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GAO-23-105293: State Small Business Credit Initiative: Improved Planning Could Help Treasury Limit Additional Delays

Summary

GAO report GAO-23-105293, "State Small Business Credit Initiative: Improved Planning Could Help Treasury Limit Additional Delays," a report to congressional addressees dated February 2023. It states that the American Rescue Plan Act of 2021 reauthorized the State Small Business Credit Initiative (SSBCI) with $10 billion appropriated, and that the Department of the Treasury extended application deadlines multiple times. All 50 states, five territories and the District of Columbia applied for capital program funds, and as of September 30, 2022, Treasury had approved 31 applications and disbursed $1.3 billion. GAO recommends that Treasury incorporate certain best practices for project scheduling in its SSBCI planning, and Treasury agreed to review options for doing so.

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“GAO-23-105293: State Small Business Credit Initiative: Improved Planning Could Help Treasury Limit Additional Delays.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-23-105293-state-small-business-credit-initiative-improved-planning-955d61717a/, SHA-256 e94c7c78c82639e34212b059fb91ef3e08ef6f73b116036395ce21d2e08dc3fa.

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                United States Government Accountability Office
                Report to Congressional Addressees




                STATE SMALL
February 2023




                BUSINESS CREDIT
                INITIATIVE

                Improved Planning
                Could Help Treasury
                Limit Additional
                Delays




GAO-23-105293
                                             February 2023

                                             STATE SMALL BUSINESS CREDIT INITIATIVE
                                             Improved Planning Could Help Treasury Limit
                                             Additional Delays
Highlights of GAO-23-105293, a report to
congressional addressees




Why GAO Did This Study                       What GAO Found
SSBCI was reauthorized by the                The State Small Business Credit Initiative (SSBCI) provides funds to eligible
American Rescue Plan Act of 2021             jurisdictions—states, territories, the District of Columbia, and tribal
(ARPA) to support small businesses           governments—to support small business lending and investment programs
recovering from the economic effects         through its capital program. Eligible jurisdictions also can apply for technical
of the COVID-19 pandemic. Congress           assistance funding (such as for legal, accounting, and financial advisory
appropriated $10 billion for the             services) to support certain businesses that apply to an SSBCI program or
program.                                     another government small business program.
The CARES Act and ARPA include               The Department of the Treasury, which administers SSBCI, extended application
provisions for GAO to monitor the
                                             deadlines for the capital and technical assistance programs multiple times (see
federal government’s efforts to respond
                                             figure). All 50 states, five territories, and the District of Columbia submitted
to COVID-19. Among its objectives,
this report examines Treasury’s efforts
                                             applications for capital program funds, and as of September 30, 2022, Treasury
to complete key implementation steps         had approved 31 applications and disbursed $1.3 billion.
for SSBCI and manage program risks
and measure program performance.             Application Deadline Extensions for State Small Business Credit Initiative, March
                                             2021–March 2023
GAO reviewed relevant legislation and
SSBCI documentation and analyzed
Treasury data on allocated and
disbursed funds. GAO also interviewed
Treasury officials, representatives of
four territories, and representatives of
nongeneralizable samples of 12 states
and three tribal governments—
selected to represent a range of
geographic regions and other
characteristics.

What GAO Recommends                          Partly because of these deadline extensions and the time needed to review and
                                             approve numerous applications, Treasury has taken longer than expected to
GAO recommends that Treasury fully
                                             disburse SSBCI funds. Significant SSBCI implementation steps remain, such as
incorporate certain best practices for
                                             reviewing remaining applications and implementing compliance monitoring and
project scheduling in its planning
efforts for SSBCI. Treasury agreed to        performance measurement plans. However, Treasury’s planning efforts have not
review options for incorporating such        fully incorporated certain best practices GAO previously developed for reliable
practices in line with GAO’s                 project scheduling. For example, Treasury’s work plan has not identified which
recommendation.                              staff or contractors would be responsible for each activity. Fully incorporating
                                             these best practices could help limit the potential for delays and help ensure
                                             timely disbursement and oversight of program funds.
                                             Treasury has been developing a framework to support and monitor jurisdictions’
                                             compliance with SSBCI guidelines. In November 2022, Treasury published
                                             compliance and oversight standards for jurisdictions to use for their programs.
                                             Officials said they have been building on procedures used for the original SSBCI
                                             and planned to develop compliance monitoring procedures (for Treasury to use)
                                             by December 31, 2022. Treasury also has published data collection and
                                             reporting requirements for SSBCI and has been developing key indicators to
View GAO-23-105293. For more information,    measure program performance.
contact Michael Clements at (202) 512-8678
or clementsm@gao.gov.


                                                                                      United States Government Accountability Office
Contents


Letter                                                                                         1
               Background                                                                      4
               Participating Jurisdictions Plan to Use a Mix of Program Types to
                 Meet SSBCI Objectives                                                        11
               Treasury Had Delays Disbursing Program Funds and Has Not
                 Fully Implemented Best Practices for Project Scheduling                      17
               Treasury’s Compliance and Performance Monitoring Efforts Are in
                 Progress                                                                     24
               Conclusions                                                                    27
               Recommendation for Executive Action                                            27
               Agency Comments and Our Evaluation                                             27

Appendix I     Objectives, Scope, and Methodology                                             31



Appendix II    Best Practices for Creating and Maintaining Reliable Schedules
                                                                                              35



Appendix III   Comments from the Department of the Treasury                                   37



Appendix IV    GAO Contact and Staff Acknowledgments                                          39


Tables
               Table 1: Program Types for State Small Business Credit Initiative
                       Capital Program                                                         4
               Table 2: Number of Jurisdictions Proposing Programs and
                       Number of Planned Programs for State Small Business
                       Credit Initiative (SSBCI) and Change in Number from
                       Original SSBCI, by Type                                                13
               Table 3: GAO’s Best Practices for Project Schedules                            35

Figures
               Figure 1: Overview of Flow of Funds in State Small Business
                        Credit Initiative (SSBCI)                                              6




               Page i                         GAO-23-105293 State Small Business Credit Initiative
Figure 2: State Small Business Credit Initiative Funding
         Allocations, 2010 and 2021                                                        7
Figure 3: Major Milestones for State Small Business Credit
         Initiative, March 2021–March 2023                                                 9
Figure 4: Organizational Chart for the State Small Business Credit
         Initiative Program Office                                                        10
Figure 5: Total Preliminary Funding Allocations and States That
         Received Disbursements for the State Small Business
         Credit Initiative (SSBCI), as of September 30, 2022                              12
Figure 6: Application Deadline Extensions for State Small
         Business Credit Initiative, March 2021–March 2023                                19




Abbreviations

ARPA              American Rescue Plan Act of 2021
CDFI              community development financial institution
FAQ               frequently asked questions
SEDI              socially and economically disadvantaged individual
SSBCI             State Small Business Credit Initiative




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Page ii                                GAO-23-105293 State Small Business Credit Initiative
                       Letter




441 G St. N.W.
Washington, DC 20548




                       February 2, 2023

                       Congressional Addressees

                       To help small businesses recover from the COVID-19 pandemic,
                       Congress has provided nearly $1 trillion through grants, loan subsidies,
                       and commitment authority to various programs. In March 2021, the
                       American Rescue Plan Act of 2021 (ARPA) reauthorized the State Small
                       Business Credit Initiative (SSBCI) in the Department of the Treasury to
                       strengthen state, territory, District of Columbia, and tribal government
                       programs that support lending and investment in small businesses. 1

                       The current SSBCI program retains key features of the original program,
                       which operated from 2010 through 2017, but it received a much larger
                       appropriation ($10 billion compared to $1.5 billion). The current program
                       also includes an allocation for tribal governments and allocations for very
                       small businesses and those owned and controlled by socially and




                       1Congress first authorized SSBCI in the Small Business Jobs Act of 2010, appropriating
                       $1.5 billion in funding following the 2007–2009 financial crisis. GAO issued four reports on
                       the program and made recommendations to Treasury on improving oversight and
                       enhancing performance measurement and evaluation. Treasury implemented our
                       recommendations. See GAO, State Small Business Credit Initiative: Opportunities Exist to
                       Improve Program Oversight, GAO-12-173 (Washington, D.C.: Dec. 7, 2011); Small
                       Business Lending: Opportunities Exist to Improve Performance Reporting of Treasury’s
                       Programs, GAO-13-76 (Washington, D.C.: Dec. 5, 2012); State Small Business Credit
                       Initiative: Opportunities Exist to Enhance Performance Measurement and Evaluation,
                       GAO-14-97 (Washington, D.C.: Dec. 18, 2013); and Small Business Credit Programs:
                       Treasury Continues to Enhance Performance Measurement and Evaluation but Could
                       Better Communicate and Update Results, GAO-15-105 (Washington, D.C.: Dec. 11,
                       2014).




                       Page 1                                 GAO-23-105293 State Small Business Credit Initiative
economically disadvantaged individuals (SEDI-owned businesses). 2
Moreover, it provides technical assistance funds that jurisdictions or
Treasury can use to provide legal, accounting, and financial advisory
services to support certain businesses that apply for SSBCI or another
government small business program (technical assistance program). 3

The CARES Act and ARPA include provisions for GAO to monitor and
oversee the federal government’s efforts to prepare for, respond to, and
recover from COVID-19. In January 2022, we reported on steps Treasury
had taken to begin implementing the program and potential challenges
facing Treasury and program participants. 4 This report examines (1)
jurisdictions’ planned use of SSBCI funds to meet program objectives; (2)
Treasury’s completion of key implementation steps for SSBCI; and (3)
Treasury’s efforts to manage program risks and measure program
performance.




2Very small businesses are those with fewer than 10 employees and may include
independent contractors and sole proprietors. According to Treasury’s capital program
policy guidelines, Treasury considers SSBCI funds to be expended for SEDI-owned
businesses if the funds are expended for loans, investments, or other credit or equity
support to business enterprises that (1) certify they are owned and controlled by
individuals who have had their access to credit on reasonable terms diminished as
compared to others in comparable economic circumstances, due to their (a) membership
of a group that has been subjected to racial or ethnic prejudice or cultural bias within
American society, (b) gender, (c) veteran status, (d) limited English proficiency, (e)
disability, (f) long-term residence in an environment isolated from the mainstream of
American society, (g) membership of a federally or state-recognized Indian Tribe, (h) long-
term residence in a rural community, (i) residence in a U.S. territory, (j) residence in a
community undergoing economic transitions, or (k) membership of another “underserved
community” as defined in Executive Order 13985; (2) certify they are owned and
controlled by individuals whose residences are in Community Development Financial
Institutions (CDFI) Investment Areas, as defined in 12 C.F.R. § 1805.201(b)(3)(ii); (3)
certify they will operate a location in a CDFI Investment Area, as defined in 12 C.F.R. §
1805.201(b)(3)(ii); or (4) are located in CDFI Investment Areas, as defined in 12 C.F.R. §
1805.201(b)(3)(ii). The term “owned and controlled” means, if privately owned, 51 percent
is owned by such individuals; if publicly owned, 51 percent of the stock is owned by such
individuals; and in the case of a mutual institution, a majority of the board of directors,
account holders, and the community which the institution services predominantly consists
of such individuals.
3Treasury also can transfer technical assistance funds to the Minority Business
Development Agency in the Department of Commerce.
4GAO, COVID-19: Significant Improvements Are Needed for Overseeing Relief Funds and
Leading Responses to Public Health Emergencies, GAO-22-105291 (Washington, D.C.:
Jan. 27, 2022).




Page 2                                 GAO-23-105293 State Small Business Credit Initiative
For the first objective, we reviewed and analyzed Treasury data on state
and territory planned programs. We assessed the reliability of these data
by obtaining written responses from Treasury officials about their process
for ensuring the accuracy of the data. We found these data to be
sufficiently reliable for describing the planned programs. We also
interviewed representatives of four of the five permanently inhabited
territories and nongeneralizable selections of 12 states and three tribal
governments on their planned programs and for perspectives on
Treasury’s implementation of SSBCI. 5 We selected states to reflect a
range of funding allocation amounts and geographic diversity, and to
include states that did and did not participate in the original SSBCI
program. We contacted 16 tribal governments from among those that
submitted a Notice of Intent to apply for SSBCI and to represent a range
of geographic regions and sizes based on preliminary total funding
allocations. We interviewed representatives of the three tribal
governments that responded, which represented three different
geographic regions (Midwest, Northwest, and Southern Plains) and all
had preliminary allocation amounts greater than the median amount of
approximately $686,000. 6 We also interviewed experts from three
business organizations, two lender organizations, and six tribal
organizations.

For the second objective, we reviewed relevant legislation and Treasury’s
SSBCI program guidelines, frequently asked questions (FAQ), notices on
Treasury’s website, and other SSBCI program documentation. We
analyzed Treasury’s time frames for developing and updating program
guidelines and application deadlines and compared Treasury’s efforts to
consult with tribal governments against its 2015 Tribal Consultation
Policy. We reviewed Treasury’s work plan and other planning efforts for
SSBCI and compared them to our best practices for project scheduling. 7
Specifically, we compared Treasury’s work plan and planning efforts to
best practices related to sequencing and establishing the duration of
activities, assigning resources to activities, and updating schedules using
actual progress. We interviewed Treasury officials on the steps they took

5The five permanently inhabited U.S. territories are American Samoa, the Commonwealth
of the Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. We
requested interviews with all five territories and one did not respond to our request.
6We categorized tribal governments by geographic region based on the 12 regions used
by the Bureau of Indian Affairs in the Department of the Interior.
7See GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules,
GAO-16-89G (Washington, D.C.: Dec. 22, 2015).




Page 3                                  GAO-23-105293 State Small Business Credit Initiative
                                                              to implement SSBCI, including hiring staff, implementation time frames,
                                                              and any planning efforts.

                                                              For the third objective, we reviewed Treasury’s oversight and monitoring
                                                              plans and reporting guidance and interviewed Treasury officials. For more
                                                              detailed information about our scope and methodology, see appendix I.

                                                              We conducted this performance audit from August 2021 to February 2023
                                                              in accordance with generally accepted government auditing standards.
                                                              Those standards require that we plan and perform the audit to obtain
                                                              sufficient, 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.

                                                              As with the original SSBCI, the current program includes a capital
Background                                                    program that jurisdictions can use to fund lending programs that facilitate
                                                              loans to small businesses—including capital access, collateral support,
                                                              loan participation, and loan guarantee programs—and venture capital and
                                                              other equity investment programs (see table 1). Each type of program
                                                              shares lending or equity financing risks with lenders or investors, thereby
                                                              facilitating transactions that otherwise might not have occurred. Eligible
                                                              jurisdictions can design new programs, restart previous programs, or
                                                              scale up existing programs. They also can implement multiple programs
                                                              of the same type.

Table 1: Program Types for State Small Business Credit Initiative Capital Program

Type of program                                     Program description
Capital access                                      Provides loan portfolio insurance wherein the borrower and lender, such as a small business
                                                    owner and a bank, contribute to a reserve fund held by the lender. Amounts in the lender’s
                                                    reserve fund are available to cover any losses incurred in its portfolio of capital access loans.
Loan guarantee                                      Allows jurisdictions to use State Small Business Credit Initiative funds to provide assurance to
                                                    lenders that they will be partially repaid in the event of default, after the lender makes every
                                                    reasonable effort to collect funds. The guarantees help small businesses secure loans that
                                                    otherwise may have been inaccessible or prohibitively expensive.
Collateral support                                  Supplies cash collateral accounts to lenders to enhance the collateral coverage of borrowers,
                                                    enabling business owners to borrow funds to help their businesses grow.
Loan participation                                  Allows jurisdictions to buy an interest in the loans made by lenders or lend directly alongside
                                                    private lenders, providing additional direct lending to finance small businesses.
Venture capital and other equity                    Allows jurisdictions to set up public-private partnerships for equity investing or investment in
investment                                          venture capital funds. These investments may be focused on providing capital to underserved
                                                    startups and making venture capital more available across geography and business founders.
Source: GAO analysis of Department of the Treasury documents. | GAO-23-105293




                                                              Page 4                                GAO-23-105293 State Small Business Credit Initiative
As stipulated by ARPA, the current capital program retains key features of
the original program, including the formula for allocating a portion of the
funds for states, the District of Columbia, and territories; the disbursement
structure; and private funding requirements.

•   Main allocations for states, territories, and the District of Columbia
    generally were based on each jurisdiction’s decline in employment
    from 2019 to 2020 as a proportion of national employment decline. 8
•   Participating jurisdictions receive up to three installments over the life
    of the program, and must use at least 80 percent of the previous
    disbursement before receiving the next installment.
•   Participating jurisdictions must match the federal contribution with
    private dollars at a level of 1:1 for each loan guarantee, collateral
    support, or loan participation program or for each fund within venture
    capital programs. 9 Jurisdictions are expected to leverage $10 in
    lending or investing for every $1 of SSBCI funding spent over the life
    of the SSBCI programs (achieve a 10:1 leverage ratio). 10

As with the original program, eligible jurisdictions can administer funds
directly or they can partner with a third party, such as an economic
development corporation or business development center, to serve as the
program administrator with state oversight (see fig. 1).




8Main allocations refer to capital program allocations that are distinct from allocations for
very small or SEDI-owned businesses and incentive allocations to support SEDI-owned
businesses.
9SSBCI funds may be used to match aggregate borrower and lender contributions at a
level of 1:1 for each capital access program.
10During the original SSBCI, participants leveraged $8.95 in new financing for every $1 in
SSBCI funds as of December 31, 2016.




Page 5                                   GAO-23-105293 State Small Business Credit Initiative
Figure 1: Overview of Flow of Funds in State Small Business Credit Initiative
(SSBCI)




The current program received a much larger appropriation than the
original ($10 billion compared to $1.5 billion in 2010) and includes an
allocation for tribal governments and allocations for certain types of small
businesses and the technical assistance program (see fig. 2).




Page 6                              GAO-23-105293 State Small Business Credit Initiative
Figure 2: State Small Business Credit Initiative Funding Allocations, 2010 and 2021




Notes: Only municipalities in states that do not submit complete applications are eligible to receive
funding. In addition to their direct allocations, the jurisdictions (including tribal governments) may
receive portions of the funding for technical assistance, very small businesses, and businesses
owned and controlled by socially and economically disadvantaged individuals (SEDI-owned
businesses) and incentive funding to support SEDI-owned businesses.


Treasury also applied the employment-based formula to determine
allocations for very small businesses to states, territories, and the District
of Columbia. In contrast, Treasury based allocations related to SEDI-
owned businesses on the percentage of each jurisdiction’s total
population residing in Community Development Financial Institution
(CDFI) Investment Areas. 11 Treasury based allocations to all eligible tribal
governments on the number of enrolled tribal members for each tribe
(using available data). 12

As required by ARPA, Treasury published capital program allocations for
states, territories, and the District of Columbia by April 9, 2021. Treasury
required these jurisdictions to submit a Notice of Intent to apply for the
program by May 10, 2021, and initiate capital program applications by



11CDFI Investment Areas, as defined in 12 C.F.R. § 1805.201(b)(3)(ii), are generally low-
income, high-poverty areas that do not receive sufficient access to capital or support for
the needs of small businesses.
12The employment-based methodology used for main allocations for states, territories,
and the District of Columbia is statutorily defined, but Treasury developed the
methodologies for allocating funds to very small and SEDI-owned businesses and tribal
governments.




Page 7                                       GAO-23-105293 State Small Business Credit Initiative
December 11, 2021. 13 As discussed in more detail later in this report,
Treasury set later deadlines for tribal governments to submit a Notice of
Intent to apply and subsequently complete applications. ARPA requires
Treasury to complete all disbursements and remaining obligations before
September 30, 2030. 14 Any remaining unexpended funds are to be
rescinded and deposited in Treasury’s general fund. Figure 3 provides a
timeline of major milestones and key implementation steps through the
end of March 2023 for the capital and technical assistance programs of
the current SSBCI.




13Eligible jurisdictions had to initiate capital program applications by December 11, 2021.
Specifically, they had to designate the implementing entity, identify key contacts, and
provide a list of proposed programs and statement of legal action. Jurisdictions were
required to complete capital program applications by February 11, 2022. That is, they had
to describe how each of their proposed programs satisfied the requirements in the SSBCI
statute and Treasury program guidelines and provide the signature of the authorized
official.
14Each jurisdiction approved for participation in SSBCI will receive main allocations of
capital funds in three disbursements (each approximately 33 percent of the total). As a
precondition to receipt of the second and third disbursements, the jurisdiction must certify
to Treasury that 80 percent or more of the prior disbursement had been expended,
transferred, or obligated to one or more approved programs. Funds generally will be
considered “expended” if the expenses were paid by or are for an approved state
program. They are considered “transferred” if they have been transferred to the
implementing or contracted entity administering daily operations of an SSBCI program to
reimburse actual expenses, when there is a clearly documented actual and immediate
cash need to fund a loan or investment to an eligible small business, or to pay for
allowable administrative expenses. Finally, funds are considered “obligated” if they have
been committed in writing to pay for orders placed, contracts awarded, goods and
services received, and similar transactions.




Page 8                                  GAO-23-105293 State Small Business Credit Initiative
Figure 3: Major Milestones for State Small Business Credit Initiative, March 2021–March 2023




                                         Page 9                              GAO-23-105293 State Small Business Credit Initiative
                                          The program office responsible for administration and oversight of SSBCI
                                          operates within Treasury’s Office of Recovery Programs. 15 As of August
                                          2022, the program office had 23 full-time authorized positions and
                                          administered SSBCI through groups responsible for policy, compliance,
                                          outreach, and technical assistance (see fig. 4). Treasury also has a
                                          contract in place to hire additional support for the program as needed.

Figure 4: Organizational Chart for the State Small Business Credit Initiative Program Office




                                          15Treasury established the Office of Recovery Programs in April 2021 to lead
                                          implementation of the department’s pandemic relief and recovery programs.




                                          Page 10                               GAO-23-105293 State Small Business Credit Initiative
Participating
Jurisdictions Plan to
Use a Mix of Program
Types to Meet SSBCI
Objectives
All States and Territories   Some of the states already have begun to receive SSBCI funding, and
Applied to Participate and   most states and territories plan to use it for a mix of lending and equity
                             investment programs.
Most Plan to Use a Variety
of Lending and Investment    Status of applications and allocations. All 50 states, all five territories,
Programs                     and the District of Columbia submitted a complete application for SSBCI
                             funding to Treasury by the February 11, 2022 deadline. 16 As of
                             September 30, 2022, Treasury had approved 31 applications and
                             disbursed the first tranche (portion) of funding to 26 jurisdictions, which
                             totaled $1.3 billion or approximately 13 percent of program funds. Figure
                             5 summarizes the amount of funding allocated and disbursed to states,
                             the District of Columbia, and territories.




                             16All five territories (American Samoa, the Commonwealth of the Northern Mariana
                             Islands, Guam, Puerto Rico, and the U.S. Virgin Islands), the District of Columbia, and all
                             but three states (Alaska, North Dakota, and Wyoming) also participated in the original
                             SSBCI. However, one or more municipalities in each of those three states participated. In
                             lieu of state programs, Anchorage (Alaska), two consortiums of municipalities in North
                             Dakota, and one consortium of municipalities in Wyoming participated in the original
                             SSBCI.




                             Page 11                                GAO-23-105293 State Small Business Credit Initiative
Figure 5: Total Preliminary Funding Allocations and States That Received Disbursements for the State Small Business Credit
Initiative (SSBCI), as of September 30, 2022




                                         Note: Once Treasury approves an application, the jurisdiction is notified of its full funding obligation
                                         and, after execution of its allocation agreement, receives its first tranche (portion) of funding, which is
                                         typically equal to approximately one-third of the preliminary allocation. Funding is disbursed in three
                                         approximately equal tranches if the jurisdiction meets SSBCI requirements. As of September 30,
                                         2022, Treasury had approved applications but not yet disbursed the first tranche to five states
                                         (Kentucky, Missouri, Nevada, Oklahoma, and Oregon).


                                         Type and numbers of planned programs. According to preliminary data
                                         from Treasury, 45 percent of the participating jurisdictions plan to
                                         implement more than one type of lending program as well as a venture
                                         capital or other equity investment program. Of the planned programs, 58
                                         percent are lending programs, 34 percent are venture capital and other
                                         equity investment programs, and 8 percent are other types. As shown in
                                         table 2, the jurisdictions plan to implement 213 programs in total—61
                                         more than the original SSBCI.




                                         Page 12                                       GAO-23-105293 State Small Business Credit Initiative
Table 2: Number of Jurisdictions Proposing Programs and Number of Planned Programs for State Small Business Credit
Initiative (SSBCI) and Change in Number from Original SSBCI, by Type

                                                         Number of jurisdictions that plan to
                                                                                                                 Total number of proposed SSBCI programs
                                                            implement a program typea
                                                                         Change in number of                         Proposed SSBCI            Change in number of
                                                  Current program as of jurisdictions from the                         programs as of            programs from the
 Program type                                        September 2, 2022         original SSBCI                       September 2, 2022                original SSBCI
 Capital access (Loan loss                                                   12                          -12↓                            12                          -12↓
 reserve)
 Loan guarantee                                                              24                           +5↑                            27                          +5↑
 Collateral support                                                          22                           +5↑                            22                          +5↑
 Loan participation                                                          43                           +4↑                            63                         +15↑
 Venture capital and other equity                                            45                           +7↑                            72                         +31↑
 investment
 Other program types                                                         12                         +12↑                             17              Not applicable
 Total number and change in                                                  56                           -1↓                          213                        (+61↑)
 number of jurisdictions
 participating / Total number
 and change in number of
 programs
Source: GAO analysis of Department of the Treasury data. | GAO-23-105293
                                                               a
                                                                Excluding tribal governments, 56 jurisdictions plan to participate in the current SSBCI (50 states, five
                                                               territories, and the District of Columbia). Fifty-seven jurisdictions participated in the original SSBCI (47
                                                               states, five territories, the District of Columbia, Anchorage, Alaska, two consortiums of municipalities
                                                               in North Dakota, and one consortium of municipalities in Wyoming). Tribal governments were not
                                                               eligible to participate in the original SSBCI.


                                                               Under the current SSBCI, loan participation and venture capital programs
                                                               are the most common planned program types and capital access
                                                               programs are the least common. The number of planned capital access
                                                               programs declined by 12 compared to the original SSBCI, while the
                                                               planned number of other lending program types increased. Under the
                                                               original SSBCI, capital access programs generated the least amount of
                                                               new financing of all program types, which may have contributed to the
                                                               decrease in their planned use under the current SSBCI. 17

                                                               Of the 16 jurisdictions whose representatives we interviewed, 10 states
                                                               and four territories participated in the original SSBCI. Of the 10 states,
                                                               three plan to restart programs used in the original SSBCI, three plan to

                                                               17Under the original SSBCI, capital access programs generated $640 million in total new
                                                               financing, and loan participation and venture capital programs generated $3.2 and $4.2
                                                               billion, respectively. See Department of the Treasury, State Small Business Credit
                                                               Initiative: A Summary of States’ 2016 Annual Reports (Washington, D.C.: July 24, 2017).




                                                               Page 13                                       GAO-23-105293 State Small Business Credit Initiative
implement new programs, and three plan to implement a mix of new and
continuing programs. Three of the four territories plan to implement new
programs, and three also plan to restart programs operated under the
original SSBCI. Twelve of the 16 jurisdictions plan to implement three or
more program types.

Officials from the 12 states we interviewed described how their
jurisdictions selected different program types to meet SSBCI program
requirements and objectives.

•   Meeting leverage requirements. States provided examples of how
    they selected certain types of programs to help ensure they meet the
    10:1 leverage ratio requirement, which was a challenge for many
    states in the original SSBCI. Officials from five states that plan to
    implement venture capital programs told us they chose such
    programs in part because they typically result in higher leverage
    ratios. 18 For example, two states estimated that their venture capital
    programs would achieve a leverage ratio of 20:1 or higher. They said
    this would help them to meet the overall leverage requirement even if
    their other programs did not reach the 10:1 leverage target.
•   Reaching very small and SEDI-owned businesses. The states
    described how they plan to leverage partnerships and deploy different
    program types to reach a range of small businesses, including very
    small and SEDI-owned businesses. All 12 states said they plan to
    leverage existing partnerships with lenders, CDFIs, small business
    development centers, or other community groups to provide support
    to very small and SEDI-owned businesses. For example, officials from
    four states said they plan to work with CDFIs or other community-
    based lenders to implement loan guarantee and loan participation
    programs. Officials from two states said they plan to continue their
    capital access programs from the original SSBCI because those were
    their primary programs for reaching very small and SEDI-owned
    businesses.

Officials from four territories we interviewed also said they plan to use a
mix of program types to meet SSBCI requirements.




18According to Treasury’s 2016 Summary of States’ Annual Reports, venture capital
programs had an overall leverage ratio of 12.8:1, compared to an overall ratio of 7.7:1 for
loan guarantee programs, 7.5:1 for loan participation programs, and 5.6:1 for collateral
support programs.




Page 14                                 GAO-23-105293 State Small Business Credit Initiative
                         •   Meeting leverage requirements. To meet the 10:1 leverage ratio,
                             officials from two territories said they plan to implement a venture
                             capital program in addition to at least one lending program, so that
                             their combined programs can achieve the leverage ratio. An official
                             from another territory said it plans to implement three different lending
                             programs and use a mix of short-, medium-, and long-term loans to
                             meet the leverage ratio.
                         •   Reaching very small and SEDI-owned businesses. Officials from
                             all four territories told us that most or all of the businesses in their
                             territories qualify as SEDI-owned, so all of their planned programs
                             would serve these businesses and help them meet that requirement. 19

                         Finally, all four territories we interviewed plan to use SSBCI funds to
                         expand or further develop certain business sectors. For example, officials
                         from two territories told us they intend to use SSBCI funds to expand
                         equity investments to businesses in industries other than construction and
                         manufacturing, which are currently their main industries.

Tribal Governments       Tribal governments were at an earlier stage of program planning and
Recently Completed       design than states and territories at the time of our review because their
                         deadline for completing capital program applications (October 31, 2022)
Applications and Some
                         was about 8 months later than the deadline for states and territories. Data
Noted Potential          on program types proposed by tribal governments were not available at
Challenges for Program   the time of our review. According to information from Treasury, 283 tribal
Implementation           governments submitted an application either individually or as part of a
                         consortium. 20 Representatives from a regional tribal organization we




                         19According to Treasury’s capital program guidelines, SEDI allocations are based on the
                         percentage of the jurisdiction’s total population residing in CDFI Investment Areas, as
                         defined in 12 C.F.R. § 1805.201(b)(3)(ii), relative to the total population residing in all
                         CDFI Investment Areas. Treasury determined that American Samoa, the Commonwealth
                         of the Northern Mariana Islands, Guam, and the U.S. Virgin Islands in their entirety
                         constitute CDFI Investment Areas for purposes of SSBCI, because each of these
                         territories has a poverty rate of at least 20 percent.
                         20According to data from Treasury, over 400 Notices of Intent to apply to SSBCI were
                         received from tribal governments by the December 2021 deadline. According to Treasury
                         officials, Treasury identified 582 tribal governments as eligible to apply to the program.
                         This included 574 federally recognized tribes and eight component bands of those tribes
                         that had submitted tribal enrollment data to the Bureau of Indian Affairs.




                         Page 15                                 GAO-23-105293 State Small Business Credit Initiative
interviewed said tribes may apply as part of a consortium to pool funding
and share administrative resources. 21

As Treasury reviews and approves applications, tribal governments will
be notified of their full funding obligation, and after executing allocation
agreements, will receive the first of their three funding tranches. The
preliminary (or minimum) allocations for tribal governments that submitted
a Notice of Intent to apply for SSBCI ranged from about $600,000 to
about $89 million, according to data from Treasury. Eighty percent of
tribal governments (333) received a preliminary allocation of less than $1
million, 19 percent (78) received between $1 million and $20 million, and
1 percent (four) received more than $20 million.

Representatives of tribal governments and tribal organizations we
interviewed offered perspectives on how their governments might deploy
SSBCI funds to meet program requirements and objectives. A
representative from a regional tribal organization told us loan guarantee
programs may be popular options because they offer greater security to
lenders that otherwise might not provide funding to tribal entrepreneurs.
Officials from two tribal governments told us they plan to implement
lending programs through CDFIs. Officials from one of these
governments said they plan to implement a loan participation program in
partnership with a CDFI with which they have an existing relationship.
Officials from the other tribal government told us they plan to work with
their tribe’s CDFI to implement a small business lending program.

Tribal government officials and organizations we interviewed indicated
potential challenges with designing and implementing programs and
meeting statutory requirements. These challenges may influence which
tribal governments participate in SSBCI and the types of programs they
implement. Specifically, interviewees highlighted the challenges of being
first-time participants, including navigating the complexity of SSBCI and
learning how to develop and operate eligible programs. Interviewees also
said that tribal governments may face challenges associated with limited
administrative resources, technical expertise, or lending capacity to
administer programs and access private capital to meet the 1:1 matching
requirement or the 10:1 leverage ratio target.



21In contrast, officials from two tribal governments we interviewed said they were leaning
towards applying individually so they could implement targeted programs to best meet the
needs of the small businesses in their communities.




Page 16                                GAO-23-105293 State Small Business Credit Initiative
                            Treasury officials noted that because of these challenges, the smallest
                            and most economically distressed tribes may find it particularly difficult to
                            access and navigate SSBCI. As discussed in the next section, Treasury
                            has taken steps to conduct outreach and provide assistance to tribes to
                            mitigate these challenges.


Treasury Had Delays
Disbursing Program
Funds and Has Not
Fully Implemented
Best Practices for
Project Scheduling
Treasury Hired Program      In the first year, Treasury staffed the SSBCI program office and generally
Office Staff, Conducted     focused on conducting outreach to stakeholders and eligible jurisdictions
                            and developing guidelines and application materials for the capital
Outreach to Stakeholders,
                            program. Treasury began staffing the SSBCI program office in March
and Completed Initial       2021 and filled about half the positions by October 2021. Initial hires
Program Guidelines          included the Director and Deputy Director/Chief of Staff, who had worked
                            on the original SSBCI program. 22 By October 2021, Treasury filled
                            additional lead roles such as the Senior Policy Advisor, Compliance
                            Manager, Technical Assistance/Grants Lead, and Supervisory Outreach
                            Manager to begin work on program implementation. By August 2022, all
                            but one position in the SSBCI program office was filled.

                            Program office staff put essential administrative plans and functions in
                            place. For example, in March and April 2021, staff coordinated with
                            Treasury budget personnel to establish an administrative budget and
                            staffing plan. They also started working with Office of Recovery Programs
                            and procurement personnel to put in place a project management support
                            contract. In August 2021, Treasury awarded a contract for support with
                            program design, operations and implementation, and outreach and
                            technical assistance to applicants.

                            Treasury also obtained input from stakeholders to inform the development
                            of program guidelines and materials. In May 2021, Treasury published a

                            22In addition to bringing back staff with experience from the original SSBCI program,
                            Treasury officials noted they reviewed organizational charts and consulted with staff from
                            the original program to inform the rebuild of the SSBCI program office.




                            Page 17                                GAO-23-105293 State Small Business Credit Initiative
                           Request for Information in the Federal Register to obtain public input on
                           effective approaches for delivering capital and technical assistance to
                           small businesses through SSBCI. Treasury received more than 90
                           responses by the June 2021 deadline, including from state agencies,
                           tribal organizations, and representatives of other program stakeholders,
                           such as lender and investor associations. From spring to fall 2021,
                           Treasury also held over 50 listening sessions with state and territory
                           officials and other organizations to identify potential implementation
                           issues. According to Treasury officials, Treasury updated its capital
                           program guidelines to provide additional clarity and flexibility in response
                           to these listening sessions.

                           Beginning in May 2021, Treasury also conducted extensive outreach to
                           jurisdictions to provide assistance with program design and help them
                           understand SSBCI program requirements. Treasury officials said they
                           held approximately 70 webinars and daily office hour sessions through
                           December 11, 2021. They also convened working groups of states and
                           connected jurisdictions with subject matter experts. Nine of the 16 states
                           and territories we interviewed reported that Treasury facilitated
                           connections with other jurisdictions, and four told us these connections
                           were helpful for sharing knowledge about specific program types.

                           Treasury officials said they recognized that tribal governments would
                           require additional support and guidance as first-time participants. In
                           accordance with its 2015 Tribal Consultation policy, Treasury held an
                           initial consultation with tribal governments in May 2021 on the capital
                           program and another in January 2022 on the technical assistance
                           program. According to officials, Treasury also conducted approximately
                           15 webinars and seven regional leadership meetings in 2021 to inform
                           tribal governments of the reauthorized SSBCI. 23

Treasury Disbursed Funds   Treasury began disbursing capital program funds later than it planned,
Later Than It Planned,     partly because it required more time and resources than anticipated to
                           support first-time participants and establish comprehensive guidelines for
Partly Because of Time
                           new program components. The larger size and increased complexity of
Needed to Implement New    the current SSBCI in comparison to the original introduced additional
Program Components         challenges in setting and meeting planned time frames for the program.
                           For example, Treasury officials noted they needed more time and
                           resources to provide support to tribal governments that had not previously

                           23In the period before the deadline for tribal governments to submit a Notice of Intent to
                           apply, Treasury’s outreach to tribes also included information sessions, periodic office
                           hours, and one-on-one outreach to eligible tribal governments.




                           Page 18                                 GAO-23-105293 State Small Business Credit Initiative
                                         participated in the program, and to implement the technical assistance
                                         component of SSBCI.

                                         Treasury issued guidelines for the capital program on November 10,
                                         2021, later than originally estimated. Officials said they wanted to allow
                                         enough time to ensure the guidelines were comprehensive and minimize
                                         the need for later revisions, a lesson learned from the previous program.
                                         In the original SSBCI, Treasury issued revised guidelines and materials
                                         after a number of states had submitted applications. As a result, some
                                         states had to amend their programs to comply with Treasury’s revised
                                         guidelines.

                                         Treasury extended the application deadlines for both the capital and
                                         technical assistance programs (see fig. 6). It did so to give jurisdictions
                                         more time to design programs following the release of its capital program
                                         guidelines, and to accommodate the additional time needed to support
                                         tribal governments.

Figure 6: Application Deadline Extensions for State Small Business Credit Initiative, March 2021–March 2023




                                         Capital program deadlines for states and territories. On September
                                         27, 2021, Treasury extended the deadline for states and territories to
                                         complete their capital program applications from December 11, 2021, to
                                         February 11, 2022. 24 Treasury officials said they extended the application


                                         24Treasury initially required states, territories, and the District of Columbia to initiate
                                         applications for the capital program by December 11, 2021, and to submit a complete
                                         application by February 11, 2022.




                                         Page 19                                   GAO-23-105293 State Small Business Credit Initiative
deadline to allow more time for jurisdictions to design their programs after
capital program guidelines were issued in November 2021.

Capital program deadlines for tribal governments. Treasury extended
the capital program application deadline for tribal governments four
times. 25 Treasury first extended the deadline in response to concerns
from tribal governments about the feasibility of submitting applications by
the original deadline of December 11, 2021. It extended the deadline a
second time to update preliminary allocations for tribal governments and
allow additional time for tribes to form consortiums, and because tribal
governments lacked experience with the original SSBCI. 26 Treasury then
extended the deadline two more times to continue to give tribal
governments time to design their programs and for Treasury staff to
continue outreach efforts.

Treasury officials said that providing support to tribal governments has
taken more time and resources than they expected because tribal
governments are statutorily held to the same requirements as states but
generally do not have similar experience in implementing capital lending
and investment programs. To assist tribal governments, Treasury
facilitated connections between tribal governments to form consortiums
and incorporated flexibilities into the program guidance where possible,
such as allowing businesses owned by tribal governments to participate
in SSBCI.

Technical assistance deadlines. Treasury also extended deadlines for
the technical assistance program multiple times. For states and territories,
Treasury extended the deadline three times from March 31, 2022, to a
final deadline of October 14, 2022. For tribal governments, it extended the
deadline four times from March 11, 2022, to March 31, 2023.

One factor that contributed to the first extension was the delayed
issuance of the technical assistance guidelines. Treasury communicated
in November 2021 that it would issue these guidelines in the following
weeks, but did not do so until April 28, 2022. Officials said the guidelines

25Treasury initially required tribal governments to submit a Notice of Intent to apply by
September 16, 2021, and subsequently extended this deadline to December 11, 2021.
26According to officials, Treasury initially communicated preliminary allocations to each
eligible tribal government before the deadline for tribal governments to submit a Notice of
Intent to apply and updated allocations after the Notice of Intent deadline. Treasury then
re-calculated the allocations based on the number of entities that submitted a Notice of
Intent to apply by the December 2021 deadline.




Page 20                                 GAO-23-105293 State Small Business Credit Initiative
were issued later than planned because they wanted to make sure they
were fully developed and reflected the capital program guidelines. They
also were balancing competing program priorities and needed time to
solidify their partnership with the Department of Commerce’s Minority
Business Development Agency, which will administer part of the program.

More broadly, according to Treasury officials, timelines for the technical
assistant component shifted from their original estimates because they
did not fully anticipate the resources needed to develop and issue
extensive reporting guidance, compliance standards, and FAQs. They
also did not fully anticipate the time and effort needed to review capital
program applications.

Finally, officials said deadlines were extended in response to feedback
from jurisdictions that wanted to complete their capital program
applications before submitting technical assistance applications. The
deadline for tribal governments to submit technical assistance
applications also was pushed back when Treasury extended the deadline
for them to submit capital program applications.

Timing of disbursements. The deadline extensions, and the time
needed to review numerous applications (many proposing multiple
programs and program types) affected the timing of disbursements of
funds to jurisdictions. In September 2021, Treasury officials said they
planned to start disbursing funds in the first quarter of 2022. They did not
begin disbursing funds until May 26, 2022—about 3 months after the
February 2022 capital program application deadline for states and
territories. As of September 30, 2022, Treasury had approved 31
applications and disbursed the first tranche of funds to 26 of the 56
jurisdictions that applied.

According to officials, completing application reviews and disbursing
funds took longer than expected in part because of the timing and volume
of capital program applications. Nearly all of the 56 capital program
applications from states, territories, and the District of Columbia were
submitted shortly before the February 11, 2022 deadline, and collectively
proposed substantially more programs than implemented during the
original SSBCI. Officials also said participating jurisdictions were planning
a wider variety of programs to absorb the increased amount of funding.
They noted that it generally takes a month to complete an application
review, including 1–3 weeks to pose questions to a jurisdiction about their
application and receive answers.



Page 21                          GAO-23-105293 State Small Business Credit Initiative
                             Participants and stakeholder views on timelines for guidance,
                             applications, and fund disbursement. While tribal governments and
                             organizations generally reported that the deadline extensions were
                             helpful, several states we interviewed between March and May 2022 told
                             us they made it more difficult to design or start their programs. Two of the
                             three tribal governments we interviewed said the deadline extensions
                             were helpful and gave them more time to design their programs. Similarly,
                             four of the six tribal organizations we interviewed noted that the
                             extensions allowed tribal governments to explore private funding options,
                             flesh out program designs, clarify guidance, obtain additional assistance
                             from Treasury, or communicate with other tribal governments.

                             However, eight of 12 states noted that collective program delays hindered
                             their efforts to design or put their programs in place. In particular, five
                             states reported that Treasury’s delays issuing guidance made it more
                             challenging to design their programs because they had to work with
                             incomplete information. Three states reported that Treasury’s guidance
                             delays made it more difficult to develop partnerships or work with third
                             parties necessary for their programs. Representatives from a financial
                             organization similarly reported that the later-than-expected disbursal of
                             funds caused program partners to drop out, which might affect
                             jurisdictions’ ability to administer programs.

                             The remaining four states did not report implementation challenges
                             resulting from the extension of SSBCI timelines. However, two of these
                             states said that delays raised concerns about getting funds to small
                             businesses in need. Three of the four territories told us that Treasury
                             could have improved the timeliness of the guidance or application
                             process.

Treasury’s Planning Could    Treasury has faced challenges setting and maintaining a reliable
More Fully Incorporate       schedule for key SSBCI program implementation steps, as indicated by
                             multiple deadline extensions and later-than-expected disbursements.
Certain Best Practices for
                             Although Treasury moved back some time frames to allow more time to
Project Scheduling           properly manage new SSBCI components and allow jurisdictions
                             additional time they needed, some jurisdictions reported challenges
                             arising from certain delays, such as increased difficulty in working with
                             partners to implement their programs.

                             Treasury’s planning efforts have not fully incorporated certain best
                             practices for creating and maintaining a reliable schedule—a document
                             that integrates the planned work of government staff and contractors, the
                             resources necessary to accomplish that work, and the associated budget


                             Page 22                         GAO-23-105293 State Small Business Credit Initiative
(see app. II for more details). 27 Incorporating these best practices can
help agencies improve their project planning processes and reduce the
potential for delays. These practices include, but are not limited to, the
following:

•   Sequencing and establishing the duration of activities. Activities
    should be logically sequenced and linked, and a schedule should
    realistically reflect how long each activity will take. Treasury officials
    noted that they began drafting a work plan in March 2022 and
    produced an updated work plan in September 2022 to help set work
    streams, develop high-level deliverables for a period of time, and
    communicate the SSBCI program office’s goals internally and to
    management. However, while Treasury’s September 2022 work plan
    documented goals and objectives through December, it did not
    describe the interim steps needed to reach deadlines for major work
    streams, how Treasury planned to sequence planned work, or
    estimations for how long each activity would take.
•   Assigning resources to activities. A schedule should reflect the
    resources needed to do the work. Treasury’s September 2022 work
    plan did not identify which staff or contractors would be responsible
    for leading and conducting each activity or reflect a consideration of
    resource availability or constraints.
•   Updating the schedule using actual progress. A schedule should
    be updated with actual dates and progress to adjust time frames for
    remaining efforts. Treasury officials noted that since spring 2021, they
    have used frequent internal meetings to establish and revise time
    frames and plan to revisit the work plan at least annually to identify
    gaps in resources and set objectives. However, Treasury’s work plan
    did not include time frames for such updates, reflect progress updates
    based on prior work plans, or report on program performance relative
    to the documented objectives.

Fully incorporating these practices for creating and maintaining a reliable
schedule could help Treasury communicate accurate time frames to
program stakeholders and ensure timely and efficient implementation of
remaining SSBCI components. These components include

•   reviewing capital program applications and disbursing funds for tribal
    governments and consortiums;


27See GAO-16-89G.




Page 23                           GAO-23-105293 State Small Business Credit Initiative
                            •   reviewing applications for all participating jurisdictions for the technical
                                assistance program; and
                            •   developing compliance and performance monitoring plans for the
                                capital and technical assistance programs.

                            Treasury officials noted that Treasury’s approach to work planning was
                            influenced by a variety of factors, including the program office’s limited
                            staff resources and the need for flexibility in planned time frames. Officials
                            noted the value of conducting planning exercises to align staff resources
                            and sequence project activities. But they said that rigorous and time-
                            consuming project planning practices might not be appropriate because
                            of the significant workload required to implement the program. However,
                            incorporating these best practices for project scheduling does not
                            necessarily require significant staff resources and could help Treasury
                            more efficiently use the limited staff resources it has available.

                            Without a planning process that incorporates best practices for project
                            scheduling, Treasury may experience additional delays as it executes the
                            remaining key implementation steps for SSBCI. In turn, this may impede
                            efforts to disburse the remaining funds and conduct oversight of
                            jurisdictions’ use of funds in a timely manner. Treasury also may be
                            unable to share reliable time frames with participating jurisdictions, which
                            could hinder jurisdictions’ efforts to design and implement programs and
                            meet the needs of small businesses.


Treasury’s
Compliance and
Performance
Monitoring Efforts Are
in Progress
Treasury Has Begun          Treasury has taken steps to support and monitor jurisdictions’ compliance
Developing a Compliance     with SSBCI capital program guidelines, and has been developing
                            compliance procedures. Key components of Treasury’s compliance
Framework for the Capital
                            efforts include the following:
Program
                            •   Compliance monitoring procedures. Treasury officials said the
                                agency plans to use compliance monitoring procedures similar to
                                those used for the original SSBCI. They plan to adjust those
                                procedures to account for the current program’s increased size and its



                            Page 24                           GAO-23-105293 State Small Business Credit Initiative
    new components, such as the addition of tribal governments and
    funding for very small and SEDI-owned businesses. According to
    officials, they expect these procedures to include conducting risk-
    based sampling of participant transactions, reviewing participant
    transactions prior to disbursing additional funds, and reviewing
    jurisdictions’ quarterly and annual reports. As of November 2022,
    officials were drafting a plan for these procedures. According to
    Treasury’s September 2022 work plan, the agency planned to
    complete a compliance monitoring plan for the SSBCI capital program
    by December 31, 2022.
•   National compliance and oversight standards. Treasury published
    standards for compliance and oversight by jurisdictions on November
    17, 2022. Similar to national compliance and oversight standards
    published for the original program, these standards describe best
    practices and Treasury’s recommended approach for designing and
    implementing a comprehensive compliance and oversight system.
    Treasury officials said the capital program policy guidelines also
    included some of the guidance from the original standards.
•   Compliance training. Treasury officials said they plan to conduct
    periodic compliance training for jurisdictions, particularly for tribal
    governments and smaller states and territories that may need
    additional support to handle the larger allocations they received under
    the current program. According to officials, the agency developed
    compliance training materials and held multiple rounds of this training
    as of December 31, 2022.

To mitigate potential compliance issues that may arise while the agency
develops its compliance framework, officials said jurisdictions will be able
to submit compliance questions to Treasury. They plan to meet frequently
with jurisdictions and lending partners to answer compliance questions.
Officials also said the application review process allows them to identify
potential issues and address them with jurisdictions before programs are
implemented. 28

In interviews conducted between March and May 2022, some states and
territories indicated a need for additional compliance guidance and tools.

28As part of the application review process, Treasury reviews whether the applicant has
represented that it completed the legal actions necessary to implement the proposed
capital programs and whether the application demonstrates an understanding of SSBCI
capital program guidelines. Treasury also evaluates the reporting mechanisms, audits, or
other internal controls and compliance activities the jurisdiction has in place to conduct
oversight and meet annual and quarterly reporting requirements.




Page 25                                GAO-23-105293 State Small Business Credit Initiative
                           Six of 12 states and one of four territories told us that additional checklists
                           or templates from Treasury would be helpful. For example, checklists or
                           templates that could be shared with participating small businesses or
                           lenders could help jurisdictions meet program requirements or prevent
                           compliance issues. Two states said Treasury’s guidance was unclear and
                           a third said it would be helpful if Treasury’s FAQs were more complete.

                           In the months since our interviews were conducted, Treasury issued
                           FAQs in June, July, August, September, and December 2022 to clarify
                           existing program guidelines. Treasury also published sample certifications
                           in June 2022 to help participating jurisdictions comply with certification
                           requirements in the SSBCI capital program guidelines, and published
                           standards for compliance and oversight by jurisdictions in November
                           2022. Treasury officials said they do not have immediate plans to develop
                           compliance templates and checklists, because it would be difficult to
                           develop a document that covers the nuances of every program that
                           jurisdictions plan to implement.

Treasury Plans to Use      Treasury officials said their approach to measuring performance for the
Performance Measures       SSBCI capital program will be similar to their approach for the original
                           SSBCI, with some additions such as measuring performance for the
from the Original SSBCI
                           SEDI-owned business component. As we reported in December 2013,
and Develop Measures for   Treasury’s performance measures for the original program included the
New Program Elements
                           •   amount of SSBCI funds used over time, as reported in SSBCI
                               quarterly reports;
                           •   volume and dollar amount of loans or investments supported by
                               SSBCI funds, as reported in SSBCI annual reports;
                           •   amount, in dollars, of private-sector leverage in SSBCI annual reports;
                               and
                           •   estimated number of jobs created or retained in SSBCI annual
                               reports.

                           As of September 30, 2022, Treasury had issued capital program reporting
                           guidance for jurisdictions and was developing performance measures for
                           that component of the current SSBCI and an online portal for jurisdictions
                           to submit reporting data. 29 Treasury had not yet developed performance
                           measures or reporting guidance for the technical assistance component

                           29Treasury issued capital program reporting guidance in May 2022 and updated guidance
                           in September 2022.




                           Page 26                              GAO-23-105293 State Small Business Credit Initiative
                     of SSBCI. The capital program reporting guidance requires jurisdictions to
                     submit quarterly and annual reports and report data on recipient business
                     and investment characteristics, the number of jobs expected to be
                     created and retained, and the amount of private financing obtained.
                     Jurisdictions must report on demographic-related characteristics of small
                     businesses participating in their programs, including the SEDI-owned
                     status of businesses and the race, ethnicity, gender, sexual orientation,
                     and veteran status of principal business owners, to the extent businesses
                     provide this information.

                     The reauthorized SSBCI provides critical funding to states, territories, and
Conclusions          tribal governments to facilitate small business lending and investing in the
                     aftermath of the COVID-19 pandemic. SSBCI’s focus on very small and
                     SEDI-owned businesses in particular makes it an important program for
                     reaching businesses that historically have faced difficulties obtaining
                     access to finance. While Treasury has made progress in implementing a
                     large and complex program, it has taken longer than expected to disburse
                     funds to jurisdictions. And significant implementation steps remain, such
                     as continuing to review applications and implementing compliance
                     monitoring and performance measurement plans. As Treasury plans work
                     and manages time frames for remaining SSBCI implementation steps, its
                     planning efforts could benefit from fully incorporating best practices for
                     project scheduling, such as sequencing and assigning resources for
                     planned activities and updating the schedule to reflect actual progress.
                     Fully incorporating these practices could better position Treasury to
                     establish and communicate reliable time frames and reduce the potential
                     for additional delays.

                     Treasury’s Chief Recovery Officer should fully incorporate best practices
Recommendation for   for project scheduling related to sequencing and establishing the duration
Executive Action     of activities, assigning resources to activities, and updating the schedule
                     using actual progress into its planning processes for the SSBCI program.
                     (Recommendation 1)

                     We provided a draft of this report to Treasury for review and comment.
Agency Comments      Treasury provided written comments, which are provided in appendix III.
and Our Evaluation   Treasury also provided technical comments, which we incorporated as
                     appropriate.

                     In its written comments, Treasury stated that it agreed with the goal of
                     ensuring appropriate planning and scheduling for Treasury’s
                     implementation of the SSBCI program. Treasury stated it will study GAO’s
                     best practices for project scheduling and review options for incorporating


                     Page 27                         GAO-23-105293 State Small Business Credit Initiative
additional functionality into its planning for the SSBCI program in line with
our recommendation.

Following this review of options, implementing the recommendation by
fully incorporating these practices would help better position Treasury to
set reliable time frames and limit additional delays for remaining SSBCI
implementation steps.

We are sending copies of this report to the appropriate congressional
committees and the Secretary of the Treasury. In addition, the report is
available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact
Michael Clements at 202-512-8678 or clementsm@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. GAO staff who made key
contributions to this report are listed in appendix IV.




Michael E. Clements
Director, Financial Markets and Community Investment




Page 28                          GAO-23-105293 State Small Business Credit Initiative
Congressional Addressees

Chair
Vice Chair
Committee on Appropriations
United States Senate

Chair
Ranking Member
Committee on Finance
United States Senate

Chair
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

Chair
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Kay Granger
Chair
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives




Page 29                       GAO-23-105293 State Small Business Credit Initiative
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives

The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives

The Honorable Lisa Murkowski
United States Senate




Page 30                        GAO-23-105293 State Small Business Credit Initiative
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology


Methodology

              This report evaluates the Department of the Treasury’s implementation of
              the State Small Business Credit Initiative (SSBCI), reauthorized by the
              American Rescue Plan of 2021. Specifically, we examined (1)
              jurisdictions’ planned use of SSBCI funds to meet program objectives, (2)
              Treasury’s completion of key implementation steps for SSBCI, and (3)
              Treasury’s efforts to manage program risks and measure program
              performance.

              To address the first objective, we reviewed and analyzed Treasury data
              on total preliminary funding allocations for states, territories, and tribal
              governments. These are allocations for the main capital program, very
              small businesses, businesses owned by socially and economically
              disadvantaged individuals (SEDI-owned businesses), and the SEDI-
              owned business incentive fund. We reviewed and analyzed data on the
              number of applications approved and the amount of funds disbursed to
              states and territories as of September 30, 2022. We compared these data
              to determine which states and territories had not yet received funds. We
              assessed the reliability of these data by reviewing Treasury guidance and
              methodologies for allocating funds to jurisdictions and interviewing
              Treasury officials about their process for ensuring the accuracy of the
              data. We found these data to be sufficiently reliable for describing
              preliminary funding allocation amounts for states, territories, and tribal
              governments and disbursement amounts for states and territories.

              To describe how jurisdictions planned to use SSBCI funds, we reviewed
              and analyzed Treasury data on states and territories’ planned programs,
              which were obtained from Treasury’s ongoing reviews of applications for
              the SSBCI capital program as of September 2, 2022. 1 We obtained data
              on the types of programs implemented by states and territories during the
              original SSBCI from Treasury’s 2016 SSBCI program evaluation. We
              compared the number of programs implemented during the original
              SSBCI to the number of planned programs for the current SSBCI. We
              assessed the reliability of these data by obtaining written responses from
              knowledgeable Treasury officials about their process for ensuring the
              accuracy of the data. We found these data to be sufficiently reliable for
              describing the planned programs.




              1These data are subject to change as Treasury continues reviewing and approving
              applications.




              Page 31                              GAO-23-105293 State Small Business Credit Initiative
Appendix I: Objectives, Scope, and
Methodology




We interviewed officials from four of the five permanently inhabited
territories and a nongeneralizable selection of 12 states and three tribal
governments. 2 We selected states with a range of (1) total preliminary
funding allocations for the current SSBCI, (2) preliminary funding
allocations for SEDI-owned businesses, and (3) geographic location; and
to include states that did and did not participate in the original SSBCI
program. We selected tribal governments that submitted a Notice of Intent
to apply for SSBCI and to represent a range of geographic regions and
sizes based on preliminary total funding allocations. We contacted 16
tribal governments and interviewed representatives of the three tribal
governments that responded, which represented three different
geographic regions (Midwest, Northwest, and Southern Plains) and all
had preliminary allocation amounts greater than the median amount of
approximately $686,000. 3

Our interviews focused on the types of programs jurisdictions planned to
implement, perspectives on Treasury’s implementation of SSBCI, and any
challenges faced or areas in which Treasury could provide additional
guidance or support. For the states and territories we interviewed, we
obtained and analyzed information on the types of programs they planned
to implement and whether they would restart programs from the original
SSBCI or develop new ones. We obtained this information through a pre-
interview questionnaire that asked jurisdictions about the status of their
application for the SSBCI capital programs, the types of programs they
were planning to implement, and whether they were planning to
implement new programs, restart programs, or fund ongoing programs.

To address the second objective, we reviewed relevant legislation and
SSBCI documentation, including program guidelines and application
materials for the capital and technical assistance programs, guidance in
the form of frequently asked questions, and Treasury notices. We
assessed Treasury’s efforts to implement its 2015 Tribal Consultation

2We interviewed representative from the following states: Alabama, Alaska, Arizona,
California, Florida, Illinois, Massachusetts, Missouri, New Hampshire, New Jersey, North
Carolina, and North Dakota. We also interviewed representatives of four of the five
permanently inhabited U.S. territories: American Samoa, the Commonwealth of the
Northern Mariana Islands, Guam, and Puerto Rico. We requested interviews with all five
territories; one did not respond to our request. We interviewed representatives of three
tribal governments: the Confederated Tribes of the Umatilla Indian Reservation, Little
Traverse Bay Bands of Odawa Indians, and Wichita and Affiliated Tribes.
3We categorized tribal governments by geographic region based on the 12 regions used
by the Bureau of Indian Affairs in the Department of the Interior.




Page 32                                 GAO-23-105293 State Small Business Credit Initiative
Appendix I: Objectives, Scope, and
Methodology




Policy for SSBCI by reviewing tribal consultation agendas and meeting
notes. We reviewed and analyzed Treasury’s time frames for developing
and updating program guidelines and application deadlines for the capital
and technical assistance programs using program guidelines, notices,
and information on SSBCI’s public website. We reviewed Treasury’s work
plan and other planning efforts for SSBCI and compared them to our best
practices for project scheduling. 4 Specifically, we compared Treasury’s
work plan and planning efforts to best practices related to sequencing and
establishing the duration of activities, assigning resources to activities,
and updating the schedule using actual progress. We interviewed
Treasury officials on the steps they took to implement SSBCI, including
hiring staff, and about implementation time frames and any planning
efforts.

To address the third objective, we reviewed prior GAO and Treasury
Office of Inspector General reports, Treasury’s national compliance and
oversight standards for the original and current SSBCI, and Treasury’s
reporting guidance for the current SSBCI capital program. Treasury’s
compliance monitoring procedures and performance monitoring
documents for SSBCI were under development at the time of our review.
We interviewed Treasury officials on their approaches to risk
management, including compliance monitoring and performance
measurement plans.

For all our objectives, we interviewed experts from three business
organizations (America’s Small Business Development Network, Council
of Development Finance Agencies, and State Science and Technology
Institute); two lender organizations (National Venture Capital Association
and Opportunity Finance Network); and six tribal organizations (Affiliated
Tribes of Northwest Indians Economic Development Corporation,
Midwest Alliance of Sovereign Tribes, NAFOA, Native American
Development Corporation, Native CDFI Network, and United South and
Eastern Tribes Sovereignty Protection Fund). We discussed their
perspectives on how states, territories, and tribal governments planned to
use SSBCI funding, Treasury’s implementation of the program, and any
challenges faced.

We conducted this performance audit from August 2021 to February 2023
in accordance with generally accepted government auditing standards.


4See GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules,
GAO-16-89G (Washington, D.C.: Dec. 22, 2015).




Page 33                              GAO-23-105293 State Small Business Credit Initiative
Appendix I: Objectives, Scope, and
Methodology




Those standards require that we plan and perform the audit to obtain
sufficient, 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.




Page 34                              GAO-23-105293 State Small Business Credit Initiative
Appendix II: Best Practices for Creating and  Appendix II: Best Practices for Creating and
                                              Maintaining Reliable Schedules


Maintaining Reliable Schedules

                                              GAO’s Schedule Assessment Guide outlines best practices for creating
                                              and maintaining a high-quality and reliable project schedule. 1 The 10 best
                                              practices described below represent key concepts and activities for
                                              developing such schedules. They help integrate the planned work, the
                                              resources necessary to accomplish that work, and the associated budget.
                                              These best practices are in no particular order and are not intended as a
                                              series of steps for developing a schedule.

Table 3: GAO’s Best Practices for Project Schedules

Best practice                  Description
Capturing all activities       The schedule should reflect all activities as defined in the program’s work breakdown structure, which
                               defines in detail the work necessary to accomplish a project’s objectives.
Sequencing all activities      The schedule should be planned so that critical program dates can be met. To do this, activities must be
                               logically sequenced and linked—that is, listed in the order in which they are to be carried out and joined
                               with logic. In particular, a predecessor activity must start or finish before its successor. Date constraints
                               and lags should be minimized and justified. This helps ensure that the interdependence of activities that
                               collectively lead to the completion of activities or milestones can be established and used to guide work
                               and measure progress.
Assigning resources to all     The schedule should reflect the resources (labor, materials, travel, facilities, equipment, and the like)
activities                     needed to do the work, whether they will be available when needed, and any constraints on funding or
                               time.
Establishing the duration      The schedule should realistically reflect how long each activity will take. Durations should be reasonably
of all activities              short and meaningful and should allow for discrete progress measurement. Schedules that contain
                               planning and summary planning packages as activities will normally reflect longer durations until broken
                               into work packages or specific activities.
Verifying that the             The schedule should be horizontally traceable, meaning that it should link products and outcomes
schedule can be traced         associated with other sequenced activities. Such links are commonly referred to as “hand-offs” and
horizontally and vertically    serve to verify that activities are arranged in the right order for achieving aggregated products or
                               outcomes. The schedule should also be vertically traceable—that is, data are consistent between
                               different levels of a schedule. When schedules are vertically traceable, lower-level schedules are clearly
                               consistent with upper-level schedule milestones, allowing for total schedule integrity and enabling
                               different teams to work to the same schedule expectations.
Confirming that the critical   The schedule should identify the program’s critical path—the path of longest duration through the
path is valid                  sequence of activities. Establishing a valid critical path is necessary for examining the effects of any
                               activity’s slipping along this path. The program’s critical path determines the program’s earliest
                               completion date and focuses the team’s energy and management’s attention on the activities that will
                               lead to the project’s success.
Ensuring reasonable total      The schedule should identify reasonable total float (or slack)—the amount of time a predecessor activity
float                          can slip before the delay affects the program’s estimated finish date—so that the schedule’s flexibility
                               can be determined. The length of delay that can be accommodated without the finish date’s slipping
                               depends on the number of date constraints within the schedule and the degree of uncertainty in the
                               duration estimates, among other factors, but the activity’s total float provides a reasonable estimate of
                               this value. As a general rule, activities along the critical path have the least total float. Unreasonably
                               high total float on an activity or path indicates that schedule logic might be missing or invalid.


                                              1See GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules,
                                              GAO-16-89G (Washington, D.C.: Dec. 22, 2015).




                                              Page 35                                  GAO-23-105293 State Small Business Credit Initiative
                                              Appendix II: Best Practices for Creating and
                                              Maintaining Reliable Schedules




Best practice                  Description
Conducting a schedule          A schedule risk analysis starts with a good critical path method schedule. Data about program schedule
risk analysis                  risks are incorporated into a statistical simulation to predict the level of confidence in meeting a
                               program’s completion date; to determine the contingency, or reserve of time, needed for a level of
                               confidence; and to identify high-priority risks. Programs should include the results of the schedule risk
                               analysis in constructing an executable baseline schedule.
Updating the schedule          Progress updates and logic provide a realistic forecast of start and completion dates for program
using actual progress          activities. Maintaining the integrity of the schedule logic is necessary to reflect the true status of the
and logic                      program. To ensure that the schedule is properly updated, people responsible for the updating should
                               be trained in critical path method scheduling.
Maintaining a baseline         A baseline schedule is the basis for managing the program scope, the time period for accomplishing it,
schedule                       and the required resources. The baseline schedule is designated the target schedule and is subjected to
                               a configuration management control process. Program performance is measured, monitored, and
                               reported against the baseline schedule. The schedule should be continually monitored so as to reveal
                               when forecasted completion dates differ from baseline dates and whether schedule variances affect
                               downstream work.
Source: GAO. | GAO-23-105293




                                              Page 36                                  GAO-23-105293 State Small Business Credit Initiative
Appendix III: Comments from the
                   Appendix III: Comments from the Department
                   of the Treasury


Department of the Treasury




         Page 37                                        GAO-23-105293 State Small Business Credit Initiative
          Appendix III: Comments from the Department
          of the Treasury




Page 38                                        GAO-23-105293 State Small Business Credit Initiative
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Michael E. Clements at 202-512-8678 or clementsm@gao.gov.
GAO Contact
                  In addition to the contact named above, John Fisher (Assistant Director),
Staff             Charlene Calhoon (Analyst in Charge), Ryder Buttry, Cathleen Carr, Gita
Acknowledgments   DeVaney, John Karikari, Kevin Lyman, Marc Molino, Sabrina Riddick,
                  Barbara Roesmann, and Farrah Stone made key contributions to this
                  report.




(105293)
                  Page 39                              GAO-23-105293 State Small Business Credit Initiative
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