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U.S. SMALL BUSINESS ADMINISTRATION
OFFICE OF INSPECTOR GENERAL
SBA’s Oversight of the Community
Navigator Pilot Program Performance
Audit Report
Report 24-25
September 24, 2024
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U.S. Small Business Administration
Office of Inspector General
EXECUTIVE SUMMARY
SBA’s Oversight of the Community Navigator Pilot Program
Performance (Report 24-25)
What OIG Reviewed
This report presents the results of our audit of
the U.S. Small Business Administration’s (SBA)
oversight of the Community Navigator Pilot
Program (Navigator program). The American
Rescue Plan Act of 2021 established the
Navigator program and authorized $100 million
to provide technical assistance and pandemic
recovery services to underserved small
businesses and entrepreneurs. SBA awarded 51
grants, ranging from $1 million to $5 million,
totaling $99.9 million. The Navigator program
had a 2-year period of performance, from
December 1, 2021, through November 30, 2023
though most were approved to continue
providing services through May 31, 2024.
Our objectives were to determine whether SBA
had effective oversight of the Navigator program
to ensure (1) program goals were measured and
achieved and (2) grant recipients complied with
grant agreement performance requirements.
What OIG Found
Opportunities existed for SBA to improve
measuring and monitoring. Although program
officials established performance measures and
program goals, there was no established target
for the number of underserved clients to reach
through the program. In addition, the absence
of pertinent information on the client intake
form coupled with data quality issues limited the
reliability of performance results.
We also found that while program officials
generally monitored the activities of grant
recipients, they had limited assurance that
recipients who were also resource partners did
not double count performance results. Further,
not all changes in participating organizations
were approved and listed on SBA’s website.
The Navigator program offered the same
services to the same types of clients and used
the same performance measures as existing
programs. By improving measuring and
monitoring efforts, SBA can more accurately
assess grant recipients’ performance and
analyze the value of the program and results to
better determine whether the $99.9 million
invested in the program served the intended
purpose.
What OIG Recommended
We made five recommendations, should the
Navigator program continue, for SBA to improve
measuring program performance, improve the
quality of performance data collection efforts,
and track partner organizations participating in
the program.
Agency Response
SBA management agreed with Recommendation
3; partially agreed with Recommendations 1, 2,
and 5; and disagreed with Recommendation 4.
Management’s planned actions resolved
Recommendation 5. Specifically, SBA plans to
update the programmatic checklist to include a
separate question to assess partner organization
changes and improve the process for updating
the website to ensure changes are reflected. We
did not reach resolution on Recommendations
1, 2, 3, and 4. Therefore, we will seek resolution
of these recommendations in accordance with
our audit follow-up policy.
OFFICE OF INSPECTOR GENERAL
U.S. SMALL BUSINESS ADMINISTRATION
MEMORANDUM
409 Third St. SW, Washington, DC 20416 • (202) 205-6586 • Fax (202) 205-7382
Date:
September 24, 2024
To:
Isabella Casillas Guzman
Administrator
From:
Hannibal “Mike” Ware
Inspector General
Subject:
SBA’s Oversight of the Community Navigator Pilot Program (Report 24-25)
This report presents the results of our audit of SBA’s Oversight of the Community Navigator Pilot
Program. We considered management comments on the draft of this report when preparing the
final report and revised Recommendations 1, 2, and 4. SBA management agreed with one
recommendation, partially agreed with three recommendations, and disagreed with one
recommendation. Four recommendations are pending resolution.
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
Aditi Dussault, Acting Associate Administrator, Office of Entrepreneurial Development
Yvette Collazo Reyes, Deputy Associate Administrator, Office of Entrepreneurial
Development
Katherine Aaby, Chief Financial Officer, Office of the Chief Financial Officer and Associate
Administrator for Performance Management
Deborah Chen, Deputy Chief Financial Officer, Office of the Chief Financial Officer and
Associate Administrator for Performance Management
Anna Maria Calcagno, Director, Office of Program Performance, Analysis, and Evaluation
Walter B. Hill, Jr., Chief Risk Officer, Office of the Chief Financial Officer and Associate
Administrator for Performance Management
Michael Simmons, Attorney Advisor, Office of General Counsel
Tonia Butler, Director, Office of Internal Controls
i
Contents
Introduction .................................................................................................................................... 1
Navigator Program Design......................................................................................................... 1
Navigator Program Administration ........................................................................................... 3
Objectives .................................................................................................................................. 4
Results ............................................................................................................................................. 4
Finding 1: Measuring Program Impact ...................................................................................... 5
Establishing Targets for Reaching Underserved Clients ...................................................... 5
Improving Client Data Collection ......................................................................................... 6
Improving Data Quality to Assess Performance Results ...................................................... 7
Recommendations .................................................................................................................... 9
Finding 2: Monitoring Program Performance ......................................................................... 10
Increasing Oversight to Avoid Anonymous Reporting of Client Information .................... 10
Monitoring Partner Organizations ..................................................................................... 11
Recommendations .................................................................................................................. 12
Evaluation of Agency Response ..................................................................................................... 13
Summary of Actions Necessary to Close the Recommendations ............................................ 13
Tables
1
Navigator Program Award Tiers ........................................................................................ 2
2
Preliminary Performance Results as of November 2023 .................................................. 8
2-1
Comparison of the Navigator Program and Existing SBA Resource Partner Programs .. 2-1
Figures
1
Navigator program Hub and Spoke Model Structure ....................................................... 2
2
Navigator Program Timeline ............................................................................................. 3
ii
Appendices
1
Scope and Methodology ................................................................................................. 1-1
2
Comparison of the Navigator Program and Existing SBA Resource Partner Programs ... 2-1
3
Agency Response ............................................................................................................. 3-1
1
Introduction
Through the American Rescue Plan Act of 2021 (the Act), Congress allocated $100 million for the
Community Navigator Pilot Program (Navigator program) to provide technical assistance and
pandemic recovery services to underserved small businesses and entrepreneurs.1 The focus of
the Navigator program was to strengthen outreach and support to underserved small business
owners, to include veterans, women, people with disabilities, and those from rural communities
and communities of color. The Small Business Administration (SBA) awarded grants ranging from
$1 million to $5 million to 51 recipients, including private, nonprofit, SBA resource partners,
Native American Tribal Organizations, and state and local governments to provide these services.
The Navigator program had a 2-year period of performance, with grant recipients performing
primarily from December 1, 2021, through November 30, 2023. Most grant recipients requested,
and SBA approved, no-cost extensions to continue providing support to small businesses for an
additional 6 months. Services provided under this program ended May 31, 2024.
Navigator Program Design
The Navigator program uses a hub and spoke model2 approach. Hubs are the grant recipients
and are responsible for leading a network of partner organizations to act as spokes to provide
outreach and engagement in targeted communities (see Figure 1). As the lead, hubs oversee
program operations, they distribute funds to the spokes, and act as intermediaries with SBA if
issues arise. Hubs rely on the spokes to provide direct outreach, loans, grants, and pandemic
relief assistance application preparation, financial literacy, credit counseling, and access to
government contracts and exports to small business owners.
Each hub is required to have a minimum of five spokes. Some hubs are within the same state or
county as their spokes while some may serve larger areas. Entities eligible for the award included
nonprofits, economic development organizations, Native American tribal organizations, state
and local governments, and nonprofit colleges and universities. SBA’s existing resource partners
such as the Small Business Development Centers (SBDC), Women’s Business Centers, SCORE, and
Veterans Business Outreach Centers were allowed to participate in the program as either hubs
or spokes.
1 American Rescue Plan Act of 2021. Pub. L. No. 117-2, §5004(b)(1) (March 11, 2021).
2 SBA, Community Navigator Program Notice of Funding Opportunity (May 25, 2021).
2
Figure 1: Navigator Program Hub and Spoke Model Structure
Source: OIG analysis of the Hub and Spoke Navigator Model and examples of the clients they are intended
to serve
Program officials established three award tiers for applicants to submit proposals for funding.
These tiers were based on the range of services, targeted communities, and geographic locations
the applicant planned to reach through the program (see Table 1).
Table 1: Navigator Program Award Tiers
Tier
Maximum Award
Amount (in millions)
Tier Requirement
Tier 1
$5.0
Intended for multi-state projects serving more than
500,000 people.
Tier 2
$2.5
Projects supporting a state, region, municipality, or city
with at least 500,000 people.
Tier 3
$1.0
Projects supporting a region, municipality, city, or tribal or
rural community with fewer than 500,000 people.
Source: OIG analysis of the Navigator program information documented in the Notice of Funding Opportunity
3
Navigator Program Administration
SBA’s Office of Entrepreneurial Development (program office) administers the Navigator
program. Program officials awarded over $99.9 million to 51 grant recipients with nearly 450
partner organizations to reach businesses owned by minorities, women, veterans, and other
socially and economically disadvantaged entrepreneurs in underserved communities. The grant
recipients had from December 1, 2021, through November 30, 2023, to perform on the award.
Program officials gave grant recipients an option to receive a no cost extension to perform on
the award up to 6 months beyond November 2023. The no-cost extension was granted to 34 of
the 51 grant recipients who will continue the Navigator program until May 31, 2024 (see Figure
2).
Figure 2: Navigator Program Timeline
Source: OIG analysis of the Navigator program period of performance
A program manager is responsible for the overall oversight of the hubs, including monitoring
hubs’ compliance with the terms and conditions of the grant. An SBA district office program
official, located in the Office of Field Operations, is assigned to each award to assist the program
manager in ensuring the recipient complied with the grant requirements. Program officials used
the Community Navigator Information Management System to store and monitor data for the
Navigator program.
Program officials required grant recipients to use the Community Navigator Pilot Program Client
and Program Information Form 3516 (client intake form) to document client participation and
activities performed on the award. The client intake form collects client information such as
demographics (race, ethnicity, gender, and sexual orientation), geographic location, disability
status, language, and military status. Program officials collect this information to monitor
program equity and integrity. They intended to use the client intake form to standardize the
4
performance data collected from the 51 grant recipients to assess how well the Navigator
program served different communities.
Objectives
Our objectives were to determine whether SBA had effective oversight of the Community
Navigator Pilot program to ensure (1) program goals were measured and achieved and (2) grant
recipients complied with grant agreement performance requirements.
Results
We found that opportunities exist for SBA to better measure and monitor the Navigator
program. While the services provided under the Navigator program were the same services that
SBA’s vast network of resource partners also provided, the Navigator program was intended to
expand SBA’s network and reach customers that had not benefited from SBA programs (see
Appendix 2). Specifically, the Navigator program was established to help underserved small
business owners and aspiring entrepreneurs access pandemic relief programs and recovery
services; however, we were unable to determine if the program reached these small business
owners and entrepreneurs as intended. Although program officials established performance
measures and goals relative to program outputs and outcomes, there was no established target
for the number of underserved clients to reach through the program. Additionally, the absence
of critical client information, coupled with data quality issues, limited the reliability of
performance results.
We also found program officials could have improved monitoring efforts to ensure grant
recipients complied with performance requirements and served small business owners who had
not received SBA’s services prior to this pilot program. While program officials generally
monitored the activities of the 12 grant recipients we reviewed, we found they had limited
assurance that recipients who were also resource partners did not double count performance
results. Further, program officials were not always aware of partner organization changes; thus,
limiting their assurance that Navigator program participants were in areas that expanded SBA’s
footprint and services to underserved clients.
By not adequately measuring and monitoring the program, SBA missed opportunities to
accurately assess grant recipients’ performance, analyze the value of the program and results,
and maximize the reach of the program. This impacts SBA’s and other decision makers’ ability to
5
assess whether the $99.9 million awarded to the 51 grant recipients served the intended
purpose.
Finding 1: Measuring Program Impact
Opportunities exist for SBA to better measure the Navigator program. Program officials
established performance measures to track vital information on the number of customers
served, types and amount of assistance provided, and key indicators of customers’ business
growth. Program officials also measured client demographic, business industry, and geographic
information to assess whether underserved clients benefited from the program; however, they
did not establish a target for reaching a specific number of underserved clients.
In addition, the demographic information on the client intake form was optional, and clients did
not always provide a response. Further, we found recipients reported inaccurate and incomplete
client data, which resulted in unreliable performance results.
Our analysis of SBA’s resource partner programs showed the Navigator program offered the
same services to the same types of clients and used the same performance measures as existing
programs (see Appendix 2). Absent targets for reaching underserved clients and enforcement of
grant recipients’ reporting accurate and complete client information, Congress and SBA leaders
will be unable to determine if the $99.9 million awarded served the intended purpose.
Establishing Targets for Reaching Underserved Clients
Federal regulations require agencies to design programs with clear goals and objectives that
facilitate the delivery of meaningful results consistent with the federal authorizing legislation of
the program.3 Agencies are also required to provide grant recipients with clear performance
goals, indicators, targets, and baseline data.4
After the first year of the Navigator program, program officials established measures with targets
to evaluate performance towards reaching an intended number of unique clients served, new
business starts, and dollar amount of funds clients received. These measures are useful for
assessing how the program helped small businesses gain access to funds, counseling, training,
and financial literacy assistance.
3 2 C.F.R. §200.202.
4 2 C.F.R. §200.301(b).
6
However, although program officials established measures to identify specific demographic
information such as gender, race, ethnicity, veteran status, and disability status to track the
types of underserved small businesses and entrepreneurs served through the program, they did
not establish targets for these measures at the grant recipient level. Program officials told us the
client demographic information collected for the Navigator program was intended to be used to
assess how various types of clients benefited from participating in the program.
SBA sets a target for reaching underserved clients at the resource partner network level and
reports on the results in SBA’s Congressional Budget Justification and Annual Performance
Results.5 By not establishing targets for the underserved clients measure for the Navigator
program, program officials missed an opportunity to effectively monitor activities to ensure
recipients reached the businesses that Congress intended to serve through this program.
Improving Client Data Collection
Program officials used the client intake form to collect client and program activity information to
assess services provided and the reach of the program. The form included prompts to identify
clients’ attributes such as race, ethnicity, gender, sexual orientation, geographic location,
disability status, language spoken, and military status.6 When program officials designed the
form, many of the fields intended to collect information to identify clients as underserved
entrepreneurs were made optional to report.
Despite program officials’ efforts to collect this pertinent client information, less than half of the
clients responded to the question of whether they received prior SBA services. At least 71
percent of the clients provided responses to some of the questions regarding demographics.
Most grant recipients we spoke with stated that most clients did not respond or did not feel
secure enough to provide their personal information. Because many of the prompts which would
have identified the client as an underserved individual were not mandatory, client information
was inconsistent. This limited SBA’s ability to measure the overall effectiveness of reaching
underserved entrepreneurs through the Navigator program.
To enhance the quality of race and ethnicity data collection across the federal government,
Office of Management and Budget (OMB) policy states information can be compared across
5 SBA’s FY 2025 Congressional Budget Justification and FY 2023 Annual Performance Results (March 11, 2024) and
the FY 2024 Congressional Budget Justification and FY 2022 Annual Performance Results (March 13, 2023).
6 SBA Form 3516 Community Navigators Pilot Program Client and Program Intake Form (April 7, 2022).
7
federal agencies to gain an understanding of how well federal programs serve a diverse
America.7 To accomplish this, OMB strongly encourages agencies to collect race or ethnicity data
through self-reporting, wherever possible. In cases where self-reporting of race or ethnicity is
not possible, OMB allows for collecting this data through an individual familiar with the client,
using existing records on the individual that contains this information, or through observation
identification. Observation identification is when an observer uses his or her best judgment of
the most appropriate race or ethnicity categories applicable to the individual. Program officials
have an opportunity to improve accuracy and completeness of information on the client intake
form to better assess Navigator program outreach if they encourage grant recipients to use
some of these approaches when clients have not self-reported.
Improving Data Quality to Assess Performance Results
According to data reported by SBA, the Navigator program surpassed nearly all established
performance goals as of November 30, 2023 (see Table 2). However, we found deficiencies with
the performance data used to measure program success.
7 OMB Statistical Policy Directive No. 15: “Standards for Maintaining, Collecting, and Presenting Federal Data on
Race and Ethnicity” (March 2024).
8
Table 2. Preliminary Performance Results as of November 2023
Performance Measures
Target
Actual
Performance*
Percent to
Target
Number of unique clients that received assistance in the
development of their loan, grant, or other applications
41,310
43,640
106%
Number of underserved clients that received assistance
through the program
Not
established
30,858
-
Dollar (millions) amount request of loan and grant
applications completed
$571,516,824 $761,708,363
133%
Dollar (millions) amount of loan and grant applications that
were approved
$260,588,979 $328,460,502
126%
Counseling hours (Includes combined results for the two
counseling hour performance measures)
193,052
207,957
108%
Number of training hours
49,728
46,107
93%
Number of clients trained
255,107
414,655
162%
Number of clients receiving approved loans or grants
(Includes combined results for the two measures that assess
approved funding to clients either starting a business or
already in business)
7,783
3,467
45%
Number of jobs created or retained
56,247
298,083
530%
Percent increase of revenue (gross sale dollars)
15%
81%
540%
Note: SBA provided performance results that grant recipients reported in the system as of November 30, 2023. The
results reported in this table are preliminary and do not represent the final performance results for the program due
to a substantial number of grant recipients that SBA authorized to continue to perform on their awards through May
31, 2024, at no additional cost.
Source: OIG analysis of the Navigator program performance data provided by SBA Program Officials and Navigator
program Hubs
9
Guidance for the Community Navigator Information Management System identified
responsibilities for SBA program officials to perform system checks to validate integrity of data
that the grant recipients uploaded or manually entered.8 Program officials told us they
performed data cleanups and would alert grant recipients to resolve any errors. However, we
judgmentally sampled 12 grant recipients and still found inaccuracies with client data reported in
the system for all 12, causing reporting errors. Inaccuracies included misspellings, spacing errors,
inconsistency in using capital and lower-case letters, and client data that was entered as not
applicable. This posed a problem because program officials stated the system is case sensitive
and data entries must be entered the exact same way each time to prevent reporting errors.
Further, because SBA did not reconcile the performance data entered into the system, duplicate
client entries were not detected or corrected. As a result, unique client data used to measure the
Navigator program performance was incomplete and overstated the number of unique clients
served. These data inconsistencies resulted in unreliable data and therefore impacted SBA’s
ability to measure the overall effectiveness of the Navigator program.
Recommendations
We recommend the Administrator direct the Associate Administrator for the Office of
Entrepreneurial Development:
Recommendation 1: Should the Navigator program continue, establish performance targets to
assess recipient’s progress towards assisting underserved small business owners and
entrepreneurs.
Recommendation 2: Should the Navigator program continue, enhance guidance for grant
recipients to use acceptable methods to collect more complete client information reported to
program officials.
Recommendation 3: Enhance the data validation procedures to ensure program officials check
for accuracy and completeness of the performance data grant recipients upload to the system.
8 Community Navigator Information Management Information System Responsible, Accountable, Consulted,
Informed Guidance (July 25, 2022).
10
Finding 2: Monitoring Program Performance
Effective monitoring and oversight practices were critical to ensure the Navigator program
expanded SBA’s services to underserved small businesses. Program officials monitored the
activities of the 12 grant recipients in our sample to ensure they complied with most
performance requirements. However, opportunities exist for program officials to monitor SBA
resource partners' performance in the Navigator program and changes in participating partner
organizations.
We found program officials had limited assurance that Navigator program grant recipients that
were also resource partners in other SBA programs, did not double count performance results.
Additionally, client data was anonymous and program officials were not always aware of partner
organization changes; thus, limiting program officials’ assurance that Navigators were in areas
that expanded SBA’s footprint and services to underserved clients. By improving monitoring
efforts, SBA can accurately assess grant recipients’ performance, analyze the value of the
program and results, and ensure program funds are used properly.
Increasing Oversight to Avoid Anonymous Reporting of Client Information
Although existing SBA resource partners, such as Small Business Development Centers (SBDCs),
SCORE, Women Owned Business Centers (WBC), and Veterans Business Outreach Centers
(VBOC), were allowed to participate in the Navigator program,9 grant terms and conditions
required that resource partners keep their performance on each program separate. In our
sample, 8 of the 12 grant recipients we selected were either an SBA resource partner or had a
partner organization that was a resource partner.
SBA resource partners used two systems to report performance results to SBA — one to report
Navigator program results and another called the Entrepreneurial Development Management
Information System to report resource partner program results. Program officials relied on the
resource partners to ensure performance activities were kept separate and not double counted
between the programs they simultaneously participated in.
However, program officials told us it was challenging to ensure performance results were not
duplicative due to limitations with collecting client data for grant recipients that are also SBDC
and WBC program participants. We found that grant recipients replaced critical information such
9 American Rescue Plan Act 2021. Pub. L. No. 117-2 §5004 (March 11, 2021).
11
as client names, address, and contact information with a partner identification number. Program
officials told us that privacy data laws prohibited resource partners from releasing client
information.10 Program officials allowed resource partners who also participated in the Navigator
program to report performance results with anonymous information. The Navigator program is
separate from the SBDC and WBC programs, and although SBA prohibits resource partners from
reporting personally identifying client data, this prohibition did not apply to the Navigator
program and no similar provision was included in the authorizing legislation for the program.
Program officials estimated that over 85 percent of the client information in the resource
partner system is anonymized making it difficult to match clients between the two systems.
Because of this limitation, we could not compare client information to determine if grant
recipients double counted performance results. Additionally, this limits program officials’ ability
to ensure that resource partners participating in the program complied with grant requirements
to keep the program results separate.
Monitoring Partner Organizations
The Navigator program grant’s terms and conditions required grant recipients to obtain prior
approval before adding or removing a partner organization. For two grant recipients in our
review, we found this process was not always followed.
One grant recipient submitted a request for approval to change one of its partner organizations;
however, there was no evidence program officials approved this request. Another grant recipient
identified an SBA resource partner as one of their partner organizations. However, according to
the resource partner, they had concerns regarding keeping the Navigator program activities
separate and apart from their core SBA resource partner activities. Based on these concerns, the
grant recipient used another partner organization, but there is no evidence they contacted SBA
prior to making this change, as required by the terms and conditions.
On a quarterly basis, program managers were required to complete a checklist to monitor each
grant recipient’s compliance with the programmatic terms and conditions of the award.11 The
checklist included a three-part question, one of which was to determine whether the grant
recipient had changed any partner organizations during the quarter. For both instances
identified during our review, the program managers did not indicate in the checklist that the
10 Small Business Act. Public L. No. 85-536 §7(A) (December 22, 2023).
11 Program Manager Quarterly Report Approval and Advance Payment Request Checklist.
12
partner organizations changed. Program officials could improve consistency in reporting by
capturing this important compliance requirement in a separate question on the checklist.
Further, we found SBA’s website for the Navigator program was outdated and included partner
organizations that were no longer providing Navigator program services because program
officials did not always update the Navigator program website page when partner organizations
changed.
By not tracking changes to partner organizations, program officials do not have assurance that
eligible organizations are providing services to Navigator program customers. Further, a lack of
awareness of partner organization changes impacts SBA’s ability to ensure the program serves
communities that historically have not benefitted from SBA resources. Lastly, maintaining
updated website information provides a better opportunity for potential clients to identify
appropriate resources to receive assistance.
Recommendations
We recommend the Administrator direct the Associate Administrator for the Office of
Entrepreneurial Development:
Recommendation 4: Establish and implement a risk-based process to compare performance
results for Navigator program grant recipients and partner organizations that are also SBA
resource partners to ensure performance is separate and discrete.
Recommendation 5: Should the Navigator program continue, update the programmatic
compliance checklist to include a separate step to identify changes in partner organizations and
ensure the grant recipient received proper prior approval; and implement procedures to
promptly update the public website for approved partner organization changes.
13
Evaluation of Agency Response
SBA management provided formal written comments that are included in their entirety in
Appendix 3. In their written response, management agreed with Recommendation 3, partially
agreed with Recommendations 1, 2, and 5, and disagreed with Recommendation 4.
Management’s planned actions are sufficient to resolve Recommendation 5. However,
management’s proposed corrective actions do not meet the intent of Recommendations 1, 2, 3,
and 4; therefore, we will attempt to resolve these recommendations with SBA management in
accordance with our audit follow-up policy.
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
Should the Navigator program continue, establish performance targets to assess recipients’
progress towards assisting underserved small business owners and entrepreneurs.
Status: Unresolved
SBA management partially agreed with the recommendation with two revisions, stating that the
recommendation should only apply to a future FY 2025 Navigator program authorized under the
American Rescue Plan Act. Management also proposed the recommendation be revised to
require SBA to create and report as a standalone Congressional Budget Justification metric the
number of unique underserved clients but that it not be used as a performance target to assess
individual grant recipients.
Management warned against asking its grantees to provide performance targets related to
underserved small business owners because it could be misconstrued as a quota system and
would open the door to significant programmatic and legal risks. Management stated that if the
program received funding in FY 2025, they planned to continue to report on the “Number of
Unique Clients Served in Underserved Communities” in the Congressional Budget Justification as
a roll-up measure for all of SBA’s entrepreneurial development programs. SBA plans to complete
final action by September 30, 2024.
14
Management’s proposed corrective actions do not meet the intent of the recommendation for
two reasons. First, SBA management proposed the recommendation only applied to a future FY
2025 Navigator program authorized under the American Rescue Plan Act, however we maintain
our position that this recommendation should not be restricted to only FY 2025 should Congress
authorize the program to continue. Second, we maintain that performance targets should be
used to assess individual grant recipient performance which aligns with federal regulations.
Agencies are required to provide grant recipients with clear performance goals, indicators,
targets, and baseline data.12
SBA established that the focus of the Navigator program was to strengthen outreach and
support to underserved small business owners, to include veterans, women, people with
disabilities, and those from rural communities and communities of color. Additionally, the
Navigator program award’s terms and conditions identified several additional underserved
populations and SBA has regulatory authority to target specific underserved populations.
By not establishing targets for the underserved clients measure for grant recipients, program
officials missed an opportunity to effectively monitor activities to ensure recipients reached the
businesses that Congress intended to serve through this program.
In accordance with our audit follow-up policy, we will attempt to reach agreement with SBA
management on the unresolved recommendation within 60 days after the date of this final
report. If we do not reach agreement, OIG will notify the audit follow-up official.
Recommendation 2
Should the Navigator program continue, enhance guidance for grant recipients to use acceptable
methods to collect more complete client information reported to program officials.
Status: Unresolved
SBA management partially agreed with the recommendation with two revisions, stating that the
recommendation only applies to a future FY 2025 Navigator program authorized under the
American Rescue Plan Act. Management also proposed the recommendation be revised to clarify
that data quality improvements are a part of the SBA guidance and not a separate aspect of the
recommendation. We revised the recommendation to address this concern.
12 2 C.F.R. §200.301(b).
15
Management acknowledged the importance of proper guidance and documentation to improve
the quality of client information reported to SBA officials. Management stated that program
officials provided significant guidance, documentation, training, and ad hoc support to
Community Navigators System users on collecting client information and ensuring proper data
quality standards. Management further stated that while SBA will ensure it provides adequate
guidance, it cannot be responsible for a specific level of quality of data that comes from the
public. SBA plans to complete final action by September 30, 2024.
Although management proposed that they would evaluate current data quality guidance and
documentation currently used for the Nexus system, Nexus was not used for the Navigator
program. Also, their proposed corrective action does not specify how the program office will
improve client information collection.
As stated earlier in the report, the Office of Management and Budget provided alternative
acceptable methods for collecting information. Program officials have an opportunity to improve
accuracy and completeness of information on the client intake form to better assess Navigator
program outreach if they encourage grant recipients to use some of these approaches when
clients have not self-reported.
Because we believe SBA management does have responsibility for the quality of data used to
measure and report program performance, enhancing the guidance to grant recipients will help
to improve accuracy and completeness of information provided in the client intake form.
This recommendation is unresolved. In accordance with our audit follow-up policy, we will
attempt to reach agreement with SBA management on the unresolved recommendation within
60 days after the date of this final report. If we do not reach agreement, OIG will notify the audit
follow-up official.
Recommendation 3
Enhance the data validation procedures to ensure program officials check for accuracy and
completeness of the performance data grant recipients upload to the system.
Status: Unresolved
SBA management agreed with the recommendation. Management stated that the current data
management system is Nexus, which is built on the same platform as the Community Navigator
Information System. Management stated that the data management systems include automated
data validations. Management plans to add an automated report for program officials to
manually check outlier data. SBA plans to complete final action by February 2025.
16
At the time of our review, program officials used the Community Navigator Information
Management System to store and monitor data for the Navigator program. While management’s
planned actions provide a way to validate data in Nexus, it is unclear how these data validation
procedures will be used to ensure the accuracy and completeness of Navigator program data.
Since we found inconsistencies in the data contained in the Community Navigator Information
System, management should verify the accuracy and make corrections to assess the overall
effectiveness of the Navigator program.
In accordance with our audit follow-up policy, we will attempt to reach agreement with SBA
management on the unresolved recommendation within 60 days after the date of this final
report. If we do not reach agreement, OIG will notify the audit follow-up official.
Recommendation 4
Establish and implement a risk-based process to compare performance results for Navigator
program grant recipients and partner organizations that are also SBA resource partners to
ensure performance is separate and discrete.
Status: Unresolved
SBA management did not concur with the recommendation. Management stated they do not
believe SBA can legally implement the recommended comparison of performance results due to
existing statutory language that limits the data SBA resource partners share with SBA.13
We acknowledge that SBA’s legal interpretation regarding data sharing for certain resource
partners create limitations on receiving complete client data from SBA resource partners and
without such data, a comparison of performance results across programs would be difficult to
accomplish. Although SBA’s legal interpretation of the Small Business Act prohibits resource
partners from reporting personally identifying client data, this prohibition did not apply to the
Navigator program. Further, no similar provision was included in the authorizing legislation for
the program.
Management stated they ensure performance is separate and discrete through other methods
such as quarterly programmatic and financial reviews of grant activities. However, we found no
evidence of this being done.
13 The Small Business Act, 15 U.S.C. 648(a)(7)(A).
17
We maintain our position that implementing a process to compare performance results will
further help to improve SBA’s ability to ensure the Navigator program results are reported
separate and discrete for grant recipients who perform similar services through SBA’s resource
partner network. While the client data sets from SBA’s resource partners include anonymous
client data information, there are common data fields currently collected that could be used to
identify potential duplicate records. These potential matches could be further analyzed during
quarterly programmatic reviews with the grant recipients. Even though grant recipients are no
longer providing services under this program, it’s important that SBA analyze the data to ensure
that performance results are not duplicated.
In accordance with our audit follow-up policy, we will attempt to reach agreement with SBA
management on the unresolved recommendation within 60 days after the date of this final
report. If we do not reach agreement, OIG will notify the audit follow-up official.
Recommendation 5
Should the Navigator program continue, update the programmatic compliance checklist to
include a separate step to identify changes in partner organizations and ensure the grant
recipient received proper prior approval; and implement procedures to promptly update the
public website for approved partner organization changes.
Status: Resolved
SBA management partially agreed with the recommendation with one revision, stating that the
recommendation only applies to a future FY 2025 Navigator program authorized under the same
statute. Should the program continue in FY 2025, management stated they will update the
programmatic compliance checklist and include a separate question to assess partner
organization changes. Management would also include in its quarterly reporting, a requirement
for grant recipients to list all partner organizations on the grant.
Lastly, management stated they worked with a contractor within the Office of the Chief
Information Officer to manually update the website with partner organization information. SBA
plans to complete final action by September 30, 2024.
Management’s proposed actions satisfy the intent of this recommendation to ensure effective
monitoring and oversight practices of the Navigator program. This recommendation can be
closed when management provides evidence of the following: (1) documented plans to update
the programmatic compliance checklist, (2) updates made to the SBA website to reflect partner
organization changes, and (3) plans to promptly update the website for partner organization
changes.
1-1
Appendix 1: Scope and Methodology
Our scope of work covered the U.S. Small Business Administration’s (SBA) oversight of the
Community Navigator Pilot Program (Navigator program). We reviewed program officials process
and procedures for monitoring program performance and grant recipient compliance with the
terms and conditions.
To meet our objectives, we reviewed the American Rescue Plan Act of 2021 (the Act), the
Community Navigator Pilot Program Notice of Funding Opportunity, the Community Navigator
Pilot Program Terms and Conditions and other applicable public laws, federal grant regulations,
and other agency guidance related to the SBA’s oversight of the Navigator program.
We judgmentally selected 12 of the 51 grant recipients for review. We interviewed SBA program
officials responsible for the oversight of the Navigator performance requirements and program
goals. We conducted site visits to one hub and interviewed hub and spoke personnel to gain an
understanding of the Navigator program operations, business process flows, controls, and
oversight. For the remaining grant recipients in our sample, we conducted virtual interviews and
issued questionnaires to both the grant recipient and at least one of the grant recipient’s partner
organizations to learn about their roles within the program. We reviewed Navigator program
performance results from December 2021 through November 2023.
We conducted this performance audit in accordance with the Government Accountability
Office’s Generally Accepted Government Auditing Standards. These standards require that we
plan and perform audits to obtain sufficient and appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions based on our
audit objectives.
Use of Computer-processed Data
We relied on computer-processed data from SBA’s Community Navigator Information
Management System. We observed the functionality of the Navigator program system
demonstrated by program officials. We tested the reliability of the data in the Navigator program
system by comparing performance data reported in SBA’s Fiscal Year 2024 Congressional Budget
Justification. As a result, we believe the data was not reliable for the purposes of this audit.
1-2
While examining information that supported performance reporting, we identified data integrity
issues, including data that was inaccurate, erroneous, and inconsistent. Specifically, the data
contained in the system was not consistent with performance reported in SBA’s Fiscal Year 2024
Congressional Budget Justification. This was due in part to client names entered inaccurately and
inconsistently, thus creating a new unique client each time a specific client was entered under
different spellings, additional characters or spaces, or case sensitive changes, which created an
overstatement of the number of unique clients served in the program. Additionally, we identified
client data submitted anonymously, making it unverifiable. Lastly, because demographic data
was voluntary, some data was unavailable to verify for accuracy. We determined that the system
data was not sufficient to rely upon to assess the performance of the Navigator program (see
Finding 1).
Assessment of Internal Controls
For this audit, we identified the following internal control components and underlying internal
control principles as significant to the audit objectives.
Table 1-1: Internal Controls
Internal Control Component
Internal Control Principle
Control activities
• Design control activities
• Implement control activities
Information and Communication
• Use of quality information
• Communicate internally and externally
Monitoring
• Perform monitoring activities
Source: OIG internal controls analysis
We assessed the operational effectiveness of the internal controls and identified deficiencies we
believe could affect SBA’s oversight of the Navigator program. The internal control deficiencies
we found are discussed in the “Finding” sections of the report; however, because our review was
limited to aspects of these internal control components and underlying principles, the findings
may not identify all internal control deficiencies that may have existed when this audit took
place.
1-3
Prior Audit Coverage
The OIG did not identify any prior audits or reviews related to the objective of this audit.
2-1
Appendix 2: Comparison of the Navigator Program
and Existing SBA Resource Partner Programs
SBA has five programs that support the training and counseling needs of small businesses. Our
analysis of SBA’s entrepreneurial development programs showed the Navigator program offered
the same services to the same type of clients as existing SBA programs. See Table 2-1 for a
comparison of SBA’s counseling and training programs.
Table 2-1: Comparison of the Navigator Program and Existing SBA Resource Partner
Programs
Navigator program
SCORE
SBDC
WBC
VBOC
Services
Provided
•
Counseling
•
Training
•
Loan, grant, and
pandemic
application
assistance
•
Financial literacy
•
Credit counseling
•
Financial
assistance
•
Mentoring
•
Training
•
Free workshops
on topics
ranging from
startup
strategies to
marketing and
finance
•
Counseling
•
Training
•
Strategic and
financial
planning
•
Business
development
•
Cash flow
management
•
Counseling
•
Training
•
Access to
capital
(funding)
•
Business
training
•
Counseling
•
Resource
partner
referrals
Target
Audience
•
COVID-19
affected
businesses
•
Minorities
•
Women
•
Veterans, Military,
and Spouses
•
Rural
•
Socially and
economically
disadvantaged
•
Tribal
Communities
•
LGBTQ
•
Microbusinesses
•
Disabled
All entrepreneurs
(existing small
businesses and
aspiring
entrepreneurs)
All entrepreneurs
(existing small
businesses and
pre-venture
entrepreneurs)
Women
•
Transitioning
service
members
•
Veterans
•
National Guard
•
Reserve
Service
Members
•
Military
Spouses
2-2
Navigator program
SCORE
SBDC
WBC
VBOC
Performance
Measures
reported in
the FY 2025
Congressional
Budget
Justification
and FY 2023
Annual
Performance
Report
•
Number of
Unique Clients
Served
•
Number of New
Business Starts
from Community
Navigators
•
Millions of Dollars
of Capital Infusion
from Hubs
•
Number of Clients
Receiving
Government
Contracting
Assistance
•
Number of
Unique SCORE
Clients Served
•
Number of
SCORE New
Business Starts
•
Percentage of
SCORE
Businesses
Realizing
Revenue
Growth
•
Number of
Unique SBDC
Clients Served
•
Number of
New Business
Starts from
SBDCs
•
Number of
Jobs
Supported
from SBDCs
•
Billions of
Dollars of
Capital
Infusion from
SBDCs
•
Average
Satisfaction
Rate of
Entrepreneurs
Assisted by
SBDCs
•
Number of
Unique WBC
Clients
Served
•
Number of
WBC New
Business
Starts
•
Number of
Transactions
to Support
Capital
Infusion
•
Number of
New Business
Starts from
VBOCs
•
Number of
VBOC Clients
Served
•
Number of
VBOC
Programmatic
and Financial
Reviews
•
Number of
Boot-2-
Business (B2B)
Participants
Trained
•
Rate of B2B
Participants
Using Follow-
on SBA
Resources
Source: SBA OIG-generated based on analysis of select SBA’s Entrepreneurial Development programs
3-1
Appendix 3: Agency Response
U.S. Small Business Administration
Response to Report
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U.S. SMALL BUSINESS ADMINISTRATION
WASHINGTON, DC 20416
To:
Hannibal “Mike” Ware
Inspector General
U.S. Small Business Administration
From:
Aditi Dussault
Acting Associate Administrator, Office of Entrepreneurial Development
Date:
August 2, 2024
Subject:
SBA’s Response to SBA’s Office of Inspector General Audit of SBA's Oversight
of the Community Navigator Pilot Program Performance (CNPP) (Project 23014)
The SBA’s Office of Inspector General (OIG) conducted an audit of the Community Navigator
Pilot Program, which ran from December 1, 2021 through May 31, 2024. The OIG audit began
in August of 2023 and OIG shared a draft report in June 2024. The report includes five
recommendations across two main findings: three recommendations related to program
measurement and two related to program monitoring.
This memo responds to each of the five recommendations and constitutes the Office of
Entrepreneurial Development’s (OED) official response. Thanks to the OIG team for their
professionalism, engagement and communications regarding the CNPP over the past year.
2 | P a g e
Recommendation 1 – Should the Navigator program continue, establish a performance target
to assess recipient’s progress towards assisting an established number of underserved small
business owners and entrepreneurs.
SBA Response: SBA partially agrees with this recommendation.
OED’s Suggested Revision and Proposed Corrective Action Plan
SBA partially agrees with this recommendation with two revisions: first, that the
recommendation only apply to a future FY25 Community Navigators program authorized
under the same statute; and second, that SBA create and report as a standalone
Congressional Budget Justification (CBJ) metric the number of unique underserved
clients, but that it not be used as a performance target to assess individual grant
recipients.
OED’s proposed revised recommendation is below:
Should the Navigator program receive funding in FY25 under the same statute,
establish a Congressional Budget Justification metric to assess the program’s
standalone assistance of underserved clients (“Number of Unique Clients Served
in Underserved Communities”).
Regarding the first revision: the Community Navigator Pilot Program did not receive
additional funding from Congress for FY2024. As of May 31st, 2024, the program sunset
and grantees are either closed out or undergoing the grant close-out process.
There is a FY2025 budget request for Community Navigators; and if obligated, this
would result in a renewal of the program and a new Notice of Funding Opportunity
(NOFO). SBA would expect that FY2025 funding would be under the same statutory
language from the American Rescue Plan Act, but it cannot guarantee this. Any future
iteration of the CNPP program beyond FY2025 would likely be under a different statute,
especially considering Sec. 5004(d) of the American Rescue Plan Act of 2021 states:
(d) Sunset.—The authority of the Administrator to make grants under this section
shall terminate on December 31, 2025.
Since the Agency is beholden to the statutory language, it cannot promise to add in a
metric for a future program for which that metric may not be relevant. As such, SBA
would of course revisit key metrics to monitor and track for any new program.
Regarding the second revision: there is an important piece of context to address at the
outset. Currently, SBA provides an annual combined target and roll-up value as part of
the agency’s strategic goal to “Ensure Equitable and Customer-Centric Design and
Delivery of Programs to Support Small Businesses and Innovative Startups.” The
relevant equity measure under this goal is “Number of Unique Clients Served in
Underserved Communities.” While Community Navigators did not have a standalone
target for this metric, it reported data as part of this larger roll-up value, which includes
targets created based on an initial baseline.
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All OED programs will continue to provide a combined target and roll-up value for
“Number of Unique Clients Served in Underserved Communities” for the duration of the
strategic goal.
SBA’s revision replaces “performance target to assess recipient’s progress” with the
specific standalone CBJ metric, which is set by the Agency as opposed to by grantees.
This is in line with how all equity-related metrics are treated at the Agency.
SBA warns against asking its grantees to provide performance targets related to
underserved small business owners. This situation could be misconstrued as a quota
system and would open the door to significant programmatic and legal risks. Further, the
data collected to define “underserved” is a voluntary information collection and is
inconsistently completed by participants. These voluntary metrics include information on
race, ethnicity, gender, military status, disability status, or sexual orientation and other
such demographic information. No other SBA Resource Partner grantees create
individual performance targets based around this voluntary data.
Target Action Date: The guidance document that pertains to SBA’s follow-up action will be
completed by September 30, 2024.
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Recommendation 2 – Should the Navigator program continue, establish guidance for grant
recipients to use acceptable methods to collect client information and improve the quality of the
information reported to program officials.
SBA Response: SBA partially agrees with this recommendation.
OED’s Suggested Revision and Proposed Corrective Action Plan
SBA partially agrees with this recommendation with two revisions: first, that the
recommendation only apply to a future FY25 Community Navigators program authorized
under the same statute; and second, to clarify that reporting guidance did exist and that
“improve the quality of the information” refers to a goal of said guidance, as opposed to a
separate aspect of the recommendation.
Our proposed revised recommendation is below:
Should the Navigator program receive funding in FY25 under the same statute,
ensure that guidance is adequate for grant recipients to use acceptable methods
to collect client information and to improve the quality of the information
reported to program officials.
Regarding the first revision: the Community Navigator Pilot Program did not receive
additional funding from Congress for FY2024. As of May 31st, 2024, the program sunset
and grantees are either closed out or undergoing close-out procedures.
There is a FY2025 budget request for Community Navigators: if obligated, this would
result in a renewal of the program and a new Notice of Funding Opportunity (NOFO).
SBA would expect that FY2025 funding would be under the same statutory language
from the American Rescue Plan Act, but it cannot guarantee this. Any future iteration of
Navigators beyond FY2025 would likely be under a different statute, especially
considering Sec. 5004(d) of the American Rescue Plan Act of 2021 states:
(d) Sunset.—The authority of the Administrator to make grants under this section
shall terminate on December 31, 2025.
Since the Agency is beholden to the statutory language, it cannot promise to take an
action that may not be relevant. However, SBA recognizes the importance of proper
guidance and documentation to help grantees with limited experience with Federal grants
programs.
Regarding the second revision: OED provided significant guidance, documentation,
training, and ad hoc support to COMNAVS users on collecting client information and
ensuring proper data quality standards. This documentation was shared with OIG as part
of the audit. OIG may feel like this guidance needs to be updated or improved, which is
why SBA suggests modifying the recommendation from “establish guidance” to “ensure
that guidance is adequate.”
The other change in this section is to clear up a minor ambiguity in the recommendation.
By replacing “improve” with “to improve”, the recommendation is clear in that data
5 | P a g e
quality improvement is part of the guidance that SBA provides, not a separate
recommendation that the Agency would be beholden to. While SBA will ensure adequate
guidance, it cannot be responsible for a specific level of quality of data that comes from
the public.
Target Action Date: The guidance document that pertains to SBA’s follow-up action will be
completed by September 30, 2024.
6 | P a g e
Recommendation 3 – Enhance the data validation procedures to ensure program officials check
for accuracy and completeness of the performance data grant recipients upload to the system.
SBA Response: SBA agrees with this recommendation.
OED Proposed Corrective Action Plan
OED’s current data management system is Nexus, which launched earlier in FY24.
Nexus is built on the same platform as COMNAVS, and replaces the previous EDMIS-
NG system. All past and present OED data management systems include automated data
validations built into the User Interface and the upload process. Sample Nexus Business
validations are attached to this memo. When errors are encountered, the end user is
presented with an error message or error report, and the error is required to be resolved
before the record can proceed through the upload process.
While these automated processes help to check for inaccurate or incomplete data,
additional steps can be taken to enhance procedures around data that is in the proper
format but may still be inaccurate. Examples of this may be duplicate records or records
that contain outliers.
OED will add an automated report for program officials to allow for manual checking of
outlier data. This will require some additional development effort and training. We
estimate an implementation date at the end of the first quarterly reporting period of FY25
(February 2025). This would allow time to design the procedure, build the report(s), and
train program officials.
Target Action Date: We anticipate remediation of this recommendation by February 2025.
7 | P a g e
Recommendation 4 – Establish and implement a process to compare performance results for
Navigator program grant recipients and partner organizations that are also SBA resource
partners to ensure performance is separate and discrete.
SBA Response: SBA does not concur with this recommendation.
OED’s Reasoning for Non-Concurrence
The Agency does not believe that it can legally implement the recommended comparison
of performance results due to existing statutory language that limits what data SBA
Resource Partners share with SBA.
The SBA Resource Partners keep their own data records and share anonymized data to
SBA’s central database (Nexus, previously EDMIS-NG), with Personally Identifiable
Information (PII) replaced with a system of unique identifiers and keys.
The Resource Partners are bound by the Small Business Act, codified in relevant part at
15 U.S.C. 648(a)(7)(A):
A small business development center, consortium of small business development
centers, or contractor or agent of a small business development center may not
disclose the name, address, or telephone number of any individual or small
business concern receiving assistance under this section without the consent of
such individual or small business concern, unless—
(i) the Administrator is ordered to make such a disclosure by a court in any civil
or criminal enforcement action initiated by a Federal or State agency; or
(ii) the Administrator considers such a disclosure to be necessary for the purpose
of conducting a financial audit of a small business development center, but a
disclosure under this clause shall be limited to the information necessary for such
audit.
This regulation prevents SBA from requiring that Resource Partners to provide this
information.
Without de-anonymized information on Resource Partner clients, the SBA is unable to
compare performance results across programs in the manner suggested.
OED’s monitoring and compliance work seeks to ensure performance is separate and
discrete through other methods as discussed throughout the audit, such as the scoring of
grant proposals by technical evaluation panels; the signing of commingling statements
detailing other SBA awards by the grantee’s Authorized Organization Representative
(AOR); and quarterly programmatic and financial reviews of grant activities.
While the Agency does not concur with this recommendation, it recognizes the utility of
a comparison effort should there be a future change in regulation.
Target Action Date: N/A
8 | P a g e
Recommendation 5 – Should the Navigator program continue, update the programmatic
compliance checklist to include a separate step to identify changes in partner organizations and
ensure the grant recipient received proper prior approval; and implement procedures to
promptly update the public website for approved partner organization changes.
SBA Response: SBA partially agrees with this recommendation.
OED’s Suggested Revision and Proposed Corrective Action Plan
SBA partially agrees with this recommendation with one revision: that the
recommendation only apply to a future FY25 Community Navigator program authorized
under the same statute.
Our proposed revised recommendation is below:
Should the Navigator program receive funding in FY25 under the same statute,
update the programmatic compliance checklist to include a separate step to
identify changes in partner organizations and to ensure the grant recipient
received proper prior approval; and implement procedures to promptly update
the public website for approved partner organization changes.
The Community Navigator Pilot Program did not receive additional funding from
Congress for FY2024. As of May 31st, 2024, the program sunset and grantees are either
closed out or undergoing the close-out process.
There is a FY2025 budget request for Community Navigators: and if obligated, this
would result in a renewal of the program with a new Notice of Funding Opportunity
(NOFO). SBA would expect that FY2025 funding would be under the same statutory
language from the American Rescue Plan Act, but it cannot guarantee this. Any future
iteration of Navigators beyond FY2025 would likely be under a different statute,
especially considering Sec. 5004(d) of the American Rescue Plan Act of 2021 states:
(d) Sunset.—The authority of the Administrator to make grants under this section
shall terminate on December 31, 2025.
Since the Agency is beholden to the statutory language, it cannot promise to take an
action that may not be relevant.
The OIG’s report explains that OED’s programmatic compliance checklist for
Community Navigators did include a step to confirm if the grantee needed to submit a
consortium change amendment. The need for prior approval for changes to partner
organizations is detailed in Section 28 of the Program Specific Terms and Conditions for
the Navigators Program.
Box 4 of the checklist under the ‘Quarterly Performance Narrative’ review states the
following:
Is the consortium leveraging the trusted advisors in the Hub and Spoke model to
reach underserved communities? Has the consortium changed its Spokes? If so, is
there a Consortium Change approval on record?
9 | P a g e
Later in the section, Box 10 includes a catch-all for any other amendments:
Does the narrative indicate a need for any amendment?
This system ensured that the vast majority of consortium changes resulted in a prior
approval request from the grant recipient.
Since Box 4 does include two separate questions, SBA would be happy to separate these
into separate questions in a FY2025 Community Navigators program. In addition, SBA
would include in its quarterly reporting, a requirement for grantees to list all partner
organizations on the grant.
For the ‘Local Assistance’ page on www.sba.gov/local-assistance, OED worked with an
OCIO contractor to manually update the website with Hub and Spoke information.
Grantees provided OED with updates on Spoke addresses, websites, or other pertinent
information either through 1:1 meetings with grantees or through a short form. OED
routinely aggregated changes and submitted tickets to the OCIO contractor to update the
map. In the advent of Navigator’s continuation in FY2025, OED would work with OCIO
to see what resources might be available to improve the process and speed with which
these changes could be reflected on the website.
Given the fact that around 75% of Community Navigator 1:1 clients had not previously
worked with SBA, the vast majority of outreach did not come from the SBA website.
Target Action Date: The guidance document that pertains to SBA’s follow-up action will be
completed by September 30, 2024.
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Conclusion and Recommendation to Close:
The above responses detail SBA’s response to these recommendations and intended next
steps. For Recommendations 1, 2, and 5, which begin with ‘Should the Navigator
Program continue…”, SBA asks that OIG modify these recommendations. Since the pilot
program has ended, any new program by Congress will have to be evaluated based on
new statutory language. SBA cannot commit to recommendations based on a nonexistent
program, and therefore, it is the belief that these recommendations would likely apply to
FY2025 funding of Community Navigators under the current statute.
For Recommendation 3, SBA will add additional reports in Nexus for data quality control
by the proposed target date of February 2025.
For Recommendation 4, SBA asks that OIG remove this recommendation due to the cited
regulation in the Small Business Act, which prohibits the Agency’s ability to implement
the recommendation.