Evaluation of SBA's Award Procedures for the CARES Act Entrepreneurial Development Cooperative Agreements

Source document: Evaluation of SBA's Award Procedures for the CARES Act Entrepreneurial Development Cooperative Agreements; document type: OIG audit report.

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EVALUATION OF SBA’S AWARD PROCEDURES FOR
THE CORONAVIRUS AID, RELIEF, AND ECONOMIC
SECURITY ACT ENTREPRENEURIAL DEVELOPMENT
COOPERATIVE AGREEMENTS
REPORT NUMBER 21-11 | MARCH 30, 2021

S B A   I N S P E C T O R   G E N E R A L   E V A L U A T I O N   R E P O R T

          Executive SummaryExecutive SummaryExecutive SummaryExecutive SummaryExecutive Summary
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Executive Summary
EVALUATION OF SBA’S AWARD PROCEDURES FOR THE CORONAVIRUS
AID, RELIEF, AND ECONOMIC SECURITY ACT ENTREPRENEURIAL
DEVELOPMENT COOPERATIVE AGREEMENTS
Report No.
21-11
March 30,
2021
What OIG Reviewed
We evaluated the Small Business Administration’s
(SBA) handling of economic relief funding to
educate, train, and advise small business owners
and entrepreneurs on practices necessary to
reduce the economic effects of the Coronavirus
Disease 2019 (COVID-19) pandemic. The SBA
Office of Entrepreneurial Development (OED)
oversees a network of centers promoting small
business
growth
through
entrepreneurial
development, training, and counseling. Within
OED, the Office of Small Business Development
Centers and the Office of Women’s Business
Ownership administer two programs that include a
nationwide
network
of
Small
Business
Development Centers (SBDCs) and Women’s
Business Centers (WBCs). OED also collaborates
with America’s SBDC and Association of WBCs for
many
of
its
entrepreneurial
development
initiatives.
The President signed the Coronavirus Aid, Relief,
and Economic Security (CARES) Act into law on
March 27, 2020, to provide economic relief to our
nation’s small businesses. One of the Act’s
provisions provided $265 million for
SBA
entrepreneurial development programs. Of the
$265 million, Congress specified allocations
resulting in $192 million made available for SBDCs,
$48 million available for WBCs, and the remaining
$25 million for developing an online training portal
known as the Resource Partners Training Portal
(RPTP).
Our objective was to determine whether SBA
awarded
the
CARES
Act
entrepreneurial
development cooperative agreements and grants
in accordance with applicable federal laws,
regulations, and other guidance.
To accomplish our objective, we reviewed the
CARES Act, laws, regulations, and the policies and
procedures SBA used to award the CARES Act
entrepreneurial
development
cooperative
agreements and grants. We reviewed the funding
opportunity
announcements,
and
RPTP
performance metrics plan documentation.
We interviewed program personnel and obtained
the required supporting documentation. We
judgmentally selected six CARES Act cooperative
agreements and one grant to evaluate, totaling
$41.6 million in funding. Of the six cooperative
agreements, we selected two SBDCs and four
WBCs. We also selected the one RPTP grant to
review.
What OIG Found
SBA awarded the CARES Act entrepreneurial
development cooperative agreements and grants
in accordance with applicable federal laws,
regulations, and guidance. We found program
officials
established
performance
goals
and
identified performance indicators. However, in
order to more effectively ensure performance goals
are achieved as intended, SBA should clearly define
the performance goals and set targets.
OIG Recommendations
We made two recommendations aimed at
promoting enhanced performance goal-setting
measures of the CARES Act entrepreneurial
development cooperative agreements and grants.
Specifically, we recommended that SBA enforce
standard operating procedures that require clearly
defined performance goals and performance
targets. We also recommended that SBA collect and
analyze
the
CARES
Act
entrepreneurial
development cooperative agreement recipient’s
performance results to establish a framework for
setting goals for future disasters.
Agency Response
SBA management concurred with both of our
recommendations and its planned actions resolve
the recommendations. SBA will improve planning
for
future
entrepreneurial
development
cooperative agreements and grant awards using a
more comprehensive, integrated, and strategic
approach to define performance goals and targets.
SBA also plans to develop and improve its data
collection
system
to
collect
and
analyze
cooperative
agreement
performance
results.
Further, SBA plans to use program logic models to
assist with establishing a framework for setting
goals for future entrepreneurial development
disaster technical assistance programs.

Office of Inspector General

U.S. Small Business Administration

409 3rd Street SW., Washington, DC 20416  •  phone: 202-205-6586  • fax: 202-205-7382

DATE:
March 30, 2021
TO:

Isabella Casillas Guzman

Administrator

FROM:
Hannibal “Mike” Ware
Inspector General

SUBJECT:
Evaluation of SBA’s Award Procedures for the Coronavirus Aid, Relief, and
Economic Security Act Entrepreneurial Development Cooperative
Agreements

This report presents the results of our evaluation of the SBA’s award procedures for the
Coronavirus Aid, Relief, and Economic Security Act entrepreneurial development
cooperative agreements. We considered management comments on the draft of this report
when preparing the final report. Management agreed with both recommendations.
We appreciate the courtesies and cooperation extended to us during this evaluation. If you
have any questions, please contact me or Andrea Deadwyler, Assistant Inspector General
for Audits, at (202) 205-6586.
cc:  Steve Kong, Acting Chief of Staff
Arthur Plews, Deputy Chief of Staff
Peggy Delinois Hamilton, General Counsel
Mark Madrid, Associate Administrator, Office of Entrepreneurial Development
Adriana Menchaca-Gendron, Deputy Associate Administrator, Office of Entrepreneurial
Development
Tami Perriello, Chief Financial Officer, Office of Performance, Planning, and the Chief
Financial Officer
Kenneth Ethridge, Acting Executive Director, Office of Executive Management,
Installation and Support Services
Martin Conrey, Attorney Advisor, Legislation and Appropriations
Tonia Butler, Director, Office of Internal Controls

Table of Contents
Introduction ....................................................................................................................................................................................................... 1
Entrepreneurial Development Programs ........................................................................................................................................ 1
Resource Partner Training Platform ................................................................................................................................................. 2
CARES Act Performance and Reporting Requirements ............................................................................................................ 2
Previous Work ............................................................................................................................................................................................. 2
Objective ........................................................................................................................................................................................................ 3
Finding: SBA Awarded CARES Act Entrepreneurial Development Cooperative Agreements and Grant as
Required but Could Improve Performance Goals and Establish Targets ............................................................................... 4
Performance Goals Should be Clearly Defined and Performance Targets Established .............................................. 4
Recommendations ..................................................................................................................................................................................... 6
Analysis of Agency Response ..................................................................................................................................................................... 7
Summary of Actions Necessary to Close the Recommendations .......................................................................................... 7
Recommendation 1 .............................................................................................................................................................................. 7
Recommendation 2 .............................................................................................................................................................................. 7
Appendix I: Objective, Scope, and Methodology................................................................................................................................ 8
Objective ........................................................................................................................................................................................................ 8
Scope and Methodology .......................................................................................................................................................................... 8
Use of Computer-Processed Data ....................................................................................................................................................... 9
Appendix II: Management Comments .................................................................................................................................................. 10

1
Introduction
The President signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act1 into
law on March 27, 2020 to provide economic relief to our nation’s small businesses. One of
the Act’s provisions provided $265 million for the Small Business Administration’s (SBA)
entrepreneurial development programs to offer counseling, training, and related assistance
to small business owners and entrepreneurs affected by the Coronavirus Disease 2019
(COVID-19) pandemic.
Of the $265 million, $240 million were made available for Small Business Development
Centers (SBDCs) and Women’s Business Centers (WBCs) for educating, training, and
advising small businesses on:
• accessing and applying for capital and business resiliency resources;
• the hazards and prevention of spreading COVID-19;
• understanding and preparing for the potential effects of COVID-19 on the
supply chains, distribution, and sale of products;
• the use of telework and remote customer service;
• the risk of and mitigation of cyber threats;
• the mitigation of the effects of reduced travel or moving business activities
outside during COVID-19;
• other relevant business practices necessary to reduce the economic effects of
COVID-19.
The Act made the remaining $25 million available for SBA to establish a single centralized,
online hub for information related to COVID-19. The Act mandated SBA to award a grant to
consolidate information on federal resources available to small businesses related to
COVID-19 and implement a training program to educate resource partner counselors on
the available resources and information.
Entrepreneurial Development Programs
The SBA Office of Entrepreneurial Development (OED) oversees a network of programs
and services that support the training and counseling needs of small businesses. The
CARES Act limited the awarding of grants to the SBA’s networks of SBDCs and WBCs.
SBDCs – The Office of Small Business Development Centers (OSBDC) oversees a
network of 62 lead centers and over 900 service centers that provide training and
technical assistance to help small business owners succeed and help aspiring
entrepreneurs achieve the American dream of business ownership. Each center has a
director, staff members, volunteers, and part-time personnel. SBDCs also use paid
consultants and other professionals from the private sector to help clients who need
specialized expertise. As of May 2020, OSBDC awarded all 62 SBDCs CARES Act
cooperative agreements, totaling $191.6 million.
WBCs – The Office of Women’s Business Ownership (OWBO) oversees 116 WBCs. The
WBCs promote the growth of women-owned businesses through programs that address

1 Public Law 116-136, CARES Act, Sec. 1103 and 1107 (March 2020).

2
business training and technical assistance. They provide guidance and training on
accessing capital and competing for federal contracts. As of May 2020, of the 116 WBCs,
OWBO awarded 113 WBCs CARES Act cooperative agreements, totaling $44.7 million.
Resource Partner Training Platform
OED awarded one grant totaling $18.6 million to America’s SBDC which teamed up with the
Association of WBCs for the creation of a single centralized online platform hub for COVID-
19 information to implement program requirements that SBA called the Resource Partners
Training Portal (RPTP).The SBA collaborates with America’s SBDC and the Association of
WBCs for many of its entrepreneurial development initiatives. America’s SBDCs and the
Association of WBCs support the nationwide networks of SBDCs and WBCs, respectively.
These nonprofit organizations that promote, inform, support, continuously improve, and
represent the interest of their members.
CARES Act Performance and Reporting Requirements
Section 1103, Entrepreneurial Development (b) (4) of the CARES Act requires that the
agency and the award recipients jointly develop, negotiate, and agree on goals and metrics
for the cooperative agreements and grants.
Further, Section 1103(d)of the CARES Act requires SBA report program performance
results to Congress six months following the enactment date of March 27, 2020, and
annually thereafter.
Previous Work
SBA OIG Report 20-13, Risk Awareness and Lessons Learned from Prior Audits of
Entrepreneurial Development Programs (April 23, 2020). Earlier this year, we informed
the SBA of lessons and risks found in audits and other reviews that it should consider as it
administers federal funds related to the COVID-19 pandemic. We provided key points for
the SBA to consider in ensuring the integrity of SBA entrepreneurial development
programs and to mitigate fraud. We suggested the SBA should establish clear oversight
requirements in the notices of awards, ensuring program officials and grant recipients
implement increased internal controls. We also recommended that it establish outcome-
oriented performance measures specific to entrepreneurial development COVID-19
priorities. We also suggested that the agency establish methodology to ensure funds are
appropriately allocated to the resource partners.
SBA OIG Report 19-02, Consolidated Findings of Office of Inspector General Reports on
SBA’s Grant Programs, Fiscal Years 2014–2018 (Nov. 8, 2018). We identified systemic
issues with the SBA’s financial and performance oversight of multiple grant programs—
specifically, the SBA’s ineffectual process of monitoring how grant recipients spent federal
funds and assess performance of its grant programs. We found that the SBA’s decentralized
grants management function hindered agency-wide improvements to the grant
management process. As a result, SBA grant programs were at risk of funds not being used
for the intended purpose and not achieving program goals and objectives. The audit report
included four recommendations, which the SBA implemented.

3
Objective
The objective was to determine whether the SBA awarded the CARES Act entrepreneurial
development cooperative agreements and grants in accordance with applicable federal
laws, regulations, and other guidance.

4
Finding: SBA Awarded CARES Act Entrepreneurial Development
Cooperative Agreements and Grant as Required but Could Improve
Performance Goals and Establish Targets
Program officials awarded the six CARES Act entrepreneurial development cooperative
agreements and one grant that we reviewed in accordance with the applicable federal laws,
regulations, and guidance. The awarded cooperative agreements and grant provided funds
to the intended recipients in support of small businesses affected by the Coronavirus
pandemic.
Although we found program officials established performance goals and identified
performance indicators, the performance goals were broad and inconsistent with federal
requirements for establishing performance goals. Further, program officials did not set
targets for the performance indicators. These requirements are essential for program
officials to accurately assess and interpret results.
Program officials told us that SBA’s strategy for awarding the CARES Act entrepreneurial
development cooperative agreements and grants was to ensure that applications were
complete, budgets were reasonable, and activities engaged were allowable under the law.
Program officials explained that the performance requirements for goals and measures
were negotiated with the recipients as required by the CARES Act. Though they established
performance goals and indicators, program officials told us that they focused on awarding
the cooperative agreements and grants expeditiously to ensure the resource partners were
able to provide immediate assistance to small businesses rather than establishing
performance targets. Without clearly defined performance goals and establishing
performance targets, SBA cannot effectively measure and accurately report performance
results.
Performance Goals Should be Clearly Defined and Performance Targets
Established
Federal government goal setting standards recommend that performance goals be clearly
stated and defined with a consistent calculation methodology. Further, the U.S. Office of
Management and Budget (OMB) issued guidance to federal agencies provided
supplemental funding in response to the pandemic. OMB requires agencies manage and
align funding and award programs with their mission performance objectives and plans
and review the progress as part of their performance consistent with OMB Circular A-11
and A-123 compliance requirements.2 Circular A-11 states agency leaders at all levels are
accountable for choosing goals and indicators wisely and for setting ambitious yet realistic
targets. Program officials should set goals and establish indicators that reflect a careful
analysis of the problems and opportunities to their agency’s mission.3

2 OMB Memorandum M-20-21, Implementation Guidance for Supplemental Funding Provided in Response to the
Coronavirus Disease 2019 (COVID-19) (April 2020).
3 OMB Circular A-11, Preparation, Submission, and Execution of the Budget, Part 6 (June 2019).

5
SBA did not clearly define the performance goals for the six cooperative agreements and
the one RPTP grant we reviewed (goals and indicators are detailed in Table 1 below). For
example, SBDC program officials set “Capital Assistance” as a performance goal and the
“Number of Clients that received information, counseling and training on Economic Injury
Disaster Loans, Paycheck Protection Program and all SBA disaster loans programs” as the
performance indicators.
Table 1. Examples of Performance Goals and Performance Indicators for the SBDC
and WBC Cooperative Agreements and the RPTP Grant
Programs
Performance Goals
Performance Indicators
SBDC
1. Capital assistance (long-
term goal: capital infusion)
2. Small businesses and
individuals served (long-
term goal: unique clients
served)
3. Consulting hours (long-
term goal: jobs supported)
1. The number of clients who
received information, counseling,
and training on SBA funding
2. The number of clients served
3. The number of hours or jobs
supported
WBC
1. Unique clients served
2. Capital infusion
3. Jobs supported
1. Number of unique clients served
2. Number of transactions processed
to include loans or other forms of
funding
3. Number of jobs retained, saved,
and created
RPTP
1. Develop and evolve online
platform for covered
businesses concerns
2. Develop and evolve
training program for
program counselors
3. Number of counselors
trained
1. Number of visitors, number of
page views, average time on site
2. Number of individual
registrations, active and inactive
users
3. Number of learning modules
started, in progress, and
completed
Source: OIG generated based on funding opportunity announcements for SBDCs and WBCs cooperative agreements and
the RPTP grant performance metrics plan.
Further, although program officials identified performance indicators for all of the CARES
Act entrepreneurial development cooperative agreements in the SBDC and WBC funding
opportunity announcements and in the performance metrics plan for the RPTP grant, they
did not establish performance targets for the goals and indicators.
Program officials told us that they did not require performance targets because they were
focused on providing immediate relief to small businesses affected by the COVID-19
pandemic. Further, program officials explained that they did not establish performance
targets because they did not have enough historical data for comparison. We disagree and
contend that SBA and its resource partners have prior experience responding to disasters.
In fact, we found that one of the SBDC’s workplans included quantifiable performance
targets. SBDC program officials cited “Jobs Supported” as a performance goal, “Number of

6
Jobs Retained and Created” as the performance indicator, and “25,000 Jobs Retained and
Created” as the performance target. Federal goal setting standards recommend that
performance goals have an associated target that is expressed in a numerical value.4 SBA
should establish policies and procedures that require entrepreneurial development
program officials to include performance targets in cooperative agreements and grants so
CARES Act program achievement can be properly assessed.
Recommendations
We recommend that the Administrator require the Associate Administrator for the Office of
Entrepreneurial Development to:
1. Enforce standard operating procedures requiring clearly defined performance goals
and include performance targets in all future SBDC and WBC cooperative
agreements and grants to objectively measure performance results.
2. Collect and analyze the CARES Act entrepreneurial development cooperative
agreement recipient’s performance results and establish a framework for setting
goals for technical assistance programs in response to future disasters. Retain the
analysis in program files for future guidance.

4 U.S. Government Accountability Office-14-704G, Standard for Internal Control in the Federal Government (September
2014).

7
Analysis of Agency Response
SBA management provided formal comments to the draft report (see Appendix II). SBA
management agreed with recommendations 1 and 2. Subsequent to receiving
management’s written comments, we met with OED officials to clarify their proposed
corrective actions and implementation timelines. Based on our discussion, we determined
that management’s proposed corrective actions resolved both recommendations.
Summary of Actions Necessary to Close the Recommendations
The following details the status of our recommendations and the actions necessary to close
them.
Recommendation 1
Resolved. SBA management concurred with this recommendation and plans to define
performance goals and establish targets through the creation of more comprehensive,
integrated, and strategic approach that aligns OED program goals with the agency mission.
Management plans to complete final action on this recommendation by July 30, 2021. This
recommendation can be closed when management provides evidence that they
implemented clearly defined performance goals and included performance targets in future
entrepreneurial development cooperative agreements and grants to objectively measure
performance results.
Recommendation 2
Resolved. SBA management concurred with this recommendation and plans to develop a
data collection system to collect and analyze future cooperative agreement performance
results establishing framework for setting defined performance goals. SBA management
plans to use OED program logic models to help with establishing realistic and measurable
program goals and targets. Management plans to complete final action on this
recommendation by October 15, 2021. This recommendation can be closed when
management provides evidence that they implemented processes that ensures program
officials collects and retains current, accurate and complete program data and analyze the
performance results to establish a framework for setting goals for future OED technical
assistance programs.

8
Appendix I: Objective, Scope, and Methodology
Objective
Our objective was to determine whether SBA awarded the CARES Act entrepreneurial
development cooperative agreements and grants in accordance with applicable federal
laws, regulations, and other guidance.
Scope and Methodology
Our scope covered all CARES Act entrepreneurial development cooperative agreements
and grants with an authorized total amount of $265 million. Of that amount, SBA awarded
about $255 million in 176 cooperative agreements and a grant to SBDCs, WBCs, and
America’s SBDC from April to May 2020.
To determine whether SBA complied with the CARES Act, we selected six CARES Act
cooperative agreements and one grant to review. Table 2 details these agreements totaling
$41.6 million. For the SBDCs, we selected the two highest dollar cooperative agreement
awards. We selected four WBCs cooperative agreements awarded and the one grant
awarded to America’s SBDC.
Table 2. Selected CARES Act Entrepreneurial Development Cooperative Agreements
and Grant
Recipient Name
Cooperative Agreement
and Grant Number
Total Award Amount
University of West Florida
SBAHQ-20-C-0022
$10,708,984
Research Foundation for the
State University of New
York
SBAHQ-20-C-0023
$11,037,517
Women's Business
Development Council
SBAHQ-20-C-0093
$420,000
Latin American Economic
Development Association
SBAHQ-20-C-0175
$27,667
Mercy Corps
SBAHQ-20-C-0003
$415,539
Cornerstone Alliance &
Chamber of Commerce
Services
SBAHQ-20-C-0147
$409,540
America’s SBDC
SBAHQ-20-C-0118
$18,583,543
Total Award Amount
--
$41,602,790
Source: OIG generated based on notice of awards.

9
To achieve our objective, we reviewed the requirements in the CARES Act, funding
opportunity announcements for the SBDCs, WBCs, and America’s SBDC, applicable SBA
policy directives, and OMB memorandums.
For each cooperative agreement and grant award selected, we reviewed the special terms
and conditions; SBA Form 1222, Notice of Award; SBA Form 1223, Approval List; SBA Form
424, Application for Federal Assistance; SBA Form 424A, Budget Information; SF-270,
Request for Advance or Reimbursement; Work Plan Narrative; Budget Narrative; Annual
Budget Summary Worksheets (Cost Price Analysis Workbook) and all other required
documentation.
We reviewed award documentation to determine whether SBA officials included all
applicable CARES Act provisions, Public Law 116-136, Sections 1103 (b-c) and 1107, in the
funding opportunity announcements, terms and conditions, or any relevant award
documentation. We examined award documentation to determine whether SBA met the
requirements of federal regulations and other guidance. We determined whether SBA
officials evaluated the CARES Act proposals from the SBDCs, WBCs, and America’s SBDC in
accordance with SBA award policies and procedures.
In addition, we interviewed SBA personnel from OSBDC, OWBO, OED, and the Office of
Grants Management that administered the CARES Act entrepreneurial development
cooperative agreement and grant awards. We also used the laws, regulations, and SBA
policies in accordance with the CARES Act as a basis for our evaluation.
We conducted this evaluation in accordance with the Council of the Inspectors General on
Integrity and Efficiency Quality Standards for Inspection and Evaluation. These standards
require that we adequately plan and perform the evaluation to obtain sufficient and
appropriate evidence to provide a reasonable basis for our findings and conclusions based
on our objective. We believe that the evidence we obtained provides a reasonable basis for
our findings and conclusions based on our evaluation objective.
Use of Computer-Processed Data
We relied on computer-processed data in the program office files. Specifically, we retrieved
SBA’s list of all cooperative agreements and grants awarded pursuant to the CARES Act. We
tested the reliability of the data in the program office files by comparing award information
to publicly available federal award information at USAspending.gov. We believe the
computer-processed information is reliable for the purposes of this evaluation.

10
Appendix II: Management Comments
SBA RESPONSE TO EVALUATION REPORT

DATE:
March 5, 2021
TO:
Hannibal “Mike” Ware
Inspector General
FROM:
Adriana Menchaca-Gendron
Deputy Associate Administrator
Office of Entrepreneurial Development
SUBJECT:
Evaluation of SBA’s Award Procedures for the Coronavirus Aid, Relief and Economic
Security Act Entrepreneurial Development Cooperative Agreements
Thank you for the opportunity to respond to the draft report entitled, “Evaluation of SBA’s Award
Procedures for the Coronavirus Aid, Relief and Economic Security Act Entrepreneurial Development
Cooperative Agreements (Project No. 20015)”. The objective of this audit was to determine whether
SBA awarded the CARES Act entrepreneurial development cooperative agreements and grants in
accordance with applicable federal laws, regulations, and other guidance.
The Office of Entrepreneurial Development (OED) appreciates the role that the Office of the Inspector
General plays in working with the Agency’s management in ensuring our programs are effectively
administered.  We also appreciate the courtesies and cooperation extended to us during this audit and
the collaborative way our teams worked together to complete this work.
One of OED’s priorities is to ensure our entrepreneurial development programs continue to be
effective, efficient, and accountable to our stakeholders, including taxpayers.  In accordance with
Section 1103, Entrepreneurial Development (b)(4) of the CARES Act, OED worked very closely with the
leadership of the America’s SBDC and the Association of Women’s Business Owners to develop the
funding opportunity announcement and the terms and conditions of the grant as well as establish the
grant’s performance goals and metrics.  OED also served on the integrated agency-wide team
established to coordinate SBA’s internal oversight of the new CARES Act programs and funds.
We will continue to strengthen the Agency’s oversight and administration of the entrepreneurial
programs.  The OED management team is committed to ensuring the Agency’s entrepreneurial
development programs serve the Nation’s small businesses to the maximum potential, and especially
small businesses impacted by the COVID-19 pandemic.  We will work expeditiously to ensure the
recommendations below are resolved.

2
Recommendation 1:  Enforce standard operating procedures requiring clearly defined performance
goals and include performance targets in all future SBDC and WBC cooperative agreements and grants
to objectively measure performance results.

Explanation of Proposed Action:  OED agrees with this recommendation.  To the maximum
extent permitted by law, OED will improve planning that includes a more comprehensive,
integrated, and strategic approach to defining performance goals and targets that support the
SBA’s mission as well as align with the Agency’s goals and subsequently with OED’s Program
goals.  While OED resource partners have annual performance goals, we acknowledge that the
unique nature of the COVID-19 nationwide pandemic demanded the immediate provision of
information and services without a comparable methodology.

Status: Ongoing

Recommendation 2: Collect and analyze the CARES Act entrepreneurial development cooperative
agreement recipient’s performance results and establish a framework for setting goals for technical
assistance programs in response to future disasters. Retain the analysis in program files for future
guidance.

Explanation of Proposed Action:  OED agrees with this recommendation. To the maximum
extent permitted by law, OED will continue to develop and improve its data collection system
to collect and analyze cooperative agreement performance results.  OED will also utilize
program logic models to assist with establishing a framework for setting goals.  OED will
maintain a shared folder to store files for future guidance.

Status:  Ongoing.

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