteran Entrepreneur Act of 1999, Pub. L. No. 106-50, § 502, 113 Stat. 233, 247 (1999)
codified at 15 U.S.C § 644 (g)(1).




Page 1                                                                         GAO-12-443T
Subsequent to the program’s initiation, several other laws were enacted
that required a separate verification process for VA contracts, provided
additional specificity on program requirements, and established
guidelines for responding to firms that violate program requirements.
Specifically, the Veterans Benefits, Health Care, and Information
Technology Act of 2006 required VA to institute controls over its SDVOSB
contracts. 6 The Act required VA to verify firms’ eligibility and maintain a
database, VetBiz, of the SDVOSBs and Veteran-Owned Small
Businesses (VOSB) it verified starting in June 2007. The Act also
required that VA only use its set-aside and sole-source award authority
for SDVOSB firms listed in the database and to debar for a reasonable
period of time, as determined by VA, firms that misrepresent SDVOSB
and VOSB status. Veterans Small Business Verification Act and Small
Business Jobs Act of 2010 provided further authorities and requirements
for agencies when utilizing SDVOSB contracting authorities. 7, 8

Today’s testimony will (1) summarize the status of governmentwide fraud
prevention controls over the SDVOSB program and (2) discuss our recent
assessment of fraud prevention control improvements instituted by VA
over its verification program. This statement is based on prior GAO
products issued in 2011 and 2009. 9 That work included review of
guidance on internal control standards from GAO’s Standards for Internal
Control in the Federal Government, 10 the fraud prevention framework, 11


6
Pub. L. No. 109-461, § 502, 120 Stat. 3403, 3431 - 3435 (2006).
7
 Veterans Small Business Verification Act, Pub. L. No. 111-275, § 104, 124 Stat. 2864,
2867 – 2868 (2010).
8
 Small Business Jobs Act of 2010, Pub. L. No. 111-240, § 1341, 124 Stat. 2504, 2543 -
2544 (2010).
9
 GAO, Service-Disabled Veteran-Owned Small Business Program: Additional
Improvements to Fraud Prevention Controls Are Needed. GAO-12-205T (Washington,
D.C.: November 30, 2011), GAO, Service-Disabled Veteran-Owned Small Business
Program: Preliminary Information on Actions Taken by Agencies to Address Fraud and
Abuse and Remaining Vulnerabilities. GAO-11-589T (Washington, D.C.: July 28, 2011)
and GAO, Service-Disabled Veteran-Owned Small Business Program: Case Studies
Show Fraud and Abuse Allowed Ineligible Firms to Obtain Millions of Dollars in Contracts.
GAO-10-108 (Washington, D.C.: October 23, 2009).
10
  GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
(Washington, D.C.: November 1999).
11
  GAO, Service-Disabled Veteran-Owned Small Business Program: Fraud Prevention
Controls Needed to Improve Program Integrity, GAO-10-740T (Washington, D.C.: May 24,
2010).




Page 2                                                                       GAO-12-443T
                      and findings from recent VA Office of Inspector General (IG) and SBA IG
                      reports. 12 Additional information on our scope and methodology is
                      available in the prior issued products.

                      We conducted the work related to this testimony from January 2012 to
                      February 2012 in accordance with generally accepted government
                      auditing standards. Those standards require that we plan and perform the
                      audit to obtain sufficient, appropriate evidence to provide a reasonable
                      basis for our findings and conclusions based on our audit objectives. We
                      believe that the evidence obtained provides a reasonable basis for our
                      findings and conclusions based on our audit objectives.


                      The governmentwide SDVOSB program has limited fraud prevention
The Governmentwide    controls, allowing ineligible firms to receive millions of dollars in SDVOSB
SDVOSB Program        contracts. The program relies on firm self-certification, where agencies
                      (with the exception of VA, as discussed below) have instituted limited
Lacks Fraud           fraud prevention controls. Our prior work has found that SBA does not
Prevention Controls   verify the eligibility of firms claiming to be SDVOSBs in CCR, nor does it
                      have a process for using the VA database of verified service-disabled
                      veterans. 13 The main process for detecting fraud involves formal bid
                      protests, whereby interested parties to a contract award can protest a
                      firm’s status with SBA if they believe that the firm misrepresented its
                      small-business size or SDVOSB eligibility.

                      In contrast, an effective fraud prevention framework includes controls at
                      key stages in the contract process (see fig. 1). The most effective and
                      efficient aspect of the framework involves rigorous preventive controls at
                      the beginning of the process to provide assurance that only eligible firms
                      are permitted to bid on SDVOSB contracts. Next, because the status of
                      an SDVOSB firm can change over time, active and continual monitoring
                      of contractors performing SDVOSB contracts is also essential. Finally,
                      these controls are not fully effective unless identified fraud is aggressively
                      prosecuted and/or companies are suspended, debarred, or otherwise
                      held accountable.



                      12
                        VA OIG, Office of Audit and Evaluations, Department of Veteran Affairs: Audit of
                      Veteran-Owned and Service-Disabled Veteran-Owned Small Business Programs, 10-
                      02436-234 (July 25, 2011).
                      13
                           GAO-10-108.




                      Page 3                                                                    GAO-12-443T
Figure 1: GAO’s Fraud Prevention Framework




In October 2009, we exposed these weaknesses in governmentwide
fraud prevention controls by reporting on 10 case study firms that
misrepresented their eligibility for SDVOSB contracts. The firms
fraudulently received about $100 million in sole-source and set-aside
SDVOSB contracts despite being ineligible for the program, because their
initial and ongoing eligibility was not verified and monitored by the
contracting agencies. They exploited the lack of an effective
governmentwide fraud prevention program using a variety of schemes,
including setting up front companies to pass SDVOSB contracts on to
large, sometimes multinational firms ineligible for the program. Other
firms received contracts even though no service-disabled veteran was
associated with the firm or, if one was employed, he or she did not
manage or control the business.

The limited consequences of firms found to have abused the SDVOSB
program were further highlighted when we testified in July 2011 on
actions taken against these 10 firms. We reported that SBA and VA had
taken some actions against firms, including suspending 2 of the firms and
requesting that all firms change their status in CCR to show they were not
eligible for SDVOSB contracts. However, in July 2011, several of the
firms remained self-certified as SDVOSBs in CCR. Further, even after our
2009 report, the firms received more than $100 million in additional




Page 4                                                         GAO-12-443T
                       obligations on federal contracts through March 2011. 14 About $16 million
                       in obligations were associated with SDVOSB set-aside contracts. In our
                       2009 report, we recommended SBA and VA coordinate with the Office of
                       Federal Procurement Policy in order to explore the feasibility of
                       expanding VA’s verification process governmentwide. However, agency
                       officials stated that legislative changes would be necessary in order for
                       federal agencies to change the governmentwide SDVOSB program from
                       a self-certification process into using VA’s VetBiz verification program.
                       We also suggested that Congress consider expanding the VA verification
                       program to all agencies to help reduce the risk of fraud and abuse,
                       though no legislation to address this issue has become law. 15


                       In contrast to the limited fraud prevention controls for the governmentwide
VA Has Instituted      SDVOSB program, VA has recently instituted its own fraud prevention
Fraud Prevention       controls. The primary focus of VA’s recent efforts has been preventive
                       controls, but VA has also made progress in monitoring and investigations.
Controls in Its        First, VA has enhanced deterrents to ineligible firms becoming verified
Verification Program   through its verification process. As of April 2011, VA had established
                       verification guidelines, including a requirement to search the exact names
                       of company principals in the Excluded Parties List System, and
                       developed a risk assessment model to examine applications. VA also
                       updated its data systems to limit manual data entries. Its process of
                       verifying service-disabled veteran status allowed VA to prevent two
                       fictitious, ineligible SDVOSB applications we submitted from being
                       verified. VA’s fraud prevention controls appropriately identified that our
                       company owners were not service-disabled veterans (according to their
                       names and Social Security numbers) and rejected the applications. In
                       addition, VA has hired more staff to conduct initial file reviews and site
                       visits. VA has also conducted announced site visits at high-risk firms
                       before they were deemed eligible for the program. According to VA, its
                       enhanced deterrents under new guidelines denied over 1,800 ineligible
                       firms.




                       14
                        Dollar amounts relate to federal contract obligations made to the 10 case studies from
                       November 13, 2009, to March 4, 2011.
                       15
                         The Small Business Contracting Fraud Prevention Act of 2011, S. 633, 112th Cong. § 4
                       (2011) did address the matter, but did not become law.




                       Page 5                                                                       GAO-12-443T
Second, in the area of monitoring and detection, VA has developed some
fraud prevention controls that may help identify firms that were previously
verified but no longer meet SDVOSB eligibility requirements, such as a
reverification initiative designed to review previously verified SDVOSB
firms using new fraud prevention control techniques. VA has also
developed a process for interested parties to protest a firm’s status, and
instituted random announced site visits of verified SDVOSB firms.

Finally, in the area of investigations, VA has taken some actions to debar
firms violating SDVOSB program requirements. VA may debar an
ineligible firm in accordance with the Veterans Benefits, Health Care, and
Information Technology Act of 2006, which requires that any business
determined to have misrepresented its status as an SDVOSB be
debarred from contracting for a reasonable period of time, as determined
by VA. VA instituted a debarment committee in September 2010
specifically to debar firms violating SDVOSB regulations. As of October
2011, the committee had debarred one SDVOSB firm and related
individuals that had misrepresented their SDVOSB status. Several other
debarment actions were currently pending or were being litigated.
Additionally, VA officials had sent about 70 referrals to the VA IG for
potential fraudulent actions by firms receiving SDVOSB contracts. VA IG
was investigating these cases.

Even with these efforts to develop a more robust verification program for
SDVOSB firms, weaknesses remain. For example, in July 2011, the VA
IG reported that 32 of 42 (76 percent) firms receiving VA SDVOSB and
VOSB contracts that the IG reviewed for eligibility were ineligible to
participate in the programs or ineligible for the awarded contracts. 16 The
VA IG reviewed a statistical sample of contracts awarded during a 12-
month period ending May 2010. Some of the specific problems identified
by the VA IG included the use of pass-through practices where firms pass
SDVOSB work on to ineligible firms, and SDVOSB firms who exceeded
allowable subcontracting thresholds. The IG projected that from $500
million to $2.6 billion annually was awarded to ineligible firms, and that
the VA overstated its percentage of contracts awarded to SDVOSBs by 3
to 17 percent.



16
  VA OIG, Office of Audit and Evaluations, Department of Veteran Affairs: Audit of
Veteran-Owned and Service-Disabled Veteran-Owned Small Business Programs, 10-
02436-234 (July 25, 2011).




Page 6                                                                    GAO-12-443T
               Subsequent to the VA IG report, we reviewed more recent fraud
               prevention control improvements to VA’s verification process, which were
               discussed above. However, even with VA’s improved fraud prevention
               controls, we made 13 recommendations in November 2011 to further
               enhance aspects of VA’s fraud prevention framework. For example, in the
               area of preventive controls we recommended that VA provide fraud
               awareness training to its verification staff and contracting officials,
               validate applicant information with third-party data, and formalize a
               process for conducting unannounced site visits for high-risk firms. In the
               area of monitoring and detection, we recommended, among other issues,
               that VA develop procedures for periodic, risk-based reviews of firms
               receiving SDVOSB contracts to ensure continued compliance with
               program standards. Finally, in the area of investigations and
               prosecutions, we recommended that VA develop criteria for its debarment
               committee and program officials to ensure firms that violate program rules
               are referred to either VA’s debarment committee or its IG. We noted in
               our November 2011 testimony that there was room for improvement in
               the area of debarments since as of the date of our statement only one
               firm and related individuals had been debarred by VA out of the 1,800
               firms rejected by VA during its verification process and the 70 firms
               referred to VA IG for potentially fraudulent actions. VA generally
               concurred with our recommendations and stated they have taken
               numerous actions to address the identified issues.


               The SDVOSB program has provided billions of dollars in contracting
Concluding     opportunities to many deserving service-disabled veterans since its
Observations   inception in 2003. Unfortunately, the limited governmentwide fraud
               prevention controls have allowed unscrupulous individuals to gain access
               to those opportunities despite not being eligible for the program. While VA
               has taken steps to improve its verification program, our November 2011
               recommendations address additional improvements that should be made
               to further reduce its vulnerability. In response to our recommendations,
               VA has stated it has taken a number of actions which we plan to verify as
               part of ongoing work. In addition, the approximately 70 percent of
               contracts not awarded by VA are at a higher risk of being awarded to
               ineligible firms. We reiterate our suggestion that Congress consider
               expanding VA’s verification process governmentwide to employ more
               effective fraud prevention controls over the billions of dollars awarded to
               SDVOSBs outside of VA’s fraud prevention controls process.




               Page 7                                                          GAO-12-443T
               Chairman Lankford, Ranking Member Connolly, and Members of the
               Subcommittee, this completes my prepared statement. I would be
               pleased to answer any questions that you may have at this time.


               If you or your staff have any questions about this testimony, please
GAO Contacts   contact Richard J. Hillman at (202) 512-6722 or hillmanr@gao.gov.
               Contact points for our Offices of Congressional Relations and Public
               Affairs may be found on the last page of this statement.




               Page 8                                                         GAO-12-443T
Related GAO Products
             Related GAO Products




             Service-Disabled Veteran-Owned Small Business Program: Additional
             Improvements to Fraud Prevention Controls Are Needed. GAO-12-205T.
             Washington, D.C.: November 30, 2011.

             Service-Disabled Veteran-Owned Small Business Program: Additional
             Improvements to Fraud Prevention Controls Are Needed. GAO-12-152R.
             Washington, D.C.: October 26, 2011.

             Service-Disabled Veteran-Owned Small Business Program: Preliminary
             Information on Actions Taken by Agencies to Address Fraud and Abuse
             and Remaining Vulnerabilities. GAO-11-589T. Washington, D.C.: July 28,
             2011.

             Department of Veterans Affairs: Agency Has Exceeded Contracting Goals
             for Veteran-Owned Small Businesses, but It Faces Challenges with Its
             Verification Program. GAO-10-458. Washington, D.C.: May 28, 2010.

             Service-Disabled Veteran-Owned Small Business Program: Fraud
             Prevention Controls Needed to Improve Program Integrity. GAO-10-740T.
             Washington, D.C.: May 24, 2010.

             Service-Disabled Veteran-Owned Small Business Program: Case Studies
             Show Fraud and Abuse Allowed Ineligible Firms to Obtain Millions of
             Dollars in Contracts. GAO-10-306T. Washington, D.C.: December 16,
             2009.

             Service-Disabled Veteran-Owned Small Business Program: Case Studies
             Show Fraud and Abuse Allowed Ineligible Firms to Obtain Millions of
             Dollars in Contracts. GAO-10-255T. Washington, D.C.: November 19,
             2009.

             Service-Disabled Veteran-Owned Small Business Program: Case Studies
             Show Fraud and Abuse Allowed Ineligible Firms to Obtain Millions of
             Dollars in Contracts. GAO-10-108. Washington, D.C.: October 23, 2009.




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             Page 9                                                      GAO-12-443T
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