The federal government has a long-standing policy to maximize contracting opportunities for small businesses. For example, the Business Opportunity Development Reform Act of 1988 amended the Small Business Act to establish an annual government-wide goal of awarding at least 20 percent of prime contract dollars to small businesses. The Small Business Reauthorization Act of 1997 further amended the Small Business Act to increase the goal to at least 23 percent. To help meet this goal, SBA annually establishes prime contract goals for various categories of small businesses for each federal agency. Although SBA is responsible for coordinating with executive branch agencies on this goal, agency heads are responsible for achieving small business goals for their agencies. As previously discussed, in 1978 Congress also established an OSDBU in each federal agency with procurement powers. These offices are intended to advocate for small businesses within the agencies and thus also work with agencies to achieve contracting goals. Duties of OSDBU directors and functions of OSDBUs. The Small Business Act, as amended, establishes a number of requirements related to the functions and duties of OSDBUs. For instance, section 15(k)(3) generally establishes a direct reporting relationship between the OSDBU director and the agency head or deputy head. Other requirements in the act specify that the director must have supervisory authority over staff performing certain duties, implement and execute the functions and duties under the relevant sections of the Small Business Act, and identify proposed solicitations that involve the bundling of contract requirements. The National Defense Authorization Act for Fiscal Year 2013 further amended the Small Business Act to include provisions that specify minimum seniority and pay levels for OSDBU directors, require that their performance appraisals be signed by the agency head or deputy head, and require that the OSDBU director have certain prior experience. Section 15(k)(2) specifies that the OSDBU director must be appointed to a position in the Senior Executive Service (SES), or in certain cases be compensated at not less than the minimum rate of basic pay for grade GS-15 of the General Schedule. Section 15(k)(3) specifies that the agency head or deputy head generally be solely responsible for the performance appraisals of the director. The act also added a number of additional requirements to the duties of the OSDBU director, and specified that the director not hold any other title, position, or responsibility, except as necessary to carry out the responsibilities of the OSDBU as described in section 15(k). Some of the required functions of the OSDBU director in section 15(k) of the Small Business Act include the following: identifying proposed solicitations that involve significant bundling of contract requirements; working with agency acquisition officials, where appropriate, to revise such proposed solicitations to increase the probability of participation by a small business; assisting small businesses in obtaining payments from an agency (or prime contractor) with which they have contracted; assigning a small business technical adviser to each office with an SBA-appointed procurement center representative (an SBA staff member assigned to federal agencies or contract administration offices and who carries out SBA policies and programs); and providing the chief acquisition officer and senior procurement executive of the agency with advice and comments on acquisition strategies, market research, and justifications related to certain provisions of the act. To carry out the functions listed in section 15(k) of the Small Business Act, OSDBU directors provide advice on small business matters and collaborate with the small business community. Some of the primary duties of OSDBU directors include advising agency leadership on small business matters; providing direction for developing and implementing policies and initiatives to help ensure that small businesses have the opportunity to compete for and receive a fair share of agency procurement; providing agency acquisition and program personnel with leadership and oversight of education and training related to small business contracting; conducting reviews of small business programs; and serving as the agency liaison to SBA, including providing annual reports on agency activities, performance, and efforts to improve performance. Reviews by Small Business Procurement Advisory Council. The National Defense Authorization Act for Fiscal Year 2013 amended the statutory requirements of 15 U.S.C. § 644a to require the interagency council known as the Small Business Procurement Advisory Council (SBPAC) to annually review each OSDBU to determine compliance with section 15(k) requirements. These reviews are used to help determine SBA’s annual scorecard grade for each agency. SBPAC must report the results to the House and Senate Small Business committees. SBA chairs the council, which serves to assist agencies in their acquisition planning efforts. The council is also directed to identify best practices for maximizing small business utilization in federal contracting. Roles of other procurement officials. OSDBU directors are not the only officials responsible for helping small businesses participate in federal procurement. At the agency level, the heads of procurement departments (sometimes with a title of senior procurement executive) are responsible for implementing the small business programs at their agencies, including achieving program goals. Generally, staff in agency procurement departments assigned to work on small business issues (small business specialists) coordinate with OSDBU directors on their agencies’ small business programs. Chief acquisition officers provide a focal point for acquisition in agency operations. Key functions of the chief acquisition officers include monitoring and evaluating agency acquisition activities, increasing the use of full and open competition, increasing performance-based contracting, making acquisition decisions, managing agency acquisition policy, acquisition career management, acquisition resources planning, and conducting acquisition assessments. Of the five director-related requirements we reviewed, the level of demonstrated compliance varied, but was not universal for any one requirement (see table 1): Four of the 10 agencies we reviewed for the requirement that the director report to the head or deputy head of the agency did not demonstrate compliance. Twenty-three of the 24 agencies we surveyed demonstrated compliance for two requirements on director experience and supervisory duties. Nineteen of 24 agencies demonstrated compliance with a requirement for collateral duties of the director. Eighteen of 24 agencies demonstrated compliance with a requirement for the director’s compensation and seniority. Appendix II discusses the section 15(k) requirements included in this review. See appendixes III–XXVII for our overall determinations of demonstrated compliance with section 15(k) requirements and determinations of demonstrated compliance at each agency. Section 15(k)(3) generally requires that the OSDBU director report directly to and be responsible only to the agency head or the deputy head. Documentation we reviewed and discussions we held at 6 of the 10 agencies indicated that the directors reported as required. Other documents such as organizational charts, position descriptions and performance appraisals from the Departments of the Air Force, Army, Labor, Navy, and State and from the National Aeronautics and Space Administration (NASA) support this finding. The remaining four OSDBU directors reported to officials at lower levels than the agency head or deputy head. Three of the four—at the Departments of Energy and Veterans Affairs (VA) and the Social Security Administration (SSA)—reported to chiefs of staff. At the Department of Education, the OSDBU director reported to the senior policy adviser. Energy. The position description states that the director reports directly to the secretary. However, the performance appraisals we reviewed were signed by the deputy chief of staff and the chief of staff. An Energy official stated that the secretary provides input into the OSDBU director’s rating. VA. Based on documentation we received from and discussions we held with VA, the OSDBU director reports to the chief of staff, who signs the performance appraisals. An OSDBU official told us that if a matter required the attention of the secretary, the director would first advise the chief of staff. However, the official stated that the director has all the access to the secretary and deputy secretary that he needs. SSA. The organizational chart and performance appraisal show that the OSDBU director reports to the chief of staff. Agency officials explained that, since 2013, the commissioner has delegated this duty to the deputy commissioner. As of May 10, 2017, the agency did not have a deputy commissioner because the deputy commissioner was serving as the acting commissioner. In the absence of a deputy commissioner, the responsibilities were transferred to the chief of staff. Education. The performance appraisal indicates that the OSDBU director reports to the senior policy adviser. An OSDBU official explained that, currently, the agency does not have a deputy secretary and that this duty had been delegated to the senior policy adviser. The official also stated that, in the past, the director typically met with the deputy secretary on a monthly basis and provided an update to the deputy secretary on small business activities. Levels of demonstrated compliance with three other requirements for directors (experience, supervisory duties, and collateral duties) varied somewhat by requirement at the 24 agencies we surveyed, but were high across all three requirements. Director experience. Section 15(k) requires that the OSDBU director have prior experience from among a number of enumerated roles (such as federal contracting officer, program manager for a federal acquisition program, or attorney specializing in federal procurement law). Based on their survey responses and follow-up discussion with officials at the agencies, 23 of the 24 agencies demonstrated compliance with the requirement relating to prior experience of OSDBU directors (examples follow). State. According to the survey response, the OSDBU director has prior experience in program management for a federal acquisition program and also was a small business technical adviser and small business liaison officer. Education. The survey response from the Department of Education indicated the director had prior experience as a federal contracting officer, contracts administrator, and federal small business contracts manager. Interior. Survey responses from the Department of the Interior indicated the director had prior experience as a contracts administrator and small business liaison officer. The OSDBU director at the Department of Housing and Urban Development (HUD) did not demonstrate compliance.