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GAO-24-106755: Small Business Administration: Targeted Outreach about Disaster Assistance Could Benefit Rural Communities

Summary

GAO-24-106755, Small Business Administration: Targeted Outreach about Disaster Assistance Could Benefit Rural Communities, a Government Accountability Office Q&A report to congressional committees dated February 22, 2024. Prepared under the Disaster Assistance for Rural Communities Act, it examines SBA disaster loan trends in rural and urban areas for fiscal years 2017–2022 and challenges rural communities may face after disasters. It reports that rural and urban disaster loan applications were approved and declined at comparable rates, and that disaster survivors may lack awareness or understanding of SBA's disaster loans. GAO recommends that SBA distinguish between rural and urban communities in its outreach and marketing plan, and SBA concurred.

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“GAO-24-106755: Small Business Administration: Targeted Outreach about Disaster Assistance Could Benefit Rural Communities.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-24-106755-small-business-administration-targeted-outreach-about-di-6c7cc3cc65/, SHA-256 4ca43e14e7e543f7018982c76857dc36f6358c5a3fe8dab503885f9529943f7c.

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                        U.S. Government Accountability Office

Small Business Administration: Targeted
Outreach about Disaster Assistance Could
Benefit Rural Communities
GAO-24-106755
Q&A Report to Congressional Committees
February 22, 2024


Why This Matters            We have previously reported that the number and cost of weather and climate
                            disasters, such as tornadoes and wildfires, are increasing in the United States. In
                            recovering from a disaster, rural communities may face different challenges than
                            urban communities because of their distinctive characteristics. According to the
                            2020 Census, approximately 20 percent of the U.S. population lived in rural
                            areas, and rural areas represented 97 percent of the land area.
                            The Disaster Assistance for Rural Communities Act includes a provision for GAO
                            to examine the unique challenges rural areas face when seeking disaster
                            assistance from the Small Business Administration (SBA) and identify potential
                            legislative recommendations for improving rural areas’ access to such
                            assistance. 1 This report examines how SBA’s disaster loan program assists
                            communities after disasters, disaster loan trends in rural and urban areas for
                            fiscal years 2017–2022, challenges rural communities may face after disasters,
                            and SBA’s actions that may address those challenges.


Key Takeaways               •   Applications for disaster loans from rural and urban areas were approved and
                                declined at comparable rates from fiscal years 2017 through 2022.
                            •   Rural areas have characteristics that can make disaster recovery difficult.
                                These include infrastructure vulnerabilities, limited local capacity and
                                resources, and rural demographics or social norms.
                            •   Rural areas face challenges in seeking SBA assistance following a disaster.
                                For example, disaster survivors may lack awareness or understanding of
                                SBA’s disaster loans. SBA has taken some actions that may help address
                                these types of challenges, but they are not specifically targeted to rural areas.
                            •   SBA has issued a regulation and taken other steps to implement the newly
                                authorized rural disaster declaration, which provides SBA with an additional
                                way to declare a disaster that is specific to rural areas.
                            •   We recommend that SBA distinguish between rural and urban communities in
                                its outreach and marketing plan. SBA concurred with our recommendation.


What SBA assistance is SBA’s Disaster Loan Program is available to rural and urban communities to
available for rural    cover qualified losses after a declared disaster. Disaster loans are intended to
communities after a    help homeowners, renters, businesses, and nonprofits repair, rebuild, and
disaster?              recover from physical and economic losses after a declared disaster. The three
                            main types of loans for disaster-related losses are (1) home and personal
                            property loans, (2) business physical disaster loans, and (3) Economic Injury


Page 1                                                             GAO-24-106755 Small Business Administration Disaster Assistance
                           Disaster Loans (EIDL) to cover normal operating expenses that cannot be met
                           due to the disaster (see table 1). 2

                           Table 1: Characteristics of SBA Disaster Loans
                            Type of loan                    Eligible borrowers                         Lending limits and use of fundsa
                            Home and personal               Homeowners and renters                     Homes. Up to $500,000 to replace or
                            property loans                                                             repair primary residences.
                                                                                                       Personal property. Up to $100,000 to
                                                                                                       replace or repair property (e.g., clothing,
                                                                                                       furniture, cars, and appliances) damaged or
                                                                                                       destroyed in a declared disaster.
                            Business physical               Most types of businesses                   Up to $2 million to repair or replace
                            disaster loansb                 and nonprofit organizations                property damaged in a declared disaster
                                                            regardless of size                         that is owned by the business, including
                                                                                                       leasehold improvements, furniture and
                                                                                                       fixtures; to refinance liens on damaged
                                                                                                       property; and to implement mitigation
                                                                                                       measures to project the damaged or
                                                                                                       destroyed property from future disasters.
                            Economic Injury                 Small businesses, small                    Up to $2 million of working capital to help
                            Disaster Loans                  agricultural and producer                  meet financial obligations and operating
                            (EIDL)                          cooperatives, small                        expenses that cannot be met as a result of
                                                            aquaculture enterprises,                   the disaster.
                                                            designated small nurseries,
                                                            and private nonprofit
                                                            organizations
                           Source: GAO analysis of Small Business Administration (SBA) information. | GAO-24-106755
                           aThe home and personal property loan limits apply to disasters declared on or after July 31, 2023, and the

                           current business loan limits have been in place since 2008.
                           bDisaster business loans, including both physical disaster loans and EIDLs, to the same borrower, together with

                           its affiliates, cannot exceed $2 million. 13 C.F.R. § 123.202.

                           This report uses Census Bureau definitions of “rural area” and “urban area,” and
                           it uses “rural community” to refer to a place, such as a county, that predominately
                           consists of rural areas. According to the Census Bureau, urban areas represent
                           densely developed territory and encompass residential, commercial, and other
                           nonresidential urban land uses. Each urban area must encompass at least 2,000
                           housing units or at least 5,000 people. Rural areas encompass all population,
                           housing, and territory not included within an urban area.


How does SBA            To administer the Disaster Loan Program, SBA’s Office of Disaster Recovery and
administer the Disaster Resilience has two Field Operations Centers that establish and maintain field
Loan Program?           operations and conduct SBA outreach in disaster areas. 3 These efforts may
                           include allocating SBA staff to federal Disaster Recovery Centers, which inform
                           disaster survivors about available federal assistance. The Field Operations
                           Centers also set up SBA Disaster Loan Outreach Centers and Business
                           Recovery Centers at disaster locations to help individuals and businesses apply
                           for disaster loans. In addition, SBA’s Office of Disaster Recovery and Resilience
                           reviews disaster declaration requests and works with federal agencies and state
                           and local governments to determine whether a minimum amount of damage or
                           economic injury occurred for a disaster declaration.
                           SBA’s Office of Capital Access is responsible for all disaster lending policy and
                           loan-making operations, including loan origination, processing, closing,
                           disbursement, and servicing. It also manages the Disaster Customer Service
                           Center to respond to incoming disaster survivor phone calls and emails.




Page 2                                                                                     GAO-24-106755 Small Business Administration Disaster Assistance
What is the process for   The process for making SBA disaster loans available to disaster survivors has
making SBA disaster       several phases, including disaster declaration, local outreach, and application
loans available to        submission and processing, loan closing and disbursement, and loan servicing
disaster survivors?       (see fig. 1).

                          Figure 1: SBA Disaster Loan Process




                          a
                           SBA refers applicants that do not meet minimum income and credit requirements or are declined to the Federal
                          Emergency Management Agency, which offers financial and direct services to eligible disaster survivors.

                          A federal disaster must be declared by the President or SBA Administrator for
                          SBA disaster loans to become available to homeowners, renters, businesses, or
                          nonprofits in the disaster area. The type of disaster declaration governs the
                          eligible borrowers and types of loan products available. Some declarations make
                          all three types of SBA disaster loans available to eligible homeowners, renters,
                          businesses, and nonprofits. Other declarations limit the loan type and eligible
                          borrowers, such as declarations that make only EIDLs available for small
                          businesses and private nonprofits. Disaster declarations define the disaster area
                          as the county or counties directly affected by the disaster (referred to as primary
                          counties). Depending on the type of declaration, the disaster area may also
                          include counties contiguous with the primary counties or other political
                          subdivisions.
                          After a disaster is declared, SBA conducts outreach to raise public awareness
                          and inform eligible homeowners, renters, businesses, and nonprofits about the
                          available disaster loan products. SBA deploys staff to the disaster area and
                          provides information to local media. Other federal, state, and local officials who
                          are knowledgeable about the Disaster Loan Program and who are operating in
                          the disaster area may augment SBA’s outreach.
                          Homeowners, renters, businesses, and nonprofits submit disaster loan
                          applications directly to SBA. SBA accepts an application if it is complete and
                          meets minimum qualifying requirements for disaster loans. 4 SBA then
                          underwrites the application and decides to approve or decline the loan,
                          depending on whether the applicant meets SBA’s eligibility and underwriting
                          criteria. If an application is approved and the loan is closed (i.e., loan documents
                          are signed and returned to SBA), the funding is disbursed to the borrower.
                          In addition, applicants may withdraw their applications prior to SBA’s underwriting
                          decision, and applicants or borrowers can cancel their loans or reduce their loan
                          amount before or after the loan is closed. Additionally, SBA may withdraw an
                          application if the applicant’s information cannot be verified or if the applicant fails
                          to provide requested documentation. SBA may cancel a loan if the applicant fails
                          to complete closing documents, or if the borrower fails to satisfy the terms and
                          conditions of the loan or experiences adverse economic changes.


Page 3                                                                       GAO-24-106755 Small Business Administration Disaster Assistance
How do SBA disaster    Applications for disaster loans from rural and urban areas were approved and
loan outcomes          declined at comparable rates for disasters that occurred in fiscal years 2017
compare in rural and   through 2022.
urban areas?
                       Accepted applications

                       During this 6-year period, SBA received 1,165,635 applications (15.7 percent of
                       these were from rural areas) and accepted 809,180 (16.9 percent were from rural
                       areas) that met minimum qualifying requirements for disaster loans. SBA
                       accepted a higher proportion of applications from rural areas (75 percent) than
                       from urban areas (68 percent). SBA received more applications from urban areas
                       because more individuals and businesses are located in urban areas. The
                       number of applications and loans fluctuated from year to year due to variation in
                       the number, intensity, and location of disasters. 5

                       Loan outcomes

                       Overall, disaster loan applications from rural and urban areas had similar
                       outcomes for fiscal years 2017–2022 (see fig. 2). Across both types of areas,
                       SBA approved about 40 percent and declined about 40 percent of accepted
                       applications. 6 The remaining applications were withdrawn (18.5 percent) or were
                       still in process as of June 2023 (1.7 percent).

                       Figure 2: Outcomes of Disaster Loan Applications SBA Accepted by Geographic Area,
                       Fiscal Years 2017–2022




                       Note: Our analysis includes applications SBA accepted as meeting minimum qualifying requirements and
                       excludes 16,581 duplicate applications and 4,301 applications that could not be classified as rural or urban. A
                       duplicate application occurs when an applicant submits more than one application for the same event. In-
                       process applications were still undergoing review by SBA as of June 2023.

                       Loan product approval rates

                       Loan outcomes were also similar for rural and urban areas when analyzed by
                       loan type (see fig. 3). 7




Page 4                                                                      GAO-24-106755 Small Business Administration Disaster Assistance
         Figure 3: Approval and Decline Rates of Disaster Loan Applications SBA Accepted, by Loan
         Product and Geographic Area, Fiscal Years 2017–2022




         Note: Our analysis includes applications SBA accepted as meeting minimum qualifying requirements and
         excludes duplicate applications and applications that could not be classified as rural or urban. The approval rate
         represents the number of approved applications divided by the sum of approved and declined applications.
         Homeowners and renters may apply for home and personal property loans, and businesses may apply for a
         combined physical disaster loan and EIDL or only an EIDL. Business loans include loans to nonprofits.

         Reasons loans were declined or applications were withdrawn

         The top reasons SBA declined loans were generally consistent across rural and
         urban areas (see fig. 4).

         Figure 4: Top Reasons SBA Declined Disaster Loans, by Geographic Area, Fiscal Years
         2017–2022




         Similarly, the top reasons SBA or applicants withdrew applications were
         generally consistent across rural and urban areas (see fig. 5). In addition, overall,
         about a third of applications were withdrawn by the applicants. A higher
         proportion of applicants from rural areas (35 percent) than from urban areas (30
         percent) withdrew their applications.

         Figure 5: Top Reasons SBA Withdrew Disaster Loan Applications, by Geographic Area,
         Fiscal Years 2017–2022




         Canceled loans

         After a disaster loan application is approved, the loan may be canceled by the
         borrower or SBA. A higher proportion of disaster loans from rural areas (29
         percent) than from urban areas (23 percent) were canceled, and cancellation
         rates varied by loan product (see fig. 6).
Page 5                                                        GAO-24-106755 Small Business Administration Disaster Assistance
                           Figure 6: Proportion of SBA Disaster Loans That Were Canceled, by Loan Type and
                           Geographic Area, Fiscal Years 2017–2022




                           The reasons loans were canceled were consistent across rural and urban areas.
                           Overall, about 60 percent of canceled loans were canceled at the borrower’s
                           request. SBA canceled the remaining loans, with the top reasons being that
                           borrowers did not complete their closing documents (55 percent), had adverse
                           changes in their economic circumstances (23 percent), or failed to satisfy terms
                           and conditions of the loan (9 percent). SBA referred borrowers with adverse
                           economic changes to the Federal Emergency Management Agency’s Individuals
                           and Households Program.


What characteristics of Rural communities may have characteristics—related to infrastructure, local
rural communities can capacity and resources, and demographics and social norms—that can make
make recovering from a recovery difficult.
disaster difficult?
                           Infrastructure vulnerabilities

                           Infrastructure vulnerabilities in rural communities include limited
                           telecommunication networks, issues with transportation networks, certain types
                           of geography, and lack of temporary housing. These vulnerabilities can affect
                           disaster recovery.
                           Telecommunications. Rural communities are more likely to have limited
                           telecommunication services because of geographic barriers, such as mountains,
                           or limited demand due to smaller and sparser populations. A lack of reliable
                           telecommunication services, such as broadband and cellular, can hamper
                           communication and outreach to survivors, according to representatives from two
                           regional nonprofit organizations, SBA field offices, and five state and local
                           stakeholders we interviewed. It can also make it harder for disaster survivors to
                           apply for disaster assistance. We reported in 2020 that lack of or intermittent
                           cellular service can make it difficult for SBA to communicate with other staff and
                           with disaster survivors. 8 We also reported in 2021 that lack of consistent internet
                           access makes it difficult for disaster survivors in rural locations to apply for
                           federal assistance. 9
                           Transportation networks. Transportation issues can leave rural communities
                           isolated. Closed roads caused by fallen debris can make it hard to reach
                           survivors to provide outreach, assistance, or basic supplies. Rural communities
                           also often lack public transportation, which can hinder survivors in getting to
                           locations offering disaster assistance, such as Disaster Recovery Centers or
                           SBA Business Recovery Centers, according to some regional nonprofit
                           organizations we spoke with.
                           Geography. Geography in rural communities can make it harder to access
                           resources, such as supplies for basic needs, clean-up, or rebuilding, according to
                           three state and local stakeholders. Isolated rural areas may have limited supplies

Page 6                                                              GAO-24-106755 Small Business Administration Disaster Assistance
         nearby, according to some state and local officials, and the cost of supplies may
         increase substantially following a disaster.
         Mountainous terrain can make it especially difficult to get supplies to a disaster-
         affected area. Such terrain can also make recovery after a wildfire challenging.
         For example, in one mountain community we visited, a state official explained
         that burned utility poles must be replaced on mountainsides using helicopters or
         by carrying them up the mountain.
         Temporary housing. Disasters can result in increased demand for housing from
         both displaced survivors and aid workers. Rural communities may lack sufficient
         temporary housing, especially when a disaster damages or destroys existing
         housing stock, according to officials from two regional nonprofit organizations
         and six state and local stakeholders. The National Low Income Housing Coalition
         reported that following a disaster, lack of affordable housing can cause rural
         families to be displaced by more than 100 miles from their homes, schools, and
         jobs. 10 This can require disaster survivors to make difficult decisions about
         whether to stay in the community and rebuild or to leave, according to an official
         we interviewed at one regional nonprofit organization.

         Limited local capacity

         Rural communities tend to have limited local capacity and resources, including
         both human resources and funding. We reported in December 2021 that
         communities that have not previously experienced a disaster may lack
         knowledge about the federal resources available and how to access them. 11 Two
         state entities and seven local stakeholders from the disaster locations we visited
         told us their local officials had limited knowledge of or prior experience with a
         large-scale disaster.
         Low-income and rural communities often do not have the capacity to support
         recovery activities, as we reported in 2021. For example, some rural communities
         may not have funding available to create or staff emergency management
         departments. 12 Rural areas may also experience outsized economic effects. For
         example, one disaster location we visited relied heavily on a single large
         employer that was destroyed during a disaster, greatly affecting the town’s tax
         base.

         Rural demographics and social norms

         The demographics or social norms of certain rural communities may affect their
         ability to recover from disasters. According to a 2007 paper, many rural
         communities are characterized by poverty, which can shape their capacity to
         respond to and recover from disasters. 13 According to the most recent estimates
         from the 2019 American Community Survey, the poverty rate for rural areas was
         15.4 percent, compared to 11.9 percent for urban areas.
         Building trust is important because some people in rural communities distrust
         outsiders, including the federal government, according to multiple stakeholders
         we interviewed. SBA officials from one district office told us they had better
         engagement with disaster survivors when they worked closely with local officials
         to reach out to the community. The importance of building trust was echoed
         throughout our conversations with four state and local stakeholders, who noted
         that rural disaster survivors were often hesitant to engage with the federal
         government.
         People in rural communities also tend to prefer in-person outreach, according to
         research and six state and local stakeholders. In April 2022, the Consumer
         Financial Protection Bureau reported that people in rural communities prefer

Page 7                                          GAO-24-106755 Small Business Administration Disaster Assistance
                            working with smaller banks and conducting all banking activities in person. 14 One
                            state entity suggested that SBA do more face-to-face outreach for its disaster
                            loans to help build trust with disaster survivors.


What are some of the    Challenges to obtaining SBA disaster assistance in rural areas can include
challenges to obtaining qualifying for a disaster declaration, survivors’ lack of awareness, and a complex
SBA assistance?         application process, according to our prior work and interviews with selected
                            regional nonprofit organizations and state and local officials.
                                                                                       15             However, these
                            challenges may not be unique to rural areas.

                            Qualifying for a disaster declaration

                            Qualifying for certain types of disaster declarations requires a minimum number
                            of damaged properties or a minimum amount of economic injury to businesses.
                            Communities must conduct and submit damage assessments, which can be time
                            consuming and onerous, according to some state and local stakeholders. Some
                            disasters create challenges in collecting damage data. For example, wildfires can
                            destroy markers, such as house numbers that identify a property, according to
                            one state official.
                            Furthermore, because rural areas are less densely populated than urban areas,
                            historically it has been difficult for rural areas to meet damage thresholds to
                            qualify for assistance. For example, some rural communities have had too few
                            damaged homes following disasters to qualify for federal assistance, according to
                            a representative of one regional nonprofit organization providing assistance in
                            disaster relief and recovery.
                            As discussed later in this report, the Disaster Assistance for Rural Communities
                            Act gave the SBA Administrator authority to make a rural disaster declaration
                            when, among other things, just one qualifying property has incurred significant
                            damage.

                            Survivors’ lack of awareness and understanding

                            SBA’s Office of Disaster Recovery and Resilience Outreach and Marketing Plan
                            states that one of SBA’s biggest challenges is communities’ lack of awareness of
                            SBA disaster assistance. 16 Officials we interviewed from three regional nonprofit
                            organizations and local officials in the three disaster locations we visited told us
                            that disaster survivors were not aware that SBA offered disaster loans to
                            homeowners in addition to businesses. In one location we visited, SBA
                            conducted its outreach virtually because the disaster occurred during the early
                            stages of the COVID-19 pandemic. SBA offered a 1-800 number, email address,
                            and website for disaster survivors to obtain information on SBA assistance.
                            However, most local stakeholders we spoke with were not aware of these
                            resources.

                            SBA’s application process

                            State and local officials at two disaster locations we visited described the SBA
                            application process as complex, slow, and inefficient. According to three regional
                            nonprofit organizations, following a disaster, people are traumatized, which
                            makes it even more difficult to navigate a complex process. State officials at two
                            disaster locations said disaster survivors preferred having someone walk them
                            through the application process in person rather than using a website. State and
                            local officials at two locations we visited described examples of SBA requesting
                            the same document multiple times, which was frustrating for residents.


Page 8                                                             GAO-24-106755 Small Business Administration Disaster Assistance
                         In a February 2020 report, we described challenges experienced by disaster loan
                         applicants and the providers that assist them. 17 Reported challenges to applying
                         for assistance included the time and burden of providing the required loan
                         documentation, frequent changes in loan officers or case managers, poor
                         customer service, lack of translation services, and delayed loan disbursements.


How can the new rural    The Disaster Assistance for Rural Communities Act authorized the SBA
disaster declaration     Administrator to declare a disaster in a rural area when just one qualifying
increase access to SBA   property has incurred significant damage and other criteria are met, as further
disaster assistance?     described below. 18 This new declaration may increase access to the Disaster
                         Loan Program for homeowners, renters, and businesses in rural areas.
                         Legislative history indicates that the rural disaster declaration was intended to
                         address situations in which a natural disaster significantly affects a large
                         proportion of a small, sparsely populated rural community but does not reach the
                         minimum threshold of damaged properties to be eligible for another type of
                         agency disaster declaration. 19 SBA implemented the new disaster declaration by
                         issuing a direct final rule that became effective on June 5, 2023. SBA is
                         authorized to declare a disaster in a rural area upon request by the governor of
                         the state or the chief executive of the Indian tribal government in which the rural
                         area is located if certain conditions are met. 20
                         Similar to other disaster declarations, SBA issues a rural disaster declaration at
                         the county level. A county may include rural and urban areas as defined by the
                         Census Bureau. Figure 7 describes the characteristics for the SBA rural disaster
                         declaration.

                         Figure 7: Characteristics of an SBA Rural Disaster Declaration




                         SBA estimates that approximately 50 additional disaster declarations will occur
                         annually with this new type of declaration. According to SBA officials, this
                         estimate is based on the average number of annual disaster declarations for
                         which only Public Assistance was authorized between 2013 and 2022.


How is SBA               To implement the Disaster Assistance for Rural Communities Act, SBA has
implementing the new     issued an implementing regulation, developed internal policies and guidelines,
rural disaster           and conducted training on the new disaster declaration. From June to November
declaration?             2023, the new authority allowed SBA to issue 12 rural disaster declarations
                         across 11 states—Alabama, California, Colorado, Illinois, Mississippi, Missouri,
                         Nevada, New Jersey, Oklahoma, Vermont, and Wyoming. According to SBA,
                         these declarations likely would not have occurred without SBA’s new authority.
                         Regulation. The act required SBA to issue implementing regulations within 120
                         days after enactment to carry out implementation of the rural disaster
                         declaration. 21 On April 19, 2023, SBA issued a direct final rule with an effective


Page 9                                                              GAO-24-106755 Small Business Administration Disaster Assistance
                          date of June 5, 2023, which implemented the rural disaster declaration now
                          codified at 13 C.F.R. § 123.3(a)(6). 22
                          Guidelines. SBA has developed guidelines for field operations staff to determine
                          if a damaged property is located within a rural area for declaration purposes.
                          SBA officials told us the disaster assistance standard operating procedures will
                          be updated to include the rural disaster declaration in fiscal year 2024. They said
                          they will use the same outreach approaches for the rural disaster declaration as
                          for all other disaster declarations.
                          Reporting. The act requires SBA to provide a report to Congress within 120
                          days of enactment and annually thereafter highlighting certain information
                          pertaining to rural areas and the rural disaster declaration. 23 On May 2, 2023,
                          SBA provided a report to congressional committees that noted the following:
                          •   Between April 19, 2022, and April 20, 2023, SBA approved 2,478 EIDLs for
                              $137.3 million in rural areas in response to major disasters declared by the
                              President.
                          •   No rural disaster declarations had yet been made because the implementing
                              regulations were not yet effective.
                          •   SBA published a direct final rule to implement the new declaration authority
                              on April 19, 2023, within the statutory deadline.
                          Training. SBA has conducted internal and external training on the new rural
                          disaster declaration, according to agency officials. SBA officials told us they
                          provided training to their field operations staff, who are responsible for
                          conducting damage assessments and coordinating outreach efforts with federal,
                          state, and local partners. According to agency officials, two external trainings
                          were conducted in May 2023, which included state emergency managers, SBA
                          resource partners, and chambers of commerce. Further, SBA officials stated in
                          January 2024 that they have incorporated training on the rural disaster
                          declaration into their default trainings.
What changes has SBA SBA has introduced new outreach approaches in recent years.
been making to its   Portable outreach centers. SBA set up its first Portable Loan Outreach Center
outreach?            in October 2022 in Florida following Hurricane Ian. These centers can be
                          established in any hard-to-reach area, including rural communities. Subsequent
                          centers were set up in Alabama, Mississippi, and Hawaii (see fig. 8). The centers
                          are staffed by customer service representatives who can provide full disaster
                          recovery center services for survivors, including application intake and loan
                          closing. These centers allow the agency to rapidly set up outreach and
                          assistance operations without the assistance of Federal Emergency
                          Management Agency or other resource partners. In January 2024, SBA stated
                          that it planned to add five additional Portable Loan Outreach Centers.




Page 10                                                          GAO-24-106755 Small Business Administration Disaster Assistance
                      Figure 8: Portable Loan Outreach Center in Rolling Fork, Mississippi, following March 2023
                      Tornadoes




                      Virtual outreach. SBA began using virtual outreach for the Disaster Loan
                      Program in 2020 during the COVID-19 pandemic. Officials say they will continue
                      to use this approach in an effort to meet survivors where they are. For virtual
                      outreach, SBA officials told us they contact survivors referred by state and local
                      entities and publicize a phone number and email address survivors can use to
                      contact SBA directly. Virtual outreach can be effective for some survivors who
                      are located far from SBA outreach centers, according to one regional nonprofit
                      organization.
                      “Whole-of-SBA” approach. The new “whole-of-SBA” approach is intended to
                      align the Disaster Loan Program with core SBA programs (i.e., small business
                      loans and resources). The purpose of this effort is to better meet the needs of
                      disaster survivors. The Office of Disaster Recovery and Resilience is leading this
                      new approach to disaster response and recovery to connect disaster survivors in
                      both rural and urban communities with other SBA assistance, such as small
                      business counseling and training. According to officials, the “whole-of-SBA”
                      approach was introduced internally to SBA in August 2023 and will be initiated in
                      2024 with the launch of a working group and the development of tools, guidance,
                      and policies and procedures.


Does SBA’s outreach   No. SBA’s outreach policies and procedures do not distinguish between rural and
distinguish between   urban communities, and SBA does not tailor its outreach to address the specific
rural and urban       needs of these communities.
communities?          To guide its implementation of outreach activities after a disaster, SBA officials
                      use the 2018 Disaster Assistance Program Standard Operating Procedures, the
                      2019 Disaster Preparedness and Recovery Plan, the SBA Fiscal Year 2022–
                      2026 Strategic Plan, and the 2023 Office of Disaster Recovery and Resilience
                      Marketing and Outreach Plan. As of December 2023, these documents did not
                      yet include guidance on Portable Loan Outreach Centers, virtual outreach, or the
                      “whole-of-SBA” approach, as these initiatives were all relatively new. SBA
                      officials told us they plan to update the 2019 Disaster Preparedness and
                      Recovery Plan in 2024.
                      None of these new outreach approaches or their associated policies and
                      procedures are designed specifically for or targeted to rural communities. SBA
                      officials told us that their overall outreach activities address the needs of all
                      communities, including rural communities, affected by a disaster.
                      SBA’s Fiscal Year 2022–2026 Strategic Plan includes an equity measure to
                      increase the number of outreach activities to underserved communities. SBA’s
                      2022 Equity Action Plan identifies people who live in rural areas as an

Page 11                                                         GAO-24-106755 Small Business Administration Disaster Assistance
                          underserved community and includes actions to reduce barriers and improve
                          access to the Disaster Loan Program for underserved communities. SBA officials
                          agreed that rural communities face unique challenges after disasters, but SBA’s
                          outreach plans do not recognize these challenges or include strategies for
                          addressing them. Developing outreach plans with specific methods to address
                          challenges rural communities face after disasters could help improve their access
                          to SBA’s Disaster Loan Program.


What other efforts does   SBA has begun implementing plans to enhance relationships with stakeholders,
SBA have to improve       train local resource partners, and improve its disaster loan application process.
its Disaster Loan         Increased coordination with stakeholders. The 2023 Office of Disaster
Program?                  Recovery and Resilience Marketing and Outreach Plan states that SBA will
                          partner with mayors who can help facilitate local partnerships to increase SBA’s
                          outreach efforts to survivors. SBA’s Fiscal Year 2022–2026 Strategic Plan also
                          includes a strategy to improve coordination and collaboration with federal, state,
                          and local partners.
                          Training for local partners. The 2023 Office of Disaster Recovery and
                          Resilience Marketing and Outreach Plan includes plans to train resource partners
                          on the range of SBA programs available to business owners, including the
                          Disaster Loan Program. It also includes plans to provide media training for SBA
                          Regional Administrators and District Directors.
                          Improvements to the application process. SBA’s Fiscal Year 2022–2026
                          Strategic Plan says that SBA will leverage technology to expedite disaster
                          application processing. To do this, SBA officials told us they are moving all loan
                          application processes to a single system called the Unified Lending Platform.
                          SBA officials said that the new platform is accessible via the MySBA Loan Portal
                          and was fully implemented as of January 2024.


Conclusions               SBA’s Disaster Loan Program can provide homeowners, renters, businesses,
                          and nonprofits in rural communities with assistance to help them recover after a
                          disaster. The new rural disaster declaration may make it easier for rural
                          communities to access this assistance. While SBA has several new outreach
                          approaches for the Disaster Loan Program, none are specifically targeted to rural
                          communities. As a result, SBA may not be addressing some of the special
                          challenges rural communities face in accessing disaster assistance.


Recommendation for        The SBA Administrator should ensure that the Associate Administrator of the
Executive Action          Office of Disaster Recovery and Resilience distinguishes between rural and
                          urban communities in SBA’s outreach and marketing plan and incorporates
                          actions to mitigate challenges encountered by rural communities in accessing the
                          Disaster Loan Program. (Recommendation 1)


Agency Comments           We provided a draft of this report to SBA for review and comment. In its
                          comments, reproduced in appendix II, SBA agreed with our recommendation.
                          SBA stated that it is in the process of updating its strategy for conducting
                          outreach to survivors of disasters and will include ongoing engagement and
                          trainings specifically focused on rural communities. SBA also provided technical
                          comments, which we incorporated as appropriate.


How GAO Did This          To describe how SBA’s Disaster Loan Program assists communities after a
Study                     disaster, we reviewed legislation, regulations, and SBA documents. We
                          interviewed officials from SBA offices responsible for the Disaster Loan Program,
Page 12                                                          GAO-24-106755 Small Business Administration Disaster Assistance
          including the Office of Disaster Recovery and Resilience and its two Field
          Operations Centers, the Office of Capital Access, and three district offices.
          To compare disaster loan outcomes in rural and urban areas, we obtained data
          from SBA disaster loan applications from disasters declared during fiscal years
          2017 through 2022. 24 We selected this time frame because 2017 had three large
          hurricanes affecting a wide geographic range and because fiscal year 2022 was
          the most recent complete fiscal year at the beginning of our review. We
          geocoded the loan addresses to classify each application as either rural or urban
          using Census Bureau definitions. 25 We analyzed the data to determine the
          percentage of approved loans and other application outcomes from rural and
          urban areas. 26 Official damage estimates from SBA and others were not
          available for all declared disasters or loan applications; therefore, we were
          unable to compare the extent of damage in rural and urban areas with loan
          applications. 27 We assessed the reliability of the application data by reviewing
          relevant documentation, interviewing knowledgeable agency officials, and
          performing electronic testing. We determined these data were sufficiently reliable
          for the purpose of describing the outcomes of the disaster loan applications for
          fiscal years 2017 through 2022.

          To identify challenges rural communities may face after disasters, we conducted
          site visits to three selected areas that experienced declared disasters in fiscal
          years 2021 or 2022 that affected both rural and urban areas (per Census Bureau
          definitions), were geographically diverse, were generally smaller in scale, and
          were generally caused by different incident types. We then selected the primary
          county within the declaration’s disaster area that was mostly rural and had more
          disaster losses than other mostly rural counties within the disaster area.

          Based on these criteria, we conducted visits in person to Graves County,
          Kentucky, and Grand County, Colorado, and we conducted a virtual visit to
          Poinsett County, Arkansas. For more information on the disasters that affected
          these counties, see appendix I. For these sites, we interviewed six state entities,
          including emergency management departments and Small Business
          Development Centers at the state level. We interviewed 12 local or regional
          stakeholders, including Small Business Development Centers, emergency
          managers, and government officials. We also interviewed nonprofit long-term
          recovery organizations and disaster case management organizations. In addition,
          we interviewed SBA officials from headquarters, both Field Operations Centers,
          and three district offices. We also interviewed representatives from four selected
          regional nonprofit organizations that work with rural communities (Center for
          Rural Strategies, Center for Disaster Philanthropy, Catholic Charities-
          Archdiocese of Oklahoma City, and Rural Community Assistance Corporation).
          To inform our questions for these interviews, we conducted a literature review of
          selected studies and reports issued from 2017 through 2022 to identify
          challenges rural areas may face after disasters. We also analyzed SBA disaster
          loan data and Census data for these selected areas to summarize the incidents,
          impacted areas, and SBA disaster loan assistance for the disasters.

          To understand how SBA conducts outreach for the Disaster Loan Program, we
          reviewed SBA’s policies and procedures, including its Fiscal Year 2022–2026
          Strategic Plan, 2022 Equity Action Plan, and its 2023 Outreach and Marketing
          Plan. We analyzed these documents to determine the extent to which SBA has
          policies designed to address challenges faced by rural communities seeking
          disaster assistance. We also reviewed SBA’s direct final rule implementing the
          Disaster Assistance for Rural Communities Act and other documents related to
          the new SBA rural disaster declaration. In addition, we discussed with SBA


Page 13                                          GAO-24-106755 Small Business Administration Disaster Assistance
                     officials how they conduct outreach and address challenges faced by rural
                     communities seeking disaster assistance.

                     We conducted this performance audit from April 2023 to February 2024 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.


List of Addressees   The Honorable Jeanne Shaheen
                     Chair
                     The Honorable Joni Ernst
                     Ranking Member
                     Committee on Small Business and Entrepreneurship
                     United States Senate

                     The Honorable Roger Williams
                     Chair
                     The Honorable Nydia M. Velázquez
                     Ranking Member
                     Committee on Small Business
                     House of Representatives

                     We are sending copies of this report to the appropriate congressional
                     committees, the Administrator of the Small Business Administration, and other
                     interested parties.


GAO Contact          For more information, contact: Daniel Garcia-Diaz, Managing Director, Financial
Information          Markets and Community Investment, GarciaDiazD@gao.gov, (202) 512-8678.
                     Chuck Young, Managing Director, Public Affairs, YoungC1@gao.gov, (202) 512-
                     4800.
                     A. Nicole Clowers, Managing Director, Congressional Relations,
                     ClowersA@gao.gov, (202) 512-4400.
                     Staff Acknowledgments: Lisa Moore (Assistant Director), Rhonda Rose
                     (Analyst-in-Charge), Lauren Capitini, Chelsea Carter, Lorraine Ettaro, Ying Long,
                     Colleen Moffatt Kimer, John Milberg, John Mingus, Marc Molino, Minda Nicolas,
                     Jennifer Schwartz, and Farrah Stone.
                     Connect with GAO on Facebook, Flickr, Twitter, and YouTube. Subscribe to our
                     RSS Feeds or Email Updates. Listen to our Podcasts.
                     Visit GAO on the web at https://www.gao.gov.
                     This work of the United States may include copyrighted material, details at
                     https://www.gao.gov/copyright.




Page 14                                                    GAO-24-106755 Small Business Administration Disaster Assistance
Appendix I: Profiles of   This appendix summarizes the incidents, affected areas, and SBA disaster loan
Selected Disasters and    assistance for the three sites we selected to visit for this report (see figs. 9–11):
SBA Assistance            •   northeast Arkansas, which experienced severe storms and tornadoes;
                          •   southwest Kentucky, which experienced severe storms, flooding, and
                              tornadoes; and
                          •   northern Colorado, which experienced wildfires.

                          Figure 9: Summary of 2021 Severe Storms and Tornadoes in Northeast Arkansas (AR-00120)




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          Figure 10: Summary of 2021 Severe Storms, Flooding, and Tornadoes in Southwest
          Kentucky (KY-00087)




Page 16                                           GAO-24-106755 Small Business Administration Disaster Assistance
          Figure 11: Summary of 2020 Wildfires in Northern Colorado (CO-00130)




Page 17                                            GAO-24-106755 Small Business Administration Disaster Assistance
Appendix II: Comments
from the Small
Business
Administration




Page 18                 GAO-24-106755 Small Business Administration Disaster Assistance
Page 19   GAO-24-106755 Small Business Administration Disaster Assistance
Endnotes
           1Pub. L. No. 117-249, § 2(c), 136 Stat. 2350, 2351 (2022). While the mandate asks GAO to identify

           potential legislative recommendations, we are making one recommendation to SBA, consistent with
           our findings.
           2SBA also offers the Military Reservist Economic Injury Disaster Loan, which does not require a

           disaster declaration. This type of loan is for qualifying small businesses that have suffered or are
           likely to suffer substantial economic injury as a result of a qualifying essential employee who has
           been called up to active service for a period of more than 30 consecutive days. 13 C.F.R. §
           123.501.
           3SBA’s Office of Disaster Recovery and Resilience was formerly known as the Office of Disaster

           Assistance. According to SBA, in addition to being renamed, it will have an expanded focus on
           recovery and resilience through enhanced coordination and a whole-of-agency approach to
           deploying all of SBA’s programs to communities affected by disasters.
           4SBA refers applicants that do not meet minimum qualifying credit and income requirements to the

           Federal Emergency Management Agency’s Individuals and Households Program, which provides
           financial and direct services to eligible individuals and households affected by a disaster. This
           assistance is intended to meet basic needs and supplement disaster recovery efforts.
           5For fiscal years 2017–2022, 49 percent of applications were from disasters that occurred in fiscal

           year 2017, 20 percent were from disasters that occurred in fiscal year 2021, and 12 percent were
           from disasters that occurred in fiscal year 2022. The remainder of applications were from 2018,
           2019, and 2020.
           6More specifically, in rural areas, SBA approved 40.0 percent and declined 39.1 percent of

           accepted applications, 19.3 percent of applications were withdrawn, and 1.6 percent of applications
           were still in process as of June 2023. In urban areas, SBA approved 39.8 percent and declined
           40.2 percent of accepted applications, 18.3 percent of applications were withdrawn, and 1.7
           percent of applications were still in process as of June 2023.
           7SBA calculates approval rates by dividing the total number of approved applications by the sum of

           both approved and declined applications.
           8GAO, Small Business Administration: Disaster Loan Processing Was Timelier, but Planning

           Improvements and Pilot Program Evaluation Needed, GAO-20-168 (Washington, D.C.: Feb. 7,
           2020).
           9GAO, Disaster Recovery: Additional Actions Needed to Identify and Address Potential Recovery

           Barriers, GAO-22-104039 (Washington, D.C.: Dec. 15, 2021).
           10National Low Income Housing Coalition, Housing Needs in Rural America (Washington, D.C.:

           Mar. 31, 2021).
           11GAO-22-104039.

           12GAO-22-104039.

           13M.A. Brennan and Courtney G. Flint, “Uncovering the Hidden Dimensions of Rural Disaster

           Mitigation: Capacity Building Through Community Emergency Response Teams,” Journal of Rural
           Social Sciences, vol. 22, no. 2 (Dec. 31, 2007).
           14Consumer Financial Protection Bureau, Data Spotlight: Challenges in Rural Banking Access (Apr.

           2022).
           15GAO-20-168.


           16Small Business Administration, ODR&R Outreach and Marketing Plan (Mar. 6, 2023). The

           outreach plan is developed by SBA’s Office of Disaster Recovery and Resilience.
           17GAO-20-168.

           18“Significant damage” means uninsured losses of 40 percent or more, calculated consistent with

           13 C.F.R. § 123.3(a)(6)(ii), which must be incurred by any home, small business concern, private
           nonprofit organization, or small agricultural cooperative in the rural area.
           19S. Rep. No. 117-103, at 2 (2022).

           20Pub. L. No. 117-249, § 2, 136 Stat. 2350 (2022) (codified at 15 U.S.C. § 636(b)(16)). See also the

           implementing regulation at 13 C.F.R. § 123.3(a)(6). For purposes of the rural disaster declaration,
           “rural area” is defined as “any county or other political subdivision of a State, the District of
           Columbia, or a territory or possession of the United States that is designated as a rural area by the
           Bureau of the Census.” In addition, the federal government has consistently recognized Indian
           Tribes as distinct, independent political communities with inherent powers of limited sovereignty.

Page 20                                                    GAO-24-106755 Small Business Administration Disaster Assistance
          21Pub. L. No. 117-249, § 2(b) (Dec. 20, 2022).

          2288 Fed. Reg. 24107 (Apr. 19, 2023).

          23Pub. L. No. 117-249, § 2, 136 Stat. 2350, 2350-2351 (2022) (codified at 15 U.S.C. §

          636(b)(16)(C)).
          24SBA provided data from the Disaster Credit Management System, which stores and processes

          disaster loan applications and loans, including loan application decisions and loan disbursements.
          For the period of our data analysis (fiscal years 2017–2022), these loan limits were lower than the
          current limits. Homeowners could apply for up to $200,000 to repair or replace their primary
          residences, and both homeowners and renters could apply for up to $40,000 to replace or repair
          personal property.
          25The Census Bureau delineates urban areas after each decennial census by applying specific

          criteria to the decennial census and other data.
          26Application outcomes, including loan approvals, were calculated using all available fiscal year

          2017–2022 application data except for duplicate applications and applications that could not be
          classified as rural or urban. Application decline or withdrawal reasons were estimated with a
          sample of the available data so that we could sufficiently compare and rank the reasons across
          rural and urban areas.
          27Disasters may be declared without a preliminary damage assessment when the anticipated or

          actual impact is deemed unmanageable by the state or local government without national
          resources (e.g., a category four or five hurricane).




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