EXPORT 

PROMOTION

Small Business 

Administration Needs 

to Improve 

Collaboration to 

Implement Its 

Expanded Role

Report to the Committee on Small 

Business and Entrepreneurship, 

U.S. Senate

January 2013

GAO-13-217

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-217, a report to the

Committee on Small Business and 

Entrepreneurship, U.S. Senate 

January 2013

EXPORT PROMOTION

Small Business Administration Needs to Improve 

Collaboration to Implement Its Expanded Role

Why GAO Did This Study

In January 2010, the President 

announced the goal of doubling U.S. 

exports over 5 years. The President’s 

plan in the National Export Initiative 

included prioritizing exports by small 

businesses and called for improved 

coordination among agencies involved 

in federal export promotion activities. 

Recently, Congress has also directed 

SBA to expand its export counseling 

and financing activities. This report (1) 

describes SBA’s role within federal 

export promotion efforts, (2) assesses 

the extent to which SBA collaborates 

with other agencies in its export 

promotion activities, and (3) assesses 

the extent to which SBA is meeting 

requirements under the Small 

Business Jobs Act of 2010 to expand 

export promotion training and staffing. 

GAO analyzed agencies’ documents 

and interviewed agency officials, 

including those in six selected field 

office locations serving areas with high 

export potential and where staff from at 

least two agencies were colocated. 

What GAO Recommends

GAO recommends that SBA (1) 

consult with Commerce and Ex-Im and

clearly define export entities’ roles and 

responsibilities; (2) consult with 

Commerce and Ex-Im and identify 

ways to increase, where possible, 

sharing of client information; and (3) 

update its plan for meeting mandated

staffing requirements to include 

funding sources and time frames, as 

well as possible efficiencies from 

improved collaboration. SBA agreed 

with our recommendations and noted it 

is taking steps to address them. We 

also received technical comments from 

other key export promotion agencies, 

which we incorporated, as appropriate. 

What GAO Found

The Small Business Administration (SBA) and five other key agencies provide a 

variety of export promotion services to small businesses. In addition to outreach, 

which all six agencies conduct, SBA’s primary activities include counseling and 

training, provided mainly through nonfederal partner entities called Small 

Business Development Centers, and export financing, provided through SBA’s 

Office of International Trade (OIT). 

While SBA collaborates to some extent with other key agencies on its export 

promotion activities, additional collaboration could enhance agency efforts and 

reduce overlap. SBA, Department of Commerce (Commerce), and the U.S. 

Export-Import Bank (Ex-Im) coordinate some export promotion activities at

headquarters and at field locations, but some services overlap. For example, 

Small Business Development Centers and Commerce both assist companies 

new to exporting as well as more experienced exporters, despite intentions to 

divide responsibilities for those types of firms. Additionally, OIT and Ex-Im offer 

similar financial products for small businesses, such as export working capital 

loan guarantees. Overlapping services may cause confusion for small 

businesses and result in inefficient use of government resources. SBA and other 

agencies developed a joint strategy to increase small business exports and, to 

varying degrees, the agencies have included collaborative efforts in the 

performance evaluations of staff with export promotion responsibilities. However, 

SBA and other agencies have not clearly defined roles and responsibilities, and 

efforts to leverage resources have not included regularly sharing client 

information where possible. Such sharing could help agencies improve client 

services and clarify each agency’s impact in promoting U.S. exports. Enhancing 

collaboration could help agencies ensure they are working toward the goal of 

increasing exports by small businesses in a way that maximizes limited 

resources and mitigates overlap. 

SBA has made some progress in increasing export training of Small Business 

Development Center counselors but has experienced challenges in meeting 

increased OIT staffing requirements under the Small Business Jobs Act of 2010. 

The law required a certain number or percentage of staff working for the 63 Small 

Business Development Center networks to obtain export counseling certification. 

As of the end of September 2012, 73 percent of the networks had met this 

requirement, for which SBA set a 2013 deadline. To meet another requirement 

under the law, SBA needed to increase its OIT field staff, who primarily provide 

export financing assistance, from 18 to 30 staff, by the end of September 2012. 

However, SBA has only advertised for four temporary positions and filled two of 

them. SBA officials noted challenges in finding qualified candidates and lack of

continued funding for additional OIT field positions. In a recent report to 

Congress, SBA stated its plans to hire the additional OIT staff but did not include 

funding plans or updated time frames to fill the positions. Furthermore, the plan 

did not discuss how SBA would overcome the hiring challenges or discuss the 

potential to leverage resources of other export promotion entities that also 

provide export assistance. View GAO-13-217. For more information, 

contact Loren Yager at (202) 512-4347 or 

yagerl@gao.gov. 
Page i GAO-13-217 Export Promotion

Letter 1 

Background 4

SBA Provides Export Promotion Assistance to Small Businesses 

within a Complex, Multiagency Environment 8

SBA Has Taken Steps to Collaborate with Other Agencies, but 

Further Collaboration Efforts Are Needed 13

SBA Has Made Some Progress in Increasing Export Training but 

Experienced Challenges in Meeting Staffing Requirements under 

the Small Business Jobs Act of 2010 24

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 32

Appendix I Scope and Methodology 34

Appendix II Comments from the Small Business Administration 37

Appendix III GAO Contact and Staff Acknowledgments 46

Tables

Table 1: Congressional Committees with Jurisdiction over Key 

Agencies’ Export Promotion Activities 5

Table 2: Export Promotion Program Budget, Fiscal Year 2012 

(Requested) 6

Table 3: U.S. Agencies’ Activities to Support Small Business 

Exports 9

Table 4: Export Financing Assistance Programs Available to Small 

Businesses, by Federal Agency 12

Table 5: Selected Features and Limitations of SBA and Ex-Im 

Working Capital Loan Guarantees 14

Table 6: Selected Features and Limitations of SBA and Ex-Im 

Express Loan Programs 15

Table 7: Best Practices in Collaboration 17

Contents 
Page ii GAO-13-217 Export Promotion

Figure

Figure 1: Locations and Number of SBA OIT Staff by SBA Region, 

as of September 30, 2012 28

Abbreviations

Commerce Department of Commerce 

Ex-Im U.S. Export-Import Bank 

NEI National Export Initiative 

OIT Office of International Trade 

SBA Small Business Administration 

SBDC Small Business Development Centers

SBJA Small Business Jobs Act of 2010 

State Department of State 

Strategy National Export Strategy 

TPCC Trade Promotion Coordinating Committee 

USDA U.S. Department of Agriculture 

USEAC U.S. Export Assistance Center

USTDA U.S. Trade and Development Agency

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

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-13-217 Export Promotion

United States Government Accountability Office 

Washington, DC 20548

January 30, 2013

The Honorable Mary Landrieu

Chair

The Honorable James Risch

Ranking Member

Committee on Small Business 

and Entrepreneurship

United States Senate

The Honorable Benjamin Cardin

Committee on Small Business 

and Entrepreneurship

United States Senate

The Honorable Jeanne Shaheen

Committee on Small Business 

and Entrepreneurship

United States Senate

In January 2010, the President launched the National Export Initiative 

(NEI) with the goal of doubling U.S. exports over 5 years and prioritizing 

exports by small businesses. The President stated that the NEI was a key 

component of his administration’s plan to help the United States transition 

from economic crisis to sustained recovery, as the potential of exports 

could help accelerate job growth. While exporting is fundamentally a 

decision driven by firms in the private sector, the federal government 

provides various types of assistance to U.S. exporters, especially small 

businesses, to help them overcome the challenges to selling their goods 

and services abroad, including a lack of information about exporting and 

foreign markets and difficulties in obtaining export financing.

Many federal agencies are involved in export promotion. While the 

Department of Commerce’s (Commerce) Commercial Service has 

historically been the primary U.S. export promotion entity, Congress 

recently directed the Small Business Administration (SBA) to increase its 

export activities, including export counseling and financing.1

 

1

Small Business Jobs Act of 2010, Pub. L. No. 111-240, §§ 1201-1209, 124 Stat. 2504, 

2520-36. 

Through the 

 
 

Page 2 GAO-13-217 Export Promotion

Small Business Jobs Act of 2010 (SBJA), Congress directed SBA to 

enhance its field presence by increasing the number and improving the 

training of its field staff, including staff at its nationwide network of over 

900 Small Business Development Centers (SBDC), SBA partner entities 

that also provide export assistance to small businesses.2

This report (1) describes SBA’s role within federal export promotion 

efforts, (2) assesses the extent to which SBA collaborates with other 

agencies in its export promotion activities, and (3) assesses the extent to 

which SBA is meeting SBJA requirements to expand export promotion 

training and staffing.

 SBA’s Office of 

International Trade (OIT) leads SBA’s efforts in cooperating with other 

federal agencies and public- and private-sector groups to encourage 

small business exports and to assist small businesses seeking to export. 

Both SBA OIT staff and the staff at the U.S. Export-Import Bank (Ex-Im) 

provide export financing assistance to small businesses.

To address these objectives, we defined “export promotion activities” as 

programs and services conducted by federal agencies that involve direct 

contact with U.S. exporters and have export promotion as their stated 

goal. Such activities include providing small businesses with export 

counseling, training, and financial assistance; they do not include 

activities such as advocacy, commercial diplomacy, and policy 

development and negotiations. Our review, therefore, covers six key 

agencies—SBA, Commerce, Ex-Im, the U.S. Department of Agriculture 

(USDA), the U.S. Trade and Development Agency (USTDA), and the 

Department of State (State)—with a particular emphasis on SBA’s 

 

2

SBDCs are partially funded by SBA and located primarily at colleges and universities as 

a cooperative effort among SBA, the academic community, the private sector, and state 

and local governments. For the purposes of our report, we refer to SBDCs as SBA’s 

partner entities.
 

Page 3 GAO-13-217 Export Promotion

activities.3 Our assessment of coordination focused on coordination 

between SBA entities and Commerce and Ex-Im, which are key agencies 

that provide export promotion activities similar to those provided by SBA 

entities. We analyzed government-wide initiatives, strategies, and laws, 

as well as agencies’ documents and data. We also interviewed agency 

officials representing the key export promotion entities in headquarters 

and in six selected field locations—Chicago, Dallas, Irvine (California), 

Miami, New York, and Portland (Oregon). We selected these locations 

because SBA staff were colocated with at least Commerce staff and in 

some cases with Ex-Im staff, had the presence of SBDCs with staff 

providing export assistance, and ranked among locations with the highest 

export potential according to Commerce data. At some of these selected 

locations, we also met with representatives of small businesses that used 

federal government export assistance. The results of our interviews with 

officials at these six locations are not generalizable to agency officials’ 

views at all U.S. locations. We assessed interagency coordination 

primarily against selected practices for enhancing and sustaining 

collaboration we previously identified.4

 

3

The scope of our work does not cover the Overseas Private Investment Corporation 

(OPIC) because export promotion is not its primary stated goal. OPIC is a development 

finance institution providing investors with financing, guarantees, political risk insurance,

and support for private equity investment funds. OPIC officials informed us that OPIC’s 

work may result in U.S. exports, but the agency does not conduct its work to seek U.S. 

export opportunities. We include SBA export promotion activities that may directly or 

indirectly support exports by small businesses, which includes SBDCs’ export promotion 

activities. We did not include SBA’s Women’s Business Centers and Service Corps of 

Retired Executives because those entities generally have a limited role in export 

promotion. Moreover, we did not include the State Trade and Export Promotion (STEP) 

program, a 3-year pilot trade and export initiative authorized by the Small Business Jobs 

Act of 2010. Funded by federal grants and matching funds from the states, the STEP 

Program is designed to help increase the number of small businesses that are exporting 

and to raise the value of exports for those small businesses that are currently exporting.

We selected four collaboration 

practices—establishing mutually reinforcing or joint strategies, reinforcing 

individual accountability for collaboration efforts, agreeing on roles and 

responsibilities, and leveraging resources to identify and address needs—

because they allowed us to highlight the most critical and relevant 

elements of collaboration among export agencies at headquarters and the 

field level. Among many requirements under the SBJA, we focused on the 

training and staffing requirements applicable to SBDC staff and OIT in the 

4

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
 

Page 4 GAO-13-217 Export Promotion

field locations, respectively. See appendix I for more details on our scope 

and methodology.

We conducted this performance audit from February 2012 to January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Title II of the Export Enhancement Act of 1992 authorized the creation of 

an interagency body called the Trade Promotion Coordinating Committee 

(TPCC) to carry out various duties, including coordinating the export 

promotion and export financing activities of the U.S. government, 

ensuring better delivery of services to U.S. businesses, and preventing 

unnecessary duplication among federal export promotion and export 

financing programs.5

 The Export Enhancement Act requires this 

committee to issue an annual report to Congress containing a 

government-wide strategic plan for federal trade promotion efforts and 

describing the plan’s implementation.6 As a result, the TPCC’s National 

Export Strategy, which articulates U.S. plans to increase exports, is 

generally issued annually.7 The President also created the Export 

Promotion Cabinet and directed it to develop and coordinate the 

implementation of the NEI, working with the existing TPCC.8

 

5

Pub. L. No. 102-429, Title II, 106 Stat. 2186. 

The Export 

Promotion Cabinet delivered a September 2010 report to the President 

with recommendations to implement the goals of the NEI. The report 

identified several recommendations that support the NEI’s priority of 

6

Pub. L. No. 102-429, § 201. 

7

The National Export Strategy for 2012 was expected to be released in September 2012 

but was delayed. The TPCC issued the 2012 National Export Strategy in December 2012, 

too late for us to review its contents for our report.

8

Executive Order 13534 established the Export Promotion Cabinet on March 11, 2010. 

Background

Federal Interagency 

Entities Involved in Export 

Promotion
 

Page 5 GAO-13-217 Export Promotion

increasing exports by small businesses, including a recommendation to 

coordinate, expand, and leverage federal outreach resources to identify 

potential exporters.

Some of the approximately 20 TPCC member agencies directly assist 

small businesses to export overseas, including the SBA, Commerce, ExIm, USDA, USTDA, and State. These six agencies are overseen by 

various congressional committees, including appropriation and 

authorizing committees (see table 1). In 1993, the TPCC recommended 

that three agencies—the SBA, Commerce, and Ex-Im—colocate their 

staff at a domestic network of selected U.S. Export Assistance Centers 

(USEAC).9

Table 1: Congressional Committees with Jurisdiction over Key Agencies’ Export Promotion Activities 

These “one-stop shops” were to provide coordinated export 

training, trade leads, export finance, and counseling to U.S. businesses 

interested in becoming exporters.

Committee on Appropriations Authorizing committees with jurisdiction

Agency House Subcommittee Senate Subcommittee House Senate

SBA Financial Services and 

General Government

Financial Services and 

General Government

Small Business Small Business and 

Entrepreneurship

Commerce 

(International Trade 

Administration)

Commerce, Justice, 

Science and Related 

Agencies

Commerce, Justice, 

Science and Related 

Agencies

Foreign Affairs Banking, Housing and 

Urban Affairs

Commerce, Science and 

Transportation

Ex-Im State, Foreign Operations, 

and Related Agencies

State, Foreign Operations, 

and Related Agencies

Financial Services Banking, Housing, and 

Urban Affairs

USDA

(Foreign Agricultural 

Service) 

Agriculture, Rural 

Development, Food and 

Drug Administration, and 

Related Agencies

Agriculture, Rural 

Development, Food and 

Drug Administration, and 

Related Agencies

Agriculture Agriculture, Nutrition and 

Forestry

USTDA State, Foreign Operations, 

and Related Agencies

State, Foreign Operations, 

and Related Agencies

Foreign Affairs Foreign Relations

State State, Foreign Operations, 

and Related Agencies

State, Foreign Operations, 

and Related Agencies

Foreign Affairs Foreign Relations

Source: GAO.

 

9

The term “USEAC” refers to the 108 domestic offices where Commerce’s Commercial 

Service operates, including where SBA and Ex-Im have staff colocated with Commerce’s 

staff. 
 

Page 6 GAO-13-217 Export Promotion

According to TPCC data, SBA’s funding for export promotion activities 

has increased substantially in recent years, although SBA’s funding 

remains a relatively small share of overall federal export promotion 

funding. For example, TPCC data showed that SBA received about $4 

million for export promotion activities in fiscal year 2006 and $5.2 million 

in fiscal year 2010 and requested $6 million and $6.4 million, respectively, 

for fiscal years 2011 and 2012. While the fiscal year 2012 request 

represents an increase of 60 percent from its fiscal year 2006 funding 

levels, SBA’s funding represents less than 1 percent of the total export 

promotion funding for the six key agencies that support small business 

exporting. According to the TPCC, the six key U.S. agencies requested 

over $1 billion for trade promotion activities in fiscal year 2012, and SBA 

requested $6.4 million, as shown in table 2.

Table 2: Export Promotion Program Budget, Fiscal Year 2012 (Requested)

Dollars in millions

Agency Budget request

SBA $6.4

Ex-Ima 3 

USTDA 51

Stateb 198

Commerce 350

USDA 515

Total $1,123

Source: TPCC Secretariat.

a

Since fiscal year 2008, Ex-Im has been self-sustaining for appropriations purposes, financing its 

operations from receipts collected from its borrowers. The fees charged by Ex-Im have covered its 

program subsidy and administrative costs in recent years. The program subsidy refers to budgetary 

resources that Ex-Im must allocate annually as capital reserves. Congress retains oversight of ExIm’s budget by setting annual limits on Ex-Im’s use of its funds for program subsidy and 

administrative expenses. For fiscal year 2012, Ex-Im requested $124.6 million for administrative 

expenses. 

b

The budget request amount for State is cumulative for all business and economic activities in the 

agency. 

TPCC member agencies may define trade promotion differently. For 

example, State’s budget includes funding for all State business and 

economic activities because, according to State, those activities could 

contribute to enhancing U.S. trade. Conversely, the budget amount for 

SBA only includes funding for OIT even though other SBA entities, such 

as the SBDCs, may devote substantial amounts of time to export 

promotion. Therefore, the reported budget amounts may not always 

Export Promotion Funding
 

Page 7 GAO-13-217 Export Promotion

reflect each agency’s total level of activity relating to export promotion or 

each agency’s actual contribution toward increasing U.S. exports. 

Furthermore, the export promotion amounts in table 2 do not differentiate 

activities directed toward small businesses from those directed to larger 

businesses. All of the agencies other than SBA work with businesses of 

all sizes, which creates difficulties when making comparisons with SBA 

about export promotion assistance specifically focused on small 

businesses.

Within SBA, OIT has primary responsibility for export promotion. OIT’s 

field staff of Export Finance Specialists are colocated with Commerce in 

19 USEACs throughout the United States, with one OIT staff per USEAC. 

OIT field staff engage in a variety of activities but are primarily 

responsible for providing technical assistance, outreach, and training on 

SBA’s export finance programs.

Separate from OIT, SBDCs are nonfederal partner entities partially 

funded by SBA that provide a wide range of business services, such as 

assisting small businesses with financial and marketing advice and tools, 

primarily through one-on-one counseling services. The over 900 SBDCs 

are organized into networks under 63 lead centers that largely correspond 

with state boundaries except in California and Texas, which have multiple 

lead centers. In addition to providing general business services, SBDCs 

may also help businesses interested in exporting, particularly those that 

are new to exporting and need assistance with preparing their business to 

export. For example, SBDCs may assist a company in developing an 

international business plan. While most SBDCs provide export assistance 

as one of many services, SBA has designated some SBDCs as 

International Trade Centers that focus primarily on exporting.

One person in each of SBA’s 68 District Offices is designated as a District 

International Trade Officer and provides basic export assistance as a 

collateral duty, but these officers spend most of their time on nonexportrelated activities.10

 

10SBA has district offices in every state that provide export and nonexport-related

services. 

The District International Trade Officers are managed 

by a separate SBA office, SBA’s Office of Field Operations, and they are 

not usually colocated at USEACS. SBA intended that District International 

SBA Entities Involved in 

Export Promotion
 

Page 8 GAO-13-217 Export Promotion

Trade Officers only spend about 15 percent of their time on export 

promotion responsibilities. These responsibilities include organizing and 

attending outreach events and fielding export-related questions from 

small businesses directed to the District Office.

SBA’s increased activities in promoting small business exports take place 

within a complex, multiagency environment. The responsibility to provide 

export assistance to small businesses is shared by six key federal 

agencies, which engage in four major activities to promote small business 

exports. The NEI identifies these primary activities for U.S. agencies 

involved in small business promotion, which we classify under four 

general terms:

• Outreach: Identify small businesses that can begin or expand 

exporting

• Counseling and Training: Prepare small businesses to export 

successfully

• Trade Leads: Connect small businesses to export opportunities

• Financing: Support small businesses once they have export 

opportunities

These activities are dispersed across the six key agencies, as shown in 

table 3 and explained in further detail below. All six of the key federal 

agencies and their partner entities that support small business exporting 

participate in outreach and education to help prepare small businesses to 

export successfully. Additionally, each agency and partner entity engages 

in at least one other primary activity to assist small businesses with 

exporting. In addition to conducting outreach, SBA provides counseling 

and training, primarily through SBDCs, and assists small businesses with 

export financing through OIT.

SBA Provides Export 

Promotion Assistance 

to Small Businesses 

within a Complex, 

Multiagency 

Environment
 

Page 9 GAO-13-217 Export Promotion

Table 3: U.S. Agencies’ Activities to Support Small Business Exports

Agency or partner entity Outreach

Counseling 

and training Trade leads Financing

SBA 

OITa X X 

 SBDC X X 

Commerce X X X 

Ex-Ima X X 

USDA X X X X 

USTDA X X 

State Department X X 

Source: GAO analysis of agency documents.

a

Both OIT and Ex-Im provide counseling and training to lenders and small businesses on federal 

export finance products. However, for the purposes of this report, we considered the counseling and 

training provided by OIT and Ex-Im to be a part of both agencies’ provision of financing assistance to 

exporters, rather than an independent service like the counseling and training provided by 

Commerce, SBDCs, and USDA. 

All six of the federal agencies that support small business exports 

conduct outreach, which can include any activity in which agencies seek 

to inform small businesses or other partners, such as lenders, about the 

export promotion services offered by the federal government. For this 

reason, outreach can be difficult to separate from other activities that are 

part of the agencies’ export promotion effort. For example, a Commerce 

trade specialist could attend a trade show to meet with and counsel a 

number of existing clients, but there she would also have the opportunity 

to meet with small businesses to identify potential clients interested in 

exporting. As another example, seminars and training sessions, which 

may be useful for existing exporters or other clients seeking to improve 

their operations, can also serve an outreach function because they often 

help introduce small businesses to exporting and help them identify 

whether they are ready to begin exporting.

Another important outreach tool for export assistance agencies is the 

Export.gov portal. Designed as a “one-stop shop” for companies 

interested in exporting, Export.gov provides content from multiple TPCC 

agencies in a single website. In September 2010, Commerce, working 

with other agencies, revamped the portal to include two new service 

channels, named “Begin Exporting” and “Expand Your Exports,” that are

designed to provide tailored information based on whether or not a 

company currently exports. Companies can use Export.gov to find 

Outreach
 

Page 10 GAO-13-217 Export Promotion

webinars or in-person training or to find local resources that can help with 

export counseling or financing. Commerce intends to roll out a new 

version of Export.gov that allows for more tailored targeting of information 

in January 2013.

SBA (through SBDCs), Commerce, and USDA all provide one-on-one 

counseling services to small businesses. Counseling is specific to the 

needs of each business and can cover a variety of topics relating to 

international trade and exporting, such as helping a business identify a 

target export market or discussing logistics for shipping exported goods. 

USDA’s services, many of which are delivered through nonfederal partner 

entities called State Regional Trade Groups, are targeted specifically at 

businesses that export agricultural products.11

As we have previously reported, export promotion counseling is often 

labor intensive and time consuming because agency staff must spend a 

significant amount of time working with a company before it is able to 

successfully export.

Both Commerce and 

SBDCs offer counseling to businesses of all types.

12

Commerce and SBDCs both also conduct training on a variety of issues 

relating to exporting, such as navigating international logistics. Commerce 

and SBDCs often coordinate with one another, and other agencies often 

participate in their training sessions. While the agencies’ courses may 

cover similar content, officials in Portland, Oregon, noted that some 

features of the courses may appeal to different audiences with different 

In particular, it can take a long time to prepare a 

company for exporting if it has never exported before. According to 

Commerce estimates, it can take 2 years or more from the time a 

company new to exporting begins to receive assistance until that 

business can make a successful export sale. Even companies with 

experience exporting may require over a year of preparation before being 

able to expand into a new market.

 

11There are four such groups located throughout the United States. The State Regional 

Trade Groups are jointly funded by state agricultural departments and USDA’s Market 

Access program. They provide a variety of services to help U.S. companies export 

agricultural goods.

12GAO, National Export Initiative: U.S. and Foreign Commercial Service Should Improve 

Performance and Resource Allocation Management, GAO-11-909 (Washington, D.C.: 

Sept. 29, 2011).

Counseling and Training
 

Page 11 GAO-13-217 Export Promotion

needs. For example, Commerce officials noted that Portland’s SBDC 

offers intensive export training through a 10-session course that takes 

place over 10 months. On the other hand, Commerce and the area’s 

District Export Council offer an Export University course that is specifically 

designed as a 1-day course.

While SBA typically does not provide much assistance with trade leads—

connecting small businesses with overseas buyers—a few of the SBDC 

counselors we met with said they sometimes try to help clients identify 

specific opportunities with overseas partners. Additionally, about 3 years 

ago, OIT started a matchmaker program in which OIT hosts or co-sponsors 

events. The matchmaker events are designed to help small businesses 

interested in exporting meet with export management companies, which 

are intermediaries that represent a company’s product overseas and 

reduce some of the risks associated with exporting by managing the 

logistics of the process. Unlike programs sponsored by other U.S. 

agencies, SBA does not directly connect companies with potential buyers 

through this matchmaking program. However, OIT’s matchmaking events 

could potentially result in more trade leads for small businesses because 

export management companies may be able to help identify foreign buyers.

Other agencies connect clients with trade leads in a variety of ways. For 

example, USDA’s Market Access Program provides funding that helps 

businesses attend trade shows, where they have opportunities to meet 

directly with potential buyers. Commerce leverages its international 

network of Commercial Officers to help U.S. businesses set up 

appointments with potential buyers abroad and to notify businesses when 

foreign buyers are looking to import U.S. goods. State Foreign Service 

Officers sometimes serve a similar role at overseas posts where 

Commerce does not have a presence. USTDA helps businesses identify 

export opportunities by providing financial assistance through grant and 

contract opportunities for U.S. businesses to conduct feasibility studies, 

pilot projects, and technical assistance, as well as hosting reverse trade 

missions, in which USTDA brings foreign buyers to the U.S. to help 

connect them with U.S. companies, both large and small.

13

 

13In commenting on our draft report, USTDA officials stated that USTDA does not provide 

export financing, but instead provides financial assistance to pursue trade leads through 

grants and contract opportunities. 

Trade Leads
 

Page 12 GAO-13-217 Export Promotion

SBA, Ex-Im, and USDA offer various forms of financing assistance to 

small businesses, as outlined in table 4. SBA and Ex-Im both offer loan 

guarantees, which help businesses secure financing from private lenders, 

for working capital loans. Working capital loans may be used by 

businesses to finance activities that will help complete export sales. For 

example, a business might use a working capital loan to buy raw 

materials that it will use in manufacturing goods for export. SBA also 

offers guarantees on facilities development loans, which can be used to 

acquire or upgrade facilities and equipment used to produce goods or 

services involved in international trade. USDA offers loan guarantees to 

facilitate international sales of U.S. agricultural products, and Ex-Im 

provides direct loans to international buyers of U.S. exports, both of which 

allow U.S. companies to secure export orders and may result in larger 

orders. Ex-Im also offers insurance on export sales. 

Table 4: Export Financing Assistance Programs Available to Small Businesses, by 

Federal Agency

Agency

Working capital 

financing

Facilities 

development 

financing

Financing for 

international 

sales

Export 

insurance

SBA X X 

Ex-Im X X X 

USDA X 

Source: GAO analysis of agency documents.

Note: The Overseas Private Investment Corporation, which is outside of the scope of our review, 

provides financing assistance and insurance on direct foreign investments. 

SBA and Ex-Im both have finance specialists in domestic field offices who

provide one-on-one technical assistance on export financing to small 

businesses and lenders. For example, they may counsel small 

businesses about different options for financing export sales.

Agencies that provide loan guarantees and export-credit insurance have 

a financial impact that can far exceed their budget. Total SBA and Ex-Im 

financing for small businesses has increased in recent years, from just 

over $5 billion in fiscal year 2009 to nearly $7 billion in fiscal year 2011.14

 

14USDA does not track export loan guarantee financing by business size and, therefore, 

was not able to provide data on financing for small businesses.

Financing
 

Page 13 GAO-13-217 Export Promotion

In fiscal year 2011, Ex-Im approved 3,247 small business transactions, 

while SBA approved 1,547 small business loan guarantees. The majority 

of Ex-Im transactions, or over 2,600 transactions worth approximately 

$3.3 billion, were for export-credit insurance, while all SBA financing is for 

loan guarantees.

SBA, Commerce, and Ex-Im collaborate on some export promotion 

activities in headquarters and at field locations, but some services 

overlap, which can be confusing for small businesses and may not be an 

optimal use of resources. Some SBDCs and Commerce staff offer similar 

counseling services, and SBA and Ex-Im offer similar financial products to 

small businesses. SBA has collaborated with other agencies to develop a 

joint strategy for increasing small business exports and to include 

collaborative efforts in performance evaluations. However, SBA and other 

agencies have not clearly defined agencies’ roles and responsibilities for 

export promotion, nor have they fully leveraged resources such as by 

regularly sharing client information, where possible. 

SBA export assistance efforts overlap with those of other agencies, 

primarily with the export counseling offered by Commerce and export 

financing products offered by Ex-Im; this overlap can create confusion for 

small businesses seeking export assistance. Overlap occurs when federal 

agencies have similar goals, engage in similar activities to achieve them, 

and target similar beneficiaries. When agencies provide overlapping 

services to the same clients, there are potential resource inefficiencies, 

and agencies could potentially focus their resources and strengths to 

better target clients and address identified needs.

SBA’s SBDCs and Commerce both provide one-on-one export counseling 

to small businesses that are new to exporting or currently exporting. 

Export counseling is tailored to the needs of each company, so the issues 

covered vary by client, but SBDCs and Commerce may cover similar 

issues. For example, both offer strategic advice to help companies 

identify target markets for exporting, assist companies in understanding 

and ensuring they are compliant with exporting regulations, and develop 

seminars to teach small businesses about the fundamentals of exporting.

Not all services provided by SBDCs and Commerce overlap. For 

example, SBDCs help companies develop business plans or conduct 

financial analysis, services that Commerce does not provide. Commerce 

also leverages its overseas offices to provide more in-depth fee-based 

services such as its Gold Key service, which incorporates market 

SBA Has Taken Steps 

to Collaborate with 

Other Agencies, but 

Further Collaboration 

Efforts Are Needed

Overlapping Export 

Assistance from SBA and 

Other Agencies Can Be 

Confusing for Small 

Businesses and May Lead 

to Inefficient Use of 

Resources
 

Page 14 GAO-13-217 Export Promotion

research, in-person counseling, and personalized appointments with 

potential partners overseas.

SBA and Ex-Im offer similar export financing products to small 

businesses, which are delivered through some of the same lending 

institutions. SBA and Ex-Im export working capital loan programs have 

many similar features, as shown in table 5. SBA and Ex-Im officials noted, 

however, that each program has limitations for eligibility, so companies 

may be able to use only one agency’s product. For example, Ex-Im 

generally requires that more than 50 percent of the content of an 

exportable good guaranteed through its Working Capital Guarantee 

Program originate in the United States. SBA’s Export Working Capital 

Program has no similar content requirement, so companies using foreign 

materials may prefer SBA loan guarantees. On the other hand, SBA can 

only guarantee a maximum loan of $5 million, so companies seeking 

larger loan guarantees may prefer Ex-Im. Additionally, since both 

products are loan guarantees, customers must still receive the actual loan 

through a private lender.

Table 5: Selected Features and Limitations of SBA and Ex-Im Working Capital Loan Guarantees

Program features and 

limitations SBA Export Working Capital Program Ex-Im Working Capital Guarantee Program

Product Loan guarantee Loan guarantee

Type Single order or revolving line of credit; allows for 

advances against purchase orders

Single order or revolving line of credit

Eligibility Small business operating for at least 1 year (can 

be waived based on management experience)

Business of any size operating for at least 1 

year (can be waived based on management 

experience)

Must meet certain financial requirements, 

including having positive net worth and 

meeting minimum standards on certain key 

industry ratios 

Collateral Export-related inventory and accounts receivable 

from export sales

Personal or corporate guarantee of the owner

Export-related inventory and accounts 

receivable from export sales

Personal or corporate guarantee of the owner

Content requirements None Must contain more than 50% U.S. content

Cannot be used to finance defense articles or 

services, with limited exceptions 

Loan percentage guaranteed Up to 90% Up to 90%

Maximum loan amount 

guaranteed 

$5 million No limit

Source: GAO analysis of Department of Treasury, SBA, and Ex-Im documents.
 

Page 15 GAO-13-217 Export Promotion

SBA and Ex-Im officials in the field noted that the agencies’ express loan 

programs also share some similarities. In 2012, Ex-Im introduced its 

Global Credit Express program as a pilot, which is designed to provide a 

relatively fast infusion of capital to small business exporters and is similar 

to SBA’s Export Express program, as outlined in table 6. Ex-Im’s Global 

Credit Express program is still smaller in terms of volume—according to 

an Ex-Im official, it had resulted in fewer than 10 loans as of November 

2012—and some details of the program are evolving, such as the options 

for lending institutions to refer clients to Ex-Im. However, both products 

are available for a variety of business activities that will support a 

company’s export development. In addition to Ex-Im’s restrictions 

regarding U.S. content of exported goods, one major difference between 

the two products is that SBA’s Export Express is a guarantee for a loan 

provided by a private lender, while Ex-Im’s Global Credit Express is a 

direct loan from Ex-Im to a small business. Ex-Im officials also noted that 

Ex-Im charges significantly higher fees for Global Credit Express than 

SBA does for Export Express to ensure the programs do not compete. 

Additionally, SBA officials noted that there are substantial differences in 

the duration of each loan, with the Export Express program offering either 

a revolving line of credit with a maturity of up to 7 years or a term loan 

with a maturity of up to 25 years, while Global Credit Express has a 

maturity of up to 1 year.

Table 6: Selected Features and Limitations of SBA and Ex-Im Express Loan 

Programs

Program features and 

limitations SBA Export Express Ex-Im Global Credit Express

Product Loan guarantee Direct loan from Ex-Im

Content requirements None Must contain more than 50% 

U.S. content

Cannot be used to finance 

defense articles or services, with 

limited exceptions 

Loan limit $500,000 $500,000

Eligibility Small business operating for 

at least 12 months

Small business operating for at 

least 3 years and exporting for at 

least 1 year

Response time One business day About 5 days

Source: GAO analysis of SBA and Ex-Im documents.
 

Page 16 GAO-13-217 Export Promotion

Overlapping services can be confusing for small businesses and may 

result in an inefficient use of government resources. Both agency officials 

and private sector representatives said overlapping services can make 

navigating the federal export assistance system difficult. According to 

SBA, SBDC, Commerce, and Ex-Im officials, small businesses typically 

do not know which services each agency provides or where to go for 

assistance. Private sector representatives agreed it is challenging for 

small businesses seeking export assistance to determine which federal 

entity would best serve their needs. They noted, for example, that export 

financing assistance is very important for small businesses to be 

competitive in international markets, but it can be difficult to understand 

the differences between federal loan programs for financing exports. 

Additionally, as we have noted in the past, overlapping federal efforts can 

result in an inefficient use of government resources.15 By addressing such 

inefficiencies, agencies could more effectively target government 

resources toward accomplishing the NEI goal.

In prior work, we identified practices that can help enhance and sustain 

collaboration among federal agencies and thereby maximize performance 

and results, and we have recommended that agencies follow them.16

These collaborative practices include among them establishing joint 

strategies, reinforcing individual accountability for collaborative efforts, 

determining roles and responsibilities, and leveraging resources, as 

described in table 7.17

 

15For example, see GAO, 2012 Annual Report: Opportunities to Reduce Duplication, 

Overlap and Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP 

(Washington, D.C.: Feb. 28, 2012). 

16GAO-06-15. 

17In addition, the Government Performance and Results Act Modernization Act of 2010 

requires agencies to describe in annual performance plans how they are working with 

other agencies to achieve their own performance goals as well as relevant federal 

government performance goals. See Pub. L. No. 111-352, 124 Stat. 3866 (2011). 

SBA and Other Agencies 

Follow Some Best 

Practices in Collaboration 

but Could Take Further 

Actions to Reduce Overlap
 

Page 17 GAO-13-217 Export Promotion

Table 7: Best Practices in Collaboration

Establish mutually reinforcing or joint strategies

Design individual but mutually reinforcing strategies or a joint strategy to help align 

activities, core processes, and resources to achieve a common outcome.

Reinforce individual accountability for collaborative efforts

Design performance management systems that emphasize and set performance 

expectations for collaboration.

Agree on roles and responsibilities

Define and agree on respective roles and responsibilities, including how the 

collaborative efforts will be led. In doing so, agencies can clarify who will do what, 

organize their joint and individual efforts, and facilitate decision making.

Leverage resources to identify and address needs

Leverage resources, such as human, information technology, physical, and financial 

resources, to support the common outcome.

Source: GAO-06-15. 

SBA and other agencies have developed a joint annual strategy at the 

headquarters level to work collaboratively toward the NEI goal of doubling 

U.S. exports by the end of 2014. The 2011 National Export Strategy 

(Strategy), drafted by SBA, Commerce, Ex-Im, and other TPCC agencies, 

was the first time that the agencies developed common metrics for 

measuring the federal government’s export-promotion and trade-access 

impacts as a whole, rather than highlighting individual agencies’ 

successes. Joint performance measures include the number of small 

business exporters assisted by U.S. government finance programs, the 

value of exports supported by counseling, and the value of exports 

supported by financing assistance.18

 

18The 2012 National Export Strategy provided the first year-to-year comparison of results 

for the performance measures outlined in the 2011 Strategy, according to Commerce 

officials.

The Strategy also discusses 

progress with regard to NEI priorities, including exports by small 

businesses and other areas such as trade access. While the Strategy 

does not identify areas of overlap in export promotion services across 

agencies, it distinguishes the different types of expertise and assistance 

needed by small businesses that have never exported (new-to-export) 

compared with those that have exporting experience and are expanding 

into new markets (new-to-market). The Strategy also notes efforts by SBA 

to track data on new-to-export companies and a Commerce initiative to 

target new-to-market companies. SBA also has agency-wide and OITSBA and Other Agencies Have 

Developed a Joint Export 

Strategy for Achieving NEI’s 

Goal
 

Page 18 GAO-13-217 Export Promotion

specific plans that address agency goals. Both plans are generally 

consistent with the NEI goal.

While the Strategy was created at the headquarters level, much of its 

implementation takes place in the field. The NEI created an overarching 

goal for the different trade agencies and guides the Strategy, but agency 

officials at the headquarters and field levels differed in their views about 

the NEI’s impact on collaboration. SBA and other agency officials at the 

headquarters level noted improvements in collaboration as result of the 

NEI, such as interagency communication and coordination of events, 

which are discussed in the Strategy. However, SBA staff and other 

agency staff we interviewed in some field locations noted that while the 

NEI has increased public awareness of federal export assistance 

activities, it has had limited effect on the extent to which the agencies 

collaborate. In its report that reviewed coordination among USEACs and 

federal and nonfederal partners with respect to NEI priorities, the 

Commerce Office of the Inspector General similarly noted that Commerce 

actions to implement the NEI have had a limited effect on the extent and 

quality of collaboration with such partners.19

SBA and other agencies have taken steps to implement the best practice 

of including collaborative efforts in performance evaluations of export 

assistance staff; however, the export promotion assistance entities vary in 

how they include collaboration efforts in their performance standards and 

measures. For example, OIT performance standards include staff’s 

participation in activities and events in conjunction with other export 

agencies. OIT officials also noted that beginning in fiscal year 2013, they 

will track the number of export credit insurance referrals made by OIT 

staff to Ex-Im staff. SBDCs’ performance measures focus on the clients 

and jobs for which SBDC staff provide assistance, but officials told us that 

SBA is beginning to track SBDCs’ collaborative efforts with other 

agencies. While Commerce staff’s performance evaluations note services 

provided by partner agencies, Commerce field staff told us that generally 

the key incentive for Commerce staff is to conduct services that help 

facilitate an export sale. Ex-Im’s performance metrics encourage 

collaboration because they allow for staff to count financial referrals to 

other agencies toward their own performance goals. An Ex-Im official 

 

19Commerce Office of Inspector General, U.S. Export Assistance Centers Could Improve 

Their Delivery of Client Services and Cost Recovery Efforts, Audit Report Number 

OIG-13-010-1 (Washington, D.C.: Nov. 30, 2012).

SBA and Other Agencies 

Generally Include 

Collaboration Efforts in Staff’s 

Performance Evaluations 
 

Page 19 GAO-13-217 Export Promotion

noted that if an Ex-Im employee determines that an SBA financial product 

is more appropriate for a client and the referral results in a completed 

transaction, the Ex-Im staff may choose to count the sale of the SBA 

product toward individual performance goals. The NEI states that 

agencies should use such incentives to encourage employees to direct 

companies to the best option for financing even if the company is sent to 

another agency.

SBA and other agencies have not developed guidance on roles and 

responsibilities to address overlapping counseling and financing 

functions. To implement this best practice in collaboration more 

effectively, SBA and other agencies providing similar export assistance to 

small businesses could clarify which export agency will serve certain

export functions or types of clients. Officials of SBA and the other 

agencies have not formalized a process for determining how to direct 

clients with differing needs and levels of exporting experience to the most 

appropriate agency.20

First, SBA and Commerce have not clearly defined each agency’s role in 

counseling small business exporters. SBDC and Commerce officials we 

spoke with indicated that they try to limit overlap by focusing on the areas 

where each entity has relatively more experience. Headquarters SBA and 

Commerce staff stated that SBDC counselors are expected to work with 

new-to-export companies while Commerce trade specialists should focus 

on new-to-market companies. According to Commerce officials, 

Commerce prefers to work with new-to-market businesses or businesses 

looking to export more in a market where they already export because 

those businesses can quickly take advantage of Commerce’s extensive 

services and overseas resources. Commerce field staff are supposed to 

refer new-to-export businesses to SBDCs, where these businesses may 

benefit from an array of general business development services. 

According to Commerce officials, when Commerce staff focus on new-tomarket businesses and send new-to-export businesses to SBDCs, the 

 

20After we submitted a draft of our report to the agencies, SBA provided us with an 

Interagency Communiqué developed by TPCC agencies. The communiqué establishes a 

“No Wrong Door” policy and provides guidance on referring U.S. businesses seeking 

export assistance to one or more specific entities based on an assessment of a client’s 

export readiness and its needs for counseling and training and/or trade leads; however, 

the communiqué does not include referral protocols for clients requiring trade financing 

products, which the communiqué said would be issued by the end of January 2013. 

Agencies Have Not Clarified 

Their Roles and 

Responsibilities for Export 

Promotion
 

Page 20 GAO-13-217 Export Promotion

result is a more efficient use of Commerce resources than if Commerce 

staff were to focus on counseling new-to-export businesses.

While some SBA and Commerce officials explained the division of 

responsibilities for assisting new-to-export versus new-to-market 

businesses, we found that the division of responsibilities between the 

SBDCs and Commerce is not clearly defined in practice. Moreover, the 

agencies have not developed guidance that outlines a common 

understanding about where clients should be directed based on their 

export readiness.21

SBDC and Commerce staff in some locations also noted that they may 

counsel the same client, but they do not regularly discuss with one 

another what services they provide to clients, nor do they regularly share 

client information. Some Commerce field staff also said that they had little 

interaction with their SBDC counterparts. Additionally, some Commerce 

field staff said that they continue to work with new-to-export clients that 

could help them meet their individual performance targets for export 

successes. SBA and Commerce officials informed us that they had not 

developed formal agency or interagency guidance that directed SBDC 

counselors and Commerce staff to primarily counsel one type of client.

SBDC and Commerce field staff indicated that 

interagency roles and responsibilities for counseling new-to-export and 

new-to-market companies are unclear. SBDC and Commerce staff at all 

six field locations we visited said that they counsel both new-to-export 

and new-to-market businesses, and that both agencies at their location 

may provide the same type of counseling. For example, sometimes both 

SBDCs and Commerce specialists at some locations provide market 

research for clients.

Second, SBA and Ex-Im have similar roles and responsibilities for similar 

financial products for small businesses. According to SBA and Ex-Im, the 

overlap in their financial products results from both agencies’ efforts to 

respond to lender preferences. Ex-Im officials said that many lenders 

prefer to work with only one agency and very few lenders use both 

agencies’ products, so clients may only be able to access one agency’s 

products through their regular bank. SBA designates Preferred Lenders 

 

21In December 2012, TPCC agencies sent field staff the Interagency Communiqué that 

provides guidance on how to assess the export readiness of clients and identifies general 

referral channels once a business has been classified as: (1) not a good candidate for 

exporting; (2) not ready to export; (3) ready to export; or (4) an existing exporter.
 

Page 21 GAO-13-217 Export Promotion

for its Export Working Capital loan guarantee with authority to process 

these loans without prior SBA review, and the SBJA has a provision that 

makes lenders participating in Ex-Im’s similar Delegated Authority 

Program eligible to participate in SBA’s Preferred Lenders program.

However, both SBA and Ex-Im field staff noted that lenders primarily 

prefer to work with only SBA or Ex-Im, due to the time and expertise 

needed to learn each agency’s complex requirements and to process 

each agency’s products. If a potential export financing client only meets 

the eligibility requirements for one agency’s product and the client’s 

lender does not work with that agency, the client would need to find a new 

lender to receive the agency’s loan guarantee. SBA and Ex-Im may be 

able to explore options to better align export financing products and to 

assist lenders in more easily adapting to the rules for both SBA and Ex-Im 

products.

Third, the roles and responsibilities of SBA’s 68 District Offices and their 

relationship to other export promotion entities have also been unclear and 

are in transition. The Strategy envisioned that District International Trade 

Officers would lead Export Outreach Teams that would coordinate 

activities with Commerce at the local level. SBA officials noted that this 

had not happened because these district officers are still learning their 

responsibilities in assisting exporters, and their role is still evolving.

Furthermore, some Commerce staff expressed uncertainty about the 

roles and responsibilities of the designated District International Trade 

Officers and had little or no interaction with them. We found the level of 

export promotion activities carried out by SBA district offices varied 

widely. For example, one District International Trade Officer with 

substantial personal experience with export-related issues was heavily 

involved in a wide variety of activities, including organizing events and 

providing one-on-one counseling to businesses interested in exporting. In 

contrast, other District International Trade Officers said that they had little 

or no experience with exporting and that their export-related activities are 

limited to serving as a point of contact within the district office and 

referring businesses to the appropriate federal entity.

While SBA and other agencies take some steps to leverage interagency 

resources both in headquarters and in the field, they do not regularly 

share client information, where possible, which may result in less effective 

client services. One best practice in collaboration emphasizes that 

agencies should leverage resources—such as human, information 

technology, physical, and financial resources—to support the common 

outcome established by the agencies’ joint strategy.

SBA and Other Agencies 

Leverage Some Resources but 

Do Not Regularly Share Client 

Information, Where Possible
 

Page 22 GAO-13-217 Export Promotion

At the headquarters level, we found several instances showing that SBA 

and other agencies have taken steps to effectively leverage one another’s 

export-promotion resources, as the following examples illustrate:

• OIT chairs the TPCC’s Small Business Working Group, which 

coordinates interagency cooperation on small business export 

promotion as part of the NEI. Agencies discuss coordination of small 

business exporting issues through this working group, including the 

issue of streamlining initial client intake across agencies to help 

agencies provide more targeted assistance to companies.

• Agencies have also produced interagency outreach materials on 

federal export financing services through this working group. For 

example, the working group distributed a brochure on export financing 

and foreign investment finance programs available through SBA, ExIm, and USTDA.

• SBA and Commerce staff in headquarters coordinate client intake 

through the Export.gov website and are working to enhance the site to 

help companies obtain more targeted assistance from agencies.

Currently, registrants of Export.gov self-identify their export readiness; a 

Commerce staff downloads registrants’ information from Export.gov and 

sends the information from new-to-export companies to OIT in SBA 

headquarters and directs new-to-market companies to Export.gov 

resources. Commerce and SBA officials told us they are working together 

to develop a new version of Export.gov, expected to be completed by 

January 2013, that is intended to improve upon the current design to 

better direct registrants to the appropriate export promotion entity and 

nearest geographical locations. These officials told us that the new 

version of Export.gov will ask the registrant a series of questions to 

determine the company’s extent of business development and export 

readiness, and direct the company to the agencies or entities that could 

best assist it.

At the field level, SBA and other agencies leverage resources by 

conducting joint outreach and training events. At all six locations we 

visited, SBA and other agencies invite one another to various events, 

including trade shows, road shows, and training events that inform small 

businesses about available federal services. For example, in one location, 

staff told us that at trade show events, SBA, SBDCs, Commerce, and ExIm may conduct joint seminars, where Commerce staff could discuss 

marketing and sales, while SBA and Ex-Im staff discuss financing. In 
 

Page 23 GAO-13-217 Export Promotion

another location, Ex-Im staff said they may include partners such as 

SBDCs in road shows they conduct.

Although we found that SBA and other agencies leverage interagency 

resources to some extent both in headquarters and in the field, we also 

found that SBA and other agencies could better leverage resources by 

sharing client information more consistently. In 2010, the Export 

Promotion Cabinet recommended strengthening interagency information 

sharing and coordination to implement the NEI. The extent to which SBA 

and other agencies share exporters’ information on a regular basis varies. 

Commerce and Ex-Im have an informal agreement to share nonbusiness

confidential client information on a quarterly basis. Commerce shares the 

name and contact information for clients that have purchased certain 

Commerce products, such as a Gold Key Service, and successfully 

exported.22 Ex-Im shares a list of new export credit insurance clients with 

Commerce but does not include client contact information. By contrast, 

SBDC counselors generally cannot share specific client information with 

other entities unless they receive permission from the client,23

Some SBA, SBDC, Commerce, and Ex-Im staff in the locations we visited 

told us that obtaining access to agencies’ client information would be 

beneficial. For example, such access could help increase their own 

clientele base and potentially provide small businesses with assistance in 

their area of expertise, as well as track the status of clients in the export 

life cycle. Commerce staff in headquarters and the field also noted that 

access to OIT client lists could improve Commerce’s ability to report 

and OIT 

does not regularly share its client list with SBDCs, Commerce, or Ex-Im, 

nor does it regularly receive client lists from other entities. OIT officials 

noted that currently, OIT field staff may share information about clients 

with other agencies informally, such as by engaging in joint client phone 

calls with other agencies’ staff at the USEACs. Agency officials noted that 

information sharing is limited by certain privacy restrictions. SBA and 

other agencies’ officials told us they are currently reviewing the types of 

information that they could share with each other.

 

22In November 2012, the Commerce Office of Inspector General found that restrictions on 

sharing of client information constrained Commerce’s ability to collaborate with other 

agencies and recommended that it explore the possibility of requiring clients to waive 

confidentiality as a condition for receiving services. Commerce concurred with this 

recommendation.

23See 15 U.S.C. § 648(a)(7)(A). 
 

Page 24 GAO-13-217 Export Promotion

export successes, thereby helping Commerce track their impact in 

helping increase small business exports.

The SBJA expanded SBA’s presence in providing export assistance to 

small businesses, by requiring an increase in the export training of SBDC 

staff and an increase in the number of OIT field staff.24 SBA has made 

progress in certifying SBDC staff by SBA’s own established target date.

However, SBA did not meet the OIT field staff levels within the deadline 

set by the SBJA, citing hiring and funding challenges. SBA’s most recent 

plan to increase OIT field staff does not provide funding information for 

the new positions and updated time frames for filling them.

According to SBA, the SBJA is the most significant piece of small 

business legislation in over a decade because it provides resources to 

help small businesses continue to drive economic recovery and create 

jobs. Among other changes, the SBJA increased the maximum size of 

SBA’s export loan and loan guarantee amounts and elevated the 

importance of OIT within SBA by making it an independent office.25 In 

supporting NEI goals, the law also increased SBA’s staff to provide 

additional export counseling resources to promote small business 

exporting.26

 

24Pub. L. No. 111-240, §§ 1201-1209.

25Pub. L. No. 111-240, §§ 1203 and 1206.

26Pub. L. No. 111-240, § 1205(a). 

SBA Has Made Some 

Progress in Increasing 

Export Training but 

Experienced 

Challenges in Meeting 

Staffing Requirements 

under the Small 

Business Jobs Act of 

2010

Small Business Jobs Act of 

2010 Expanded SBA 

Training and Staffing 

Requirements for Export 

Promotion Activities
 

Page 25 GAO-13-217 Export Promotion

The SBJA included the following requirements for SBA with regard to 

export promotion staffing and training:

Small Business Development Centers training/certification. At 63 lead 

SBDCs,27 SBJA required that five staff or 10 percent of staff, whichever is 

less, obtain certification in providing export assistance.28

Office of International Trade field staff levels. SBJA required that by 

December 27, 2010, the number of OIT export financial specialists at 

USEACs would be at least the same as the number of these staff in 2003, 

which was 22, according to SBA.

SBA provides 

that certification can be obtained through an exam or a specific 

professional certification program

29 The law required that there should be 

at least 3 of these OIT staff in each of the 10 SBA regions by September 

27, 2012, which would require a minimum of 30 staff at USEACs 

nationwide.30 In addition, SBJA stipulated that SBA should place priority 

in certain locations and then strategically assign staff to the USEACs 

based upon the needs of exporters.31

The export and trade certification program for SBDC staff is intended to 

greatly expand the number of qualified small business counselors 

available to help small businesses to engage in international trade and to 

provide consistency in the quality of assistance across the SBDC 

networks. In interpreting the SBJA requirement for certifying staff at the 

63 lead SBDCs, SBA determined that the certification standard would be 

based on the total number of staff in each of the 63 SBDC networks and 

not merely on the number of staff at the lead SBDCs. The certification 

program would encompass staff at any of the over 900 SBDCs that 

 

27Each statewide or region-wide SBDC network is managed by a Lead Center. There are 

63 Lead Centers throughout the states that manage and administer the 63 small business 

assistance networks, each consisting of the Lead Center and its Service Centers.

28Pub. L. No. 111-240, § 1204(a)(7).

29Pub. L. No. 111-240, § 1205(a). 

30Id. 

31Pub. L. No. 111-240, § 1205(a). The SBJA required that SBA, to the maximum extent 

possible, fill new OIT staff positions at those USEACs that (1) had OIT staff before 

January 2003 and (2) had not had OIT staff between January 2003 and September 27, 

2010, due to retirement or reassignment. 

SBA Has Made Progress in 

Certifying Small Business 

Development Center Staff 

to Increase Expertise in 

Export Counseling
 

Page 26 GAO-13-217 Export Promotion

provide services to small businesses. According to SBA, this 

interpretation of the certification requirement helps ensure that all of the 

63 SBDC networks have a minimum number of qualified counseling and 

training staff available to provide export and trade assistance to their 

small business clients. Although the SBJA did not specify a time frame to 

meet this requirement, SBA established its own agency policy to 

complete the certification requirement by December 31, 2013.32

SBA provided two options for SBDC staff to obtain certification: (1) staff 

could take and pass an online competency test administered by SBA, or 

(2) staff could obtain certification in the National Association of Small 

Business International Trade Educators’ Certified Global Business 

Professional program.33 SBA collaborated with the TPCC to develop an 

export education program that offers education in basic concepts, key 

international trade assistance resources, and key aspects of global trade 

to help small business counselors prepare for the SBA test. As of the end 

of September 2012, 73 percent of the SBDC networks (46 of 63) had met 

the certification requirement.34 SBA noted that the certification 

requirement was intended to achieve one of the key goals of the SBJA—

to improve the quality of international trade counseling and training 

received by businesses through the SBDC network. During our fieldwork, 

we found that SBDC staffs’ knowledge and experience with international 

trade varied across some locations. Some SBDCs were focused primarily 

on international trade.35

 

32For SBDCs with cooperative agreements that begin and end on the federal fiscal year 

cycle, the deadline is September 30, 2013. For SBDCs with cooperative agreements that 

begin and end on a calendar year cycle, the deadline is December 31, 2013.

Some SBDC staff had prior export experience 

that was helpful in providing export counseling to small businesses, 

33The Certified Global Business Professional program is an internationally recognized 

independent certification for advanced proficiency in global trade assistance, available 

through training offered by a third party, such as a community college.

34A total of 195 SBDC staff were certified because they passed SBA’s online competency 

test, and 132 staff were certified through the Certified Global Business Professional 

program.

35According to SBA officials, some SBDC networks have one or more separately 

budgeted International Trade Centers that specialize in export and international trade 

assistance. In 2012, there were nine designated International Trade Centers. Other 

SBDCs within a given network may be very active in providing export assistance although 

they are not designated as a separate International Trade Center. The designation is 

based on each SBDC network’s preferred organizational structure and small business 

needs.
 

Page 27 GAO-13-217 Export Promotion

according to these officials, while others had less experience and 

acknowledged the need for additional training. Field staff at the locations 

we visited informed us that they had either obtained or were in the 

process of obtaining certification.

The SBJA directed OIT to increase field staff in two phases, and to 

distribute staff regionally. In an attempt to meet the SBJA requirement of 

increasing its OIT field staff levels from 18 to 22 at USEACs by the end of 

2011, SBA advertised 4 temporary positions in 4 specific locations but 

filled only 2 positions by June 2011 using SBJA funding that expired on 

September 30, 2012. The 4 locations were based on SBA’s analysis of 

locations that lacked OIT staff since 2003 and had exporters with the 

greatest needs. With the expiration of the SBJA funding, SBA stopped 

advertising the remaining 2 positions left unfilled. Although SBA needed 

to increase its field presence to 30 OIT staff by September 27, 2012, SBA 

had not hired any more than the 2 additional OIT staff and had a total of 

19 OIT staff in USEACs.36 Furthermore, despite the SBJA’s requirement 

for 3 OIT staff to be placed in each of SBA’s regions, there are currently 

only 2 out of 10 SBA regions with 3 or more OIT staff, while the other 8 

regions do not have the required staff levels. See figure 1 for a map of the 

current number of SBA OIT staff by SBA region.

 

36SBA started with 18 OIT field staff and then hired 2 additional staff. Given the attrition of 

one existing OIT staff and the placement of one of the new staff to fill the vacated position, 

SBA had a total of 19 at the end of September 2012.

SBA’s Efforts to Add OIT 

Field Staff Have Fallen 

Short of Requirements, 

and Its Staffing Plan Lacks 

Key Information
 

Page 28 GAO-13-217 Export Promotion

Figure 1: Locations and Number of SBA OIT Staff by SBA Region, as of September 30, 2012

Notes: Though OIT field staff serve in the USEACs shown, USEAC regions do not match up with the 

SBA District Office regions shown in the map. For example, SBA OIT staff in the Portland, Oregon, 

USEAC cover Montana. Montana is covered, however, by a different SBA District Office than the one 

serving Oregon. 

a

Alaska is in the Pacific Northwest Region. 

b

Hawaii is in the Pacific Region. 

c

Guam is in the Pacific Region 

d

Puerto Rico and the U.S. Virgin Islands are in the Atlantic Region. 
 

Page 29 GAO-13-217 Export Promotion

According to SBA officials, SBA encountered hiring challenges that 

hindered it from filling the four temporary, 13-month term positions it 

advertised. The main difficulties were that the positions offered were not 

permanent positions and required specialized trade finance expertise, 

which contributed to a shortage of qualified candidates. SBA officials said 

that there were no qualified applicants for the OIT position in one location 

and few interested and qualified candidates in the other locations.

Applicants for the temporary OIT positions that SBA advertised were 

required to have 1 year of specialized experience to minimally qualify for 

the position. SBA also considered qualifications such as knowledge of 

SBA’s trade finance programs; knowledge of advanced concepts, 

principles, and practices of international trade; and the ability to 

underwrite export trade finance transactions.

Citing difficulties with finding qualified staff for the four advertised OIT 

positions, and not having continued funding to hire more staff, SBA never 

advertised for the additional eight OIT positions it would have had to fill, in 

addition to the original four, to meet the SBJA field staffing requirement. 

SBA officials noted that they still have the goal to hire additional OIT staff, 

and said they intend to implement the requirement to hire up to 30 OIT 

staff after fiscal year 2012, if SBA has sufficient funds available for that 

purpose. With the expiration of SBJA funding at the end of September 

2012, SBA officials told us that they no longer have the funding to hire 

additional OIT staff. SBA received $26.5 million in SBJA funds to 

implement SBJA requirements, according to SBA officials. Since OIT 

positions required by the SBJA were not filled, SBA used the funds to 

meet other SBJA requirements, such as hiring staff in offices other than 

OIT and, within OIT, hiring an Assistant Administrator and preparing 

export-related reports, both as required by the SBJA.

SBA developed a plan to increase its OIT staff levels to 30 staff and 

proposed—in a report submitted to Congress in September 2012—to 

place the staff in specific USEACs. This proposed allocation of staff does 

not match the one specified in the SBJA requirement. While the SBJA 

required 3 OIT field staff in each of SBA’s 10 regions, SBA’s proposal for 

staff allocation was a minimum of 2 staff in some SBA regions and 5 staff 

in 1 region. SBA explained that its staffing allocation proposal reflected 

optimal distribution to support exporters’ needs based on available fullyear trade data from U.S. Census and Commerce. The SBA OIT field 

staffing plan noted that the underlying logic of its proposed allocation was 

that the more exporters there were within a state, the more opportunities 

SBA staff would have to directly interact with and assist them.
 

Page 30 GAO-13-217 Export Promotion

SBA’s plan lacks some critical updated information. The plan listed the 

proposed USEAC locations and the SBA regions where OIT staff would 

be located, as well as the number of SBA exporters and percentage of 

small business exporters in each of SBA’s 10 regions. It also noted that 

the SBJA funding for the OIT positions would expire on September 30, 

2012, but did not discuss how SBA intended to fund the future new 

positions to meet the required staffing levels. Although the report was 

submitted to Congress only weeks before the SBJA deadline to meet 

OIT’s staffing requirement, the plan also did not discuss revised targets 

for time frames, providing no information on when SBA expects to reach 

the level of OIT field presence required under the SBJA.

Moreover, the plan explained SBA’s difficulties in attracting qualified 

candidates, but the plan did not discuss how SBA would overcome the 

hiring challenges or discuss the potential for leveraging the resources of 

other export promotion entities that could provide similar export 

assistance as that provided by OIT staff. Some OIT staff told us that they 

are currently covering OIT work for a large geographic area. With the 

current OIT staff levels and locations, these staff have been meeting the 

needs of small businesses within their office’s jurisdiction but outside the 

metropolitan areas where they are based. They said they can do this by 

traveling to attend outreach events and by relying on referrals from staff 

of other export promotion entities with offices in various locations outside 

the OIT-served metropolitan areas. These other entities include 

Commerce, SBDC, or financial institutions that serve as lenders of SBA 

export loans. In light of the array of services provided by existing export 

assistance entities, SBA may be able to leverage other entities’ resources 

in fine-tuning its plan for hiring additional OIT field staff to meet the SBJA 

requirements, provided that SBA and other agencies clarify their roles 

and responsibilities and begin to exchange information on a regular basis.

SBA’s increased responsibilities in the realm of export promotion have 

thrust it into an already crowded field of federal agencies providing small 

businesses with assistance. The challenges SBA now faces in limiting the 

extent to which its export promotion efforts overlap with those of other 

agencies highlight the need for SBA and other key export promotion 

agencies to further their collaboration efforts. SBA and the other agencies 

have collaborated on export promotion activities to some extent by 

developing strategies, conducting joint outreach events, and sharing 

some client information among agencies, but many challenges to 

effective collaboration remain. In particular, some of SBA’s OIT and 

SBDC activities overlap with those of Ex-Im and Commerce, respectively. 

Conclusions
 

Page 31 GAO-13-217 Export Promotion

Without clear definition of each entity’s roles and responsibilities, the 

overlapping export financing products offered by SBA and Ex-Im and the 

labor-intensive export counseling sessions provided by SBDCs and 

Commerce may cause confusion for small businesses and could result in 

duplication of efforts and inefficient use of government resources. 

Additionally, SBA and other federal agencies do not regularly or 

comprehensively share client information, which is a significant 

impediment to achieving effective interagency collaboration in providing 

export promotion assistance to small businesses. While some entities’ 

staff told us that they are limited in their ability to share client information, 

additional information sharing, where possible, would help improve client 

services and help agencies better track their impact in promoting U.S. 

exports.

SBA has had mixed results in meeting SBJA requirements expanding its 

export promotion presence. On the positive side, SBA is well on its way to 

ensuring that a sufficient number of SBDC staff are better trained and 

prepared to assist small business exporters. On the negative side, 

however, SBA has fallen short of meeting the law’s specific requirements 

for increasing and placing OIT field staff, citing funding and hiring 

challenges. The most recent SBA report to Congress reiterates the 

agency’s intention to hire all the additional OIT staff required by the SBJA. 

However, SBA’s plan does not clearly identify the funding sources or time 

frames for hiring the additional staff, nor does it explain how it will address 

the hiring challenges it experienced previously. SBA needs to fill in those 

gaps in its OIT staffing plan, which presents an opportunity for the agency 

to step back and strategically reassess its plan and related resource 

allocation decisions in light of actions that could address the collaboration 

and information-sharing challenges identified in this report.

We are recommending that the Administrator of the Small Business 

Administration take the following three actions:

1. To help small businesses understand and get the most benefit from 

the various export assistance products and services provided by 

different federal entities, and to efficiently use government resources, 

consult with Commerce and Ex-Im and more clearly define roles and 

responsibilities of export promotion entities’ export counseling and 

financing staff agencywide and at the local levels.

2. To improve collaboration and leverage available resources, consult 

with Commerce and Ex-Im and identify ways to increase, where 

Recommendations for 

Executive Action
 

Page 32 GAO-13-217 Export Promotion

possible, sharing of client information deemed useful for SBA, 

Commerce, and Ex-Im.

3. To more effectively implement SBA’s expansion of OIT field staff as 

required by the SBJA, update SBA’s plan for additional OIT staff to 

include funding sources and time frames, as well as possible 

efficiencies from clearly defining roles and responsibilities and 

leveraging other entities’ export assistance resources.

We provided a draft of this report to SBA, Commerce, Ex-Im, USDA, 

USTDA, and State. In its written comments on the draft, which are 

reprinted in appendix II, SBA concurred with our recommendations and 

noted that SBA would work to implement the recommendations. We also

received comments from Commerce stating that Commerce generally 

agreed with our findings and noting developments that had occurred 

since we provided them our draft—including the subsequent issuance of 

the 2012 National Export Strategy. 

More specifically, in response to our recommendation on the need to 

clarify agency roles and responsibilities, SBA and Commerce provided us 

with a copy of the December 2012 Interagency Communiqué developed 

by TPCC agencies. The communiqué, which we included in appendix II, 

was intended to clarify roles and responsibilities and provide guidance on 

referring U.S. businesses seeking export assistance to federal, state, and 

nonfederal resources according to each firm’s export readiness and 

business needs. We mentioned the communiqué in our report and noted 

that it did not include referral protocols for clients requiring trade financing 

products, which the communiqué said would be issued by the end of 

January 2013. The communiqué also notes that agencies intend to 

develop local Export Outreach Teams, to increase awareness of local 

international trade expertise and enhance communication and 

collaboration at the local level. Among other things, the Export Outreach 

Teams would develop referral protocols and initiate ongoing discussions 

of shared clients. Thus, the communiqué’s plans, when fully implemented, 

would begin to address two findings in this report: the need to clarify roles 

and responsibilities among SBA, Commerce, and Ex-Im and the need to 

identify ways to increase sharing of client information deemed useful for 

SBA, Commerce, and Ex-Im. Regarding our recommendation to increase 

sharing of client information where possible, SBA acknowledged its 

continued work with other agencies to integrate knowledge management 

within current legislative restrictions on information sharing, and noted its 

optimism about the potential for information technology to facilitate 

Agency Comments 

and Our Evaluation
 

Page 33 GAO-13-217 Export Promotion

greater information sharing. SBA also noted that the SBDC program’s 

authorizing legislation prevents SBDCs from sharing specific client 

information outside of their network without prior written consent from the 

client, except under limited purposes. Furthermore, SBA agreed that it 

intends to respond to staffing requirements of the SBJA while 

acknowledging resource constraints in its next annual report to Congress. 

We also received comments from Ex-Im, USDA, and USTDA, clarifying 

information about their activities. We incorporated agencies’ technical 

comments throughout our report, as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to appropriate congressional 

committees; the Administrator of the SBA; the Secretaries of Commerce, 

Agriculture, and State; the Chairman and President of Ex-Im; and the 

Director of USTDA. In addition, the report will be available at no charge 

on the GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-4347 or yagerl@gao.gov. Contact points for our Office of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix III.

Loren Yager

Managing Director

International Affairs and Trade
Appendix I: Scope and Methodology

Page 34 GAO-13-217 Export Promotion

The objectives of this report were to (1) describe Small Business 

Administration’s (SBA) role within federal export promotion efforts; (2) 

assess the extent to which SBA collaborates with other agencies in its 

export promotion activities; and (3) assess the extent to which SBA is 

meeting Small Business Jobs Act (SBJA) requirements to expand export 

promotion training and staffing.

In our review, we defined “export promotion activities” as programs and 

services conducted by federal agencies that involve direct contact with 

U.S. exporters and have export promotion as their stated goal. Such 

activities include providing small businesses with export counseling, 

training, and financial assistance; they do not include activities such as 

advocacy, commercial diplomacy, and policy development and 

negotiations. Our review, therefore, covers six key agencies—SBA,1

Department of Commerce (Commerce), the U.S. Export-Import Bank 

(Ex-Im), the Department of Agriculture (USDA), the U.S. Trade and 

Development Agency (USTDA), and the Department of State (State)—

with a particular emphasis on SBA’s activities.2

To address all of our objectives, we interviewed agency officials 

representing the key export promotion entities in headquarters and in six 

selected field locations—Chicago, Dallas, Irvine (California), Miami, New 

York, and Portland (Oregon). We selected these locations because they 

We reported data from the 

Trade Promotion Coordinating Committee (TPCC) Secretariat on 

agencies’ requested budget authority for export promotion activities for 

fiscal year 2012, which was the most recent data available. We also 

analyzed TPCC data on SBA’s budget authority for export promotion 

activities for fiscal years 2006 through 2012. We determined that the data 

were sufficiently reliable for our purpose of illustrating SBA’s relative 

share of the overall federal export promotion budget.

 

1

We include SBA export promotion activities that may directly or indirectly support exports 

by small businesses, including the export promotion activities of the Small Business 

Development Centers. We did not include SBA’s Women’s Business Centers and Service 

Corps of Retired Executives because those entities generally have a limited role in export 

promotion. 

2

The scope of our work does not cover the Overseas Private Investment Corporation 

(OPIC) because export promotion is not its primary stated goal. OPIC is a development 

finance institution providing investors with financing, guarantees, political risk insurance, 

and support for private equity investment funds. OPIC officials informed us that OPIC’s 

work may result in U.S. exports, but the agency does not conduct its work to seek U.S. 

export opportunities.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 35 GAO-13-217 Export Promotion

had at least two export promotion entities’ staff colocated, had the 

presence of Small Business Development Centers (SBDC) with staff 

providing export assistance, and ranked among locations with the highest 

export potential according to Commerce data. At some of these selected 

locations, we also met with representatives of small businesses that 

utilized federal government export assistance. The results of our 

interviews with officials at these six locations are not generalizable to 

agency officials’ views at all U.S. locations.

To describe SBA’s export promotion activities within federal export 

promotion efforts, we analyzed government-wide initiatives, strategies, 

and TPCC’s and agencies’ documents and data. Our description of SBA 

and other agency activities is intended to be illustrative of the types of 

activities agencies engage in to support small business exports and is not 

exhaustive of all activities undertaken by each of the agencies.

To assess the extent to which SBA collaborates with other agencies in its 

export promotion activities, we focused our assessment on coordination 

between SBA entities with Commerce and Ex-Im, the key agencies that 

provide similar export promotion activities to similar clients and that work 

together at the headquarters and field level, including at five of the 

selected field locations that feature all three agencies colocated in the 

same city. We analyzed government-wide initiatives, strategies, as well 

as TPCC’s and agencies’ documents, including the National Export 

Initiative and National Export Strategy. Additionally, we compared export 

promotion activities of Commerce and Ex-Im that are similar to SBA’s 

activities, based on our analysis of information provided agency officials.

We also used the results of our discussions with agencies’ headquarters 

and field staff in six selected locations to assess the level of interagency 

collaboration. We assessed interagency coordination primarily against 

selected practices for enhancing and sustaining collaboration we 

previously identified.3

 

3

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, 

We selected four elements of collaboration best 

practices—establishing mutually reinforcing or joint strategies, reinforcing 

individual accountability for collaboration efforts, agreeing on roles and 

responsibilities, and leveraging resources to identify and address needs—

because they allowed us to highlight the most critical and relevant 

elements of collaboration among export agencies at both the 

GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
Appendix I: Scope and Methodology

Page 36 GAO-13-217 Export Promotion

headquarters and field level. These elements also relate to issues 

identified in the 2011 National Export Strategy—for example the need for 

each SBA, Commerce, and Ex-Im to target clients and focus their 

strengths to achieve the common NEI goal to double U.S. exports.

To assess the extent to which SBA is meeting SBJA requirements to 

expand export promotion training and staffing, we analyzed the SBJA and 

identified the specific export promotion requirements applicable to 

increasing the level of training of SBDC staff and increasing OIT staff 

numbers. We did not examine the other requirements under the SBJA.

We analyzed SBA and SBDC documents and interviewed agency officials 

in headquarters and field locations to determine the implementation 

status of the SBJA requirements. We determined the extent to which 

SBDCs have met the certification requirement through an exam with the 

assistance of available training, but we did not assess the content or 

effectiveness of the certification, exam, or training. Furthermore, we 

reviewed SBA OIT’s September 2012 report to Congress which, 

according to SBA, contained the most current implementation status and 

plans for the SBJA requirements.

We conducted this performance audit from February 2012 to January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Comments from the Small 

Business Administration

Page 37 GAO-13-217 Export Promotion

Appendix II: Comments from the Small 

Business Administration 
Appendix II: Comments from the Small 

Business Administration

Page 38 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 39 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 40 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 41 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 42 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 43 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 44 GAO-13-217 Export Promotion
Appendix II: Comments from the Small 

Business Administration

Page 45 GAO-13-217 Export Promotion
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 46 GAO-13-217 Export Promotion

Loren Yager, (202) 512-4347, or yagerl@gao.gov

In addition to the individual named above, Adam Cowles, Assistant 

Director; Lina Khan; Victoria Lin; and Kara Marshall made key 

contributions to this report. The team benefited from the expert advice 

and assistance of David Dayton, David Dornisch, and Grace Lui.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(320885)
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