oversight

Small Business Administration Contracting Programs: Additional Efforts Needed to Implement GAO Recommendations

Published by the Government Accountability Office on 2019-06-12.

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

                           United States Government Accountability Office
                           Testimony
                           Before the Committee on Small
                           Business and Entrepreneurship,
                           U.S. Senate

                           SMALL BUSINESS
For Release on Delivery
Expected at 2:30 p.m. ET
Wednesday, June 12, 2019

                           ADMINISTRATION
                           CONTRACTING
                           PROGRAMS
                           Additional Efforts Needed
                           to Implement GAO
                           Recommendations
                           Statement of William B. Shear, Director,
                           Financial Markets and Community Investment




GAO-19-623T
                                                June 12, 2019

                                                SMALL BUSINESS ADMINISTRATION
                                                CONTRACTING PROGRAMS
                                                Additional Efforts Needed to Implement GAO
Highlights of GAO-19-623T, a testimony before
                                                Recommendations
the Committee on Small Business and
Entrepreneurship, U.S. Senate




Why GAO Did This Study                          What GAO Found
Federal agencies conduct a variety of           The Small Business Administration (SBA) has not fully implemented GAO’s prior
procurements that are reserved for              recommendations to address oversight deficiencies in the Women-Owned Small
small business participation through            Business (WOSB) and Historically Underutilized Business Zone (HUBZone)
small business set-asides. These set-           programs and to improve evaluation of its procurement scorecard. GAO
asides can be for small businesses in           maintains that its recommendations should be addressed.
general, or they can be specific to             Women-Owned Small Business Program. In its March 2019 report, GAO
small businesses that meet additional           found that SBA had not addressed WOSB program oversight deficiencies
eligibility requirements in programs            identified in GAO’s 2014 report (GAO-15-54). For example, GAO had found that
such as those for WOSB or                       SBA did not have procedures related to reviewing the performance of the four
HUBZone. SBA administers both the               third-party certifers—private entities approved by SBA to certify the eligibility of
WOSB and HUBZone programs. SBA                  WOSB firms—as well as information the certifiiers submitted to SBA. GAO
also produces an annual Small                   recommended that SBA establish procedures to assess the performance of the
Business Procurement Scorecard to               certifiers and the information they submitted. While SBA conducted a compliance
measure how much contracted                     review of the certifiers in 2016, SBA said in June 2018 that it had no plans to
spending federal agencies allocate to           conduct further compliance reviews until a final rule implementing a new
small businesses and whether the                certification process was completed. SBA officials said that they expected the
federal government is meeting its               rule to be implemented by June 2021. By waiting to improve its oversight of the
goals for awarding contracts to small           WOSB program, SBA cannot provide reasonable assurance that certifiers are
businesses.                                     complying with program requirements and cannot improve its efforts to identify
GAO issued three reports between                ineligible firms or potential fraud.
September 2018 and March 2019 on                HUBZone Program. In September 2018, GAO reported that it had reviewed
SBA contracting programs (see GAO-              case files for a nongeneralizable sample of 12 firms in Puerto Rico that received
18-666, GAO-18-672, and GAO-19-                 HUBZone certification between March 2017 and March 2018 and found that SBA
168). This testimony is primarily               did not consistently document or follow its policies and procedures for
based on these three reports and                certification reviews. For example, SBA did not have complete documentation in
discusses prior GAO findings and                nine of 12 cases and did not follow its policy to conduct three levels of review
SBA’s progress on implementing                  when determining whether to approve or deny a firm in four of 12 cases. As a
GAO’s recommendations on (1) the                result, SBA did not have reasonable assurance that firms meet HUBZone criteria.
WOSB program, (2) the HUBZone                   SBA said that it planned to implement GAO’s recommendations that SBA (1)
program, and (3) SBA’s procurement              update internal policy manuals for certification and recertification and (2) conduct
scorecard.                                      and document reviews of staff compliance with relevant procedures. However, as
To update the status of prior                   of May 2019, SBA had not provided documentation showing that it had
recommendations, GAO reviewed                   completed these planned actions.
updates from SBA and interviewed                Small Business Procurement Scorecard. For fiscal year 2017, SBA revised
officials.                                      the methodology for its Small Business Procurement Scorecard, which assesses
                                                the efforts of federal agencies to support contracting with small businesses. For
                                                example, one revision reduced the share of the total scorecard grade devoted to
                                                prime contracting achievement (the dollar amount of contracts awarded directly
                                                to small businesses). GAO recommended in September 2018 that SBA design
                                                and implement a comprehensive evaluation to assess the scorecard revisions.
                                                Since that report was issued, SBA has proposed but not yet implemented a two-
                                                phase evaluation of the scorecard to include an evaluation of the scorecard’s
View GAO-19-623T. For more information,         effect on federal agencies achieving small business contracting goals. SBA said
contact William B. Shear at (202) 512-8678 or   that it expects to complete phase one by September 2019 and has not provided
shearw@gao.gov.                                 a time frame for phase two.

                                                ______________________________________ United States Government Accountability Office
Letter
         Letter




         Chairman Rubio, Ranking Member Cardin, and Members of the
         Committee:

         I am pleased to be here today to discuss our recent work on the Small
         Business Administration’s (SBA) contracting programs and SBA’s
         progress in implementing our recommendations. Federal agencies
         conduct a variety of procurements that are reserved for small business
         participation through small business set-asides. These set-asides can be
         for small businesses in general, or they can be specific to small
         businesses that meet additional eligibility requirements, such as those for
         SBA’s Women-Owned Small Business (WOSB) or Historically
         Underutilized Business Zones (HUBZone) programs. 1 SBA also produces
         an annual Small Business Procurement Scorecard (scorecard) to
         measure how much contracted spending federal agencies allocate to
         small businesses and whether the federal government is meeting its
         goals for awarding contracts to small businesses.

         My testimony today is based primarily on three reports we issued
         between September 2018 and March 2019, as well as a report we issued
         in October 2014. 2 I will discuss SBA’s progress on implementing our prior
         recommendations on (1) the WOSB program, (2) the HUBZone program
         in Puerto Rico, and (3) SBA’s procurement scorecard.

         To conduct the work on the WOSB program, we reviewed relevant laws,
         regulations, and program documents; analyzed federal contracting data
         from April 2011 through June 2018; and interviewed SBA officials,
         officials from contracting agencies selected to obtain a range of
         experience with the WOSB program, and three of the four private third-


         1
          Congress authorized the WOSB program in 2000, allowing contracting officers to set
         aside procurements to women-owned small businesses in industries in which they are
         substantially underrepresented. The purpose of the HUBZone program is to provide
         federal contracting preferences to qualified small businesses located in economically
         distressed communities (referred to as HUBZones) that employ residents of the areas.
         2
          GAO, Women-Owned Small Business Program: Actions Needed to Address Ongoing
         Oversight Issues, GAO-19-168 (Washington, D.C.: Mar. 14, 2019); Small Business
         Contracting: Small Business Administration Could Further Strengthen HUBZone Eligibility
         Reviews in Puerto Rico and Programwide, GAO-18-666 (Washington, D.C.: Sept. 24,
         2018); Small Business Administration: Actions Needed to Improve Confidence in Small
         Business Procurement Scorecard, GAO-18-672 (Washington, D.C.: Sept. 27, 2018); and
         Women-Owned Small Business Program: Certifier Oversight and Additional Eligibility
         Controls Are Needed, GAO-15-54 (Washington, D.C.: Oct. 8, 2014).




         Page 1                  GAO-19-623T Small Business Administration Contracting Programs
                     party certifiers. 3 For our HUBZone report, we analyzed SBA documents
                     and reviewed files of a nongeneralizable sample of 12 firms located in
                     Puerto Rico that received certification between March 2017 and March
                     2018. We also interviewed SBA officials, representatives from HUBZone-
                     certified firms in Puerto Rico, and local economic development agencies
                     in Puerto Rico. To conduct the work on SBA’s procurement scorecard, we
                     analyzed SBA’s prior and revised scorecard methodology and results and
                     interviewed officials from SBA, four other federal agencies selected based
                     on small business procurement volume and other attributes, and three
                     groups representing the interests of small businesses. To update the
                     status of recommendations from these reports, we reviewed updates from
                     SBA and interviewed officials. We conducted the work on which this
                     testimony is based in accordance with generally accepted government
                     auditing standards. More details on our methodology can be found in the
                     three reports on which this testimony is based.


                     SBA has not fully addressed deficiencies we have previously identified for
SBA Has Not Fully    the WOSB program, and these deficiencies are affected by SBA’s
Addressed            ongoing implementation of changes to the program authorized by the
                     National Defense Authorization Act of 2015 (2015 NDAA). As of early
Deficiencies in      June 2019, SBA had implemented one of the three changes to the
Oversight and        program authorized in the 2015 NDAA. 4 Specifically, in September 2015
                     SBA published a final rule to implement sole-source authority (to award
Implementation for   contracts without competition), effective October 2015. The two other
the WOSB Program     changes—authorizing SBA to implement its own certification process for
                     WOSBs and requiring SBA to eliminate the option for firms to self-certify
                     that they are eligible for the WOSB program—had not been
                     implemented. 5 On May 14, 2019, SBA published in the Federal Register a
                     proposed rule that eliminates the self-certification option and describes a
                     potential certification process to be administered by SBA. 6 SBA officials
                     have stated that the agency will not eliminate self-certification until the

                     3
                      To be eligible to participate in the WOSB program, firms have the option to self-certify or
                     be certified by a third-party certifier.
                     4
                         GAO-19-168.
                     5
                      The 2015 NDAA expanded the WOSB certification process to include certification by the
                     SBA Administrator, in addition to the previously approved methods of certification by a
                     federal agency, a state government, or a national certifying entity approved by SBA.
                     6
                       Women-Owned Small Business and Economically Disadvantaged Women-Owned Small
                     Business – Certification, 84 Fed. Reg. 21256 (May 14, 2019).




                     Page 2                    GAO-19-623T Small Business Administration Contracting Programs
new certification process for the WOSB program is in place, which they
expect to implement by June 2021.

In addition, SBA has not fully addressed WOSB program oversight
deficiencies described in our March 2019 report and first identified in our
2014 report. 7 We reported that SBA did not have formal policies for
reviewing the performance of its four approved third-party certifiers
(private entities approved by SBA to certify the eligibility of WOSB firms),
including their compliance with their agreements with SBA. Further, we
found that SBA had not developed formal policies and procedures for,
among other things, reviewing the monthly reports that certifiers submit to
SBA. 8 We recommended that the Administrator of SBA establish
comprehensive procedures to monitor and assess the performance of the
third-party certifiers in accordance with their agreements with SBA and
program regulations. While SBA has taken some steps to address our
recommendation, including conducting a compliance review of the
certifiers in 2016, SBA officials said in June 2018 that SBA had no plans
to conduct further compliance reviews until the final rule implementing the
new certification process was completed. By waiting to improve its
oversight of the WOSB program, SBA cannot provide reasonable
assurance that certifiers are complying with program requirements and
cannot improve its efforts to identify ineligible firms or potential fraud. In
addition, the implementation of sole-source authority in light of these
continued oversight deficiencies can increase program risk.
Consequently, we maintain that our recommendation should be
addressed.

SBA also has not fully addressed deficiencies related to eligibility
examinations that we described in our March 2019 report and first
identified in our October 2014 report. We found that SBA lacked
formalized guidance for its eligibility examination processes and that the
examinations identified high rates of potentially ineligible businesses. As
a result, we recommended that SBA enhance its examination of
businesses that register for the WOSB program to ensure that only
eligible businesses obtain WOSB set-asides. Specifically, we suggested
that SBA should take actions such as (1) completing the development of
procedures to conduct annual eligibility examinations and implementing

7
    GAO-15-54.
8
Per their written agreements with SBA, the third-party certifiers are required to submit
monthly reports to SBA describing WOSB program performance information.




Page 3                   GAO-19-623T Small Business Administration Contracting Programs
such procedures; (2) analyzing examination results and individual
businesses found to be ineligible to better understand the cause of the
high rate of ineligibility in annual reviews and determine what actions are
needed to address the causes, and (3) implementing ongoing reviews of
a sample of all businesses that have represented their eligibility to
participate in the program.

SBA has taken some steps to implement our recommendation, such as
including written policies and procedures for WOSB program eligibility
examinations in a standard operating procedure and a Desk Guide.
However, SBA does not collect reliable information on the results of its
annual eligibility examinations. In addition, SBA continues to have no
mechanism to look across examinations for common eligibility issues to
inform the WOSB program. As we noted in 2014, by not analyzing
examination results broadly, the agency is missing opportunities to obtain
meaningful insights into the program, such as the reasons many
businesses are deemed ineligible.

Further, SBA still conducts eligibility examinations only of firms that have
already received a WOSB award. Restricting the samples in this way
limits SBA’s ability to better understand the eligibility of businesses before
they apply for and are awarded contracts, as well as its ability to detect
and prevent potential fraud.

We recognize that SBA has made some effort to address our
recommendation by documenting procedures for conducting annual
eligibility examinations of WOSB firms. However, without maintaining
reliable information on the results of eligibility examinations, developing
procedures for analyzing results, and expanding the sample of
businesses to be examined to include those that did not receive
contracts, SBA limits the value of its eligibility examinations and its ability
to reduce ineligibility among businesses registered to participate in the
WOSB program. Leading fraud risk management practices state that
federal program managers should design control activities that focus on
fraud prevention over detection and response, to the extent possible. 9
The deficiencies in SBA’s oversight of the WOSB program limit SBA’s
ability to identify potential fraud risks and develop any additional control
activities needed to address these risks. As a result, the program may

9
 GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 2015).




Page 4                GAO-19-623T Small Business Administration Contracting Programs
continue to be exposed to the risk of ineligible businesses receiving set-
aside contracts. In addition, in light of these continued deficiencies, the
implementation of sole-source authority without addressing the other
changes made by the 2015 NDAA could increase program risk. For these
reasons, we maintain that our previous recommendation that SBA
enhance its WOSB eligibility examination procedures should be
addressed.

In addition, similar to previous findings from SBA’s Office of Inspector
General, our March 2019 report found that about 3.5 percent of contracts
using a WOSB set-aside were awarded for ineligible goods or services
from April 2011 through June 2018. 10 At that time, SBA was not reviewing
contracting data that could identify this problem and inform SBA which
agencies making awards may need targeted outreach or training. As a
result, we found that SBA could not provide reasonable assurance that
WOSB program requirements were being met and that the program was
meeting its goals. We recommended that SBA develop a process for
periodically reviewing the extent to which WOSB program set-asides are
awarded for ineligible goods or services and use the results to address
identified issues, such as through targeted outreach or training to
agencies making awards under the ineligible codes. In early May 2019,
SBA said that it had initiated such efforts.




10
   GAO-19-168. See also Small Business Administration Office of Inspector General,
Improvements Needed in SBA’s Management of the Women Owned Small Business
Federal Contracting Program, SBA OIG Report 15-10 (Washington, D.C.: May 14, 2015)
and SBA’s Women-Owned Small Business Contracting Program, SBA OIG Report 18-18
(Washington, D.C.: June 20, 2018).




Page 5                 GAO-19-623T Small Business Administration Contracting Programs
                        In September 2018, we found that although SBA had adopted criteria and
SBA Has Not Yet         guidance for a risk-based approach to certifying and recertifying firms for
Implemented             the HUBZone program in March 2017, the extent to which it conducted a
                        risk assessment to inform its approach was unclear. 11 In 2015, we found
Recommendations to      that SBA lacked key controls for its recertification process and
Improve the             recommended that SBA assess the process. 12 In 2009, SBA increased
HUBZone                 documentation requirements for certification but not recertification (which
                        determines continued program eligibility every 3 years). In March 2017,
Certification Process   SBA changed its recertification criteria and guidance to require firms with
                        $1 million or more in HUBZone contract awards to provide documentation
                        to support continuing eligibility. During our work for the September 2018
                        report, SBA officials stated they had completed a risk assessment of the
                        HUBZone recertification process, but did not provide us with
                        documentation on when they performed the risk assessment, which risks
                        were identified and considered, or what analysis established the $1
                        million threshold. As of May 2019, SBA had not provided documentation
                        showing that it had performed the risk assessment, but we maintain that
                        an assessment of the recertification process would help inform a risk-
                        based approach to reviewing and verifying information from firms that
                        appear to pose the most risk to the program. In addition, SBA had not
                        provided documentation showing that a technology-based solution
                        designed to address some of the ongoing challenges with the
                        recertification process had been implemented. SBA officials had
                        previously estimated this solution would be available first in spring 2017
                        and then by the end of calendar year 2017. 13

                        We also found in our September 2018 report that, based on our review of
                        case files for a nongeneralizable sample of 12 firms in Puerto Rico that
                        received HUBZone certification between March 2017 and March 2018,
                        SBA did not consistently document or follow its policies and procedures
                        for certification reviews:


                        11
                             GAO-18-666.
                        12
                         See GAO, Small Business Contracting: Opportunities Exist to Further Improve HUBZone
                        Oversight, GAO-15-234 (Washington, D.C.: Feb. 12, 2015).
                        13
                          See GAO, HUBZone Program: Opportunities Exist to Further Improve Oversight, GAO-
                        16-866T (Washington, D.C.: Sept. 7, 2016); and HUBZone Program: Oversight Has
                        Improved But Some Weaknesses Remain, GAO-17-456T (Washington, D.C.: Mar. 2,
                        2017).




                        Page 6                 GAO-19-623T Small Business Administration Contracting Programs
                     •      SBA did not have complete documentation in nine of 12 cases. SBA
                            officials described alternative procedures they used to determine
                            firms’ eligibility, but SBA had not updated its internal policy manuals to
                            reflect these procedures, and analysts did not document use of such
                            procedures in the files we reviewed. As a result, SBA did not have
                            reasonable assurance that firms met HUBZone criteria.
                     •      In four of 12 cases, SBA did not follow its policy to conduct three
                            levels of review (by an analyst, a senior analyst, and the program
                            director or deputy) when determining whether to approve or deny a
                            firm.
                     •      It was unclear to what extent SBA reviewed staff compliance with
                            certification and recertification review procedures. SBA provided an
                            assurance letter stating that it evaluated the Office of HUBZone’s
                            internal controls and concluded the controls were effective, but the
                            letter did not specify what steps SBA took for the evaluation.
                     We recommended that SBA (1) update its internal policy manuals for
                     certification and recertification reviews to reflect existing policies and
                     procedures not currently in written guidance and (2) conduct and
                     document reviews of staff compliance with procedures associated with
                     HUBZone certification and recertification. In response to our report, SBA
                     said that it planned to update its internal policies on certification and
                     recertification by issuing a procedural notice and to begin reviewing and
                     documenting staff compliance with the updated procedures outlined in the
                     notice. However, as of May 2019, SBA had not provided documentation
                     showing that it had completed these planned actions.


                     In September 2018, we found that for fiscal year 2017, SBA revised the
SBA Has Taken Some   methodology for its Small Business Procurement Scorecard, which is
Steps to Address     used to assess federal agencies’ progress toward small business
                     procurement goals. 14 SBA made revisions to address requirements
Recommendations      specified in the National Defense Authorization Act for Fiscal Year 2016.
about the            SBA (1) reduced the share of the total scorecard grade devoted to prime
                     contracting achievement, which is the dollar amount of contracts awarded
Procurement          directly to small businesses, and (2) added an element calculating
Scorecard            changes in the number of small businesses receiving prime contracts.
                     SBA made two additional revisions—with input from other agencies’
                     representatives—to increase the share of subcontracting achievement

                     14
                          GAO-18-672.




                     Page 7                  GAO-19-623T Small Business Administration Contracting Programs
results and the share of the peer review of required activities designed to
facilitate small business procurement. In July 2018, officials said they had
begun developing a plan to evaluate the effects of the revised scorecard
methodology but did not provide a draft plan. Conducting a well-designed
and comprehensive evaluation could aid SBA in determining whether the
scorecard is an effective tool for helping to achieve the agency’s strategic
goals.

In our September 2018 report, we also found that the published fiscal
year 2017 scorecards originally contained errors, including an incorrect
grade and numeric score for one agency, and SBA does not have a
process to ensure that scorecard results are published accurately.
Although SBA later corrected the errors, it did not initially document that
scorecards had been changed, which is inconsistent with SBA’s policy on
information quality. SBA officials said that errors occurred in the process
of formatting scorecards for publication. Errors in the published
scorecards—and the initial lack of disclosure about corrections—weaken
data reliability and may undermine confidence in scorecard data.

We recommended that SBA (1) design and implement a comprehensive
evaluation to assess scorecard revisions and (2) institute a process for
reviewing scorecards for accuracy prior to publication and a mechanism
for disclosing corrected information. Since our report, SBA has proposed
a two-phase program evaluation of the scorecard. SBA officials said that
they plan for phase one to include a report to Congress on the impact of
the small business procurement goal program for Chief Financial Officers
Act agencies and to provide a recommendation on continuing, modifying,
expanding, or terminating the scorecard program. 15 SBA plans to provide
the phase one report in September 2019. In phase two, SBA plans to
conduct a program evaluation that investigates the effectiveness of the
small business contracting scorecard on federal agency small business
contracting goal achievement. SBA has not provided a time frame for
phase two. With respect to the second recommendation, SBA officials
said that SBA has developed a procedure that includes a prepublication
review process for procurement scorecards. The officials said the
procedure identifies responsibilities, provides for an independent peer
review, and includes supervisory review. Officials said the procedure also

15
  The Chief Financial Officers Act of 1990, Pub. L. No. 101-576, established chief financial
officers to oversee financial management activities at 23 major executive departments and
agencies. The list now includes 24 entities, which are often referred to collectively as Chief
Financial Officers Act agencies.




Page 8                    GAO-19-623T Small Business Administration Contracting Programs
                  includes measures for post-publication review and corrections. We will
                  review supporting documentation for this new procedure to assess
                  whether this recommendation can be closed as implemented.


                  Chairman Rubio, Ranking Member Cardin, and Members of the
                  Committee, this completes my prepared statement. I would be pleased to
                  respond to any questions that you may have at this time.


                  If you or your staff have any questions about this testimony, please
GAO Contact and   contact William Shear, Director, Financial Markets and Community
Acknowledgments   Investment at (202) 512-8678 or shearw@gao.gov. Contact points for our
                  Offices of Congressional Relations and Public Affairs may be found on
                  the last page of this statement. GAO staff who made key contributions to
                  this testimony are Andrew Pauline (Assistant Director), Paige Smith
                  (Assistant Director), Winnie Tsen (Assistant Director), and Jennifer
                  Schwartz.




(103592)
                  Page 9              GAO-19-623T Small Business Administration Contracting Programs
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