Export Promotion: Small Business Administration Needs to Improve Collaboration to Implement Its Expanded Role
Published: 2013-01-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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. Through the  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. 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.
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.
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  activities. 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.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   We selected four collaboration  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.
subsections: section_title: Background
subsections: section_title: Federal Interagency Entities Involved in Export Promotion
paragraphs: 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. 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. As a result, the TPCC’s National  Export Strategy, which articulates U.S. plans to increase exports, is  generally issued annually. 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. 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  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, Ex- Im, 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). These “one-stop shops” were to provide coordinated export  training, trade leads, export finance, and counseling to U.S. businesses  interested in becoming exporters.
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.
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  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.
section_title: SBA Entities Involved in Export Promotion
paragraphs: 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 nonexport- related activities. 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  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.
section_title: SBA Provides Export Promotion Assistance to Small Businesses within a Complex, Multiagency Environment
paragraphs: 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
Counseling and Training: Prepare small businesses to export
Trade Leads: Connect small businesses to export opportunities
Financing: Support small businesses once they have export  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.
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  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.
subsections: section_title: Counseling and Training
paragraphs: 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.SBDCs offer counseling to businesses of all types.
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. 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.
GAO, 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). 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.
section_title: Trade Leads
paragraphs: 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.
section_title: Financing
paragraphs: 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.
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.
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.
section_title: SBA Has Taken Steps to Collaborate with Other Agencies, but Further Collaboration Efforts Are Needed
paragraphs: 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.
subsections: section_title: Overlapping Export Assistance from SBA and Other Agencies Can Be Confusing for Small Businesses and May Lead to Inefficient Use of Resources
paragraphs: 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  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.
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.
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. By addressing such  inefficiencies, agencies could more effectively target government  resources toward accomplishing the NEI goal.
section_title: SBA and Other Agencies Follow Some Best Practices in Collaboration but Could Take Further Actions to Reduce Overlap
paragraphs: 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.  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.
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. 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 OIT- 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.
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  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.
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-to- market businesses and send new-to-export businesses to SBDCs, the  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. 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.
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.
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  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.
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, Ex- Im, 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 Ex- Im may conduct joint seminars, where Commerce staff could discuss  marketing and sales, while SBA and Ex-Im staff discuss financing. In  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. 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, 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.
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  export successes, thereby helping Commerce track their impact in  helping increase small business exports.
section_title: SBA Has Made Some Progress in Increasing Export Training but Experienced Challenges in Meeting Staffing Requirements under the Small Business Jobs Act of 2010
paragraphs: 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. 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.
subsections: section_title: Small Business Jobs Act of 2010 Expanded SBA Training and Staffing Requirements for Export Promotion Activities
paragraphs: 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. In  supporting NEI goals, the law also increased SBA’s staff to provide  additional export counseling resources to promote small business  exporting.
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, SBJA required that five staff or 10 percent of staff, whichever is  less, obtain certification in providing export assistance. SBA provides  that certification can be obtained through an exam or a specific  professional certification program  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,   The law required that there should be  which was 22, according to SBA. 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. 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.
section_title: SBA Has Made Progress in Certifying Small Business Development Center Staff to Increase Expertise in Export Counseling
paragraphs: 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  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.
The 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. 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.
section_title: SBA’s Efforts to Add OIT Field Staff Have Fallen Short of Requirements, and Its Staffing Plan Lacks Key Information
paragraphs: 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. 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.
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 full- year 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.
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.
section_title: Conclusions
paragraphs: 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.
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.
section_title: Recommendations for Executive Action
paragraphs: 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  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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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  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.
section_title: Appendix I: Scope and Methodology
paragraphs: 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,  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. 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.
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  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. 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  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.
section_title: Appendix II: Comments from the Small Business Administration
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.