a

GAO

United States General Accounting Office

Report to the Committee on Small 

Business and Entrepreneurship, U.S. 

Senate

March 2004 SMALL AND 

DISADVANTAGED 

BUSINESSES

Most Agency 

Advocates View Their 

Roles Similarly

GAO-04-451
www.gao.gov/cgi-bin/getrpt?GAO-04-451.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact David G. Wood 

at (202) 512-8678 or woodd@gao.gov. 

Highlights of GAO-04-451, a report to the 

Committee on Small Business and 

Entrepreneurship, U.S. Senate 

March 2004

SMALL AND DISADVANTAGED 

BUSINESSES 

Most Agency Advocates View Their Roles 

Similarly 

At least 19 OSDBU directors, or almost 80 percent, said that they viewed five 

of the eight functions identified in section 15(k) as their duties. A smaller 

majority of OSDBU directors (from 13 to 17) viewed the remaining three 

functions as responsibilities of their offices. However, the extent to which 

respondents said they carried out these functions varied. Directors who did 

not view all of the functions as responsibilities of their offices provided 

explanations. For example, the OSDBU directors at the Departments of the 

Army and the Navy explained that their role is one of developing policy for 

small business programs at their agencies. 

Most of the OSDBU directors responded that they also viewed functions 

other than those listed in section 15(k) as their responsibilities. These 

functions included outreach activities, such as holding meetings and hosting 

conferences for small businesses and trade associations, and reviewing 

plans for how prime contractors would use small businesses as 

subcontractors. A much smaller number of respondents reported that they 

viewed participating in their agencies’ procurement process as one of their 

duties. 

While most OSDBU directors reported experiencing few challenges in 

carrying out their responsibilities, some reported challenges in three areas—

lack of influence in the procurement process, limited budgetary resources, 

and lack of adequate staffing levels. 

Survey Results from 24 OSDBU Directors on Section 15(k) Functions 

Section 15(k) functions 

Number of OSDBU 

directors viewing 

function as a current 

duty

Supervisory authority over personnel with the duties and functions of 

OSDBU 22

Working with agency acquisition officials to revise procurement 

strategies for bundled contract requirements to increase small business 

participation 22

Attempting to identify solicitations that involve bundling of contract 

requirements 21

Assisting small businesses to obtain payments from your agency 20

Facilitating small business participation as subcontractors to bundled 

contracts 19

Assisting small businesses to obtain payments from prime contractors 17

Reviewing individual acquisitions for small business contract awards 17

Assigning a small business technical advisor 13

Source: GAO analysis of survey data. 

The Small Business Act is one of 

several laws designed to enhance 

the participation of small and 

disadvantaged businesses in 

federal procurement—a market 

that reached more than $200 billion 

in fiscal year 2002. Section 15(k) of 

the act requires that all federal 

agencies with procurement powers 

establish an Office of Small and 

Disadvantaged Business Utilization 

(OSDBU) and specifies eight 

functions that OSDBU directors are 

responsible for carrying out in their 

roles as advocates for small 

businesses. GAO surveyed OSDBU 

directors at 24 agencies to obtain 

information on the extent to which 

the respondents (1) viewed the 

functions listed in section 15(k) as 

functions of their offices, (2) 

viewed other potential activities as 

OSDBU duties, and (3) saw 

potential challenges to carrying out 

their functions. 
Page i GAO-04-451 Small and Disadvantaged Businesses

Contents

Letter 1

Background 2

Results in Brief 5

Almost All of the OSDBU Directors Viewed Most Section 15(k) 

Functions as Duties of Their Offices 7

OSDBU Directors Reported Performing Additional Activities as Well 

as Their Section 15(k) Functions 17

Most OSDBU Directors Saw Few Challenges to Carrying Out Their 

Responsibilities 19

Scope and Methodology 20

Agency Comments and Our Evaluation 22

Appendixes

Appendix I: Twenty-four Agencies Surveyed on OSDBU Roles and 

Functions 24

Appendix II: Summary of GAO Survey Results from 24 OSDBU 

Directors 25

Introduction 25

OSDBU Roles in Agency Procurement 25

Appendix III: GAO Contact and Staff Acknowledgments 44

GAO Contacts 44

Staff Acknowledgments 44

Figures Figure 1: Survey Results from 24 OSDBU Directors on Section 

15(k) Functions 8

Figure 2: Level of OSDBU Activity on Contract Bundling 

Functions 10

Figure 3: Level of OSDBU Activity of Reviewing Individual 

Acquisitions for Small Business Set-asides 12

Figure 4: Level of OSDBU Director Cooperation and Consultation 

with SBA 13

Figure 5: OSDBU Directors’ Reporting Challenges 20
Contents

Page ii GAO-04-451 Small and Disadvantaged Businesses

Abbreviations

DLA Defense Logistics Agency

DOD Department of Defense

DOT Department of Transportation

FAR Federal Acquisition Regulation

GSA General Services Administration

HUD Department of Housing and Urban Development

NASA National Aeronautics and Space Administration 

OMB Office of Management and Budget

OPM Office of Personnel Management

OSDBU Office of Small and Disadvantaged Business Utilization

SBA Small Business Administration

SSA Social Security Administration

USAID U.S. Agency for International Development

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

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other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-04-451 Small and Disadvantaged Businesses

United States General Accounting Office

Washington, D.C. 20548

A

March 22, 2004 Letr

The Honorable Olympia J. Snowe

Chair

The Honorable John F. Kerry

Ranking Minority Member

Committee on Small Business and Entrepreneurship

United States Senate

During the last 25 years, Congress has enacted several laws designed to 

foster small business participation in federal procurement—a market that 

reached more than $200 billion in fiscal year 2002. One of these laws, Public 

Law 95-507, enacted in 1978, amended section 15 of the Small Business Act 

(15 U.S.C. § 644) to require that all federal agencies with procurement 

powers establish an Office of Small and Disadvantaged Business Utilization 

(OSDBU) and appoint a director to head the office. Under this act, the 

OSDBU is responsible for helping to oversee the agency’s functions and 

duties related to the awarding of contracts and subcontracts to small and 

disadvantaged businesses. Paragraphs (4)-(10) of section 15(k) of the act 

specify a number of functions that OSDBU directors are responsible for 

carrying out in their roles as advocates for small businesses. 

On September 4, 2003, we issued a report to you assessing federal agencies’ 

compliance with section 15(k)(3) of the Small Business Act, which requires 

that the OSDBU director be responsible to and report only to agency heads 

or deputy heads. The report covered the 24 federal agencies that procured 

at least $200 million or more in goods and services in fiscal year 2001.1

 As 

requested, this current report provides additional information on the views 

of the OSDBU directors regarding their functions within the agencies. 

Specifically, we obtained information on the extent to which the OSDBU 

directors (1) viewed the functions listed in section 15(k) as the duties of 

their offices, (2) viewed other potential functions as OSDBU duties, and (3) 

saw any potential challenges to their ability to carry out their duties.

1

See U.S. General Accounting Office, Small and Disadvantaged Businesses: Some 

Agencies’ Advocates Do Not Report to the Required Management Level, GAO-03-863

(Washington, D.C.: Sept. 4, 2003).
Page 2 GAO-04-451 Small and Disadvantaged Businesses

To address these objectives, we administered a Web-based questionnaire to 

24 OSDBU directors between May 2003 and September 2003.2

 The 

questionnaire asked the directors about their functions in three areas: (1) 

participation in the agency procurement process, (2) facilitation of small 

business participation in agency contracting, and (3) interaction with the 

Small Business Administration (SBA). The three areas covered OSDBU 

functions listed in section 15(k) of the Small Business Act as well as 

functions mentioned by OSDBU directors during our preliminary 

interviews with them. In addition, the questionnaire asked the directors 

what challenges they faced in carrying out their responsibilities. All 24 

OSDBU directors responded to the questionnaire.3

 In order to understand 

the basis of their responses, we conducted follow-up interviews with those 

directors who indicated that one or more of the functions listed in section 

15(k) were not functions of their OSDBU. However, we did not assess the 

24 agencies’ compliance with the provisions of section 15(k). We 

conducted our work in accordance with generally accepted government 

auditing standards. 

Background The federal government purchases billions of dollars in goods and services 

each year in a structured process regulated by the Federal Acquisition 

Regulation (FAR). The FAR establishes uniform policies and procedures 

for the acquisition of supplies and services. For the purpose of our survey, 

we divided the procurement process into four steps:

• Acquisition planning involves developing an overall management 

strategy for the procurement process for a potential contract. It takes 

place well in advance of a contract’s award date and generally involves 

both a close partnership between the program and procurement offices 

and the involvement of other key stakeholders.

2

See appendix I for the list of agencies that participated in the survey.

3

See appendix II for a summary of the OSDBU directors’ responses to the questionnaire. 
Page 3 GAO-04-451 Small and Disadvantaged Businesses

• Solicitation development is the process of preparing requests for 

vendors to submit offers, or bids. Solicitations can be conducted using 

various procedures, such as sealed bids, negotiation, or a simplified 

acquisition.4

• Proposal evaluation occurs after potential contractors submit 

proposals that outline how they will fulfill the solicitation requirements. 

Contracting officers evaluate quotations and award the contract. 

• Monitoring, also known as surveillance, helps to determine a 

contractor’s progress and identify any factors that may delay 

performance. 

The federal government’s long-standing policy has been to maximize 

procurement opportunities for small, small disadvantaged, and womenowned businesses. To ensure that small businesses receive a share of 

federal procurement contract dollars, Congress has mandated that SBA 

negotiate annual procurement goals with each federal agency. Congress 

has also amended the Small Business Act several times to increase small 

business participation in the federal procurement marketplace. For 

example, the Business Opportunity Reform Act of 1988 amended the Small 

Business Act to require the President to establish an annual 

governmentwide goal of awarding not less than 20 percent of prime 

contract dollars to small businesses.5

 The Small Business Reauthorization 

Act of 1997 further amended the Small Business Act to increase the goal to 

not less than 23 percent. To help meet this goal, SBA annually establishes 

prime contract goals for all categories of small businesses for each federal 

agency.6

 Although SBA is responsible for coordinating with executive 

4

The use of sealed bids is a method of contracting that uses competitive bidding where the 

award is made generally on the basis of cost. For negotiated contracts, bids are not sealed. 

Agencies use negotiation when it may be in the best interest of the government to consider 

awarding the contract on a basis other than the lowest price. Agencies use simplified 

acquisition procedures to the maximum extent practicable for all purchases of supplies or 

services not exceeding a certain threshold, generally $100,000. Purchases can be made 

through various streamlined means, including governmentwide commercial purchase cards, 

purchase orders, and blanket purchase agreements. 

5

A prime contract is any direct contract between the government and a contractor.

6

The small business categories include small businesses; women-owned small businesses; 

small disadvantaged businesses, including section 8(a) and non-section 8(a) disadvantaged 

businesses; HUBZone small businesses; veteran-owned small businesses; and servicedisabled, veteran-owned small businesses.
Page 4 GAO-04-451 Small and Disadvantaged Businesses

branch agencies to prompt the federal government toward this mandated 

goal, agency heads are responsible for achieving the small business goals 

within their agencies. 

Section 15(k) of the Small Business Act describes eight functions of 

OSDBU directors as follows:7

• Identifying solicitations that involve bundled contract requirements.8

• Working with agency procurement officials to revise bundled contracts 

to increase the probability of participation by a small business.

• Facilitating the participation of small businesses as subcontractors for 

bundled contracts.

• Assisting small businesses in obtaining payments from an agency with 

which it has contracted.

• Helping small businesses acting as subcontractors to obtain payments 

from prime contractors.9

• Making recommendations to agency contracting officers regarding 

whether a particular contract should be awarded to a small business.10

• Maintaining supervisory authority over OSDBU personnel. 

• Cooperating and consulting on a regular basis with SBA in carrying out 

OSDBU functions and duties, and assigning a small business technical 

7

These functions are also part of section 19.201(d) of the FAR, the implementing regulation 

for section 15(k) of the Small Business Act. 

8

The Small Business Reauthorization Act of 1997 defines the bundling of contract 

requirements as the consolidation of two or more procurement requirements for goods or 

services previously provided or performed under separate, smaller contracts into a 

solicitation of offers for a single contract that is likely to be unsuitable for award to a small 

business concern.

9

A subcontractor is any person, other than the prime contractor, who offers to furnish or 

furnishes any supplies, materials, equipment, or services of any kind under a prime contract.

10Under section 15(k), the OSDBU director is to make recommendations regarding whether 

a particular contract should be awarded to a small business under certain programs 

designed to promote contracting opportunities for small businesses. 
Page 5 GAO-04-451 Small and Disadvantaged Businesses

advisor to each office where SBA has appointed a procurement center 

representative.11 (A procurement center representative is an SBA staff 

member assigned to a federal agency’s contract administration office to 

carry out SBA policies and programs.) 

In addition to these eight functions, OSDBU directors have working 

relationships with SBA and the agency procurement staff. However, 

OSDBU directors are not the only officials responsible for helping small 

businesses participate in federal procurement. The FAR establishes a 

number of responsibilities for SBA and agency procurement staff in 

implementing small business programs. The FAR provides that, among 

other things, SBA may assign one or more procurement center 

representatives to any agency’s contracting activity or contract 

administration office to carry out SBA policies and programs. A 

procurement center representative’s responsibilities include 

• increasing small businesses’ share of federal procurement awards by 

initiating small business set-asides, 

• reserving procurements for competition among small business firms, 

• providing small business sources to federal agencies, and 

• counseling small firms. 

At the agency level, the heads of procurement departments are responsible 

for implementing the small business programs at their agencies, including 

achieving program goals. Generally, staff within agency procurement 

departments who are assigned to work on small business issues, or small 

business specialists, coordinate with OSDBU directors on their agencies’ 

small business programs. 

Results in Brief Almost all of the 24 OSDBU directors reported that they viewed most of the 

section 15(k) functions we asked about as current responsibilities of their 

offices. Specifically, at least 19 of the 24 directors reported that they viewed 

five of the eight as functions of their office. These five functions included 

11The small business technical advisor is to be a technically trained employee of the 

contracting activity who is familiar with the supplies or services purchased at the office, and 

is to assist the procurement center representative. 
Page 6 GAO-04-451 Small and Disadvantaged Businesses

the three relating to contract bundling; the other two were helping small 

businesses obtain payments from the agencies and maintaining supervisory 

authority over OSDBU staff. A smaller majority (from 13 to 17) of OSDBU 

directors viewed the remaining three functions—helping small businesses 

obtain payments from prime contractors, reviewing individual contracts 

for small business set-asides, and appointing a small business technical 

advisor to offices with an SBA representative—as their responsibilities. 

However, the extent to which respondents said they carried out these 

functions varied. For example, 17 of the 24 directors reported that they 

attempted to identify solicitations that involve contract bundling to either a 

great or very great extent, but fewer than half reported helping small 

businesses with payment problems to a great or very great extent. 

Directors who did not view all of the functions as responsibilities of their 

offices provided reasons for their responses. For example, the OSDBU 

directors at the Departments of the Army and the Navy explained that their 

role is one of developing policy for the small business programs at their 

agencies, and that the 15(k) functions are generally carried out by the 

Army’s and Navy’s small business specialists. 

Most of the OSDBU directors responded that they also viewed functions 

other than those listed in section 15(k) as their responsibilities. For 

example, a majority of the directors reported that they viewed outreach 

activities, such as holding meetings and hosting conferences for small 

businesses and trade associations, as their functions, and 20 reported 

having hosted such events in the last 2 years. In addition, almost all (21) of 

the OSDBU directors agreed that one of their functions was reviewing 

subcontracting plans that show how prime contractors would use small 

businesses as subcontractors. A much smaller number of OSDBU directors 

reported that they viewed participating in the various steps of their 

agencies’ procurement process as one of their functions. For example, only 

9 directors cited developing proposed bid solicitations as a function, and 8 

cited evaluating bid proposals. 

Most OSDBU directors reported experiencing few challenges in carrying 

out their responsibilities. Of the seven potential challenges identified in our 

survey, more than half of the directors viewed three issues—lack of 

influence in the procurement process, limited budgetary resources, and 

lack of adequate staffing levels—as challenges to at least some extent. 

We sent a draft of this report to all 24 agencies in our study and SBA for 

their comments. Of these agencies, we received comments from the 

Department of Defense (DOD), the Department of Transportation (DOT), 
Page 7 GAO-04-451 Small and Disadvantaged Businesses

the National Aeronautics and Space Administration (NASA), and SBA. The 

comments were largely technical, and we incorporated them as 

appropriate. DOD also commented that the draft contained statements 

attributed to the Navy OSDBU director that were incorrect. Because our 

draft accurately characterized the statements made by the director, we did 

not change them. However, we added language to the report to reflect 

DOD’s reasons, as stated in its comments, for viewing the information as 

incorrect.

Almost All of the 

OSDBU Directors 

Viewed Most Section 

15(k) Functions as 

Duties of Their Offices 

Almost all of the 24 OSDBU directors that we surveyed reported that they 

viewed most of the functions outlined in section 15(k) of the Small 

Business Act as current duties of their offices. At least 19 OSDBU directors, 

or almost 80 percent, said that they viewed five of the eight functions 

identified in 15(k) as their duties, and a smaller majority (13 to 17) saw the 

remaining three functions as their responsibilities (fig. 1). In cases where 

we asked respondents about the extent to which they carried out these 

functions, responses varied. For example, a large majority of the OSDBU 

directors reported that they identified solicitations for contract bundling to 

either a great or very great extent. In contrast, only 5 OSDBU directors 

reported helping small businesses to obtain payments from agencies to 

either a great or very great extent. Some directors did not view all of the 

functions as their responsibilities, but in follow-up interviews these 

directors provided explanations for their responses. 
Page 8 GAO-04-451 Small and Disadvantaged Businesses

Figure 1: Survey Results from 24 OSDBU Directors on Section 15(k) Functions

a

According to the OSDBU directors, SBA had not assigned a procurement center representative to 3 of 

the 24 agencies in our study—the Department of the Interior, the Office of Personnel Management, 

and the U.S. Agency for International Development. Therefore, the OSDBU directors at these agencies 

were not required to assign a small business technical advisor.

The Extent to Which 

OSDBU Directors Carried 

Out Some Section 15(k) 

Functions Varied

We asked OSDBU directors about the extent to which they carried out 

several of the section 15(k) functions. Of those directors who saw the 

contract bundling functions as responsibilities of their OSDBUs, more than 

half reported carrying out these duties to a great or very great extent (fig. 

2). For example, 17 of the 21 OSDBU directors who viewed identifying 

solicitations that involved contract bundling as a function reported doing 

so to a great or very great extent, as did more than half (13) of the 22 

directors who viewed working with agency acquisition officials to revise 

Number of OSDBU directors who answered:

Yes, this function is a duty

Section 15(k) functions of the OSDBU director

No, this function is not a duty

of the OSDBU director No answer

Source: GAO analysis of survey data.

Supervisory authority over personnel with the 

duties and functions of the OSDBU

Facilitating small business participation as 

subcontractors to bundled contracts

Assisting small businesses to obtain payments 

from your agency 

Assisting small businesses to obtain payments 

from prime contractors

Determining/Reviewing individual acquisitions 

for small business set-asides

Assigning a small business technical advisora

Attempting to identify solicitations that involve 

bundling of contract requirements

Working with agency acquisition officials to revise 

procurement strategies for bundled contract requirements 

to increase small business participation 

22

21

19

20

17

17

22

13

2

3

4

4

4

7

7

7

2

1
Page 9 GAO-04-451 Small and Disadvantaged Businesses

procurement strategies for bundled contracts as a duty. For example, 1 

OSDBU director wrote: “When and if a program office announces its 

intention to bundle, the OSDBU works with it to ensure that the small 

business market share does not suffer.” Another OSDBU director stated, 

“We are reviewing previously bundled contracts in order to unbundle them. 

We’re also developing questions for the [contracting] personnel to answer 

regarding past contract awards.” 

Eleven of the 19 OSDBU directors who viewed facilitating small business 

participation as subcontractors on a bundled contract as a duty said that 

they carried out the function to a great or very great extent. In their written 

comments, several directors noted that they worked with the acquisition 

officials on large contracts to increase subcontracting for small businesses. 

One director wrote the following: 

“...the Director reviews major acquisitions and other acquisitions that have agencywide 

impact. These venues provide the OSDBU with opportunities to ensure that acquisitions are 

not unnecessarily consolidated, and to influence the establishment of aggressive proposal 

evaluation factors and subcontracting goals to encourage small business opportunities.” 

Another OSDBU director commented, “OSDBU works with acquisition 

officials on large dollar contracts to encourage contracting officers to 

include increased subcontracting incentives in solicitations.” 
Page 10 GAO-04-451 Small and Disadvantaged Businesses

Figure 2: Level of OSDBU Activity on Contract Bundling Functions

Our survey occurred after the Office of Federal Procurement Policy, an 

office within the Office of Management and Budget (OMB), issued new 

guidance on limiting the use of contract bundling. In October 2002, OMB 

issued a plan entitled Contract Bundling: A Strategy for Increasing 

Federal Contracting Opportunities for Small Business. The aim of the 

plan was to eliminate unnecessary contracting bundling and to mitigate the 

effects of necessary contract bundling. Under the plan, OSDBUs were to be 

required to conduct periodic reviews and submit their assessments to 

OMB.12 By giving the issue of contract bundling more prominence, the 

guidance in this plan may have affected how the OSDBU directors saw 

their role in contract bundling. In written comments on contract bundling, 

Great

Moderate

Some

Little or no

No answer

Don't know

Extent of OSDBU

activity on contract

bundling functions

7

0

0

0 0

3

1

1

6

0

4

2

2 2

7

5

0

3

3

10 6

Source: GAO analysis of survey data.

OSDBU attempts to identify 

solicitations that involve bundling of 

contract requirements (n=21)

OSDBU works with agency acquisition 

officials to revise procurement strategies for 

bundled contract requirements to increase 

small business participation (n=22)

OSDBU facilitates small business 

participation as subcontractors to

bundled contracts (n=19)

Very great

12Another GAO team is currently conducting a study on the extent to which contract 

bundling occurs and the effect of OMB’s strategy on small business federal contracting 

opportunities. 
Page 11 GAO-04-451 Small and Disadvantaged Businesses

several OSDBU directors referred to OMB’s guidance. One OSDBU director 

wrote, “We are changing our procurement review function as a result of the 

recent OMB guidance so we will become more involved more than 

currently.” Similarly, another director commented, “...under OMB’s 

renewed interest in his area, OSDBU is very active in identifying and taking 

action to avoid unnecessary contract bundling.”

Twenty OSDBU directors viewed assisting small businesses to obtain 

payment from agencies as an OSDBU function, but only 5 reported doing so 

to a great or very great extent. Eleven reported that they carried out this 

function to a moderate level or less. In written comments and follow-up 

interviews, a majority of the OSDBU directors who viewed this assistance 

as a function stated that the problem of nonpayment to small business had 

arisen only occasionally. Moreover, the directors explained that although 

they will assist small businesses with payment problems whenever they are 

contacted, the issue is more clearly administrative and thus more likely be 

handled by other agency personnel. Several OSDBU directors reported that 

they typically refer such matters to contract administrators, and 1 director 

noted that his office worked with the agency’s Vendor Claims Division on 

payment issues. Another director said that the agency’s Office of 

Acquisition Management was responsible for ensuring payment for all 

vendors, large and small, but that the OSDBU acted as a mediator when 

necessary. 

A slightly lower number (17) of respondents viewed helping to obtain 

payments from prime contractors as an OSDBU function. Slightly less than 

half (8) of the 17 OSDBU directors reported that they carried out this 

function to a moderate extent or less; only 3 said they had carried out the 

function to either a great or very great extent.13

Seventeen OSDBU directors reported that they viewed reviewing or 

determining individual contracts that should be set aside for a small 

business as an OSDBU function. As figure 3 shows, 8 of the 17 OSDBU 

directors stated that they reviewed proposed small business set-asides for 

individual acquisitions in all or most cases, and another 8 carried out this 

function in some or a few cases. An additional 3 OSDBU directors reported 

that determining small business set-asides for a class of acquisitions was a 

function of their OSDBU. 

13Six respondents did not provide an answer.
Page 12 GAO-04-451 Small and Disadvantaged Businesses

Figure 3: Level of OSDBU Activity of Reviewing Individual Acquisitions for Small 

Business Set-asides

The process of setting aside contracts for small business programs is a 

responsibility that is shared among SBA, the agencies’ contracting staff, 

and the OSDBU. The OSDBU director’s role in the process, according to the 

FAR, consists of making recommendations on whether particular contracts 

can be set aside. In their written comments, several OSDBU directors 

stated that they reviewed contracts above the threshold for simplified 

acquisitions (generally $100,000), and then they either concurred or did not 

concur with the contracting officers that the contracts should be set aside. 

One OSDBU director wrote the following:

“For acquisitions valued over $100,000, contracting officers are required to submit small 

business set-aside clearance review forms to the OSDBU via the bureau’s small business 

specialist. The clearance forms document the acquisition planning activities and strategies 

for individual contract actions. The OSDBU works with the contracting officers to create 

acquisition strategies for full and partial set-asides.” 

We also asked OSDBU directors to indicate the extent to which they 

cooperated and consulted with SBA in carrying out their responsibilities. 

Twenty-three directors reported that they cooperated and consulted with 

SBA on small business matters, 16 of them to a great or very great extent 

012345678

No answer

Don't know

In no cases

In few cases

In some cases

In most cases

In all cases

Number of respondents (n=17)

6

7

1

0

0

2

1

Source: GAO analysis of survey data.
Page 13 GAO-04-451 Small and Disadvantaged Businesses

(fig. 4). For example, in commenting on their working relationship with 

SBA staff, 1 OSDBU director wrote, “We work closely with various SBA 

district offices that manage the portfolios of our various 8(a) contractors. 

We also participate on the Small Business Procurement Advisory Council, 

which is co-chaired by SBA and meets monthly.” 

Figure 4: Level of OSDBU Director Cooperation and Consultation with SBA

Section 15(k) of the Small Business Act requires the OSDBU director to 

designate a small business technical advisor when SBA has assigned a 

procurement center representative to their agency. Twenty OSDBU 

directors stated that SBA had assigned a procurement center 

representative to their agencies.14 Of these, 13 directors reported that they 

had assigned a small business technical advisor, and 7 said that they had 

not. 

14Three of the 24 OSDBU directors (those at the Department of the Interior, the Office of 

Personnel Management, and the U.S. Agency for International Development) reported in the 

survey that SBA had not assigned a procurement center representative. 

Number of respondents (n=24)

0 2 4 6 8 10

No answer

Don't know

Little or

no extent

Some extent

Moderate extent

Great extent

Very great extent

6

3

2

2

0

10

1

Source: GAO analysis of survey data.
Page 14 GAO-04-451 Small and Disadvantaged Businesses

OSDBU Directors Explained 

Why They Did Not View 

Some 15(k) Functions as 

Their Current 

Responsibilities

The number of OSDBU directors who did not view a section 15(k) function 

as their current responsibility varied, depending on the specific function. 

The number of directors ranged from 2 who did not view supervisory 

authority over OSDBU personnel as a responsibility to 8 who did not view 

assigning a small business technical advisor as a responsibility. During 

follow-up interviews, the OSDBU directors provided a variety of reasons 

for their views. 

• Two OSDBU directors (the Office of the Secretary of Defense and the 

Social Security Administration (SSA)) reported that they did not 

supervise OSDBU personnel. In a follow-up interview, the OSDBU 

director at the Office of the Secretary of Defense told us that he does not 

supervise the OSDBU directors at the military services because his 

duties are primarily developing policy and providing oversight of the 

military OSDBUs. The OSDBU director at SSA stated that he did not 

have OSDBU staff assigned to his office, and that he was assisted by a 

small business specialist, who works for the Office of Acquisition and 

Grants. 

• Two OSDBU directors (Navy and the U.S. Agency for International 

Development (USAID)) indicated that two functions involving contract 

bundling were not their responsibilities: working with agency 

acquisition officials to revise procurement strategies for bundled 

contract requirements and attempting to identify solicitations that 

involve bundling contract requirements. In our follow-up conversations, 

Navy’s OSDBU director told us that her role was primarily developing 

policy for small business programs at her agency. She stated that her 

role stems mostly from the decentralized nature of the DOD’s 

procurement system. She stated that she does not review individual 

contracts to identify bundling of contract requirements because these 

duties are the responsibility of the small business specialists. The 

OSDBU director at USAID stated that she is not aware of any bundling 

at the agency and thus did not consider the two functions a 

responsibility. However, she noted that her response did not mean that 

USAID had not bundled any contracts.

• Four OSDBU directors (the Department of Education, Army, Navy, and 

the Office of Personnel Management (OPM)) indicated that they did not 

view facilitating small business participation as subcontractors to 

bundled contracts as a duty of their offices. In a follow-up interview, the 

OSDBU director at Education stated that she worked with the 

contracting officer to unbundle contracts, but she added that the 
Page 15 GAO-04-451 Small and Disadvantaged Businesses

OSDBU did not work with subcontractors. She indicated that her role 

was limited to referring the names of small businesses to the contracting 

office as potential subcontractors. The OSDBU directors at Army and 

Navy stated that their roles were primarily developing policy, and that 

small business specialists generally carry out this function. The OSDBU 

director at OPM told us that he did not view the function as a duty 

because contract bundling had not happened at OPM in the past fiscal 

year.

• Four OSDBU directors (the Office of the Secretary of Defense, the 

Department of Housing and Urban Development (HUD), Navy, and the 

Department of the Treasury) reported that they did not see assisting 

small businesses to obtain payments from agencies as their function. In 

follow-up interviews, the OSDBU director at the Office of the Secretary 

of Defense told us that few if any problems occurred in this area and, if 

there were any problems, they would be handled by the small business 

offices. The OSDBU director at HUD explained that the agency’s 

contract administrators handle this function. The OSDBU director at 

Navy explained that small businesses seeking payment would need to 

contact the small business specialist at one of the commands or the 

Defense Contract Management Agency. Treasury officials told us that 

assisting small businesses to obtain payments would be the 

responsibility of the contracting office or the financial management 

office. 

• Seven OSDBU directors (the Defense Logistics Agency (DLA), the 

Department of Agriculture, Army, Education, HUD, Navy, and Treasury) 

did not view assisting small businesses to obtain payments from prime 

contractors as a function of their offices. Several OSDBU directors 

(DLA, Agriculture, and Education) told us in follow-up interviews that 

they did not view it as a function primarily because as government 

personnel, they could not become involved in a contractual dispute 

between the prime contractors and the subcontractors. The OSDBU 

directors at Army and Navy explained that the Defense Contract 

Management Agency or the small business specialists would resolve 

these issues. Treasury officials explained that contracting officers at 

individual bureaus were responsible for addressing the payment 

problems, and that the agency’s involvement would be limited by legal 

constraints. Again, the OSDBU director at HUD stated that the agency’s 

contract administrators would handle the problems. 
Page 16 GAO-04-451 Small and Disadvantaged Businesses

• Four OSDBU directors (Army, Navy, the General Services 

Administration (GSA), and USAID) stated that determining a small 

business set-aside for either an individual contract or a class of 

acquisitions was not a function of their offices. The OSDBU directors for 

Army and Navy stated that the small business specialists review 

contracts for small business set-asides. Also, the OSDBU director at 

GSA told us that procurement officials determine set-asides. The 

OSDBU director at USAID stated in a follow-up interview that she 

makes set-aside recommendations on contracts when she sees the 

contract.

• Seven OSDBU directors (DLA, the Office of the Secretary of Defense, 

Education, the Department of State, the Department of Veterans Affairs, 

SSA, and the Environmental Protection Agency) reported that they did 

not assign a small business technical advisor at offices where SBA had 

assigned a procurement center representative. For example, the OSDBU 

director at the Office of the Secretary of Defense told us that his 

responsibility for assigning small business technical advisors was 

delegated to the military services, and the OSDBU director at DLA said 

that the function had been delegated to the head of DLA’s contracting 

affairs. Also, the OSDBU director at SSA told us that the small business 

specialist from the agency’s Office of Acquisition and Grants, who works 

with him, could fulfill the role of a small business technical advisor. He 

explained that the small business specialist assists the procurement 

center representative when the procurement center representative 

comes to the agency to review the set-aside determinations. 

In commenting on a draft of this report, the Director, Office of Small and 

Disadvantaged Business Utilization, Office of Under Secretary of Defense 

for Acquisition, Technology, and Logistics, stated that the draft included 

information, attributed to the Navy OSDBU director, that is incorrect. Our 

draft report stated that the director did not view three of the section 15(k) 

duties we asked about—working with agency acquisition officials to revise 

procurement strategies for bundled contract requirements, attempting to 

identify solicitations that involve bundling contract requirements, and 

assisting small businesses to obtain payments from agencies—as 

responsibilities of her office. Our report was based on the Navy director’s 

response to our survey, which we reaffirmed in a follow-up interview with 

her. DOD’s OSDBU director commented that generally these functions are 

performed by small business specialists, but that if mutually agreeable 

solutions cannot be worked out between the parties, the matters are 

elevated to the Navy OSDBU director for resolution.
Page 17 GAO-04-451 Small and Disadvantaged Businesses

OSDBU Directors 

Reported Performing 

Additional Activities as 

Well as Their Section 

15(k) Functions

During preliminary interviews, OSDBU directors noted that they view as 

their responsibility some functions, such as outreach activities and 

reviewing subcontracting plans, that are not among those specifically 

identified in section 15(k). Our survey results show that nearly all of the 24 

directors viewed most of these additional functions as a current duty. Some 

directors also reported that they viewed involvement in the solicitation 

development and proposal evaluation phases of the procurement process 

as a current function of their office. 

Most Directors Saw 

Outreach to Small 

Businesses as a Function of 

Their OSDBU 

Nearly all (21) of the OSDBU directors saw hosting conferences for small 

businesses as one of their responsibilities, and 20 had hosted such an event 

in the last 2 years. In their written comments, several OSDBU directors said 

that they typically designed the conferences to expose small businesses to 

their agency’s specific needs. For example, 1 OSDBU director described (1) 

hosting annual networking sessions for small businesses and prime 

contractors and a “fair” for veteran-owned small businesses and (2) 

cohosting six information technology “fairs.” Those OSDBU directors that 

had not hosted conferences said that they had either participated in 

another agency’s fairs or had assigned this duty to the small business 

specialists. For example, 1 OSDBU director said that his office usually 

participated in outreach conferences hosted by relatively large 

organizations, including SBA, the Minority Business Development Agency, 

and the Department of Commerce. 

A majority (17) of OSDBU directors saw sponsoring training for small 

businesses as a function, and 15 said that they had sponsored a training 

program in the last 2 years. In their written responses, several directors 

said that the purpose of the training programs is to familiarize small 

businesses with doing business with their agencies. Four directors said that 

they had partnered with another agency to provide training. For example, 1 

director said, “In conjunction with the SBA Baltimore District Office, the 

OSDBU has hosted training events on subjects concerning GSA schedules, 

teaming agreements, and how to do business with [the agency].” Of those 

OSDBU directors that did not host their own training programs, 1 said he 

had provided small businesses with a brochure explaining contracting 

opportunities at the agency, and 2 referred small businesses to SBA for 

training.
Page 18 GAO-04-451 Small and Disadvantaged Businesses

Almost All of the Directors 

Reported That Reviewing 

and Monitoring 

Subcontracting Plans Are 

Functions of Their OSDBU

Almost all (22) of the OSDBU directors said that reviewing prime 

contractors’ subcontracting plans for small business consideration is a 

current function, and 15 reported that they performed this activity in all or 

most cases. According to the FAR, any prime contractor with a contract 

above the simplified acquisition threshold ($100,000) must agree to allow 

small businesses the “maximum practicable opportunity” to participate in 

the contract. If a contract for more than $500,000 is awarded, or is to be 

awarded, to a business other than a small business, the government 

requires the winner of the contract to submit an acceptable subcontracting 

plan that shows how small businesses will be used as subcontractors.15 We 

found that some OSDBU directors reviewed subcontracting plans for all 

acquisitions, while a few OSDBU directors said they reviewed plans for 

contracts only above certain dollar thresholds. 

Almost all (19) of the OSDBU directors also reported that they monitor 

prime contractors’ implementation of the subcontracting plans. Several of 

the OSDBU directors stated they reviewed certain standard forms to 

determine if the prime contractors were following their subcontracting 

plans.16 Three of the five defense services noted that the Defense Contract 

Management Agency monitors implementation of the subcontracting plans 

of DOD prime contractors. One director at a civilian agency said that the 

OSDBU had implemented a pilot program that required the prime 

contractors to report monthly on the level of subcontracting and the actual 

payments made to small business. According to the director, “This handson approach was highly successful and resulted in significant levels of 

small business participation at the subcontracting level.”

15The threshold for construction contracts is $1,000,000.

16These forms include the Standard Form 294 (Subcontracting Report for Individual 

Contracts) and the Standard Form 295 (Summary Subcontract Report). 
Page 19 GAO-04-451 Small and Disadvantaged Businesses

Some Directors Saw 

Participating in Soliciting 

and Evaluating Proposals as 

Responsibilities of Their 

OSDBU 

Nine of the OSDBU directors we surveyed said that developing proposed 

solicitations was a function of their OSDBU.17 Two OSDBU directors noted 

that their involvement was limited to major procurements. For example, 1 

director noted that his office worked with contracting officers and program 

officials through the agency small business specialists “to develop special 

language or provisions for some solicitations.” 

Only 8 OSDBU directors said that evaluating proposals submitted by 

potential contractors in response to bid solicitations was a function of their 

OSDBU.18 Of these directors, 3 said that they participated in the function 

only on an exception basis or in a few cases.19 Two of the OSDBU directors 

wrote that their participation in evaluating proposals submitted by 

potential contractors consisted of reviewing the subcontracting plans of 

the prime contractors. 

Most OSDBU Directors 

Saw Few Challenges to 

Carrying Out Their 

Responsibilities 

Most of the OSDBU directors we surveyed reported that they face few 

challenges to carrying out their responsibilities. However, more than half 

viewed three issues—lack of influence in the procurement process, limited 

budgetary resources, and lack of adequate staffing—as challenges to at 

least some extent. As shown in figure 5, between 15 and 19 respondents 

saw four of the access and independence issues in our questionnaire as 

challenges to little or no extent. On the other hand, a slight majority saw 

their lack of influence over procurement as a challenge to at least some 

extent, and a larger majority (17) saw limited budgetary resources and 

inadequate staffing levels as challenges to at least some extent. We 

received very few written comments explaining respondents’ views on the 

challenges. 

17The Departments of the Air Force, Agriculture, Commerce, Energy, Health and Human 

Services, Labor, the Treasury; the National Aeronautics and Space Administration; and the 

Office of Personnel Management.

18The Defense Logistics Agency; the Departments of Agriculture, Commerce, Health and 

Human Services, Labor, State, and Transportation; and the National Aeronautics and Space 

Administration.

19The Defense Logistics Agency and the Departments of Transportation, Health and Human 

Services, and State.
Page 20 GAO-04-451 Small and Disadvantaged Businesses

Figure 5: OSDBU Directors’ Reporting Challenges 

Scope and 

Methodology

To learn more about the duties and functions of OSDBUs, we administered 

a Web-based questionnaire to OSDBU directors at 24 federal agencies.20 To 

develop the survey instrument, we conducted pretest interviews with 2 

OSDBU directors and obtained input from GAO experts on survey design. 

A summary of the OSDBU directors’ responses to the questionnaire is 

contained in appendix II. The questions asked the respondents whether 

certain functions were a current role or function of their OSDBU. The 

functions covered three areas: OSDBU participation in the procurement 

Issue Great Moderate Some Little or no Very great

To what extent OSDBU directors viewed each issue as a challenge:

15

Limited

budgetary

resources

2 3 3 9 6

Lack of

adequate

staffing level

1 4 5 7 6

Lack of influence

in the procurement

process

2 2 3 6 10

Insufficient

access to agency

head or deputy

0 0 2 3 18

Lack of independence 

to oppose procurement 

official decisions

0 2 2 2 17

Employment status

(e.g., political appointee

or civil servant)

0 0 1 1 19

Lack of 

independent 

budget

1 1 1 5

Other 1 0 1 0 0

Source: GAO analysis of survey data.

20The Federal Emergency Management Agency was not included in the survey because it 

became part of the Department of Homeland Security in March 2003 and ceased to be an 

independent agency.
Page 21 GAO-04-451 Small and Disadvantaged Businesses

process, OSDBU facilitation of small business participation in agency 

contracting, and OSDBU interaction with SBA staff. The questions were 

drawn from the OSDBU functions listed in section 15(k) of the Small 

Business Act as well as those functions mentioned by OSDBU directors 

during preliminary interviews we conducted during the design phase of the 

instrument. 

We began the survey in late May 2003 by sending an e-mail either directly to 

the OSDBU director or through their agency liaisons with unique 

passwords and the locations of our Web survey. Follow-up contacts with 

those not completing the survey were made in June and July, and the 

survey was closed in early September 2003. We received completed 

questionnaires from all 24 directors in the survey population. In one case, a 

GAO liaison officer reviewed the OSDBU director’s responses before 

submitting the survey to GAO. 

We conducted 17 follow-up discussions with OSDBU directors, consisting 

of 15 interviews and 2 e-mail discussions. The purpose of the follow-ups 

was to confirm answers when respondents said they did not view one or 

more functions listed in section 15(k) as a role of their office. On the basis 

of these discussions, we changed 23 of the answers originally placed on the 

survey as the director not viewing a 15(k) function as an OSDBU role to the 

director viewing it as an OSDBU role. We used the following two criteria to 

make these changes: (1) the directors explicitly stated that they wished to 

change their answer and provided a reason for the change or (2) the 

directors misunderstood the question. Thus, these adjustments are 

reported as being a “yes” response in our findings. 

While OSDBU directors at the 24 agencies were asked to participate in the 

survey and the survey results are therefore not subject to sampling errors, 

not all OSDBUs responded to every individual question. Nonresponse, and 

the practical difficulties of conducting any survey, may introduce error in 

survey results. We took steps to minimize such errors in the development 

and testing of our questionnaire by conducting follow-ups with 

nonrespondents, and by checking and editing survey responses and 

analysis. We did not assess the 24 agencies’ compliance with the provisions 

of section 15(k).

We conducted our work in Washington, D.C., between January 2003 and 

January 2004 in accordance with generally accepted government auditing 

standards. 
Page 22 GAO-04-451 Small and Disadvantaged Businesses

Agency Comments and 

Our Evaluation

We sent a draft of this report to all 24 agencies in our study and to SBA for 

their comments. We received technical comments from DOD, DOT, NASA, 

and SBA, which we incorporated as appropriate. DOD also commented that 

the draft did not accurately reflect responses attributed to the Navy 

OSDBU director. Our draft report stated that the director did not view three 

of the section 15(k) duties we asked about—working with agency 

acquisition officials to revise procurement strategies for bundled contract 

requirements, attempting to identify solicitations that involve bundling 

contract requirements, and assisting small businesses to obtain payments 

from agencies—as responsibilities of her office. According to the 

comments received from DOD’s OSDBU director, Navy’s OSDBU director is 

ultimately responsible for carrying out these duties (1) if Navy’s small 

business specialists are unable to reach a mutually agreeable solution when 

working with agency officials to revise procurement strategies for a 

bundled contract and identify solicitations that involve contract bundling 

requirements and (2) when the buying command or contract administration 

office has not been able to resolve matters regarding payments. 

We do not take exception with DOD’s statement that Navy’s OSDBU 

director is ultimately responsible for these three duties if the matters have 

not been resolved by other agency officials. However, we believe the Navy 

OSDBU director’s responses are accurately reflected in this report. In both 

the questionnaire and follow-up interview, Navy’s OSDBU director stated 

that she did not view the three functions as her duties. 

As agreed with your offices, unless you publicly release its contents earlier, 

we plan no further distribution of this report until 30 days from its issuance 

date. At that time, we will send copies of this report to the Chairman and 

the Ranking Minority of the House Committee on Small Business. We will 

make copies available to others on request. In addition, this report will be 

available at no charge on the GAO Web site at http://www.gao.gov.
Page 23 GAO-04-451 Small and Disadvantaged Businesses

If you have any questions regarding this report, please contact me or 

Charles E. Wilson, Jr., Assistant Director, at (202) 512-8678. Key 

contributors to this report are listed in appendix III.

David G. Wood

Director, Financial Markets and 

Community Investment 
Page 24 GAO-04-451 Small and Disadvantaged Businesses

Appendix I

Twenty-four Agencies Surveyed on OSDBU Apendxies

Roles and Functions ApendxiI

Defense Logistics Agency

Department of Agriculture 

Department of Commerce

Department of Defense—Office of the Secretary

Department of Education

Department of Energy

Department of Health and Human Services

Department of Housing and Urban Development

Department of Justice

Department of Labor

Department of State

Department of the Air Force

Department of the Army

Department of the Interior

Department of the Navy

Department of the Treasury

Department of Transportation

Department of Veterans Affairs

Environmental Protection Agency

General Services Administration

National Aeronautics and Space Administration

Office of Personnel Management

Social Security Administration

U.S. Agency for International Development
Page 25 GAO-04-451 Small and Disadvantaged Businesses

Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors ApendxiI

Introduction The United States General Accounting Office (GAO) is conducting a study 

on small business contracting for the Senate Committee on Small Business 

and Entrepreneurship. Several weeks ago, we asked you and each of the 

other OSDBU directors at the 21 federal agencies with procurements of 

$200 million or more in 2001 for information on the reporting relationship 

between the OSDBU director and other agency officials, including the 

agency head.

Now we would like to know more about how the OSDBU directors are 

carrying out the duties and functions of their offices. To make the task of 

reporting this information easier for you, we delayed this second part of 

our request until now.

This questionnaire should take about half an hour to complete, depending 

on the need to consult records and other people. Your response by June 

11th would be greatly appreciated.

Your cooperation in answering all of the questions in this survey is vital to our ability to report to Congress.

Q1. How long have you been Director of the Office of Small and Disadvantaged Business Utilization (OSDBU)?

Q2. Please briefly describe the overall mission of your OSDBU.

OSDBU Roles in 

Agency Procurement

The following sections ask you about the functions and duties that your 

OSDBU might perform under Section 15(k) of the Small Business Act. For 

each of the following activities, please tell us whether each is currently a 

role or function that your OSDBU can perform, even if it has not yet done 

so. For those activities that fall to your OSDBU as official roles or 

functions, please tell us to what extent your OSDBU actually engages in 

those activities, and describe that involvement.

Mean Median Minimum Maximum

Number 

of 

respondents

How long have 

you been 

Director of 

OSDBU? 4 2 0 15 24
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 26 GAO-04-451 Small and Disadvantaged Businesses

Q3. Is involvement in acquisition planning, as defined in Part 7 of the Federal Acquisition Regulation, currently a role or function of your 

OSDBU?

Q4. In general, to what extent is your OSDBU involved in acquisition planning?

Q5. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q6. Is determining small business set-asides for individual acquisitions currently a role or function of your OSDBU?

Q7. How often is your OSDBU involved in determining small business set-asides for individual acquisitions?

Q8. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q9. Is determining small business set-asides for a class of acquisitions currently a role or function of your OSDBU?

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

18 6 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

2 7 4 4 1 0 18

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

17 7 0 24

In all cases In most cases In some cases In few cases In no cases Don’t know

Number 

of 

respondents

2 6 7 1 0 0 16

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

17 6 0 23
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 27 GAO-04-451 Small and Disadvantaged Businesses

Q10. How often is your OSDBU involved in determining small business set-asides for a class of acquisitions?

Q11. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q12. In the event of a formal disagreement between your OSDBU and procurement officials during the acquisition planning process

concerning small business matters, what is the first level of appeal for your OSDBU if the situation is not resolved?

If you checked "Other" - please describe below:

Q13. Does your agency require written justification from procurement officials if they disagree with your OSDBU objections?

If you checked "Written justification required" - please describe below:

Q14. Has your OSDBU formally disagreed with the procurement officials during acquisition planning concerning small business matters in 

the past 24 months?

In all cases In most cases In some cases In few cases In no cases Don’t know

Number 

of 

respondents

3 2 5 5 0 0 15

N/A - OSDBU 

cannot 

formally 

disagree

No specific 

first level of 

appeal Agency Head

Deputy 

Agency Head

Chief 

Financial 

Officer

Other - please 

describe in 

box below

Number 

of 

respondents

0 3 4 5 0 12 24

No written 

justification 

required

Written 

justification 

required - please 

describe elements 

of this justification 

in box below

Number 

of 

respondents

9 14 23

Yes - OSDBU 

has disagreed 

with 

procurement 

officials

No - OSDBU has 

not disagreed 

with procurement 

officials

Number 

of 

respondents

15 7 22
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 28 GAO-04-451 Small and Disadvantaged Businesses

Q14a. How often has your OSDBU formally disagreed with procurement officials during acquisition planning concerning small business 

matters in the past 24 months?

Q14b. Typically, what were the outcomes of these disagreements?

Q15. If your OSDBU is not currently involved in acquisition planning, what entity is involved in acquisition planning that advocates for small 

business consideration?

If you checked "Other" - please describe:

In all cases In most cases In some cases In few cases Don’t know

Number 

of 

respondents

0 0 7 7 2 16

Checked

Number 

of 

respondents

Other Entity involved 

in acquisition 

planning: N/A - 

OSDBU involved 14 24

Other Entity involved 

in acquisition 

planning: None 1 24

Other Entity involved 

in acquisition 

planning: 

Procurement Officials 11 24

Other Entity involved 

in acquisition 

planning: SBA 

Procurement Center 

Reps 7 24

Other Entity involved 

in acquisition 

planning: Agency 

Program Officials 11 24

Other Entity involved 

in acquisition 

planning: Other 5 24
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 29 GAO-04-451 Small and Disadvantaged Businesses

Q16. Is developing proposed solicitations currently a role or function of your OSDBU?

Q17. In general, to what extent is your OSDBU involved in developing proposed solicitations?

Q18. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q19. Is attempting to identify proposed solicitations that involve bundling of contract requirements currently a role or function of your 

OSDBU?

Q20. In general, to what extent does your OSDBU attempt to identify proposed solicitations that involve bundling of contract requirements?

Q21. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q22. Is working with agency acquisition officials to revise procurement strategies for bundled contract requirements to increase small 

business participation currently a role or function of your OSDBU?

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

9 15 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

0 216009

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

21 3 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

7 10 1 3 0 0 21

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

22 2 0 24
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 30 GAO-04-451 Small and Disadvantaged Businesses

Q23. In general, to what extent does your OSDBU work with agency acquisition officials to revise procurement strategies for bundled 

contract requirements to increase small business participation?

Q24. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q25. Is facilitating small business participation as subcontractors to bundled contracts currently a role or function of your OSDBU?

Q26. In general, to what extent does your OSDBU facilitate small business participation as subcontractors to bundled contracts?

Q27. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q28. Is developing evaluation factors for solicitations for your agency currently a role or function of your OSDBU?

Q29. How often does your OSDBU develop evaluation factors for solicitations for your agency?

Q30. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

6 7 2 4 0 1 20

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

19 4 0 23

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

5 6 3 3 0 0 17

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

15 9 0 24

In all cases In most cases In some cases In few cases In no cases Don’t know

Number 

of 

respondents

0 3 9 3 0 0 15
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 31 GAO-04-451 Small and Disadvantaged Businesses

Q31. In the event of a formal disagreement between your OSDBU and procurement officials during solicitation development concerning 

small business matters, what is the first level of appeal for your OSDBU if the situation is not resolved?

If you checked "Other" - please describe:

Q32. Does your agency require written justification from procurement officials if they disagree with your OSDBU objections?

If you checked "Written justification required" - please describe:

Q33. Has your OSDBU formally disagreed with the procurement officials during solicitation development concerning small business

matters in the past 24 months?

Q33a. How often has your OSDBU formally disagreed with procurement officials during solicitation development concerning small 

business matters in the past 24 months?

Q33b. Typically, what were the outcomes of these disagreements?

N/A - OSDBU 

cannot 

formally 

disagree

No specific 

first level of 

appeal Agency Head

Deputy 

Agency Head

Chief 

Financial 

Officer

Other - please 

describe in 

box below

Number 

of 

respondents

1 5 4 3 0 10 23

No written 

justification 

required

Written 

justification 

required - please 

describe elements 

of this justification 

in box below

Number 

of 

respondents

15 8 23

Yes - OSDBU 

has disagreed 

with 

procurement 

officials

No - OSDBU has 

not disagreed 

with procurement 

officials

Number 

of 

respondents

13 10 23

In all cases In most cases In some cases In few cases Don’t know

Number 

of 

respondents

0 0 5 6 2 13
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 32 GAO-04-451 Small and Disadvantaged Businesses

Q34. Is evaluating proposals submitted by potential contractors in response to solicitations currently a role or function of your OSDBU?

Q35. How often does your OSDBU evaluate proposals submitted by potential contractors in response to solicitations?

Q36. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q37. Is reviewing sub-contracting plans for small business consideration from potential prime contractors currently a role or function of 

your OSDBU?

Q38. How often does your OSDBU review sub-contracting plans for small business consideration from potential prime contractors?

Q39. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q40. Is making recommendations to procurement officials on whether a particular contract should be awarded to a small business 

currently a role or function of your OSDBU?

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

8 16 0 24

In all cases In most cases In some cases In few cases In no cases Don’t know

Number 

of 

respondents

0 062008

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

22 2 0 24

In all cases In most cases In some cases In few cases In No cases Don’t know

Number 

of 

respondents

9 6 3 2 0 1 21

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

15 8 0 23
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 33 GAO-04-451 Small and Disadvantaged Businesses

Q41. How often does your OSDBU make recommendations to procurement officials on whether a particular contract should be awarded to 

a small business?

Q42. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q43. If your OSDBU does not make contract recommendations, what entity makes recommendations on contracts for small business 

consideration?

If you checked "Other" - please describe:

In all cases In most cases In some cases In few cases In No cases Don’t know

Number 

of 

respondents

2 4 6 1 1 1 15

Checked

Number 

of 

respondents

Other entity 

recommending

-N/A, OSDBU 

role 11 24

Other entity 

recommending

-None 0 24

Other entity 

recommending

-Procurement 

officials 9 24

Other entity 

recommending

-SBA 

Procurement 

Center Rep 2 24

Other entity 

recommending

-Agency 

program 

officials 5 24

Other entity 

recommending

-Other 3 24
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 34 GAO-04-451 Small and Disadvantaged Businesses

Q44. In the event of a formal disagreement between your OSDBU and procurement officials during proposal evaluation concerning small 

business matters, what is the first level of appeal for your OSDBU if the situation is not resolved?

If you checked "Other" - please describe:

Q45. Does your agency require written justification from procurement officials if they disagree with your OSDBU objections?

If you checked "Written justification required" - please describe:

Q46. Has your OSDBU disagreed with the procurement officials during solicitation review concerning small business matters in the past 24 

months?

Q47. If your OSDBU and the procurement officials have disagreed in the past 24 months, approximately what percentage of contract 

awards was in dispute?

Q48. Typically, what were the outcomes of these disagreements?

N/A - OSDBU 

cannot 

formally 

disagree

No specific 

first level of 

appeal Agency Head

Deputy 

Agency Head

Chief 

Financial 

Officer

Other - Please 

describe in 

the box below Don’t know

Number 

of 

respondents

2 3 2 4 1 10 0 22

No written 

justification 

required

Written 

justification 

required - Please 

describe in the 

box below

Number 

of 

respondents

12 9 21

Yes - OSDBU 

has disagreed 

with 

procurement 

officials

No - OSDBU has 

not disagreed 

with 

procurement 

officials

Number 

of 

respondents

5 15 20

1%-25% 26%-50% 51%-75% 76%-99% 100%

Number 

of 

respondents

4 01005
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 35 GAO-04-451 Small and Disadvantaged Businesses

Q49. Is monitoring small businesses that receive prime contracts from your agency currently a role or function of your OSDBU? For 

example, monitoring can include your OSDBU meeting at regular intervals with small businesses that receive prime contracts.

Q50. In general, to what extent does your OSDBU monitor small businesses that receive prime contracts from your Agency?

Q51. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q52. Is monitoring prime contractors’ implementation of sub-contracting plans currently a role or function of your OSDBU? For example, 

monitoring can include your OSDBU meeting at regular intervals with small businesses that receive sub- contracts.

Q53. In general, to what extent does your OSDBU monitor the prime contractors implementation of sub-contracting plans?

Q54. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

12 12 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

2 3 2 4 1 0 12

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

19 5 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

4 5 4 5 1 0 19
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 36 GAO-04-451 Small and Disadvantaged Businesses

Q55. In what ways are agency program officials and procurement officials made aware of small businesses as potential contractors?

If you checked "Other ways" - please describe:

Q56. Does your OSDBU have written policies and procedures relating to the functions and duties of your OSDBU?

If you checked "Yes" - please describe:

Checked

Number 

of 

respondents

Ways made 

aware-Not 

done 0 24

Ways made 

aware-Agency 

Small Business 

Contractor 

Database 19 24

Ways made 

awareMeetings 

between 

procurement & 

business 22 24

Ways made 

awareMeetings 

between 

agency 

program off & 

business 22 24

Ways made 

aware-SBA 

PRO-Net 22 24

Ways made 

aware-Dont 

know 0 24

Ways made 

aware-Other 

ways 11 24

Yes - briefly describe 

the topics covered 

under these policies 

and procedures in the 

box below No

Number 

of 

respondents

22 2 24
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 37 GAO-04-451 Small and Disadvantaged Businesses

Q57. Is facilitating small business participation with your agency as contractors, sub-contractors or suppliers currently a role or function of 

your OSDBU?

Q58. In general, to what extent does your OSDBU facilitate small business participation with your agency as contractors, sub-contractors 

or suppliers?

Q59. Please briefly explain your answer or describe the office that carries out this role or function.

Q60. Is assisting small businesses to obtain payments from your agency currently a role or function of your OSDBU?

Q61. In general, to what extent does your OSDBU assist small businesses to obtain payments from your agency?

Q62. Please briefly explain your answer or describe the office that carries out this role or function.

Q62a. Is assisting small businesses to obtain payments from prime contractors currently a role or function of your OSDBU?

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

24 0 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

17 5 0 1 0 0 23

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

20 4 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

1 4 2 7 3 0 17

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

17 7 0 24
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 38 GAO-04-451 Small and Disadvantaged Businesses

Q62b. In general, to what extent does your OSDBU assist small businesses to obtain payments from prime contractors?

Q62c. Please briefly explain your answer or describe the office that carries out this role or function.

Q63. Is disseminating information to small businesses on how to secure business opportunities with your agency currently a role or 

function of your OSDBU?

Q64. In general, to what extent does your OSDBU disseminate information to small businesses on how to secure business opportunities 

with your agency?

Q65. Please briefly explain your answer or describe the office that carries out this role or function:

Q66. Is hosting conferences to familiarize small businesses with opportunities at your agency currently a role or function of your OSDBU?

Q67. Has your OSDBU hosted any conferences to familiarize small businesses with opportunities at your agency in the past 24 months?

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

1 2 1 4 3 0 11

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

24 0 0 24

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

19 3 1 1 0 0 24

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

21 3 0 24

Yes No

Number 

of 

respondents

20 1 21
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 39 GAO-04-451 Small and Disadvantaged Businesses

Q68. How many conferences has your OSDBU hosted to familiarize small businesses with opportunities at your agency in the past 24 

months?

Q69. Please briefly explain your answer or describe the office that carries out this role or function.

Q70. Is sponsoring training programs for small businesses currently a role or function of your OSDBU?

Q71. Has your OSDBU sponsored any training programs for small businesses in the past 24 months?

Q72. Please briefly explain your answer or describe the office that carries out this role or function.

Q73. Is conducting meetings with small business trade associations and/or prime contractors currently a role or function of your OSDBU?

Q74. Has your OSDBU conducted any meetings with small business trade associations and/or prime contractors in the past 24 months?

Mean Median Minimum Maximum

Number 

of 

respondents

How many 

conferences 

has OSDBU 

hosted in past 

24 months? 39 12 3 405 19

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

17 6 0 23

Yes No

Number 

of 

respondents

15 2 17

Yes - an 

OSDBU role or 

function

No - not an 

OSDBU role or 

function Don’t know

Number 

of 

respondents

22 1 0 23

Yes No

Number 

of 

respondents

20 2 22
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 40 GAO-04-451 Small and Disadvantaged Businesses

Q75. On average, how many meetings does your OSDBU conduct with small business trade associations and/or prime contractors in a

typical week?

Q76. Please briefly explain your answer or describe the office that carries out this role or function.

Q77a. How many full-time equivalent (FTE) staff in fiscal year 2003, excluding administrative support staff, does your OSDBU employ?

Q78. Do you, the Director of the OSDBU, have supervisory authority over personnel with duties and functions of your OSDBU?

Q78a. Do you, the Director of the OSDBU, serve as the primary contact for your agency for inquiries into small business matters and those 

affecting your agency’s socioeconomic program goals?

Q79. If you checked "No" - list the primary contact:

Mean Median Minimum Maximum

Number 

of 

respondents

Average 

meetings 

OSDBU 

conducts w/ 

trade assocs in 

week 7 4 0 47 20

Mean Median Minimum Maximum

Number 

of 

respondents

FTEs in FY 

2003 12 6 1 90 23

Yes No

Number 

of 

respondents

22 2 24

Yes

No - please 

list the 

primary 

contact below

Number 

of 

respondents

22 1 23
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 41 GAO-04-451 Small and Disadvantaged Businesses

Q80. Who is responsible for ensuring that small businesses receive the maximum practicable procurement opportunities from the agency?

If you checked "Other" - explain:

Q81. Has the SBA designated one or more procurement center representatives to your agency?

Q82. Have you, the Director of the OSDBU, assigned a small business technical advisor to each office with a SBA procurement center 

representative?

Q83. To what extent does your OSDBU work with the SBA procurement center representatives?

Q84. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

Q85. To what extent does your OSDBU cooperate and consult with the SBA?

Q86. Please briefly explain your answer to the previous question - what level of activity, if any, has your OSDBU had in this area?

OSDBU 

Director

Procurement 

Director Agency Head

Deputy 

Agency Head

Other - please 

explain in the 

box below

Number 

of 

respondents

13 1 3 1 5 23

Yes No

Number 

of 

respondents

20 3 23

Yes No

Number 

of 

respondents

13 7 20

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

4 6 1 3 5 0 19

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

10 6 3 2 2 0 23
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 42 GAO-04-451 Small and Disadvantaged Businesses

Q87. Does your OSDBU negotiate the small business goals, (also referred to as socioeconomic goals) for your agency with the SBA?

Q88. In your agency’s annual small business goal-setting process, does your OSDBU discuss potential goals with any of the following 

parties?

If you checked "Other" - please describe:

Q89. Does your OSDBU have other functions that do not relate to section 15(k) of the Small Business Act? For example, responsibilities 

for monitoring agency processes in areas other than those relating to small business.

Yes No

Number 

of 

respondents

21 3 24

Yes No

Number 

of 

respondents

OSDBU discuss 

goals with:

A. Agency head or 

deputy? 16 3 19

OSDBU discuss 

goals with: 

B. Procurement 

officials 18 0 18

OSDBU discuss 

goals with: 

C. Agency program 

officials 14 2 16

OSDBU discuss 

goals with: 

D. Other - please 

describe in the box 

below 6 2 8
Appendix II

Summary of GAO Survey Results from 24 

OSDBU Directors

Page 43 GAO-04-451 Small and Disadvantaged Businesses

Q90. To what extent is your OSDBU facing each of the following challenges in performing its mission?

If you checked "Other" - Please describe:

Q91. If you have any other comments on the topics covered in this survey, please enter them below.

Very great 

extent Great extent

Moderate 

extent Some extent

Little or no 

extent Don’t know

Number 

of 

respondents

Challenges: 

A. Lack of 

independent 

budget 1 1 1 5 15 0 23

Challenges: 

B. Limited 

budgetary 

resources 2 3 3 9 6 0 23

Challenges: 

C. Lack of 

adequate 

staffing level 1 4 5 7 6 0 23

Challenges: 

D. Lack of 

influence in 

procurement 

process 2 2 3 6 10 0 23

Challenges: 

E. Director has 

insufficient 

access to 

head/deputy 0 0 2 3 18 0 23

Challenges: 

F. Lack of 

independence 

to oppose 

procurement 

decns 0 2 2 2 17 0 23

Challenges:

G. Director 

employment 

status 

(appointee vs. 

civil) 0 0 1 1 19 1 22

Challenges:

H. Other - 

Please 

describe in box 

below 1 0 1 0 0 0 2
Page 44 GAO-04-451 Small and Disadvantaged Businesses

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contacts David G. Wood, (202) 512-8678

Charles E. Wilson, Jr., (202) 512-6891

Staff 

Acknowledgments

In addition to the individuals named above, Emily R. Chalmers, William R. 

Chatlos, Nancy Eibeck, Brodi Fontenot, John T. McGrail, Marc Molino, and 

Carl Ramirez made significant contributions to this report. 

(250150)
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