OIG Final Report 21-18 Evaluation of SBA's Coronavirus Reconstitution Plan

Summary

SBA Office of Inspector General evaluation report 21-18, Evaluation of SBA's Coronavirus Reconstitution Plan, dated July 12, 2021 and sent by Inspector General Hannibal "Mike" Ware to Administrator Isabella Casillas Guzman. The OIG reviewed whether SBA's May 2020 COVID-19 Reconstitution Plan for returning employees, contractors and visitors to its offices followed federal guidance and whether SBA followed it. It found the plan met federal guidance, but that SBA did not follow occupancy procedures for advancing or reverting phases at its Washington, DC headquarters and did not consistently trace cases, notify staff, contact potentially exposed personnel or ensure 14-day quarantines, based on 19 of the 231 cases in its tracker as of January 4, 2021. The OIG recommends SBA enforce its February 2021 COVID-19 Workplace Safety Plan, and management concurred.

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EVALUATION OF SBA’S CORONAVIRUS
RECONSTITUTION PLAN
REPORT NUMBER 21-18 | JULY 12, 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 SUMMARY

EVALUATION OF SBA’S CORONAVIRUS RECONSTITUTION PLAN
Report No.
21-18

July 12, 2021

What OIG Reviewed
We evaluated actions the Small Business
Administration (SBA) took to responsibly
return employees, contractors, and visitors to
SBA offices.
Our objectives were to determine (1) whether
the
agency
established
a
COVID-19
reconstitution plan in accordance with
applicable federal guidance and (2) if the
agency adhered to that plan.
To answer our objectives, we reviewed SBA’s
Coronavirus
Disease
2019
(COVID-19)
Reconstitution Plan, White House and Centers
for Disease Control and Prevention (CDC)
Opening Up America Again guidelines. We also
reviewed other federal guidelines from the
Office of Personnel Management, the Office of
Management
and
Budget,
and
the
Occupational
Safety
and
Health
Administration. In addition, we reviewed
SBA’s policies and procedures used to mitigate
the risk of COVID-19 exposure to SBA
employees to include the February 2021
COVID-19 Workplace Safety Plan which
replaced
the
Agency’s
COVID-19
Reconstitution Plan established in May 2020.
We interviewed the SBA officials who
established and implemented the plans and
obtained supporting documentation. We
selected the only two occupancy decisions for
SBA’s Washington DC headquarters available
to verify whether SBA adhered to its
procedures. We also selected 19 of the 231
individual COVID-19 cases that SBA reported
in its COVID-19 tracker as of January 4, 2021,
to verify whether SBA adhered to its exposure
tracking procedures.
What OIG Found
SBA established its May 2020 COVID-19
Reconstitution Plan in accordance with
applicable federal guidance. The SBA replaced
the reconstitution plan with its new COVID-19

Workplace Safety Plan in February 2021. We
identified issues with the implementation of
the May 2020 reconstitution plan that should
be addressed to help the agency safeguard its
employees from contracting and spreading
COVID-19 in the workplace. Specifically, we
found agency did not follow occupancy
procedures for advancing, or reverting phases
at the Washington, DC headquarters. SBA also
did
not
implement
exposure
tracking
protocols to ensure it consistently traced
COVID-19 cases. We found the agency did not
consistently notify its staff of presumed or
confirmed COVID-19 cases in the sampling of
cases we analyzed. SBA did not consistently
contact potentially exposed personnel and
ensure
employees
completed
14-day
quarantine periods.
OIG Recommendation
We recommend SBA enforce the requirements
of the February 2021 COVID-19 Workplace
Safety
Plan
by
consistently
applying
procedures for occupancy and exposure
tracking and accurately record and maintain
supporting documentation for all reported
COVID-19 cases.
Agency Response
SBA
management
concurred
with
our
recommendation to enforce the requirements
of its February 2021 COVID-19 Workplace
Safety Plan and its planned actions resolve the
recommendation. SBA officials plan to track
and document cases of exposure with an
emphasis on maintaining both workforce
safety and individual privacy

Office of Inspector General
U.S. Small Business Administration

DATE:
July 12, 2021

TO:

Isabella Casillas Guzman

Administrator

FROM:
Hannibal “Mike” Ware
Inspector General

SUBJECT:
Evaluation of SBA’s Coronavirus Reconstitution Plan

This report represents the results of our evaluation of SBA’s Coronavirus Reconstitution
Plan. We considered management comments on the draft when preparing the final report
and SBA management agreed with our recommendation. Based on management’s
comments, we have updated finding 2 to consistently describe SBA’s efforts to trace and
isolate COVID-19 cases as exposure tracking instead of contact tracing.
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:
Antwaun Griffin, Chief of Staff
Arthur Plews, Deputy Chief of Staff
Peggy Delinois Hamilton, General Counsel
Stephen Kong, Acting Chief Operating Officer and Acting Deputy General Counsel
Elias Hernandez, Chief Human Capital Officer, Office of Human Resource Solutions
Kenneth Etheridge, Acting Executive Director, Office of Executive Management,
Installation and Support Services
Jason Bossie, Acting Associate Administrator for Performance, Planning, and the
Chief Financial Officer
Martin Conrey, Attorney Advisor, Office of General Counsel
Michael Simmons, Attorney Advisor, Office of General Counsel
Joshua Barnes, Acting Director, Office of Continuous Operations and Risk
Management
Tonia Butler, Director, Office of Internal Controls

Table of Contents
Introduction ............................................................................................................................................................ 1
Federal Guidance .............................................................................................................................................. 1
COVID-19 Agency-wide Pandemic Reconstitution Plan Issued May 2020 ................................ 2
Updated Federal Guidance ............................................................................................................................ 3
Updated COVID-19 Workplace Safety Plan Issued February 2021 ............................................... 3
Previous Work ................................................................................................................................................... 4
Objectives ............................................................................................................................................................ 4
SBA’s COVID-19 Reconstitution Plan Incorporated Federal Guidance Allowing for the Safe
Return of its Workforce. ..................................................................................................................................... 5
Management Actions ....................................................................................................................................... 5
Consistent Application of Occupancy and Exposure Tracking Procedures are Needed to
Successfully Implement SBA’s Workforce Health and Safety Safeguards. ...................................... 6
Occupancy ........................................................................................................................................................... 6
COVID-19 Exposure Tracking and Notifications .................................................................................. 7
Recommendation .............................................................................................................................................. 9
Analysis of Agency Response ........................................................................................................................ 10
Summary of Actions Necessary to Close the Recommendation .................................................. 10
Appendix I: Objectives, Scope, and Methodology .................................................................................. 11
Objectives ......................................................................................................................................................... 11
Scope and Methodology .............................................................................................................................. 11
Use of Computer-Processed Data ............................................................................................................ 11
Appendix II: Management Comments ........................................................................................................ 13

1
Introduction
On March 11, 2020, the World Health Organization declared the Coronavirus Disease 2019
(COVID-19) a pandemic. Following this declaration, federal agencies issued health, safety,
and travel guidelines for employers to use in developing plans to help identify risk levels in
workplace settings and to determine appropriate control measures.
Federal Guidance
On April 16, 2020, the White House in conjunction with the Centers for Disease Control and
Prevention (CDC) issued the Opening Up America Again guidelines.1 It outlined a three-
phased, data-driven approach to help federal, state, and local officials reopen their
economies and get people back to work safely.
Federal agencies were required to develop and implement agency-specific policies and
procedures in accordance with federal regulations and industry best practices regarding:
• social distancing and personal protective equipment (PPE);
• temperature checks;
• testing, isolation, and contact tracing;
• sanitation;
• use and disinfection of common and high-traffic areas; and
• business travel.
On May 26, 2020, in support of Opening Up America Again, the CDC provided guidelines for
federal agencies to safely return their employees to the workplace.2 The CDC guide
explained a three-phased re-entry strategy based on analysis of community infection rate
trends and healthcare system capacities. Table 1 shows the CDC gating criteria, which
describes six conditions and thresholds to be considered as federal agencies progress
toward reoccupying workplaces.
Table 1. CDC Gating Criteria
No. Condition
Threshold for Phase 1 Occupancy
1.
Decrease in newly identified COVID-19
cases
14-day downward trajectory (or
near-zero incidence) of COVID-19
cases
2.
Decrease in emergency room visits for
COVID-like illness
14-day downward trajectory (or
near-zero incidence) of COVID-19
cases
3.
Decrease in emergency room visits for
influenza-like illness
14-day downward trajectory (or
near-zero incidence) of influenza-
like illness

1 Opening Up America Again (April 2020).
2 CDC Activities and Initiatives Supporting the COVID-19 Response and the President’s Plan for Opening America Up Again
(May 2020).

2
4.
Decrease in percentage of positive severe
acute respiratory syndrome coronavirus 2
(SARS-CoV-2, the virus that causes COVID-
19) tests
14-day downward trajectory (or
near-zero incidence) of positive tests
as a percentage of total tests
5.
Treat all patients without crisis care
Intensive care beds less than 80
percent full, more than 4-day supply
of personal protective equipment
6.
Robust testing
Test results available in less than 4
days
Source: OIG generated based on CDC Activities and Initiatives Supporting the COVID-19 Response
and the President’s Plan for Opening America Up Again.
Federal guidance recommends agencies to develop policies and procedures for employees
to report when they are sick or experiencing symptoms of COVID-19 and actively
encourage sick employees to stay home. In addition, federal guidance recommended
employers implement a contact tracing process so appropriate restrictions could be
implemented.
COVID-19 Agency-wide Pandemic Reconstitution Plan Issued May 2020
In response to the COVID-19 pandemic, the former SBA Administrator established a
command center to oversee all COVID-19 related efforts, including the safe return of the
workforce to SBA offices. The command center consisted of three teams that drafted and
finalized the SBA COVID-19 Agency-Wide Pandemic Reconstitution Plan.3 On May 15, 2020,
the then Administrator approved and distributed the plan. The purpose of the plan was to
provide SBA leaders with guidance to safely return SBA employees to their workplaces.
SBA has over 177 offices located throughout the 50 states, District of Columbia, and 5
territories with workplace occupancy ranging from 1 to 900. The reconstitution plan
allowed SBA management the flexibility to establish health and safety strategies specific to
each SBA office.
At a minimum, the plan required SBA managers to consider community infection trends, to
include state and region as described in the CDC gating criteria, prior to advancing to the
next occupancy phase.
• Phase 1 – Maximum of up to 25 percent staff occupancy
• Phase 2 – Maximum of up to 50 percent staff occupancy
• Phase 3 – Maximum of up to 75 percent staff occupancy
The plan also required all SBA offices to be sanitized using commercial-grade disinfectant
on accessible surfaces before the start of phase 1 for staff occupancy. The plan further
required that following occupancy, the building’s common area will continue to be
regularly cleaned in accordance with General Services Administration’s guidelines.
The SBA reconstitution plan included workforce health and safety protocols necessary to
control the spread of COVID-19. The protocols included social distancing practices,
personnel security to protect employees from verbal or physical threats, and health

3 SBA COVID-19 Agency-Wide Pandemic Reconstitution Plan (May 2020).

3
screening services to prevent staff who have COVID-19 symptoms from entering the
workplace.
The plan promoted the maximization of telework and other workforce flexibilities as
authorized by the Office of Personnel Management and Office of Management and Budget
(OMB) guidelines.4 In addition, the plan include Occupational Safety and Health
Administration (OSHA) guidelines on infection controls through the enforcement of social
distancing requirements.5
SBA provided virtual COVID-19 training designed to educate, inform, and prepare its
employees and supervisors on returning to the workplace. The supervisor training
included instructions on handling COVID-19 matters during occupancy phases.
Updated Federal Guidance
On January 20, 2021, the Administration issued new federal guidance requiring agencies to
develop agency-tailored COVID-19 workplace safety plans.6 It also asked agencies to
designate their own individual COVID-19 coordination teams. The new guidance provided
model safety principles for federal agencies to follow, including:
• requiring mask wearing and social distancing in all federal buildings and
land;
• establishing testing methodologies and protocols;
• investigating cases and contact tracing; and
• accessing and acquiring sufficient equipment, including PPE.
To protect the safety of the federal workforce and reduce community spread of COVID-19,
the updated guidance mandated agencies establish a staffing plan and limit occupancy
levels at or below 25 percent of normal occupancy standards during periods of high
community infection transmission.
Updated COVID-19 Workplace Safety Plan Issued February 2021
In response to the new federal guidance, agency management issued the SBA COVID-19
Workplace Safety Plan in February 2021, replacing the COVID-19 Reconstitution Plan
established in May 2020. The new plan outlined the Agency policies and requirements
regarding COVID-19 related matters that may affect the health and safety and workplace
operations.
To implement the new plan, SBA established the COVID-19 coordination team. The
coordination team consists of several agency senior leaders from SBA Headquarters and
field offices. The SBA coordination team is responsible for:

4 OMB Memorandum M-20-13, Updated Guidance on Telework Flexibilities in Response to Coronavirus (March 2020).
5 OSHA 3990-03, Guidance on Preparing Workplaces for COVID-19 (March 2020).
6 Executive Order 13991, Protecting the Federal Workforce and Requiring Mask-Wearing (January 2021); White House
National Strategy for the COVID-19 Response and Pandemic Preparedness (January 2021); OMB Memorandum M-21-15,
COVID-19 Safe Federal Workplace: Agency Model Safety Principles (January 2021).

4
• establishing, implementing, and monitoring compliance with safety
protocols.
• updating the current COVID-19 workplace safety plan as necessary in
consultation with the Safer Federal Workforce Task Force, established to
provide ongoing guidance to heads of agencies.
• developing staffing plans that outlines which employee will work on-site full
time, on-site occasionally, or fully remote.
• determining appropriate workplace closures for suspected or confirmed
cases of COVID-19 in the workplace.
• collaborating and supporting local health departments’ contact tracing
programs to help identify, track, and manage contacts of COVID-19 cases.
The February 2021 plan identified specific roles and responsibilities for SBA employees
and supervisors. SBA managers are expected to take proper precautions to maintain
occupancy levels when community-level transmission is high. SBA management notified
staff that noncompliance with the planned safety protocols may result in disciplinary action
or penalties.
SBA provided virtual training on the February 2021 plan, which included question and
answer sessions. Similar sessions were done for the May 2020 plan.
Previous Work
We have not completed previous work of the evaluation subject matter.
Objectives
Our objectives were to determine (1) whether the agency established a COVID-19
reconstitution plan in accordance with applicable federal guidance and (2) if the agency
was adhering to that plan.

5

SBA’s COVID-19 Reconstitution Plan Incorporated Federal
Guidance Allowing for the Safe Return of its Workforce
SBA incorporated federal guidance in its May 2020 COVID-19 Reconstitution Plan. The
reconstitution plan identified roles and responsibilities for SBA officials and included the
following pandemic prevention measures:
• expanding and maximizing telework policy;
• limiting workspace in accordance with occupancy phases;
• cleaning and sanitizing facilities;
• providing adequate personal protective equipment;
• restricting common areas;
• limiting non-essential business travel throughout all occupancy phases;
• installing social distancing markings and signage; and
• staffing health screeners at entrances.
As a result of incorporating the federal guidance, SBA appropriately planned for the safe
and gradual return of SBA workers to offices.
Management Actions
In response to the new federal guidance, the agency issued the SBA COVID-19 Workplace
Safety Plan in February 2021, replacing the COVID-19 Reconstitution Plan of May 2020.

6

Consistent Application of Occupancy and Exposure Tracking
Procedures are Needed to Successfully Implement SBA’s
Workforce Health and Safety Safeguards
While we recognize SBA instituted its COVID-19 Workplace Safety Plan in February 2021,
our review of the May 2020 COVID-19 Agency-wide Pandemic Reconstitution Plan for
occupancy, identified issues that should be addressed for successful implementation of the
new plan. SBA did not always adhere to the original occupancy plan and did not
consistently implement COVID-19 exposure tracking procedures to provide for the safe
return of its workforce. For instance, SBA decided to return workers to SBA headquarters
and advance through occupancy phases but did not provide support that showed all the
CDC gating conditions were met. SBA did not downgrade phases during periods of
community COVID-19 resurgence or when a case was reported at headquarters. SBA
leadership was responsible for making decisions regarding occupancy phases and did not
revert phases consistently with available data points. Consequently, SBA employees could
not rely on the designated phase of operation to accurately reflect the current pandemic
risk environment within headquarters.
SBA could improve its exposure tracking procedures based on the 19 cases of presumed,
exposed, or confirmed COVID-19 cases we reviewed. Specifically, SBA should consistently:
• notify staff of presumed or confirmed COVID-19 cases,
• contact potentially exposed personnel, and
• ensure employees completed 14-day quarantine periods before returning to
the workplace.
To successfully implement adequate exposure tracking procedures moving forward, the
agency should ensure these inconsistencies are addressed to mitigate the risks of spreading
COVID-19 infections within its workforce.
The February 2021 SBA COVID-19 Workplace Safety Plan set expectations for the
supervisors to implement a range of operational controls that limit occupancy at or below
25 percent of the normal headcount. The plan required the agency to consider surrounding
community infection rates as a condition of occupancy, consistent with the new federal
guidelines. In addition, the plan included exposure tracking and reporting processes that
were similar to the procedures in the May 2020 reconstitution plan. The February 2021
plan established supervisor and employees’ responsibilities and required affected staff to
quarantine for 14 days. If SBA leadership enforces these operational controls, the agency
will be able to better safeguard its employees from contracting and spreading COVID-19.
Occupancy
The May 2020 plan stated SBA managers would make their decisions to advance through
office reoccupation phases based on local conditions. The plan said each office location
would be evaluated according to CDC gating criteria and other factors, including access to
public transportation and building capacity for safe social distancing. To assess the CDC
gating criteria for its 177 offices, SBA relied on CDC-endorsed data it received daily from
the Department of Health and Human Services.

7
On June 29, 2020, SBA advanced to phase 1, allowing up to 25 percent of staff to occupy the
headquarters building. SBA management cited that Washington Metropolitan Area Transit
Authority stations were re-opened, health and safety measures were taken, and employees
had access to agency-provided PPE. SBA advanced to phase 2 on September 14, 2020,
allowing up to 50 percent of staff to occupy the building. SBA officials asserted that they
justified the phase advancement decision by monitoring local conditions, specifically
having awareness of downward infection trends, healthcare system capacity, status of
public transportation, and status of building projects to improve staff access to the facility.
However, they were unable to demonstrate that proper CDC-recommended conditions
were met when deciding to advance to phases 1 and 2 at SBA headquarters.
The May 2020 plan also provided authority to SBA officials to revert phases as necessary to
lessen the health and safety risk to employees. The plan called for monitoring and assessing
multiple factors including local conditions.  The plan also required that during any phase, if
there is a development of a positive COVID-19 case, the office should revert phases.
However, despite detecting incidences of positive COVID-19 cases at SBA headquarters, the
agency did not revert from phase 1 or phase 2. Similarly, SBA did not revert from phase 2
despite a resurgence of COVID-19 in the local community in November and December
2020. SBA officials did not provide reasonable justification or rationale on that decision,
indicating that they made occupancy decisions based on multiple conditions not a single
data point like community infection spread.
The February 2021 plan directs agency management to consider moving to the next phase
only when less than 100 new COVID-19 confirmed infections are reported for every
100,000 people in the area of an SBA office. In the event of a resurgence, agency managers
should consult with the newly created SBA COVID-19 coordination team. These operational
controls, if enforced, should help SBA better safeguard its employees from contracting and
spreading the COVID-19.
COVID-19 Exposure Tracking and Notifications
The May 2020 plan outlined supervisor and employee expectations when faced with a
COVID-19 case. Employees who experience symptoms, are exposed, or test positive for
COVID-19 should report it immediately to their supervisor. The plan required that the
supervisor report the case to the command center. The command center was required to
notify colleagues who may have been exposed. The plan instructed exposed and sick
employees to remain at home for 14 days. SBA’s Office of Administrative Services
coordinates with the SBA facility management on cleaning and sanitizing affected areas.
SBA did not consistently adhere to its exposure tracking procedures. Of the 19 cases we
reviewed, SBA adhered to these procedures 34 percent of the time. None of the presumed,
exposed, or confirmed case files contained all supporting documentation. Although the May
2020 reconstitution plan required employees who were exposed, presumed, or confirmed
to have COVID-19 to telework or use sick leave, employees and supervisors did not
consistently adhere or enforce the requirement respectively. We requested time sheets for
the 19 cases we selected for review. The command center told us that they were unable to
provide time sheets for five of the cases because the employee’s supervisors reported the
exposed, presumed, or confirmed COVID-19 case without identifying the employee’s name.
The command center provided time sheets for 14 cases. Of the 14 time sheets, only 6

8
showed the employee was either on telework or sick leave status consistent with
completing quarantine period.
As part of its planned COVID-19 exposure mitigation protocols, SBA’s command center was
required to contact potentially affected employees to inquire on the extent of contact with
other employees and requested the employee answer a COVID-19 exposure tracking
questionnaire. Of the cases we reviewed, SBA provided evidence that it contacted and
obtained responses from only 7 of the 19 potentially affected employees.
Federal standards for internal controls require management to clearly document internal
controls and all significant operational transactions in a manner that allows the
documentation to be readily available for examination, demonstrating management met its
compliance responsibilities.7 In the absence of documented exposure tracking efforts, SBA
did not provide evidence that its COVID-19 prevention procedures were consistent with
the CDC and other federal guidelines.
In addition, we reviewed five notifications SBA sent to DC Headquarters employees and
found only two notifications that related to the cases recorded in SBA’s COVID-19 Tracker.
We determined the COVID-19 Tracker was unreliable because SBA did not provide
sufficient support documentation. The COVID-19 Tracker likely underreported the number
of reported cases in the agency. SBA used the COVID-19 tracker to manage its exposure
tracking responsibilities and relied on this information for making decisions involving
COVID-19 infections.
The January 2021 OMB guidance8 required employers to support local health departments’
contact tracing programs by identifying, tracking, and managing employees’ potential
contact to exposed colleagues. Following the guidance, SBA established the February 2021
plan. Although SBA recognized contact tracing as a specialized skill requiring training, the
new plan established exposure tracking and reporting processes for the following
scenarios:
• Employee may have been exposed but has not been in the office within the
last 14 days.
• Employee tested positive or is presumed to have contracted COVID-19 in the
office within the last 14 days.
• Employee tested or presumed to have contracted COVID-19 but has not been
in the office within the last 14 days.
In addition, the February 2021 plan outlined supervisor and employees’ roles and
responsibilities, as well as mandating all COVID-19 affected employees to quarantine for 14
days. The plan established disciplinary actions to enforce compliance with the required
quarantine period. If SBA management follows exposure tracking procedures and ensures
employees quarantine according to the plan, they will help mitigate risks of spreading
COVID-19 in the workplace.

7 Government Accountability Office GAO-14-704G, Standards for Internal Control in the Federal Government (September
2014).
8 OMB Memorandum M-21-15, COVID-19 Safe Federal Workplace: Agency Model Safety Principles (January 2021).

9
Recommendation
We recommend that the Administrator require the SBA COVID-19 coordination team to:
Enforce the requirements of the February 2021 COVID-19 Workplace Safety Plan by
consistently applying occupancy and exposure tracking and accurately recording and
maintaining supporting documentation for all reported COVID-19 cases.

10
Analysis of Agency Response
SBA management provided formal comments to the draft report (see Appendix II). SBA
management agreed with the recommendation and the proposed corrective actions
resolved the recommendation.
In its response, SBA explained a primary reason for not providing sufficient support
documentation for exposure tracking was that SBA supervisors protected their employees’
privacy by not providing the specific names of individuals with a positive COVID-19
infection. However, our findings indicate that only 5 of the 19 tested reports lacked the
name of the employee. As such, the concerns noted in this report regarding adhering to
exposure tracking requirements in the Reconstitution Plan were not limited and not solely
attributable to actions taken by supervisors to protect employees’ privacy. SBA’s February
2021 COVID-19 Workplace Safety Plan states that medical information, including test
results and any other medical information, will be treated according to applicable law. It
will be accessible only to those who need to protect the health and safety of SBA personnel.
It is important that SBA adhere to its exposure tracking procedures, requiring officials to
collect information and safeguard employees’ privacy.
Summary of Actions Necessary to Close the Recommendation
Recommendation
Enforce the requirements of the February 2021 COVID-19 Workplace Safety Plan by
consistently applying occupancy and exposure tracking and accurately recording and
maintaining supporting documentation for all reported COVID-19 cases.
Status: Resolved.
SBA management concurred with the recommendation and noted they will follow the
protocol established in the February 2021 COVID-19 Workplace Safety plan. Management
plans to complete final action on this recommendation by December 31, 2021. This
recommendation can be closed when SBA management provides evidence that procedures
for occupancy and exposure tracking are being followed in accordance with its February
2021 COVID-19 Workplace Safety plan.

11
Appendix I: Objectives, Scope, and Methodology
Objectives
Our audit objectives were to determine whether SBA established a COVID-19
reconstitution plan in accordance with applicable federal guidance and if SBA was adhering
to that plan.
Scope and Methodology
Our scope covered all actions taken by SBA to prevent workplace exposure to COVID-19
from March 11, 2020 to December 31, 2020. To achieve our objective, we reviewed federal
guidance including from the Centers for Disease and Control, Office of Management and
Budget, Office of Personnel Management, and Occupational Safety and Health
Administration. We reviewed SBA’s COVID-19 Reconstitution Plan, procedural notices, and
other COVID-19 positive case tracking tools used to comply with CDC requirements.
We interviewed SBA personnel responsible for establishing and implementing the agency-
wide Reconstitution Plan. We also reviewed agency actions and its implementation of the
occupancy phases. We reviewed supporting documentation and justification provided for
management decisions to move to the next phases, including whether management
decisions considered CDC gating criteria on community spreads over 14-day downward
infection trends.
As of January 4, 2021, the agency’s COVID-19 Tracker contained 231 cases, of which 118
were confirmed while the remaining 113 cases were contact-exposures. We judgmentally
selected 19 COVID-19 cases to review whether SBA adhered to its planned exposure
tracking procedures, Thirteen of 19 individual cases were identified in the Washington DC
headquarters location, while the remaining 6 cases were from a Disaster Assistance
Processing and Disbursement Center in Fort Worth, Texas.
We also judgmentally selected five of the eight notifications SBA sent to its headquarters
employees regarding presumed or confirmed cases of COVID-19 to test the reliability and
completeness of SBA’s COVID-19 Tracker.
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
Although we used computer-processed data throughout this evaluation, we did not rely
solely on the data but confirmed its accuracy and completeness through validations to
originating source documentation. To determine whether SBA appropriately gathered and
managed COVID-19 cases, we tested agency-provided support documentation. We
conducted analytical procedures to verify the completeness and accuracy of available data
used to support COVID-19 Tracker and agency COVID-19 alerts or email notifications sent
to headquarter employees in the Washington DC Metropolitan area. We deemed the

12
agency’s COVID-19 Tracker as unreliable because the agency could not provide all
requested source documentation data. As a result, our opinion is solely based on the result
of our testing of sampled items for review through source documentation. We made a
recommendation to address the completeness and accuracy of the COVID-19 Tracker.
To determine whether management decisions were consistent with the CDC’s gating
criteria regarding community infection rates and improved healthcare conditions, we
reviewed agency justifications and support evidence provided to move through occupancy
phases. We relied on CDC’s published data regarding community spread reported on SBA
surrounding area COVID-19 cases to test the validity of SBA management justifications
during movements of phases.

13
Appendix II: Management Comments

U.S. SMALL BUSINESS ADMINISTRATION

WASHINGTON, D.C. 20416
TO:

Hannibal “Mike” Ware
Inspector General
FROM:
Stephen Kong

Acting Chief Operating Officer

Elias Hernandez

Chief Human Capital Officer

Joshua Barnes

Acting Director, Office of Continuous Operations and Risk Management
SUBJECT:
OIG Project 21003, Evaluation of SBA's Coronavirus Reconstitution Plan
DATE:
June 21, 2021
SBA appreciates the role the Office of Inspector General (OIG) plays in working with
management in ensuring that SBA's programs are administered effectively and for the
feedback provided in this Draft Report. We take the findings and recommendation
seriously and understand the importance of the work OIG does to support risk mitigation
for the Agency.
This Draft Report presents the results of OIG's Evaluation of SBA's Coronavirus
Reconstitution Plan (Project 21003). OIG reviewed the actions of SBA to responsibly return
employees, contractors, and visitors to SBA offices during the pandemic. In the Draft
Report, OIG questions the Agency’s implementation of certain aspects of the May 2020
Reconstitution Plan. More specifically, OIG contends that SBA did not follow occupancy
procedures for advancing or reverting phases, follow exposure tracking protocols, or
consistently contact potentially exposed personnel and ensure employees completed 14-
day quarantine periods.
At the outset we must emphasize that SBA has prioritized the safety of our employees
throughout the pandemic and provided support in a number of significant ways. Employees
indicated on the most recent Federal Employee Viewpoint Survey (FEVS) that 1) senior
leaders demonstrated a commitment to health and safety (84% positive) and 2) supported
policies and procedures to protect employee health and safety (84% positive). Positive
feedback for supervisory support was even higher. In addition, as acknowledged by
employees on the FEVS, SBA has supported the well-being of the workforce through a
variety of means including: virtual onboarding; maximum telework flexibilities; health
screenings (including temperature checks) before entering the worksite; mandating the
use of personal protective equipment and social distancing in the office; expanded mental
health resources; frequent cleaning and sanitizing of facilities, especially common areas;

14
training on health and safety protocols; and the frequent use of telework/readiness
surveys to ensure that the Agency has addressed on-going staff needs during these trying
and uncertain times.
While SBA concurs with the OIG's recommendation that the Agency should enforce the
requirements in the February 2021 COVID-19 Workplace Safety plan, we note that there
are technical errors in some of the inconsistencies identified by OIG in the Draft Report.
Specifically, the Agency does not engage in "contact tracing" as this public health activity is
a function that trained public health practitioners should perform. Instead, the Agency
implemented a robust and structured process of tracking exposure whenever a positive
COVID-19 infection was made known to the Agency by the employee's supervisor or
another manager.
In following the Reconstitution Plan, and in isolated cases, supervisors and managers
respected the privacy of their staff and did not disclose the specific name of the individual
with a positive COVID-19 infection. The supervisor or manager then informed the Agency
of those who had contact with the unnamed individual, and the affected employees were
notified and directed to telework for 14 days or take leave, as appropriate. It is SBA’s
position that a lack of documentation to satisfy the continuum of each infection for OIG is
primarily a result of supervisors in those cases achieving a balance between sustaining
employees' privacy and ensuring the Agency has the information it needs to notify anyone
potentially exposed to an infection.
OIG made the following recommendation, and management's response to the
recommendation in the Draft Report is noted as follows:
OIG Recommendation 1:
Enforce the requirements of the February 2021 COVID-19 Workplace Safety Plan by
consistently applying occupancy and exposure tracking and accurately record and maintain
supporting documentation for all reported COVID-19 cases.
SBA's Response to Recommendation 1:
SBA concurs with the recommendation
We thank OIG for acknowledging in the report that the SBA has implemented a new plan
that extends further health and safety considerations for SBA employees, contractors, and
visitors. SBA will continue to track and document cases of exposure with an emphasis on
maintaining both workforce safety and individual privacy.

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