Women-Owned Small Business Program: Certifier Oversight and Additional Eligibility Controls Are Needed
Published: 2014-10-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2000, Congress authorized the WOSB program to increase contracting opportunities for WOSBs by allowing contracting officers to set aside procurements to such businesses. SBA, which administers the program, issued implementing regulations that became effective in 2011. GAO was asked to review the WOSB program. This report examines (1) how businesses are certified as eligible for the WOSB program, (2) SBA's oversight of certifications, and (3) the effect the program has had on federal contracting opportunities available to WOSBs or EDWOSBs. GAO reviewed relevant laws, regulations, and program documents; analyzed federal contracting data from April 2011 through May 2014; and interviewed SBA, officials from contracting agencies selected to obtain a range of experience with the WOSB program, third-party certifiers, WOSBs, and organizations that represent their interests.
section_title: What GAO Found
paragraphs: Businesses have two options to certify their eligibility for the women-owned small business (WOSB) program. Whether self-certifying at no cost or using the fee-based services of an approved third-party certifier, businesses must attest that they are a WOSB or an economically disadvantaged WOSB (EDWOSB). Businesses also must submit documents supporting their attestation to a repository the Small Business Administration (SBA) maintains (required documents vary depending on certification type), and, if they obtain a third-party certification, to the certifier.
SBA performs minimal oversight of third-party certifiers and has yet to develop procedures that provide reasonable assurance that only eligible businesses obtain WOSB set-aside contracts. For example,
SBA generally has not reviewed certifier performance or developed or implemented procedures for such reviews, including determining whether certifiers inform businesses of the no-cost self-certification option, a requirement in the agency's agreement with certifiers.
SBA also has not completed or implemented procedures to review the monthly reports that third-party certifiers must submit.
Without ongoing monitoring and oversight of the activities and performance of third-party certifiers, SBA cannot reasonably assure that certifiers fulfill the requirements of the agreement. Moreover, in 2012 and 2013, SBA found that more than 40 percent of businesses (that previously received contracts) it examined for program eligibility should not have attested they were WOSBs or EDWOSBs at the time of SBA's review. SBA officials speculated about possible reasons for the results, including businesses not providing adequate documentation or becoming ineligible after contracts were awarded, but SBA has not assessed the results of the examinations to determine the actual reasons for the high numbers of businesses found ineligible. SBA also has not completed or implemented procedures to conduct eligibility examinations. According to federal standards for internal control, agencies should have documented procedures, conduct monitoring, and ensure that any review findings and deficiencies are resolved promptly. As a result of inadequate monitoring and controls, potentially ineligible businesses may continue to incorrectly certify themselves as WOSBs, increasing the risk that they may receive contracts for which they are not eligible.
The WOSB program has had a limited effect on federal contracting opportunities available to WOSBs. Set-aside contracts under the program represent less than 1 percent of all federal contract obligations to women-owned small businesses. The Departments of Defense and Homeland Security and the General Services Administration collectively accounted for the majority of the $228.9 million in set-aside obligations awarded under the program between April 2011 and May 2014. Contracting officers, business owners, and industry advocates with whom GAO spoke identified challenges to program use and suggested potential changes that might increase program use, including allowing sole-source contracts rather than requiring at least two businesses to compete and expanding the list of 330 industries in which WOSBs and EDWOSBs were eligible for a set-aside.
section_title: What GAO Recommends
paragraphs: GAO recommends that SBA, among other things, establish and implement procedures to monitor certifiers and improve annual eligibility examinations, including by analyzing examination results. SBA generally agreed with GAO's recommendations.

section_title: Letter
paragraphs: Women-owned businesses contribute significantly to the U.S. economy.  According to the most recent Census Survey of Business Owners, 28.7  percent, or 7.8 million, of all U.S. businesses in 2007 were women- owned. Between 1997 and 2007, the number of women-owned  businesses grew by 44 percent (or twice as fast as businesses owned by  men) adding roughly 500,000 jobs nationwide, according to the U.S.  Department of Commerce. However, the federal government has yet to  meet its annual goal of awarding 5 percent of its procurement to women- owned small businesses (WOSB).
Over the years, Congress has taken a number of actions to increase  opportunities for small business (including minority-owned and  economically disadvantaged) participation in federal contracting. In 1978,  Congress amended the Small Business Act to require federal agencies to  negotiate with the Small Business Administration (SBA) to establish prime  and subcontracting goals for certain businesses, which did not specifically  include WOSBs until 1994. In 2000, Congress authorized a contracting  program to reserve contracts for WOSBs in industries where the  businesses were historically underrepresented. Its purpose is to enable  federal contracting officers to identify and establish a sheltered market, or  set-aside, for competition among only WOSBs or economically  disadvantaged WOSBs (EDWOSB) to provide goods and services  through contracts in designated industries. On October 7, 2010, SBA  issued a final rule to implement the WOSB Federal Contract Program and  the program started operating in 2011. To establish WOSB program set- asides, SBA conducted studies to identify industries in which WOSBs  were underrepresented and substantially underrepresented and  published a list of specific industries in which these businesses needed  greater access to federal contracts. EDWOSBs may receive contracts in  any industry SBA identified as eligible for the program, and WOSBs may  receive contracts in industries in which SBA deemed WOSBs to be  substantially underrepresented. According to SBA officials, program staff  have been planning a new study of underrepresented EDWOSBs and  substantially underrepresented WOSBs, which the agency expects to  complete by 2015.
You asked us to examine the WOSB program, including any effects it has  had on increasing contracting opportunities for WOSBs. This report (1)  describes how WOSBs and EDWOSBs are certified as eligible for the  program; (2) examines the extent to which SBA has implemented internal  control and oversight procedures of WOSB program certifications; and (3)  discusses the effect the program has had on federal contracting  opportunities available to WOSBs or EDWOSBs.
To describe how businesses are certified as eligible for the WOSB  program, we reviewed SBA’s policies and procedures to establish  program eligibility, including the responsibilities of businesses, third-party  certifiers, contracting officers, and SBA. To evaluate how certification  procedures may affect program participation, we obtained data from SBA  and the Federal Procurement Data System-Next Generation (FPDS-NG)  to determine the number of WOSBs that used third-party certifiers from  August 2011 through May 2014. Using electronic edit checks and a  review of data system documentation, we deemed these data sufficiently  reliable for this purpose. We interviewed SBA officials, contracting  officials at the Departments of Defense (DOD) and Homeland Security  (DHS), and the General Services Administration (GSA); and interviewed  selected WOSBs for perspectives on the program. The agencies were  selected to reflect varying levels of program participation (based on  contracts issued and program obligations from 2011 through 2013). To  evaluate SBA’s internal controls and oversight of certification methods,  we reviewed the program regulation and program documents,  agreements with third-party certifiers, and monthly reports submitted by  third-party certifiers to SBA, among other documents. We interviewed  three of the four certifiers: El Paso Hispanic Chamber of Commerce, the  National Women Business Owners Corporation, and the U.S. Women’s  Chamber of Commerce. We were not able to interview the fourth certifier,  the Women’s Business Enterprise National Council (WBENC). To  evaluate the effect the program has had on federal contracting  opportunities for WOSBs, we analyzed FPDS-NG data from April 2011  through May 2014 and identified trends in program participation by  agencies. Finally, we interviewed SBA officials and contracting agency  officials about the extent to which the program has met its regulatory  purpose of increasing contracting opportunities for WOSBs. We deemed  the FPDS-NG data sufficiently reliable for our purposes. Appendix I  contains additional information on our scope and methodology.
We conducted this performance audit from August 2013 to October 2014  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
paragraphs: Federal agencies conduct a variety of procurements that are reserved for  small business participation (through small business set-aside and sole- source opportunities, hereafter called set-asides). The set-asides can be  for small businesses in general or be specific to small businesses  meeting additional eligibility requirements in the Service-Disabled  Veteran-Owned Small Business Concern (SDVOSBC), Historically  Underutilized Business Zone (HUBZone), 8(a) Business Development,  and WOSB programs.
The WOSB program, which started operating in 2011, has requirements  that pertain to the sectors in which set-asides can be offered as well as  eligibility requirements for businesses. That is, set-aside contracts under  the WOSB program can only be made in certain industries in which  WOSBs were substantially underrepresented and EDWOSBs  underrepresented, according to the program regulation. Additionally, only  certain businesses are eligible to participate in the WOSB program. The  business must be at least 51 percent owned and controlled by one or  more women. The owner must provide documents demonstrating that the  business meets program requirements, including submitting a document  in which the owner attests to the business’s status as a WOSB or  EDWOSB.
The program’s authorizing statute directs that each business either be  certified by a third party, or self-certified by the business owner. SBA’s  final rule includes these two methods. Self-certification is free and  businesses pay a fee for third-party certification.
A third-party certifier is a federal agency, state government, or national  certifying entity approved by SBA to provide certifications of WOSBs or  EDWOSBs. To be approved as certifiers, interested organizations submit  an application to SBA that contains information on the organization’s  structure and staff, policies and procedures for certification, and  attestations that they will adhere to program requirements. SBA has  approved four organizations to act as third-party certifiers:
El Paso Hispanic Chamber of Commerce;
National Women Business Owners Corporation;
U.S. Women’s Chamber of Commerce; and
Women’s Business Enterprise National Council.
The most active certifier is the Women’s Business Enterprise National  Council (WBENC), which completed about 76 percent of all WOSB third- party certifications performed from August 2011 through May 2014. To  conduct the certifications, WBENC uses 14 regional partner  organizations.
The fees for certification vary depending on a WOSB’s gross annual  sales, membership status in the certifying organization, and geographic  location (see table 1). In the case of businesses that seek a WOSB  program certification through WBENC’s partner organizations, businesses  that pay for a Women’s Business Enterprise certification (used for private- sector or some local, state, and federal procurement, but not for the  WOSB program) can receive WOSB program certifications at no  additional cost. We discuss the WOSB certification process in greater  detail later in this report.
SBA’s Office of Government Contracting administers the WOSB program  by publishing regulations for the program, conducting eligibility  examinations of businesses that received contracts under the WOSB or  EDWOSB set-aside, deciding protests related to eligibility for a WOSB  program contract award, conducting studies to determine eligible  industries, and working with other federal agencies in assisting WOSBs  and EDWOSBs. According to SBA officials, the agency also works at the  regional and local levels with its Small Business Development Centers,  district offices, and other organizations (such as Procurement Technical  Assistance Centers) to assist WOSBs and EDWOSBs to receive  contracts with federal agencies. The services SBA coordinates with these  offices and organizations include training, counseling, mentoring, access  to information about federal contracting opportunities, and business  financing.
section_title: Businesses Can Use Two Methods to Certify Eligibility for WOSB Program
paragraphs: According to the program regulation, businesses may use self- or third- party certification to demonstrate they are eligible for WOSB or EDWOSB  status. Both certification processes require signed representations by  businesses about their WOSB or EDWOSB eligibility. For this reason,  SBA has described all participants in the program as self-certified. When  using the self-certification option, businesses must provide documents  supporting their status to the online document repository for the WOSB  program that SBA maintains. Required submissions include copies of  citizenship papers (birth or naturalization certificates or passports) and,  depending on business type, items including copies of partnership  agreements or articles of incorporation. Businesses must submit a signed  certification on which the owners attest that the documents and  information provided are true and accurate. Moreover, businesses must  register and attest to being a WOSB in the System for Award  Management (SAM), the primary database of vendors doing business  with the federal government. Businesses also must make  representations about their status in SAM before submitting an offer on a  WOSB or EDWOSB solicitation.
For third-party certification, businesses submit documentation to  approved certifiers. According to third-party certifiers we interviewed, they  review documents (and some may conduct site visits to businesses) and  make determinations of eligibility. If approved, businesses will receive a  document showing receipt of third-party certification. Business then can  upload the certificate to the WOSB program repository along with  documents supporting their EDWOSB or WOSB status. SBA does not  track the number of businesses that self certify and could not provide  information on how many self-certified businesses obtained contracts  under the WOSB program. While SBA can look at an individual business  profile—which lists the documents the business has uploaded to support  its eligibility—in the repository to determine if a certificate from a third- party certifier is present, it has no corresponding mechanism to determine  if a business lacking such a certificate was self-certified. That is, there  are no data fields for certification type in any of the systems used in the  program and SBA cannot generate reports to isolate information on  certification type by business. According to SBA officials, such information  on certification type is not needed because both certification options are  treated equally under the program and, because all businesses make an  attestation of status as a WOSB whether or not the business uses a third- party certifier. Therefore, SBA considers this a self-certification program.
Contracting officers obtain a solicitation and conduct market research to  identify businesses potentially capable of filling contract requirements.  Once a contracting officer has determined that a solicitation can be set  aside under the WOSB program, the officer obtains bids and selects an  awardee for the contract. Only after selecting an awardee, does the  agency obtain access to the business’s profile in the WOSB program  repository, which lists the documents the business has uploaded to  support its eligibility (the business must grant the contracting agency  access). SBA’s Contracting Officer’s Guide to the WOSB Program states  that contracting officers must determine that specified documents have  been uploaded by the business to the program repository, but the guide  does not require contracting officers to assess the validity of those  documents. Only after viewing the uploaded documents would the  contracting officer be able to determine if the business was likely self- certified or had a certificate from a third-party certifier. Two groups we  interviewed that represent the interests of WOSBs said that contracting  officers prefer third-party over self-certified businesses when selecting an  awardee. A representative of one organization thought that contracting  officers tended to select businesses with third-party certifications because  they did not have to review as many documents in the program repository  as for self-certified businesses. However, the certification method does  not appear to influence contract awards. According to officials from all  contracting agencies with whom we spoke and SBA officials, contracting  staff are unaware of the certification method used by a business until after  an awardee is selected.
section_title: SBA’s Oversight of Certifiers Has Been Minimal and Does Not Provide Reasonable Assurance That Only Eligible Businesses Obtain Set-Aside Contracts
paragraphs: SBA generally has not overseen third-party certifiers and lacks  reasonable assurance that only eligible businesses receive WOSB set- aside contracts. SBA has not put in place formal policies to review the  performance of third-party certifiers, including their compliance with a  requirement to inform businesses of the no-cost, self-certification option.  The agency has not developed formal policies and procedures for  reviewing required monthly reports submitted to SBA by certifiers or  standardized reporting formats for the certifiers, or addressed most issues  raised in the reports. Although SBA examinations have found high rates  of ineligibility among a sample of businesses that previously received set- aside contracts, SBA has not determined the causes of ineligibility or  made changes to its oversight of certifications to better ensure that only  eligible businesses participate in the program.
subsections: section_title: SBA Generally Has Not Reviewed Certifier Performance
paragraphs: To date, SBA generally has not conducted performance reviews of third- party certifiers and does not have procedures in place for such reviews.  According to federal standards for internal control, agencies should  conduct control activities such as performance reviews and clearly  document internal controls. Third-party certifiers agree to be subject to  performance reviews by SBA at any time to ensure that they meet the  requirements of the agreement with SBA and program certification  regulations—including requirements related to the certification process,  obtaining supporting documents, informing businesses about the no-cost  option for WOSB program certification, and reporting to SBA on certifier  activities.
Before beginning the certification process, SBA requires third-party  certifiers to inform businesses in writing (on an SBA-developed form) that  they can self certify under the program at no cost. Certifiers, a WOSB  advocacy group, and WOSBs had perspectives on fees for third-party  certification. Representatives of all three certifiers with whom we spoke  stated that fees their organization charged for certifications were  reasonable and affordable for a small business. Staff from one WOSB  advocacy organization told us that such fees could deter some  businesses from participating in the program, but owners of WOSBs with  which we spoke generally did not concur with this view. Certifiers with  whom we spoke told us that they inform businesses about their option to  self certify, but SBA does not have a method in place to help ensure that  certifiers are providing this information to businesses and agency officials  told us that they do not monitor whether certifiers fulfilled the requirement.  SBA officials said that they believe that the no-cost option ameliorates the  risk of excessive fees charged to businesses or the risk that fees would  deter program participation and that because all certifiers must provide  national coverage, businesses can seek lower fees. Officials also told us  that they believed that businesses and advocacy groups would inform the  agency if certifiers were not providing this information. However, they  were not able to describe how SBA would learn from businesses that  certifiers had failed to provide this information. The requirement is part of  SBA’s agreement with third-party certifiers, but SBA has not described  the requirement on the program web-site or made it part of informational  materials to businesses. Thus, businesses may not know of this  requirement without being informed by the certifier or know to inform SBA  if the certifier had not fulfilled the requirement.
The largest certifier, WBENC, has delegated the majority of certification  activity to other entities that SBA also has not reviewed. WBENC has  conducted about 76 percent of third-party certifications through May  2014. However, WBENC delegates WOSB certification responsibilities to  14 regional partner organizations. SBA neither maintains nor reviews  information about standards and procedures at WBENC, including a  compliance review process for each of its 14 partner organizations that  WBENC told SBA it uses. SBA officials told us that they rely on  information available on public websites to determine the fee structures  set by WBENC’s partner organizations. SBA also does not have copies of  compliance reviews that WBENC told SBA it annually conducts for each  partner organization. SBA requested documents from WBENC, which  included information about WBENC’s oversight of its 14 partner  organizations. WBENC’s response was incomplete; WBENC referenced  but did not provide its standards and procedures to oversee partner  organizations. SBA told us it recognized that WBENC’s response was  incomplete, and indicated it had not followed up on WBENC’s response.  Without this information SBA cannot determine how WBENC has been  overseeing the 14 entities to which it has delegated certification  responsibilities.
Although SBA has not developed or conducted formal performance  reviews of certifiers, officials described activities they consider to be  certifier oversight. For example, when a business is denied third-party  certification but wishes to self-certify, it must subject itself to an eligibility  examination by SBA before doing so. In this case, or during a bid protest,  SBA conducts its own review of documentation the business submitted to  the certifier. SBA officials stated that these reviews were not intended as  a form of certifier oversight but described them as de facto reviews of  third-party certifier performance. However, such reviews do not involve a  comprehensive assessment of certifiers’ activity or performance over  time. An SBA official acknowledged that the agency could do more to  oversee certifiers. SBA plans to develop written procedures for certifier  oversight to be included in the standard operating procedure (SOP) for  the program, which remains under development. But SBA has not yet  estimated when it would complete written procedures for certifier  oversight or the SOP.
Without ongoing monitoring and oversight of the activities and  performance of third-party certifiers, SBA cannot reasonably ensure that  certifiers have fulfilled the performance requirements of their agreement  with SBA—including informing businesses about no-cost certification.
section_title: SBA Lacks Procedures for Reviewing Certifiers’ Reports and Has Not Followed Up on Issues Reports Raised
paragraphs: SBA has not yet developed written procedures to review required monthly  reports from certifiers and does not have a consistent format for reports.  In SBA’s agreement with third-party certifiers, the agency requires each  certifier to submit monthly reports that must include  the number of WOSB and EDWOSB applications received, approved,  and denied;  identifying information for each certified business, such as the  business name;  concerns about fraud, waste, and abuse; and a description of any changes to the procedures the organizations  used to certify businesses as WOSBs and EDWOSBs.
Internal control should include documented procedures and monitoring or  review activities that help ensure that review findings and deficiencies are  brought to the attention of management and resolved promptly.
Based on our review of each monthly report submitted from August 2011  through May 2014 (135 in total), not all reports contained consistent  information. Some monthly reports were missing the owner names and  contact information for businesses that had applied for certification. One  certifier regularly identified potential fraud among businesses to which it  had denied certification, about one or two per month for 16 of the 34  reporting months included in our review. This certifier provided detailed  narrative information in its reports to SBA about its concerns. The  reporting format and level of detail reported also varied among certifiers.  One certifier listed detailed information on its activities in a spreadsheet.  Another described its activities using narrative text and an attached list of  applicants for certification. One certifier included dates for certification,  recertification, and the expiration of a certification, while other certifiers  did not include this information.
According to SBA officials, the agency did not have consistent procedures  for reviewing monthly reports, including procedures to identify and resolve  discrepancies in reports or oversee how certifiers collect and compile  information transmitted to the agency. SBA officials said that one official,  who recently retired, was responsible for reviewing all certifier monthly  reports. Current officials and staff were not able to tell us what process  this official used to assess the reports.
Finally, with one person responsible for reviewing monthly reports until  recently, SBA generally has not followed up on issues raised in reports.  Agency officials told us that early in the program they found problems with  the monthly report of one of the certifiers that indicated that the certifier  did not understand program requirements and they contacted the certifier  to address the issue. We found additional issues that would appear to  warrant follow up from SBA. For example, two businesses were denied  certification by one third-party certifier and approved shortly after by  another. SBA stated that it had not identified these potential  discrepancies but that it was possible for businesses to be deemed  ineligible, resolve the issue preventing certification, and become eligible  soon after. However, according to the program regulation, if a business  was denied third-party certification and the owner believed the business  eligible, the owner would have to request that SBA conduct an  examination to verify its eligibility to represent the business as a WOSB.  According to SBA officials, the agency was unaware of this business or its  certification. And, as discussed previously, one certifier regularly identified  potential fraud among businesses to which it had denied certification.  SBA officials told us that they had not identified or investigated this  certifier’s concerns about potential fraud. When we asked SBA officials  how the agency addressed such concerns, an official responded that  fraudulently entering into a set-aside contract was illegal and the business  would be subject to prosecution. However, without SBA following up on  these types of issues, it is unclear how businesses committing fraud in  the program would be prosecuted.
According to an SBA official, the agency has been developing written  procedures to review the monthly reports, but has not yet estimated when  the procedures would be completed. The procedures will be included in  SBA’s SOP for the program, which also remains under development. As  noted earlier, SBA could not estimate when it would complete the SOP.  Without procedures in place to consistently review monthly reports and  respond to problems identified in those reports, SBA lacks information  about the activities and performance of third-party certifiers and leaves  concerns raised by certifiers unaddressed.
section_title: SBA Found High Rates of Ineligibility among Businesses but Has Not Developed Controls to Help Ensure Only Eligible Businesses Receive Awards
subsections: section_title: Methods to Assess the Eligibility of Set-Aside Contract Recipients
paragraphs: SBA’s methods to verify the eligibility of businesses in its WOSB program  repository include annual examinations of businesses that received set- aside contracts. SBA’s program responsibilities include conducting  eligibility examinations of WOSBs and EDWOSBs, according to SBA’s  compliance guide for the WOSB program and its regulation. Section 8(m)  of the Small Business Act sets forth eligibility criteria businesses must  meet to receive a contract under the WOSB program set-aside. SBA  examines a sample of businesses with a current attestation in SAM and  that received a contract during SBA’s examination year. SBA does not  include in its sample businesses that had not yet obtained a WOSB  program contract. According to SBA officials, staff conducting the  eligibility examination review the documents each business owner  uploaded to the WOSB program repository to support the representation  in SAM of eligibility for WOSB or EDWOSB status. For example, agency  officials said that reviewers ensure that all documents required have been  uploaded and review the contents of the documents to ensure that a  business is eligible. SBA said staff conducting the examination then  determine that the business has met the requirements to document its  status as a WOSB, or determine that information is missing or not  consistent with the program requirements and the business is not eligible  at the time of SBA’s review to certify itself as a WOSB. SBA officials said  the agency also uses the same process to investigate the eligibility of  businesses on an ad hoc basis in response to referrals from contracting  agencies or other parties, such as other businesses, that question the  eligibility of a business.
If a business has not sufficiently documented its eligibility representation,  SBA sends a letter directing the business to enter required information or  documents into the repository or remove its attestation of program  eligibility in SAM within 15 days. If SBA receives no response after 15  days, it sends a second letter instructing the business to remove its  WOSB attestation in SAM within 5 days. In 2012 and 2013, SBA sent final  5-day letters to 44 businesses identified through annual examinations or  examinations following a referral. If the business does not do so, it may  be subject to enforcement actions including suspension or debarment  from federal contracting or criminal penalties, according to SBA officials.  An SBA official said that the agency is unaware of any such enforcement  actions as part of the WOSB program.
SBA also decides protests from contracting agency staff or any other  interested parties relating to a business’s eligibility. SBA considers  protests if there is sufficient, credible evidence to show that the business  may not be at least 51 percent owned and controlled by one or more  women, or if the business has failed to provide documents required to  establish eligibility for the program. Once SBA has obtained a protest, it  examines documents submitted in the case, makes a determination of  program eligibility based on the content of these documents and notifies  relevant parties—typically, the contracting officer, protester (if not the  same), and the business—of the determination. If eligible for the set- aside, the contracting officer may make an award to the business.  Otherwise, the contracting officer may not award a contract to the  business in question. From program implementation in April 2011 through  July 2, 2014, SBA responded to 27 protests, and in 7 protests the  businesses involved were found to be ineligible for the WOSB program. In  the remaining protests, the businesses were found eligible, the party that  filed the protest withdrew it, or SBA dismissed the protest.
As described earlier in the report, contracting officers check for the  presence of documents in the repository when making a WOSB program  award. This could be considered part of SBA’s framework to oversee  certifications, but the requirement for contracting officers to review  documents is limited to ensuring that businesses have uploaded  documents listed in the regulation. Representatives from some of the  contracting offices we interviewed believed that they had to assess the  validity of the documents or did not think they had the necessary  qualifications to assess the documents. However, program guidance does  not require contracting officers to assess the validity of these documents,  and SBA officials told us contracting officers are not expected to evaluate  the eligibility of businesses.
section_title: SBA’s Approach to Eligibility Verification and Enforcement Has Weaknesses
paragraphs: SBA activities relating to eligibility verifications, particularly examinations,  have several weaknesses. For instance, SBA has not yet developed procedures to conduct annual eligibility  examinations although such efforts are in process, according to  officials; has not evaluated the results of the eligibility examinations in the  context of how the actions of businesses, contracting agencies, and  third-party certifiers may have contributed to the high levels of  incomplete and inaccurate documentations found in examinations;  and has not assessed its internal controls or made procedural changes in  response to the findings of its eligibility examinations.
According to federal standards for internal control, agencies should have  documented procedures, conduct monitoring, and ensure that any review  findings and deficiencies are brought to the attention of management and  are resolved promptly. Corrective action is to be taken or improvements  made within established time frames to resolve the matters brought to  management’s attention. Also, management needs to comprehensively  identify risks the agency faces from both internal and external sources,  and management should consider all significant interactions between the  agency and all other parties.
SBA conducted annual eligibility examinations in 2012 and 2013 on a  sample of businesses that received contracts under the WOSB program  and found that 42 percent of businesses in the 2012 sample were  ineligible for WOSB program contract awards on the date of its review,  and 43 percent in the 2013 sample were ineligible. According to SBA  officials, both self- and third-party certified businesses were found  ineligible at the time of review. SBA staff reviewed the documents that  each business in its sample had posted to the program repository to  ensure the businesses had sufficiently supported their attestations as  required in program regulations. However, SBA could not provide  documentation of a consistent procedure to examine each business. SBA  staff reviewing documentation in the repository did not have guidelines  describing how to conduct each review. SBA officials told us that they  have been developing written procedures to conduct annual eligibility  examinations, estimated a completion date that the agency did not meet,  and that the agency does not have an estimation of completion.
SBA officials explained that they determined the eligibility of businesses  on a given date after the business received a contract. According to SBA  officials, a finding of ineligibility does not mean the business was ineligible  at the time of contract award because the status of the business might  have changed. Although SBA officials did not know whether businesses  examined were eligible at the time of award, the high rate of ineligibility it  found raises questions about whether contracts may have been awarded  to ineligible businesses. According to SBA officials, information in its  repository constantly changes and SBA has yet to determine how or if a  business was eligible when it received a WOSB set-aside contract. SBA  officials told us that they believe they may be able to make such a  determination but could not describe exactly how they would conduct the  review or confirm that the business was an eligible WOSB or EDWOSB at  the time of award. As part of its annual examination, SBA only examines  businesses at some time after the business received a contract and,  therefore, SBA’s examination is limited in its ability to identify potentially  ineligible businesses prior to a contract award.
SBA officials said that after the annual examinations they did not institute  new controls to guard against ineligible businesses receiving program  contracts because they described the examinations and the results as a  method to gain insight about the program—specifically, that WOSBs may  lack understanding of program eligibility requirements—and not a basis  for change in oversight procedures. According to SBA officials, the levels  of ineligibility found during the examinations were similar to those found in  examinations of its other socioeconomic programs. SBA officials said  businesses were deemed ineligible because they did not understand the  documentation requirements for establishing eligibility and also attributed  the ineligibility of third-party certified businesses to improper uploading of  documents by the businesses themselves. SBA officials said they needed  to make additional efforts to train businesses to properly document their  eligibility. However, SBA officials could not explain how they had  determined lack of understanding was the cause of ineligibility among  businesses and have not made efforts to confirm that this was the cause.  As a result, they have missed opportunities to obtain meaningful insights  into the program.
SBA regarded the bid protest as means of identifying ineligibility. SBA  officials referred to the program as a self-policing program, because of  the bid protest function through which competing businesses, contracting  officers, or SBA can protest a business’s claim to be a WOSB or  EDWOSB and eligible for contract awards under the program. In addition,  an SBA official stated that business owners affirm their status when  awarded a contract and are subject to prosecution if they had done so  and later were found to have been ineligible at the time of contract  award—which the official considered a program safeguard.
However, without (1) developing program eligibility controls that include  procedures for conducting annual eligibility examinations; (2) analyzing  the results of the examinations to understand the underlying causes of  ineligibility; (3) developing new procedures for examinations, including  expanding the sample of businesses to be examined to include those that  did not receive contracts; and (4) investigating businesses based on  examination results, SBA may continue to find high rates of ineligibility  among businesses registered in the WOSB program repository. In turn,  this would continue to expose the program to the risk that ineligible  businesses may receive set-aside contracts. Also, by reviewing the  eligibility of businesses that have not received program contracts, SBA  may improve the quality of the pool of potential program award recipients.
section_title: Program Set-Asides Have Had Minimal Effect on WOSB Contracting
paragraphs: Set-asides under the WOSB program to date have had a minimal effect  on overall contracting obligations to WOSBs and attainment of WOSB  contracting goals. WOSB program set-aside obligations increased from  fiscal year 2012 to fiscal year 2013. The Department of Defense (DOD),  the Department of Homeland Security (DHS), and the General Services  Administration (GSA) accounted for the majority of these obligations. The  WOSB program set-asides represented less than 1 percent of total  federal awards to women-owned small businesses. Contracting officers,  WOSBs, and others with whom we spoke suggested a number of  program changes that might increase use of the WOSB program,  including increasing awareness, allowing for sole-source awards, and  expanding the list of eligible industries for the set-aside program.
subsections: section_title: WOSB Program Set-Aside Obligations Increased from Fiscal Year 2012 to Fiscal Year 2013, with Three Agencies Accounting for the Majority of Set-Asides
paragraphs: WOSB program set-aside obligations increased from fiscal year 2012 to  fiscal year 2013. Obligations to WOSBs under the WOSB set-aside  program increased from $33.3 million in 2012 to $39.9 million in 2013,  and obligations to EDWOSBs increased from $39.2 million in 2012 to  $60.0 million in 2013. The National Defense Authorization Act for Fiscal  Year 2013 removed the dollar cap on contract awards eligible under the  WOSB set-aside program, which may account for some of the increase in  obligations from 2012 to 2013. SBA officials told us that they expect  increased use of the program in the future as a result of this change.
As shown in table 2, three federal agencies—DOD, DHS, and GSA— collectively accounted for the majority of the obligations awarded under  the set-aside program. DOD (Air Force, Army, Navy, and all other  defense agencies) accounted for 62.2 percent of obligations, DHS for  10.7 percent, and GSA for 4.0 percent of obligations. No other individual  agency accounted for more than 3.4 percent of obligations awarded  under the program.
section_title: WOSB Program Set- Asides Accounted for Less Than 1 Percent of Obligations Awarded to WOSBs
paragraphs: From April 2011 through May 2014, WOSB program set-asides  constituted a very small percentage (0.44 percent) of all the contracting  obligations awarded to WOSBs (see fig. 1). The majority of obligations  awarded to WOSBs were made under other, longer-established set-aside  programs. For example, if eligible, a WOSB could receive a contracting  award under the 8(a), HUBZone, or SDVOSBC programs, or through a  general small business set-aside. WOSBs also can obtain federal  contracts without set-asides (through open competition).
Based on our analysis of FPDS-NG data of federal contracting agencies,  contract obligations awarded through the WOSB set-aside totaled $228.9  million, or 0.44 percent, of the $52.6 billion in contract obligations  awarded to WOSBs from April 2011 through May 2014.
Additionally, the WOSB set-aside has had relatively little impact on  federal agency achievement of goals for contracting to WOSBs, because  the program set-asides represent a very small percentage of all  contracting awards to WOSBs. Since 2011, the overall percentage of  contracting obligations awarded to WOSBs (through any program or open  competition) has remained below the government-wide goal of 5 percent  (see table 3). Goal achievement by the three contracting agencies with  the highest amount of obligations through the set-aside program varied.  For example, DOD did not meet its 5 percent goal for contracting  obligations to WOSBs in any of the 3 years. DHS and GSA met their  goals in all 3 years. Excluding obligations made by DOD, about 5.7  percent of total federal contracting obligations to small businesses  included in SBA’s fiscal year 2013 Small Business Goaling Report were  awarded to WOSBs. For the 24 agencies subject to the Chief Financial  Officers Act listed in SBA’s scorecards, 19 met their WOSB contracting  goal in fiscal year 2012 and 20 met their goal in fiscal year 2013. One  agency missed its goal in fiscal year 2012 but met its goal in fiscal year  2013. Four agencies (the same four each year) did not meet their goal for  either year.
section_title: Contracting Officers, WOSBs, and Others Suggested Program Changes That Might Increase Use of the Set- Aside
paragraphs: Selected federal contracting officials, businesses that received a WOSB  or EDWOSB set-aside, third-party certifiers, and a WOSB advocacy  organization with which we spoke gave their perspectives on existing  challenges and possible changes to increase program usage.
Complexity and burdensome requirements. Contracting officers  described challenges to using the WOSB set-aside. Some contracting  officers noted that generally, all contracts awarded to WOSBs count for  the purposes of meeting agencies’ 5 percent goal and that from their  perspective it does not matter whether a contract is awarded to a WOSB  using the WOSB program, another set-aside program, or open  competition. Some contracting officers said that WOSB program  requirements were burdensome or complex relative to other SBA  programs with set-asides. Unlike the other programs, the WOSB program  requires the use of a separate electronic repository, maintained by SBA,  to collect and store certification documents. One contracting officer noted  that the contracting process slowed when officials had to seek information  from the repository. Another contracting officer told us the role of the  contracting officer included confirming that businesses had uploaded  required documents in the SBA repository based on a list of required  documents in the program regulation—but noted this task was not  required under other contracting programs.
Lack of awareness and agency commitment. Representatives from  advocacy groups also identified awareness of and commitment to the  program as another area for improvement. An advocacy group  representative told us that some of their member WOSBs had  encountered confusion and reluctance on the part of contracting officers  to use the program. Another advocacy group said that SBA should  engender more commitment to the program among contracting officers  and agencies. Another representative noted that there are no  consequences for agency leaders for failure to meet contracting goals for  WOSBs or use the set-aside program. SBA officials described to us  consequences that included a low rating in the publicly available SBA  contracting scorecard, which may draw negative attention to the agency.  Also, the National Defense Authorization Act for Fiscal Year 2013  includes the extent to which agencies meet contracting goals as a  competency by which members of the senior executive service are rated.  All of the businesses we interviewed that received WOSB program  contracts cited the need for increased agency outreach or awareness of  the program. For example, one participant advocated increasing  contracting officer awareness and understanding of how an agency could  benefit from using the WOSB set-aside program.
Changes to increase use of program. Contracting officers also  identified changes they believe could increase use of the WOSB set- aside. For example, some noted that allowing sole-source contracts could  increase program use. Currently, contract officers can establish a set- aside only if there is a reasonable expectation that at least two eligible  WOSBs will submit a bid for the contract. Some contracting officers  suggested expanding the list of North American Industry Association  Classification System (NAICS) codes eligible for use under the WOSB  set-aside. For example, one contracting office said that the designated  NAICS for the set-aside program did not meet their procurement needs.  One representative pointed out that SBA had designated some NAICS  codes just for EDWOSB and others for WOSBs. SBA officials told us the  agency does not have the authority to change the list of industry sectors  eligible for program set-asides without conducting a study of industries in  which WOSBs were underrepresented or substantially underrepresented.  Representatives from all of the WOSB advocacy groups, three of which  are also third-party certifiers, said that expanding the NAICS codes would  improve the program. For example, one advocacy group said that certain  WOSBs would like to obtain WOSB or EDWOSB set-asides but did not  have NAICS codes that were listed as eligible. Another said that they  would not limit the number of eligible industries under the program.  Finally, the businesses we interviewed also believed that allowing sole- source awards or adding more NAICS codes would increase program  use. Six participants commented on the limitations for awarding sole- source contracts through the WOSB set-aside. Five participants felt that  the NAICS codes under the program were limited. One program  participant mentioned that she felt that limiting set-asides for the WOSB  program to certain NAICS codes was inconsistent with other SBA  programs with set-asides, such as 8(a), HUBZone, and SDVOSBC. She  gave an example of an agency that issued a draft solicitation that sought  to award two contracts each to WOSB set-asides, HUBZone, and  SDVOSBC businesses. However when it became clear that the contract  was not in an eligible NAICS code for the WOSB program, the agency  converted the two contracts intended for WOSB set-aside to a general  small business category.
Some program participants also mentioned positive aspects of the  program. Five participants believed that the program provided greater  opportunities for their businesses and WOSBs in general. Furthermore,  five of the six businesses with whom we spoke that received only one or  two contracts felt that the program improved their ability to compete for a  federal contract. For example, one participant noted that while she has  not seen many set-aside solicitations for the NAICS code under which her  business primarily operates, the existence of the program prompted her  to bid on set-asides under other NAICS codes.
section_title: Conclusions
paragraphs: As the only federal procurement set-aside specifically for women-owned  businesses, the WOSB program could play an important role in limiting  competition to certain federal contracts for WOSBs and EDWOSBs that  are underrepresented in their industries. However, weaknesses in  multiple areas of SBA’s management of the program hinder effective  oversight of the WOSB program. Specifically, SBA has limited information  about the performance of its certifiers and does not use what information  is available to help ensure certifiers adhere to program requirements, a  deficiency exacerbated by the highest-volume certifier’s—about 76  percent of third-party certifications—delegation of duties to 14 partner  organizations. An incomplete response to SBA’s request for information  on WBENC’s certification process demonstrates the need for an oversight  framework to ensure that certifiers adhere to agreements with SBA. SBA  did not follow up on the incomplete response from WBENC, which raises  questions about SBA’s commitment to oversight of the certifiers.  Furthermore, the lack of procedures for review and analysis of monthly  certifier reports means that SBA has forgone opportunities to oversee  certifiers and pursue concerns about fraud of individual businesses  identified by one certifier. According to federal standards for internal  control, agencies should conduct control activities such as performance  reviews and clearly document internal controls. Formalizing existing ad  hoc processes (by developing procedures) will help SBA obtain the  information necessary to better ensure that third-party certifiers fulfill the  requirements of their agreements with SBA—an effort SBA said it plans to  undertake, although it has not estimated a completion date. Additionally,  SBA could use results and insights from reviews of certifier reports— which are to include concerns about businesses—to inform its processes  for eligibility verification, particularly examinations.
Weaknesses related to SBA’s examination of program participants and  approach to enforcement mean that the agency cannot offer reasonable  assurance that only eligible businesses participate in the program.  Although the agency’s examinations found high rates of ineligibility, SBA  has not yet formalized examination guidance for staff or followed up on  examination results to determine the status of ineligible businesses at the  time of contract award. SBA also has not focused on identifying factors  that may be causing businesses to be found ineligible; rather, the agency  appears to have determined that more training for businesses about  eligibility requirements could address the issue. However, training alone  would be a limited response to examination results, and SBA officials  could not say what analysis determined training to be the relevant  response. Additionally, the sample of businesses that SBA examines  includes only those businesses that received WOSB set-aside contracts.  All these factors limit SBA’s ability to better understand the eligibility of  businesses before applying for and being awarded contracts. Rather than  gather and regularly analyze information related to program eligibility,  SBA relies on other parties to identify potential misrepresentation of  WOSB status (through bid-protest filings and less formal mechanisms)—a  reactive and limited approach to oversight. Federal standards for internal  control state that agencies should have documented procedures, conduct  monitoring, and ensure that any review findings and deficiencies are  brought to the attention of management and are resolved promptly.  Additionally, the standards state that management needs to  comprehensively identify risks the agency faces from both internal and  external sources. By expanding its examination of firms and analyzing  and following up on the results, SBA could advance the key program goal  of restricting competition for set-aside contracts to WOSBs and  EDWOSBs.
section_title: Recommendations for Executive Action
paragraphs: We make the following recommendations to improve management and  oversight of the WOSB program.
To help ensure the effective oversight of third-party certifiers, the  Administrator of SBA should establish and implement comprehensive  procedures to monitor and assess performance of certifiers in accord with  the requirements of the third-party certifier agreement and program  regulations.
To provide reasonable assurance that only eligible businesses obtain  WOSB set-aside contracts, the Administrator of SBA should enhance  examination of businesses that register to participate in the WOSB  program, including actions such as: promptly completing the development of procedures to conduct  annual eligibility examinations and implementing such procedures; analyzing examination results and individual businesses found to be  ineligible to better understand the cause of the high rate of ineligibility  in annual reviews, and determine what actions are needed to address  the causes; and  implementing ongoing reviews of a sample of all businesses that have  represented their eligibility to participate in the program.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to SBA, DHS, DOD, and GSA for review  and comment. SBA provided written comments that are described below  and reprinted in appendix II. The other agencies—DHS, DOD, and  GSA—did not provide comments on this report. SBA generally agreed  with our recommendations and said that the agency is already in the  process of implementing many of our recommendations.
While SBA generally agreed with our recommendations, the agency  stated that the report could be clearer about the program examination  process. Specifically, SBA stated that the agency has authority to conduct  eligibility examinations at any time for any firm asserting eligibility to  receive WOSB program contracts. We have added information to the  draft to clarify this point. The draft report we sent to SBA for comment  discussed the agency’s process of conducting annual eligibility  examinations and provided a description of SBA’s current process. SBA  also stated that “the report recommends that SBA conduct ongoing  annual eligibility examinations and implement such procedures.”  However, our report recommends that SBA complete the development of  procedures to conduct annual eligibility examinations (which SBA has  conducted for the past 2 years) and implement such procedures. We  separately recommend implementing ongoing reviews of a sample of all  businesses that have represented their eligibility to participate in the  program. We do not specify that these eligibility reviews, which are  eligibility examinations, should be annual. SBA could choose to conduct  these reviews more frequently if deemed appropriate. Whether SBA  conducts eligibility examinations annually or more frequently,  examinations should be consistently conducted by following written  procedures and the results assessed to determine the causes of  ineligibility.
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 of this report to appropriate  congressional committees and members, the Secretary of DOD, the  Secretary of DHS, the Administrator of GSA, the Administrator of SBA,  and other interested parties. This report will also be available at no  charge on our website at http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-8678 or shearw@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines the Women-Owned Small Business (WOSB)  program of the Small Business Administration (SBA). More specifically,  the report (1) describes how WOSBs and economically disadvantaged  WOSBs (EDWOSBs) are certified as eligible for the program, (2)  examines the extent to which SBA has implemented internal control and  oversight procedures of WOSB program certifications, and (3) discusses  the effect the program has had on federal contracting opportunities  available to WOSBs or EDWOSBs.
To describe how businesses are certified as eligible for the program, we  reviewed SBA policies and procedures to establish program eligibility  including the responsibilities of businesses, third-party certifiers,  contracting officers, and SBA. We interviewed SBA officials from the  Office of Government Contracting. To evaluate how certification  procedures may affect program participation, we obtained from SBA  monthly reports (from September 2011 through May 2014) from each of  the four third-party certifiers. We took steps to develop a dataset we could  use for our analyses, including creating and merging monthly  spreadsheets, identifying missing business names, and clearing the list of  duplicate entries. We compared this dataset with Federal Procurement  Data System-Next Generation (FPDS-NG) data for businesses that  received a WOSB program set-aside contract. We determined that the  data on how many third-party certified businesses received contracts as  part of the WOSB program were sufficiently reliable for our purposes by  corroborating a sample of businesses we identified as third-party certified  with documentation for the businesses in the WOSB program repository.  We were not able to determine how many self-certified businesses  obtained contracts under the program, because the format of the  documentation maintained in the SBA repository does not include a  record of documents that were present at the time of contract award. We  also interviewed a sample of contracting officers from selected  components in the Department of Defense (DOD), Department of  Homeland Security (DHS), and the General Services Administration  (GSA). We selected these three agencies to represent a range of  program participation based on the number and total obligation amounts  of active set-aside contracts awarded in 2011 through 2013. Within DOD  and DHS, we selected two components from each that demonstrated  high- and mid-level program participation (based on number of contracts  and obligation amounts). For DOD, we selected the U.S. Army and  Defense Logistics Agency. For DHS, we selected the U.S. Coast Guard,  and Customs and Border Protection. Within each of the components and  GSA, we compared FPDS-NG data on program activity by obligation  amount, contract number, and North American Industry Classification  System (NAICS) codes for 2011 through 2013. For each, we selected two  contracting offices using the same criteria we used to select agencies,  which included identifying a high- and mid-level program obligation  amount and offices with multiple contracts and under multiple NAICS  codes. We excluded one Customs and Border Patrol office because only  one office awarded multiple contracts under multiple NAICS codes.
We also interviewed three of the four SBA-approved third-party certifiers  (the El Paso Hispanic Chamber of Commerce, the National Women  Business Owners Corporation, and the U.S. Women’s Chamber of  Commerce). We were unable to interview the Women’s Business  National Enterprise Council (WBENC). SBA requested documentation of  WBENC’s oversight procedures for the certification activity and fee  structures of its regional partner organizations. WBENC provided a  written response to SBA, which was not fully responsive to the request,  as discussed in the report. We conducted semi-structured interviews with  a sample of 10 businesses that were certified for the program, 9 of which  had received a set-aside contract.
To evaluate SBA’s oversight of certification, we reviewed the program  regulation and program documents, agreements with third-party certifiers,  135 monthly reports submitted by all four third-party certifiers, and letters  SBA sends to inform businesses when their WOSB or EDWOSB status is  in question, among other documents. We discussed the agency’s  procedures to monitor certifiers and ensure participant eligibility with SBA  officials from the Office of Government Contracting. We compared  officials’ descriptions of their oversight activities with federal internal  control standards. We inquired about documentation and eligibility  examinations conducted in 2012 and 2013, and a planned examination  for 2014, and reviewed reports of the 2012 and 2013 examination results.  We also inquired about ongoing plans to develop a standard operating  procedure, and future plans to evaluate the program.
To determine what effect, if any, the WOSB program has had on federal  contracting opportunities available to WOSBs, we identified set-aside  contract obligations in FPDS-NG from April 2011 through May 2014 to  identify trends in program participation by contracting agencies included  in both FPDS-NG and SBA goaling reports. Using a review of FPDS-NG  documentation and electronic edit checks, we deemed these data  sufficiently reliable for our purposes. We also analyzed SBA goaling  reports from 2011 through 2013 to describe progress made towards  meeting the 5 percent goal for federal contracting to WOSBs. We  conducted semi-structured interviews with a sample of 10 businesses  there were certified for the program, 9 of which had received a set-aside  contract. We selected this nongeneralizable sample of businesses to  reflect whether they had been certified by a third-party entity, or had self- certified. While the results of these interviews could not be generalized to  all WOSB program participants, they provided insight into the benefits  and challenges of the program. We interviewed SBA officials and  contracting agency officials about the extent to which the program has  met its statutory purpose of increasing contracting opportunities for  WOSBs. Finally, we interviewed industry advocates, including three of the  four third-party certifiers (the El Paso Hispanic Chamber of Commerce,  the National Women Business Owners Corporation, and U.S. Women’s  Chamber of Commerce) and one other industry advocate (Women  Impacting Public Policy) actively involved in promoting the program with  WOSBs.
We conducted this performance audit from August 2013 to October 2014  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 contact named above, Andrew Pauline (Assistant  Director), Julie Trinder-Clements (analyst-in-charge), Pamela Davidson,  Daniel Kaneshiro, Julia Kennon, Barbara Roesmann, Jessica Sandler,  and Jena Sinkfield made key contributions to this report.