Improvements Needed in SBA’s Shuttered Venue Operators Grant Post-Award Review Process — SBA-OIG Report 24-21

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U.S. SMALL BUSINESS ADMINISTRATION 
OFFICE OF INSPECTOR GENERAL 
Improvements Needed in SBA’s 
Shuttered Venue Operators Grant 
Post-Award Review Process 
Management Advisory 
Report 24-21 
July 10, 2024 
 

 
 
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release of such information. 
NOTICE: 
Pursuant to the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, 
Public Law 117-263, Section 5274, any nongovernmental organizations and business entities 
identified in this report have the opportunity to submit a written response for the purpose of 
clarifying or providing additional context as it relates to any specific reference contained herein. 
Comments must be submitted to AIGA@sba.gov within 30 days of the final report issuance date. 
We request that any comments be no longer than two pages, Section 508 compliant, and free 
from any proprietary or otherwise sensitive information. The comments may be appended to 
this report and posted on our public website. 
 

 
i 
Date: 
July 10, 2024 
To: 
Isabella Casillas Guzman 
Administrator 
From: 
Hannibal “Mike” Ware 
Inspector General 
Subject: 
Improvements Needed in SBA’s Shuttered Venue Operators Grant Post-Award Review 
Process (Report 24-21) 
The Office of Inspector General (OIG) is issuing this management advisory to bring to your 
attention concerns regarding the U.S. Small Business Administration’s (SBA) post-award review 
process to monitor Shuttered Venue Operators Grant (SVOG) award recipients’ eligibility, award 
calculation, and use of funds. 
Since the agency is currently conducting post-award reviews of SVOG awards, we believe 
management should take immediate action to apply a more robust risk-based approach in 
selecting awards to review for eligibility. Specifically, the agency has selected 155 awards for 
eligibility reviews; however, OIG has identified an additional 1,818 high-risk awards totaling 
$1.6 billion that warrant review. We also believe the agency should assess the post-award review 
process to ensure reviews are conducted timely. The agency’s current pace of review will not 
keep up with applicable statute of limitations for taking action on fraudulently obtained awards. 
Therefore, program officials must prioritize the reviews to increase the opportunity to save 
taxpayer funds and improve the integrity of this vital pandemic relief program. 
We considered management comments on the draft of this report when preparing the final 
report. SBA management partially agreed with two recommendations and disagreed with one 
recommendation. 
We appreciate the cooperation and courtesies provided by your staff. If you have any questions 
or need additional information, please contact me or Andrea Deadwyler, Assistant Inspector 
General for Audits, at (202) 205-6586. 
Cc: Dilawar Syed, Deputy Administrator, Office of the Administrator 
 
Arthur Plews, Chief of Staff, Office of the Administrator 
 
Isabelle James, Deputy Chief of Staff, Office of the Administrator 
 
Therese Meers, General Counsel, Office of General Counsel 
 
Francisco Sanchez Jr., Associate Administrator, Office of Disaster Recovery and Resilience 
 
Rafaela Moncheck, Deputy Associate Administrator, Office of Disaster Recovery and 
Resilience 
 
Katherine Aaby, Associate Administrator and Chief Financial Officer, Office of Performance, 
Planning and the Chief Financial Officer  

 
ii 
 
Deborah Chen, Deputy Chief Financial Officer(Acting), Office of Performance, Planning and 
the Chief Financial Officer  
 
Han Nguyen, Associate Administrator, Office of Communications and Public Liaisons 
 
George Holman Jr., Associate Administrator, Office of Congressional and Legislative Affairs  
 
Anna Maria Calcagno, Director, Office of Program Performance, Analysis, and Evaluation  
 
Walter B. Hill Jr., Chief Risk Officer, Office of Performance, Planning and the Chief Financial 
Officer  
 
Michael Simmons, Attorney Advisor, Office of General Counsel 
 
Tonia Butler, Director, Office of Internal Controls 
 
 
 

 
iii 
Contents 
Background ..................................................................................................................................... 1 
Selecting High-Risk Recipients for Eligibility Review ........................................................................ 1 
Leveraging All Available Data to Identify Potentially Ineligible Recipients ................................ 2 
Verifying Talent Representative Recipients Met Eligibility Requirements ................................ 3 
Recommendation ...................................................................................................................... 4 
Conducting More Timely Reviews ................................................................................................... 4 
Recommendations .................................................................................................................... 5 
Evaluation of Agency Response ....................................................................................................... 5 
Summary of Actions Necessary to Close the Recommendations .............................................. 5 
Scope and Methodology ................................................................................................................. 8 
Use of Computer-Processed Data ................................................................................................... 9 
Tables 
1   
SVOG Awards with High-Risk Indicators of Eligibility Concerns ..................................... 2 
Appendix 
1  
Agency Response ......................................................................................................... 10 
  

 
1 
Background 
The Shuttered Venue Operators Grant (SVOG) program was established on December 27, 2020, 
as part of the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic 
Aid Act).1 The program was amended by the American Rescue Plan Act on March 11, 2021, 
which increased program funding and reduced SVOG assistance for some recipients who also 
received loans under the Paycheck Protection Program.2 Collectively these laws provided the 
SVOG program with $16.25 billion to provide grants to eligible businesses that engage in venue 
operations. Eligible entities included live venue operators or promoters, theatrical producers, 
live performing arts organization operators, motion picture theatre operators, non-profit 
museums, and talent representative operators. In total, SBA disbursed $14.6 billion to 13,011 
awardees to include additional supplemental awards to 9,800 of the original awardees. 
The Economic Aid Act required the SBA Administrator to increase oversight efforts which may 
include requiring additional documentation consistent with eligibility requirements and use of 
funds to ensure compliance. The Act further states the Administrator may review and audit 
grants. If fraud or material noncompliance is found, the Administrator may require repayment of 
misspent funds or pursue legal action to collect funds.3  
The SVOG division within SBA’s Office of Disaster Recovery and Resilience oversees the 
administration of the SVOG program. As part of their oversight responsibilities, SVOG program 
officials established post-award review processes. SBA reviews grants to determine whether (1) 
the recipients were eligible, (2) the award amount was correct, or (3) the funds were used 
appropriately. 
Selecting High-Risk Recipients for Eligibility 
Review  
SBA planned to use a risk-based approach to select awards for review. SBA selected awards 
based on identified risks from internal reviews, external referrals, and random selection. As of 
February 2024, program officials selected 2,162 awards for post-award reviews, the majority of 
which will be reviewed to check the accuracy of the amount of funds awarded or verify the 
 
1 Pub. L. No. 116-26, Sections 323 and 324. 
2 Pub. L. No. 117-2, Section 5005. 
3 Pub. L. No. 116-26, Section 324(e). 

 
2 
recipient used the funds for allowable expenses. Only 155 of the selected awards will be 
reviewed to verify eligibility. Based on our review, we identified an additional 1,818 high-risk 
awards totaling $1.6 billion that could have been selected for eligibility reviews (see Table 1). 
Specifically, these awards either had unresolved potential ineligibility or fraud in SBA’s 
Coronavirus Disease 2019 (COVID-19) program databases; or recipients self-certified that they 
were talent representatives, and their operations met the threshold requirement; however, 
these high-risk awards were not selected for review. 
By using a more robust risk-based methodology in selecting high-risk awards for eligibility 
reviews, SBA will ensure funds benefited the businesses Congress intended to support with the 
SVOG program and increase the opportunity to recover any improperly disbursed funds. 
Table 1: SVOG Awards with High-Risk Indicators of Eligibility Concerns 
Description of Potential Eligibility Concerns 
Number of 
Awards 
Total Award 
Amount 
SVOG recipients with unresolved flags in the Payment Protection Plan 
(PPP) and/or Economic Injury Disaster Loan (EIDL) databases. 
526 
$716,083,604 
Recipients who claimed to operate as a talent representative 
1,404 
 $982,253,270 
Total 
1,930 
$1,698,336,874 
Less: Awards in both high-risk categories 
(112) 
($88,274,574) 
Net Total 
1,818 
$1,610,062,300 
Source: SBA OIG Analysis of PPP, EIDL, and SVOG available data 
Leveraging All Available Data to Identify Potentially Ineligible 
Recipients  
To support agencies implementing programs funded through the American Rescue Plan Act of 
2021, Office of Management and Budget (OMB) issued guidance that emphasized using existing 
federal resources, such as the U.S. Department of the Treasury’s Do Not Pay Portal, or internal 
databases when designing internal controls to reduce the risk of making improper payments.4 
Further, OMB guidance for implementing internal controls requires managers to establish and 
 
4 Office of Management and Budget, Circular M-21-20, “Promoting Public Trust in the Federal Government through 
Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources” (March 19, 
2021). 

 
3 
integrate internal controls into its operations in a risk-based manner.5 According to federal 
standards and leading practices for internal controls, managers should compare actual 
performance to planned or expected results, analyze significant differences,6 and take steps to 
detect fraud, including conducting data analytics and matching activities.7 
Program officials selected 155 awards to review for eligibility based on identified risks from 
internal reviews or external referrals. However, we identified an additional 526 awards that had 
eligibility risk indicators by cross-referencing SBA’s Paycheck Protection Program (PPP) and 
COVID-19 Economic Injury Disaster Loans (EIDL) databases. These SVOG award recipients also 
received a PPP or COVID-19 EIDL loan that had been flagged for concerns of potential fraud and 
required program officials’ review. By using data available within the agency, SBA can identify 
SVOG recipients that have been identified as high-risk in other pandemic loans programs, thus 
increasing the opportunity to ensure SVOG funds were awarded to eligible businesses. 
Verifying Talent Representative Recipients Met Eligibility 
Requirements  
Talent representatives were eligible for SVOG awards if at least 70 percent of their operations 
involved representing or managing two or more artists and entertainers, primarily at live events 
in venues or at festivals, whose payment was based on the number of tickets sold or a similar 
basis, among other requirements. Applicants who claimed to operate as a talent representative 
were required to provide documentation to confirm they met the eligibility requirement. 
Program officials planned to verify that applicants met these requirements during the pre-award 
review and awarded 1,404 talent representatives over $982 million in SVOG funds. However, 
based on our limited review of the award files, we found program officials did not consistently 
verify the applicant’s claims were supported by documentation. During our review, program 
officials told us that they considered talent representatives as high-risk when conducting post 
award reviews. However, we found only 21, or 1 percent, of talent representative awards were 
selected for post-award eligibility reviews. SBA should review more of these high-risk awards to 
ensure SVOG funds were awarded to eligible businesses. 
 
5 Office of Management and Budget, Circular A-123, “Management’s Responsibility for Enterprise Risk Management 
and Internal Control” (July 15, 2016). 
6 U.S. Government Accountability Office, GAO-14-704G, Standards for Internal Control in the Federal Government, 
(September 2014). https://www.gao.gov/assets/gao-14-704g.pdf. 
7 U.S. Government Accountability Office, GAO-15-5935SP, A Framework for Managing Fraud Risks in Federal 
Programs, (July 2015). https://www.gao.gov/assets/gao-15-593sp.pdf. 

 
4 
Recommendation 
We recommend the Administrator direct the Associate Administrator for the Office of Disaster 
Recovery and Resilience to: 
Recommendation 1: Take immediate action to review 1,818 SVOG awards that we identified as 
high-risk of potential ineligibility and recover any funds from recipients who did not meet the 
requirements. 
Conducting More Timely Reviews 
Program officials assigned 30 staff members to review 2,162 of the 13,011 SVOG awards in total. 
As of February 5, 2024, SBA completed 165 reviews since it began conducting post-award 
reviews in July 2022. At this pace, we estimate it will take 19 years, or until February 2043, to 
complete the remaining reviews. This is concerning because the current pace will not allow SBA 
to use all available tools to recover improperly paid funds within relevant statutes of limitations. 
Improved processing times will increase the likelihood that misused funds are recovered and 
fraudsters are held accountable before the 5-year statute of limitations expires.8 
Program officials said the primary reason for the slow pace was recipients’ unfamiliarity with 
federal grant requirements, as well as the unique and expansive nature of the SVOG program. 
They also said that some award recipients were unresponsive to post-award review requests. To 
resolve this, SBA established a team called the Enhanced Outreach Team, to focus on contacting 
unresponsive recipients. 
Despite SBA’s efforts, we still found delays in receiving supporting documentation to start 
reviews. We noted numerous award recipients who were selected for review took over a year to 
respond to SBA’s documentation request. Program officials established guidelines for staff to 
follow for initiating the process to recover funds from nonresponsive recipients. The guidance 
instructed that after 14-days of attempting to reach the award recipients, program officials are 
directed to terminate the award and begin actions to recover funds. 
In addition to the long wait times for recipients to provide requested documentation, we found 
program officials did not immediately review the documentation once it was received. According 
 
8 Time for Commencing Actions Brought by the United States, 28 U.S. Code § 2415, and Crimes and Criminal 
Procedure 18, U.S. Code § 2415. 

 
5 
to SBA, delays were caused by attrition of temporary staff, training new staff, and extensive 
documentation to review. They also had to account for human error. 
The post-award review effort to recover improper or fraudulent payments needs to be 
completed accurately and at a faster pace to meet statutory deadlines. If program officials do 
not conduct reviews in a timely manner, SBA will not increase the opportunity to remedy and 
promptly recover funds incorrectly or fraudulently obtained.  
Recommendations 
To address concerns in the SVOG program, we recommend the Administrator direct the 
Associate Administrator for the Office of Disaster Recovery and Resilience to: 
Recommendation 2: Finalize and implement updated guidance dated April 18, 2024, to 
terminate the award for unresponsive recipients and initiate actions to recover funds within the 
stated timeline. 
Recommendation 3: Assess staffing and procedures to ensure post-award reviews are 
conducted in a prompt manner. Use the results of the assessment to improve processing times 
to ensure reviews are completed in time to accommodate relevant statute of limitations. 
Evaluation of Agency Response 
SBA management provided formal written comments that are included in their entirety in 
Appendix 1. Management disagreed with Recommendation 1 and partially agreed with 
Recommendations 2 and 3. We found the agency’s planned actions are sufficient to resolve all 
three recommendations.  
Summary of Actions Necessary to Close the Recommendations 
The following section summarizes the status of our recommendations and the actions necessary 
to close them. 
Recommendation 1 
Take immediate action to review 1,818 SVOG awards that we identified as high-risk of potential 
ineligibility and recover any funds from recipients who did not meet the requirements. 

 
6 
Status: Resolved 
SBA management disagreed with the recommendation stating they already completed fraud 
evaluations for 494 of the 526 SVOG awards OIG identified with eligibility risk indicators in PPP 
and EIDL databases; however, they did not provide supporting documentation. Management 
further stated they plan to conduct reviews for the remaining 32 awards by September 30, 2024. 
Regarding talent representative award recipients, SBA management stated they cannot 
substantiate OIG’s concerns that awards made to talent representatives are a higher risk than 
other SVOG eligible entities. Management’s position is that all seven SVOG entity types had 
different requirements and means of demonstrating eligibility, and talent representatives are 
not inherently riskier than any other category. Management asserted that their robust 
application review process and post-award oversight serve as an effective safety net to prevent 
waste or abuse of SVOG funds. Accordingly, management stated they selected 133 talent 
representative recipients for post-award reviews and 381 for probable fraud reviews. 
OIG’s concerns regarding increased risks associated with awards to talent representatives are 
based on statements and information SBA program officials provided during our review. Our 
limited testing supported program officials’ concerns that awards made to talent representatives 
were higher risk because we found that program officials did not consistently verify that the 
applicant’s eligibility claims were supported by documentation. When we assessed the awards 
selected for post-award eligibility reviews, we were concerned that only 21 talent representative 
recipients were selected. 
However, since we expressed our concerns to management, they increased the number of 
awards they identified to review for fraud in this category. They provided a list of 381 talent 
representative applications selected for probable fraud reviews. We found 185 of 381 
applications were awarded funds. In total, management plans to review 318 talent 
representative awards (133 awards for post-award reviews and 185 awards for probable fraud 
reviews). 
Since management has selected 46 percent (318 awards to talent representatives and 526 
awards with eligibility risks in PPP and EIDL databases) or 844 of the 1,818 awards we identified 
for review, we believe they met the intent of the recommendation. As we continue our ongoing 
audit of SBA’s oversight of SVOG recipients, we will notify management of additional risks or 
specific entities that we identify that may require review. 
This recommendation can be closed once management provides documentation to confirm they 
(1) completed reviews for the 526 awards with eligibility risk indicators in PPP and COVID-19 EIDL 

 
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databases and the 318 talent representative awards; and (2) took action to recover funds from 
recipients who did not meet the requirements. 
Recommendation 2 
Finalize and implement updated guidance dated April 18, 2024, to terminate the award for 
unresponsive recipients and initiate actions to recover funds within the stated timeline. 
Status: Resolved 
SBA management partially agreed with the recommendation, stating they finalized and 
implemented guidance to terminate awards for unresponsive recipients and initiated actions to 
recover funds in a timely manner. Management further stated that they have had over 1,950 
successful outreach attempts to re-establish contact with non-responsive recipients and have 
referred 98 non-responsive grantees to the SVOG funds recovery team. SBA plans to complete 
implementation of actions to initiate funds recovery related to post-award reviews by 
September 30, 2024. 
This recommendation can be closed once management provides evidence that they finalized and 
implemented (1) procedures to terminate unresponsive recipients; and (2) a process to recover 
funds from unresponsive award recipients. 
Recommendation 3 
Assess staffing and procedures to ensure post-award reviews are conducted in a prompt 
manner. Use the results of the assessment to improve processing times to ensure reviews are 
completed in time to accommodate relevant statute of limitations. 
Status: Resolved 
SBA management partially agreed with the recommendation, stating they did not agree with 
OIG’s calculation that it would take an additional 19 years to complete post-award reviews. Our 
calculation was based on data received as of February 5, 2024, when only 165 of the 2,162 post 
awards, or nearly 8 percent, had been completed. 
Management stated that during fiscal year 2024, they updated daily performance metrics and 
enhanced outreach tactics and staffing assignments to increase the speed of SVOG post-award 
reviews. They also stated that most of the staff time is now spent issuing final determinations. 
According to management, as of May 9, 2024, SBA completed 25 percent of the SVOG post-
award reviews for eligibility, award amount, and/or use of award funds, reflecting a 237 percent 
increase when compared to the number of reviews completed as of February 5, 2024. 

 
8 
Management plans to continue to assess staffing and procedures and use the results of 
assessments of staff’s daily performance measures to adjust and improve processing times. SBA 
plans to complete final action by September 30, 2024. 
This recommendation can be closed when management provides results of staffing and 
procedural assessments and evidence of improved processing times. 
Scope and Methodology 
The overall objectives of our ongoing audit, SBA’s Oversight of the Shuttered Venue Operators 
Grant Recipients, are to determine whether SBA implemented a process to (1) monitor 
recipients’ use of grant funds; (2) monitor program performance; and (3) ensure unallowable or 
unused funds were returned to the Treasury. During our audit, we found SBA could review 
awards that were flagged by existing SBA databases and award systems as potential fraud, 
abuse, or misuse. This management advisory brings attention to concerns about SBA’s post-
award review process in the SVOG program. 
We reviewed federal laws, regulations, policies, procedures, and internal memorandums 
pertaining to SBA’s oversight of SVOG recipients. We obtained a list of SVOG recipients from the 
SVOG application portal and from USASpending.gov.9 
We interviewed Office of Disaster Recovery and Resilience program officials and reviewed 
supporting documentation to gain an understanding of SBA’s plans and procedures for selecting 
and reviewing SVOG award recipients’ use of funds, award calculation, and eligibility to verify 
funds were awarded and used appropriately and evaluated their response. We also analyzed 
SVOG data to identify potentially ineligible and fraudulent awards not selected for review and to 
assess the timeframe for completing post-award reviews. 
Our ongoing audit of the SBA’s oversight of SVOG recipients is being conducted in accordance 
with generally accepted government auditing standards. We prepared this management advisory 
in alignment with OIG’s quality control standards and the Council of the Inspectors General on 
Integrity and Efficiency’s Quality Standards for Federal Offices of Inspector General, which 
require that we conduct our work with integrity, objectivity, and independence. We believe that 
the evidence obtained provides a reasonable basis for our findings and conclusions. 
 
9 SVOG application portal (https://sbaodagrants.my.salesforce.com); USASpending.gov is a public data source of 
federal spending information (https://www.usaspending.gov). 

 
9 
Use of Computer-Processed Data 
We relied on computer-processed data in the SVOG online application platform. We retrieved 
applications, award information, and SBA’s evaluation record for all SVOG applicants. We tested 
the reliability of computer-processed data in the SVOG online application platform by comparing 
the report, which included application and award information generated by program officials. 
Further, we tested the reliability of the data by comparing data received from the SVOG platform 
to USASpending.gov. We also compared data received from the SVOG online application 
platform to SBA’s PPP and COVID-19 EIDL databases. We believe the computer-processed 
information is reliable for the purposes of this management advisory. 
 

 
10 
Appendix 1: Agency Response 
SBA Response to Report 
 
 

409 Third St. SW, Washington, DC 20416 — (817) 868-2300
Date: 
06/07/2024 
To: 
Hannibal “Mike” Ware  
Inspector General 
U.S. Small Business Administration 
From: 
Francisco Sanchez, Jr. Associate Administrator 
Office Of Disaster Recovery & Resilience (ODR&R) 
Subject: 
SBA’s Comment Letter to OIG Management Advisory “Improvements Needed in SBA’s 
Shuttered Venue Operators Grant Post-Award Review Process (Project 24002)” 
We have reviewed the Office of Inspector General (OIG) report, “Improvements Needed in SBA’s 
Shuttered Venue Operators Grant Post-Award Review Process,” sent on May 2, 2024. 
Our response and management decision(s) for each recommendation follows. The information 
provided should be understood to be reliant on an understanding of the policies, procedures, and 
internal controls of the Shuttered Venue Operators Grant Program (SVOG), as well as documents that 
have been submitted to Congress.  
If you have any questions or follow-up on the provided SVOG information, please be sure to include 
sheena.mcshan@sba.gov and ODRRAuditLiaisonTeam@sba123.onmicrosoft.com in the request you 
submit. 
We appreciate the opportunity to provide this information and look forward to a successful audit. 

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 2 of 9 
EXECUTIVE SUMMARY 
SBA disagrees with Recommendation #1, and only partially agrees to Recommendations #2 and #3. 
SBA anticipates remediation of Recommendations #2 and #3 by the end of the 2024 fiscal year. 
SBA’s Response to the Report 
Recommendation 1 
“Take immediate action to review 1,818 SVOG awards that we identified as potentially 
ineligible and recover any funds from recipients who did not meet the requirements.” 
SBA disagrees with Recommendation 1. 
SBA’s Process for Cross-Program Flag Evaluations Already Reviews the Identified Recipients 
SBA shares OIG’s interest in ensuring eligibility concerns as well as fraud flags by other pandemic 
programs are evaluated. However, SBA’s existing processes have already conducted the reviews OIG 
indicates. As it relates to concerns of possible fraud, SBA has used data available within the agency to 
evaluate approximately 702 SVOG awards flagged by other pandemic programs for probable fraud. As 
of May 2024, SBA  has evaluated 1,949 applicants and 1,221 award recipients for potential or probable 
fraud concerns since program onset. Additionally, SBA’s Office of Disaster Recovery & 
Resilience (ODR&R) has referred approximately 150 SVOG awards to OIG.   
As it relates to the specific 526 SVOG awards OIG identified with eligibility risk indicators in 
SBA’s Paycheck Protection Program (PPP) and COVID-19 Economic Injury Disaster Loans (EIDL) 
databases, ODR&R program officials had completed fraud evaluations for 494 of those 526 awards 
prior to OIG issuing this Management Advisory.  The SBA Fraud Risk Management Board (FRMB) and 
data scientists within the SBA Office of the Chief Financial Officer facilitate cross program fraud data 
analytics with an agency database of cross-program fraud flags (Cross-Program Report). Each 
update to the Cross-Program Report identifies program recipients with new, updated, or closed 
hold codes related to suspected fraud or identity theft. These updates are distributed to the SVOG 
program officials and to ODR&R Internal Controls for post-award fraud reviews to determine if SVOG 
eligibility is impacted. Given the small difference between the 526 flags OIG indicates and the 494 
which had already been reviewed, SBA believes it is likely just a matter of the timing of OIG’s data-
pull.  

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 3 of 9 
SBA has identified the 32 flags which were not already reviewed previous to this advisory, and they are 
in the process of being reviewed as a matter of course. 
SBA’s Process for Eligibility Review Validated that Talent Representative Recipients Met Eligibility 
Requirements  
SBA cannot substantiate OIG’s concerns that the entire class of talent representatives are a higher risk 
than other SVOG-eligible entities.  
In a May 14, 2024 correspondence submitted to OIG, SBA raised concerns that OIG did not provide SBA 
with the methodology used to distinguish the entire class of talent representatives as high-risk in 
comparison to the other types of eligible entities. On May 29th, OIG responded that it considered talent 
representatives “high risk” because the category had “more required areas to be eligible,” such as “at 
least 70% of operations involved representing or booking two or more performers at ticketed live events.” 
SBA’s position is that all seven SVOG entity types had different requirements and means of 
demonstrating eligibility, and Talent Representatives are not inherently riskier as a class than any 
other category. For example, museums had to demonstrate they were non-profit. SBA required all 
SVOG applications, regardless of entity type, be reviewed for support documentation and to verify 
eligibility.  
SBA trained all SVOG application review staff to consistently verify talent representative applications 
were supported by documentation. Prior to any award making/decision staff were instructed to verify 
talent representative status. SBA required contracts and booking information be provided with the 
application, and SBA directed staff consult external sources such as the Celebrity Access webpage, the 
Bandcamp webpage, artists’ webpages, Lexis Nexis Comprehensive Person Searches, Lexis Nexis 
Comprehensive Business Searches, IMDB, and/or social media posts made prior to application dates. 
Where inconsistencies may have impacted eligibility, a robust appeals process, re-checks of key 
data and databases during screening for supplemental awards, and post-award reviews for quality 
assurance, cost-compliance monitoring, and suspected fraud serve as an effective safety net to 
prevent clear waste or abuse of SVOG funds. 
SBA provided Congress with an Audit and Oversight Plan for the program which explained that 
the SVOG application review process included “a robust set of controls based on applicant-
provided information as well as additional third-party data, including IRS tax verification, and the 
Treasury’s “Do Not Pay” list. The application review process [was] concerned with verifying 
applicant eligibility, applicant and business identity, and key financial information critical to 
calculating the appropriate 

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 4 of 9 
grant amount.” Post-award oversight was then designed with audit, oversight, and monitoring 
activities informed by annual “risk assessment for internal and external risks . . . [where] SBA identified 
areas of potential risk, [such as] likelihood of impact … and amount of award. After assigning risk levels 
to those with risk potential, we then identified mitigation strategies using appropriate government 
resources.”    
As it pertains to any risks in the use of funds, 133 talent representative recipients were identified for 
post-award reviews based on being selected for the random sample and/or based on cost compliance 
risk. Specifically, 110 talent representative recipients were selected for use of award monitoring, 21 
talent representative recipients were selected for eligibility monitoring and 2 talent representative 
recipients were selected for award amount reviews. Furthermore, 381 talent representative 
recipients were selected for fraud reviews.   
OIG’s May 29th correspondence provided the name of an SVOG recipient where OIG had concerns with 
how eligibility had been verified for a Talent Representative entity, stating: “we did not see any 
documentation how agency reviewed eligibility (e.g. 70% threshold).” For that particular entity, SBA was 
able to locate the documented checklists and four reviews in the expected location in the SVOG Award 
System dated June 28, 2021, June 30, 2021, and July 2, 2021, inclusive of social media, contracts, and 
Lexis search results.  
SBA’s review of OIG’s advisory does not support a blanket re-review the entire class of talent 
representative files. However, should the OIG provide the program with a subset of talent 
representative files with specific eligibility concerns beyond simply belonging to the class of talent 
representative, the program can provide evidence of its reviews and/or conduct a re-examination at 
that time.  
Results 
As of May 2024, SBA has accomplished the following: 
•
Identified 133 talent representative recipients for a post-award review.
•
Identified 381 talent representative recipients for probable fraud review.
•
Evaluated 1,221 SVOG recipients flagged for probable fraud and/or identify theft by another
pandemic program.
•
Completed fraud evaluations for 494 of the 526 awards the OIG identified with eligibility risk
indicators by cross-referencing SBA’s Paycheck Protection Program (PPP) and COVID-19
Economic Injury Disaster Loans (EIDL) databases.

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 5 of 9 
Corrective Actions 
ODR&R plans to complete the following corrective actions by quarter 4 of the 2024 fiscal year: 
•
Conduct post-award fraud evaluations for the remaining 32 awards OIG identified with
eligibility risk indicators by cross-referencing SBA’s Paycheck Protection Program (PPP) and
COVID-19 Economic Injury Disaster Loans (EIDL) databases.

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 6 of 9 
Recommendation 2 
“Finalize and implement updated guidance dated April 18, 2024, to terminate the 
award for unresponsive recipients and initiate actions to recover funds within the 
stated timeline.”  
SBA partially agrees with Recommendation 2 and has made significant 
progress aligned with Recommendation 2.  
As SBA has indicated in its closure package for OIG Report 24-03 Recommendation 18, SBA’s follow-up 
procedures for SVOG award recipients are implemented and effective. As of the end of April 2024, SBA 
has had over 1,950 successful outreach attempts to re-establish contact with recipients that had 
become non-responsive with their grant terms by failing to adequately or timely complete a 
post-award action item.  
In October 2022, the program formally launched Tier 1 outreach to grantees observed as non-
responsive. Tier 2 enhanced outreach was formally launched in February 2023 and Tier 3 enhanced 
outreach tactics were launched by April 2024. Tier 1 outreach involves attempts by the assigned Grants 
Management Specialist (GMS) to contact the grantee and re-establish responsiveness. Upon 
expiration of a post-award action item, GMS will document the grantee’s non-responsiveness and 
conduct outreach attempts to get the entity back in compliance. 
Tier 2 sees the funding request elevated to enhanced outreach team (EOT) after previous attempts by 
the assigned Grants Management Specialist to contact the grantee and re-establish responsiveness 
failed (Tier 1 outreach). Tier 2 enhanced outreach involves attempts by the EOT to contact the grantee 
and re-establish responsiveness by continuing outreach to the funding request contacts during 
various times throughout the day and during the weekends, researching alternative contact 
information for the grantee using additional resources, and documenting any unusual events or 
circumstances. 
If initial Grant Management Specialist outreach and Tier 2 enhanced outreach are unsuccessful, Tier 3 
enhanced outreach is conducted by SBA district offices as a final attempt to contact non-responsive 
grantees in their area. District offices are given 14 calendar days to identify alternative contacts and/or 
attempt to contact the grantee and report back any findings to SVOG. If SBA is unable to engage the 
grantee after 14 calendar days and determine a compliance plan, SBA will terminate the grant award 
due to non-compliance and pursue recoupment of the funds. 

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 7 of 9 
Results 
ODR&R has accomplished the following: 
•
SBA has finalized and implemented the April 18, 2024 guidance document to terminate awards 
for unresponsive recipients and to initiate actions to recover funds in a timely manner. 
•
SBA has referred 98 non-responsive grants to the SVOG funds recovery team. 
Corrective Actions 
ODR&R plans to complete the following corrective actions by the end of the fiscal year 2024: 
•
Complete implementation of actions to initiate funds recovery related to post-award reviews
in a timely manner.

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 8 of 9 
Recommendation 3 
“Assess staffing and procedures to ensure post-award reviews are conducted in a 
prompt manner. Use the results of the assessment to improve processing times to 
ensure reviews are completed in time to accommodate relevant statute of limitations.” 
SBA partially agrees with Recommendation 3 and has made significant 
progress aligned with Recommendation 3. 
SBA shares OIG’s interest in ensuring reviews are conducted in a timely manner. However, ODR&R 
does not agree with the conclusion that SVOG post-award reviews will take an additional 19 years to 
complete.  
Within Fiscal Year 2024, ODR&R has updated its daily performance metrics, enhanced outreach tactics, 
and staffing assignments to increase the speed of SVOG post-award reviews. As of May 09, 2024, 
ODR&R has completed almost all audit report reviews and Cross-Program Report fraud reviews, and 
25% of SVOG post-award desk audits for eligibility, award amount, and/or use of award are completed. 
This reflects a 237% increase when compared to the number of complete post-award reviews as 
of February 05, 2024.   
An additional factor in this increase in processing speed is that the majority of cost-
compliance oversight was conducted incrementally: the majority of identified grants received a 
customized notification prior to work beginning on reviewing interim results, and most interim 
results were reviewed prior to ODR&R beginning to close monitoring events. No additional 
increments are planned, so the majority of staff time is now spent on issuing final determinations. 
Results 
To conduct timely post-award reviews, ODR&R has taken the following corrective actions: 
•
ODR&R tracks SVOG staffs’ daily performance metrics and reports end of day results to ODR&R 
senior leaders. 
•
SBA has three tiers of enhanced outreach to unresponsive SVOG grantees. 

 SBA’s Comment Letter to OIG Management Advisory (Project 24002)
SBA’s Comment Letter to OIG Management Advisory for Project 24002 
Page 9 of 9  
•
ODR&R has increased the number of staff conducting enhanced outreach and has adjusted 
human resources to increase the number of staff conducting post-award reviews. 
Corrective Actions 
To ensure post-award reviews are completed in time to accommodate relevant statute of limitations, 
ODR&R has planned the following corrective actions: 
•
ODR&R will continue to assess staffing and procedures.
•
ODR&R will continue to use the results of assessments of staffs’ daily performance metrics to
adjust and improve processing times.

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